Mobile Biochar Production and the Clean Air Act of 1990

Pyrolysis is a combustion process of woody biomass conducted under low or no oxygen conditions. New innovations and the need to limit open burning has resulted in numerous mobile and fixed plant pyrolysis methods that burn a variety of woody residues. Production technologies that reduce the need for open burning, the main source of potential pollutants, fall under the regulations in the Clean Air Act of 1990. This Act is the legal instrument to regulate air pollution at its source across the United States of America and it is implemented and enforced through the Environmental Protection Agency, in coordination with sister agencies. One newer innovation for reducing woody residues and emissions is an air curtain incinerator. Currently, the Clean Air Act regulates stationary solid waste incinerators, and this is also applied to mobile air curtain incinerators burning woody biomass. However, other woody biochar production methods (e.g., flame cap kilns) are not subject to these regulations. Discrepancies in the interpretation of definitions related to incineration and pyrolysis and the myriad of differences related to stationary and mobile air curtain incinerators, type of waste wood from construction activities, forest residues, and other types of clean wood make the permitting regulations confusing as permits can vary by jurisdiction. This review summarizes the current policies, regulations, and directives related to in-woods biochar production and the required permits.