by Paul Dale, Chair, Massachusetts Energy Committee & Deb Pasternak, Chapter Director, Massachusetts Chapter
Background: The Alternative Portfolio Standard (APS) was initially established to provide incentives for facilities that install energy-efficient heating technologies, such as combined heat and power. It was expanded in December 2017 to include renewable thermal technologies, including solar hot air and water, air and ground source heat pumps, wood boilers and furnaces (biomass), and garbage incinerators that produce steam energy (of which there is only one in Massachusetts). Many groups had weighed in with detailed comments opposing the lax rules for wood-burning boilers that Massachusetts adopted. The Baker Administration subsequently proposed weakening the rules for biomass power plants in the RPS to match the weak APS rules in order to “streamline” them (source: Laura Haight, PFPI).
The Massachusett Department of Energy Resources (DOER) is currently conducting a review of the (APS) to examine the costs and benefits of the program to ratepayers, effectiveness of the program in meeting the energy and environmental goals of the Commonwealth, and whether it needs to amend the minimum standard.
The Massachusetts Chapter submitted the following comments to DOER on December 3, 2020 in regard to the proposed review of the APS.
The 2020 APS Review is the moment to remove incentives for biomass from the APS. The GWSA Implementation Advisory Committee has recommended that biomass be removed from eligibility under all clean energy incentive programs administered by EEA, including the RPS, APS, CES, and CPS, and has further recommended that EEA address the localized public health impacts of other air pollutants (PM2.5, ozone, NOx, etc.) that co-occur with GHG emissions from combustion.
APS incentives should be entirely directed at the nascent market for air source heat pumps, which are now available for significant deployment in cold climates, and for geothermal heating.
The APS was established in 2009 to offer “an incentive for alternative energy systems which contribute to the Commonwealth’s clean energy goals”. Burning biomass does not do this; it inhibits the attainment of the GWSA emissions mandates and impacts public health due to the associated particulate matter pollution.
DOER’s action (or inaction) reaches beyond our borders. Massachusetts is looked to as a climate leader, and we must lead, and we have led. If we don’t lead, who will?
The Problems with Biomass
Problem 1: Biomass produces more greenhouse gas emissions per unit of thermal energy produced than fossil fuels. According to the Manomet study, it would take approximately 10 years for emissions to reach parity when biomass replaces natural gas for thermal applications if only logging residues are burned, and about five years for oil. Under the APS standards, which allow mixed wood, it could take much longer. Converting from oil or gas heat to biomass increases greenhouse gas emissions.
Problem 2: Trees are the only effective means to take CO2 out of the atmosphere. The Harvard Forest report, “Wildlands and Woodlands” (Sep. 2017) states that, “Annually, New England’s forests take up a vast amount of carbon dioxide from the atmosphere, providing the critical service of mitigating climate change. Across the region this storage offsets approximately 20 percent of the total carbon dioxide that is released across New England through fossil fuel combustion”. The chart shows (in red) that the forests of Massachusetts have the highest carbon storage rate in New England because our trees are actively growing.
Problem 3: The “renewable” aspect claimed for biomass is no longer valid. There is a misconception that trees are a renewable resource because we can plant new trees that will recapture the CO2 released by burning. This would be true if our time horizon was hundreds of years. It is not. New trees cannot be grown in the time available to fight the climate crisis. In the New Yorker magazine article, “Don’t Burn Trees to Fight Climate Change – Let them Grow” (8/15/19), William Moomaw, Professor Emeritus of International Environmental Policy and founding director of the Center for International Environment and Resource Policy at Fletcher School, Tufts University, says, “A stand of white pines, for instance, will take up twenty-two tons of carbon by its fiftieth year, which is about when it would get cut down to make pellets. But if you let it grow another fifty years, it adds twenty-five tons. And in the next fifty years it adds 28.5 tons. It would be a mistake to cut them down when they’re forty and make plywood. It’s really foolish to cut them down when they’re forty and burn them.” He calls letting trees stand and accumulate carbon “proforestation” – as opposed to reforestation.
Problem 4: Burning biomass has terrible health impacts. Combustion of biomass releases fine particulates (soot) and other air pollutants. Low-income communities, communities of color, and sensitive populations such as children, the elderly, and people with respiratory ailments are at risk. Massachusetts already has the highest levels of particulate pollution in New England from residential wood burning. According to the most recent data from the National Emissions Inventory, wood-burning accounted for 83% of all particulate matter emissions from heating in Massachusetts in 2014 (more info here), and a quarter of the state’s total particulate matter emissions. There is a direct public and private health care cost from the use of biomass.
Problem 5: Harvesting and burning depletes the soil needed for regrowth. Like fossil fuels, burning biomass is an extractive, not renewable, energy source. Nature’s balance requires that wood decay in place in the forests over an extended period of time.
Conclusion
DOER needs to seize this opportunity to reduce public and private health costs and step up its response the climate crisis. We need aggressive emissions reductions by 2030. There is not a moment to waste.