October 31, 2013
Re: End Federal Tax Subsidies for Dirty Biomass Energy
For many years, federal and state policies have promoted biomass energy—in particular, burning trees and other woody materials from the nation’s forests in power plants—as a “clean” and “renewable” source of energy. These policies, ranging from regulatory exemptions to tax credits and subsidies, have facilitated a boom in bioenergy development in many parts of the country.
Over that same period, however, numerous scientific studies have shown that low-efficiency wood-fired power plants are neither “clean” nor “carbon neutral” within a timeframe relevant to addressing climate change. Accordingly, we ask that you either remove biomass from the Production Tax Credit or at least restrict it to the most efficient forms with the lowest net carbon dioxide (CO2) emissions. At the smoke stack, biomass-fueled power plants emit far more CO2 per megawatt-hour of electricity generated than
fossil fueled plants, and current science shows that burning biomass for energy can increase atmospheric CO2 concentrations for many decades, even if it displaces fossil fuels.
Whether fossil or biogenic in origin, once CO2 is in the atmosphere, it contributes to climate disruption equally. To reflect this reality, federal policy must no longer give generous incentives to this entire industry categorically. Instead, lawmakers and regulators must meet the challenge of credibly accounting for biomass CO2 emissions in both regulatory and incentive programs.
Intensive forest harvesting for bioenergy represents a significant new demand that both threatens forest resources and competes with the existing wood-products industry. According to industry data, operating biomass energy facilities currently consume about 48 million tons of wood per year. Facilities currently permitted and planned will consume another 43 million tons of fuel per year by 2020. At least 78% of this demand will be sourced from forests, an amount of wood equivalent to that yielded by clearcutting 421,000 acres of U.S. forests per year. These totals do not include manufacturing of wood pellets, primarily for export to markets in Europe, which is projected to require another 44 million tons of wood annually by 2020.
Emissions from the existing and emerging bioenergy industry are significant. Burning one ton of green wood emits almost exactly one ton of CO2, thus the tens of millions of tons of wood used as fuel represent a substantial transfer of forest carbon into the atmosphere each year. Biomass-fueled power plants also emit conventional air pollutants that harm public health, including particulate matter and nitrogen oxides, at levels comparable to fossil fuels.
Given the current exponential growth of the bioenergy industry and its environmental consequences, it is time to reexamine federal support for biomass energy. The production tax credit (PTC) for biomass alone will remove more than $2 billion from the Treasury through 2020 if current trends continue. The operator of a 50 MW biomass power plant is eligible for up to $4.5 million per year in taxpayer support through the PTC, along with millions more in other state and federal renewable energy subsidies that are direct cash
payments—regardless of whether the plant’s emissions worsen climate change rather than help address it. In an era of extreme fiscal constraint—and facing a climate crisis that demands immediate and effective greenhouse gas emissions reductions—we cannot afford to be spending scarce public dollars on “alternatives” that exacerbate the problem.
The undersigned organizations request that Congress either eliminate or significantly restrict the PTC for biomass energy. At minimum, before receiving any credit, biomass generators should be required to demonstrate (a) net greenhouse gas reductions by 2020, using a baseline that reflects what otherwise would have happened to the materials used as fuel over that same time period; and (b) achievement of at least 60% efficiency in converting biomass to useful energy (e.g., through combined heat and power
applications). We also ask that other biomass subsidy programs, including those administered by the Departments of Energy and Agriculture, be eliminated or carefully reviewed and revised to ensure compliance with similar standards. The science is clear: the utility-scale expansion of burning wood for energy threatens our forests, our climate, and the health of our communities. Decisions about how to spend scarce public dollars should prioritize truly clean alternatives.