The scammy, whammy world of the “bioeconomy” – a warning to regulators on National Bioenergy Day

On National Bioenergy Day, how better to celebrate than by publishing PFPI’s response to OSTP’s request for input on the bioeconomy.  What is it about this sector that makes it so prone to scams? Obviously the biggest scam is burning biomass and claiming it’s “sustainable” so there are no emissions… but the sector as a whole sometimes seems to attract the type who take advantage of the credulity of the public around “green” claims. 

Comments to Office of Science and Technology Policy from Partnership for Policy Integrity Regarding Request for Information on the Bioeconomy

October 22, 2019

Download these comments here. 

Submitted via email at: MBX.OSTP.WHBioeconomy@ostp.eop.gov

Partnership for Policy Integrity is pleased to submit these comments to the Office of Science and Technology Policy in response to its request for input on the U.S. Bioeconomy. Founded in 2010, our organization has focused on highlighting and reducing the forest and carbon impacts of burning wood for electricity, a form of power typically called bioenergy or biomass power. We have also researched other biomass-based products including biofuels, biochar, and lubricants.
 

Our analyses have found that bioeconomy firms often provide misleading and unsubstantiated information to investors, policymakers, and the general public, sometimes resulting in significant investment losses. We have submitted two reports and one petition to the U.S. Securities and Exchange Commission, supported by as many as 34 sustainable investment organizations, detailing the misleading or unsubstantiated claims that a dozen or more biomass-based companies have made about their products’ environmental benefits, particularly that these products result in lower greenhouse gas emissions.[1] Our petition earlier this year to the SEC received coverage in the Wall Street Journal and included information about inflated claims related to biomass-based products that bilked investors and taxpayers out of millions of dollars. In 2014, we submitted a report to the Federal Trade Commission examining marketing claims by 17 biomass energy companies. We found that the companies appeared to routinely violate consumer protection standards and make misleading claims in advertising and promotional materials that their wood-burning power plants are “clean” and “carbon neutral.”[2] In 2018, we published a report about the fate of 25 biomass power plants that had each received $10 million or more in federal “Stimulus” grants. We found these plants often had cost overruns and imposed inflated costs on taxpayers and ratepayers.[3]
 

Based on our knowledge of the bioeconomy and President Trump’s position that human activities are not causing climate change, it is a bit odd that the Office of Science and Technology is asking for comments that “will guide the transformation and expansion of the U.S. Bioeconomy” and “support the growth of the Bioeconomy.” Bioeconomy companies routinely tout as central to their businesses their abilities to reduce carbon dioxide emissions that are contributing to climate change. This focus is seemingly inconsistent with President Trump’s denial that such emissions are a problem, raising questions about why the administration wants to support the industry.
 

In any event, we urge caution before devoting additional tax dollars to bioeconomy firms. Our specific recommendations for guiding the bioeconomy address the four questions that the Office has asked, but particularly numbers 1 and 4.
 

What specific actions could the U.S. Government take to reinforce a values-based ecosystem that will guide the transformation and expansion of the U.S. Bioeconomy, in both the short- and long-term?
In what ways can the U.S. Government partner with the private sector, industry, professional organizations, and academia to ensure the training and continued development of a skilled workforce to support the growth of the Bioeconomy?
In what ways can the U.S. Government partner with the private sector, industry, professional organizations, and academia to establish a more robust and efficient Bioeconomy infrastructure?
Across the spectrum, from basic discovery to practical application, what data policies, information-sharing mechanisms, and safeguards will be necessary for a prosperous U.S. Bioeconomy?
 

Summary
We are a bit unclear what the term “values-based ecosystem” means, but two of the values that should guide the U.S. bioeconomy are scientific integrity and fiscal responsibility. To ensure both and to establish safeguards that protect our environmental and financial health, the U.S. Government should accurately account for the greenhouse gas emissions from biomass-based products and avoid policies that actually exacerbate emissions while claiming “carbon neutrality.” The government should also carefully evaluate the financial realities of bioeconomy firms to determine whether the firms will be able to produce the quantities of biomass-based products they claim and whether such products will contribute to environmental degradation.
 

Environmental Concerns about the Bioeconomy
Most bioenergy, whether derived from liquid biofuels or solid biomass, is treated as “carbon neutral.” However, there are now a large number of studies demonstrating that the net carbon impacts of bioenergy can be significant. Regarding forest biomass, despite claims that bioenergy is “low carbon” or “carbon neutral,” wood burning power plants emit more carbon dioxide per unit of electricity than fossil fueled plants. Cutting forests and burning the wood for fuel incurs a large carbon debt – that is, terrestrial carbon that is released to the atmosphere, which must be “paid back” by forest regrowth for any semblance of “carbon neutrality.” Proponents of bioenergy have often relied on the idea that such regrowth will render bioenergy carbon neutral. The problem is, growing forests takes a long time. Several peer reviewed studies[4] and scientific bodies, including recently for instance the European Academies Science Advisory Council,[5] have concluded that burning trees for fuel increases net emissions relative to fossil fuels for decades to more than a century, meaning that biomass power plants worsen atmospheric carbon dioxide loading in the 12-year-timeframe specified by the Intergovernmental Panel on Climate Change as critical for reducing emissions.[6] A multiyear EPA task force concluded this year that burning wood can have significant net emissions,[7] but even before the panel had completed its work, Maine Senators Susan Collins and Angus King, both strong biomass boosters, shoehorned a rider into a 2018 congressional appropriations bill that forces the EPA to treat forest biomass as carbon-neutral.
 

There are examples of responsible policymaking: a study commissioned by the State of Massachusetts determined that net emissions from biomass power plants would be significant enough over decades to undermine state-mandated efforts to reduce greenhouse gas emissions from the power sector. Massachusetts consequently ended renewable energy subsidies for utility-scale wood-burning power plants in 2012.[8] The District of Columbia enacted a similar law in 2015.[9]
 

Another argument used to justify claims of biomass energy “carbon neutrality” is that if mill or forestry residues are used as fuel or pellet feedstock (i.e., treetops and branches left over from logging operations), emissions from combustion are no greater than the emissions from letting the material decompose, rendering the material effectively carbon neutral. However, even under industry best-case scenarios where no new trees are cut for fuel, and only forestry wastes are used, burning biomass has significant net emissions that persist for decades.[10]
 

A third argument made in support of bioenergy is that as long as forests are growing more wood than is being cut, and are thus harvested “sustainably,” burning any of that wood has zero net emissions. This is the concept that underpins the Collins rider in the Appropriations bill. By this logic, even as the biomass industry cuts more trees, it must claim offsetting carbon uptake in an ever-increasing area of forests elsewhere to neutralize those emissions. But this notion quickly bumps up against the reality that the amount of carbon locked up in forests is decreasing globally according to a recent study;[11] there is no instantaneous regrowth that is compensating for all the supposedly sustainable harvesting. (The correct accounting approach, in fact, recognizes that forest carbon uptake is already counted as offsetting a portion of existing fossil-fuel emissions; the biomass industry’s claim seeks to double-count that benefit.)
 

Other biomass-based products such as biofuels often rely on annual crops that have much shorter growing rotations than trees. But even these products may not be “carbon neutral” or “low carbon.” On the one hand, the biomass portion of the fuel’s net emissions is considered carbon-neutral because yearly crop regrowth and carbon uptake are assumed to offset the CO2 emitted by fuel combustion the year before. However, the U.S. Government should also consider emissions of fossil fuels burned during biofuel production and transport, and significant indirect emissions, including those related to carbon loss from land use change that occurs when demand for biofuel causes farmers to convert grasslands, forests or wetlands to farmland in order to grow additional energy crops. EPA requires such analysis in order for biofuels to meet the Renewable Fuel Standard.[12] When all of these emissions sources are considered, the lifecycle emissions for biofuels can be greater than emissions from burning fossil fuels.
 

Because of these realities, the U.S. government should conduct rigorous greenhouse gas accounting for any biomass-based products that includes the annual carbon dioxide emissions from use or combustion of the biomass; total lifecycle greenhouse gas emissions from production, use and disposal of the biomass; direct and indirect land use change; and scrutiny of any assumptions that new plant growth will offset emissions from the manufacture, use, and disposal of the product. The government should avoid providing subsidies to biomass-based products that have total lifecycle greenhouse gas emissions that are worse than alternative products.
 

Financial Concerns about the Bioeconomy
The U.S. government should also focus on fiscal integrity when it comes to the bioeconomy. PFPI has found that bioenergy firms are often poor investments for both governments and private citizens. Our report on the 25 “open loop” biomass facilities that received $10 million or more in Stimulus funds found that collectively, these facilities received $856,701,874. We found that seven of these plants were closed, idled, or partially idled, largely due to their inability to compete with less expensive electricity from wind or natural gas – even with hefty subsidies. Five of the plants entered into long term power purchase agreements requiring ratepayers to pay above market prices for their electricity. Thirteen of the plants received additional state and federal grants and loans, in some cases exceeding the stimulus grant. And 17 of the plants violated federal clean air and/or clean water laws among other pollution problems. One of the plants we included in our report was the Deerhaven Renewable Energy Center in Gainesville, Florida, the sister facility of a similar plant in Austin, Texas mentioned below. Ratepayers were paying $70 million a year for the Florida plant that would sit mostly idle because natural gas was a cheaper source of fuel. Even putting aside the concerns with bioenergy related to the impacts to climate and forests, the record does not suggest that the biomass plants were a good place to invest federal funds.
 

In addition, in our petition to the SEC filed earlier this year, we highlighted several significant examples of investment losses in the bioeconomy related to bioenergy, biofuels, and biochar:
 

Cello
Alabama-based Cello was ordered by a federal court in 2009 “to pay $10.4 million in punitive damages for fraudulently claiming it could produce cheap, diesel-like fuel from hay, wood pulp and other waste.”[13]
 

KiOr
Mississippi-based biofuels company KiOr was backed by high-profile investor, Vinod Khosla, and a $75 million loan from Mississippi taxpayers. In 2011, the company claimed in its registration statement with the SEC for its initial public offering that it had “achieved” a yield of 67 gallons of fuel per ton of biomass, a claim the company continued to repeat publicly.  However, the SEC found that this supposed achievement was based on undisclosed assumptions about technologies still under development. Internal test results showed actual yields 18-30 percent lower than what was publicly disclosed. In 2016, KiOr settled fraud charges from the SEC that the company was claiming it was producing more biofuel than advertised. The company went bankrupt in 2014, costing Mississippi taxpayers $69 million, according to the Jackson Clarion-Ledger. The newspaper found that KiOr “hoodwinked” then Mississippi Gov. Haley Barbour and other public officials “about its ability to produce large amounts of a cheap bio-crude that oil companies could refine.”[14]
 

Mantria and Speed of Wealth
Operating between 2005 and 2009, a Pennsylvania-based company called Mantria claimed that it was producing biochar to mitigate climate change – a product that was largely nonexistent and infeasible for the company to manufacture.[15] Mantria partnered with a man named Wayde McKelvy who ran “Speed of Wealth” investment clubs in Colorado through which he urged members to withdraw funds from their retirement accounts or to take loans against insurance policies and max out credit card loans, home equity loans and other types of bank loans.  According to a plea agreement, “many investors withdrew their life’s savings from their retirement accounts or even took out loans to invest in Mantria.”[16] McKelvy told investors that they could “get paid by just owning land and spreading this stuff [biochar] all over your field, because this stuff pulls the toxins out of the atmosphere.’” Other sources indicate that ‘toxins’ included carbon dioxide.[17] The Clinton Foundation put its support behind the product, stating on its website that “Mantria Corporation commits to help mitigate global warming through the use of its Carbon Fields site, where Mantria will perform trials on their product BioChar, a carbon-negative charcoal, to prove how this product can sequester carbon dioxide, improve soil quality when buried, and reduce emissions in developing countries.”[18] In 2009, the SEC shut down Mantria and later secured a federal court judgment of more than $135 million against the company.[19] In 2015, a federal grand jury indicted McKelvy, and Mantria’s principals, Troy Wragg and his girlfriend, Amanda Knorr, on 10 counts including securities fraud and wire fraud. Knorr and Wragg pled guilty to all 10 counts in 2016 and 2017, respectively.[20] In 2018, a jury convicted McKelvy of all 10 counts.[21] On August 20, United States District Judge Joel H. Slomsky sentenced Wragg to 22 years in prison for his role in Mantria and for perpetrating a second fraud when he was on bail pending sentencing in the Mantria case. “Wragg and his co-conspirators talked a big game about their bogus trash-to-green-energy business, but it was all a lie,” said U.S. Attorney William M. McSwaim. Knorr received a sentence of 30 months in prison. McKelvy has not been sentenced yet.[22]
 

Nacogdoches Generating Facility
Through its subsidiary Southern Power, Southern Company operated the 115-megawatt, wood-chip fueled Nacogdoches Generating Facility in Sacul, Texas. The plant began operating commercially in 2012 and “is one of the largest biomass power plants in the U.S.,” according to Southern Company.[23] However, the Austin-American Statesman reported in October 2015 that the plant “mostly sits idle” largely because low natural gas prices made the plant uneconomic. The plant cost Austin $54 million a year because the city committed to buy power from the facility for 20 years under a contract, the details of which were kept hidden from the public.[24] The city made the deal anticipating that the federal government would tax carbon dioxide emissions from fossil fuels, making them more expensive (a doubly dubious decision considering that biomass carbon dioxide emissions are higher than those for fossil fuels). Instead, the carbon taxes never materialized and natural gas prices plummeted. The city of Austin ended up purchasing the plant from Southern Power for $460 million, a deal that the city said would save $275 million over the additional term of the contract. The Austin American-Statesman reported that the plant “operates rarely because it’s generally too expensive to run.” The manager of Austin’s utility said the deal was one of the largest purchases in the city’s history.[25] The fate of the Nacogdoches plant was very similar to that of its sister plant, Deerhaven Renewable Energy, mentioned above. Like Austin, the city of Gainesville purchased the Deerhaven facility for $754 million and paid an over-market price to buy out its power purchase agreement. Echoing Austin’s utility manager, The Gainesville Sun concluded that “The city of Gainesville has officially closed on one of the most expensive deals in its 148-year history,” highlighting that investments in bioenergy and biomass-based products can be extremely risky.[26]
 

To promote fiscal responsibility in the bioeconomy, the U.S. government should take the following actions:
 

Determine whether the firms will be able to produce the quantities of biomass-based products they claim before the firms receive any taxpayer subsidies. If the firms’ projections appear to be inflated, the U.S. government should avoid subsidizing the companies.

Assess whether such products will entail environmental costs. Subsidies may be warranted in some cases for products that are truly beneficial environmentally and need assistance to become economically viable. However, if the products increase environmental degradation, the U.S. government should avoid subsidizing the companies.
 

We appreciate this opportunity to comment. Please let us know if you have any questions.
 

Sincerely,

Dusty Horwitt
Senior Counsel
Partnership for Policy Integrity
 

[1] Partnership for Policy Integrity. Petition to the U.S. Securities and Exchange Commission (Feb. 27, 2019). At http://www.pfpi.net/wp-content/uploads/2019/02/SECPetitionAccurateBiogenicCarbonReporting2.27.2019.pdf (visited Oct. 21, 2019). Partnership for Policy Integrity and Dogwood Alliance. Carbon Emissions and Climate Change Disclosure by the Wood Pellet Industry – a Report to the SEC on Enviva Partners LP (March 14, 2016). At http://www.pfpi.net/wp-content/uploads/2016/03/Report-to-SEC-on-Enviva-March-14-2016.pdf (visited Oct. 21, 2019). Partnership for Policy Integrity. Analysis of Risks and Corporate Disclosures Regarding Environmental and Climate Considerations in the Biomass Power Sector (Nov. 2013). At http://www.pfpi.net/wp-content/uploads/2016/03/Report-to-SEC-on-Enviva-March-14-2016.pdf (visited Oct. 21, 2019).

[2] Partnership for Policy Integrity. Climate of Deception: Why Electricity Consumers Who Care about Global Warming and Air Pollution Need FTC Protection from Biomass Industry Greenwashing (July 29, 2014). At http://www.pfpi.net/wp-content/uploads/2014/07/PFPI-report-to-FTC-on-biomass-power-greenwashing.pdf (visited Oct. 21, 2019).

[3] Mary S. Booth and Brett Leuenberger. Partnership for Policy Integrity. The Bioenergy Boom from the Federal Stimulus: Outcomes and Lessons (October 2018). At http://www.pfpi.net/wp-content/uploads/2018/10/PFPI-Bioenergy-and-the-Stimulus-Oct-24.pdf (visited Oct. 21, 2019)

[4] Walker, T., et al. Massachusetts Biomass Sustainability and Carbon Policy Study: Report to the Commonwealth of Massachusetts Department of Energy. Manomet Center for Conservation Sciences. 2010. Searchinger, T., et al. 2009. Fixing a critical climate accounting error. Science 326: 527-528 (demonstrating the theoretical impossibility for biopower emissions to be carbon neutral where forests are cut for fuel. Colnes, A., et al. 2012. Biomass supply and carbon accounting for Southeastern Forests. Biomass Energy Resource Center, Montpelier, VT (concluding that even under seemingly favorable conditions at fast-growing pine plantations, it would take 30–50 years for biopower emissions to be drawn down to a level comparable to net emissions from fossil fuels). Mitchell, S., et al. 2012. Carbon debt and carbon sequestration parity in forest bioenergy production. GCB Bioenergy (2012) doi:10.1111/j.1757-1707.2012.01173.x. (determining 24 that under a wide variety of land use histories and harvesting regimes in the United States, forests store more carbon than using them for energy “saves.”). McKechnie, J. et al. 2011. Forest bioenergy or forest carbon? Assessing trade-offs in greenhouse gas mitigation with wood-based fuels. Environmental Science and Technology, 45: 789-795. (finding that for all scenarios compared, biopower from forest wood reduced forest carbon and increased atmospheric CO2 emissions).

[5] European Academies Science Advisory Council. Commentary by the European Academies Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality (June 15, 2018) (concluding that “carbon emissions per unit of electricity generated from forest biomass are higher than from coal and thus it is inevitable that the initial impact of replacing coal with forest biomass in power stations is to increase atmospheric carbon dioxide levels”) At https://easac.eu/fileadmin/PDF_s/reports_statements/Carbon_Neutrality/EASAC_commentary_on_Carbon_Neutrality_15_June_2018.pdf (visited Oct. 21, 2019).

[6] Intergovernmental Panel on Climate Change. IPCC Special Report on the Impacts of Global Warming of 1.5o C Above Pre-industrial Levels. Summary for Policymakers, October 6, 2018. At http://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf (visited Oct. 21, 2019).

[7] U.S. Environmental Protection Agency. Science Advisory Board Review of Framework for Assessing Biogenic CO2 Emissions from Stationary Sources (March 5, 2019). At https://yosemite.epa.gov/sab/sabproduct.nsf/0/B86C81BACFAF9735852583B4005B3318/$File/EPA-SAB-19-002+.pdf (visited Oct. 21, 2019).

[8] Mary S. Booth and Margaret Sheehan. Closing the Biomass Carbon Loophole. Commonwealth Magazine. Reposted by the Manomet Center at https://www.manomet.org/publication/commonwealth-magazine-closing-the-biomass-carbon-loophole/ (visited Oct. 22, 2019).

[9] D.C. Act 20-595 (Jan. 26, 2015).

[10] Domke, G. M., et al (2012). “Carbon emissions associated with the procurement and utilization of forest harvest residues for energy, northern Minnesota, USA.” Biomass and Bioenergy 36: 141-150; Laganière, J., et al (2017). “Range and uncertainties in estimating delays in greenhouse gas mitigation potential of forest bioenergy sourced from Canadian forests.” GCB Bioenergy 9(2): 358-369; Walker, T., et al (2013). “Carbon Accounting for Woody Biomass from Massachusetts (USA) Managed Forests: A Framework for Determining the Temporal Impacts of Wood Biomass Energy on Atmospheric Greenhouse Gas Levels.” Journal of Sustainable Forestry 32(1-2): 130-158; Mary S. Booth. Not Carbon Neutral: Assessing the Net Emissions Impact of Residues Burned for Bioenergy. Environmental Research Letters, Vol. 13, No. 3 (February 21, 2018).

[11] Food and Agriculture Organization of the United Nations. Global Forest Resources Assessment 2015: How are the World’s Forests Changing? At http://www.fao.org/3/a-i4793e.pdf (visited Oct. 21, 2019).

[12] U.S. Environmental Protection Agency. Renewable Fuel Standard Program. At https://www.epa.gov/renewable-fuel-standard-program (visited Oct. 25, 2018). U.S. Environmental Protection Agency. Program Overview for Renewable Fuel Standard Program. At https://www.epa.gov/renewable-fuel-standardprogram/program-overview-renewable-fuel-standard-program (visited Oct. 25, 2018).

[13] Steven Mufson. Billionaire Vinod Khosla’s Big Dreams for Biofuels Fail to Catch Fire. Washington Post (Nov. 28, 2014). At https://www.washingtonpost.com/business/economy/billionaire-vinod-khoslas-big-dreams-for-biofuels-fail-to-catch-fire/2014/11/27/04899d12-69d7-11e4-9fb4-a622dae742a2_story.html?utm_term=.53b440870f7a (visited Oct. 21, 2019). The Wall Street Journal. The Range Fuels Fiasco (Feb. 10, 2011). At https://www.wsj.com/articles/SB10001424052748704364004576132453701004530 (visited Oct. 21, 2019). Brendan Borrell. Biofuel Fraud Case Could Leave the EPA Running on Fumes. Scientific American (July 10, 2009). At https://www.scientificamerican.com/article/cello-biofuel-fraud-case/ (visited Oct. 21, 2019).

[14] U.S. Securities and Exchange Commission. Litigation Release 23655. SEC Charges Alternative Fuels Company and Former Executive for Key Omissions Regarding Technology (Sept. 27, 2016). At https://www.sec.gov/litigation/litreleases/2016/lr23655.htm (visited Oct. 21, 2019). Jeff Amy. KiOR Biofuel Case: Investors to Get $4.5M Under Federal Settlement. Associated Press (June 10, 2017). At https://www.clarionledger.com/story/business/2017/06/10/kior-biofuel-case-investors-get-4-5-m-under-federal-settlement/386696001/ (visited Oct. 21, 2019). Jerry Mitchell. Texas Company KiOR Hoodwinked Mississippi for $75M, Documents Show. Jackson Clarion Ledger (July 29, 2017). At https://www.clarionledger.com/story/news/politics/2017/07/30/Texas-company-kior-hoodwinked-mississippi-75-m-documents-show/511059001/ (visited Oct. 21, 2019).

[15] U.S. v. Wragg. Case 2:15-cr-00398-JHS, filed in U.S. District Court for the Eastern District of Pennsylvania (Sept. 2, 2015), at 3-4, 6-7, 10-12, 16-17, 21.

[16] U.S. v. Wragg. Government’s Change of Plea Memorandum, Criminal No. 15-398, in the U.S. District Court for the Eastern District of Pennsylvania. U.S. v. Knorr. Government’s Change of Plea Memorandum, Criminal No. 15-398, in the U.S. District Court for the Eastern District of Pennsylvania. U.S. Securities and Exchange Commission v. Mantria, Complaint filed in U.S. District Court for the District of Colorado (Nov. 16, 2009), case number 09CV02676cma-mjw.

[17] Clinton Foundation. Commitment to Action: Mantria Carbon Grids for Carbon Sequestration. At https://www.clintonfoundation.org/clinton-global-initiative/commitments/mantria-carbon-grids-carbon-sequestration (visited Oct. 21, 2019). See also Sarah Tory. High Country News. In Colorado, A Green Fleecing Worth Millions. At https://www.hcn.org/articles/colorados-great-green-scam (visited Oct. 21, 2019).

[18] Clinton Foundation. Press Release: President Bill Clinton and Secretary of State Hilary Clinton Close Fifth Annual Meeting of the Clinton Global Initiative (Sept. 25, 2009). At https://www.clintonfoundation.org/main/news-and-media/press-releases-and-statements/press-release-president-bill-clinton-and-secretary-of-state-hillary-clinton-clos.html (visited Oct. 21, 2019).

[19] U.S. Securities and Exchange Commission. Litigation Release No. 22483 (Sept.18, 2012). At https://www.sec.gov/litigation/litreleases/2012/lr22483.htm (visited Oct. 21, 2019).

[20] U.S. v. Knorr. Government’s Change of Plea Memorandum. U.S. District Court for the Eastern District of Pennsylvania. Criminal No. 15-398. U.S. v. Wragg. Government’s Change of Plea Memorandum. U.S. District Court for the Eastern District of Pennsylvania. Criminal No. 15-398.

[21] U.S. Department of Justice. Founder of Bogus Green Energy Firm Convicted of Running a $54 Million Ponzi Scheme. News Release (Oct. 12, 2018). At https://www.justice.gov/usao-edpa/pr/founder-bogus-green-energy-firm-convicted-running-54-million-ponzi-scheme (visited Oct. 21, 2019)

[22] U.S. Department of Justice. Founder of Mantria Corp. Sentenced to 22 Years for Operating $54 Million Ponzi Scheme. News Release (Aug. 20, 2019). At https://www.justice.gov/usao-edpa/pr/founder-mantria-corp-sentenced-22-years-operating-54-million-ponzi-scheme. Electronic mail from U.S. Attorney’s Office of the Eastern District of Pennsylvania to Partnership for Policy Integrity (Oct. 21, 2019).

[23] Southern Power. Nacogdoches Generating Facility (October 2018). At https://www.southerncompany.com/content/dam/southern-company/pdf/southernpower/Nacogdoches_Generating_Facility_factsheet.pdf (visited Oct. 21, 2019).

[24] Austin-American Statesman. It’s Time to Probe Details of Billion-Dollar Power Plant Contract. Editorial (Oct. 9, 2015). At https://www.statesman.com/news/20160904/its-time-to-probe-details-of-billion-dollar-power-plant-contract (visited Oct. 21, 2019).

[25] Austin Energy. Austin Energy to Acquire Nacogdoches Biomass Facility. News Release (April 23, 2019). At https://austinenergy.com/ae/about/news/press-releases/2019/austin-energy-to-acquire-Nacogdoches-biomass-facility (visited Oct. 21, 2019). Philip Jankowski. Austin Buys Troubled Plant for $460 Million. Austin American-Statesman (April 18, 2019). At https://www.statesman.com/news/20190418/austin-buys-troubled-power-plant-for-460-million (visited Oct. 21, 2019).

[26] Andrew Caplan. City owns GREC after $754M deal. The Gainesville Sun (Nov. 7, 2017). At http://www.gainesville.com/news/20171107/city-owns-grec-after-754m-deal (visited Oct. 22, 2018).