To the Town of Greenfield
Rationale for the biomass and waste-to-energy moratorium bylaw proposal
There are many questions about the effects of various forms of biomass burning for
energy. The Manomet study was published two years ago and that study came to very
different conclusions about biomass and its effects on our forests and co2 emissions than
we previously believed. And those new ideas led to new regulations for biomass
subsidies.
There continue to be many experts with varying opinions about the effects of biomass
burning including effects on forested land, air quality, relative carbon dioxide emissions
as well as economic considerations.
The Town of Greenfield has engaged in this debate, and there is still a special permit
issued for a 47 MW power plant for North Greenfield. Now while the state has revised
how biomass will get subsidized, there are no rules in place at the state level that prevent
any biomass facilities of any size or type, except some restrictions on burning
construction and demolition debris.
Our current zoning laws leave citizens vulnerable to any possible downsides of biomass
projects that may be proposed or built in the Town. Those considerations include the
cumulative impacts of various wood burning practices in the Town, and how large
biomass facilities would add to those impacts. A moratorium would give the town and its
residents a chance to decide what is right for Greenfield.
The 1 million btu per hour threshold was arrived at by talking with heating and
engineering professionals and environmental experts. For perspective, a large three
bedroom house would need approximately 150,000 btu/hour for oil heat at 80%
efficiency. A typical wood stove is 50% efficient, and a wood stove or pellet stove would
need 250,000 btu’s/hour wood or so to match the 150,000 btu/hour of oil. Therefore, a 1
million btu/hour limit would not effect a house or an outdoor wood boiler, and would
accommodate the equivalent of 4 large homes, for the purposes of the moratorium. For an
added perspective, a 3 million btu/hour facility is the size that requires a mechanical
feed system, and the Greenfield Community College biomass pellet boiler is estimated to
be of the 10 million btu/hour size. For added perspective on the scope of this moratorium,
for there to be a requirement for a Department of Environmental Protection (DEP) air
permit and a review by the State for air pollution concerns, the emissions of any pollutant
would be 1 ton. Those pollutants included particulates, nitrogen oxides, sulfur oxides or
carbon dioxide. The GCC wood pellet facility is an example of a facility that passes that
threshold.
Specifically, we feel that some of the reasons to have time to research the effects of
biomass burning in our Town are expressed here by a local environmentalist:
“I do believe that if/when we start to see more projects moving forward due
to the subsidies like the large bio-fuel proposal in Pittsfield (which would
require more wood than the entire annual MA timber harvest and may be the
reason for the 40% efficiency loophole), and schools and hospitals with
their vulnerable to particulate populations switching to biomass, this
potentially large problem will become more apparent.”
.
The new rules (Massachusetts biomass regulations for being eligible for
subsidies) eliminate subsidies for large, wood-fueled power plants that
produce electricity only, while rewarding high-efficiency combined
heat-and-power facilities, which utilize some of their steam for heat and
have lower CO2 emissions per unit of useful energy. These lower emissions
are still generally worse than fossil fuels for both CO2 and most conventional
pollution emissions.
Large bio-power units are available with efficiency levels much greater than the
50% (State) standard (for subsidies) which would be better, but still worse than
fossil fuels.
One would think these are actually low CO2 emission units, when in fact they are
still very high emitters, but just a bit lower than the worst of the worst.
Regarding CO2 emissions, the Manomet said biomass was worse than oil for 1530 years and worse than gas for 60-90 years for heat operations, and that was
based on using biomass with 75% efficiency, so it would even be worse at the
50% efficiency level.
The small biomass facilities pollute at an even higher rate per unit of
energy produced than do the larger facilities. The cumulative impacts from a
multitude of "small" facilities could ultimately be worse than a few large
ones and we should think about allowing more burning, and increased pollution.”
Regarding the moratorium on waste-to-energy, this is from Massahchusetts DEP dated
December 2012. “ Mass DEP will modify the moratorium on municipal solid waste
combustion to encourage the development of alternative technologies (e.g., gasification
and pyrolysis) for converting municipal solid waste to energy or fuel on a limited basis.
The moratorium will remain in place for new capacity for traditional combustion of
municipal solid waste. Total new capacity for gasification or pyrolysis of municipal solid
waste will be limited statewide to 350,000 tons per year. This limit is set at 1/2 of the
projected in-state capacity shortfall of approximately 700,000 tons if our disposal
reduction goals are met, ensuring that we do not overbuild long-term disposal capacity.
These technologies will be used for those portions of the waste stream for which reuse or
recycling are not an option. Proposed projects will have to meet stringent emissions,
energy efficiency, and upfront recycling standards. New facilities will be subject to the
same site assignment rules as other facilities. MassDEP will seek stakeholder input while
developing performance “
Given the controversy sure to erupt over this action by the DEP, we feel that it would be
best to have time to research waste-to-energy for the Town, rather than be faced with a
proposal for a waste-to-energy project that would divide our community.
Respectfully submitted by the Moratorium Petitioners