Re: Provisions in legislation that would force EPA to treat wood-burning power plants as emitting zero carbon pollution
June 16, 2016
Dear Members of the Massachusetts Congressional Delegation:
The signatories to this letter are located in Massachusetts. We write to express our deep concern at recent attempts in Congress to legislate biomass energy as “carbon neutral.” These anti-environmental policy riders in the House and Senate Interior and Environmental Appropriations bills threaten our air, land, water and wildlife. We are particularly concerned about language that would undermine efforts to address climate change by mandating policies that fail to account for the carbon pollution emitted by biomass power facilities. Such language has been attached to the House bill and is in the Senate version of the bill, now in committee. These industry-crafted provisions undermine EPA’s independence to regulate carbon and other sources of pollution and weaken US leadership on global forest preservation and climate change commitments reached under the 2015 COP 21 Paris Agreement. Accordingly, we request that you make it an urgent priority to strongly oppose placement of this language, or any similar language dictating specific favorable treatment for bioenergy, in any legislation.
Utility-scale biomass plants are a highly inefficient and polluting way to generate electricity. Typical CO2 emissions at a utility-scale biomass plant are 150% those of a coal-fired plant, and as much as 400% those of natural gas facility. Theoretically, forests can regrow and capture CO2 to offset these emissions, but forest modeling shows that such regrowth takes decades, and is not adequate to recapture the full lifecycle emissions of biomass electricity production, which are significant.
(see footnote 2 for graph references).
Massachusetts removed low-efficiency biomass power from the state’s renewable energy portfolio after commissioning a study that found carbon dioxide emissions from wood-burning power plants would compromise the state’s ability to meet its established 2020 and 2050 emission reduction targets. This landmark policy is now at risk of being overruled by Congress. We do not have to imagine the outcome if such provisions are enacted, because the experience in the EU and the UK shows us that treating bioenergy as carbon neutral, and putting a price on carbon as the Clean Power Plan would do, drives large coal plants to convert to burning wood. Currently, the majority of the biomass burned in the UK is wood pellets manufactured from American forests, with a significant portion of the fuel coming from wetland hardwood forests,  that constitute some of the most important forest carbon stocks in the eastern United States. The biomass industry is eager to develop a wood pellet market that would be worth hundreds of millions of dollars here in the US, advertising wood pellets as the “easy solution” for keeping “aging coal plant assets” operating under the Clean Power Plan.
The policy riders declaring bioenergy to be carbon neutral defy climate science and the physical, demonstrable fact that burning biomass to generate electricity emits more carbon pollution than burning coal or gas. Such efforts jeopardize forests, undermine the integrity and authority of EPA, and signal internationally that our climate and renewable energy policy has been captured by industry. We thus ask that you join with your fellow MA delegation members and rigorously oppose any and all efforts to legislate biomass as “carbon-neutral.”
Thank you for your consideration,
Vice President and Director
Conservation Law Foundation Massachusetts
Nancy Goodman, Vice President for Policy
Environmental League of Massachusetts
Cindy Luppi, New England Director
Clean Water Action, Massachusetts
Sylvia Broude, Executive Director
Toxics Action Center
John J. Clarke, Director of Public Policy and Government Relations
Cathy Buckley, Chapter Chair
Massachusetts Sierra Club
Ben Hellerstein, State Director
Donna Brownell, President
Mary S. Booth, President and Director
Partnership for Policy Integrity
 From page 83 at http://appropriations.house.gov/uploadedfiles/bills-114hr-sc-ap-fy2017-interior-subcommitteedraft.pdf:
“The Administrator of the Environmental Protection Agency shall base agency policies and actions regarding air emissions from forest biomass including, but not limited to, air emissions from facilities that combust forest biomass for energy, on the principle that forest biomass emissions do not increase overall carbon dioxide accumulations in the atmosphere when USDA Forest Inventory and Analysis data show that forest carbon stocks in the U.S. are stable or increasing on a national scale, or when forest biomass is derived from mill residuals, harvest residuals or forest management activities. Such policies and actions shall not pre-empt existing authorities of States to determine how to utilize biomass as a renewable energy source and shall not inhibit States’ authority to apply the same policies to forest biomass as other renewable fuels in implementing Federal law.”
 References for figure: CO2 per MWh at power plants
a, b, c: from EIA at http://www.eia.gov/environment/emissions/co2_vol_mass.cfm. Value for coal is for "all types." Different types of coal emit slightly more or less.
d: Assumes HHV of 8,600 MMBtu/lb for bone dry wood (Biomass Energy Data Book v. 4; Oak Ridge National Laboratory, 2011. http://cta.ornl.gov/bedb.) and that wood is 50% carbon.
a: DOE National Energy Technology Laboratory: Natural Gas Combined Cycle Plant F-Class (http://www.netl.doe.gov/KMD/cds/disk50/NGCC%20Plant%20Case_FClass_051607.pdf)
b: International Energy Agency. Power Generation from Coal: Measuring and Reporting Efficiency Performance and CO2 Emissions. https://www.iea.org/ciab/papers/power_generation_from_coal.pdf
c. EIA data show the averaged efficiency for the U.S. coal fleet in 2013 was 32.6% (http://www.eia.gov/electricity/annual/html/epa_08_01.html)
d: ORNL's Biomass Energy Data Book (http://cta.ornl.gov/bedb; page 83) states that actual efficiencies for biomass steam turbines are "in the low 20's"; PFPI's review of a number of air permits for recently proposed biopower plants reveals a common assumption of 24% efficiency.
 Manomet Center for Conservation Sciences. 2010. Massachusetts Biomass Sustainability and Carbon Policy Study: Report to the Commonwealth of Massachusetts Department of Energy Resources. Walker, T. (Ed.). Contributors: Cardellichio, P., Colnes, A., Gunn, J., Kittler, B., Perschel, R., Recchia, C., Saah, D., and Walker, T. Natural Capital Initiative Report NCI-2010- 03. Brunswick, Maine.
 See https://www.dogwoodalliance.org/wetland-investigation-3-16/ for photos of wetland forest clearing by Enviva, the largest pellet manufacturer in the US.