SEA and biomass energy industries planning Abstract This work will examine the case study of a biomass power plant in Sardinia (Italy), as a part of a greater industrial reconversion plan. In this plan are involved: a monomer for biodegradable plastic plant and a biodegradable oils plant, starting from vegetable oil, a biomass power plant (fed with straw of thistle) for steam and energy production. No SEA for the whole industrial plan has been made. EIA at single plant level showed some problems and both cumulative impacts and environmental sustainability assessments haven’t been implemented. The integration between biomass production for energy purpose and oil production, for monomer and biodegradable oils plants needs, has not sufficiently been developed. Straw of thistle combustion brings environmental consequences (loss of soil, problems with intensive crop, potentially dangerous emissions and ash production) and uncertainties (availability of biomass). On the other hand, the choice to produce energy from biomass combustion seems to be mostly determined by granted incentives for renewable energy. An efficient planning is therefore crucial. For example, the wastewaters reuse planning could direct the development of alternative and/or complementary crops, with better integration in biodegradable plastic production. In conclusion, there are still several unsolved problems in this field: food vs no food crops; incomplete assessments on the environmental sustainability at single project level; effectiveness and interpretation of National and European laws. Answers could come from good planning and from its SEA, as well as from the revision of laws concerning both renewable energy planning and the policy of incentives for the bioenergy production. Introduction Sustainability criteria established by Directive 2009/28/CE, on which also recommendation COM (2010)11 is based, mainly concern reduction of Green House Gases emission. Legislator’s purpose is to increase the renewable bioenergy production. As result of the policy of incentives, the projects for renewable energy production plants proliferate and, between them, plants of bioenergy production represent an important chapter. The development of several biomass power plants has generated serious concerns among the local communities. This case study shows some limits related to the environmental assessments at single project level (particularly regarding cumulative impacts) and it highlights how the energy production considered “Green” may cause several negative environmental consequences. The simple criteria of CO2 emissions reduction that is adopted to grant incentives may not be sufficiently precautionary to ensure an effectively sustainable project. Materials and methods The present work is focused on a case study assessment concerning EIA of a biomass energy plant. It is located in Sardinia (Sardinia is a Mediterranean island of about 24.000 km2 where tourism and agriculture play a major role). This plant is part of an industrial reconversion plan, which also includes the realization of monomer plants (for bioplastic production) and biodegradable oils plants, using vegetable oils. Biomass is obtained from a thistle crop, Cynara cardunculus var. altilis. Its seeds are processed for extracting oil that is 1 used to meet partial needs of the chemical plants. Thistle straw would feed the thermal power plant in cogeneration, namely able to produce electric energy for the electric distribution network and low pressure steam for the monomer and biodegradable oils plants (Figure 1). The whole project is divided into phases. Every phase has its own independent EIA, limited in space and time. This approach obviously doesn't allow cumulative and synergistic impacts assessment: EIA at single plant level doesn’t assess crop and oil production impacts; monomer and biodegradable oil plants are intended to expand over time; the integration between monomer production, biodegradable oil, thistle crop and energy production hasn't been properly assessed. Ultimately, EIA doesn't show to be the right tool in this case, and only SEA, related to the whole industrial plan, could highlight these deficiencies. Figure 1 - Whole Project Diagram Analysis of main issues discussed in the EIA procedure has been used to underline the importance of planning, of Strategic Environmental Assessment and also to show some weaknesses, both in renewable energy incentive system and sustainability assessment of bioenergy production in large combustion plants. Results The project analysed in the present work concerns a large combustion plant sized to burn average 250.000 t/y of biomass, able to produce 135 MWth in a year, working 7500 hours. EIA of the biomass power plant highlights a long list of environmental issues (figure 2). Main issues will be shown below. 2 Biomass chosen (thistle straw) is characterized by a high chlorine concentration. Experiences showed concentration between 1 and 2 % in mass. High chlorine and alkali concentration may create damage such as corrosion of metal parts (tubes) and obstructions. It is well known that every combustion in presence of organic carbon, oxygen and chlorine can generate dioxins. High chlorine concentration in thistle can produce PCDD/PCDF, favoured by: heterogeneous catalysis (fly ashes in smokes), temperature lowering (of combustion and smokes), precursors from pesticides, metals content. Thistle straw is characterized by high content of ashes (about 10 % in mass). A part of the ashes are classified as hazardous waste. Ashes management options indicated are: reuse in building materials, reuse for environmental recovery, reuse for compost production, landfilling. Some limitations are well known: ashes characterized by high content of alkali and chlorine are not suitable for reuse in building materials; today, technical and regulatory pathways concerning reuse of ashes as fertilizer and/or soil improvers aren't available. Experiences implemented in North Europe Countries show potential issues, related to ashes composition and contaminants content as metals, Polycyclic Aromatic Hydrocarbons (PAH) and Dioxins. The reuse of thistle combustion ashes is not evident, so a waste amount between 500.000 and 750.000 tons would be landfilled in 25 years. Today, such volumes in landfill are not available in the surrounding area. Thistle straw has a good calorific value and a good yield of biomass, that may be a good reason to justify this choice. On the other hand oil yield isn't so good (0,4 – 0,6 t/ha) and the total amount is entirely inadequate to meet real needs of chemical plants. Furthermore oleic acid content of thistle oil is about 25% while for monomer production, an oleic acid content about 80% or more is required. Biomass crop and oil production are not subjected to an EIA procedure, so these issues weren't sufficiently considered. In addiction, possible crop environmental impact on different environmental matrices were not analysed. Main issues will be shown below. Cynara cardunculus var. altilis is a non-native species. Cultivating a 40.000's hectares surface creates concerns about its invasiveness and about related impacts on natural and agricultural ecosystems. This invasiveness must be investigated, precautionary, with Pest Risk Analysis, performed according to the International Standard for Phytosanitary Measures. There are doubts about: surfaces availability for crop needs, impacts on surrounding crops, integration with local production systems, the agrarian rotation feasibility, substantial and irreversible change of crop habitat, particularly for areas subject to environmental protection due to national and/or European laws. Cynara cardunculus var. Altilis productivity varies, from 5 to 15 tons per hectare, depending on meteorological factors, pest attacks and pedoclimatic characteristics of the site. Absence of irrigation with lack of precipitation and absence of phytosanitary protection against the curculionidae Larinus cynarae F., can make the biomass production economically unsustainable and the total lack of seed production. Cultivation technique is experimental and has to be optimized for stable yields of the crop. Mechanized harvesting is experimental too as well as the use of prototype testing. On the contrary, high input cultivation ensures crop productivity, but raises some doubts about the environmental sustainability of the project. Taking into account all issues related to thistle straw combustion and incomplete integration of various production cycles, it becomes necessary to assess alternative crops suitable for bioplastic and biodegradable oil production having less hazards due to ashes, chlorine, alkali and nitrogen content. Alternative cultivations require also irrigation and wastewater reuse may provide the water. Biomass procurement plan highlights, as an impact reduction factor, that the Cynara cardunculus var. altilis might be termed a dry farming crop. It must be emphasized that several areas, in which thistle cultivation is expected, have an effective irrigation infrastructure that would be in large part unused in case of dry farming and therefore wasting a lot of public funds. Furthermore, in the same areas there are two wastewater 3 treatment plants, overall sized for treatment of 25 million m3/y of wastewater, financed by European funds to propel agricultural reuse of treated wastewater. In absence of agricultural reuse, treated wastewater would be discharged in a catchment area whose final destination is a lagoon zone, bound to environmental European Directives. The Lagoon, which is close to the sea, currently shows a number of environmental problems due to anthropogenic impacts, especially related to the water quality. These issues affect coastal bathing waters quality too, with great economic damage for the tourist sector. On the other hand, water availability (also considering wastewater reuse) could allow alternative crops, suitable for oil needs requested by monomer plants. Both EIA and SEA require, as assessment method, a comparative analysis of different scenarios. The alternative crops would represent a fundamental alternative to be assessed in SEA Procedure. The lack of this methodological approach doesn’t allow both identification and assessment of the projects global impacts on the involved territories. Figure 2 - Environmental Issues: Summary Diagram Conclusions Ultimately, EIA procedure shows deficiencies in impact assessments. The choice of the biomass seems to be determined by needs of energy production, rather than by oil production needs, maybe due to the adopted incentive system. However, as shown, this choice generates many environmental issues, so the CO 2 emissions reduction criteria seem not to be precautionary. The integration between energy, monomers and 4 biodegradable oil production proved to be scarcely developed. The analyzed project considers the use of residual biomass-derived oil production, therefore estimated zero CO2 - emissions. However, even though the whole project doesn’t concern energy crops, the thistle crop has to be considered a no food culture. Therefore appropriate assessments in relation to the loss of soil and cumulative impacts on biodiversity should be made considering also all the intensive cultivation (making a distinction between food and no food crops) throughout all the territory. Planning is strategic, including wastewater reuse that may develop crop diversification. The wide range of aspects involved in the process could have been adequately analyzed through SEA procedures. On the other hand the incentive policy should require greater guarantees on the environmental sustainability, including the constraints on waste production and its management, on air emissions, as well as on thresholds of agricultural surfaces used for no food crops, as a form of protection of the food crops. References Aru A., Arangino F., Baldaccini P., Vacca S. (1986). I suoli delle aree irrigabili della Sardegna. 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