February 4, 2009 TECHNICAL SUPPORT DOCUMENT FOR BIOLOGIC PROCESS SOURCES EXCLUDED FROM THIS RULE Office of Air and Radiation U.S. Environmental Protection Agency February 4, 2009 ------- CONTENTS Introduction 4 Biological Process Excluded Sources Summary 4 Total Emissions 4 Review of existing relevant reporting programs/ methodologies 4 Monitoring Methods 4 Threshold Analysis 5 Enteric Fermentation 6 Monitoring Emissions 6 Information to be Collected 6 Uncertainty 6 Reporters and Thresholds 7 Existing Federal Data Collection Systems 9 References 9 Rice Cultivation 10 Monitoring Emissions 10 Information to be Collected 10 Uncertainty 11 Reporters and Thresholds 11 Existing Federal Collection Systems 12 References 12 Field Burning of Agricultural Residues 13 Monitoring Emissions 13 Information to be Collected 13 Uncertainty 13 Reporters and Thresholds 13 Existing Federal Data Collection Systems 14 References 14 Composting 16 Monitoring Emissions 16 Information to be Collected 16 Uncertainty 16 Reporters and Thresholds 17 Existing Federal Data Collection Systems 17 References 17 Agricultural Soil Carbon Sequestration 19 Monitoring 19 Information to be Collected 20 Uncertainty 20 Reporters and Thresholds 20 Existing Federal Data Collection Systems 21 References 22 Agricultural Soil NiO Emissions (including fertilizer use) 23 Monitoring 23 Information to be Collected 23 Uncertainty 24 ------- Reporters and Thresholds 24 Existing Federal Data Collection Systems 25 Source Category 26 Monitoring Emissions 26 Information to be Collected 26 Uncertainty 26 Identification of Reporters 26 Existing Federal Data Collection Systems 27 References 27 Forest Land NiO and CEL; (including fertilizer use and forest fires) 28 Monitoring Emissions 28 Information to be Collected 29 Uncertainties 29 Reporters and Thresholds 29 Existing Federal Data Collection Systems 31 References 31 Other Land Use, Land-Use Change, and Forestry C Emissions and Sinks 33 Monitoring 33 Information to be Collected 34 Uncertainties 34 Reporters and Thresholds 34 Existing Federal Data Collection Systems 35 References 35 ------- Introduction The proposed rule does not require reporting of GHG emissions from enteric fermentation, rice cultivation, field burning of agricultural residues, composting, agricultural soils (including C sequestration and N2O emissions), settlements (including N2O emissions), forestland (including CH4 and N2O emissions) or other land uses and land-use changes, such as emissions associated with deforestation, and carbon storage in living biomass or harvested wood products. The challenges to including these source categories in the rule are that available methods to estimate facility-level emissions for these sources yield uncertain results, and that these sources are characterized by a large number of small emitters. In light of these challenges, we have determined that it is impractical to require entity-level reporting of emissions from these sources in the proposed rule for the reasons explained below. For more information on these sources and sinks of greenhouse gases, please see page 6 of this TSD for enteric fermentation, page 10 for rice cultivation, page 13 for field burning of agricultural residues, page 16 for composting, page 19 for agricultural C sequestration, page 23 for agricultural N2O emissions (including fertilizer use), page 26 for settlement N2O emissions (including fertilizer use), page 28 for forestland CFLi and N2O emissions (including fires and fertilizer use), and page 33 for other land use, and land-use change, and forestry emissions and sinks. Biological Process Excluded Sources Summary Total Emissions EPA reports on the greenhouse gas emissions and sinks associated with the biological process sources excluded from this rule in the Inventory of U.S. Greenhouse Gas Emissions and Sinks. In the agriculture sector, the U.S. GHG Inventory estimates that agricultural soil management contributed emissions of 265 MMTCC^e and enteric fermentation contributed emissions of 126 MMTCO26 in 2006. Rice cultivation, agricultural field burning, and composting contributed emissions of 5.9, 1.2, and 3.3 MMTCC^e, respectively, in 2006. Total carbon fluxes for U.S. forestlands and other land uses and land-use changes were also reported in the U.S. GHG Inventory, rather than specific emissions from deforestation. Land use, land-use change, and forestry activities in 2006 resulted in a net C sequestration of 883.7 MMTCC^e. Review of existing relevant reporting programs/ methodologies Several protocols and programs contain methods for estimating greenhouse gases from these sources, including the 2006 IPCC GL and the U.S. GHG Inventory. These methods are used to estimate national-level emissions and sinks. Monitoring Methods For these sources, there are no direct greenhouse gas emission measurement methods available except for research methods that are prohibitively expensive and require sophisticated equipment. Instead, limited modeling-based methods have been developed for voluntary GHG ------- reporting protocols, which use general emission factors, or large-scale models that are used for comprehensive national-level emissions estimates. To calculate the emissions resulting from these sources at a reporting entity-level using emission factor or carbon stock change approaches, it would be necessary for landowners to report on a number of parameters such as management practices and a variety of data inputs. While some input data can be collected with reasonable certainty, the emissions estimates would have a high degree of uncertainty because the factors available for individual reporters do not reflect the variety of conditions that need to be considered for accurate estimates. At the scale of individual reporters, these estimates can be complex and costly to generate. Without accurate facility-level emissions factors and the ability to accurately measure all facility- level calculation variables, estimates of national-level emissions from these sources are more suitably calculated on a broad regional basis using models and data available from national databases. While a systematic measurement program of these sources could improve understanding of the environmental factors and management practices that influence emissions, this type of measurement program would be very difficult to implement through a landowner- based reporting program due to the difficulty and expense in establishing and maintaining rigorous measurements over time. Threshold Analysis Despite these issues, threshold analyses were conducted for several of these sources as part of their consideration for inclusion in this rule. The resulting analyses showed that for most of these sources no facilities would meet thresholds consistent with those proposed in this rule. ------- Enteric Fermentation Ruminant agriculture (cattle -beef and dairy, sheep, goats and buffalo) is the primary source of enteric CH4. Since feed quality and quantity affects enteric CH4 emissions, approaches for estimating QrU emissions focus on gross energy intake from feed and CH4 yield (portion of gross energy that is converted to CFL^n the rumen). For example, dairy cows in California on a total mixed ration (a blend of all feedstuffs provided to dairy cows) diet emit between 100 to 160 kg CHVcow/yr (2,100 to 3,360 kg CO2e/cow/yr). At these emission rates, only the largest facilities (over 3,000-5,000 cows) would have to report enteric emissions under a mandatory reporting threshold of 10,000 mtCO2e/yr. Monitoring Emissions In general, there are two approaches for monitoring enteric CH4 emissions: direct measurement and modeling. Since direct measurement using tracers is prohibitively expensive and overly burdensome for reporters, modeling enteric emissions with emission factors is the only reasonable alternative. The 2006 IPCC Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories Volume 4, Chapter 10, Equation 10.21 provides the following emission factor equations most suitable for monitoring: EFEntenc_cH4 = [GE x Ym ] *365 / [55.65 MJ/kg CHJ Where: EFEnteric-cH4 = emission factor (kg CHVhead/year) GE = gross energy intake (MJ/head/day) Ym = CFLt conversion rate which is the fraction of gross energy in feed converted to CFLt (percent) Most livestock producers have a good understanding of their diet regimes. However, they would need to calculate the gross energy intake based on the amount and type of feed. Information to be Collected The following information would need to be collected to monitor emissions using the IPCC methodology: number of animals by livestock type on farm (track seasonal changes), gross energy intake (derived from diet) by livestock type, and estimate of methane conversion rate (could be estimated based on feed efficiency, but requires chamber measurements to estimate accurately). Uncertainty In addition to the uncertainty in estimating gross energy intake, a large source of uncertainty in estimating enteric emissions is due to the large variability in the CFLjconversion rates (Ym). Tables 10.12 and 10.13 from Volume 4, Chapter 10 of 2006 IPCC Guidelines for National Greenhouse Gas Inventories provide ranges of Ym based on livestock category. For example, feedlot cattle have Ym range of 3 ±1%, indicating that using the 3% value can result in overestimation by 50% or an underestimation up to 33%. Research by Benchaar et al (1998) has shown an even greater range of Ym values from less than 3% to ------- greater than 10%. Although the use of feed additives (e.g., ionophores, probiotics, propionate precursors, and growth hormones), which can improve feed efficiency by suppressing methanogenesis, is becoming more widespread, quantification of their effectiveness in reducing enteric emissions is not well understood. Reporters and Thresholds Individual livestock operations would be the reporters as they have information on their livestock numbers and general feeding regimes. According to the 2002 NASS Agricultural Census there are over 1 million farms with cattle and approximately 2,450 of these farms have over 2,500 cattle. Tables 1 and 2 present the number of farms by size class for beef and dairy cattle, respectively. Table 1. Beef Farm Sizes Beef Farm Size (2002) Less than 1,000 head 1,000-2,499 2,500-4,999 head 5,000 - 9,999 head Greater than 10,000 head Number of Farms 918,184 5,728 1553 655 250 % of Total Population 70% 8.6% 6.0% 8.5% 6.5% Note: Given the lack of data on farms larger than 10,000 head and the observed decrease in number of beef farms with increasing size, we estimate that there are less than 96 farms with greater than 20,000 head of beef cattle. There are a few very large beef feedlots (e.g., A ranch in California has over 100,000 head of cattle). Table 2. Large Dairy Farms Size Distribution Dairy Farm Size (2002) 1,000-1,999 cows 2,000-2,999 cows 3,000-3,999 cows 4,000-4,999 cows 5,000-9,999 cows 10,000 or more Number of Farms 795 249 115 48 39 8 % of Total Population 13% 6.8% 4.4% 2.4% 3.2% 1.1% Table 3 presents the size thresholds for beef and dairy livestock operations to exceed the 3 reporting thresholds. Given, the large amount of uncertainty in estimating enteric emissions, two sets of calculations are provided with average and high end emission factors. The average emission factors were derived dividing total enteric emissions (Table A-157 EPA 2008) by population (Table A-159 EPA 2008). The high factors were estimated at 50% greater than the average emission factors. ------- Table 3. Threshold Populations for Beef and Dairy Farms BEEF FARM: AVERAGE (Emission factor: 1,016 kg CO2e/head/yr) BEEF FARM: HIGH (Average plus 50%: 1,524 kg CO2e/head/yr) DAIRY FARM (Average emission factor: 2,305kg CO2e/head/yr) DAIRY FARM (Average plus 50%: 3,458 kg CO2e/head/yr) Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Total number of head to meet threshold 984 656 434 289 9,843 6,562 4,338 2,892 24,606 16,404 10,846 7,230 98,425 65,617 43,384 28,918 Note: Estimates presented have not been adjusted to account for significant figures. Table 4 presents the maximum number of potential reporters by threshold level. The number of reporters was estimated based on the number of livestock needed to exceed each threshold level (Table 3) and a rough estimate of the number of livestock facilities that have the corresponding number of cattle (see note on interpolation assumptions within each size category in Tables 1 and 2. Table 4. Maximum Number of Beef and Dairy Farms (reporters) that Exceed Threshold Levels BEEF FARM: AVERAGE (Emission factor: 1,016 kg CO2e/head/yr) BEEF FARM: HIGH (Average plus 50%: 1,524 kg CO2e/head/yr) DAIRY FARM (Average emission factor: 2,305kg CO2e/head/yr) DAIRY FARM (Average plus 50%: 3, 45 8 kg CO2e/head/yr) Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Maximum number of farms to exceed threshold 8,186* 197,410 3129 5,175 25 0+ 460 65 222 <96 150 8 17 <13 21 <8 <8 Note: Estimates assumed the following inter-censal distribution of farms within farm size ranges with 50%, 30%, 15% and 5% in each of the quartiles. For example, there are 3,000 beef farms with 2,000 to 4,999 cattle. We assume 1,500 have 2,000 to 2,750 head, 900 have 2,750 to 3,500 head, 450 have 3,500 to 4,250 head, and 150 have 4,250 to 4,999 head. * is the number of farms with 1,000 or more cattle, thus is a conservative estimate of maximum number of farms that could exceed the 1,000 mtCO2e threshold). + is the number of farms with 10,000 or more head, thus is a conservative estimate for the number of farms with 9,843 or more head. ------- Existing Federal Data Collection Systems There are currently no federal data collection systems that collect the information required to estimate these emissions at the entity-level. However, with the EPA 2005 Air Quality Compliance Agreement, animal feeding operations will be required to report any qualifying releases of ammonia (NH3), hydrogen sulfide (H2S) and volatile organic compounds (VOCs: CH/tis a VOC, but this agreement includes non- methane VOCs) as required by section 103 of CERCLA and section 304 of EPCRA. However, since the content and mechanisms of these reporting requirements have not been set, it is difficult to gauge how the data collection systems could be used to report enteric emissions of CH4. References Benchaar, C., J. Rivest, C. Pomar, and J. Chiquette, Prediction of methane production from dairy cows using existing mechanistic models and regression equations, Journal of Animal Science, 76, 617-627, 1998. EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. IPCC (2007) Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories, Intergovernmental Panel on Climate Change. ------- Rice Cultivation Rice cultivation can produce QrU through the biological reduction of CO2 or organic carbon under anaerobic conditions in flooded rice fields, and N2O through the processes of nitrification (microbial oxidation of ammonium) and denitrification (microbial reduction of nitrate) [Note: N2O is discussed under the Agricultural soils source category]. Emission rates of CF^are a function of water management practice (flooding and draining), soil type (texture, organic carbon content, pH, and bulk density), climate (temperature and precipitation), rice cultivar, and other cultivation practices (e.g., fertilizers, organic amendments, tillage, herbicide use). Methane emissions from rice cultivation in the United States are highly variable, with emissions ranging from 22 to 1,490 kg CHVhectare/season, and double cropped rice systems yielding higher emissions (EPA 2008 Chapter 6.3). Monitoring Emissions There are three general approaches for monitoring CH4 emissions from rice cultivation: direct measurement (using automated flux chambers and/or eddy correlation techniques), use of emission factors, and process modeling. Direct measurement is prohibitively expensive, over burdensome, and not suitable for producer reporting. Use of emissions factors is difficult unless there are a sufficient number of factors to capture the range in management practices and local environmental conditions. Use of process models (e.g., DNDC model) could be considered but requires systematic validation coupled with statistical modeling to quantify accuracy and precision of model estimates. Other approaches include using simple equations that would require measurement of soil conditions (e.g., soil carbon content, texture) and tracking of management activities (e.g. number of days flooded) for estimating CFU emissions (see Chapter 9, Willey and Chameides 2007). The 2006IPCC Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories, Volume 4, Equation 4.41 provides the following emission factor equations: EFnce_cH4 (kg/yr) = Zi Zj Zk (EFljk * Aljk ) Where: EFljk = a seasonally integrated emission factor for i,j, and k conditions, in kg CFiyha Aljk = annual harvested area for i,j, and k conditions, in ha/yr i, j, and k = represent different ecosystems, water management regimes, and other conditions under which CFi4 emissions from rice may vary (e.g. addition of organic amendments). The i, j, and k indices are used to adjust the EF based on a scaling factor for water management regime, organic amendments, and soil type. Information to be Collected The following information would need to be collected to monitor emissions using the IPCC methodology: water management practices (continuous flooding vs. intermittent drainage, number of drain events), type and amount of organic amendments, number of rice crops grown annually, and soil type. 10 ------- Uncertainty The uncertainties in the scaling factors, and hence emissions, is quite high, with uncertainty ranges more than double the default values (source 2006IPCC Good Practice Guidance and Uncertainty Management in National Greenhouse Gas Inventories, Volume 4, Table 4.22). With uncertainties greater than 100%, current emission factor approaches do not provide emission estimates suitable for mandatory reporting. Approaches for reducing uncertainties include use of statistical modeling and biogeochemical process modeling. Reporters and Thresholds There are approximately 485,000 hectares of rice grown on over 8,000 rice farms in the United States (USDA 2006, 2002). Table 1 presents the distribution of farms and harvested acreage of rice. Assuming the EPA average per hectare emission factors of 210 kg CHVhectare/season (1,785 kg CO2e/acre) and 780 kg CHVhectare/season (6,632 kg CO2e/acre) for single and double (ratoon) cropped rice (EPA 2008), respectively, Table 2 presents the size of harvested acreage required to meet the reporting thresholds of 1,000 mtCO2e, 10,000 mtCO2e, 25,000 mtCO2e, and 100,000 mtCO2e levels. Table 1. Rice Farm Size Distribution. Harvested Rice Farm Size (1997) - Source U.S. Census of Agriculture 1-99 acres 100 -249 acres 250 - 499 acres 500 - 999 acres 1,000 or more acres Number of Farms 1,747 2,885 2,812 1,433 414 Table 2. Acreage requirements to exceed reporting thresholds. Single Rice with Emission factor: 1,785 kg CO2e/acre Ratoon Rice with Emission Factor 6,632 kg CO2e/acre Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Total number of acres to meet threshold 560 151 5,602 1,508 14,006 3,770 56,022 15,078 In 2005, total ratoon rice acreage was 53,144 acres. Florida, Louisiana and Texas were the only states that had ratoon rice with total harvested acres greater than 1,508 acres. However, only Texas had farms (64) that harvested more than 500 acres. Given the total area of ratoon rice in Texas was 21,963 acres, it is likely that only a few may harvest sufficient areas to trigger the 10,000 mtCO2e and 25,000 mtCO2e thresholds. Given the high acreage requirements for single rice, it is also unlikely that there are many farms that reach the threshold levels. 11 ------- Existing Federal Collection Systems There are no current systems that collect information on water management, organic amendments, rice cultivars, and soil property information. References EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. USD A, 2002, NASS Agricultural Census, http://www.agcensus.usda.gov/Publications/2002/index.asp USDA, 2006 USDA Crop Production Summary, http://usda.mannlib.Cornell.edu/MannUsda/viewDocumentInfo.do?documentID=1046 Willey, Z. and Chameides, B, 2007, Harnessing Farms and Forests in the Low-Carbon Economy: How to Create, Measure and Verify Greenhouse Gas Offsets, Duke University Press, Durham and London. 12 ------- Field Burning of Agricultural Residues Agricultural field crop residues include stalks and stubble or stems, leaves, and seed pods. Farmers often choose to remove crop residue from their fields by directly burning the material. However, open field burning of residue results in a complex mix of aerosols and GHG emissions to the atmosphere that include PM, CFLt, CO, NOX, and N2O (Guoliang et al. 2007; Gupta et al. 2004; and others). Monitoring Emissions Techniques for calculating emissions from residue burning on field crops (including rice, wheat, sugarcane, barley, corn, soybeans, and peanuts) are discussed in EPA 2007, and are based on the Revised 1996IPCC Guidelines. Emissions are calculated using a series of step calculations and crop-specific statistics. There is no direct measurement technique suitable for capturing emissions from this disperse source category. There are, however, hybrid-type approaches that combine satellite-derived data with ground-report databases, such as SMARTFIRE (http:www. getbluesky.org/smartfire). Information to be Collected Specific data needed for determining emissions by crop include annual crop production (Ibs), residue/crop ratio, proportion of crop produced in fields where residue is to be burned (%), dry matter content of the residue (%), crop burn efficiency (%), crop combustion efficiency (%), and the carbon/nitrogen content of the residue to be burned (Ibs of C and N/ Ibs of dry matter). Uncertainty Emission estimation techniques are subject to a large amount of uncertainty (EPA 1999) and would require extensive effort on the part of farmers to consistently record the needed crop statistics. Emission ratios also vary significantly between the flaming and smoldering phases of a fire. CO2 and N2O are mainly emitted during the flaming stage, while CFLt is mainly emitted during the smoldering stage. The relative importance of these two stages will vary between fires in different ecosystems and under different climatic conditions. Since simple emission factors are not available without direct monitoring of emission during burning, growers will be unable to estimate emissions from burning of agricultural residue. Reporters and Thresholds Reporters would be the entity that controls how crops are grown or grassland is managed on the land (e.g. lessee for leased lands). In 2007, there were 2.08 million farms in the United States with a total land in farms of 930.9 million acres with an average farm size of 449 acres (USDA Agricultural Statistics Board 2008). In 2002, there were 14,644 farms that harvested over 5,000 acres (USDA 2002 Agricultural census, Volume 1, Table 9). Figure 1 provides the size class distribution of farm. For demonstration purposes, we calculated the acreage requirements for burning of corn residues to meet the reporting thresholds under consideration. We assumed an average of 75 Ibs of corn residue per bushel production of corn (source from biomass energy study in Wyoming, http://www.wyomingbusiness.org/pdf/energy/Biomass_CropResidue.pdf). With averaged corn yields of 140 bushels per acre, we estimate average corn residue of 10,500 Ibs/acre. Based on greenhouse gas emission ratios and crop residue characteristics from Tables 6-23 and 6-24 in EPA 2008, burning corn 13 ------- residue produces a total of 324 kg CO2e/acre (78 kg CO2e/acre from nitrous oxide and 246 kg CO2e/acre from methane). EPA (2008) estimates that approximately 3% of crop residues are burned each year (excluding rice where a much higher percentage of residue is burned annually). Ditribution of US Farm Sizes Source: 2002 USDA Agricultural Census •s * 200000 - 179346| 1 1 i~O [ 1 • All Farms • Farms with Harvested Croplands CO ro P PI R r • | o ^ 1 CO 0> Jg | 1 CM i- |5i O n-i istl l oH ""*! 1 1 1 fl 1 ft 1 fS CM ^ SI CD ^| 1 S|l 1 a to 9 1 0 to 50 to 70 to 1 00 to 1 40 to 1 80 to 220 to 260 to 500 to 1 , 000 2, 000 5,000 acres 49 acres 69 acres 99 acres 139 179 219 259 499 999 to 1,999 to 4,999 acres or acres acres acres acres acres acres acres acres more Figure 1. Size class distribution of United States farms based on acreage of cultivated lands [Note: Data are presented for all farms and those farms that have harvested cropland.] Table 1. Acreage requirements (corn example) to exceed reporting thresholds. Corn Residue Example: 324 kg CO2e/acre Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Total number of acres to meet threshold 3,086 30,864 77,160 308,642 Existing Federal Data Collection Systems There are no existing federal collection systems that collect the information needed to estimate greenhouse gas emissions from agricultural residue burning at the entity-level. References Andrews, SS, 2006. Crop residue removal for biomass energy production: Effects on soils and recommendations. United States Department of Agriculture (USDA), Natural Resource Conservation Service, White paper, 25 pp. 14 ------- EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. Guoliang et al., 2008. Investigation on emission factors of particulate matter and gaseous pollutants from crop residue burning. Journal of Environmental Sciences (20) 50-55. Gupta et al., 2004. Residue burning in rice-wheat cropping system: Causes and implications. Current Science (87) 1713-1717. Pathak, H and R Wassmann, 2007. Introducing greenhouse gas mitigation as a development objective in rice-based agriculture: I. Generation of technical coefficients. Agricultural Systems (94) 807-825 U.S. Environmental Protection Agency (EPA), Office of Research and Development. Emissions of organic air toxics from open burning, EPA-600/R-02-076, 62 pp. U.S. Environmental Protection Agency (EPA), Emission Inventory Improvement Program (EIIP) Volume VIII, 1999. Methods for estimating greenhouse gas emission from burning of agricultural crop wastes. Chapter 11 - Agricultural crop wastes, 25 pp. Wang, WJ and RC Dalai, 2006. Carbon inventory for a cereal cropping system under contrasting tillage, nitrogen fertilisation and stubble management practices. Soil & Tillage Research (91) 68-74. 15 ------- Composting Both N2O and CH^ can be emitted during the composting process. While CH4 is produced only under anaerobic conditions, the compost pile itself tends to be heterogeneous, such that N2O is produced in aerobic sections of the compost and QrU is produced in anaerobic sections of compost that are created due to excessive moisture or inadequate mixing. It is estimated that the CH4 emissions total <1% to a few percent of the C present in the waste material, while N2O emissions total 0.5% to 5% of the initial N present in the waste material (EPA 2008). Nitrous oxide emissions from compost generally decrease over time, unless the organic material is composed at least partially of manure (He et al. 2000, Morand et al. 2005). The mass of material composted has jumped nearly 400% between 1990 and 2006, due to steady growth in population as well as state and local regulations discouraging landfilling of yard trimmings, and includes primarily yard trimmings (grass, leaves, and tree and brush trimmings) and food scraps from residences and commercial establishments (such as grocery stores, restaurants, and school and factory cafeterias) (EPA 2008). Monitoring Emissions Methods for measuring N2O and QrU emissions from compost usually involve closed compost systems (Morand et al. 2005) or equipment such as dynamic chambers (Osada and Fukumoto 2001). Development of decay curves for typical compost materials and compost operation sizes will be useful for ongoing measurement and monitoring of emissions from compost. To apply the IPCC default methodology for estimating N2O and CH4 emissions from composting operations, the mass of wet waste composted (M) is multiplied by an emission factor (EFi) (typically 4 g t per kg of wet organic waste and 0.3 g N2O per kg of wet organic waste). The relevant equation is: Ei = M x EFi. (EPA 2008) Information to be Collected The following information would need to be collected to monitor emissions using the IPCC methodology: mass of material composted, and associated emission factors. Uncertainty In 2006, compost was included in the U.S. GHG Inventory for the first time. That report estimated annual emissions of N2O and CFLt from composting operations, not including backyard composting operations, at 3.3 MMTCO2e, with a quantitative estimate of uncertainty (with 95% confidence) between 1.7 and 5.0 MMTCO2e annually (EPA 2008). While uncertainty is held constant at +/-50% in the IPCC Tier 1 methodology, additional uncertainty in N2O and CFLt emissions from composting can be attributed to the scale of the operation (Fukumoto et al. 2003), the turning schedule of the compost, and the composition of the inputs. 16 ------- Reporters and Thresholds The U.S. Economic Census estimates that there are 17 establishments that produce compost as fertilizer in the United States, with annual shipments of roughly $57.0 million. Clearly most composting operations are small-scale endeavors, conducted on farms or in backyards nationwide. Using the equation above and assuming a global warming potential (GWP) of 21 for CH4, in order to meet the 1,000 mtCO2e/ year emission threshold for 10,000 mtCO2e/ year emission threshold for CUt alone, a composting operation would need to compost 11,905 tons of waste annually (Table 1). To meet the 10,000 mtCO2e/ year, 25,000 mtCO2e/ year and 100,000 mtCO2e/ year thresholds for CH4 emissions, an entity would need to compost 119,048 tons, 297,619 tons, and 1.2 million tons of wet waste annually, respectively (Table 1). Assuming a GWP of 310 for N2O, the mass of waste composted would be somewhat lower in order to meet the reporting threshold based on N2O emissions alone. Specifically, a facility would need to compost 10,753 tons, 107,527 tons, 268,817 tons, and 1.08 million tons of wet waste annually to meet the threshold reporting targets based on N2O (Table 1). Practically, a compost operation would emit both gases simultaneously, thus reducing the volume of waste composted to meet the same emission threshold. Assuming the same emission factors, the waste needed to meet the threshold for reporting would be 5,650 tons for the 1,000 mtCO2e threshold, 56,497 tons for the 10,000 mtCO2e threshold, 141,243 tons for the 25,000 mtCO2e threshold and 564,972 tons for the 100,000 mtCO2e threshold (Table 1). Table 1. Mass of wet organic waste (in tons) needed to meet threshold reporting targets for annual CH4and N2O emissions, separately and in combination, from composting operations. N2O CH4 combined 10,753 11,905 5,650 107,527 119,048 56,497 268,817 297,619 141,243 1,075,269 1,190,476 564,972 N2O CH4 combined 10,753 11,905 5,650 107,527 119,048 56,497 268,817 297,619 141,243 1,075,269 1,190,476 564,972 Existing Federal Data Collection Systems There are no current systems that collect the data needed for entity reporting, though existing systems for managing waste could be adapted to track the amount of organic waste directed to compost operations. References EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: R-08-005. 1990-2006 (April 2008) USEPA #430- Fukumoto Y, Osada T, Hanajima D, Haga K. 2003. Patterns and quantities of NH3, N2O and CH4 emissions during swine manure composting without forced aeration—effect of compost pile scale. Bioresource Technology 89: 109-114. 17 ------- He Y, InamoribY, Mizuochib M, Kongb H, Imawib N, Suna T. 2000. Measurements of N2O and CH4 from the aerated composting of food waste. The Science of the Total Environment 254: 65-74. Morand P, Peres G, Robin P, Yulipriyanto H, Baron S. 2005. Gaseous emissions from composting bark/manure mixtures. Compost Science and Utilization 13: 14-26. Osada T, Fukumoto Y. 2001. Development of a new dynamic chamber system for measuring harmful gas emissions from composting livestock waste. Water Science and Technology 44: 79-86. 18 ------- Agricultural Soil Carbon Sequestration The top one meter of soil is estimated to have 1,502 billion metric tons of soil organic carbon (Schlesinger, 1997, Jobbagy and Jackson 2000), which is approximately 3 times the size of other terrestrial carbon pools (i.e. biomass and dead organic matter). The top one meter of agricultural soils contains approximately 170 billion metric tons of C (Cole et al, 1996). Soil organic carbon (SOC) pools in agricultural soils are highly dynamic as agricultural processes, such as tillage, change the temperature and moisture regimes in soils and rate, quantity and quality of organic inputs. Thus, rates of SOC sequestration and oxidation (release) vary based on SOC pools, soil type, climate, and agricultural management. Monitoring In general, there are three approaches for monitoring changes in SOC from cultivation of agricultural soils: direct measurement, use of activity-based emission factors, and process modeling. Accuracy of direct measurement of SOC pools in agricultural soils vary with the scale of the measurements from ±0.1 MT/hectare at plot scale and ±1 MT/hectare at farm scale (Kimble et al. 2002). However, the cost of direct measurements can be expensive and overly burdensome for mandatory reporting due to the sampling design requirements to meet desired accuracy (e.g., sample depth, # of soil samples, frequency of sampling) and costs of analyzing soil samples (Willey and Chameides 2007). Performance or activity- based approaches (e.g. CCX, IPCC) use regionally-based emission factor approaches for monitoring SOC changes of time. While these approaches may not capture the influence of different soils or climate conditions within the region, they are thought to capture average regional changes in SOC, as opposed to farm-specific SOC changes. Process models (e.g., CENTURY, EPIC, DNDC) simulate the biogeochemical processes that drive crop growth and SOC dynamics. An advantage of process models is that they can be used for full GHG accounting to look at the relationship between SOC sequestration and subsequent emissions of N2O (see Li et al. 2005 and Six et al. 2004). Process models have been used to generate data for web-based modeling tools (e.g., COMET-VR and C-LOCK) to enable growers to estimate changes in SOC based on local soils and climate and their specific management practices. The IPCC methodology accounts for net C emissions (sinks and sources) for three categories of agricultural soils: (i) changes in C stocks of mineral soils due to cropland management practices; (ii)changes in C stocks from organic soils that are drained; and (iii) liming of agricultural soils. For mineral soils, changes in soil carbon stocks are estimated based on reference carbon stocks and stock change factors related to land use (long-term cultivated, paddy rice and set aside), tillage practices (full till, reduced till or no-till) and organic matter inputs (low, medium, high without manure, and high with manure). For drained organic soils, the IPCC Tier 1 method for estimating changes in soil carbon content: ACorgamc (t C/yr) = EC (A*EF)C Where: EF = emission factor for climate region c, in tC/ha/yr A = land area of drained organic soils in climate region c, in ha 19 ------- Information to be Collected The following information is required to apply the IPCC methods for estimating change in soil organic carbon stocks: crop type (characterized by amount of crop residue), local climate, soil type, tillage practices and use of organic amendments. Uncertainty A range of techniques are used to estimate uncertainty in process model estimates, including standard error propagation and simple empirical models, to more computationally-intensive Monte Carlo numerical approaches (Ogle et al. 2007). The IPCC approach for estimating changes in SOC stocks uses a set of stock change factors that are adjusted based on climate, soil type, tillage practices, and organic carbon inputs. IPCC estimates that errors in using their stock change factor approach for SOC sequestration over a 20-year period ranges from ±4% (for low C input systems) to ±90% (for high C input systems, like rice residue incorporation). Since process models offer the best opportunity for reducing uncertainty in SOC sequestration, rigorous uncertainty analyses, such as the current efforts to improve the uncertainty estimator in COMET-VR, are needed. In summary, the required data collection for accurate reporting and subsequent measurement of changes in organic carbon stocks in agricultural soils is subject to large uncertainties and burdensome calculations, whether it is for reporting loss or sequestration of soil carbon. Reporters and Thresholds In 2007, there were 2.08 million farms in the United States with a total land in farms of 930.9 million acres with an average farm size of 449 acres (USDA Agricultural Statistics Board 2008). In 2002, there were 14,644 farms that harvested over 5,000 acres (USDA Agricultural census, Volume 1, Table 9). Rates of carbon loss or gain in agricultural soils are highly variable and can be difficult to estimate. Using IPCC stock change factors for cool temperate dry region emissions of carbon, and agricultural lands with low biomass inputs and full conventional tillage, average emission rates can be as high as 0.93 mtCO2e/acre/yr. Table 1 presents the acreage required to meet the reporting thresholds at this emission rate. Table 1. Example acreage requirement for reporting thresholds Mineral Soils - Cold Temperate Region, low inputs, full tillage Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Total number of acres to meet threshold 1,075 10,753 26,881 107,527 Note: Since the uncertainties (see discussion below) are high, this is meant to be an illustrative example. To put SOC sequestration in agricultural soils in perspective with possible reporting thresholds for emissions, assuming the upper range of SOC sequestration in the Kimble et al. (2002) summary estimates, a farmer would need to switch 12,200 acres from plow-till to no-till or shift 5,900 acres to Conservation Reserve Program (CRP) to sequester 10,000 mtCO2e/yr. 20 ------- Drainage of organics soils can lead to high rates of soil carbon loss. On average from 1993 to 2006 drainage of organic soils in the United States released 27.7 MMTCO2e/yr (EPA 2008). Approximately 640,000 hectare of organic soils were drained during this time period. Thus the average carbon flux was 43,281 kg CO2e/ha. Table 2 present a summary analysis of acreage required to meet candidate reporting thresholds for drainage of organic soils. Table 2. Acreage requirements for drainage of organic soils to exceed reporting thresholds. Organic Soils - Avg emission rate 43,281 kg CO2e/ha Threshold Levels (mtCO2e) 1,000 10,000 25,000 100,000 Total number of acres to meet threshold 57 571 1,427 5,707 Figure 1 present the size distribution of U.S. farms. Approximately 7% of all farms have over 1,000 acres. The total area of cropland on organics soils is 720,000 ha which represents less than 0.5% of the total cropland area. Assuming an even distribution of farm size on mineral and organic soils, we expect approximately 0.035% of all farms are cultivating more than 1,000 acres of organic soils. Thus, while the emission rates can be high for drained organic soils, the likely number of reporters would be small. Ditribution of US Farm Sizes Source: 2002 USDA Agricultural Census 600000 1 500000 DAI I Farms • Farms with Harvested Croplands 1to9 10 to 50 to 70 to acres 49 acres 69 acres 99 acres Figure 2. Size class distribution of US farms based on acreage of cultivated lands. Data are presented for all farms and those farms that have harvested cropland. Existing Federal Data Collection Systems There are no current systems that collect all the necessary data and information for accurate reporting of changes in organic carbon stocks in agricultural soils. 21 ------- References Cole, V., C. Cerri, K. Minami, A. Mosier, N. Rosenberg, D. Sauerbeck, J. Dumanski, J. Duxbury, J. Freney, R. Gupta, O. Heinemeyer, T., Kolchugina, J. Lee, K. Paustian, D. Powlson, N. Sampson, H., Tiessen, M.Van Noordwijk, andQ. Zhao. 1996. Agricultural options for mitigation of greenhouse gas emissions, p. 745-771. In R.T. Watson et al. (ed.) Climate Change 1995. Impacts, adaptations and mitigation of climate change: Scientific-technical analyses. IPCC Working Group II. Cambridge Univ. Press, Cambridge. EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. IPCC, 2003, Good Practice Guidance for Land Use, Land-Use Change and Forestry, IPCC National Greenhouse Gas Inventories Programme. Jabbagy, E.G., and R.B. Jackson, 2000, Below-ground processes and global changes, Ecol. Appl., 10:423- 436. Kimble, J.M., Lai, R., and R.R. Follett, 2002, Agricultural Practices and Policy Options for Carbon Sequestration in Soil, Lewis Publishers, 495-502. Lai, R., 1999, Soil management and restoration for carbon sequestration to mitigate the accelerated greenhouse effect, Prog. Env. Sci., 1:307-326. Li, C., Frolking, S., Butterbach-Bahl, K., 2005, Carbon Sequestration in Arable Soils is Likely to Increase Nitrous Oxide Emissions, Offsetting Reductions in Climate Radiative Forcing, Climate Change, 72(3):1573-1480. Schlesinger, W.H. 1997. Biogeochemistry: An analysis of global change. Academic Press, San Diego, CA. Six, J., Ogle, S.M., Jay breidt, F., Conant, R.T., Mosier, A. R, and K. Paustian, 2004, The potential to mitigate global warming with no-tillage management is only realized when practised in the long term Global Change Biology 10 (2), 155-160 doi:10.1111/j.l529-8817.2003.00730.x Smith, P., D. Martino, Z. Cai, D. Gwary, H.H. Janzen, P. Kumar, B. McCarl, S. Ogle, F. O'Mara, C. Rice, R.J. Scholes, O. Sirotenko, M. Howden, T. McAllister, G. Pan, V. Romanenkov, U. Schneider, S. Towprayoon, M. Wattenbach, and J.U. Smith, 2007, Greenhouse gas mitigation in agriculture. Philosophical Transactions of the Royal Society, B., 363. doi:10.1098/rstb.2007.2184. USD A Agricultural Census, 2002, Volume 1, Table 9. Land in Farms, Harvested Cropland, and Irrigated Land, by Size of Farm: 2002 and 1997 (http://www.nass.usda.gov/census/census02/volume l/us/st99_l_009_010.pdf). Willey, Z. and Chameides, B, 2007, Harnessing Farms and Forests in the Low-Carbon Economy: How to Create, Measure and Verify Greenhouse Gas Offsets, Duke University Press, Durham and London. 22 ------- Agricultural Soil N2O Emissions (including fertilizer use) Nitrous oxide is produced naturally in soils through the microbial processes of nitrification and denitrification both through anthropogenic and natural causes. The IPCC considers all emissions of N2O from managed lands to be anthropogenic. The U.S. GHG Inventory conforms to IPCC guidance, and accounts for all emissions from managed lands, which includes natural background N2O emissions. In 2006, N2O emissions from agricultural soil management were 265.0 MMTCO2e, which is 72% of all U.S. N2O emissions, and 3.8% of all U.S. GHG emissions. Anthropogenic emissions of N2O from agricultural soils consist of both direct and indirect emissions that result from inputs of N, and management practices that lead to a greater release of mineral N to the soil on managed lands. Direct emissions result from a variety of management practices, including: fertilization; application of managed livestock manure and other organic materials such as sewage sludge; deposition of manure by grazing animals; production of N-fixing crops and forages; retention of crop residues; and drainage and cultivation of organic cropland soils (i.e., soils with a high organic matter content, otherwise known as histosols). Other agricultural soil management activities, including irrigation, drainage, tillage practices, and fallowing of land, can influence N mineralization in soils and thereby affect direct emissions. Indirect emissions of N2O occur through two pathways: (1) volatilization and subsequent atmospheric deposition of applied N, and (2) surface runoff and leaching of applied N into groundwater and surface water. (See attached figure of N flows resulting in emissions of N2O.) Monitoring In general, there are three approaches for monitoring N2O emissions from management of agricultural soils: (1) direct measurement (using automated flux chambers and/or eddy correlation techniques), (2) use of emission factors, and (3) process modeling. Direct measurement is prohibitively expensive due to the cost of equipment and need for continuous measurements to capture episodic emission events. Use of a single emissions factor, like the IPCC factor of 1%, based on amount of applied nitrogen can result in large uncertainty at the farm level as field data have shown that actual emission rates can range from 0.1% to almost 10% of applied fertilizer. Use of process models (e.g., DAYCENT, DNDC model) is promising but can be data intensive and requires systematic validation coupled with statistical modeling to quantify accuracy and precision of model estimates. A hybrid option that combines the IPCC emission factor and modeling approaches is the use of a model such as the one under development for NRCS using preset DAYCENT runs. This model could be used in combination with the COMET-VR soil carbon model to estimate soil N2O emissions, utilizing activity data similar to that required by the IPCC methodology, but would be an improvement in accuracy over the standard IPCC approach while keeping the data requirements at a reasonable level. Information to be Collected Application of N at a farm results in direct emissions onsite and also offsite through volatilization, leaching/runoff of N and later deposition where the N is made available for nitrification/denitrification, (i.e., indirect emissions). Accounting for these indirect emissions is extremely uncertain, as it is rarely known where the N is eventually emitted as N2O. For emissions estimates, it is only practical to include direct emissions resulting from inputs of N by the landowner. Indirect emissions (those resulting from N that was not directly applied to the land) are not under the control of the landowner and very difficult to 23 ------- quantify. Reporting N2O emissions onsite and not reporting N2O offsite would, however, result in incomplete estimates. In order to capture all of the direct N2O emissions resulting from application of N to soils, it would be necessary for farmers to report on a number of different N inputs. Synthetic N and organic N inputs (e.g., synthetic fertilizer, manure, sewage sludge) are the only inputs that be measured with reasonable accuracy and minimal burden by a landowner. N resulting from mineralization of organic matter (plant residue or soil organic matter) would be very uncertain. This leaves synthetic and organic inputs of N as the only potentially reportable inputs. Table 4. Activity data for calculation N2O emissions Activity data for N inputs Synthetic N application (at farm level) Urine and Dung (from grazing animals) N input to land Organic Amendments (including sewage sludge, manure, compost) Crop residue N contribution Other (Mineralization of soil organic matter, asymbiotic fixation of N from atmosphere) Feasibility of data collection High Medium/Low Medium/Low Low Very Low Share of N2O Emissions from Agricultural Soils 26% 9% 5% 10% 50% Uncertainty While some input data can be collected with reasonable certainty, the estimation of N2O emission from these inputs varies greatly spatially and temporally. Until the available modeling-based approaches can be implemented in a routine manner, efforts for reporting N2O emissions from agricultural soils will be hampered with emission factor approaches that suffer from large uncertainties. Reporters and Thresholds All land-use types occurring in the United States (cropland, grassland, forestland, settlements and wetlands) emit N2O. Thus all landowners could potentially be reporting entities. In 2007, there were 2.08 million farms in the United States with a total land area of 930.9 million acres, and an average farm size of 449 acres (USDA Agricultural Statistics Board 2008). Analysis for the GHG reporting rulemaking is focusing on thresholds of 1,000 mtCO2e, 10,000 mtCO2e, 25,000 mtCO2e, and 100,000 mtCO2e. Using average fertilizer application rates and IPCC emission factor N2O estimation methodologies, it becomes apparent that even at the highest N fertilization rate of 180 Ibs N/acre, it would take a farm of over 25,000 acres to equal the 10,000 mtCO2e threshold. Given that the USDA Farm Census from 2002 reports as its largest farm size 5000+ acres (see Figure 1), there is a very low probability that any farm in the United States would meet even the 10,000 mtCO2e threshold. (See Table 1 below.) 24 ------- 600000 500000 400000 300000 200000 100000 - - DAN Farms Farms with Harvested Croplands is -i 1to9 10 to 50 to 70 to 100 to 140 to 180 to 220 to 260 to 500 to 1,000 2,000 5,000 acres 49 acres 69 acres 99 acres 139 179 219 259 499 999 to 1,999 to 4,999 acres or acres acres acres acres acres acres acres acres more Figure 1. Distribution of US Farm Sizes. Source: 2002 USD A Agricultural Census Table 1, Threshold analysis with IPCC Factors N Fertilizer Rates In US Wheat: 68 Ibs/acre Cotton: 92 Ibs/acre Corn (Avg. rate) 137 Ibs/acre Corn (High value) 180 Ibs/acre Number of acres to reach 10,000 mtCO2e threshold 68,488 49,019 33,112 25,062 Another way of performing this analysis is to use data from the U.S. GHG Inventory (EPA 2008) and estimate area-based emission factors for direct N2O emissions from all N inputs to cropland as well as isolating just synthetic N inputs (See Table 2 below). Table 2. Threshold analysis with US GHG Inventory Factors Category Cropland: Synthetic N Additions Cropland: All N Inputs Grassland: All N Inputs N2O Emission Rate (kg CO2e/acre) 134 347 104 Number of Acres to reach 10,000 mtCO2e Threshold 74,626 28,818 96,000 It becomes apparent after performing these analyses and reviewing farm size data that it is very unlikely that any farm in the United States would meet a 10,000 mtCO2e threshold. Existing Federal Data Collection Systems There are no current systems that collect the data needed for entity reporting. 25 ------- Settlement NiO Emissions (including fertilizer use) Source Category N2O is emitted from soils in settlements due to nitrification and denitrification. While typical nitrification and denitrification rates in natural systems vary primarily with moisture and temperature, in settlements lawn fertilization and irrigation can increase rates of N2O release by as much as 15 times during the days immediately following fertilization (Bremer 2006, Hall et al. 2008). Significant release of CH4 has not been measured from urban soil, and - overall - soils in urban settlements are probably a net sink for QrU (Kaye et al. 2004). Monitoring Emissions Application rates of fertilizer are quite heterogeneous and can vary by homeowner, but do correlate with socioeconomic characteristics, neighborhood, and lawn size (Law et al. 2004, Zhou et al. 2007). Despite these correlations, empirically predictive methods for understanding fertilizer application rates do not yet exist. Monitoring of N2O emissions from settlements are also complicated by the rapid change in settlement land area, as the overall land area devoted to settlements increased by 32.2% between 1990 and 2006, resulting in an increase in N2O flux by 48% over the same period (EPA 2008). Current methodology for estimating N2O flux from settlements remaining settlements is based on aggregate fertilizer applications rather than on per-unit-area estimates, thus there are no region- or area-specific emission factors appropriate for settlements. Since lawn areas tend to be fairly homogeneous, however, one can estimate the per-unit-area emissions by dividing the total N2O flux from fertilizer application (1.5 MMTCO2e) by the total area of turfgrass in the United States (32 million acres [Milesi et al. 2005]) for an overall nationwide average of 0.05 mtCO2e per acre of turfgrass per year. Information to be Collected The following information would need to be collected to monitor emissions: area subject to fertilizer application, type of fertilizer and application rate. Also needed are accurate estimates of emission factors for settlements remaining settlements. Uncertainty N2O flux from settlements depends on a large number of variables in addition to N inputs, including organic C availability, O2 partial pressure, soil moisture content, pH, temperature, and irrigation/watering practices. The effect of the combined interaction of these variables on N2O flux is complex and highly uncertain. The IPCC default methodology only accounts for variations in fertilizer N and sewage sludge application rates, such that all settlement soils are treated equivalently. A quantitative uncertainty analysis of N2O flux from settlements remaining settlements found that the 95% confidence interval ranged from -59% to +163% of the estimated 2006 emission estimate of 1.5 MMTCO2e (EPA 2008). Identification of Reporters Estimates of the turfgrass area covered by home lawns in the United States range from 17.7 million (EPA 2007) to 21 million acres (Bormann et al. 2001). A 2005 remote sensing study estimated the total land area covered by turfgrass in the United States (including home lawns as well as recreational fields, commercial and industrial parks, golf courses, etc.) to be roughly 32 million acres, corresponding to 1.9% of total U.S. land area (Milesi et al. 2005). The 2000 U.S. Census reports 105.5 million households in the United States, roughly 80% of which maintain a private lawn (Tempelton et al. 1998). While the average 26 ------- lawn size in the United States varies with region, the national mean lawn size is 0.3 acres (Vinlove and Torla 1995). At the nationwide average N2O emission rate of 0.05 mtCO2e per acre per year, an entity would need to reach 20,000 acres of fertilized turfgrass in order to be eligible for reporting under the 1,000 mtCO2e/ year threshold and 200,000 acres of fertilized turfgrass in order to be eligible for reporting under the 10,000 mtCO2e/ year threshold. Entities larger than 533,000 acres would be eligible under the 25,000 mtCO2e/ year threshold, and entities larger than 2.1 million acres would be required to report under the 100,000 mtCO2e/ year threshold. For reference, an 18-hole golf course can be built on as little as 100 acres, and few courses are larger than 1000 acres. Existing Federal Data Collection Systems There are no current systems that collect the data needed for entity reporting. References Bremer, DJ. 2006. Nitrous oxide fluxes in turfgrass: effects of nitrogen fertilization rates and types. Journal of Environmental Quality 35: 1678-1685. Hall SJ, Huber D, Grimm NB. 2008. Soil N2O and NO emissions from an arid, urban ecosystem. Journal of Geophysical Research 113: doi: 10.1029/2007JG000523. Kaye JP, Burke 1C, Mosier AR, Guerschman JP. 2004. Methane and nitrous oxide fluxes from urban soils to the atmosphere. Ecological Applications 14: 975-981. Law, N.L., L.E. Band, and J.M. Grove. 2004. Nitrogen input from residential lawn care practices in suburban watersheds in Baltimore County, MD. Journal of Environmental Planning and Management 47(5): 737-755. Zhou, W., A. Troy, and M. Grove. 2007. Modeling Residential Lawn Fertilization Practices: Integrating High Resolution Remote Sensing with Socioeconomic Data. Environmental Management, DOI 10.1007/s00267-007-9032-z. EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. Milesi C, Running SW, Elvidge CD, Dietz JB, Turtle BT, Nemani RR. 2005. Mapping and modeling the biogeochemical cycling of turf grasses in the United States. Environmental Management 36: 426-438. EPA, 2007, EPA Pesticide Environmental Stewardship Program, http ://www. epa. gov/pesp/strategies/2007/planet07 .htm Bormann, F.H., Balmori, D., Geballe, G.T. (2001). Redesigning the American Lawn: A Search for Environmental Harmony (2nd edition). Yale University Press, 192 pp. Templeton, S.R., Zilberman, D., & Yoo, S.J. (1998). An economic perspective on outdoor residential pesticide use. Environmental Science & Technology, 2, 416A - 423A. Vinlove, F.K., Torla, R. (1995) Comprehensive Estimation of U.S. Home Lawn Area. Journal of Turfgrass Management. l(l):83-97. 27 ------- Forest Land N2O and CH4 (including fertilizer use and forest fires) Nitrous oxide and CFL, are emitted in this source category primarily via emissions from soils and wildfire. N2O is emitted from forest soils via nitrification and denitrification (Carnol and Ineson 1999, Davidson et al. 1993, Kester et al. 1997, Wolf and Brumme 2002). Dry upland forest soils are sinks for CH4 (Castaldi et al. 2006, DelGrosso et al. 2000, Hein et al. 1997, Jang et al. 2006, Wuebbles and Hayhoe 2002), though some studies have suggested that CH4 may be emitted from wet forest soil under natural conditions due to anaerobic decomposition (Megonigal and Guenther 2008, Ullah et al. 2008). Wildfire emissions of N2O and CH4 from forests depend on the amount of biomass burned, together with the expected emission factors for the biomass involved in the fire. In the United States, forest fires caused the release of 24.6 MMTCO2e as CH4 and 2.5 MMTCO2e as N2O in 2006 (EPA 2008). These fire-related emissions totaled 27.1 MMTCO2e, or 73% of the non-CO2 emissions from the LULUCF sector in that year. This 2006 emissions total was a five-fold increase from the 5.0 MMTCO2e (0.5 MMTCO2e as N2O, 4.5 MMTCO2e as CFL,) attributable to fire in 1990, when the forest-fire-related non-CO2 emissions totaled only 38% of the non-CC>2 emissions from the LULUCF sector. While recent research has yielded important information about dry upland soils as sinks for CFL,, this phenomenon has not yet been quantified at the national scale. Globally, a sink of roughly 30 MMTCFL, per year (630 MMTCO2e per year) in upland soils has been estimated. In the United States, this sink would partially offset the emissions from wildfire, as the ratio of upland soils to wetland soils is large. Monitoring Emissions Direct measurement of trace gas fluxes such as N2O and CFL, typically involve chamber-based instrumentation that is quite costly and time-consuming to install and maintain. The measurements collected tend to be quite variable over space and time, and can depend substantially on microclimatic variables such as temperature and moisture. Thus collection of direct measurements of CFL, and N2O fluxes, and even interpolation of existing trace gas measurements, is difficult for large scales. While fertilizer application could be used as a proxy for N2O emissions from soils, substantial uncertainty exists related to fertilization rates, area of land receiving fertilizer, and emission factors. Non-CCh gases emitted from forest fires depend on several variables, including forest area and C density, emission ratios, and combustion factor values (proportion of biomass consumed by fire). In the IPCC default methodology (IPCC 2006), CFL, and N2O emissions from fire are calculated by multiplying the total estimated C emitted from forest burned by gas-specific emissions ratios and conversion factors. The relevant equation is: Lfire=A-MB -Cf-Gef-W3 Where L = total emissions from fire (in tonnes of GHG emitted) A = spatial extent of fire (area burnt, ha) M = mass available for combustion (tonnes per ha) Cf = combustion factor (the proportion of biomass that is consumed by fire) (dimensionless) Gef = emission factor (tonnes GHG emitted per kg biomass combusted) At large scales, the extent of wildfires can be measured using satellite based monitoring programs such as those spearheaded by the Fire and Environmental Research Applications Team 28 ------- (http://www.fs.fed.us/pnw/fera/fccs/index.shtmn and the MODIS Active Fire Mapping Program at the USDA Forest Service (http://activefiremaps.fs.fed.us/'). These can be paired with information about forest inventory developed from the USDA Forest Service Forest Inventory and Analysis Program, but there is likely a minimum area below which this approach would not be feasible. This minimum area is determined by the spatial accuracy of the spatial input layers ~ specifically, the pixel size of the satellite imagery being used as well as the relative accuracy of the classification. Small ownerships would not be well represented by a satellite monitoring approach. A modeling approach can also be used, at small scales or together with maps of the spatial extent of fires. Process models such as Consume 2. 1 (and 3.0) can be used to predict trace gas emission from wildfire, but these models must still be parameterized with field data about the biomass involved in the fire and the fire severity (http://www.fs. fed.us/pnw/fera/research/smoke/consume/consume_download.shtmn. In addition, there are also hybrid-type approaches that combine satellite-derived data with ground-report databases, such as SMARTFIRE (http : www. getbluesky.org/smartfire) . Information to be Collected The following information would need to be collected to monitor emissions using the IPCC methodology. For non-fire N2O losses, fertilizer application rate, and type of fertilizer used would be needed. For fire- related N2O and CFLt losses, the required information includes spatial extent of fire, severity of fire (i.e. proportion of biomass consumed by fire), and C density of burned forest. Uncertainties For N2O emissions from forest soils, uncertainties relate to variability in human-induced parameters such as fertilizer inputs and tree planting/ harvesting cycles, as well as biogeochemical processes including organic C availability, O2 partial pressure, soil moisture content, pH, and temperature (EPA 2008). Quantitative analysis suggests uncertainties in inventory-based estimates of N2O flux between +211% and -59% (EPA 2008). Uncertainty also exists "due to lack of sufficient field data, sampling conditions with a tendency to over-represent one mode of combustion over the other, and differences in the types of measurements (tower vs. ground-based vs. aircraft measurements). Furthermore, emission factors vary as the fire season progresses due to changing moisture conditions (Hayhoe, pers. comm..). These uncertainties result in quantitative uncertainty estimates of between +71% (CUt)/ +75% (N2O) and -69% and N2O) around existing estimates of wildfire emissions (EPA 2008). Reporters and Thresholds There are 620 million acres of forest land in the United States, of which 393 million acres (roughly two- thirds) are in private ownership, including a combination of family forestland owners and land held by partnerships and corporations (Butler and Leatherberry 2004). An estimated 10.3 million family forest owners in the United States collectively control 42% of forested land in the United States (family forest land is owned by individuals not incorporated as a legal entity). Most of these (88%) family forestland owners are in the Eastern United States; the remaining 12% own land dispersed across the Western states. Owners with 50+ acres hold 69% of family forestland across the United States, but account for 1 1% of family forest owners. Public forestland is predominantly owned by the Federal Government in the West, and by State and county governments in the East. Public land accounts for 69% of the forest land in the West, and 17% of the forest land in the East (USDA 2001). The IPCC methodology for quantifying non-CO2 GHG emissions from wildfires and prescribed fires describes a range of emission factors from 0.06 g N2O per kg biomass burned (for biofuel burning) to 0.26 g N2O per kg of biomass burned (for extratropical forests). For CFLj, the low emission factor estimate is 2.3 g CFLt per kg biomass burned (for savanna and grassland), and the high emission factor is 6.8 g CFLt per kg biomass burned (for tropical forest). Clearly there is biome-specific variation in these 29 ------- factors, but emission factors with finer spatial or biome-specific resolution are not available. Similarly, a range of pre-burn biomass (M) and proportion burned (Cf) are available. Assuming the IPCC default of 0.45 for Cf in "temperate forests," we can identify a threshold reporter size for wildfire extent to be eligible for entity-level reporting. N2O: Assuming the highest emission factor (0.26 g N2O per kg burned) and a high forest C density of 300 tons C per ha, a wildfire of 227 acres would be eligible for entity reporting if the threshold were 1,000 mtCO2e and a wildfire of 2,270 acres would be eligible if the threshold were 10,000 mtCO2e. A wildfire of 5,675 acres would be required if the threshold for reporting were 25,000 mtCO2e, and a wildfire of 22,700 acres would meet the 100,000 mtCO2e threshold (Table 1). Assuming the lowest emission factor (0.06 g N2O per kg of biomass burned) and an average forest density of 150 tons C per ha, a wildfire of 1,967 acres would be eligible for entity reporting at an emissions threshold of 1,000 mtCO2e and a wildfire of 19,673 acres would be eligible at an emissions threshold of 10,000 mtCO2e. A wildfire of 49,184 acres would be required at an emissions threshold of 25,000 mtCO2e, and a wildfire of 196,734 acres would be eligible for reporting under an emissions threshold of 100,000 mtCO2e (Table 1). Assuming the highest emission factor (6.8 g QrU per kg burned) and a high forest C density of 300 tons C per ha, a wildfire of 128 acres would be eligible for entity reporting if the threshold were 1,000 mtCO2e and a wildfire of 1,281 acres would be eligible if the threshold were 10,000 mtCO2e. A wildfire of 3,203 acres would be required if the threshold for reporting were 25,000 mtCO2e, and a wildfire of 12,813 acres would meet the 100,000 mtCO2e threshold (Table 2). Assuming the lowest emission factor (2.3 g CH4 per kg of biomass burned) and an average forest density of 150 tons C per ha, a wildfire of 758 acres would be eligible for entity reporting at an emissions threshold of 1,000 mtCO2e and a wildfire of 7,576 acres would be eligible at an emissions threshold of 10,000 mtCO2e. A wildfire of 18,940 acres would be required at an emissions threshold of 25,000 mtCO2e, and a wildfire of 75,761 acres would be eligible for reporting under an emissions threshold of 100,000 mtCO2e (Table 2). N2O and CH/jCombined: Assuming that both Or^and N2O are released simultaneously during fire and a high forest C density of 300 tons C per ha, and using the highest emission factors reported in the literature, a wildfire of 82 acres would be eligible for entity reporting at the 1,000 mtCO2e threshold level and a wildfire of 8 1 9 acres would be eligible at the 1 0,000 mtCO2e threshold level. A wildfire of 2,047 acres would trigger the reporting requirement at the 25,000 mtCO2e level, and a fire size of 8, 190 acres would be reported under the 100,000 mtCO2e threshold. Assuming the lowest emission factors for both N2O and Or^and an average forest C density of 150 tons C per ha, the threshold sizes are much larger: 547 acres for the 1,000 mtCO2e reporting threshold, 5,470 acres for the 10,000 mtCO2e reporting threshold, 13,674 acres for the 25,000 mtCO2e threshold and 54,697 acres for the 100,000 mtCO2e threshold (Table 3). Table 1. Threshold wildfire sizes under Highest emission factor, high forest C density Lowest emission factor, average forest C density various reporting thresholds for N2O emissions (acres). 1,000 mtCO2e 227 1,967 10,000 25,000 mtCO2e mtCO2e 2,270 5,675 19,673 49,184 100,000 mtCO2e 22,700 196,734 Table 2. Threshold wildfire sizes under various reporting thresholds for CH4 emissions (acres). 1,000 mtCO2e 10,000 mtCO2e 25,000 mtCO2e 100,000 mtCO2e Highest emission factor, high forest C 30 ------- density Lowest emission factor, average forest C density 758 7,576 18,940 75,761 Table 3. Threshold wildfire sizes under various reporting thresholds for combined N2O and CH4 emissions (acres). Highest emission factor, high C density Lowest emission factor, average C density 1,000 82 547 10,000 819 5,470 25,000 2,047 13,674 100,000 8,190 54,697 While fires larger than 400 ha (about 1000 acres) have historically been fairly infrequent in the United States, Westerling et al. (2006) reported a dramatic increase in these large fires over the last several decades. Between 2000 and 2003, between 50 and 100 such large wildfires burned annually in the Western states. Existing Federal Data Collection Systems There are no Federal monitoring programs for N2O and CFL, emissions from soils and vegetation in forests remaining forests. Data is available on a national level for "wildland area burned." To complete national emissions estimates for this source, the forest proportion of wildland area must be approximated and extracted from this area data. There are no current systems that collect the data needed at the entity level for reporting of N2O and CFL, emissions from fire (fire severity, proportion of biomass burned per fire, aerial extent of fire). References Carnol M and Ineson P. 1999. Environmental factors controlling NO3 leaching, N2O emissions and numbers of NH4 oxidisers in a coniferous forest soil. Soil Biology and Biochemistry 31: 979-990. Castaldi, S., A. Ermice, & S. Strumia. 2006. Fluxes of N2O and CH4 from soils of savannas and seasonally-dry ecosystems. J. of Biogeogmphy 33(3): 401-415. Davidson EA, Matson PA, Vitousek PM, Riley R, Dunkin K, Garcia-Mendez G, Maass, JM. 1993. Processes regulating soil emissions of NO and N2O in a seasonally dry tropical forest. Ecology 74: 130-139. Del Grosso, S. J., W. J. Parton, A. R. Mosier, D. S. Ojima, C. S. Potter, W. Borken, R. Brumme, K. Butterbach-Bahl, K. D. P.M. Crill, & K. A. Smith. 2000. General CH4 oxidation model and comparisons of CH4 oxidation in natural and managed systems. Global Biogeochem. Cycles 14(4): 999-1019. EPA, 2008, Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006 (April 2008) USEPA #430- R-08-005. Hein, R., P. J. Crutzen, & M. Heimann. 1997. An inverse modeling approach to investigate the global atmospheric methane cycle. Global Biogeochem. Cycles 11(1)'. 43-76. IPCC, 2006, IPCC Guidelines for National Greenhouse Gas Inventories, Volume 4, Agriculture, Forestry, 31 ------- and Land Use. Chapter 2: Generic methodologies applicable to multiple land-use categories. Available at: http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol4.html. Jang, I., S. Lee, & J. Hong. 2006. Methane oxidation rates in forest soils and their controlling variables: A review and a case study in Korea. Ecol. Res. 21(6): 849-854. Keppler F, Hamilton JTG, Brass M, Rockmann T. 2006. Methane emissions from terrestrial plants under aerobic conditions. Nature 439: 187-191. Kester RA, Meijer ME, Libochant JA, De Boer W, Laanbroek HJ. 1997. Contribution of nitrification and denitrification to the NO and N2O emissions of an acid forest soil, a river sediment and a fertilized grassland soil. Soil Biology and Biochemistry 29: 1655-1664. Megonigal JP and Guenther AB. 2008. Methane emissions from upland forest soils and vegetation. Tree Physiology 28: 491-498. Ullah S, Frasier R, King L, Picotte-Anderson N, Moore TR. 2008. Potential fluxes of N2O and CH4 from soils of three forest types in Eastern Canada. Soil Biology and Biochemistry 40: 986-994. Wolf I and Brumme R. 2002. Contribution of nitrification and denitrification sources for seasonal N2O emissions in an acid German forest soil. Soil Biology and Biochemistry 34: 741-744. Wuebbles, D. J., & K. Hayhoe. 2002. Atmospheric methane and global change. Earth Sci. Rev. 57(3-4): 177-210. Butler, B. J. and E.G. Leatherberry 2004. America's Family Forest Owners. Journal of Forestry 102(7): 4- 9. Westerling, A.L., H.G. Hidalgo, D.R. Cayan, T.W. Swetnam. 2006. Warming and earlier spring increase western US forest wildfire activity. Science 303: 940-943. USD A, 2001, USDA Forest Service Forest Inventory and Analysis Unit, US Forest Facts and Historical Trends, FS-696. 32 ------- Other Land Use, Land-Use Change, and Forestry C Emissions and Sinks In the Inventory of U.S. Greenhouse Gas Emissions and Sinks, the United States reports net greenhouse gas fluxes associated with IPCC designated land-use categories according to UNFCCC reporting guidelines and IPCC guidance. The carbon flux estimates included in the national GHG Inventory represent total net carbon stock changes on United States land areas. This net carbon stock change approach accounts for both gains and losses of forest carbon in the aboveground and belowground biomass, dead organic matter, and soil, as well as in durable wood products in use and in landfills. The net carbon stock changes reflect growth, mortality, harvesting, and other management activities, as well as increases and decreases in forest area. The approach used for the national GHG Inventory, therefore, implicitly accounts for carbon dioxide emissions due to disturbances such as forest fires. For more information on the magnitude of CO2 emissions from forest fires in the United States, the Inventory of U.S. Greenhouse Gas Emissions and Sinks. Net carbon CO2 flux reported in the GHG Inventory also includes C fluxes from croplands, grasslands, and settlements, and changes from one land use type to another. In the United States, the total net CO2 flux from C stock changes in Land Use, Land-Use Change, and Forestry was 883.7 MMTCO2 in 2006. Monitoring Land use-based accounting methods for quantifying CO2 sources and sinks typically involve average C density and accumulation values for land use types (emission factors) applied to land areas categorized by type (activity data). Emission factors are developed at multiple scales and involve different levels of resolution depending on the datasets used to develop them. Often, average emission factors by region or vegetation type are developed and used (e.g. Smith et al. 2006). At the national scale, the U.S. Forest Service Forest Inventory and Analysis (FIA) program collects data on forest area and management. Forest carbon stocks and net carbon stock changes are estimated by applying a collection of conversion factors and models, referred to as FORCARB2, to the tree and plot- level forest survey data collected through the FIA program. For forest C accounting at the project and entity scales, the USDA Forest Service has developed look-up tables based on FIA data, which is available in a consistent format at the national scale. These look-up tables 1) quantify C stocks by age in "average" forest for a given region, stratified by forest type; and 2) directly estimate biomass using allometric approaches but indirectly estimate pools such as soil C, forest floor C, coarse woody debris, and understory C. Inventory datasets can provide useful activity data, though their data are most robust at the county scale, so there are limitations in tracking emissions from smaller-scale land conversion. In the IPCC default methodology for land converted to settlements, the biomass in vegetation after land conversion is set to zero (IPCC 2006). Thus, for these forests the emission factor is essentially the C density in the standing forest prior to conversion. These default methods assume that 20% of soil C is also lost during forest conversion (IPCC 2006). Land use conversions to cropland typically result in a net loss of C and N2O from biomass and soils, though conversion of sparsely vegetated or highly degraded land to cropland may lead to a net C increase. As with settlements, in the IPCC default methodology for land converted to croplands the biomass in vegetation after conversion is set to zero (IPCC 2006). Year-to-year increases in woody biomass on cropland (orchards, vineyards, etc.) can be estimated using default emission factors, though no change in vegetation biomass occurs for annual crops (IPCC 2006). C stock changes on the majority of cropland 33 ------- are typically a result of soil C gain or loss from the soil pool. The emission factors describing change in the soil C pool before and after conversion to cropland can indicate a net loss or a net increase of soil C, depending on the intensity of cultivation, the types of inputs used, and the climate regime in the area of interest (IPCC 2006). Because grasslands "vary greatly in their degree and intensity of management, from extensively managed rangelands and savannahs - where animal stocking rates and fire regimes are the main management variables - to intensively managed (e.g., with fertilization, irrigation, species changes) continuous pasture and hay land" (IPCC 2006), it is even more difficult to generalize about the impacts of land conversion to this type. Depending on the land use prior to conversion, C may be gained or lost from the vegetation and soils. Prescribed fire may also contribute to the emissions due to land conversion to grassland (IPCC 2006). Information to be Collected The following information would need to be collected to monitor emissions using the IPCC methodology: land area converted, and forest and soil C density prior to land conversion. Uncertainties When large land areas are involved in land use change-based emissions monitoring, coarse estimates may be appropriate and even desirable. At the scale of individual reporters, accurate reporting of C gains and losses due to land use change could require reporters to report the amount of land use change along with estimates of emissions associated with the change. These estimates may be quite uncertain at the scale of individual reporters, especially if the land areas being considered are small or if there are deviations from standard management regimes. For individual reporters, the emissions factors and look-up tables that are readily available for assessment of forest C storage are not likely to reflect the variety of conditions that exist for a specific portion of the landscape. Similarly, for croplands, grasslands, and settlements, the management regimes before and after conversion are the main drivers of changes in C stocks for particular ownerships. Characterization of these changes requires site-specific information that is typically not available at the scale of individual reporters. Even for cases where such information is available, emissions factors are not expressed at a resolution fine enough to account for this site-level variability. Reporters and Thresholds Reporters could be real estate developers or investors, individuals with private land, land conservation organizations, governments, or other entities. Complicating the identification of reporters, and the reporting of emissions, is that a plot of land that exceeds an emissions threshold level one year may be a sink of emissions the next and vice versa. The emission or storage of greenhouse gases in a land area is determined by the C density of the original forests or soils, management practices, any land conversion that occurs on that land, and the fate of the C and N in any cleared soil and vegetation. Developed land areas are quite heterogeneous and this will greatly impact the change in soil C and biomass C stocks as well as the mineralization of soil organic carbon and resulting N2O emissions. As an example, there could be a hectare of grassland converted to a hectare of settlement area, which could include trees, a building, turf grass, a parking lot, ornamental plants, maybe even a pond. Soil C and biomass C could increase or decrease depending on the actual conversion implemented. This makes a threshold analysis for emissions from land use very difficult as there is great variation between land types and land use changes in the United States, and land areas can be either emissions sources or sinks. 34 ------- To conduct a threshold analysis for this source, it would be necessary to estimate the emissions per unit land area in the United States. An estimate based on carbon flux nationally would result in net sequestration per acre and no land area would therefore meet or exceed the threshold. An estimate that uses IPCC default values for forest C density and the default assumption that forest clearing for development results in a complete loss of aboveground biomass due to decomposition would not provide information that could be used to assess the number of reporters or emission covered because it may overestimate carbon loss per unit of land. Either of these approaches is also complicated by the fact that management practices, vegetation, soils, etc., in any specific land area can vary greatly from year to year. Existing Federal Data Collection Systems Detailed, spatially-explicit activity data are available from a variety of sources at numerous spatial resolutions, including the National Land Cover Dataset (coarse resolution), the National Resource Inventory dataset (fine resolution), satellite imagery purchase by federal/state/local governments and organizations (varying resolution), or the National Agricultural Imagery Program (fine resolution). Many of these sources provide raw data that must be classified in order to be useful, yet classification is expensive, time-consuming, and often inaccurate. References Albani M, Medvigy D, Hurtt GC, Moorcroft PR. 2006. The contributions of land-use change, CO2 fertilization, and climate variability to the Eastern US carbon sink. Global Change Biology 12: 2370-2390. Environmental Protection Agency (EPA). 2008. Inventory of US Greenhouse Gas Sources and Sinks: 1990-2006. USEPA#430-R-08-005. Erb K-H. 2004. Land-use related changes in aboveground carbon stocks of Austria's terrestrial ecosystems. Ecosystems 7: 563-572. Ewing R, Pendall R, Chen D. 2003. Measuring sprawl and its transportation impacts. Transport Res Rec 1831: 175-183. Golubiewski, NE. 2006. Urbanzatino increases grassland carbon pools: Effects of landscaping in Colorado's Front Range. Ecological Applications 16(2): 555-571. Gonzalez GA. 2005. Urban sprawl, global warming and the limits of ecological modernisation. Environ Politics 14: 344-362. Gower ST, McKeon-Ruediger A, Reitter A, Bradley M, Refkin D, Tollefson T, Souba FJ, Taup A, Embury-Williams L, Schiavone S, Weinbauer J, Janetos AC, Jarvis R. 2006. Following the Paper Trail: The Impact of Magazine and Dimensional Lumber Production on Greenhouse Gas Emissions. Washington, DC: The H. John Heinz III Center for Science, Economics and the Environment. Harmon ME, Ferrell WK, Franklin JF. 1990. Effects on carbon storage of conversion of old-growth forests to young forests. Science 247: 699-702. Heath LS, Birdsev RA, Row C, Plantinga AJ. 1996. Carbon pools and flux in U.S. forest products. In: Forest Ecosystems, Forest Management, and the Global Carbon Cycle, (MJ Apps and DT Price, eds). NATO ASI Series I: Global Environmental Changes, Volume 40, Springer-Verlag, 271- 278. 35 ------- Ingerson, A. and W. Loya. 2008. Measuring Forest Carbon: Strengths and Weaknesses of Available Tools. Science and Policy Brief. Washington, B.C. The Wilderness Society. Intergovernmental Panel on Climate Change. 2007. Good Practice Guidance for National Greenhouse Gas Inventories. Vol 4: Agriculture, Forestry, and Other Land Use. Chapter 4: Forest Land, Chapter 5: Cropland, Chapter 6: Grassland, and Chapter 8: Settlements. Jandl R, Lindner M, Vesterdal L, Bauwens B, Baritz R, Hagedorn F, Johnson DW, Minkkinen K, Byrne KA. 2007. How strongly can forest management influence soil carbon sequestration? Geoderma 137: 253-268. Kim, S. 2000. Urban development in the United States, 1690-1990. Southern Economic Journal 66: 855-880. Micales JA and Skog KE. 1997. The decomposition of forest products in landfills. International Biodeterioration & Biodegradation 39: 145-158. Pataki DE, Alig RJ, Fung AS, Golubiewski NE, Kennedy CA, McPherson EG, Nowak DJ, Pouyat RV, Lankao PR. 2006. Urban ecosystems and the North American carbon cycle. Glob Change Biol 12: 2092-2102. Paustian K, Six J, Elliott ET, Hunt HW. 2000. 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