PFPI-BiomassIsTheNewCoal-April-2-2014

fueled power plant proposed in Montgomery, New York depends on plastics in fuel togenerate sufficient energy for the gasification process they plan to use. 113Shredded tires are another attractive fuel that is seen as integral to the success of the proposed 25MW North Star Jefferson wood-tire burner proposed in Wadley, Georgia, where thedeveloper states that “TDF is important to the financial viability of the project given its high caloric contentas evidenced by its use in various industries such as pulp and paper production, cement plants in addition toelectricity generation.” 114 The North Star plant avoided PSD and thus did no pre-construction airquality modeling. It will be a significant new source of air pollution in a community that alreadyincludes several large polluters, including a lumber mill that is a large source of emissions fromburning wood. Developers of the North Star plant include the U.S. Endowment for Forestry andCommunities, a non-profit organization that is setting up the for-profit wood and tire-burner togenerate revenue and, they say, to revitalize the economy around Wadley. 115Loophole 7: EPA rules blur the line between biomass facilities and incineratorsThe bioenergy industry needed EPA to redefine wastes as legitimate fuels, because for biomassplants where the “traditional fuel” is unadulterated forest wood, the waste rule’s requirement that“non hazardous secondary materials” (NHSM) contain no more contamination than traditionalfuels 116 might be assumed to exclude most contaminated materials. EPA’s response, which hasbeen to define “traditional fuel” as any fuel afacility might burn, even a very dirty coal, hasbeen more than satisfying to the bioenergyindustry and other facilities that burncontaminated fuels. The EPA’s latest waste rule isEPA’s waste rule classifies contaminatedmaterials as “non-hazardous,” allowingthem to be burned as biomassexplicit – a facility can burn contaminated fuels, including construction and demolition wood, aslong as concentration levels of contaminants are “comparable to or less than the levels in the traditionalfuel the unit is designed to burn, whether wood or another traditional fuel,” 117 and that “Designed to burn”means, “can burn or does burn, and not necessarily permitted to burn.” 118 This includes coal. The ruleclarifies further: “The agency has also determined that restricting comparisons to traditional fuels the unit ispermitted to burn is unnecessary. The fact that a facility is not currently permitted to burn a particulartraditional fuel does not mean it could not be permitted to burn that traditional fuel in the future. For thisreason, we do not believe it is reasonable to limit the comparison to permitted traditional fuels.” 119113Our report on Taylor Biomass is available at http://www.pfpi.net/wp-content/uploads/2013/05/PFPI-Gasification-and-DOE-loan-guarantees.pdf.114http://northstarrenewable.com/index.php/projects/north-star-jefferson/faqs115http://usendowmentblog.blogspot.com/2011/12/working-not-where-light-is-best-rather.html116Because the rule requires comparing contamination on a material weight basis, not a material energy content basis, a biomassfacility can burn a “less contaminated” material and still emit more air toxics than a same-sized coal plant, because the lowefficiency of bioenergy requires burning more fuel to produce the same amount of energy.117 40 CFR Parts 60 and 241. Commercial and industrial solid waste incineration units: reconsideration and final amendments;non-hazardous secondary materials that are solid waste. Federal Register Vol. 78, No. 26, Thurs. February 7, 2013. p. 9139.118Ibid, p. 9136119Ibid, p. 914957