Dodd: PSB needs to take a hard look at CO2 emissions from woodchip power plant

Editor’s note: This commentary is by Walter C. Dodd, a retired mechanical engineer and a longtime resident of North Springfield.

The proposed woodchip power plant project known as the North Springfield Sustainable Energy Project or NSSEP has been working its way through the Vermont Public Service Board hearing process for nearly two years. Along the way the project applied for and received an “Air Pollution Control Permit to Construct” from the State of Vermont, Agency of Natural Resources, Department of Environmental Conservation, and Air Pollution Control Division. This was issued on April 19, 2013. While the application was reviewed by and the permit awarded by the ANR, the standards applied are largely dictated by federal EPA standards.

Buried deep within the 39-page permit a very significant number appears in just two places (page 6 and page 23). The number is 2,668 and the units are pounds of CO2e per megawatt hour (lb CO2e / MW-hr). This is the measure of greenhouse gas (GHG) that the facility is expected to produce for each megawatt hour of electric and thermal power produced in the first two years of operation.

This number largely escaped notice. Few people read it and fewer had comparative numbers for context.

Now the EPA has come forward in a major recent announcement with the very context that gives the NSSEP numbers meaning. The EPA, citing grave concerns over global warming, announced proposed standards for CO2 emissions from natural gas- and coal-fired power plants. The EPA proposes a standard of 1,100 lb CO2 / MW-hr for coal-fired facilities. In an article published Sept. 19, 2013, on this announcement, the New York Times added for context: “Industry officials say the average advanced coal plant currently emits about 1,800 pounds of carbon dioxide per megawatt hour.”

There we have it! The proposed NSSEP biomass wood chip power plant, if it receives a certificate of public good from the PSB will come on line in 2016 and emit 2,668 lb CO2e / MW-hr compared to a currently operating coal-fired plant emitting about 1,800 lb CO2 / MW-hr and an EPA proposed standard for coal-fired plants of 1,100 lb CO2 / MW-hr. Currently operating natural gas-fired power plants emit an average of 1,220 lb CO2 / MW-hr according to the U.S. Energy Information Agency website.

The difference is quite dramatic, but should not be surprising because woodchips come to the facility green and saturated with moisture which severely compromises combustion thermal efficiency. By contrast, coal is delivered with nearly no moisture content.

The EPA has issued no active or even proposed limits for CO2 or GHG emissions by any biomass facility, including woodchip biomass burning power plants. These facilities have been given a free pass. Industry proponents claim that biomass is “carbon neutral” because recently sequestered carbon is re-emitted and then re-absorbed by new growth. A number of recent studies and policy shifts by states and foreign governments belie this assertion. Trees that are actively absorbing CO2 are removed from that function, the carbon content is immediately emitted back into the atmosphere, and then we wait 50 years for new growth to reabsorb it.

On July 12, 2013, “In a 2-1 decision a U.S. Court of Appeals panel in the District of Columbia Circuit struck down a 2011 Environmental Protection Agency rule that deferred for three years regulating the greenhouse gas emissions from biomass burning in the same manner the agency regulates plants that burn fossil fuels.” (Huffington Post Green, July 15, 2013). To this date I have found no indication if and when the EPA will comply, appeal or ignore the ruling.

The federal government not only does not regulate carbon emissions from such facilities, but has multiple programs to facilitate planning and to subsidize them with our tax dollars and our incurred national debt. Clearly it is the promise of federal tax benefits that is driving this project. On July 11, 2013, an attorney representing NSSEP in the PSB review and approval process, wrote to the PSB “… any further delay will jeopardize Petitioner’s ability to construct this year and obtain approximately $40 million in tax benefits needed to keep this Project viable.”

The fact that there is no requirement for GHG consideration at either the federal or state level in order to reap such tax benefits is brought starkly home by this quote from the rebuttal testimony of Daniel Ingold, technical director at NSSEP, which was filed with the PSB on Nov. 27, 2012:

“Also, under Section 248, NSSEP does not have the burden of showing that its facility will reduce GHG emissions or that the Project will be ‘carbon neutral.’ NSSEP is, however, required to demonstrate that the Project will ‘promote the general good of the state’ and that it will not have an undue adverse effect on air purity, the natural environment or the public health and safety with due consideration having been given to, among other things, GHG impacts.”

Given the recent behavior of the federal government we cannot expect any responsible action any time soon, if ever. But certainly we have a right to expect responsible action from the level-headed regulators and administrators of Vermont.

It is interesting to note that during the PSB testimony and hearing process before July of this year, much of the testimony from the ANR’s Department of Forest, Parks and Recreation and from the Department of Public Service has been critical of the NSSEP project. Yet since that time their testimony has been quite conciliatory. The only thing that has changed that I have seen is that NSSEP has agreed to a harvesting plan “stipulation” that applies only to the harvesting of trees within the state of Vermont and no issues beyond that.

I urge the PSB to look very closely at the concerns expressed by these parties and determine if they have actually been addressed and resolved. I believe it will be determined that many have not been resolved.

The bottom line to all of this comes down to two central questions:

1. What is the objective of Vermont energy policy?
2. Does the proposed NSSEP project meet that objective?

The many statements from the governor and others in the administration all focus on the need for Vermonters to do their share to reduce carbon emissions to limit the global climate effects of the buildup of GHG in the atmosphere. Sometimes there is a bit of confusion between terms like “renewable energy” and “clean energy” and “zero carbon” and “carbon neutral.” Clearly these terms are not synonymous. But the message is always to reduce CO2 and other GHG emissions. Certainly reduction of GHG emissions is the ultimate objective of Vermont policy.

The NSSEP facility is expected to produce 2,668 pounds of CO2e for every megawatt hour of electric and thermal energy delivered according to the Air Pollution Control Permit to Construct. Compare this to current coal-fired plants which produce approximately 1,800 lb CO2 / MW-hr according to the New York Times. Compare it also to an EPA proposed standard of 1,100 lb CO2 / MW-hr for new coal-fired plants. That certainly doesn’t meet the objective.