It's bad enough that the baseline emissions estimates for the proposed Clean Power Plan treated biomass as having zero emissions, but now it's clear that the CPP treats municipal waste burning as zero-carbon, too. Not just "biogenic" muni waste, but all muni waste - plastics, tires, pretty much anything one can imagine. Naturally, this should come as fantastic news to the biomass and waste industries, but perhaps not so much to those communities forced to endure the pollution that these bogus "clean energy" industries inflict.
This week, PFPI sent a letter to the Office of Management and Budget, which is currently reviewing the Clean Power Plan, to draw attention to this problem. This letter follows an earlier letter signed by 14 groups asking for bioenergy to be removed as a compliance measure in the Clean Power Plan. Will EPA fix this problem? Can they? We should find out soon, as the final Clean Power Plan is supposed to be released in the next couple of weeks.
Here's the analyis showing EPA treats both muni waste burning and biomass as having zero carbon emissions.
Office of Management and Budget
Office of Information and Regulatory Affairs
1800 G Street, NW
9th Floor
Washington, DC 20006
July 22, 2015
Dear Mr. Frey,
Thank you for meeting with us last week to discuss bioenergy in the Clean Power Plan. We wanted to follow up with an example of how not counting bioenergy and waste emissions distorts CPP estimates and creates perverse incentives. These examples underscore that bioenergy and waste energy cannot serve as the best system of emissions reduction for climate pollution from the power sector.
Your colleague asked about "non-forestry" bioenergy emissions. While we and others have emphasized the CPP's treatment of wood-burning power plants as having zero emissions, it has gone little remarked that the CPP also treats municipal waste burning as having zero emissions. In fact, in the proposed rule, it appears that EPA has treated all waste burning – even fossil-fuel derived materials such as plastic and tires – as having zero emissions. EPA’s rate equation[i] fails to count these emissions because the numerator does not include emissions from non-covered sources like municipal waste incinerators or biomass power plants, but the denominator does count the electricity generated at these facilities.
The example below,[ii] from Maine, shows how excluding emissions from biomass and waste burning affects EPA's baseline emissions rate estimate. Maine generates a high proportion of its electricity from burning wood, and also has four incinerators that burn municipal waste.
EPA's 2030 target rate for Maine is 378 lb CO2/MWh, which clearly depends on the current baseline estimate of 437 lb CO2/MWh – an estimate that excludes bioenergy and waste emissions.
We are aware that in a recent meeting at OMB, a New Hampshire representative expressed hope that the CPP would recognize RGGI as a means of compliance with the CPP, as well as "low emitting" renewables like bioenergy.[iii] Unfortunately, the RGGI program also treats bioenergy as having zero emissions, "baking in" the carbon neutral assumption here as well.[iv] As for New Hampshire's commitment to bioenergy, EPA's facilities datafile shows two municipal waste incinerators in the state with an averaged emissions rate of 4,242 lb CO2/MWhr, and six wood-burning facilities with an averaged emissions rate of 3,162 lb CO2/MWh. The 2012 tally did not yet include a new 70 MW wood-burning power plant in Berlin, NH, which, according to its air permit,[v] consumes 113 tons of "whole logs" per hour (a USFS report[vi] finds aboveground biomass in NH forests is around 138 tons/acre). At full-time operation this facility would consume close to a million tons of wood a year and emit about 3,085 lb CO2/MWh.[vii]
Inclusion of bioenergy and waste-burning as compliance measures have a distorting effect on baseline emissions rates, which in turn serve in the proposed rule as the basis for the 2030 target rates. Further, the low efficiency of bioenergy and waste incineration makes these technologies highly polluting per megawatt-hour, so that where they are used as compliance they will undermine the substantial health benefits anticipated from clearer skies under the Clean Power Plan. We urge OMB to reject bioenergy and waste-burning as compliance measures in the CPP, and only include technologies that produce immediate and verifiable reductions in carbon and air pollution emissions.
Thank you again for your time.
Mary S. Booth, PhD.
Director, Partnership for Policy Integrity
Dusty Horwitt, Esq.
Counsel, Partnership for Policy Integrity
[i] Goal Computation Technical Support Document for the Clean Power Plan, page 16.
[ii] Numbers were taken from the Excel datafile that EPA provided in support of the CPP ("TSD Egrid Methodology") and also Goal Computation Technical Support Document at page 25.
[iii] Inside EPA. "EPA's State Supporters Urge White House To Finalize Strong ESPS." July 15, 2015
[iv] From https://www.rggi.org/market/tracking/data/emissions : "CO2 emissions from eligible biomass reduce the total CO2 allowance compliance obligation of the emitting unit."
[v] http://www.pfpi.net/wp-content/uploads/2011/06/100726air_permit.pdf
[vi] http://nsrcforest.org/sites/default/files/uploads/hooverfull06.pdf
[vii] Based on specs from air permit: 1,013 MMBtu/hr boiler, 70 MW gross output, and fuel moisture content of 50%.