Is the CHS Another CFL Moment?
By Steve Crowley, Energy Chair, VT Sierra Club
So, here’s my problem. I have this box in the corner of my closet that’s full of brand new CFLs, compact fluorescent lightbulbs, that I bought about a decade ago. I might not have, except that Efficiency Vermont was running this great program that got schools to sell them, part as a fundraiser but also as a competition, the winner of which would get a modest-sized wind turbine to power their school. Supporting my student’s efforts, and certain this was the right move for the planet, I purchased enough to cover my needs for the next ten years.
Very soon thereafter, we started to see that the toxic mercury in the CFLs outweighed their efficiency benefit. Plus, as LEDs scaled up, and Efficiency Vermont built the rebate into the shelf price, there was a far better option. Now I have a box of hazardous waste in my closet. Woops.
Sadly, this is not the only time we enviros were caught with an idea that seemed good at the time but later required a major fix. Some of us recall the early air pollution laws that demanded improving the air quality around a polluting factory or power plant, which resulted in the construction of enormously tall smokestacks. While that had some effect at cleaning the air locally, the pollutants mixed and reacted in the upper atmosphere, and the plume far downwind gave us tropospheric ozone and acid rain. Woops.
The proposed new Clean Heat Standard seems poised to present another CFL moment.
To be fair, the CHS has some very important benefits. For one thing, it brings the whole thermal sector under regulation for greenhouse gas emissions, an essential step if we are going to start caring for our planet properly. Another big plus is that it demands careful life-cycle accounting, if not for ‘embedded carbon’ at least for the energy it took to create and use the fuels. We need that in the electric sector as well, and this may be the push needed to make that happen. Another big plus is that it sets up a “Default Provider” for clean heat measures, something like an Efficiency Vermont for the thermal sector. Add to this a number of important steps toward equity and environmental justice, not enough some say, but important nonetheless. That’s all good.
But when you look closer, it’s hard not to identify a few bugs in the system. How big are they, and can they be corrected? Hopefully some careful scrutiny in the Senate can fix them.
The biggest is the open door for the use of bioenergy as a low-carbon substitute for the heating oil, diesel, propane, and natural gas we use to heat our homes. It does seem that at a small scale, this is less harmful and provides a net GHG benefit. But as we scale up, as is already happening on the national and global scene, serious problems emerge. Some biofuels require cropland and water, both scarce, and growth will displace food crops, pushing farmers to utilize land set aside as conservation reserve, with ripple effects through the global system that even gets to replacing rainforests with soy crops or palm oil plantations. When transportation fuels started adding corn-based ethanol (replacing MTBE, a highly toxic additive which itself replaced the lead in fuels, another idea that seemed good at the time), the supply chain for corn was so disrupted that its price skyrocketed and availability plummeted, leading to food riots in Mexico. The demand for wood pellets for heating systems and electricity is already causing massive forest devastation in the southeastern US, serving a global market. How far can we go with this in Vermont, or do we just export the problem by importing fuel from a forest in someone else’s, less cared for, backyard? And renewable natural gas is its own can of worms. Some of that will come from landfills, although there will be less if the landfill is not loaded with organics that should be composted elsewhere. Some will come from CAFOs, concentrated animal feeding operations, well known for their water and air pollution and severe impacts on nearby communities, often lower income or BIPOC communities. Some CAFOs are even registered superfund sites. Modest greenhouse gas benefits with monstrous impacts.
So, let’s take a minute to get real about the impacts of relying on bioenergy to solve our climate problem. Does the Public Utility Commission (PUC) have the capacity, will, or even the authority to study these impacts and draw a clear line preventing them?
There are other issues to clear up with the CHS. What are the potential pitfalls with this brand new credit trading system, and the banking of credits that was so damaging to the Regional Greenhouse Gas Initiative (RGGI) system; is the PUC really up to this, are they given the direction and authority to effectively manage this? And then what about the cost? The anticipated push for weatherization and other clean heat measures will not come for free, and those costs will of course be passed to consumers. And what about conflicts of interest as big players in the fuel market are given seats on the Technical Advisory Group, or are even allowed to apply to become the Default Provider?
We did not foresee the tall stacks problem that later contributed to acid rain. We didn’t foresee the toxicity and mobility of MTBE, or the impact on food systems of ramping up ethanol. We did know about mercury, although this was less than the mercury pollution from burning coal, but we did not know that the LEDs would be ready so quickly, so we got caught in that excuse. Right now, we absolutely do know about the problems associated with bioenergy. So there can be no excuse.
There are reasons some of Vermont’s great environmental advocates and legislators are enthusiastically behind this. It’s very possible this could turn out to be an important solution. But the way the Clean Heat Standard bill looks right now as it’s poised to move from the house to the senate, there are some very big gaps, and unless they are fixed, we become part of the problem, not the solution.
OK, now I have to go get rid of some toxic waste.