The Role of Biomass in the Clean Power Plan - EPA's Carbon Accounting Punt and Emerging Threats to Forests

Transcription

1 The Role of Biomass in the Clean Power Plan - EPA's Carbon Accounting Punt and Emerging Threats to Forests Mary S. Booth Partnership for Policy Integrity Monday, February 2, 3:00 PM 4:00 PM (Eastern Time) Dial in at this number: (there is no passcode)

2 Conference Call setup Welcome to the webinar. Lines will be muted during the presentation, but you can unmute yourself by pressing ** Lines will be unmuted at the end for questions and discussion, which can go beyond the hour if necessary. 2

3 What is Biomass? For our purposes, Biopower or Bioenergy : Burning wood and other materials of recent biological origin in power plants to generate electricity. Often treated as carbon neutral based on assumption that fuels are wastes that would decompose and emit CO 2 anyway, or, that trees and other plants will regrow and sequester CO 2 released by burning. Other energy wood : Wood Pellets (exportable biomass fuel for burning in European coal plants); and Liquid Biofuels made from wood as feedstock. Topic for today: Why EPA s treatment of bioenergy as carbon neutral is a threat to forests and the climate. 3

4 EPA s Clean Power Plan Clean Air Act program for regulation of CO 2 from the fossil-fired electricity sector. Four building blocks to decrease the state-wide rate (of pounds CO 2 emitted per megawatt-hour) (MWh): 1. Increase efficiency at coal plants 2. Increase deployment at natural gas plants 3. Increase deployment of nukes and build renewables (incl. biopower) 4. Increase demand-side efficiency EPA s equation for the state-level emissions rate,* with target rates to be achieved by 2020 and 2030: lb CO 2 (fossil fueled power plants) MWh electricity (fossil fuels, nukes, renewables including biopower) * Equation has been simplified for purposes of this discussion 4

5 The bioenergy loophole at the heart of the Clean Power Plan Burning biomass does emit CO 2 more CO 2 than fossil fuels. Emissions may be offset by forest regrowth over time, but paying off this bioenergy carbon debt takes years, decades, even more than a century The Clean Power Plan rate equation ignores these emissions: No biopower emissions term lb CO 2 fossil fueled power plants +?? MWh electricity (fossil fuels, nukes, renewables including biopower) Treating biomass as carbon neutral i.e., Counting bioenergy MWh (in the denominator), but not counting bioenergy emissions (in the numerator) is a policy mistake that ignores science, undermines the Clean Power Plan, and threatens forests (the real DeflateGate of the rate!) 5

6 It gets worse! Not only does the rate equation for the CPP treat all bioenergy as having zero emissions - Also, EPA has signaled that virtually ALL biomass will be permitted and treated as zero emissions for purposes of Clean Power Plan compliance at the State level (the McCabe memo ). 6

7 Domestic biopower 50 MW McNeil plant, Burlington Vermont. ~625,000 green tons/year 7

8 Pellet production Enviva wood pellet facility, Ahoskie, North Carolina (850,000 green tons/year) 8

9 Liquid Biofuels using wood as feedstock Kior plant, Columbus, MS ( , ). ~360,000 green tons/year 9

10 Actual and projected growth in the biopower industry (built capacity for 2008 from Energy Information Administration; built capacity and proposed capacity from 2008 onwards from Forisk, Wood Bioenergy US database, December 2013). Not all facilities will be built. The biopower industry is growing rapidly ~21% increase in capacity,

11 Energy Information Administration s reference case: Bioenergy triples by 2035 ~120 bn KWh ~40 bn KWh End-use generators Biomass sector generated about 40 billion KWh in 2013 Industry as a whole burned 119 million tons of fuel (includes pulping liquors); about half of this was wood (53 million tons) End-use sector still dominant but this will change. 11

12 EIA s GHG pricing and low-cost renewables projections Highest projected growth in bioenergy projected under GHG pricing framework ~225 bn KWh Reference case from previous slide ~40 bn KWh Assumption of zero carbon emissions is baked in. Having a fuel that is treated as zero-carbon is valuable. 12

13 EIA scenarios would require massive increase in forest harvesting Scenarios would provide just 2.5% to 4% of domestic electricity generation by 2030 (year by which Clean Power Plan achieves GHG reductions ) But scenarios require ~25% to 40% increase in forest harvesting just for domestic biopower (ignores wood demand for pellets, biofuels) Total US annual average harvest: ~729 million green tons Total wood required by three scenarios, 2030: Scenario in 2030 Tons wood/year Clearcut-acres equivalent/year Reference 167,218,291 2,229,577 Low-cost renewables 210,247,537 2,803,300 GHG$10 267,684,126 3,569,122 13

14 Replacing 10% of US coal power with wood would require cutting millions of acres of forest each year % decrease in coal generation compared to 2005 Year Million tons wood Million tons CO Acres forest 2,836,753 2,805,239 2,841,802 2,798,601 2,474,606 2,603,397 2,442,933 2,133,749 2,235,156 14

15 Growth in pellet industry Plants that are operating or under construction: 29 million green tons/year Plants that are in permitting,/contracts, financing: 24 million green tons/year Photo: Matt Eich, from 15

16 Export Pellets from the USA (Slide from presentation given by Irene Kowakczyk, MeadWestvaCo, March 2014 Kentucky Industrial Utility Customers annual meeting) Without the foreign (EU) subsidy, the entire industry fails European sustainability and certification specifications are being developed. There is no auditing mechanism available to verify even claims made today. This creates tremendous uncertainty. Pellet plant sites are being selected to minimize transportation costs to a port. The wood baskets won t sustain the harvesting pressure. The vast majority of the fiber is coming from whole trees, not residuals. This is the pellet model going forward. The perspective is that a bubble (demand in the resource) is being created that won t be sustainable. The damage created during its existence will create a lot of dislocation in the USA domestic wood markets. Once the coastal areas have been depleted the pellet plant sites will move more inland and pellets will be trucked or railed to ports. 16

17 Projections for liquid biofuels using wood as feedstock Few operating plants technology still being developed Some plants in development will use 1million tons of wood/year USDA just awarded $91m loan guarantee to Cool Planet biofuels for facility development in Louisiana Potential demand is massive. 17

18 Given that massive growth in energy wood use is underway and given that the assumption of C neutrality underlies use of wood for energy, EPA must use real science to assess bioenergy carbon emissions a blanket exemption is not acceptable. 18

19 A simple physical fact: Biomass power plants emit more CO 2 per MWh than coal or gas facilities Fuel CO2 per heat content (lb/mmbtu) Facility efficiency Fuel mmbtu required to generate 1 MWh Lb CO2/MWh Gas combined cycle Gas steam turbine ,218 Coal steam turbine ,086 Biomass steam turbine ,029 A biomass plant emits lb CO2 emitted per MWh ~150% the CO2 of a coal plant ~250% the CO2 of a gas plant ~ 340% the CO2 of a combined cycle plant Gas CC Gas ST Coal ST Fuel CO2 per heat content data are from EIA. Efficiency for fossil fuel facilities calculated using EIA heat rate data Biomass ST ( biomass efficiency value is common value for utility-scale facilities ,000 1,500 2,000 2,500 3,000 3,500 19

20 Not controversial that biomass emits more CO 2 per unit energy than fossil fuels So why has biomass energy been treated as carbon neutral? The waste argument: Materials burned are waste would decompose and emit CO 2 anyway e.g. forestry residues. No net increase in CO 2 emissions, but release from combustion is instantaneous while decomposition takes years to decades. The resequestration argument: Future forest growth offsets equivalent carbon as released by burning. No net release of carbon from fuel, over very long timeframes: carbon re-sequestration takes decades to centuries. Underlying both these arguments is the common misconception that the Intergovernmental Panel on Climate Change (IPCC) treats bioenergy as carbon neutral. It does not. 20

21 The IPCC does not treat bioenergy as carbon neutral Where do the emissions get counted? IPCC counts harvesting emissions in the land use change basket, not the energy basket The IPCC approach of not including bioenergy emissions in the Energy Sector total should not be interpreted as a conclusion about the sustainability or carbon neutrality of bioenergy. ( 21

22 Bioenergy carbon accounting The question carbon accounting should answer for any power plant: What does the atmosphere see? Each fuel has a different emissions story gas, oil, coal, biomass, shredded tires, garbage Burning one ton of green wood (~45% moisture content) emits ton CO 2 Biomass is the only fuel where we discount present carbon emissions because of future forest uptake, decades hence. Meanwhile, remember that forests take up carbon from all sources, not just bioenergy! 22

23 US forests are both sources and sinks for carbon U.S. GHG Emissions and Sinks by Sector (million tons CO 2 equivalent) Sector Energy 5, , ,333.6 Industrial Processes Solvent and Other Product Use Agriculture Land Use, Land-Use Change and Forestry Waste Total Emissions. 6, , ,388.0 Land Use, Land-Use Change and Forestry (Sinks). (875.8) (1,099.9) (997.6) Net Emissions (Sources and Sinks). 5, , ,390.4 Sinks mostly comprised of forest growth ,388 = the equivalent of 13.5 % of US emissions re-sequestered From U.S. EPA 40 CFR Parts 60, 70, 71 et al. Standards of Performance for Greenhouse Gas Emissions From New Stationary Sources: Electric Generating Units; Proposed Rule (page 1441) 23

24 What does the atmosphere see? Less CO 2 More trees More CO 2 Fewer trees Biopower emits more CO 2 per MWh and suppresses forest C sequestration over decades, compared to fossil fuels 24

25 Modeling results: forest harvesting residues (net emissions estimated on assumption that decomposition would occur anyway) The difference between the two lines is the additional CO 2 emitted by burning biomass instead of letting it decompose. Net CO 2 emissions from bioenergy still exceed fossil emissions for years to decades, even when burning Waste wood that would decompose anyway Worse than coal for 10 years, worse than gas for more than 30 years Decomposition calculation: (material left at year-x = e -0.1*(year-x 0.05 ) 25

26 But what about methane??! EPA: In the United States, methane is not a significant contributor to landscape carbon-based emissions related to the growth and harvest of biogenic feedstocks because most forestand agriculture-derived feedstocks are produced in upland areas rather than in areas with higher moisture content, such as rice paddies or wetlands. These areas do not typically generate methane emissions or, in some cases, have a small negative net methane flux. * * US EPA. Framework for Assessing Biogenic CO 2 Emissions from Stationary Sources. November,

27 CUMULATIVE EMISSIONS Conceptual model: net emissions from whole trees, other materials Trees that would otherwise continue growing ~32 years to parity with natural gas emissions Natural gas (stack emissions only) ~ 85 years to parity with natural gas emissions Waste wood/residues that would decompose anyway Forestry residues that would be burned onsite YEARS 27

28 Million tons CO2 Carbon debt payoff for 50 MW scenario Year facility MW Timber acres cut/yr % AG cut for timber, timber acres % AG cut for fuel, timber acres % AG cut, biomass only acres % slash left, timber acres % slash left, biomass only acres year Proportion fuel from residues Emissions rate (cumulative lb/mwh) , % 2, % 2, % 2, Net bioenergy 4 86% 2, emissions 5 86% 2, Natural gas 6 86% 2, % 2, % 2, Coal 9 86% 2, % 2, % 1, % 1, % 1, % 1, % 1, % 1, % 1, % 1, % 1, YEAR 20 86% 1, % 1, The atmosphere sees more CO 22 86% 1,469 2 from biomass than % 1, coal for >10 years, even though the biomass is mostly 24 86% 1, sourced from residues that would decompose anyway 25 86% 1, % 1,361 Sawtimber Total acres in 50 mile radius Proportion forest Proportion harvestable Rotation length (yrs) acres harvested per year 5,024, ,680 28

29 What a 50-mile radius looks like 100 miles 29

30 Million tons CO2 Increasing carbon debt for 150 MW scenario Year facility MW Timber acres cut/yr % AG cut for timber, timber acres % AG cut for fuel, timber acres % AG cut, biomass only acres % slash left, timber acres % slash left, biomass only acres year Proportion fuel from residues Emissions rate (cumulative lb/mwh) , % 2, % 2, % 2, Net bioenergy 4 29% 2, emissions 5 29% 2, Natural gas 6 29% 2, % 2, % 2, Coal 9 29% 2, % 2, % 2, % 2, % 2, % 2, % 2, % 2, % 2, % 2, % 2, YEAR 20 29% 2, % 2, Carbon debt of biomass is still increasing after 25 years 22 29% 2, % 2, % 2, % 2, % 2,768 Sawtimber Total acres in 50 mile radius Proportion forest Proportion harvestable Rotation length (yrs) acres harvested per year 5,024, ,680 30

31 Million tons CO2 Biomass parity with coal for increasing capacity scenario Year facility MW Timber acres cut/yr % AG cut for timber, timber acres % AG cut for fuel, timber acres % AG cut, biomass only acres % slash left, timber acres % slash left, biomass only acres year Proportion fuel from residues Emissions rate (cumulative lb/mwh) , % 2, % 2, % 2, Net bioenergy 4 86% 2, emissions 5 86% 2, Natural gas 6 58% 2, % 2, % 2, Coal 9 58% 2, % 2, % 2, % 2, % 2, % 2, % 2, % 2, % 1, % 1, % 1, YEAR 20 35% 1, % 1, % 1, The atmosphere sees about the same CO 2 from 23 29% 1, biomass and coal for about 20 years 24 29% 1, % 1, % 1,837 Sawtimber Total acres in 50 mile radius Proportion forest Proportion harvestable Rotation length (yrs) acres harvested per year 5,024, ,680 31

32 Biopower creates carbon debt even when fastgrowing plantation trees burned as fuel Southeastern Study (Colnes et al, 2012), Executive summary: The expanded biomass scenario creates a carbon debt that takes years to recover. This outcome depends on the fossil fuel pathway used for comparison and assumes forests re-occupy the site through planting or natural regeneration, with no forest land conversion. 32

33 EPA s framework for assessing net biogenic emissions Two approaches included: 1. Incorrect, and dismissed by EPA Science Advisory Board: As long as growth exceeds harvesting in a woodshed, biomass from that woodshed is carbon neutral ( sustainable harvesting) Double-counts credit for sequestration that is happening anyway! Is scale-dependent! 2. Correct: To determine what the atmosphere sees, calculate net emissions as the difference between emissions from burning biomass and emissions from alternate fate for that material (can then compare those net emissions against other fuels). 33

34 Defying its own science, EPA punts on carbon accounting November 19 th 2014 McCabe memo : EPA declares intention to treat most wood wastes as having zero emissions In fact, EPA scientists found that black liquor is the only fuel likely to have lower emissions if burned than if discarded in alternate fashion (see Appendix D of EPA carbon accounting framework) Most importantly: EPA will likely treat sustainably harvested biomass as having zero carbon emissions. 34

35 Treating sustainably harvested fuels as carbon neutral greenlights massive forest harvesting Drax (3,000 MW plant in UK, 50% wood pellet fueled, ~18 million tons green wood/year): "We are pleased that the US Environmental Protection Agency has signalled its intent to recognise the full carbon benefits of biomass where it is sourced from sustainably managed forests. Drax already has a robust, independently audited sustainability policy to ensure the sustainability of the wood fibre we use. Image: Drax Power Station as seen from a train travelling north on the main East Coast line. Copyright Dave Pickersgill and licensed for reuse under this Creative Commons Licence 35

36 Oh, The Irony Obama/McCarthy EPA proposes burning forests as means of reducing greenhouse gas emissions. 36

37 Sustainable Forestry Initiative certified biomass harvesting, Nova Scotia Photo credit: Jamie Simpson 37

38 Biomass harvest, Moosehead Lake region, Maine Photo credit: Jim Wallace, Massachusetts Gun Owners Action League 38

39 Sustainability is not the same as carbon neutrality! GROWTH: Tons forest biomass accumulation per year HARVEST: Tons forest biomass harvested and burned per year Net forest biomass accumulation Is harvesting "sustainable"? EMISSIONS: Tons CO 2 emitted from biomass burning Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No 13 39

40 Bioenergy carbon neutrality relies on emissions being offset EPA has said real offsets won t count under the Clean Power Plan: For emission budget trading programs that regulate EGUs and include offsets, which we define here as emissions reductions from sources not regulated by the trading program, emissions reductions from offsets would not be counted when evaluating CO 2 emission performance of affected EGUs, because those reductions would not come from those affected EGUs U.S. EPA. Projecting EGU CO 2 Emission Performance in State Plans. Technical Support Document (TSD) for Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units. Docket ID No. EPA-HQ-OAR , June Page 37. But EPA treats bioenergy as zero carbon even though discounting assumes emissions will be offset by forest growth in some other place, at some future time. 40

41 Will states/power companies actually use biomass to comply with the Clean Power Plan? 41

42 Existing and New Users of Pulpwood from Virginia (Export Pellet and Biomass Electrical Generation) (Slide from presentation given by Irene Kowakczyk, MeadWestvaCo, March 2014 Kentucky Industrial Utility Customers annual meeting) 42

43 Dominion Energy Virginia Three coal plants recently converted to burn forest wood (153 MW) 600 MW hybrid energy center can co-fire ~20% wood (117 MW) Existing Pittsylvania plant (83 MW) Combined demand: ~4.5 million green tons/year. Virginia s fossil-fueled electricity sector 2012: generated 69.7 million MWh emitted 31.7 million tons of CO 2. Dominion s wood-burners provide: 4.1% increase in electricity generation 13.6% increase in day to day power sector CO 2 emissions Dominion s anticipated mix of renewable energy generation in Appendix 6A of Dominion s Integrated Resource Plan, August 29, Dominion told the VA State Corporation Commission that if biomass were not considered carbon neutral, the value of coal-to-biomass conversions is less than Net Present Value of continued operation on coal 43

44 What should EPA do? Reducing power sector emissions with forest-derived bioenergy is like putting out a fire with gasoline. The CPP requires Best System of Emissions Reduction to reduce CO 2 emissions. Biomass doesn t qualify, so eliminate it as a compliance measure. If bioenergy is allowed, require robust, conservative, sciencebased carbon accounting that accurately assesses the impact of particular facilities and fuels on net CO 2 emissions over timeframes relevant to addressing climate change. Protect forests at all costs and scrub out any renewable energy policy that incentivizes forest cutting. 44

45 Key PFPI reports on bioenergy Trees, Trash, and Toxics: How Biomass Energy Has Become the New Coal (Meta-analysis of 88 emissions permits for biopower facilities, and the loopholes in the Clean Air Act that make biomass energy so polluting) Report and letter to Securities and Exchange Commission signed by investment groups, on climate and investment risks of bioenergy (names Dominion, Southern Co., and Covanta) Climate of Deception Report to Federal Trade Commission on how bioenergy greenwashing violates consumer protection standards (names 17 companies). 45

46 Mary S. Booth