Clean Energy: Biomass Should Qualify for Standard

The Biotechnology Industry Organization ("BIO") is pleased to submit responses to question numbers 1,2, 4, 5, and 6 of the Senate Energy and Natural Resources Committee's March 21, 2011 Clean Energy Standard ("CES") White Paper. The following are brief summaries of BIO's responses to these questions.

Question One - What should be the threshold for inclusion in the new program? Whatever threshold is established to determine which utilities are subject to a CES, BIO believes it is vital that small clean energy producers have access and opportunity to generate renewable electricity credits, both for clean energy provided to the grid and for clean energy generated and utilized on site.

Question Two - What resources should qualify as "clean energy"? BIO believes that power derived from biomass should qualify as "clean energy," and therefore qualify to generate renewable energy credits under a federal clean energy standard mandate. Biomass power provisions under a CES should be consistent and complementary to other federal programs - particularly the federal Renewable Fuel Standard ("RFS"), 2008 Farm Bill and Biomass Crop Assistance Program ("BCAP") - in terms of definitions, eligibility, and performance characteristics, of biomass feedstocks. A federal CES should also be designed to encourage and incentivize industrial energy efficiency including industrial biotechnologies as well as the development and use of "bioenergy buffers."

Question Four - How will a CES affect the deployment of specific technologies? If implemented appropriately, a federal CES could support and accelerate the deployment of highly desirable and efficient integrated biorefineries, and hasten commercialization of a new generation of advanced biofuels and renewable chemicals.

Question Five - How should Alternative Compliance Payments, regional costs, and consumer protection be addressed? BIO and its Members support the development of a federal CES that provides opportunity for flexibility in compliance and which also provides incentive for investment in the development and commercialization of "clean energy" sources, including biomass power.

Question Six - Are there policies that should be considered to complement a CES? A federal CES mandate should complement and not interfere with the existing federal policies, including the RFS and BCAP programs.