BACKGROUNDER
FOR
SEC
LETTER
ON BIOENERGY
Mary S. Booth, PhD
Partnership for Policy Integrity
October 25, 2013
“BIOMASS
ENERGY”
– Combustion of wood and other biological materials to
produce steam and generate heat and power; or
gasification of fuel to drive a turbine.
– Combustion at “direct-fired” plants or as co-firing with coal
– “Biomass” = wood. Few facilities using agricultural residues
or energy crops
– Considered “renewable energy”: eligible for same
incentives and subsidies as wind and solar power.
– Has been considered “carbon neutral” –now changing
2
McNeil Power Plant,
Burlington, Vermont
Photo: Chris Matera, Massachusetts Forest Watch
3
Wood chip pile, 49 MW biomass plant, Anderson, CA
4
5
Company claims
• Biomass power is “clean”
• Biomass power is “carbon neutral”
• Bioenergy “reduces” greenhouse gas
emissions
• Bioenergy mitigates climate change
6
Bioenergy is not “clean”
• CO2 emissions greater than from fossil fuels
• Conventional air pollutant emissions similar
to or greater than from fossil fuels
7
California: “Blue Lake Power Plant Smokes Out City”
8
Bioenergy pollutant emissions per MWh are
greater than from coal or gas
1.80
COAL: Santee Cooper Pee Dee Generating Station, SC
Pounds per megawatt-hour
1.60
BIOMASS: Gainesville Renewable Energy, FL
1.40
GAS: Pioneer Valley Energy Center, MA
1.20
1.00
0.80
0.60
0.40
0.20
Carbon monoxide
Nitrogen oxides
Filterable PM10
Sulfur dioxide
Volatile organic
compounds
9
Permitted emissions for Russell Biomass, 50 MW
plant in MA (forest wood only)
Particulate matter: 84.3 tons/yr
Nitrogen oxides: 194.5 tons/yr
Carbon monoxide: 243.1 tons/yr
Sulfur oxides: 81 tons/yr
Volatile org. cmpds: 32.4 tons/yr
Ammonia: 32.4 tons/yr
Mercury: 8 lb/yr
Lead: 400 lb/yr
Hydrochloric acid: 11.4 tons/yr
Hazardous air pollutants: 49.1 tons/yr
CO2: 635,000 tons/yr
- Cooling water requirement: 880,000 gallons/day from Westfield River
- Discharge of warm concentrated boiler blowdown to river
- Eligible for about $96 million in subsidies over 10 years
10
Biomass energy is opposed by health
organizations
Massachusetts Medical Society resolution:
(December, 2009)
• “biomass power plants pose an unacceptable risk to the public’s
health by increasing air pollution”
American Lung Association Energy Policy:
(June 11, 2011)
• The American Lung Association does not support biomass
combustion for electricity production, a category that includes
wood, wood products, agricultural residues or forest wastes, and
potentially highly toxic feedstocks, such as construction and
demolition waste.
• The American Lung Association strongly opposes the
combustion of wood and other biomass sources at schools
and institutions with vulnerable populations.
11
Bioenergy is not “carbon neutral” – at
least not in timeframes we care about
• Bioenergy transforms forest carbon into
atmospheric carbon
• Bioenergy CO2 emissions higher than from fossil
fuels
• Emissions persist – atmosphere can’t tell the
difference between bioenergy emissions and
fossil fuel emissions
• Takes decades to achieve parity with fossil fuels
• Carbon neutrality does not equal climate
neutrality
12
Biomass power facilities emit more CO2 per MWh than
coal or gas facilities
Fuel CO2 per
heat content
Facility
(lb/mmbtu) efficiency
Fuel mmbtu
required to
generate 1 MWh
Lb CO2/MWh
Gas combined cycle
117.1
0.45
7.54
883
Gas steam turbine
117.1
0.33
10.40
1,218
Coal steam turbine
205.6
0.34
10.15
2,086
213
0.24
14.22
3,029
Biomass steam turbine
A biomass plant emits
~150% the CO2 of a coal plant
~250% the CO2 of a gas plant
~ 340% the CO2 of a combined cycle plant
lb CO2 emitted per MWh
Gas CC
Gas ST
Coal ST
Fuel CO2 per heat content data are from EIA. Efficiency for
fossil fuel facilities calculated using EIA heat rate data
Biomass ST
(http://www.eia.gov/cneaf/electricity/epa/epat5p4.html);
biomass efficiency value is common value for utility-scale
facilities.
500
1,000
1,500
2,000
2,500
3,000
3,500
13
U.S. Biomass industry CO2 emissions, 2009
Fuel type
Agricultural fuels
Wood solids
Pulping liquors
"other" biomass solids
Total
fuel (tons)
4,252,601
48,165,174
57,011,003
1,981,226
heat input
(mmbtu)
32,312,178
489,243,148
645,150,689
20,853,306
111,410,004
1,187,559,321
CO2 emissions
(tons)
5,613,433
48,566,550
32,923,854
1,997,736
89,101,573
Equivalent to combined reported power sector emissions from
RI, SD, DE, AK, ME, NH, CT, HI, OR, WA, and NJ
Wood demand for bioenergy and pellets will triple by 2020
14
Why has biomass energy been treated as
carbon neutral?
– The “waste” argument: Materials burned are waste and
would decompose and emit CO2 anyway – e.g. forestry
residues – tops and branches left over after commercial
timber harvesting. Thus, no net release of carbon.
– The “resequestration” argument: Ongoing or future
forest growth re-sequesters carbon that’s released by
burning, thus no net release of carbon.
• Bioenergry “offsetting”
Neither argument acknowledges time-lag between burning
biomass and offsetting those emissions.
15
Burning emits more CO2 than decomposition
45
40
35
25 tons
Biomass energy:
cumulative stack CO2
emissions if residues
are burned for energy
30
25
20
15
10
Cumulative CO2 if
residues are left to
decompose
15 tons
5
0
0
10
20
30
40
50
Year
16
May 12, 1998
25-ACRE
CLEARCUT,
MAINE
~ 950 dry tons biomass
Enough fuel to power a 50-MW
biomass plant for about 21 hours
October 31,
2007
TREES
TAKE A LONG
TIME TO GROW BACK
17
Sustainable Forestry Initiative certified biomass
harvesting, Nova Scotia
18
Photo credit: Jamie Simpson
Manomet Study
Commissioned by the State of Massachusetts to examine
carbon and forest cutting impacts of biomass power
Years to Achieve Equal Flux with Fossil Fuels
Fossil Fuel Technology
Harvest Scenario
Oil (#6), Thermal Gas, Thermal Coal, Electric Gas, Electric
Mixed Wood
15 - 30
60 - 90
45 - 75
>90
Logging Residues Only
<5
10
10
30
When using whole trees as fuel, net CO2 emissions are
greater than coal emissions for more than 45 years.
19
Manomet Study: Northeastern Forests
When using whole trees as fuel, net CO2 emissions exceed coal
emissions for more than 45 years, and exceed gas emissions for
more than 90 years, even taking forest regrowth into account.
Southeastern Study
(Colnes et al, 2012)
Executive summary: “The expanded biomass scenario creates a
carbon debt that takes 35-50 years to recover. This outcome
depends on the fossil fuel pathway used for comparison and
assumes forests re-occupy the site through planting or natural
regeneration, with no forest land conversion.”
20
Massachusetts regulations constrain biomass
power eligibility for the RPS
Efficiency
 50% efficiency to qualify for ½ REC/MWh (60% for full REC)
 Promotes combined heat and power
GHG emissions accounting
 Framework accounts for carbon debt of whole tree harvesting
 Requires 50% reduction in GHGs over 20 yrs compared to
combined cycle natural gas facility
Harvesting Sustainability
 Allowable biomass removals (as a percent of the forest products
harvested) depend on soil conditions
 Protection old growth, steep slopes; retention of naturally down
woody material
 Harvest plans/fuel sourcing plans required
21
The consequences of getting it wrong
22
The consequences of getting it wrong
Green Swamp, Brunswick County, NC
(Photo: Dogwood Alliance)
23
The consequences of getting it wrong: ACESA, 2009
Million tons carbon dioxide
2,950
3% reduction
from 2006
2,750
2,550
2,350
EIA projected emissions
14% reduction
from 2006
2,150
1,950
1,750
EIA projected emissions plus
biomass emissions
EIA projected emissions plus
biomass emissions, without the
benefit of CCS
2005
2010
2015
2020
2025
2030
BOOTH AND WILES, “CLEARCUT DISASTER,” ENVIRONMENTAL WORKING GROUP 24
Intergovernmental Panel on Climate Change (IPCC)
We need to reduce emissions NOW
Concentrations of the greenhouse gases CO2, CH4, and N2O now
substantially exceed the highest concentrations recorded in ice cores during
the past 800,000 years. The mean rates of increase in atmospheric
concentrations over the past century are, with very high confidence,
unprecedented in the last 22,000 years.
The pH of ocean surface water has decreased by 0.1 since the beginning of
the industrial era (high confidence), corresponding to a 26% increase in
hydrogen ion concentration.
Continued emissions of greenhouse gases will cause further warming and
changes in all components of the climate system. Limiting climate change
will require substantial and sustained reductions of greenhouse gas
emissions.
(Intergovernmental Panel on Climate Change, Fifth Assessment Report.
Summary for policymakers, September 27, 2013. www.ipcc.ch)
25
Millions of tons of new demand
for “energy wood”
Biopower (mostly proposed)
Pellets (existing and proposed)
Liquid biofuels using wood (mostly proposed)
Yearly wood demand,
thousands of tons
0 – 100k
100k – 250k
250k – 500k
500k – 1,000k
1,000k – 2,000k
26
IPCC “Mitigation” Scenario – incompatible
with wood-fired power plants
Three out of for scenarios project continued
temperature rise past 2100
Only mitigation scenario stabilizes – requires
immediate effort to reverse emissions
We should be planting trees, not burning them.
27
Investor risk and bioenergy
Risks:
• Of regulation
• Of damage to the company’s reputation
• Of investments that won’t pay off
We are asking the SEC:
• Have companies adequately disclosed material risks?
• Are they making materially misleading statements to
investors, including claims that appear to be
unsupportable?
• Can the SEC offer some accounting or disclosure
guidance for claims of carbon neutrality?
28
Relevant policy developments
State-level: MA biomass regulations; proposed regulations
in MD, DC (heavy opposition from Dominion)
Federal level: EPA regulates CO2 under the Clean Air Act –
bioenergy emissions initially included
July 2011: 3-yr deferral for bioenergy emissions, exempting
most facilities from PSD permitting. Enviros sue EPA.
Meanwhile: EPA’s Science Advisory Panel, Sept. 2012:
“Bioenergy can not a priori be considered carbon neutral”
Center for Biological Diversity, et al. v. U.S. EPA, July 2013:
Environmental groups win case.
29
September, 2013: EPA’s New Source
Performance Standard for CO2
acknowledges biogenic emissions:
“In general, the overall net atmospheric loading of CO2
resulting from the use of a biogenic feedstock by a stationary
source, such as an EGU, will ultimately depend on the
stationary source process and the type of feedstock
used, as well as the conditions under which that
feedstock is grown and harvested.”
30
Mary S. Booth
[email protected]
413-253-3256
Sanford Lewis
[email protected]
413-549-7333