Biomass thermal energy pollutes, solar energy doesn’t – why subsidize both?

A bill in the Massachusetts Legislature, S. 1593  – “An Act Relative to Credit for Thermal Energy Generated with Renewable Fuels” would provide alternative energy portfolio subsidies to “thermal-only” biomass, along with other “thermal-only” technologies.

PFPI and the Project for Energy Accountability (formerly the Biomass Accountability Project) have written testimony on the bill.  We’ve included the introduction below; click here to see the rest of our comment letter, and here to see what a more careful thermal bioenergy policy could look like.

Comments are due in August. We encourage others to submit comments on the bill.


Dear Chairman Downing, Chairman Keenan, and Members of the Committee,

It was exactly a year ago that Massachusetts finalized regulations on large-scale biomass energy after a long and difficult public process. The Massachusetts rules are the first science-based regulations in the country to recognize that utility-scale biomass energy is a large net source of greenhouse gas emissions, and as such, should not receive renewable energy subsidies.   With regard to conventional air pollution, it is increasingly recognized that biomass energy is very polluting – for instance, the Massachusetts Medical Society has passed a resolution opposing biomass energy because it poses an “unacceptable risk” to human health,[i] and the American Lung Association not only opposes subsidies for bioenergy,[ii] but also “strongly opposes the combustion of wood and other biomass sources at schools and institutions with vulnerable populations.”[iii]

However, looking at S. 1593, it is as if none of those policy developments ever occurred. As written, the bill shows no awareness or concern for impact that “thermal only” bioenergy may have on greenhouse gas emissions, air quality, or forests. Its construction is so open, even the biomass energy proponents who have commented on the bill have called for it to be made more restrictive.[iv]

We believe the inclusion of biomass energy in S. 1593 is like a rotten apple that is going to spoil the barrel for the truly “clean” technologies that would be promoted by this bill, and that it should be excluded altogether. This bill would subsidize a technology, wood burning, that is one of the largest sources of air pollution in the U.S., a technology that actually causes people to get sick and die. This is not an exaggeration. The effects of particulate pollution on respiratory and cardiac health are well-known and characterized by a linear response that extends below the current EPA health threshold. “Natural experiments,” such as the example of how traffic restrictions during the Atlanta Olympics led to decreased particulate levels and lower hospitalization rates for asthma,[v] confirm that reducing pollution pays dividends virtually immediately in improved health and reduced medical costs. Conversely, “bad air days” are accompanied by increased rates of respiratory and cardiac incidents. Regional air quality  monitoring does not reflect the intense patches of air pollution that can develop in certain areas, so that air quality is very poorly characterized at the local level. If you are an asthmatic, the pollution emitted by even a “well controlled” biomass burner in your neighborhood can put you in the hospital, particularly if it is adding to the existing burden of air pollution.

It also seems strange to see bills. 1593 offered as it is, given the efforts that were expended by all in recent years – citizens, environmental groups, and government officials – to enact a serious and science-based policy on utility-scale bioenergy. In that context, the present promotion of “thermal-only” bioenergy with absolutely no scrutiny or side-rails of any kind is incompatible with the standard previously set by the State.  The bill almost looks like an “end-run” around Massachusetts’ new biomass regulations, given that it contains no efficiency standards, which are essential to reducing net greenhouse gas emissions from bioenergy and therefore a critical component of the new rules. If biomass energy continues to be included in S. 1593, the bill needs to be dramatically rewritten, but only after a science-driven public process that scrutinizes the real impacts of “thermal only” bioenergy on greenhouse gas emissions, air quality, and forests.  The people of Massachusetts deserve no less.


[i] Massachusetts Medical Society. “Massachusetts Medical Society Adopts Policy Opposing Biomass Power Plants.” Press release, December 9, 2009

[ii] Letter from American Lung Association to Representatives Waxman and Markey, requesting that bioenergy not be subsidized as renewable energy under the American Clean Energy and Security Act. June 24, 2009.

[iii] American Lung Association Public Policy Position on Energy. Approved June 11, 20011.

[iv] Testimony of the Massachusetts Renewable Thermal Coalition on S. 1593, July 16, 2013.

[v] Friedman M.S., et al. 2001. Impact of changes in transportation and commuting behaviors during the 1996 Summer Olympic games in Atlanta on air quality and childhood asthma. Journal of the American Medical Association 285:897-905.

Partnership for Policy Integrity