The Atlantic Monthly notes Chu’s SEAB members “are insiders who know how to fight in Washington’s trenches.”  Sue is the former Assistant Secretary for Policy at the U.S. Department of Energy (appointed by President Clinton).  She also served as the Secretary for Environmental Affairs in Massachusetts (appointed by Governor Weld), Commissioner at the Massachusetts Department of Public Utilities (appointed by Governor Dukakis), and executive director of the Massachusetts Energy Facilities Siting Council.  Recently, she co-led the Obama/Biden Transition’s Department of Energy Agency Review Team.   Her area of expertise include gas and electric markets and regulatory policy, resource planning and analysis (including energy efficiency and renewable energy), regional transmission organizations, the siting of generation, transmission and natural gas pipeline projects, and environmental policy and regulation.  We look forward to seeing the advances in energy policy and practice that are sure to come in the future. Congratulations Sue!

These new rules will significantly limit which projects can qualify for renewable energy credits, without which many of the facilities most likely cannot be built economically.  Biomass power, the New York Times writes in an article about this very topic, is “a $1 billion industry in the United States according to the Biomass Power Association, a trade group based in Maine.  Biomass has long been considered both renewable and carbon-neutral on its most basic level.” The article goes on to state, “[t]he technology has long held substantial allure for state and federal regulators seeking to diversify energy portfolios. California, Maine, Michigan, New Hampshire, Oregon, Vermont and Washington are among the states that make heavy use of biomass.” Because Massachusetts is considered a leader in the development of renewable energy portfolio standards, the stricter regulations that the Commonwealth is developing may carry considerable implications for biomass developers, as well as for other states developing their own renewable portfolio targets.

We agree that there must be regulations in place to support the sustainable development of biomass power, especially surrounding the use of “clean wood;” however these regulations should not stymie the development of biomass power as part of the State’s renewable energy portfolio. When it was first released, the results of the Manomet study were widely misrepresented and Manomet’s President, John Hagan, released a statement in an attempt to clarify the conclusions.  Hagan wrote “One commonly used press headline has been ‘wood worse than coal’ for GHG [greenhouse gas] emissions or for ‘the environment.’ This is an inaccurate interpretation of our findings, which paint a much more complex picture.”  He goes on to clarify a number of the findings point by point and ends saying reminding us that there are many factors, in addition to greenhouse gases, that must be taken into consideration when developing energy policy, including: energy security, air quality, forest recreation values, local economics, and other environmental impacts.

Biomass power has the potential to significantly strengthen the State and the Nation’s domestic and renewable energy goals.  Biomass energy offers a baseload power solution that solar and wind cannot. Waste biomass, especially, offers significant benefit as the wood as already reached the end of its useful life and using the material beneficially for energy production not only helps to reduce reliance on fossil fuels but it also reduces the amount of wood that is landfilled.  We hope that the policymakers at the Massachusetts Department of Energy Resources consider this as they begin to write new regulations on biomass energy as a renewable resource.

The preceding master plan (Beyond 2000 Solid Waste Master Plan) outlined a vision for solid waste management in Massachusetts that included:

• Reducing the toxicity of our waste to the irreducible minimum,
• Disposing only residuals from recycling and other waste reduction efforts, and
• Ensuring that waste handling facilities are environmentally sound.

While still including an emphasis on waste disposal reduction, the 2010-2020 Plan focuses on an integrated approach that manages materials throughout their lifecycles. Including:

• Promoting more efficient use of materials,
• Increasing recycling of materials that have served their useful purpose,
• Reducing the amount of waste requiring disposal,
• Reducing the toxicity of the waste requiring disposal, and
• Improving the environmental performance of solid waste management facilities.

MassDEP goes on to state that the plan “also lays the groundwork for a zero waste approach for the future, where all materials are efficiently used and then given a future use—whether in new products, nutrients returned to the earth, or energy” (p. 14). To achieve zero waste for the future, MassDEP is shifting their solid waste management priorities from focusing on a waste reduction to a disposal rate reduction target for a measuring progress. More specifically, by 2020 the goal is to reduce annual solid waste disposal by 30% from 6,550,000 tons of disposal in 2009 to 4,550,000 tons of disposal in 2020.  MassDEP writes “This reduction in disposal could happen through varying combinations of source reduction, material reuse, recycling, composting, and using source separated materials as fuels, or other beneficial uses of materials” (p. 16). We have a number of options for disposal reduction, and once we fully embrace the technologies and alternative markets that allow us to reduce landfill use, we will be able to reach this 30% goal.

The path to zero waste, MassDEP acknowledges, can only be achieved when we all shift our views on the use of materials. Instead of relying on the assumption that our unwanted material is trash and should be disposed, we need to first think about reusing and recycling, which not only adds commercial value to the material, but it also transforms waste from a burden on the environment to valuable product for alternative use.  It is important that as the Department works to implement the objectives outlined in the document, that innovative technologies do receive the encouragement and regulatory support that are necessary to altering the views of material from waste to valuable products.  In addition to helping to reduce waste disposal, the reuse of materials for energy in advanced technologies helps the Commonwealth reduce its reliance on fossil fuels.  We at Ze-gen see a tremendous opportunity in being one of many new technologies focused on reducing the scourge of landfill disposal and instead increasing recycling and beneficial reuse of materials to produce energy and other useful products.

The draft is ready for comment and public hearings will be held throughout the month of July and September (see schedule), and public comments are due September 15^th.

The results of the study call into question the ‘carbon-neutrality’ of biomass and brings up a number of other points that are due to be hotly debated as the DOER develops its policy. Bill Opalka, of renewablesbiz.com, suggests this study, and the subsequent stakeholder meetings and public commenting periods “could eventually lead to the state downgrading biomass resources.” It will be important to keep watch on this issue as we move forward in developing our renewable energy portfolio, as it will undoubtedly affect the shape of our energy goals.

1. Reduce statewide greenhouse gas (GHG) emissions between 10 and 25 percent below the statewide GHG emissions levels in 1990 by 2020, and
2. Reduce statewide GHG emissions at least 80% below the statewide GHG emissions level in 1990, by 2050.

In order to ensure that these goals are met, the Secretary of the Executive Office of Energy and Environmental Affairs (EOEEA) must set the 2020 emissions target (between 10% and 25%) and develop an implementation plan for achieving the required GHG emissions reductions by 2020. To officially set the emissions target, the EOEEA will be holding public hearings. During the hearings, the Secretary will take public comment on a 2020 reduction target between 18% and 25%, as well as testimony on measures to achieved that target that show the greatest potential for energy cost savings and job growth.  On April 30th, Massachusetts released the “Commonwealth of Massachusetts’ Draft Climate Implementation Plan: A framework for meeting the 2020 and 2050 goals of the Global Warming Solutions Act,” which is available from the Massachusetts Department of Environmental Protection’s website. The draft plan outlines the criteria for strategies to reduce GHG emissions in the state and where the Commonwealth should aim for cost-effective GHG reductions.

Massachusetts’ technical consultant completed an analysis that showed that state and federal policies now in place or anticipated have Massachusetts on track toward emissions reductions of 18 percent by 2020. This number indicates the State is on target to achieve the lower end of the target in reductions, and it also suggests there is room to make improvements to reach the at least the 25% target. While the analysis suggests there are three major areas of opportunity (transportation, buildings, and energy supply), it is important that we do not lose sight of the less commonly thought of reduction opportunities such as reducing the landfilling of waste. When organic waste decomposes in landfills it produces methane gas, which is 21 times more potent a greenhouse gas than CO2.   Clean technology solutions, such as waste gasification, offer the Commonwealth the ability to reduce the amount of waste that is sent to landfills, while also adding the benefit of generating a clean gas that can be used to offset fossil fuel consumption. Often it is easy to ignore what happens to our waste once we put it out on the curb, but investing the resources to end landfilling has the potential to make significant gains in our efforts to reduce GHG emissions. The public hearings represent an excellent opportunity to add to the discussion about implementing innovative strategies to achieve the Commonwealth’s greenhouse gas emissions reductions goals.

(Please See MassDEP website for the Public Hearing Notice)

Including biomass power plants under the EPA’s tailoring rule is a clear policy shift and may imply a change in position for future policy.  The lack of distinction between renewable biomass as an alternative fuel to traditional fossil fuels like coal, oil, and natural gas means that biomass may no longer be considered more attractive as an option for increasing the nation’s alternative energy portfolio from a carbon emissions perspective.  In the New York Times article, “Biomass Industry Sees ‘Chilling Message’ in EPA’s Greenhouse Gas Emissions Rule” policy analyst for the Natural Resources Defense Council, Franz Matzner  points out his view that there is an important difference between biomass that increases greenhouse gas emissions (such as trees in a forest) and biomass that leads to reductions such as waste biomass (i.e. agricultural crops, wood waste).  The environmental sustainability of widespread use of forest trees for energy production has been questioned by some policy advocates in recent years and is being actively debated in many policy circles.

Using biomass waste for energy production offers significant environmental benefits.  Real reductions in CO₂ emissions occur when waste is used to replace fossil fuels, instead of being left to decompose in landfills or on fields. When wood waste is left to decompose in landfills, the decaying wood releases methane which is 21 times more potent a greenhouse gas than CO₂.  Failing to make the distinction between different types of biomass for energy production threatens to deter efforts to reduce fossil fuel usage for energy production that also have positive benefits for carbon emissions.

When issuing the final statement on the “tailoring rule,” the EPA stated that it does not have enough evidence to exclude CO₂ emissions from biogenic sources at this time, but that they recognize the issue warrants further explanation, and they plan to seek further comments on addressing the issue.  It is important that the EPA examine this issue further.  Retaining the carbon neutral status of biomass and exempting biomass from the tailoring rule may help to decrease the nation’s reliance on fossil fuel by making use of a domestic renewable resource.  Policymakers must be careful not to create maligned incentives in carbon policy that would stem this transition toward increased renewable fuel use in our nation’s energy mix.

Logically, renewable biomass should include things that grow in the ground: wood and wood products, crops, grains, grasses, fruits, veggies, and the like.   However, the politics of renewable energy are complicated and there are a number of competing views on what should be included:

1. Agricultural interests tend to support an inclusive approach – they would love for all their crops, forestry products and by-products to be included
2. Energy industry interests would like to make the definition narrow and specific, allowing a limited level of biomass-fueled electricity, but trying not to displace other fuels in large quantity.
3. Environmental groups have a mixed view – support for greater use of biomass in order to move away from fossil fuels, but a distaste for some components of biomass, like wholesale clearcutting of forest lands for fuel or the burning of  painted or treated wood due to the potentially harmful air emissions.

While the Waxman-Markey Bill settled on one definition of renewable biomass (see below) there are currently 14 definitions floating around in the Senate, stemming from the many definition that exist under Federal law and regulation. For Ze-gen, one of the most important parts of the definition is whether or not construction & demolition debris, and painted & treated wood are included because Ze-gen’s advanced gasification process is well suited for these difficult-to manage materials. The Waxman-Markey definition of renewable biomass includes construction waste, and other waste wood. Similarly, the Boxer/Kerry bill includes construction wood waste, but specifically excludes “painted, treated or pressurized wood, or wood contaminated with plastic or metals”. While the combustion of painted and treated wood may cause harmful air emissions when used in some waste to energy technologies, we believe that the exclusion of this valuable material should be reconsidered given emerging technologies that can safely process these materials.

While clearly defining what “renewable biomass” is an important nuance of any comprehensive energy bill, legislation should not forget to promote new technologies that can convert these materials into useful clean energy, while meeting stringent air emissions guidelines. Technologies like Ze-gen’s liquid metal gasification process are emerging that can properly manage the contaminants typically associated with painted and treated wood, and incentives promoting the use of biomass should consider these new developments. Including all types of waste wood in the definition of renewable biomass serves to increase the Nation’s renewable energy production potential, encourage new technologies that can effectively process these more challenging biomass materials, and help to end the unnecessary landfilling of biomass waste material.

For Reference:

Waxman-Markey Definition of Renewable Biomass

• `(i) Materials, pre-commercial thinnings, or removed invasive species from National Forest System land and public lands (as defined in section 103 of the Federal Land Policy and Management Act of 1976 (43 U.S.C. 1702)), including those that are byproducts of preventive treatments (such as trees, wood, brush, thinnings, chips, and slash), that are removed as part of a federally recognized timber sale, or that are removed to reduce hazardous fuels, to reduce or contain disease or insect infestation, or to restore ecosystem health, and that are–
  • `(I) not from components of the National Wilderness Preservation System, Wilderness Study Areas, Inventoried Roadless Areas, old growth stands, late-successional stands (except for dead, severely damaged, or badly infested trees), components of the National Landscape Conservation System, National Monuments, National Conservation Areas, Designated Primitive Areas, or Wild and Scenic Rivers corridors;
  • `(II) harvested in environmentally sustainable quantities, as determined by the appropriate Federal land manager; and
  • `(III) harvested in accordance with Federal and State law, and applicable land management plans.
  • `(ii) Any organic matter that is available on a renewable or recurring basis from non-Federal land or land belonging to an Indian or Indian tribe that is held in trust by the United States or subject to a restriction against alienation imposed by the United States, including–
    • `(I) renewable plant material, including–
      • `(aa) feed grains;
      • `(bb) other agricultural commodities;
      • `(cc) other plants and trees; and
      • `(dd) algae; and
• `(II) waste material, including–
  • `(aa) crop residue;
  • `(bb) other vegetative waste material (including wood waste and wood residues);
  • `(cc) animal waste and byproducts (including fats, oils, greases, and manure);
  • `(dd) construction waste;
  • `(ee) food waste and yard waste; and
  • `(ff) the non-fossil biogenic portion of municipal solid waste and construction, demolition, and disaster debris.
  • `(iii) Residues and byproducts from wood, pulp, or paper products facilities.’.

• (b) Reduction- The last sentence of section 211(o)(7)(D) of the Clean Air Act (42 U.S.C. 7545(o)(7)(D)) is amended to read as follows: `For any calendar year in which the Administrator makes such a reduction, the Administrator shall also reduce the applicable volume of renewable fuel and advanced biofuels requirement established under paragraph (2)(B) by the same volume.’.

In addition,  Senator Debbie Stabenow (D-MI) stated Clinton “warned lawmakers about the danger of the U.S. falling behind China in the global race to dominate the clean-energy market.” A national energy bill that provides sufficient funding for the research and development of cutting edge technologies and establishes a market for the commercialization of clean technologies will not only help the United States lead in renewable energy production, but it will offer companies and institutions across the country the tools to establish sustainable green jobs to bring products, tools, and ideas to the market that harness the U.S.’s renewable energy potential.  Kerry, Boxer, and Lieberman’s efforts to introduce a bill by Easter are a step in the right direction toward ensuring the future success of clean technology development in the U.S.   It is crucial that government supports not only the funding for research and development, but also demonstration-scale testing and commercialization efforts so that new clean energy technologies can effectively move out of the lab and into full-scale production.  Only then can we begin to build the next generation of low-carbon energy infrastructure.

The initiation of the solicitation process represents a significant step forward for the sustainability of renewable energy development and generation in Massachusetts. The ability to sign long-term contracts provides renewable energy projects with increased financial certainty, and therefore, helps to increase the project’s ability to attract investors. For example, when Ze-gen begins to commercialize our process, in order to finance the construction and operation of the facility,  a long-term power purchase agreement will help to make the financing much more attractive. This is true not just for Ze-gen, but for other alternative energy developers, such as solar and wind projects as well, which means these contracts will help to further diversify and increase the State’s energy portfolio.  Helping to ensure financial certainty for renewable energy projects will go a long way toward Massachusetts to fulfill its energy goals.