December 1, 2014
Dear Administrator Gina McCarthy,
We, the undersigned organizations are alarmed that on November 19, 2014 the EPA released the Revised Framework for Assessing Biogenic CO2 Emissions from Stationary Sources. This new Framework has a significant impact on the EPA Clean Power Plan, yet was released less than two weeks before the December 1, 2014 deadline for public comments on the Plan.
The EPA Memo for this Framework unilaterally asserts that climate pollution from burning waste and biomass “are likely to have minimal or no net atmospheric contributions of biogenic CO2 emissions” and hence, should not be counted as harmful emissions, despite growing evidence to the contrary.
The growing body of evidence that burning waste and biomass has long term climate consequences includes a 2014 study of U.S. biomass energy emissions found that burning biomass is worse for the climate than burning coal. This adds to the many studies that have found that biomass energy is more carbon-intensive than coal, and that the life-cycle emissions associated with various sources of biomass and waste fuels are much greater than those of fossil fuels. According to EPA’s own database, burning municipal waste is the most carbon intensive form of energy generation, producing over twice the amount of CO2 per unit of energy than coal plants. This has been corroborated by recent studies comparing the emissions of waste (“WTE”) incinerators and coal plants in Maryland and New York.
If the EPA formalizes this new biogenic emissions framework, and allows all biogenic emissions to be counted as zero in emissions rate calculations, the door will be opened wide for states to encourage the co-firing of biomass and waste in power plants through various subsidies and incentives that states will implement under the Clean Power Plan. This will lead to a severe increase in both greenhouse gas and toxic emissions.
Incentivizing any form of combustion energy, whether it be coal, gas, trash, or biomass, raises serious concerns about increased public health impacts, especially for communities already overburdened by such industrial pollution. We are gravely concerned that together, the Clean Power Plan and this biogenic emissions framework will result in an increase of health consequences and related economic burdens for frontline communities of color and low income communities across the United States. As Dr. Robert Bullard noted in his 2011 article “Dismantling Energy Apartheid in the United States,” “burning biomass to generate electricity…. is neither green nor clean.” The EPA should prioritize the reduction of pollution burdens in communities disproportionately impacted, not promote such avenues for greater harm.
By allowing exemptions for pollution control requirements for power plants using waste derived fuels and so-called “sustainable” forestry and agricultural feedstocks, the EPA is sending a clear signal to a range of combustion energy companies that they can access a free pass for increases in their climate and toxic pollution loads, by burning biomass fuels and substituting a portion of their fossil fuels with such feedstocks.
Such exemptions would fly in the face of recommendations made by over 90 scientists earlier this year in a July 14th letter, which stated “only when bioenergy results in additional carbon being sequestered above and beyond the anticipated baseline can there be a justification for concluding that such energy use results in little or no increase in carbon emissions.”
We believe the EPA should adhere to the Precautionary Principle in ensuring the protection of community health, while applying rigorous science in assessing real greenhouse gas emissions reductions. In doing so, the implementation of the Clean Power Plan should in no way incentivize the combustion of waste, biomass, or any other fuels for energy generation.