B IOMASS E NERGY : E NVIRONMENTAL I MPACTS AND E MERGING R EGULATION Mary S. Booth, PhD Partnership for Policy Integrity KIUC Energy Conference, Lexington, KY March 13, 2014

“B IOMASS 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

O UTLINE Biomass power plants emit more CO 2 and key “conventional” pollutants than fossil-fueled plants New policies and regulatory decisions recognize these impacts 3

WOOD-FUELED BIOPOWER AND ITS EMISSIONS 4

McNeil Power Plant, Burlington, Vermont Photo: Chris Matera, Massachusetts Forest Watch 5

P ROPOSED ECO P OWER PLANT, H AZARD ~58 MW gross; likely less than 52 MW net (parasitic load) 745 MMBtu boiler Air cooled, low-efficiency Will harvest trees for fuel “Synthetic minor” source under Clean Air Act: allowable particulate matter emissions 2x greater than coal; no air quality modeling; no short term emissions limits 6

ECO P OWER WEBSITE 7

B IOMASS POWER EMITS MORE CO 2 PER MW H THAN COAL OR GAS 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 data are from EIA. Efficiency for fossil fuel facilities calculated using EIA heat rate data ( biomass efficiency value is common value for utility-scale facilities. 8

B IOPOWER AIR POLLUTANT EMISSIONS ARE GREATER THAN COAL OR GAS 9

B IOMASS 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. 10

– The “waste” argument: Materials burned are waste and would decompose and emit CO 2 anyway – The “resequestration” argument: Ongoing or future forest growth re-sequesters carbon that’s released by burning. Bioenergy “offsetting” Neither argument acknowledges time-lag between burning biomass and offsetting emissions. 11 W HY HAS BIOMASS ENERGY BEEN TREATED AS “ CARBON NEUTRAL ”?

S IMPLISTIC EXPLANATION “Carbon in biomass is part of the natural carbon cycle” - versus fossil fuels. But again: timing matters 12

Fossil fuel scenario Biopower scenario Time Less stack CO 2 More stack CO 2 Less forest biomass More forest biomass W HERE ’ S THE CARBON ?

N ET BIOPOWER NET CO 2 EMISSIONS EXCEED EMISSIONS FROM NATURAL GAS FOR DECADES “Waste” wood that would decompose anyway Trees that otherwise continue growing Slash that would be burned in the woods CUMULATIVE EMISSIONS YEARS Natural gas (stack emissions only) 14

ECO P OWER WILL BURN WHOLE TREES FOR FUEL “Within a 55-mile radius of the Project, there are more than 400,000 green tons of mill residuals and over 67 million green tons of standing low-grade wood with a growth rate of over 1 million green tons annually.” 15

60- MILE FUEL - SOURCING RADIUS 16

B IOMASS HARVESTING THREATENS FORESTS AND BIODIVERSITY

NEW REGULATORY AND POLICY DEVELOPMENTS FOR BIOENERGY 18

EPA’ S “ DEFERRAL ” FOR COUNTING BIOENERGY CO 2 UNDER C LEAN A IR A CT DEEMED UNLAWFUL U.S. Court of Appeals: EPA should not exclude bioenergy CO 2 emissions from counting toward Prevention of Significant Deterioration (PSD) triggering threshold 19

F UTURE REGULATION OF BIOMASS CO 2 UNDER C LEAN A IR A CT ? Science Advisory Board: “Bioenergy is not a priori carbon neutral” July, 2014: Bioenergy exemption ends 20

EPA’ S P OWER P LANT R ULE FOR CO 2 Suggests standards may be set for bioenergy CO 2 eventually: “the overall net atmospheric loading of CO 2 resulting from the use of a biogenic feedstock by a stationary source 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.” Again – bioenergy not automatically carbon neutral

M ASSACHUSETTS RULES ELIMINATE LARGE - SCALE BIOMASS POWER FROM RPS Efficiency  50% efficiency to qualify for ½ REC/MWh (60% for full REC) 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 standards  Allowable removals depend on soil conditions  Protects old growth, slopes, downed woody material  Requires harvest plans Other states have similar plans to restrict biopower eligibility for RPS: MD, DC

V ERMONT P UBLIC S ERVICE B OARD DENIES BIOMASS PLANT “ CERTIFICATE OF PUBLIC GOOD ” BASED ON CO 2 EMISSIONS “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. This annual level of greenhouse gas emissions is a significant burden to be weighed in determining whether the Project would promote the general good.” Plant will interfere with ability of state to reduce greenhouse gas emissions 23

I NVESTOR COMPLAINT LETTER TO S ECURITIES AND E XCHANGE C OMMISSION ON BIOENERGY “ GREENWASHING ” Signed by investors with over $100b in assets Calls out “carbon neutral” claims and other misrepresentations by Dominion, Southern Company, Covanta Shareholder resolution on ballot at Dominion, calling for study of bioenergy climate and investment risks 24

Mary S. Booth