Mass Audubon Comments on Biomass

Russell Biomass Expanded Environmental Notification Form – 2005: A utility scale (50 MW) electrical power generating plant to be fueled primarily by biomass (wood), with a fuel oil starting system. Mass Audubon urged that a full Draft and Final Environmental Impact Report (EIR) be required. Project impacts include rare species habitat, wetland alterations, large-scale (885,000 gpd) water withdrawal, and industrial wastewater discharge, and air quality.

Russell Biomass Draft Environmental Impact Report – 2007: We requested that the Final EIR further evaluate impacts to sensitive resources impacted in this relatively large-scale biomass project,  including the Westfield River and rare species habitats, and look into alternatives.

Russell Biomass Final Environmental Impact Report and draft Water Management Act permit – 2008: The FEIR did not sufficiently address concerns regarding impacts of proposed water withdrawals and discharges on the Westfield River and its resource values, including cold water fisheries, and its wild and scenic characteristics. The Final EIR did not adequately address requirements in the Certificate on the Draft EIR regarding analysis of wet and dry cooling, impacts on aquatic and fishery resources, commitments to water temperature and quality monitoring, and a commitment to the full suite of mitigation measures necessary to protect the Westfield River and other environmental resources.

Responses to Green Communities Act stakeholder comments – 2008: Mass Audubon strongly supported the development of renewable energy resources as required by the Act.  It is critical that renewable energy facilities, including new hydroelectric facilities or improvements on existing facilities, do not exacerbate the impact of climate change and other threats to ecosystems. We recommended that biomass facilities only qualify for RPS credits to the extent their operations are carbon-neutral and meet other criteria to protect ecosystem service values of Massachusetts forests.

Green Communities Act proposed final regulations –225 CMR 14.00, RPS 1 and 225 CMR 15.00, RPS II – 2009: We were pleased to see Low Impact Hydropower Institute (LIHI) requirements in the proposed final regulations. With regard to wind, Mass Audubon recommended that only wind facilities that meet certain siting criteria be eligible for the RPS.   

Mass Audubon position statement on Department of Conservation and Recreation (DCR) Forestland Management – 2009: The commonwealth owns approximately 600,000 acres of conservation land protected under Article 97 of the State Constitution. DCR is the single largest landowner of such land in the commonwealth, with over 450,000 acres under its care and control. Mass Audubon supports a management approach protecting the functions and values of these lands and addressing threats to biodiversity, including a landscape level system of reserves and sustainably managed woodlands. We recommended that the Forest Vision review process consider expanding the relative allocation of land to reserves, and that a new tiered land management zoning system by implemented. 

Pioneer Renewable Energy, Greenfield, Environmental Notification Form – 2009: Mass Audubon recommended that a full Environmental Impact Report (EIR) be required due to direct and indirect impacts to land and forests.  Supplying the needed 500,000 tons per year of woody biomass to this facility would require harvesting of wood from over 10,000 acres of land. An EIR was needed to address the specific impacts of this project and to review the cumulative impacts of proposed industrial scale biomass facilities in Massachusetts on GHG emissions, forest carbon sequestration, and forest sustainability.

Proposed amendments to 310 CMR 7.71, Greenhouse Gas emissions reporting – 2009: We supported the goals of the Global Warming Solutions Act. Our comments focused on the proposed separation of reporting requirements for “biogenic” GHG emissions from other emissions. We noted the need for the commonwealth to address the degree to which various biogenic emissions are or are not “carbon neutral.” In particular, emissions from burning of woody biomass should be evaluated in the context of the sources and methods used in obtaining and transporting this material. We recommended that Massachusetts adopt an approach similar to the “carbon intensity” rules applied by California to biofuels.

Statewide Greenhouse Gas Emissions Level Baseline Draft Report – 2009: Mass Audubon recommended that the final Baseline Report address the carbon capture and storage functions of forests.

Proposed Scope of Work, DOER Biomass Study – 2009: Mass Audubon agreed that further study of the lifecycle GHG emissions from biomass and related issues of forest sustainability and other environmental impacts was needed.  However, we commented that key assumptions in the Scope could skew the results if not reexamined, particularly those related to the percentage of forestland available for harvesting. In addition, the roles forests play in climate change adaptation need to be considered.  

Russell Biomass Notice of Project Change – 2009: The NPC documented significant impacts of the project in terms of acreage of land impacted; impervious surfaces created; impacts to wetland resources including Riverfront Area, Bordering Land Subject to Flooding, Bordering Vegetated Wetlands, and rare species habitat. Mass Audubon requested that a Supplemental EIR be required to address the new and cumulative impacts of the project, and to further evaluate alternatives to a new roadway, including an alternative of having some of the wood delivered via rail and some via truck, which could limit habitat fragmentation effects on wildlife connections between the river and Turtle Bend Mountain.

Mass Audubon Biomass position statement – 2009: Mass Audubon recognized that there is a role for burning of clean woody biomass to produce heat and electricity within the state’s overall energy mix. However, we had concerns about greenhouse gas emissions and impacts to forests associated with large scale biomass use. Mass Audubon opposed the permitting, construction, and operation of electric generation woody biomass facilities until the following regulatory changes have been put in place:

• The Massachusetts Forest Cutting Practices regulations must be refined to ensure that forest harvesting is sustainable and minimizes negative effects on forest carbon storage and sequestration, habitat, water quality, and other ecosystem services provided by forests.
• Federal and state renewable energy regulations and tax credit programs must be modified so that biomass facilities only receive financial incentives to the extent a facility produces more energy per unit of carbon emitted than the average fossil fuel plant. 

Manomet Center for Conservation Science study on biomass sustainability and carbon policy – 2010: Mass Audubon supported the review and revision of regulations and policies related to biomass burning, forest harvesting, and associated incentives and programs by DOER and other agencies.  The report supported a conclusion that most large-scale uses of woody biomass for electricity will emit higher GHG levels than an equivalent amount of fossil fuel energy, at least over the next few decades.  It is vital that the state establish programs and regulations that will significantly reduce GHG emissions during that timeframe rather than increase them. Furthermore, the analysis may not fully account for all of the actual GHG impacts of intensive biomass utilization as it relies on several assumptions that are not necessarily accurate.
          
Economic Analysis of Low Carbon Fuel Standards for Northeast and Mid-Atlantic States – 2010: One of Mass Audubon’s major areas of involvement in addressing climate change is our support for federal, regional, and state initiatives to reduce carbon and other GHG emissions. Mass Audubon supported the Regional Greenhouse Gas Initiative (RGGI) and the efforts of 11 states to develop and implement a Low Carbon Fuel Standard (LCFS). We supported a LCFS designed to help achieve the regional and state targets for GHG emission reductions, and an approach that includes full lifecycle accounting and that addresses and minimizes potential negative effects of land use conversions for biofuel production. However, we believed it was important for the modeling to more fully address the heating sector and consider potential interactions between the transportation and heating sectors. We are also concerned that amount of woody biomass available for production of cellulosic ethanol may be significantly overstated, and that the methodology used for calculating carbon intensity should be based on existing technologies and facilities rather than projections for biofuels for 2022.

Carbon Accounting and Biomass/RPS Policy Directions – 2010
Mass Audubon supported DOER’s efforts to revise the Renewable Portfolio Standard (RPS), emphasizing the need to ensure the most efficient use of available, sustainably harvested woody biomass and promote the long term protection and sustainable management of forests in Massachusetts and across the region. Financial incentives should only be available for projects resulting in actual GHG emission reductions compared to the production of energy from efficient fossil fuel facilities.  The Manomet study and other scientific data demonstrated that most uses of biomass for utility scale electric generation cannot meet this standard, and it was essential that DOER revise the RPS to constrain the applicability of renewable energy credits to the highest efficiency forms of biomass use.

Renewable Energy Portfolio Standard, RPS I (225 CMR 14.00) – 2010
The regulatory revisions included several important provisions, including clarifying the definition of “Eligible Biomass Fuel” and establishing harvesting and efficiency standards. We continued to support the direction DOER is taking on this topic, and generally supported the proposed regulations. We strongly supported further reassessment by 2015 or sooner, and recommend that the Forest Impact Assessment include cooperative data gathering and analysis from other states as well as DCR. Mass Audubon opposed the proposed eligibility of land clearing debris from forestland development as fuel eligible for RPS credits.  Mass Audubon supports the requirement to reduce lifecycle GHG emissions by 50% compared to a new combined cycle natural gas electric generating facility.

Palmer Renewable Energy Project, Springfield, Notice of Project Change – 2011:
Mass Audubon requested that a full Environmental Impact Report be required, with a scope that includes more complete evaluation of the sources of wood to fuel the proposed facility, air pollution impacts including heat-trapping pollutants such as carbon dioxide, and a Greenhouse Gas assessment addressing impacts to land and vegetation at the sources of the wood fuel.

Renewable Portfolio Standard (RPS) Draft Regulation on Woody Biomass Eligibility – 2011:
Mass Audubon and 13 other environmental and public health groups urged legislative support for revisions to the proposed regulations for woody biomass. Setting eligibility criteria for biomass-burning electric generation units will help direct ratepayer dollars away from energy sources that have negative health, climate and forestry impacts. We recommended changes to ensure biomass power facilities that qualify under the RPS are consistent with greenhouse gas reduction targets and responsible forestry practices as informed by the Manomet Study (see above).

Recommended Corrections to RPS Regulations – 2011
Mass Audubon and 11 other groups encouraged the environmental and energy administrations to move swiftly to correct flaws in the biomass/RPS regulations and guidance. Our suggested changes included setting a 15% limit on total harvested material that could be treated as RPS-eligible biomass fuel, and initiating an open and transparent public comment process to review the carbon accounting guidance, much as DOER had done in connection with previous regulatory guidance.

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