In a letter being sent today to EPA, Senators Elizabeth Warren (MA) and Edward Markey (MA) call on EPA to enact a moratorium on use of bioenergy as renewable energy in the Clean Power Plan. The letter points out that by treating biomass power plants as if they have zero emissions under the draft Clean Power Plan, EPA risks undermining the ability of the Plan to actually reduce emissions from the power sector.

Massachusetts eliminated renewable energy subsidies for biomass power plants after conducting a study that found wood-burning power plants increase carbon emissions relative to fossil-fueled power plants, an effect that persists for decades. Noting the science-based Massachusetts standard, Bill Snape, Senior Counsel at the Center for Biological Diversity, observed that "Two Senators with home grown experience on the perils of biomass have called for a needed national time out."

Wood-burning power plants emit about 3,000 pounds of carbon dioxide per megawatt-hour, about fifty percent more than coal-burning plants. EPA has been engaged in a process to determine how to count carbon emissions from biomass, given the assumption that emissions from wood-burning are eventually offset by new forest growth. Although no framework for counting biogenic emissions is in place, EPA has indicated that the agency will likely permit states to use biomass power to replace coal under the Clean Power Plan, and that the agency will treat wood-burning power plants as having zero emissions, alongside wind and solar power.

Mary Booth, Director of the non-profit Partnership for Policy Integrity, said “Treating biomass as having zero emissions not only contradicts EPA’s own science, it defies common sense. We can’t reduce emissions under the Clean Power Plan by replacing coal with the only thing that emits more carbon pollution: biomass.”

The letter requests that EPA suspend eligibility of bioenergy as a compliance measure until the agency develops a way to account for biogenic carbon emissions under the Plan.

Download the letter here.

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May 8, 2015

The Honorable Gina McCarthy

Administrator

U.S. Environmental Protection Agency

Ariel Rios Building

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Dear Administrator McCarthy,

As strong supporters of the Environmental Protection Agency’s Clean Power Plan (Plan), we write to express our concern that any decision by EPA to treat bioenergy as having zero emissions under the Plan could undermine the Plan’s intended purpose of reducing power sector carbon emissions. EPA needs time to develop a robust method of accounting for bioenergy emissions at the facility level. Accordingly, we recommend a temporary moratorium on the use of biomass combustion as a method of complying with the requirements of the Plan.

Although we understand that the Plan is not yet final, aspects of the proposed plan indicate that EPA may decide to treat all bioenergy generation as having no greenhouse gas emissions. For example, the equation that EPA used to calculate state-level emissions rate goals includes all of the energy, but none of the emissions, associated with renewable generation—including bioenergy, which is not a zero-carbon technology. Furthermore, EPA Assistant Administrator Janet McCabe suggested in a memorandum issued in November 2014 that EPA may allow states to utilize bioenergy from “sustainably harvested” forest materials as compliance under the Plan. While we support efforts to promote sustainable forestry practices, forest sustainability standards do not typically include carbon accounting as a component.

As EPA knows, wood-burning power plants emit around 3,000 pounds of carbon dioxide per megawatt-hour. A growing body of scientific evidence, including a study commissioned by the State of Massachusetts,[1] has found that it takes decades of forest regeneration to offset these emissions. In response to these findings, Massachusetts eliminated renewable energy subsidies for utility-scale wood-burning power plants, finding they compromised the state’s ability to achieve its emissions reduction targets. Massachusetts’ renewable energy portfolio is now focused on the technologies that produce the most immediate reductions in power sector emissions.

We are concerned that including bioenergy as a compliance measure in the Plan could similarly compromise the Plan’s ability to achieve emissions reductions by 2030. The EPA has not determined that any form of biomass combustion is carbon neutral within the compliance timeframe set by the Plan. The Scientific Advisory Board Biogenic Carbon Emissions Panel only just held a meeting at the end of March to review the Framework for Assessing Biogenic CO2 Emissions from Stationary Sources released in November 2014 and the agency has stated that the review of EPA’s biogenic carbon accounting framework will not be completed by the time the Plan is finalized this summer.

The EPA should not approve biomass combustion as a compliance method under the Plan until the agency has a method in place to account for facility-level emissions and a means of ensuring that emissions offsetting actually occurs in an appropriate timeframe. Accordingly, we suggest a moratorium on the use of bioenergy as a compliance measure under the Plan, extending to 2020, when states will have the opportunity to apply for modifications to their implementation plans. This approach has a number of advantages:

· It gives EPA time to finalize a biogenic carbon accounting framework, develop a tool for assessing net carbon emissions at the facility level, and determine how best to count bioenergy emissions under the Plan.

· It avoids incentivizing a carbon-intensive energy source that works against the Plan’s objectives and that emerging evidence suggests is contributing to unsustainable deforestation and.

· It focuses near-term state efforts on wind, solar, and other zero-carbon renewable energy technologies whose contribution to the Plan’s objectives are well understood.

We urge EPA to complete the process it began several years ago of developing a robust, policy-relevant method of accounting for the net atmospheric impact of bioenergy generation. It is critical that EPA get the accounting right before states commit to measures that could aggravate rather than alleviate climate concerns. A temporary moratorium on using bioenergy as a compliance measure in state implementation of the Clean Power Plan will give the agency time to do so.

Sincerely,

Edward J. Markey

U.S. Senator

Elizabeth Warren

U.S. Senator