FutureMetrics criticizes treatment of biomass in EPA’s ACE rule

By Erin Voegele | June 24, 2019

FutureMetrics has released a statement criticizing the U.S. EPA’s Affordable Clean Energy Program for its treatment of biomass and calling the program’s discussion of how to measure CO2 emissions “misguided.”

The EPA released the final rule for its ACE program June 19. The program replaces the Obama-era Clean Power Plan and establishes emissions guidelines for states to use when developing plans to limit carbon dioxide at coal-fired power plants. While biomass co-firing was discussed as a potential compliance option in the proposed rule, the final rule specifies that biomass co-firing cannot be used to comply with the ACE program.

The ACE rule identifies heat rate improvements (HRI) as the best system of emission reduction (BSER) for carbon dioxide from coal-fired power plants. Heat rate is a measure of the amount of energy required to generate a unit of electricity. The BSER must be applicable to, at, and on the premises of an affected facility.

Within the final ACE rule, the EPA clarifies “that biomass does not qualify as a system of emission reduction that can be incorporated as part of, or in its entirely, as BSER,” noting that the “BSER determination must include systems of emission reduction that are achievable at the source.”

“While firing of biomass occurs at a designated facility, biomass firing in and of itself does not reduce emissions of CO2 emitted from that source,” the EPA continued in the rulemaking. “Specifically, when measuring stack emissions, combustion of biomass emits more mass of emissions per Btu than that from combustion of fossil fuels, thereby increasing CO2 emissions at the source. Recognition of any potential CO2 emissions reductions associated with biomass utilization at a designated facility relies on accounting for activities not applied at and largely not under the control of that source, including consideration of offsite terrestrial carbon effects during biomass fuel growth, which are not a measure of emissions performance at the level of the individual designated facility. Use of biomass in affected units therefore not consistent with the plain meaning of ‘standard of performance’ and cannot be considered as part of the BSER.”

William Strauss, president of FutureMetrics, released a statement June 24 criticizing the agency’s treatment of biomass within the rule.

“In a bit of an Orwellian logic, the EPA’s recently finalized ACE rules…ignore the basis for why using biomass for power and heat is the principal pathway for decarbonization in most other developed countries,” Strauss wrote. “By only counting the CO2 emission at the source and ignoring the continuous adsorption of CO2 by sustainably managed forests, the EPA has excluded a proper consideration of the dynamics that keep the net CO2 added into the atmosphere neutral or even negative.

“In Europe, wood pellets and wood chips are recognized as low carbon fuels because a full life-cycle analysis shows that under well-crafted (and necessary) sustainability criteria, the combustion of those fuels is carbon neutral,” Strauss continued. “The supply chain carbon footprint accounting, given that fossil fuel are used in transportation and in the electricity used to upgrade the biomass into pellets, typically yields an 85 percent or more reduction in net CO2 added to the atmosphere. Because of the carbon benefits, biomass derived fuel makes up about 60 percent of the total renewable energy in the EU28.”

Strauss argues that the agency’s “ACE determinations are inaccurate in stating that ‘accounting for activities not applied at and largely not under the control of the source’ is a reason to ignore carbon sequestration under well-managed forest sustainability protocols.”

Rather, Strauss notes utilities in the U.K. and EU that substitute wood pellets for coal account for “activities” that are across the Atlantic Ocean from their emissions sources. He said the nearly 9 million metric tons of pellets that North America will export to Europe this year for use on power plants “are all subject to rigorous requirements to prove that the carbon stock in the landscape that is the source of pellet production feedstock is not being depleted.”

“The EPA is ignoring well-established protocols that supported about $1 billion in pellet exports from the U.S. in 2018,” Strauss continued. “Almost all those exports were certified by independent third-party entities as sustainably sourced and thus able to qualify as low-carbon fuel for power stations.

“It is only with blinders on and with half-baked logic that the EPA is able to ignore the net carbon intensity of coal generation, the consequences of rapidly increasing atmospheric CO2 concentrations, and the benefits of substituting wood pellets produced from renewing forests for coal,” he said.

Strauss cites EPA estimates that show the CPP was expected to reduce CO2 emissions by 970 million tons by 2030. The ACE rule, however, is expected to result in only 11 million tons of CO2 reductions over the same time period. Strauss also notes that FutureMetrics published two white papers in recent years that aimed at Congress and President Trump that explain why it makes good economic sense to consider co-firing wood pellets at power stations. Those papers, titled “Trump Wants to Save the Coal Industry—We Offer a Plan that can Help” and “Why the Clean Power Plan is NOT War on Coal” can be downloaded from the FutureMetrics website.