August 3, 2009

To All Members of the United States Senate

              Re:  Clean Energy and Climate Change Legislation

Dear Senators:

We are members of a network of concerned Americans and environmental groups who work every day to ensure the health of our planet and our communities. Our goals include meaningful progress on climate change. We write because the American Clean Energy and Security Act (ACES) bill passed by the House of Representatives on June 26, 2009, proposed as the template for a Senate bill, has sections that are seriously flawed.

According to David G. Hawkins, Director of Climate Programs, Natural Resources Defense Council in testimony before the Senate Environment and Public Works Committee on July 7, 2009, the ACES bill contains “a large biomass loophole that ignores the global warming emissions related to biomass production and combustion.” In fact, this loophole extends beyond biomass burning, to the incineration of municipal solid waste, construction and demolition debris and other materials to generate what is wrongly referred to as “renewable electricity.”[1]  This loophole allows these power plants to generate unlimited and uncontrolled amounts of CO2.  According to U.S. Department of Energy figures, by 2020 biomass burning will generate 700,000,000 million tons of CO2 per year.  The bottom line is that classifying this burning as a “renewable energy source” means that it is promoted and subsidized by the bill even though CO2 emissions accelerate climate change.

It is our position that the Renewable Electricity Standard (RES) of any climate change bill should not qualify burning biomass, municipal solid waste, construction and demolition debris, or other materials as a “renewable energy resource.”  When compared to coal, per megawatt, this burning emits 1.5 times the carbon dioxide (CO2), 1.5 times the carbon monoxide (CO, a toxic air pollutant), and as much particulate matter. [2] The latter toxic emissions cause cancer, asthma and respiratory ailments.  Incineration and biomass burning to generate renewable electricity also generates toxic ash, drains rivers through the evaporation of large volumes of cooling water, often discharges heated and polluted effluent to rivers, and when wood is used, burns forests thereby decreasing the capacity of the ecosystem to sequester carbon.  The large amounts of woody biomass required by these power plants threatens our Nation’s forests, regarded by other parts of the bill as critical “carbon sinks” for their carbon sequestration value.  By qualifying this burning as a “renewable energy resource”, the RES replaces burning coal with something worse. 

While industry argues that incineration is “carbon neutral,” particularly with regard to burning forests, this is a myth.  In fact, burning to generate “renewable electricity” adds greenhouse gases to the atmosphere in the critical near-term period.  Moreover, this CO2 will not be reabsorbed before the planet reaches its “tipping point.”  According to U.S. EPA, the CO2 emitted by burning biomass and other materials to generate renewable electricity will not be reabsorbed for hundreds to thousands of years.  The U.S. EPA’s April 2009 proposed endangerment finding puts the matter starkly:  “… for a given amount of CO2 released today, about half will be taken up by the oceans and terrestrial vegetation over the next 30 years, a further 30 percent…over a few centuries, and the remaining 20 percent…will take many thousands of years to remove from the atmosphere.”  74 Fed. Reg. 18899, 4/24/2009.

Clearly, the large volumes of CO2 emissions emitted by burning to generate “renewable electricity” will not be reabsorbed in time to “neutralize” this  CO2. This is true – regardless of the number of trees planted to replace the wood that is burned.  After all, there is a difference in CO2 absorption capacity between old forests and new growth trees.  In an article entitled “The Giving Trees,” Spring 2008 edition of NRDC publication ONEARTH, the author writes: “It turns out forests hundreds of years old can continue to actively absorb carbon, holding great quantities in storage.  Resprouting clear-cuts, on the other hand, often emit carbon for years, despite the rapid growth rate of young trees.”[3]

              Senators, we stand ready to support a climate change bill that will implement real reductions in greenhouse gas emissions.  But, American taxpayers and rate payers ought not to incur costs for the implementation of a regulatory scheme that ignores the science by classifying biomass burners and incinerators as “renewable energy” when the science shows exactly the opposite.

We seek your assurance that your actions will be based on the EPA science on this matter, and accordingly that you will change pertinent provisions of the House-backed bill (H.R. 2454). Whatever else a climate change bill does, we are sure you will agree that it ought not to harm the environment and human health.

Very truly yours,

BiofuelWatch

Blue Ridge Environmental Defense League

Cascadia’s Ecosystem Advocates (WA)

Connecticut River Watershed Council

Concerned Citizens of Russell (MA)

Concerned Citizens of Crawford County (IL)

Greenwich Citizens Committee, Inc. (NY)

Deer Creek Valley Natural Resources Conservation Association (OR)

Dogwood Alliance

EcoLaw/Massachusetts

Ecology Party of Florida

Energy Justice Network

Environmental Alliance of North Florida

Finger Lakes Zero Waste Coalition (NY)

Florida League of Conservation Voters

Floridians Against Incinerators in Disguise

Food First/Institute for Food and Development Policy

Forest Ethics

Friends of Freetown/Fall River State Forest (MA)

Friends of Middlesex Fells Reservation (MA)

Global Alliance Against Incinerators

Green Berkshires, Inc.

Green Delaware

Green Party of Florida

Greenvironment, LLC (MA)

HealthLink (MA)

HOPE (Help Our Polluted Environment) in Taylor County, Florida

Green Press Initiative

Indiana Forest Alliance

Institute for Local Self Reliance (Washington, D.C.)

Jones River Watershed Association (MA)

Jones River Landing (MA)

Kentucky Heartwood

Leaders for Today (MA)

Massachusetts Environmental Energy Alliance

Massachusetts Forest Watch

Nassau County Group of the Sierra Club (FL)

Native Forest Council

Neighbors Against the Burner (MN)

Oregon Toxics Alliance

Pioneer Valley Preservation Coalition (MA)

Pike Gibson Citizens for Quality Environment (IN)

RESTORE: The North Woods

Salem Alliance for Environment (MA)

Springfield Area Sustainable Energy Association (MA)

Stand Up/Save Lives Campaign (IL)

Trout Unlimited/Greater Boston (MA) Chapter

ValleyFree Radio (MA)

The Wilderness Society/Australia, Forests and Climate Change Campaign

World Species List Forest (MA)

Individuals

Massachusetts

Glen Ayers, Soil Scientist, BS, MS, Leverett

Anne Bingham, Esq., Sharon,

Lynn Ballard, Greenfield

Shelley Beck, Greenfield

Jana Chicoine, Russell

Patrick Devlin, Greenfield

Donna Fashishta, R.N., M.Ed., Greenfield

David Gaffney, Esq.

Gary Greene, Greenfield

Peter Gallant, Wendall State Forest

John Heffernan, Conway

Wendy Howes, Hubbardston

Claudia Hurley, Westfield

Michael Hurley, Westfield

Susan E. Laing, Greenfield

Ashley Lessard, Buckland

Michelle P. Lesieur, Westfield

Lorena Loubsky-Lonergan

Ellen Moyer, Ph.D., P.E., Montgomery

Adrianne Rogers, Winchester

Janet Sinclair, Shelburne Falls

Gene H. Theroux, Southwick,

Alex Peterkin, Northampton

Shelly Beck, Greenfield

Wilder Sparks, Buckland

Lillian Woodburn

Henry Worchol, Westfield River Watershed Association

Florida

Thomas Bussing, PhD, Former Mayor, Gainesville

Emily Hamilton, Miami

Karen Orr, Gainesville

Dick Stokes, Gainesville

Vermont

Richard Stafursky, Brattleboro

[1] See, ACES, Section 101(a)(17) definition of “renewable electricity”, Section 101(a)(18) definition of “renewable energy resource,” Section 101(a)(12)(A)-(D) definition of “other qualifying energy resources,” Section 101(14)(a) definition of “qualified waste to energy,” and Section 101(16) definition of “renewable biomass.” 

[2] See, www.massenvironmentalenergy.org for plant data on typical 50 MW power plants that burn wood and/or construction and demolition debris.  The Global Alliance for Incinerator Alternatives has also documented that emissions from incineration to generate renewable electricity emits more toxins than coal burning.  Additional information can be obtained from Energy Justice Network, www.energyjustice.org.

[3] http://www.onearth.org/article/the-giving-trees?page=1

Public should be privy to biomass discussion