The Department of Energy Resources is proposing to roll back most of the rules that keep large, polluting biomass plants from getting renewable energy subsidies in MA.

DOER has rescheduled the final public hearing on the rollback (Springfield) for June 5th.

Please scroll down for info on the hearing.

Click here to sign the petition to get polluting technologies out of our renewable energy supply!
Email us if you want to be added to the list-serve where we post updates and detailed talking points, discuss issues, and answer questions.

Meanwhile: we also STILL NEED YOU TO PLEASE call and write your legislators ASAP to say you support passing H.853, “An Act to assure the attainment of greenhouse gas emissions goals in the alternative portfolio standard”

Which would take biomass out of the Alternative Portfolio Standard. The bill was heard in committee Tues May 7th.  It went well, so NOW is the time to send your state legislators a quick note saying you support the legislation, and further, you want the bill amended to take biomass burning out of the Renewable Portfolio Standard, too.  

Click here to see an description of the bill, with information on why legislators should support it.

Click here to see talking points on the bill.

Click here to see the detailed comment letter we (and 13 other groups) submitted on the problems with biomass in the APS (the letter was ignored – DOER did not make any recommended changes)

Click here to find your MA legislators!

See table below for an explanation of the difference between the Alternative Portfolio Standard and the Renewable Portfolio Standard. See our memo  (or read further down on this page) for an explanation of why the APS bill should be amended to take wood-burning out of the RPS.

Info on June 5 DOER hearing and comment process for biomass regs rollback
Last chance to say your piece!  DOER scheduled a fourth and final hearing in Springfield at the request of EJ groups who have been fighting against the proposed Palmer Renewable Energy (PRE) biomass power plant for the past decade. DOER’s proposed rule changes would allow PRE to receive $10-12 million in renewable energy credits each year – while polluting an economically distressed EJ community that already suffers the worst asthma problems in the nation.

Stand in solidarity with Arise for Social Justice and other Springfield groups at a massive stand out before the public hearing and tell DOER “Don’t Pay Polluters – We BREATHE What They BURN!” 
DATE:              Wednesday, June 5, 2019

RALLY:           5:45 pm

                       
HEARING:        6:30 – 8:30 PM John J. Duggan Academy Auditorium
1015 Wilbraham Road
Springfield, MA 01109

Click here for talking points for testimony at the hearing.

Verbal and written testimony will be accepted at the hearings; however, the state asks parties to provide written copies of their testimony. 

It’s never a bad idea to write out your spoken testimony in advance. They usually let people speak for three minutes. Three minutes is about 500 – 600 words if you talk fast (~2/3 of a page). We recommend practicing your testimony and timing it before giving it in public – let us be the ones who are concise and impactful!

 

You can also submit written comments on the RPS Regulations (any length) until 5 PM on June 7, 2019. Please submit written comments on the RPS Class I and RPS Class II regulations to John Wassam electronically to DOER.RPS@mass.gov or via mail to the Department of Energy Resources, 100 Cambridge Street, Suite 1020, Boston, MA 02114.
DOER has posted the proposed changes to the RPS here.

All the core requirements of the 2012 RPS bioenergy rules have been greatly reduced or completely eliminated in DOER’s proposed rule changes.

• Facility efficiency criteria would be reduced, or, for plants burning broadly defined categories of “salvage” wood, completely eliminated, allowing construction of massive electric-only plants, instead of the small, efficient combined heat and power (CHP) plants that were promoted under the 2012 rules. This will open the door to giving subsidies to the proposed “Palmer Renewable Energy” plant in Springfield, which would dramatically increase pollution emissions in the region (more details to come about this plant)
• Plants would be allowed to burn a huge variety of woody fuels, including whole trees, that DOER has classified as “residues” to allow calculation of a minimal carbon impact, even though the Manomet definition of residues was confined to tops and limbs from sawtimber harvesting.
• The requirement that facilities show a net reduction in GHG emissions relative to fossil fueled plants within 20 years would be changed to a 30-year timeframe. The 20-year timeframe is already too long, according to climate science, making the 30-year timeframe look totally mad by comparison.
• The calculations for determining the lifecycle CO₂ emissions from bioenergy ignores fossil fuels burned during harvesting, processing, and transport of biomass – even though such emissions can be considerable for certain fuels, especially wood pellets.
• Requirements for liquid fuels to show a real reduction in GHG’s relative to fossil fuels are eliminated by substituting a calculation approach that treats all biomass feedstocks as having zero emissions
• All the Massachusetts-specific forest harvesting criteria that were designed to protect forests, maintain soil fertility, and protect from overharvesting, are eliminated and replaced by vague and unenforceable forest industry language about “sustainable harvesting.”

The proposal also weakens requirements for controlling emissions of air pollutants from biomass, especially particulate matter, and opens the door to using contaminated and even hazardous wastes as fuels and feedstock, a topic that has caused enormous concern and controversy in the past.  It also eliminates any means of citizen oversight and reduces DEP oversight in matters of health and safety, ceding more authority to DOER in matters where the Department has little expertise. Further, though not discussed here, the rules will increase Class II RPS subsidies to garbage incineration, helping these massively polluting facilities continue to operate.
More background: here’s what going on with wood-burning in Massachusetts Renewable energy is mandated in Massachusetts to help the state reduce greenhouse gas emissions and fight climate change. MA residents pay extra on their electric bill to fund a pot of money that the state doles out as subsidies to the operators of renewable energy generators (wind farms, solar panels, and, sad to say, garbage incinerators and wood-burning power plants).  These subsidies can be worth millions of dollars per year to an individual company.
MA ratepayers fund two main programs that subsidize renewable energy – the Renewable Portfolio Standard (RPS) and the Alternative portfolio Standard (APS).  Both subsidize wood burning and garbage burning – and both are in play right now and need your input, as Table 1 describes.
Renewable Portfolio Standard (RPS)                     Alternative Portfolio Standard (APS)

What it subsidizes: Renewable electricity generation (wind, solar, biomass/wood, garbage)	What it subsidizes: Recently expanded to include renewable heating (solar, geothermal, wood)
Rules for wood burning plants: Includes wood-burning power plants under strict rules that govern efficiency, pollution, and carbon emissions. (See below for more on the history of the regs and what’s at stake).	Rules for wood-burning units: Allows wood-burning boilers under lax rules which were enacted despite opposition from scientists and health professionals. See here for overview of problems.
What’s in play now: Protective regulations that restrict biomass in the RPS are being dismantled by the Baker administration’s Dept. of Energy Resources (DOER). By weakening the regulations, the DOER is opening the door to the wood-burning power plants that the state already rejected years ago.  DOER is also proposing to increase financial support for garbage incinerators.	What’s in play now: Lawmakers are considering great new legislation that would remove subsidies for wood-burning from the APS so that it would only support zero-emissions renewable energy – instead of dirty wood burners! The HEARING on the APS bill is Tuesday, May 7th at the Statehouse, 1 pm – 5 pm on Tues May 7th in Hearing Room A2.  If you want to attend the hearing (you can give a short statement) great – but what’s easier and just as important is calling and writing your legislators to say you support the bill. Please do this asap to increase the chances of the bill surviving!
What you can do: Sign the petition; Attend the Springfield hearing June 5th; send written testimony (read above for details).	What you can do: Please call or write your legislator to say you support H. 853, “An Act to assure the attainment of greenhouse gas emissions goals in the alternative portfolio standard“ Click here to find your MA legislators!

Table 1.
WE ARE IN A CLIMATE EMERGENCY. Does anyone think we need more CO₂ in the atmosphere now? But that’s what the Baker administration’s proposed changes to the RPS will do – send more forest carbon into the atmosphere.  We need the public to weigh in on these programs NOW – because bottom line, we all know it’s never been more urgent to reduce greenhouse gas emissions and protect forests, even if the Baker administration doesn’t.

Recap on the Massachusetts biomass rules: how we got here, what’s at stake

Climate science shows that to avoid catastrophic warming, we must reduce emissions and take CO₂ that’s already in the atmosphere out – most likely by restoring and expanding forests.  We need to cut our net emissions in half in the next ten years, and reach emissions neutrality – with emissions balanced by uptake – by 2050. (See our summary of the latest climate science from the IPCC – including the call for a reduction in bioenergy generation! – here).

That’s why burning forest wood for energy is so counterproductive. Wood is technically renewable, but wood-burning power plants emit more CO₂ per unit energy than fossil-fired plants, pumping greenhouse gases into the atmosphere just when we need most to reduce emissions. Forests cut for fuel may grow back eventually to offset those emissions, but this takes decades to more than a century. The result is a net increase in CO₂ emissions to the atmosphere just when it’s most important to reduce emissions.

This was the big finding of the Manomet Report that was commissioned by Massachusetts to inform the state’s biomass energy policy. The study concluded that net emissions from wood-burning power plants that burn a mixture of trees and forestry residues exceed emissions from a same-sized coal or gas plant  for years to decades (even under a best-case scenario that assumes forests grow back perfectly). The study was published in a peer-reviewed journal – you can download it here. See Table 2 for the outcomes of Manomet; see further below for an explanation of why it matters if fuel is sourced from whole trees or residues.

Table 2. The main conclusions of the Manomet Study: Even assuming efficiency of 80% or more for thermal-only units, it takes 15 – 30 years for net CO₂ from biomass units to be drawn down to the same level of an oil burner, and 60 – 90 years for gas.  For electricity-only plants, where efficiency is around 24%, it takes much longer for net emissions to fall to the same level as net emissions from a fossil-fired plant.

The Manomet Study was commissioned by the state because back in 2008 or so, there were three big wood-burning power plants proposed Massachusetts (in Russel, Greenfield, and Springfield. The Springfield plant, confusingly named “Palmer Renewable Energy,” may still be built – see below). Scientists and activists came together to defeat these proposals, in part by launching the “Stop Spewing Carbon” campaign, a petition drive for a ballot measure that would have taken most polluting energy sources out of the state’s Renewable Portfolio Standard (RPS).  The petition drive collected over 100,000 signatures and qualified for the ballot. In the meantime, however, DOER had realized there was a problem with CO₂ pollution from wood-burning plants, and had commissioned the Manomet Study to inform state policy. When the Manomet Study was completed, the state agreed to issue a science-based set of rules eliminating subsidies to the most polluting biomass plants, and the ballot measure was set aside.

Finalized in 2012, the Massachusetts biomass rules became the first in the nation and the world to recognize that burning trees for energy increases emissions just when we should be reducing them. The whole process took about four years, and involved the multi-investigator Manomet study, many public meetings, and thousands of hours of time by citizens and concerned scientists who weighed in to make sure the state’s rules were based in science.

Now, unbelievably, we have to defend those rules, AGAIN – because they are under attack by the Baker administration. DOER is proposing rolling back the rules enacted in 2012, with changes that will lead to more forests being cut for fuel, more CO₂ in the atmosphere, and more climate damage. It even seems likely the rule changes will help at least one of the three large biomass plants be built (Palmer Renewable Energy in Springfield.). Adding insult to injury, all of this will come at great cost to ratepayers, who pay millions to support this polluting technology – money that could be allocated instead to residential heating efficiency (nega-watts!) and lower/zero emissions technologies.

The 2012 RPS rules still allowed biomass power plants to get subsidies, but the plants would have to meet strict efficiency criteria, so that only efficient combined-heat-and-power (CHP) plants would qualify, and not the large inefficient electricity-only plants that had been proposed. Biomass power plant operators were required to provide fuel supply plans that would demonstrate they were getting the majority of their fuel from “forestry residues,” not whole trees (see appendix below for why the type of wood matters). The cumulative net carbon impact of biomass power plants had to be 50% that of a natural gas plant after 20 years, which at this point seems absurdly long. 

Now, the Baker administration wants to rewrite those rules to make them more favorable to the biomass industry, including weakening and even eliminating plant efficiency requirements, removing fuel supply requirements to allow burning more whole trees, and the requirement to show a “benefit” relative to fossil fuels in 20 years (the Baker administration is changing it to 30 years, because apparently, they know better than the climate scientists, and think addressing global warming isn’t that urgent). They’re also weakening requirements for emissions of “conventional” pollutants (e.g. particulate matter) and removing requirements for citizen oversight and oversight by the MA Dept. of Environmental Protection (DEP), the agency that safeguards our air quality. The rules will even increase subsidies to garbage-burning! These changes represent a total betrayal of a hard-won compromise and agreement from 2012, to say nothing of the 100,000+ people who signed a petition to take ALL biomass out of the RPS. DOER apparently got an earful from the forestry and biomass industries that the biomass rules were too restrictive – so now they’re rewriting them. (Not unlike the Trump administration, the Baker administration DOER seems to contain people who advocate for the industries they represent, rather than regulating them.)

It’s a similar story with the Alternative Portfolio Standard (APS). After the RPS rules went into place in 2012, and it became clear that the large wood-burning plants would probably not be built, the forestry and biomass lobby went into high gear, and working with DOER, added biomass thermal energy to the APS, which had previously been a catch-all program that provided subsidies to a few technologies that the state wanted to incentivize, but that did not really qualify as “renewable” energy (such as combined heat and power). Along with solar and geothermal heating, biomass heat-only units were made eligible for public subsdies (as were biomass combined heat and power plants, just like in the RPS – except the APS contained none of the protective rules the RPS contained. Click here for an overview of the differences between the programs).
It took a few years to get the APS regulations finalized. Scientists and activists fought to keep the APS “clean” by advocating that it only include zero-emissions thermal sources (like solar and geothermal) but the wood industry was powerful, and they got biomass thermal added. It seemed like at every round of public comment, the DOER had further weakened the APS regulations (you can see some of our comment letters here). We ended up with lax regulations that promote the wood fuel that can be the most carbon-intensive – wood pellets. (Click here for a presentation summarizing some of the problems with the APS).
We’ll be sharing our summary of the impacts of the proposed rule changes to the RPS, and how the new rules will combine with the newly enacted APS thermal standard to undermine forest and climate protection in Massachusetts. Please stay tuned for that. In the meantime, though, legislators need to hear from you that you support the bill to take biomass OUT of the Alternative Portfolio Standard. You can find your legislator’s contact information here.  DOER’s lax standards for biomass in the APS, and DOER’s proposal to gut the hard-won biomass RPS rules from 2012, shows the Baker administration can’t be trusted to put the interests of forests and the climate above the biomass industry demands. They had their chance to show they take climate change seriously, and they’ve blown it, so now we the people need to act.

 

Appendix: Net carbon impacts of different types of wood fuel

Determining the carbon impact of burning these for fuel requires comparing the emissions from combustion to the emissions from an alternative fate. The type of wood burned is thus important to the net CO₂ emissions impact. There are four main categories of fuel.
Mill residues: wood shavings, sawdust, bark. “Clean” mill residues can be burned directly or made into wood pellets.

• Mill residues are considered to have relatively low net carbon impact if the alternative fate of this material is to decompose (emitting carbon) or be burned without energy recovery.
• However, if this material would have been used for some other purpose (e.g. particleboard), then burning it for energy can force the former user to go out and harvest more trees (“leakage”) which increases emissions.

 

Forestry residues: tree tops and limbs left over after sawtimber harvesting.

• Forestry residues have been considered to have relatively low net carbon impact if the alternative fate of this material is to decompose. However, the net carbon impact of burning residues is still significant – especially in a world where we want to limit emissions now.  PFPI published a paper on this (and there’s a short video abstract if you’re not in a reading mood) – available here.
• The relatively low net emissions impact of residues in the Manomet Study and the subsequent regulations by MA means that DOER (and foresters) want to call everything residues. True residues are the by-product of sawtimber harvesting. Cutting trees and calling them “residues,” as the forest industry tends to do, is not legitimate and significantly increases the net emissions impact.

 

Trees: Whole trees that are cut specifically for fuel, or trees that are “thinned” because now there is a market for the wood.

• Trees are considered to have the highest carbon impact because if they were not cut and burned for energy, they’d either continue growing and taking carbon out of the atmosphere; OR, they’d be harvested for some other purpose, potentially a long-lived wood product that locks up some of the tree’s carbon away from the atmosphere.
• And as with mill residues, if the trees would have been used for some other purpose (e.g. pulp and paper) and now they are harvested for bioenergy, that means the paper industry needs to go cut trees somewhere else – hence, more leakage, and more emissions. (Note:  if the paper industry went out of business already, then harvest for paper isn’t the “alternative fate” anymore. Now, the alternative fate is for the forest to continue growing and sequestering carbon. That’s why claims that biomass harvesting is simply taking up the slack from the dying paper industry in New England don’t change the fact that cutting and burning trees means the atmosphere sees more CO₂than under an alternative scenario).

 

Construction and Demolition Debris wood (CDD): This material tends to contain relatively high concentrations of toxics like lead, the pressure-treatment chemicals arsenic and chromium, pentachlorophenol, and other contaminants that are released by burning chemically treated and glued wood.  Proponents of burning this material say it can be sorted to remove the most contaminated materials, but there is no evidence this produces a clean fuel source.

• In terms of carbon impact, recycling the clean wood rather than burning it would increase carbon sequestration and reduce forest harvesting. Contaminated wood can be landfilled, where it represents sequestered carbon (and is actually counted as such in the US greenhouse gas accounts). Burning contaminated wood, if it must occur, should only be done in incinerators with especially tough emissions controls to help reduce toxic emissions. The biomass industry has fought hard, however, to get contaminated wood classified as “biomass” so that they can burn it anywhere (see our “Trees, Trash, and Toxics” report on the loopholes in air permitting for biomass).