Biomass doesn’t belong in a “Clean Energy Standard”

Input on the question of what belongs in a “Clean Energy Standard” was due yesterday, April 12. A whitepaper from Senators Jeff Bingaman (R, NM) and Lisa Murkowski (R, AK) outlined questions to be answered, such as
·         What resources should qualify as “clean energy”?
·         Should the definition of “clean energy” account only for the greenhouse gas emissions of electric generation, or should other environmental issues be accounted for? 
·         How will a CES affect the deployment of specific technologies?
It’s been an article of faith with many in Congress that everything from Godzilla (nukes) to unicorns (coal with carbon capture) belongs in a Clean Energy Standard. We’re so grateful to find Republicans that acknowledge that reducing greenhouse gas emissions is a worthy goal, we figured we’d play along, and submit our comments on why biomass doesn’t belong in a Clean Energy Standard.  Here’s a summary; click here for the full document (containing permit numbers comparing emissions from natural gas and biomass, and details on EPA’s boiler rule)
Executive summary
We have focused on four sub-questions of question 2, “What resources should qualify as “clean energy”.
On what basis should qualifying “clean energy” resources be defined?
·         Any credible definition of “clean” energy must take into account both greenhouse gas production and conventional pollutant production. Otherwise, what distinguishes it as “clean”?
·         Burning biomass emits similar amounts of conventional pollutants (such as NOx and CO) as coal and natural gas, and greater amounts of CO2
·         EPA’s own “boiler rule” recognizes that biomass emits as much pollution as coal. For filterable particulate matter, carbon monoxide, hydrogen chloride, mercury, and dioxins, the average emission standard set for biomass is identical to, or higher than the standard set for coal.
What is the role for energy efficiency in the standard?
·         In the real world, we need to generate a certain amount of electricity, so a clean energy standard should ask, How do we generate electricity with the least impact on air quality and the lowest carbon emissions? It is thus extremely important that efficiency be taken into account, because by governing the amount of fuel burned to create power, it also governs emissions.
·         Utility-scale biomass power averages about 24% efficiency, compared to 33% average efficiency for the U.S. coal fleet, and around 44% for modern gas plants. When efficiency is a criteria for a clean energy standard, direct-fired biomass plants and indeed many other forms of biomass energy do not measure up.
Should retrofits or retirements of traditional fossil-fuel plants be included in the standard?
·         We confine our comments to the co-firing and re-firing of coal plants with biomass. Considerable data exist to demonstrate that adding just 5 – 10% biomass to the fuel stream can reduce overall plant efficiency by 1 – 2%. Completely re-firing coal plants with wood always results in a substantial decrease in plant capacity and a decrease in efficiency.
·         Data from a proposal to co-fire biomass at the Killen coal plant in Ohio demonstrates that large increases in pollutant emissions can occur when biomass is co-fired with coal. The Killen plant proposes to co-fire 5% wood by heat content (amounting to over 8% by mass). This amounts to around 180,000 tons of wood per year, or the equivalent of the wood that could be produced by clearcutting about 2,050 acres of Ohio’s forests per year.
·         Replacing 5% of the Killen coal plant’s heat input with biomass produces no improvement in criteria pollutant emissions (SOx, NOx, and PM). However it does produce large increases in carbon monoxide (150% increase), volatile organic compounds (126% increase), and organic hazardous air pollutants such as benzene (456% increase), formaldehyde (2,135% increase), and toluene (521% increase) (see /air-pollution-2 for data). 
Should the definition of “clean energy” account only for the greenhouse gas emissions of electric generation, or should other environmental issues be accounted for?
·         For ratepayers and taxpayers to willingly support development of clean renewable energy, it is incumbent on Congress to ensure that what is delivered is actually “clean” and “renewable”.
·         Biomass energy is not carbon neutral. New science demonstrates that net emissions from using whole trees for biomass are not only higher than from fossil fuels (especially natural gas), but that they remain so over years, decades, and even more than a century, even taking forest regrowth into account. Burning biomass increases greenhouse gas emissions.
·         Forest cutting will increase to meet emerging biomass fuel demand. Even if the industry did only use “waste” forestry residues as fuel as is often claimed, co-firing this material and utilizing 50% of all the logging residues generated in the US (a generous estimate of availability) would replace only 1.7% of our current coal usage.
·         Given the prevailing climate of fiscal conservatism, there is also a new climate of skepticism about “clean” energy claims. We expect that Congress would share our aim of ensuring that any new clean or renewable energy standard actually delivers what it promises. A technology that increases forest cutting, pollution emissions, and carbon emissions does not belong in a clean energy standard.