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A Blow to Biomass

Massachusetts’ final RPS regulations could quash biomass energy in the state
By Lisa Gibson | May 22, 2012

On April 27, the Massachusetts Department of Energy Resources released its months-overdue proposed final regulations for the qualification of woody biomass under the state’s renewable portfolio standard (RPS). Massachusetts biomass developers and foresters alike have expressed concern that the regulations could effectively kill the state’s biomass industry.


“While we have no doubt that the Department of Energy Resources intended to protect the state’s and region’s forests with these rules, they are not based on sound science and, in reality, will have the opposite effect,” says Bob Cleaves, president and CEO of the Biomass Power Association.

Among a number of changes from the draft regulations filed in May 2011, is an increase in the minimum efficiency mandate from 40 to 50 percent. Now, biomass plants will receive half a renewable energy credit (REC) upon reaching 50 percent efficiency, and one full credit beginning at 60 percent. “This provision fundamentally will shift biomass development from power-only generation units typically operating at efficiencies around 25 percent,” the DOER writes in its summary of changes.
Many developers in Massachusetts have been waiting for the regulations before finalizing project plans. “They don’t make it easy in Massachusetts,” says John Bos, of Russell Biomass LLC, which has held development of its 50 MW biomass power plant in Russell, Mass., in the midst of regulation uncertainty.


The DOER also made changes to the regulations in the areas of carbon accounting, biomass fuel certificates and certificate registry, annual compliance and provisions for under-compliance, treatment of previously qualified biomass units, and eligible forest biomass and residue retention.


“The administrative requirements for documenting fuel sources and verifying qualification will greatly burden small biomass facilities, raising a question as to whether they can or will comply,” says Peter Bos, developer for Russell Biomass. “The further delay in enacting the final regulations serves to delay and likely kill all biomass projects.” Adjacent state biomass projects will use Massachusetts wood for fuel, he adds, and are not subject to the forestry requirements in the DOER regulations.
“The main or overarching constraint to any biomass development is not even in the biomass regulations,” Bos emphasizes. “It is the inability of any biomass plant to compete with wind for a power purchase agreement from an electric utility.”


The regulation change, following decades of subsidizing biomass power, came swiftly after the infamous Manomet study, which reported woody biomass releases more carbon dioxide per unit of energy than some fossil fuels. Despite several reports challenging the findings for numerous reasons, Massachusetts has continued with its goal of prompt policy change.


“As we have pointed out repeatedly, the Manomet study upon which these regulations are based did not explore the carbon accounting of energy using waste wood—the fuel used by the vast majority of biomass facilities,” Cleaves says. “More important, the use of waste wood by the biomass industry actually promotes forest health by removing the dead, rotting material. This allows new growth to replace it and, in the process, absorb more carbon. If forests remain at constant levels or increase, then the net effect is that carbon that is being removed is being reabsorbed, and indeed is better than ‘carbon neutral.’”


A comment period on the proposed final regulations is open from May 19 to June 18. A link to the full regulations and information for submitting comments can be found here: www.mass.gov/eea/energy-utilities-clean-tech/renewable-energy/biomass/renewable-portfolio-standard-biomass-policy
“If the true objective here is to reduce the use of fossil fuels in favor of homegrown, alternative energy sources—thereby reducing the carbon in our atmosphere—then Massachusetts is making a grave error,” Cleaves adds.

—Lisa Gibson