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Nathanael Greene’s Blog

DOE data shows scale of biomass loophole

Nathanael Greene

Posted May 27, 2010

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Yesterday I wrote about 90 leading scientists calling on Congress and the Obama administration to carefully account for the greenhouse gas emissions from burning biomass. I want to underscore again that now is the time for Congress to pass a climate bill, and the House ACES bill and Kerry-Lieberman APA provide a solid framework. (You can link here, here and here for more information on the bill's various provisions,)

Today I'm digging into some DOE data that gives a measure of how important it is to get the biomass accounting right and casts some light on how final legislation can ensure the treatment of biomass supports the carbon reduction goals. 

It's easier to understand why the biomass loophole is wrong if we think about an extreme example: both versions of climate legislation would give a utility a free pass if it replaced coal with wood — even if that wood came from a forest that was clear-cut and turned into a parking lot. In other words, even when carbon that was locked up in soils and wood is released with no chance of reabsorption, the accounting in ACES and APA would count it as zero emissions.

Here's how DOE's Energy Information Administration explains its own accounting, which mirrors the proposed climate legislation:

CO2 emissions from the combustion of biomass to produce energy are excluded from the energy-related CO2 emissions reported in AEO2010. According to current international convention, carbon released through biomass combustion is excluded from reported energy-related emissions. The release of carbon from biomass combustion is assumed to be balanced by the uptake of carbon when the feedstock is grown, resulting in zero net emissions over some period of time. However, analysts have debated whether increased use of biomass energy may result in a decline in terrestrial carbon stocks, leading to a net positive release of carbon rather than the zero net release assumed by its exclusion from reported energy-related emissions.

That's how we end up with the biomass loophole: we exclude biomass combustion emissions from energy-related accounting and fail to regulate terrestrial carbon. Both ACES and APA fall into this trap.

As I mentioned yesterday, EIA does forecast the smokestack and tailpipe greenhouse gas emissions from biomass power, heat and fuels. The figure below shows the reference-case biogenic emissions through 2035.

AEO biogenic emissions reference case.PNG

[Note: Heat and coproducts from biofuels processing is listed under industrial emissions as "biofuels heat and coproducts." But after talking to the helpful folks at EIA, I understand this to account for the balance of carbon that goes into biofuel refineries in the form of feedstock and doesn't come out as biofuels. Makes sense. It's got to go somewhere.]

Now some will look at this and point out that the majority of these emissions are associated with biofuels--either the burning of biofuels in cars and trucks or the producing of biofuels at refineries--and these emissions are covered by the Renewable Fuel Standard as updated in EISA2007. But as I explained yesterday, the efforts to prop the biomass loophole open go hand in golve with efforts to gut the protections in the RFSII. Both ACES and APA would expand the definition of renewable biomass to include just about anything, and ACES included a provision prohibiting EPA from accounting for the single largest source of GHG pollution associated with most conventional biofuels—the market ripple effect caused by increased biofuels use, also known as international indirect land-use change.

And as if the incentive for bad biofuels created by a climate bill with a loophole that also guts the environmental protections in our existing biofuels policies wasn't bad enough, the corn ethanol industry is doing a full court press to try to extend its tax credit, which by all rights should expire this year. I've written before about how this $0.45 per gallon give-away lines to pockets of big oil and old ethanol and is the most expensive way to create jobs and ravish the environment.

EIA provides a scenario, called the "no sunset" scenario, which gives a bit more insight into the climate cost of the VEETC. As the name suggests, this scenario assumes that the VEETC and other biofuels tax credits don't expire. The result is nearly 20% more CO2 emissions from the burning of biomass and this doesn't even factor in the incentive created by a climate bill with a loophole. Here's what the emissions chart looks like in this case:

AEO biogenic emissions no sunset case.PNG

The good news from these graphs is that they suggest a path forward for Congress. The most important step is to protect the definition of renewable biomass and the full GHG accounting established under the RFSII through EISA2007.

Then through the climate bill, Congress should put our GHG controls on track to fully and carefully account for the pollution emissions and sinks associated with different sources of bioenergy. Specifically, we recommend that Congress direct EPA to work with USDA and DOE to commission a study by the National Academy of Sciences to evaluate and measure emissions associated with bioenergy and how to account for them. EPA should establish rules to cover these emissions under a cap based on the recommendations of the study.

Finally, Congress should let the VEETC expire at the end of this year. It's time to stop throwing good tax payer dollars after bad biofuels. We can do better--more jobs, less pollution, more energy security--investing in better biofuels, wind power, solar power... just about anything.

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Dan WhitingMay 27 2010 03:23 PM

What Nathanael is missing here is that biomass emissions are accounted for with annual land use accounting. So, if a forest is harvested, that is accounted for annually. To also account for it in energy emissions would double count it. In fact, the EIA document he cites makes this very point, "To capture the potential net emissions, the international convention for GHG inventories is to report biomass emissions in the category 'agriculture, forestry, and other land use,' usually based on estimates of net changes in carbon stocks over time. "

The point is simple - biomass energy emissions are accounted for and as the forests or crops regrow, that net sink is also accounted for - demonstrating that, as the EPA states, “CO2 emissions from the combustion or decomposition of biogenic materials (e.g., paper, wood products, and yard trimmings) grown on a sustainable basis are considered to mimic the closed loop of the natural carbon cycle—that is, they return to the atmosphere CO2 that was originally removed by photosynthesis.”

Meg SheehanMay 28 2010 08:13 AM

Thanks, Nathanael.

Citizens around the U.S. are angry that biomass incinerators are getting lucrative taxpayer and ratepayer subsidies based on the false premises that these plants have "carbon neutral" emissions and thus help reduce U.S. emissions, and that they are "clean energy." Data shows the plants are not carbon neutral in any timeframe meaningful to the climate crisis, and that this is dirty energy.

Here in Massachusetts we are headed to a state wide ballot vote in Nov. 2010 that will limit the CO2 emissions from incinerators that burn biomass and garbage for so-called "clean energy."

Since Congress and EPA don't have this right yet, citizens are taking the lead.

Help support our ballot question. The Mass. Medical Society and American Lung Association endorse the question because these plants present an "unacceptable health risk."

Thanks for crunching the numbers and calling for counting the carbon from these incinerators in disguise!

Neil SeldmanMay 28 2010 09:32 AM

Thanks for these comments.

Why do you support the environmental legislation that allows garbage incinerators subsidies? Yet there are no subsidies for recycling and composting which are more environmentally acceptable?

David DonigerMay 28 2010 12:49 PM

Thanks to Dan Whiting of the National Alliance of Forest Owners for his comment.

We totally agree that biomass emissions need to be fully accounted, so thanks for acknowledging that this is an issue that needs to be addressed.

Unfortunately, while the annual land-use accounting report to which Dan refers (I assume he means the EPA annual inventory) theoretically does include an estimate of emissions associated with land-use change, there is no connection between that inventory and emissions accounting system in the climate bill. The draft bill does not require any federal agency to "hold the atmosphere harmless” if there is a disconnect between the emissions as counted in the climate bill and in the inventory. Net emissions from our forests or farmlands simply do not count -- either positively or negatively -- in measuring whether we are meeting the national carbon pollution limits established in the bill. Said another way, the category of “land-use change” is not part of the bill’s carbon limits at all.

Nor does the draft bill require individual forest or farm landowners to monitor or even estimate whether their own lands are taking up or giving off carbon dioxide when they produce biomass for energy. Nor does the bill require those who burn that biomass or turn it into motor fuel to account for the net emissions of those fuels -- net emissions are just *assumed* to be zero even though that is scientifically unjustified (as we pointed out here: The lack of a requirement to account for the net emissions of those fuels needs to be rectified.

Finally, Dan points to international greenhouse gas inventory guidelines, but those guidelines aren’t applicable here because, as noted above, the bill doesn’t use those guidelines, or any other method, to account for those emissions. I also feel compelled to note that these protocols have serious flaws and loopholes when it comes to accounting for land-use emissions. These are gaps in the US inventory related to land-use which were just noted in a review conducted by experts from around the world:

Dan has raised a good point that biomass energy emissions COULD be accounted for through accounting for land-use change on an annual aggregate national basis. But if (as in the draft bill) they're assumed to be zero in the energy sector and there also is no aggregate land-use change accounting, then biomass emissions fall into a serious loophole.

While the carbon pollution framework of the APA bill is basically solid (as my colleague discussed:, we'd welcome the chance to work with others, including the National Alliance of Forest Owners, to fix this problem.

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