On December 1, the Environmental and Energy Study Institute (EESI) submitted comments to the Environmental Protection Agency (EPA) on its Clean Power Plan, a draft regulation to cut carbon emissions from existing power plants. In November, EESI welcomed the EPA’s recent release of the Framework for Assessing Biogenic CO2 Emissions from Stationary Sources, which recognizes the important role that using “waste-derived feedstocks” as well as “forest-derived industrial by-products” can play in the low-carbon economy, as they “are likely to have minimal or no net atmospheric contributions of biogenic CO2 emissions, or even reduce such impacts, when compared with an alternate fate of disposal.” However, EESI cautioned that while the Framework is a step in the right direction, more needs to be done to achieve the significant greenhouse gas reductions that implementing the full suite of biomass energy sources would make possible. Unlike other renewable energy sources, waste materials can pose significant environmental problems if not sustainably dealt with – but if utilized they can provide significant benefits on several levels.
Biomass power can be derived from both waste (forestry, agriculture, organics, manure, landfills, waste water treatment) and purpose-grown biomass crops, such as perennial grasses. The Department of Energy’s 2011 Billion Ton Update estimates that there are currently 244 million dry tons of sustainably recoverable agricultural wastes in the United States, and that that number could reach as high as 910 million dry tons per year by 2030. The non-profit Dairy Checkoff estimates that U.S. farms alone could support 2,600 anaerobic digesters, producing 11.7 million megawatts of electricity per year. Already, biomass power generates enough energy to power 1 million homes and businesses, according to the Biomass Power Association. According to the Energy Information Administration (EIA), biomass power represents a full 22 percent of the United State’s renewable energy supply, and these resources must be adequately addressed by the proposed Clean Power Plan.
Not only does biomass provide a low-carbon source of consistent, baseload power, sustainable biomass can also provide significant economic and ecosystem co-benefits at the local level. For example, purpose-grown biomass crops can support a multi-functioning agricultural system by increasing a soil’s organic carbon, increasing its capacity to hold water and nutrients, and reducing runoff. Using organic wastes also monetizes a waste stream that would otherwise pose significant environmental problems to communities, yet these resources are consistently underutilized. Biomass power and waste-to-energy can provide local jobs, additional revenue to municipalities, and partially address the issues of overflowing landfills and growing waste streams.
EESI maintains, as do many forestry groups, scientists, and forestry product industries, that there is a fundamental difference between carbon emissions from burning fossil fuels and emissions from burning biomass that is sustainably harvested and regrown, and thus able to sequester carbon. Quantifying carbon emissions from woody fuels is important because individual states will need to assess whether their wood-based energy resources qualify under the Clean Power Plan. Therefore, EESI urges EPA and EPA’s Scientific Advisory Board to consider the significant body of peer-reviewed research that suggests that biomass power can help to reduce greenhouse gas emissions. Additionally, states such as Michigan and California have already created definitions for sustainable biomass energy. Both states draw a distinction for GHG emissions from wastes that would already be headed to the landfill, such as wood wastes and residues that have no value. EESI hopes that EPA will consider the types of standards already in place at the state level in their further clarification of the definition of ‘sustainable’ biomass.
Bioenergy can play a role in preserving and increasing the carbon stores of working lands. Using anaerobic digestion on farms to produce renewable natural gas creates valuable co-products (fertilizers, compost) that can be used to boost soil organic carbon levels and improve the health of soils. Additionally, bioenergy can help preserve rural land. The U.S. Geological Survey has found that urbanization in the Southeast could increase 190 percent by 2060, resulting in a 15 percent loss of agricultural land, a 10 percent loss of forests, and a 12 percent loss of grasslands, as well as negatively impacting wildlife, water and air quality. Providing an economic incentive to maintain farms and forested lands, as bioenergy and biofuels do, will help to preserve these lands. Preserving such open spaces is a critical component of climate adaptation, protecting critical wildlife habitats, and preserving air and water quality. All of this links back to the Clean Power Plan through recognition of the sustainable use of bioenergy.
Already, most states with a Renewable Portfolio Standard (RPS) recognize biomass energy, but it receives unequal treatment from both RPS and federal tax credits. To provide states flexibility in using their biomass resources, EESI recommends that EPA:
- Recognize that sustainable woody biomass harvesting (especially waste utilization) does not increase net carbon accumulation, as long as overall forest stocks are stable or increasing.
- Recognize thermal heat in the Clean Power Plan. Thermal energy represents 40 percent of energy used in the United States – its omission skews recognition of emissions from this use of energy.
- Build upon the programs and work occurring in the agriculture and forestry sectors at the state level, which have already defined and developed sustainable practices for biomass harvesting.
- The category of “waste-derived materials” should be inclusive of the significant organic waste streams created in the United States. The Clean Power Plan should incentivize the use of these organic wastes (including manure, landfill, organic, food waste) for the generation of electricity.