PFPI response to Biomass Power Association, and a Challenge – Let’s Debate Biomass Power in Public

Dear Biomass Power Association,

When we put out our report last week, “Trees, Trash, and Toxics: How Biomass Energy Has Become the New Coal,” you quickly responded by emailing a statement to reporters that slammed the report, maligned our integrity, and smeared us as anti-science.

We’re reposting the statement you sent to reporters (a couple of whom forwarded it to us) so we can respond to it.  We note you’ve removed some of the more egregious parts from the version you posted on the web, but your initial, private email to reporters really deserves a response, so here it is.

But before we get started, here’s a challenge. Since you’re so sure you can demonstrate that biomass energy is “clean,” we’re challenging you to a public debate on the science.   Let’s negotiate some terms, and let’s air things out publicly.  What do you say?

Now, on to the fun. Our responses to your statements are highlighted, below.

Biomass Power Association Addresses Inaccurate Report

Rather than a scientific study, the report issued by Partnership for Policy Integrity this week should be regarded as an 81-page editorial. It showcases a fundamental misunderstanding of the science surrounding forestry and biomass, and a lack of familiarity with the state and federal laws governing energy and the environment. Governing bodies from the State of California to the nation of Denmark rightly look to biomass as a sound, proven solution for generating clean energy while keeping forests healthy, and an essential part of any renewable energy policy.

We’ll let people who actually read the report decide if it’s an editorial.

This report was not peer-reviewed, nor was it joined or supported by any credible national environmental organization.

Actually, a statement issued by Clean Air Task Force, Earthjustice, Greenpeace, Natural Resource Defense Council, The Center for Biological Diversity, the Massachusetts Sierra Club, and the Southern Environmental Law Center states that they do find the report quite useful. As, we hope, will the EPA.

Indeed, national environmental groups like the Natural Resources Defense Council (NRDC) have endorsed the use of biomass from wood waste by facilities mentioned in the report like Plainfield Renewable Energy. In a letter to the facility, NRDC wrote: “NRDC has reviewed the plans for Plainfield Renewable Energy project and found that the categories of wood you propose to use meet our criteria for environmentally acceptable wood. In particular the standard for cleaned wood from construction and demolition debris appears to exclude all of the materials of concern to NRDC.”

You’re quoting a statement made in 2007 – long before the permit for the Plainfield plant was issued in 2011. We think many people would find the contaminants allowed to be emitted quite concerning.  Here’s a table of allowable emissions from the Plainfield permit:

Placer County Air Pollution Control District, home to Cabin Creek Biomass Facility featured in the report, was awarded the 2010 Clean Air Excellence Award by the Environmental Protection Agency for its public-private solution for keeping forests healthy while generating clean energy using biomass.

We don’t mention the Cabin Creek facility in the report. Obviously that fact didn’t stand in your way when you sent your missive out to reporters.

It is unfortunately very easy to misrepresent numbers as true science. The anti-vaccination movement is a good example of this. Famous vaccination opponents like Jenny McCarthy no doubt genuinely believe they are helping kids by discouraging parents from vaccinating their children. Science – along with the sudden increase of long-extinct childhood diseases – shows the opposite is true.

Wait, what are you saying here? The “numbers” don’t support the anti-vaccination movement.  We guess you figured out this particular argument didn’t serve you well, as we note you removed it from the version of this letter that you posted on your site.

Similarly, this report uses poorly understood science to stoke fears. PFPI believes it is helping the environment – but the end result of studies like this is that, if they are taken as fact, more fossil fuels will be used for power.

We continue to review the report and collect its inaccuracies. For an initial review, we took a close look at the report’s evaluation of two recently permitted, very different type projects-one in California and the other in Connecticut.

Considering that you (inaccurately) state that we included the Cabin Creek facility in our review, we hope you’ll be more accurate about the inaccuracies in the future.

Plainfield Renewable Energy – Plainfield Connecticut

The Connecticut project, called Plainfield Renewable Energy is a $220 million biomass generation facility that uses wood derived from construction and demolition waste that would otherwise be placed in landfills, causing methane emissions-a potent greenhouse gas. When completed, it will generate enough power for 40,000 households and account for 15% of Connecticut’s renewable energy. The project has strict fuel processing requirements designed to prevent the combustion of creosote or other non-wood materials.

This is a favorite argument of the biomass power industry – that demolition waste emits methane when placed in landfills, and thus burning it, which emits CO2, is better for the climate.

However, it’s not an argument that’s supported by science. The tables from EPA’s waste report chapter on organics and the chapter on wood waste are excerpted below and show that EPA considers landfilled wood to represent carbon sequestration. While the table on organics deoes report some landfill emissions of methane (highlighted in red), the landfilling of wood is not shown as a source of methane. 

Fuel Sources and Inspection

On the subject of wood from construction and demolition used at the facility, the report questions the efficacy of the permitting process and fuel inspection, without any supporting data and without an understanding of the process for testing and inspecting fuel (pg. 56): “…the permit does at least require testing, its provisions still appear to be contradictory and unenforceable… it is not clear how effective such sorting can be, given that the sorting facilities rely on visual inspection to remove contaminated materials from a fast-traveling conveyor belt loaded with tons of debris.”

In fact, we have reviewed the literature on sorting demolition wood, and also data from a study conducted in Massachusetts for the Palmer Renewable Energy facility proposed in Springfield, MA.  That facility proposed to burn “sorted” C&D, too, but what we found is that their own data on wood contamination showed that the plant would still emit significant amounts of arsenic, lead, chromium, etc. Partially in response to our review of the sorting study, the Massachusetts Bureau of Environmental Health called for a risk assessment to be conducted on the effects of burning contaminated wood. (The state did issue a scoping study for the risk assessment, but the biomass developer decided not to burn contaminated wood, so the study wasn’t conducted).

Yet, the Natural Resources Defense Council reviewed the project and in 2007 concluded that “the standard for clean wood from construction and demolition debris appears to exclude all of the materials of concern to NRDC from an air quality and public health perspective.” The New England States for Coordinated Air Use Management-a non-profit association comprised of the six New England states-also endorsed the use of Plainfield’s fuel.

We can’t speak for NRDC, but we can examine the air permit for the plant. We don’t see any percentage limit in the permit for the amount of contamination allowed in the chipped wood fuel, and the testing requirements are thin, as well.  The permit states that the plant only has to test once a year for emissions of hazardous air pollutants, and the permit clearly has little idea, going in, how much of the contamination in the fuel will come out of the stack:


From a climate perspective, Plainfield – and indeed all biomass facilities – are a no-brainer when it comes to carbon, and vastly preferable to fossil fuel facilities. In 2009, PhD ecologists-from such institutions such as Minnesota, Princeton, Dartmouth and UC Berkley-published an analysis of biomass carbon in Science Magazine. Entitled “Beneficial Biofuel-The Food, Energy and Environmental Trilemma”-the report listed fuels considered to be “biofuels done right” because of their lower life cycle greenhouse-gas emissions profile, including municipal and industrial wastes but also sustainably harvested wood and forest residues.

A no-brainer, indeed! How does accelerating CO2 emissions to the atmosphere help combat climate change?  That’s what burning wood does, because emissions per megawatt-hour are about 150% those of a coal plant, and 300 – 400% those of a natural gas plant.

In calculating Plainfield’s CO2 emissions-indeed all CO2 emissions from the 81 facilities purportedly reviewed in the report, there is no attempt to analyze these emissions on a life-cycle basis. (Eighty-EIGHT facilities)

In other words, the emission calculations are simply what goes up the stack while ignoring the simple fact that carbon is “recycled” by a closed-loop process that takes carbon from the air in photosynthesis, resulting in the regrowth of plants. Because of this natural cycle, the science of greenhouse gases from biogenic sources like wood is undeniably and fundamentally different than the science of gases from geologic sources.

BPA, we’re just glad to hear that you agree that lifecycle accounting has its place.  Because until recently the biomass power industry has been claiming bioenergy effectively has zero emissions!

Cabin Creek Biomass Facility – Placer County, California

What about other emissions? This is where a California facility-called Cabin Creek Biomass Facility in Placer County-is particularly revealing. In 2012, the Sequoia Foundation conducted an assessment with technical assistance from the California Department of Public Health and in collaboration with Placer County Division of Planning Services and Department of Health and Human Services. The Assessment received funds from the Health Impact project, a collaboration funded by the Robert Wood Johnson Foundation and the Pew Charitable Trusts.

In California and indeed throughout the West, wood waste materials from forests is often burned in piles-causing uncontrolled emissions-or left in forests to become fuel for fires that threaten communities and ecosystems. Sequoia compared the fate of biomass if left to openly burn in piles or in forest fires versus the controlled combustion of the fuel in a biomass facility. This “alternative fate” analysis is completely missing from PFPI’s report, and for good reason. If PFPI had done such analysis, it would have come to the same conclusion that Sequoia reached.

Actually, the reason we didn’t include this analysis is, a) we didn’t include the permit for the Cabin Creek plant in the study, and b) even if we had, this plant is completely unrepresentative of the 88 plants we did review.  It’s all of 2 MW in capacity (the plants we reviewed were up to 116 MW) and probably won’t be using anywhere near the air pollution control equipment you’d find on a big biomass power plant. In fact, per unit energy, this facility is likely even more polluting than the facilities we did review.

You also failed to mention that this facility was originally proposed for the North Shore of Lake Tahoe, but met with furious opposition from opponents who didn’t want the air pollution it would bring.

From a local article:
“The situation for residents of Kings Beach, California has finally taken a turn for the better.  As we have reported, this small town set hard against the North Lake Tahoe shore has been targeted for a potentially noisy and polluting biomass energy plant in the middle of a residential neighborhood, a mere block away from the town’s only elementary school, and only three blocks from the lake itself. 

But on July 26, Tahoe Regional Planning Agency (TRPA) Executive Director Joanne Marchetta reported to the Placer County Board of Supervisors “that the Kings Beach site is ‘unworkable’ and should be removed from consideration in the project’s environmental review process,” according to a news release from the county.”

Specifically, for regulated pollutants-the same pollutants discussed in the PFPI report-the construction of the Cabin Creek biomass plant, which used the wood waste that traditionally had been open burned, resulted in staggering reductions in emissions-95 to 99 percent. Similar reductions were confirmed by Placer County in a 2011 published, peer-reviewed report in the Journal of the Air & Waste Management Associationparticulate emissions by 98%, NOX emissions by 54%, CO emissions by 97% and CO2 emission by 17%.

In other words, far from being a source of “pollution,” biomass energy projects like Cabin Creek are part of the solution, contributing to forest health and improving air quality. No wonder the California Energy Commission describes biomass in its Bioenergy Action Plan as an energy source that “creates jobs, provides local energy, enhances energy security, and helps protect public health and safety by reducing waste materials and fire danger.”

What about other claims made by PFPI? 

The report asserts that the DC Circuit invalidated a rule, requiring regulation of CO2 from biomass, when in fact the Court found that the Agency failed to adhere to the procedural rules in reaching that conclusion. PFPI fails to discuss the very exhaustive regulatory proceeding now before EPA that includes a Science Advisory Board and almost three years of hearings and analysis. That proceeding, we trust, will result in the affirmation of biomass as providing carbon benefits long recognized by many states like California and virtually every international regulatory body.

The most important conclusion of EPA’s Science Advisory Board: Bioenergy can not a priori be considered carbon neutral – and that even using “waste” wood as fuel results in a significant emission of CO2 compared to just letting it decompose. We reviewed much of the science in a report to the Securities and Exchange Commission, accompanied by a letter from investors, asking them to investigate “greenwashing” claims by certain bioenergy companies.

The report asserts that biomass plants can emit more “pollution” than fossil-fuel fired plants. That is simply incorrect. Facilities that emit less than 250 tons are very minor contributors to overall air quality. The PSD permitting program is designed appropriately to focus on larger emitters given they are the source of the vast majority of emissions in this country. Creating unnecessary permitting hurdles for small facilities discourages investment and job creation. Some states require a Best Available Control Technology (BACT) analysis for minor sources, a BACT analysis for renewable energy sources, or have state-only limits for new NOx sources to prevent deterioration of air quality outside the PSD program. For example, the Texas Commission on Environmental Quality uses a three-tier approach to evaluate the BACT analysis in minor NSR air permit applications.

The emissions numbers in the permits we reviewed speak for themselves. A biomass plant emits more criteria pollutants than a modern coal plant of the same size, and the loopholes in regulation we found mean that the biomass industry on average is far more polluting than it should be.  If you don’t agree, and you have the evidence – then meet us in public debate, and we can discuss.

PFPI claims that states use exemptions like the so-called “synthetic minor” category to allow biomass plants to skirt regulations. In fact, emission limits in synthetic minor source permits are enforceable permit conditions that must be met by the facility. The facility must operate in compliance with the emissions limits in its permits or be subject to enforcement action, permit termination, and permit revocation and reissuance as a major source permit.

Many of the permits reviewed have few enforceable limits. That’s the point. The permits aren’t being written so they are enforceable.

PFPI claims that biomass plants have no restrictions on hazardous air pollutants (called “HAP emissions”), criticizing EPA for what they call lax standards. Standards for what are called Maximum Achievable Control Technology for biomass boilers are described as lenient compared to coal (27x) especially when biomass boilers could burn up to 90% coal and are still classified as biomass boilers. In fact, EPA went through an extensive analysis of boilers in the last several years under what is called Boiler MACT, appropriately identified many different subcategories of boilers based on differences in class and type and then set MACT limits for each of the regulated pollutants. The process appropriately resulted in different HAP limits for different subcategories based on the best performing sources. Those rules are in place, going through the usual legal reviews and become effective in January 2016.

Most biomass plants are not required to limit their emissions of heavy metals, dioxins, and organic carcinogens like benzene and formaldehyde. The air permits contain no limits on these pollutants, and emissions testing for air toxics is rarely required. That is just a fact, as found by our review of 88 permits.

PFPI asserts, wrongly, that biomass boilers are burning wastes and should be regulated as incinerators. Biomass has a long tradition of safely burning various biomass residuals that reduce reliance on fossil fuels while diverting materials from landfills and reducing harmful greenhouse gases. Biomass boilers are not designed to accept “trash.” That is why EPA has an entire regulatory regime for waste-to-energy facilities. There is, and always will be, a bright line between Municipal Solid Waste and clean, organic material.

We weren’t comparing the emissions standards for biomass burners to those for Municipal Waste Combustors, as is evident if you read the report.  We were comparing the emissions standards for biomass burners to Commerical and Industrial Waste Incinerators, which must meet stricter emissions standards. If biomass plants are going to burn contaminated fuels, they should be regulated as incinerators, because under the biomass emissions rules, they are not required to limit their emissions of hazardous air pollutants.

BPA, we’d love to meet and air out these issues in a debate.  Are you going to keep hiding behind statements sent to reporters and unsigned statements on your website, or are you willing to defend your claims in public?

Partnership for Policy Integrity