On Tuesday, August 21, the Trump administration released its plan to dramatically revise the Clean Power Plan (CPP), President Obama’s signature climate policy.  Under the CPP, emissions from the power sector would have been reduced 32 percent by 2030 relative to 2005 levels. While the EPA is legally required to tackle greenhouse gas emissions per the endangerment finding, the Trump administration has taken a much narrower interpretation of the Clean Air Act than what was found in the CPP.   

The CPP asserted that EPA has the power to regulate sector-wide emissions from power generation, while ACE assumes that emissions reductions can only be mandated “within the fence line,” or at individual power plants. However, despite EPA’s recent finding that biomass utilization is carbon neutral so long as forestry stocks are stable or increasing, the administration does not consider biomass as a major pathway for reducing emissions from the power sector.  This, combined with the paltry emissions reduction target under ACE, provides little incentive to utilize both forest and non-forest biomass (agriculture, urban wood wastes) for power applications.  

In mandating sector-wide emissions reductions, the CPP was technology forcing and would have brought more renewable power onto the grid. Additionally, it allowed states to consider biomass utilization as one potential emissions reduction pathway, if states could demonstrate that biomass utilization reduced emissions. Several wood basket states, such as Arizona, Oregon, Washington, Minnesota and several others, were considering using relatively small amounts of wood energy under the CPP, either in coal co-firing or stand-alone power generation.  

Conversely, the ACE program sets CO2 reduction targets between 1 to 2 percent by 2035.  Environmental and public health groups (including EESI), have blasted the ACE, noting that it is likely going to be more expensive to comply with and cause additional, needless deaths.  Indeed, it is largely a handout to prop up coal-fired power generation, at the expense of cheaper, cleaner renewables and natural gas. These cleaner power sources are already making up an ever-growing share of U.S. electricity generation, with or without federal intervention.

ACE states that “biomass co-firing is more expensive and/or less achievable than the measures determined to be part of best system of emission reduction.”  EPA goes on to state that biomass fuels should not be used as a BSER “because too few individual sources will be able to employ that measure in a cost-reasonable manner.”

However, EPA does leave the door open for the use of biomass in certain situations, noting that it may be attractive to particular power plants, with the Notice of Proposed Rulemaking soliciting comments on the use of both forest and non-forest biomass as a compliance option. However, without more stringent emissions reduction goals, it is unlikely that states and utilities will aggressively pursue the use of woody biomass.

There are several reasons for this. In the three years since the CPP was finalized, the power sector has already begun to rapidly shift away from coal use towards natural gas. Biomass was thought of as largely as a way to reduce coal’s emissions by co-firing. Without that use, its applications are narrower, but still important.

Woody biomass utilization, in the form of combined heat and power, could provide baseload renewable power and renewable thermal to more intermittent renewables, as well as providing support to needed forest thinning initiatives and rural economies.  Thermal energy (heating and cooling) is responsible for approximately a third of domestic energy consumption, but is still mostly derived from fossil sources (oil and natural gas).  Biomass, including woody biomass and biogas could play a role in providing renewable thermal to both industry and residential sectors.


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