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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. - PowerPoint PPT Presentation
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BACKGROUNDER FOR SEC LETTER ON BIOENERGY
Mary S. Booth, PhDPartnership 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
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Company claims• Biomass power is “clean”• Biomass power is “carbon neutral”• Bioenergy “reduces” greenhouse gas
emissions• Bioenergy mitigates climate change
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Bioenergy is not “clean”• CO2 emissions greater than from fossil
fuels• Conventional air pollutant emissions
similar to or greater than from fossil fuels
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California: “Blue Lake Power Plant Smokes Out City”
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Bioenergy pollutant emissions per MWh are greater than from coal or gas
-
0.20
0.40
0.60
0.80
1.00
1.20
1.40
1.60
1.80
Carbon monoxide Nitrogen oxides Filterable PM10 Sulfur dioxide Volatile organic compounds
Poun
ds p
er m
egaw
att-h
our
COAL: Santee Cooper Pee Dee Generating Station, SC
BIOMASS: Gainesville Renewable Energy, FL
GAS: Pioneer Valley Energy Center, MA
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Permitted emissions for Russell Biomass, 50 MW plant in MA (forest wood only)
Particulate matter: 84.3 tons/yr Nitrogen oxides: 194.5 tons/yrCarbon monoxide: 243.1 tons/yrSulfur oxides: 81 tons/yrVolatile org. cmpds: 32.4 tons/yr
Ammonia: 32.4 tons/yrMercury: 8 lb/yrLead: 400 lb/yrHydrochloric acid: 11.4 tons/yrHazardous 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
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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.
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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
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
Fuel CO2 per heat content (lb/mmbtu)
Facility 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
Biomass steam turbine 213 0.24 14.22 3,029
Fuel CO2 per heat content data are from EIA. Efficiency for fossil fuel facilities calculated using EIA heat rate data (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
Biomass ST
Coal ST
Gas ST
Gas CC
lb CO2 emitted per MWh
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U.S. Biomass industry CO2 emissions, 2009
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
Fuel type fuel (tons)heat input (mmbtu)
CO2 emissions (tons)
Agricultural fuels 4,252,601 32,312,178 5,613,433 Wood solids 48,165,174 489,243,148 48,566,550 Pulping liquors 57,011,003 645,150,689 32,923,854 "other" biomass solids 1,981,226 20,853,306 1,997,736
Total 111,410,004 1,187,559,321 89,101,573
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– 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.
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Why has biomass energy been treated as carbon neutral?
Burning emits more CO2 than decomposition
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0
5
10
15
20
25
30
35
40
45
0 10 20 30 40 50Year
Biomass energy: cumulative stack CO2 emissions if residues are burned for energy
Cumulative CO2 if residues are left to decompose
25 tons
15 tons
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May 12, 1998
October 31, 2007
25-ACRE CLEARCUT, MAINE~ 950 dry tons biomassEnough fuel to power a 50-MW biomass plant for about 21 hours
TREES TAKE A LONG TIME TO GROW BACK
Sustainable Forestry Initiative certified biomass harvesting, Nova Scotia
Photo credit: Jamie Simpson18
Manomet Study
Oil (#6), Thermal Gas, Thermal Coal, Electric Gas, ElectricMixed Wood 15 - 30 60 - 90 45 - 75 >90Logging Residues Only <5 10 10 30
Harvest Scenario
Years to Achieve Equal Flux with Fossil FuelsFossil Fuel Technology
Commissioned by the State of Massachusetts to examine carbon and forest cutting impacts of biomass power
When using whole trees as fuel, net CO2 emissions are greater than coal emissions for more than 45
years.
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Manomet Study: Northeastern ForestsWhen 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.”
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Massachusetts regulations constrain biomass power eligibility for the RPSEfficiency 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
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The consequences of getting it wrong
Green Swamp, Brunswick County, NC (Photo: Dogwood Alliance) 23
The consequences of getting it wrong
2005 2010 2015 2020 2025 20301,750
1,950
2,150
2,350
2,550
2,750
2,950
EIA projected emissions
EIA projected emissions plus biomass emissions
EIA projected emissions plus biomass emissions, without the benefit of CCS
Mill
ion
tons
carb
on d
ioxi
de
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14% reduction from 2006
3% reduction from 2006
BOOTH AND WILES, “CLEARCUT DISASTER,” ENVIRONMENTAL WORKING GROUP
The consequences of getting it wrong: ACESA, 2009
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)
Intergovernmental Panel on Climate Change (IPCC) We need to reduce emissions NOW
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Millions of tons of new demand for “energy wood”
0 – 100k100k – 250k250k – 500k500k – 1,000k
1,000k – 2,000k
Yearly wood demand, thousands of tons
Biopower (mostly proposed)
Pellets (existing and proposed)
Liquid biofuels using wood (mostly proposed)
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IPCC “Mitigation” Scenario – incompatible with wood-fired power
plants
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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.
Investor risk and bioenergyRisks:• 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
Federal level: EPA regulates CO2 under the Clean Air Act – bioenergy emissions initially includedJuly 2011: 3-yr deferral for bioenergy emissions, exempting most facilities from PSD permitting. Enviros sue EPA.
Center for Biological Diversity, et al. v. U.S. EPA, July 2013: Environmental groups win case. 29
State-level: MA biomass regulations; proposed regulations in MD, DC (heavy opposition from Dominion)
Meanwhile: EPA’s Science Advisory Panel, Sept. 2012: “Bioenergy can not a priori be considered carbon neutral”
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.”
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