PFPI Comments on Bioenergy in MA Thermal Standard

Massachusetts is a leader nationwide in ensuring that use of forest and wood products to produce electricity is conducted sustainably and efficiently, in part due to the landmark Biomass regulations adopted in 2012  This hard-won victory is now at risk as the state prepares to make changes that would incentivize the wood pellet industry. The Department of Energy Resources (DOER) is proposing changes to the Massachusetts Alternative Portfolio Standards (APS) that would promote the burning of biomass for thermal energy, including wood pellets, and grant subsidies for use of thermal bioenergy.  Details on our concerns are outlined below.


The hearings are being held this week and written comments are due June 30th.  


Hearing Schedule


 Wednesday June 15, 1-3 PM Amherst, MA

    Room 221, Integrated Sciences Building

    University of Massachusetts

       Amherst, MA 01003


 Friday June 17, 1-3 PM Boston, MA

       First Floor Conference Room, Design and Media Center

    Massachusetts College of Art and Design

    621 Huntington Ave, Boston, MA 02115

The link to the regulations is here:


There are three main areas of concern regarding the promotion of wood as a heating source –

  • carbon emissions;

  • biomass “sustainability” (which impacts carbon emissions); and

  • air pollutant emissions.


PFPI does not support granting subsidies to burning trees for energy.  The concentration of carbon dioxide in the atmosphere has now passed an important milestone of 400 parts per million.  We are swiftly on the way to runaway global warming that will have drastic consequences for our way of life, thus we should not be incentivizing anything that increases carbon pollution to the atmosphere.  Burning biomass emits significantly more carbon pollution than burning fossil fuels per unit energy, and harvesting trees for fuel reduces the ability of forests to take carbon out of the atmosphere.


Further,  we recognize that many in the Northeast already rely on burning wood for heat.  Any significant ramp-up in use of wood for heat could impact firewood prices and the people who already rely on firewood in the winter.


Our specific concerns with the proposed APS regulations follow.

Carbon emissions

Wood pellets force a tradeoff between reducing conventional air pollution and reducing carbon pollution

  • DOER promotes the use of pellets as a way of reducing conventional pollutant emissions, compared to burning green wood.  However, this requires a trade-off with carbon emissions, because pellets, and pellet manufacture, emits so much more carbon pollution per unit energy than green chips.


The proposed APS regulations promote the use of wood pellets as fuel, but the state has not conducted a lifecycle carbon emissions study to determine carbon pollution impacts.

  • The state has not conducted a full greenhouse gas (GHG) accounting study for pellets.   PFPI’s data indicate that GHG’s from pellet manufacture and combustion are significantly higher per unit useful thermal energy than carbon emissions from burning green wood chips.


The proposed APS regulations fail to include a timeframe for assessing net emissions  – thereby rendering them invalid

  • The regulations for the RPS, which require biomass electricity facilities to “reduce” net emissions compared to fossil-fueled units, have a 20-year timeframe assigned as the mandatory assessment framework.  The APS regulations do not contain a timeframe.  


The revisions to the APS state:


Page 14 of track changes version

The average emissions rate will include all net carbon dioxide emissions related to combustion, gasification, fuel processing, and sequestration, whether or not such activities occur at the Generation Unit or another location


Page 17 of track changes version

(iii) Greenhouse Gas Emission Reduction. APS Renewable Thermal Generation

Units shall reduce life-cycle greenhouse gas emissions by at least 50% compared to a high-efficiency unit utilizing the fuel that is being displaced or, for a new load, a high-efficiency natural gas unit, if natural gas is available at reasonable cost to the site, or otherwise, the fuel that is most likely to be utilized. To that end, an APS Renewable Thermal Generation Unit using Eligible -Biomass Woody Fuel shall contain at least 50% Residues or Forest Salvage and not more than 50% Thinnings.


  • By definition, the “net” emissions from biomass are assessed continuously, on the assumption that carbon pollution impacts are reduced as trees grow back after being harvested for biomass.  At time zero, emissions from biomass are assessed as stack emissions; then after ten years (for example), they are assessed as stack emissions minus the forest carbon sequestration that has supposedly occurred over that time.  Without assigning a timeframe, the APS regulations are incapable of assessing net emissions.


It sounds like the state has decided that “50% residues and 50% thinnings” is a convenient shortcut to claiming “low” emissions. This isn’t the case, as we explain below.


Massachusetts data show that thermal bioenergy has significantly higher net emissions than fossil fuels over periods of more than a decade

The State of Massachusetts commissioned the Manomet study to assess the net emissions from burning biomass.  The Manomet study assessed both thermal units and electricity generating units.  Manomet did not conduct a full lifecycle emissions impact study of the carbon pollution from pellet manufacturing and combustion, therefore, its findings probably significantly underestimate the full carbon pollution impacts. Nonetheless, Manomet found that biomass thermal units have significantly higher net emissions than fossil fueled units, even assuming relative parity in unit efficiency.   

Here are the Manomet findings.  The time to parity – ie, equivalence of “net” emissions from biomass, taking forest regrowth into account, with emissions from fossil-fueled units – is 15 – 90 years for biomass-fueled units.

Manomet summary



The proposed APS regulations do not contain any meaningful restrictions on types of wood, meaning carbon emissions are unrestricted

Carbon accounting for bioenergy is conducted based on two assumptions:

  1. Emissions are offset eventually, because the materials burned are “waste” fuels that would ultimately decompose and emit CO2 anyway (the rationale behind faster carbon debt payoff times for forest residues)

  2. Emissions are offset eventually because even though fuels are derived by cutting down trees, new trees grow back.  Timeframes for carbon debt payoff are much longer


The APS regulations leave the door open to harvesting a variety of types of wood, including “thinnings.”  Our FOIA of the fuel harvesting data for the RPS revealed wide use, and misuse, of this fuel category.  Forests in New England are not “thinned” in the way that pine plantations in the Southeast are.  Further, there is no carbon accounting that shows a different/shorter carbon debt payoff time for “thinnings.”  The inclusion of this category is meaningless.


The proposed APS regulations do not conform to the requirement, as affirmed in court recently, that state actions actually reduce GHG’s under the Global Warming Solutions Act

  1. A recent SJC ruling requires that the state adopt regulations, pursuant to the Global Warming Solutions Act, that establish limits on multiple greenhouse gas emissions sources and that such limits must decline on an annual basis.The proposed changes could result in significant new sources and increases in carbon dioxide emissions prior to the state having adopted the required regulations.

  2. There is no ability to enforce these regulations, particularly due to upfront minting, full prepayment of subsidy to installation


Sustainability Standards

PFPI requested biomass harvesting records from the MA Department of Energy Resources using a freedom of information request.  These data were collected as part of enforcement of the existing Massachusetts regulations that restricted renewable energy subsidies for biomass electricity facilities to combined heat and power plants.


Some of the data we received are posted here: /wp-content/uploads/2016/06/Biomass-Asset-Report.xlsx


Our analysis of these data was significantly restricted because the data are so poor.  How can the state enforce sustainability standards when they are collecting so little information? This list of harvest data – completely self-reported by the loggers – hardly tells us anything about the real sources of wood, or the real carbon impacts.  Extending this kind of “accountability” to the APS, where the state is providing incentives for pellet manufacture, could allow a great deal of very irresponsible harvesting to occur.  We believe the state have very little ability, or willingness, to to enforce sustainability standards and a failure to address the reality of where pellets are made and purchased.


The proposed APS regulations do not contain assurances that woody biomass is produced sustainably from an ecological and carbon sequestration standpoint

•    FOIAs of past biomass cutting records show information is inadequate to assess or enforce sustainability

•    There is no single standard for “sustainable forestry” among foresters, states, and third-party certifiers

•    There is little accountability, with verification of data based on reviews of forms submitted by suppliers rather than on-site inspection and third-party audit


The proposed APS regulations do not ensure that biomass-producing forests remain intact over time

•    The claimed climate benefits of biomass energy depend on ensuring that the forests providing feedstock do not undergo loss of forest cover, land conversion to non-forest uses, or depletion of carbon stocks over time.

•    The regulations ignore this issue, despite numerous options for keeping forests intact, such as conservation easements, full fee purchase, and robust zoning incentives and regulations.


The proposed APS regulations do not provide accounting for impacts on soil carbon stocks

•    There is a growing concern about the loss of soil carbon from logged forests. At least 50 percent of total ecosystem carbon may be stored in soils, and logging releases much of this carbon, some immediately and more over time.

•    The regulations do not address this issue. Timberland owners would not be required to provide any information on existing soil carbon or the impacts of producing woody fuel on future soil carbon stocks.


The APS standards are not able to ensure that people use wood that is “sustainable”

The APS standards propose to give “up-front minting” of alternative energy subsidies to people who install biomass boilers.  The regulations specify that


“Facilities seeking qualification as APS Renewable Thermal Generation Units using woody biomass will be required to only use fuel from a supplier on the Department’s list of suppliers for the duration of the APS qualification of the thermal energy generating unit, and keep records to demonstrate compliance with this requirement.“ … “Fuel suppliers will need to document the chain of custody from the forest to the retail supplier and on to the end customer.“


Does DOER seriously expect people to comply? This is an invitation to sloppy oversight and a blank check for increasing air pollution.


Air emissions

The proposed APS regulations do not protect against the use of pellets contaminated with heavy metals

The Executive Office of Energy and Environment currently has a webpage where they promote burning wood pellets for fuel (  


EEOA’s webpage states


“If you own a pellet stove, it’s important to know that not all wood pellets are the same. When you purchase bagged pellets, look for products that have been tested by an independent laboratory and certified  by the Pellet Fuels Institute (PFI) Standards Program. All pellets that are certified will have a PFI label on the front lower third of the bag. Currently, twelve pellet manufacturing facilities in the U.S. participate in the voluntary certification”


However, as there is currently no compulsory pellet standard, it is difficult to ensure that people won’t burn contaminated pellets.

DOER has commented on the risk presented by contaminated materials in pellets. In a 2014 letter to EPA, DOER said:


The EPA has reviewed the existing voluntary industry pellet fuel standard of the Pellet Fuel Institute (PFI) and believes it is “a good program that obviates the need for the EPA to develop our own program at this time”.


The DOER disagrees, and rather views the PFI standard as a good start that does not obviate the need for EPA to take additional steps. DOER recommends instead using the PFI standard as a basis to establish a better and more comprehensive required standard at the federal level.


"In an analysis of the chemical composition of 23 wood chip samples and 132 wood pellet samples manufactured in the United States and Canada, the New York State Energy and Research Development Authority (NYSERDA) found most of the wood pellets tested would meet U.S. voluntary standards but would likely not meet standards for residential use in European markets.14 The pellet samples came from locations across northern New York and New England and encompassed 100 different manufacturers, with some duplicate sampling. Some pellet samples had unusually high concentrations of several heavy metals, including arsenic, copper, and chromium. This may be due to extraneous materials in the pellets, such as preservative-treated and painted waste wood. The report’s authors concluded: “Based on these test results, establishing enforceable U.S. standards for elemental compositions of commercial wood pellets and chips would help exclude inappropriate materials and promote cleaner combustion.”


Pellets can contain considerable amounts of heavy metals.  A study (Elemental Analysis of Wood Fuels) conducted by NYSERDA in 2013 found large variation and some high values for heavy metals in wood pellets sampled from a variety of manufacturers. At page 55, the study calls out the “inability to track pellet material”:


Some heavy metals (such as As, Cu and Cr) were found to be higher in several wood pellet samples. High concentrations of these heavy metals in wood pellets indicate the likely use of preservative-treated wood. It is possible that some CCA-treated25 scrap wood might have been included in pellet production. The information gathered from the manufacturers of the wood pellets suggested that some of them used recycled wood products, wood waste and wood residues. The inability to track the pellet material from “cradle to grave” limits the capacity to determine if the elevated levels result from use of treated wood products, harvesting practices or elemental composition.


(Note that “tracking” pellet material is exactly what the DOER regs propose to do.  We think this is extremely unrealistic).

Table 3.5, at page 50 of the NYSERDA study, shows the amounts of heavy metals that were found in the wood pellets they sampled:

Heavy metals

The emissions control requirements for particulate matter in the APS are weak and do not match protections the state has said are needed elsewhere


The APS regulations state, at page 17-18 of the pdf of the redline, that:


(iv) System Performance. APS Renewable Thermal Generation Units shall meet fuel conversion efficiency performance standards achievable by best-in-class commercially-feasible technologies




(v) Emission Performance Standards. APS Renewable Thermal Generation Units shall meet air emission performance standards that are protective of public health, including standards for particulate matter sized 2.5 microns or less and carbon monoxide, as detailed in the Department’s APS Guideline on Biomass, Liquid Biofuels and Biogas.

However, the emission guidelines that are set in the APS do not meet these criteria.  As specified in the guidelines, the allowable emissions rate for PM is the following:





Contrast this with Massachusetts’ “SAPHIRE” renewable thermal program, which contains the following more stringent requirements:

2.3 Wood Chip Boiler

2.3a Performance Criteria

·         For wood chip boilers ranging from 200,000 BTU/hr to 3 MMBTU/hr rated heat input;

o   < 0.15 lb/MMBTU/hr PM2.5 based on heat input

o   > 80% Efficiency

·         For wood chip boilers ranging from 3 MMBTU/hr to 10 MMBTU/hr rated heat input;

o   < 0.10 lb/MMBTU/hr PM2.5

o   < 0.30 lb/MMBTU/hr NOx

o   < 0.27 lb/MMBTU/hr CO

o   > 80% Efficiency

·         All wood chip boilers at sensitive receptor sites including: schools, hospitals and nursing homes, boilers must meet the above criteria for NOx, CO and efficiency, and will be held to a PM2.5 limit of 0.03 lb/MMBTU.

Why doesn’t the APS standard doesn’t contain the same protective standard? The APS allows 0.08 lb/MMBtu; the SAPHIRE program allows much less, 0.03 lb PM/MMBtu at sensitive sites.  Units that emit 0.03 lb/MMBtu PM are certainly “commercially feasible.”