PFPI-BiomassIsTheNewCoal-April-2-2014

sound green and renewable, whereas “biomass power” does. A letter from Michigan Biomass,an advocacy group working on behalf of six biopower plants 106 in Michigan, filed inEPA’s waste rule docket, explains the bioenergy industry’s problem:“Waste wood from the pulp and paper and forest products industries is the major source of biomass fuel for thesefacilities. However, for nearly a decade, these industries have been in decline, drastically reducing the woodavailable for fuel. Because of this, alternative fuels have played a significant role in offsetting the constrainedwood fuel supply. This will only grow tighter as the state’s new energy policy promoting biofuels productionand incentivizing new biomass-fueled power production puts increasing demand on this limited resource. Theability to fire alternative fuels with our main forest-based wood fuel is imperative to the survival of theseprojects in this new energy landscape.Being regulated as incinerators would represent a regulatoryburden to power plants that utilize wood as a fuel and couldkill the legitimate reuse of materials that work well as fuel intraditional power plant boilers. Additionally, there is astigma attached to being classified as an incinerator thatBiomass industry to EPA: “There isa stigma attached to being classifiedas an incinerator that plants willwant to avoid”plants will want to avoid. It is likely a facility will cease using a material as a fuel if it means they will beclassified as an incinerator. Limiting the use of such fuel will jeopardize the viability of these plants and morematerial will be sent to landfills or open burned.” 107Because biomass burners are usually eligible for renewable energy subsidies and tax breaks, whereasincinerators may not be, it’s clear that the stigma of being classified as an incinerator may haveactual financial consequences.Many biomass plants plan to burn contaminated waste materials as fuelMany of the biomass power plants currently being developed plan to burn waste wood as fuel. Anindustry database of operating and proposed bioenergy plants lists 54 facilities that burn, or plan toburn, “urban wood,” which often includes construction and demolition wood and other potentiallycontaminated waste wood, such as railroad ties. 108 Of the permits in our database, the majority (61permits, 69%) allowed burning of some kind of waste wood besides forest and mill residues, withmany explicitly stating that construction and demolition debris would be burned. While some ofthese permits are for plants that have subsequently been cancelled, and some plants won’t be built,the high percentage of total permits that allow waste wood burning indicates how widespread thispractice has become. Of those 60 permits that allow burning waste wood, 38 (63%) are clearlyclaiming area source status under the boiler rule, meaning they will only be required to meet the106The six plants represented by Michigan Biomass are Cadillac Renewable Energy, in Cadillac; Genesee Power Station, in Flint;Grayling Generating Station, in Grayling; Hillman Power Company, in Hillman; Lincoln Power Station, in Lincoln; and McBainPower Station, in McBain.107 Letter from Tamra S. Van Til, representing Michigan Biomass, to EPA: Comments on advanced notice for rulemaking, docketID# EPA-HQ-RCRA-2008-0329, Identification of non-hazardous materials that are solid waste. February 2, 2009.108Forisk, Wood Bioenergy US database, December, 201355