Massachusetts Environmental Groups to EPA – Treating Bioenergy as Having Zero Emissions Undermines the Science
Massachusetts was the first state to recognize that wood-burning power plants not only emit more carbon dioxide that fossil-fueled power plants, but that it takes years to several decades for new forest growth to resequester the excess carbon that’s released. Accordingly, Massachusetts eliminated renewable energy subsidies for low-efficiency biomass power generation. Environmental groups in Massachusetts thus oppose EPA’s apparent decision to treat bioenergy as having zero carbon emissions under the Obama Administration’s Clean Power Plan. The following letter was sent to EPA today by Massachusetts environmental groups.
The letter can be downloaded here.
February 11, 2015
Gina McCarthy, Administrator
William Jefferson Clinton Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460
Dear Administrator McCarthy:
We are pleased that EPA is moving forward with the Clean Power Plan. However, we write to express our deep concern at EPA’s apparent decision to treat biomass power as carbon neutral for the purposes of EPA’s Clean Power Plan and Prevention of Significant Deterioration permitting, as failure to address this will offset benefits of these rules. This decision contradicts sound science and promotes burning forest wood for electric power production, which is exactly the wrong direction for our county’s renewable energy policy. We strongly oppose the decision.
The signatories to this letter are located in Massachusetts. Our state removed low-efficiency biomass power from the state’s renewable energy portfolio after commissioning a study that found carbon dioxide emissions from biomass power would compromise the state’s ability to meet its established 2020 and 2050 emission reduction targets. Just as Massachusetts found the state cannot reduce greenhouse gas emissions by burning wood in inefficient power plants, the inclusion of bioenergy as a “zero-carbon” form of renewable energy under the Clean Power Plan undermines the Plan’s ability to actually reduce emissions. EPA’s apparent decision to override established science and treat biomass energy as carbon neutral is thus deeply disappointing for clean energy advocates, but beyond this, it is a particular threat to the hard-won, science-based rules adopted in Massachusetts.
In fact, Massachusetts is not alone in recognizing that wood-fired power plants emit too much CO2 to be useful in fighting climate change. The Washington DC City Council voted unanimously in 2014 to remove low-efficiency biopower from the city’s Renewable Portfolio Standard, and the Vermont Public Service Board voted in 2014 to deny a Certificate of Public Good to a proposed wood-fired power plant due to its excessive CO2 emissions, stating “the evidentiary record supports a finding that the Project would release as much as 448,714 tons of CO2e per year, and that sequestration of those greenhouse gases would not occur until future years, possibly not for decades, and would not occur at all in the case of forest-regeneration failures.”
EPA’s memo of November 19th, 2014, states that biomass will be treated as carbon-neutral for Prevention of Significant Deterioration permitting so long as it comes from "waste-derived feedstocks” and “non-waste biogenic feedstocks derived from sustainable forest or agricultural practices.” It likewise intends to ignore emissions from the same categories of biomass under the Clean Power Plan. The EPA is by now certainly aware not only that “sustainability,” most generously defined, means that harvesting does not exceed forest growth, but also that EPA's own Science Advisory Panel explicitly rejected this approach as a means of determining net carbon emissions from biomass power generation. As the Science Advisory Panel report points out, EPA is not charged with regulating regional or national forest carbon stocks; it must regulate stationary facilities, and simply assessing whether land carbon stocks are rising is inadequate to this task. 
In any case, the concept of sustainability has only minimal relevance to what the atmosphere “sees” when a facility burns biomass as fuel. In Massachusetts, forest harvesting is not intensive and much cutting could be described as “sustainable,” and was accordingly modeled as such by the 2010 Manomet Study, the project commissioned by the state to assess net carbon emissions from wood-fired bioenergy. Nonetheless, the Manomet Study found that net cumulative emissions from biomass power plants exceed emissions from coal or gas generation for years to decades. Further, the term "sustainability" is so widely used as to mean little; in some parts of the Northeast, clear-cutting forests is common, including for biomass fuel, yet such practices are routinely described and even certified as “sustainable.”
Our groups supported the science-based process that led to low-efficiency biomass power being removed from the Massachusetts Renewable Energy Portfolio. We were supportive when EPA similarly committed to a science-based process for determining bioenergy emissions for biogenic greenhouse gas permitting on the federal level. The EPA’s proposal to treat entire classes of biomass as having zero emissions – when in fact burning any of these materials emits more CO2 at the stack than coal, and in many cases, excess net emissions from these fuels persist for decades – overturns the Agency’s commitment to science-based assessment. We urge the EPA to fully account for biomass carbon emissions and take a conservative path forward to ensure that the Clean Power Plan genuinely reduces emissions from the power sector, and does nothing that will promote forest harvesting in the name of reducing emissions.
Thank you for your consideration,
VP and Director, CLF Massachusetts and Director, Healthy Communities and Environmental Justice
Conservation Law Foundation
Vice President for Policy
Environmental League of Massachusetts
John J. Clarke
Director of Public Policy and Government Relations
Cathy A. Buckley, Chair
Edward Woll, Jr, Conservation and Energy Chair
Massachusetts Sierra Club
Mary S. Booth
Partnership for Policy Integrity
 http://yosemite.epa.gov/sab/sabproduct.nsf/0/57B7A4F1987D7F7385257A87007977F6/$File/EPA-SAB-12-011-unsigned.pdf. Page 4
 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.