Biomass combustionDue Diligence

William A. H. Sammons, M.D.drsammons@aol.com

781-799-0014

Assurances

• I am not paid by a power producer or other energy entity. This is an imperative issue to address.

• The material is not my beliefs or my opinions• Every statement is referenced• I have been to DC in talks with EPA and

Congressional staff and elected officials in Congress

• I have played a part in stopping more than a dozen plants

What are we going to talk about?

• HEALTH– Dioxin and particulate matter [PM <2.5 microns]– Risk to everyone, but especially children

• REALITY– Current regulations are NOT PROTECTIVE OF HUMAN HEALTH– Requires difficult decisions by county/city leaders

• MONEY– 240+ plants across the country– > $20,000,000,000 in federal tax credits, grants, subsidies– $6-8,000,000,000/yr in renewable energy credits– Millions more in state grants, subsidies, and tax breaks

• CLIMATE EFFECTS

Data shows the following is true

• Biomass combustion is “dirtier” than burning coal• Health care effects and secondary increase in

costs are significant• Power from biomass combustion is expensive• Biomass combustion is unequivocally not carbon

neutral or climate neutral within any useful time frame

• Forest management science is controversial at minimum

Emissions from biomass combustionTHE TRUTH

• Not carbon neutral in a useful timeframe – multiple decades to a century

• Not climate neutral• Not human health benign• Not affordable

Biomass is NOT “clean”

• Biomass combustion, per unit of power produced, whether direct combustion or in a multiple stage gasification process, produces more harmful pollutants than burning coal

• THIS IS THE PRIMARY REASON IT IS A HEALTH RISK FOR ALL PEOPLE LIVING NEAR A PLANT

EMISSIONS COMPARISON DATA– Numbers Confirmed by EPA BURNING WOOD IS “DIRTIER” THAN BURNING COAL

PLANT FUEL CO2/MW(tpy)

NOx/MW(tpy)

PM/MW(tpy)

Boardman (PGE) Coal 9067 3.38 0.59

PVEC NG 3130 0.23 0.12

BIOMASS PLANTS IN MASSACHUSETTS

RUSSELL BIOMASS WOOD 12,644 3.9 1.69

Re: Coal (+39%) (+15%) (+186%)

Re: NG (+304%) (+1596%) (+1309%)

PRE BIOMASS WOOD 11,312 3.49 1.15

Re: Coal (+25%) (+3%) (+95%)

Re: NG (+262%) (+1417%) (+858%)

PALMER C&D 12,415 3.53 0.71

Re: Coal (+37%) (+4%) (+20%)

Re: NG (+297%) (+1435%) (+492%)

Gainesville, FL

• In 2010, Florida issued an air pollution permit for the 100 MW Gainesville Renewable Energy Center (GREC) biomass burning electricity project. In 2007, the adjacent coal plant installed new pollution controls. A comparison of relevant emissions between the two plants shows the biomass combustion plant will emit, per megawatt hour of power produced:

• 67% more carbon dioxide• 367% more particulate matter • 62% more NOx

– http://www.pfpi.net/carbon-emissions

Multiple Pollutants with known Negative Health Effects

• NOx• Ozone• Heavy Metals• VOC• HAPS• Dioxin• Furans• CO

Effects of air pollution--children• Air pollution affects the growth of lung function during the period of rapid

lung development between the ages of 10 and 18 years. Gauderman et al. (2007)

• Children’s Health study (CHS), which began in Southern California in 1993, included more than 6000 public school children. Many research papers emerging from this study have produced findings showing that exposure to air pollution in the region has resulted in increased school absences, asthma exacerbation, and new-onset asthma. (Künzli et al. 2003).

• Data from the American Cancer Society (ACS) cohort5 estimated that for each 10-µg/m3 increase in annual average exposure to PM2.5, long-term all-cause, cardiopulmonary, and lung cancer mortality were increased by approximately 4%, 6%, and 8%, respectively. The relationship between PM2.5 and adverse health effects was linear and without a discernible lower "safe" threshold. http://circ.ahajournals.org/cgi/content/full/109/21/2655

2009 SOTA from the American Lung Association

• The researchers concluded that air pollution may increase the risk of babies being born with low birth weight, even though almost all the air pollutants were at levels that were officially listed as safe by the U.S. Environmental Protection Agency.58

• Researchers tracking 3,500 students in Southern California found an increased onset of asthma [3x] in children who were taking part in three or more outdoor activities in communities with high levels of particle pollution.61

• Air Pollution Increases Risk of Underdeveloped Lungs Another finding from the Southern California Children’s Health study looked at the long-term effects of particle pollution on teenagers. Tracking 1,759 children between ages 10 and 18, researchers found that those who grew up in more polluted areas face the increased risk of having underdeveloped lungs, which may never recover to their full capacity. The average drop in lung function was 20 percent below what was expected for the child’s age, similar to the impact of growing up in a home with parents who smoked.62

Permit process provides inadequate protection

• American Heart Association• American Lung Association• American Cancer Society• More than 70,000 physicians

Florida –American Lung AssociationApril 11, 2011

• “Burning biomass could lead to significant increases in emissions of nitrogen oxides, particulate matter and sulfur dioxide and have severe impacts on the health of children, older adults, and people with lung diseases. “

• Furthermore, we have noticed a pattern nationwide of biomass plants being proposed for rural areas away from cities; where less protective pollution control restrictions and weaker permitting requirements apply. Plant proponents will say that they “meet the air pollution requirements” but the requirements themselves tend to be more lax.

DANGERSTATEMENTS FROM MEDICAL ORGANIZATIONS

• “[1] Not grant renewable energy credits to biomass, as well as [2] to not grant any other preferential treatment of biomass in any of the energy or climate change legislation.

American Lung Association to Senator Kerry Nov 16, 2009.

• The Massachusetts Medical Society stated its opposition to the three currently proposed largescale biomass power plants in Massachusetts on the grounds that each facility poses an unacceptable public health risk.

Testimony to the Massachusetts Legislature Feb 2010 by Massachusetts Medical Society

• The Hampden County Medical Society has expanded its opposition to construction and operation of this [Russell] and all other biomass power plants in Western Massachusetts, again citing unacceptable health risks to the population.

Open letter from HCMS November 19, 2009

EMISSIONS COMPARISON DATA– Numbers Confirmed by EPA BURNING WOOD IS “DIRTIER” THAN BURNING COAL

PLANT FUEL CO2/MW(tpy)

NOx/MW(tpy)

PM/MW(tpy)

Boardman (PGE) Coal 9067 3.38 0.59

PVEC NG 3130 0.23 0.12

BIOMASS PLANTS IN MASSACHUSETTS

RUSSELL BIOMASS WOOD 12,644 3.9 1.69

Re: Coal (+39%) (+15%) (+186%)

Re: NG (+304%) (+1596%) (+1309%)

PRE BIOMASS WOOD 11,312 3.49 1.15

Re: Coal (+25%) (+3%) (+95%)

Re: NG (+262%) (+1417%) (+858%)

PALMER C&D 12,415 3.53 0.71

Re: Coal (+37%) (+4%) (+20%)

Re: NG (+297%) (+1435%) (+492%)

Particulates• Particulates are produced by combustion– at very

high levels by diesel truck engines and biomass combustion.– More than burning coal per unit of power produced– Stack emissions [filterable] and those which form in the

atmosphere [condensable]

• Particulates come in multiple types:– PM 10 – a relatively minor health hazard– PM 2.5 & PM ultrafine & PM nano– major health hazards,

especially for children, as reported in literally thousands of medical articles in the last four years

– Other smaller particles

Particulates Inhale at Your Own Risk

• Studies demonstrate larger cardiovascular risks posed by more prolonged exposures to higher PM levels than observed over only a few days. p. 71

• Women may be at greater risk for cardiovascular mortality related to PM [p. 76], as are people who are overweight [p 35].

• Long-term exposure to elevated concentrations of ambient PM2.5 at levels

encountered in the present-day environment (i.e., any increase by 10 µg/m3) reduces life expectancy within a population probably by several

months to a few years. p 113• PM elicits numerous adverse biological responses (e.g., systemic

inflammation) that may further augment future cardiovascular risk over

the long term after months to years of exposure. p 9• Although the dangers to 1 individual at any single time point may be small,

the public health burden derived from this ubiquitous risk is enormous.

Short-term increases in PM2.5 levels lead to the early mortality of tens of thousands of individuals per year in the United States alone. p 116.

Recent studies

• Alzheimers disease and Parkinson’s disease related to prolonged PM exposure– http://www.niehs.nih.gov/news/newsletter/index.cfm

• Autism related to PM exposure– http://www.ncbi.nlm.nih.gov/sites/entrez?db=pubmed&cmd=link&linkname=pubmed_pubmed&uid=

20361442

• Bronchiolitis -- There was a clear link between total charges and costs for infant bronchiolitis hospitalizations and levels of fine particulate matter pollutant surrounding those hospitals.– aje.oxfordjournals.org/cgi/content/full/kwn252

• ADHD and executive cognitive function impaired by prolonged exposure to PM– Eur J Pediatr. 2010 Dec 30

DANGER• The latest draft of the US EPA Air Quality Criteria for

Particulate Matter has confirmed the presence of an apparent linear dose-response relationship between PM and adverse events.

http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=58003

• Data from all North American studies demonstrate that this curve is without a discernible threshold below which PM concentrations pose no health risk to the general population.

http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=58003, http://circ.ahajournals.org/cgi/content/full/109/21/2655

DANGER

• The most dangerous particulates are not regulated or accounted for in the permitting process– so permits are not “protective of human health”.

• “Although the dangers to 1 individual at any single time point may be small, the public health burden derived from this ubiquitous risk is enormous. Short-term increases in PM2.5 levels lead to the early mortality of tens of thousands of individuals per year in the United States alone.”

http://circ.ahajournals.org/cgi/content/full/109/21/2655 p 116.

DANGER

• It is the opinion of the writing group that the overall evidence

is consistent with a causal relationship between PM2.5 exposure and cardiovascular morbidity and mortality. This body of evidence has grown and has been strengthened substantially since publication of the first AHA scientific statement.1 – http://circ.ahajournals.org/cgi/content/full/121/21/2331– (Circulation. 2010;121:2331-2378.)© 2010 American Heart Association, Inc

• Because the evidence reviewed supports that there is no safe

threshold, it appears that public health benefits would accrue

from lowering PM2.5 concentrations even below present-day annual (15 µg/m3) and 24-hour (35 µg/m3) NAAQS p 116

Dioxin“But the amounts will be very small”

• There has been ongoing discussion at EPA for more than a decade trying to decide if the agency can risk declaring a “safe threshold”

• Of the approximately 100 scientists many say say there is no safe threshold of exposure.

• The current number is 0.7 picograms/kg/day– For a 100 kg man that is 70 picograms/day– In pounds that is: 0.000000000000154 lbs/day

DioxinFindings of Institute of Medicine at National Academy of Sciences

• The U.S. Institute of Medicine, part of the National Academy of Sciences, now links dioxin to various cancers, insulin dependent diabetes, nerve and heart disease among people exposed directly or indirectly, and to spina bifida in their children.– http://www.nap.edu/catalog/12662.html – http://iom.edu/Activities/Nutrition/DioxinFoodSu

pply.aspx [2008]

Dioxin• “The provisional cancer potency factor is the highest of any chemical EPA

has evaluated. Dioxin has been shown to produce cancer at far lower concentrations than any of the more than 600 other chemicals EPA has studied and for which EPA has developed cancer potency values. DeGrandchamp, p 30 www.epa.gov/region8/superfund/ut/magnesium/HHRA06Feb07.pdf

• Systemic effects: The primary targets appear to be the skin, liver, thyroid, and cardiovascular, endocrine, and immune systems. [P 316 USPHS]. Median half life of the chemical in the body is estimated to be 7.1 years [Pirke, 1989]

• Nursing increases exposure of infants: Consumption of breast milk by nursing infants leads to higher levels of exposure and higher body burdens of dioxins during early years of life as compared with non- nursing infants. Lipid concentrations peaked at around 4 months at about 46 ppt TEQDFP-WHO98. The formula-fed infants peaked at less than 10 ppt after the first year. P 1-18 EPA/600/P-00/001Cb

Regulation hang-up

• The principle assumption, and the basis for the conclusion, is that if air quality standards are not exceeded by the combination of existing ambient concentrations and the marginal increase from the boiler then no harm is assumed to occur. This approach is, of course, fundamentally flawed for those emissions, like particulates for which no safe level can be demonstrated.

Protection or Sham?

• The permitting process is meant to protect people from harm, especially children and the most vulnerable

So if SRE gets all the permits isn’t everything going to be safe– or at least OK?

PEOPLE ASSUME THEY GET PROTECTION

Permit≠Protection??

SRE MAY BE DOING WHAT IS LEGAL BUT THAT DOES NOT MEAN YOU ARE SAFE

AND GETTING ALL THE REQUIRED PERMITS DOES NOT MEAN YOUR CHILDREN ARE

SAFE

Underestimated Risk• It is the opinion of the writing group that the overall

evidence is consistent with a causal relationship between PM2.5 exposure and cardiovascular morbidity and mortality. This body of evidence has grown and has been strengthened substantially since publication

of the first AHA scientific statement.1 At present, no credible alternative explanation exists. These conclusions of our independent review are broadly similar to those found in the EPA’s Integrated Science Assessment for Particulate Matter final report (http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546). P 117

NAAQS is NOT Sufficiently Protective

• The Clean Air Scientific Advisory Committee of the EPA, which is mandated by the Clean Air Act to provide scientific advice on setting air quality standards, argued “there is clear and convincing scientific evidence that significant adverse human-health effects occur in response to short-term and chronic particulate matter exposures at and below 15 µg/m3, the level of the current annual PM2.5 standard” (CASAC 2006). http://www.epa.gov/sab/pdf/casac-ltr-06-003.pdf

DANGER

• A reasonable argument can now be made that the "real" effects [of particulates] are likely to be even stronger than previously estimated.

http://circ.ahajournals.org/cgi/content/full/109/21/2655

DANGER

• Moreover, because a number of studies have demonstrated associations between

particulate air pollution and adverse cardiovascular effects even when levels of ambient PM2.5 were within current standards,

even more stringent standards for PM2.5 should be strongly considered by the EPA. http://circ.ahajournals.org/cgi/content/full/109/21/2655

Industry statements• Epidemiologic studies reported a correlation between adverse health effects and increases

in ambient particulate concentration, even when the mass concentration was below the then-current air quality standards.

• Particle surface area, number of ultrafine particles, bioavailable transition metals, polycyclic aromatic hydrocarbons (PAH), and other particle-bound organic compounds are suspected to be more important than particle mass in determining the effects of air pollution.

• Accumulating evidence suggests that mass concentration is not the most appropriate measure of potential health effects,1 and that health studies need to consider other characteristics, such as particle number, particle morphology, and detailed chemical speciation.2–4

• The result is that the removal efficiency of particles from air is least efficient in an intermediate size range from 0.1 to 1 µm. This minimum PM removal efficiency is observed in post-combustion cleanup equipment at the source, in the atmosphere, and in the respiratory system.

• Particles in the 0.1–0.3 µm range have the highest penetration through APCD compared with both larger and smaller particles,63,78,179,180 so the 0.1–1 µm particles form a larger fraction of the mass distribution leaving the APCD than they do in the uncontrolled combustion emissions.63 – Air & Waste Manage. Assoc. 50:1565-1618

Best controls

• Permits aren’t protective in part because the POLLUTION CONTROLS REQUIRED ARE NOT THE BEST AVAILABLE.

RISK from biomass combustion

• Health risk to everyone, especially children• Increase the release of harmful pollutants

especially particulates and dioxin• Expensive power which requires taxpayer

subsidies when the country is in a financial crisis

What’s Driving the System

$$$$$$$

MoneyLots of it– you pay & SRE profits

• Federal dollars– Section 1603 -- $12-14 billion on biomass

combustion alone without accounting for pellet plants and conversion of coal to co-firing biomass

– Production Tax Credit– DOE loan guarantees– Section 48c -- Manufacturing tax credit– BCAP– underwrites the fuel supply costs

MoneyLots of it– you pay & SRE profits

• South Carolina

MoneyLots of it– you pay SRE profits

• Renewable Energy Credits– The EIA projects that at minimum under current

policies the country will add 50 GW of biomass combustion this decade.

– The current market for REC’s is > $20/REC and expected to rise as high a $35-$40/REC

– 1 REC per MWh of power produced– $ 2.63 million/yr for Allendale– $ 7. 45 billion/yr

• 50,000 X 24 X 365 X 20 X 0.85

MoneyDoes SRE deserve a tax abatement

• Renewable Energy Credits – $2.63 million/yr• Federal taxpayer obligation– will be 30% of

development costs• SC funds• Ongoing power purchase agreement– If selling power at $0.04/KWh then SRE will have a

guaranteed income of at least $5.26 million/yr

The Assumption

• “Combustion of biomass emits greenhouse gases….[but] the CO2 emissions from these activities are not included in the national emissions totals. It is assumed that the C released during the consumption of biomass …causes no net addition of CO2 to the atmosphere.”

http://epa.gov/climatechange/emissions/downloads09/Energy.pdf

This was the opinion of experts that has now been discredited

The FOIA– The discovery!

• EcoLaw asked EPA for data to support the assumption of carbon neutrality– 1.6 GB of material received– More than 80 repetitions of the word “assumed”

or “assumption”• The data, the papers, the meeting notes, the

substantive e-mails: THE RESULTS >>>>>

The Paradox—VOODOO REPORTING

• EPA HAS UNTIL NOW EXEMPTED POWER PLANTS WHICH USE BIOMASS AS A FUEL SOURCE TO GENERATE ELECTRICAL ENERGY FROM ACCOUNTING FOR THEIR CARBON EMISSIONS AND ALLOWED REPORTING THOSE EMISSIONS AS A ZERO. THAT’S RIGHT– ZERO

• Tailoring rule: Goes was going into effect January 2, 2011. Now new ruling is July1, 2011 so they need the permit quickly.

CLIMATE NEUTRAL

• CARBON NEUTRAL

IS NOT THE SAME AS

• CLIMATE NEUTRAL

Biomass Burning is not Carbon Neutral

• Burning [regardless of the type of combustion process] releases CO2 in minutes but the CO2 won’t be re-sequestered for centuries so burning biomass will accelerate climate change not help.

• EPA’s proposed endangerment and cause or contribute findings stated:– “Indeed, 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 will be removed over a few centuries, and the remaining 20 percent will only slowly decay over time such that it will take many thousands of years to remove from the atmosphere. 74. Fed Reg.18886, 18899

The truth and the facts • Searchinger/Hamburg– Science, 325:529, October 23, 2009

– “Exempting emissions from bio-energy use is improper for greenhouse gas regulations. Replacing fossil fuels with bio- energy does not by itself reduce carbon emissions, because the CO2 released by tail- pipes and smokestacks is roughly the same per unit of energy regardless of the source ”

– “Maintaining the exemption for CO2 emitted by bioenergy use under the protocol (IPCC) wrongly treats bioenergy from all biomass sources as carbon neutral. For example, the clearing of long-established forests to burn wood or to grow energy crops is counted as a 100% reduction in energy emissions despite causing large releases of carbon.”

The truth and the facts IIThe lifecycle argument

• EPA Proposed Endangerment Finding on CO2– If there is a lifecycle it exceeds a hundred years

• Beebe—Tongass Forest Roundtable Feb 2009– “It has also been shown the carbon uptake accrued over a given

harvest rotation would not make up for the amount of carbon stored in the originally logged old-growth. Managed stands on 80 year rotations stored only half the carbon of old growth forests.”

• Ingerson– April 2009– “But timing still matters. If the source forest regenerated instantly,

biomass would earn its “carbon-neutral” label, but the longer it takes to regenerate forest carbon after a biomass harvest, the longer that carbon dioxide remains in the atmosphere exerting its heating effect.”

The truth and the facts III“Biogenic is a red herring”

• The total amount of carbon in the biosphere is fixed. • What will matter is the total amount of carbon in

the atmosphere in the next 2-3 decades.• Every molecule of CO2 is created equal• CO2 (biomass smokestack)=CO2 (car)=CO2(industrial). Each

molecule is equally “dirty”• CO2 (biomass smokestack)=CO2 (car)=CO2(industrial). Each

molecule has an equivalent effect in terms of climate change

Biogenic carbon is “safe”• If all 392 ppm were biogenic CO2 molecules

would the current climate effects be any different?

• If all 392 ppm were biogenic CO2 molecules would it be sequestered at a faster rate?

• If we filled this room with biogenic CO2

molecules rather than CO2 molecules derived from burning fossil fuel, would the survival rate of the participants be higher?

AllendaleWhat’s in it for you?

• Maybe 20 jobs– Multiple studies show more jobs from spending

the same federal money to make houses more energy efficient

– Teamsters oppose biomass incineration• Unknown health risks especially to children

• Expense– waste of tax dollars from a policy based on now discredited assumptions