Shall we begin by stating that biomass incinerators are rarely, if ever, factually represented by the many sales pitches we see issued by the Energy Industry sector that promotes them. In fact, the marketing language that has now become de rigueur is reminiscent of George Orwell’s 1984. “War is peace. Freedom is slavery. Ignorance is strength.”

To the point, biomass incineration is NOT clean and green, sustainable and renewable, carbon neutral and cost effective, or environmentally friendly and ecologically sound. It is quite the opposite of these beautiful and alluring marketing slogans. Biomass incineration is in reality quite polluting, unsustainable to the extreme and, in some cases, less environmentally friendly than coal burning plants.

Remember the old-fashioned hospital incinerator that nobody ever wanted to live downwind from. Who would want mercury vapors, and the many other highly toxic aerosols, wafting through their neighborhood? Well, then, why would a community want a biomass incinerator sited within winds’ reach of their schools, subdivisions and businesses. The post incineration output of these biomass plants can be much worse than a hospital’s depending on what is being incinerated.

Let’s not forget the golden rule of energy production: “Garbage in; garbage out”. Ultimately the permitting process for these incinerators often allows for the burning of various types of refuse and other feedstocks, which will necessarily degrade air quality. A close look at any state air permit application for these biomass plants will reveal the mix of carcinogens, toxins, pollutants, contaminants and poisons that is really quite alarming.

As we have evaluated the emission estimates of various pollutants, which have been submitted by the very biomass companies themselves, we wonder how they make the leap across the chasm to such environmentally attractive sound bites. Let’s be clear about the assortment and type of contaminants which will inevitably show up in the surrounding air of these biomass plants. As follows:
(1) Dioxins and Furans (2) Particulate Matter – 10.0, 2.5 and 1.0 microns (3) Hydrogen Chloride (4) Nitrogen Dioxide (5) Carbon Monoxide (6) Hydrogen Sulfide (7) Sulfur Dioxide (8) Sulfuric Acid (H2SO4) (9) Mercury, Lead and Arsenic (10) Volatile Organic Compounds (VOC’s) such as benzene, toluene and naphthalene

One can only imagine the harmful effects to human and animal life that these pollutants will cause in those unfortunate cities and counties that have succumbed to the governmental and energy industry forces, which routinely foist these schemes on an uninformed public. What follows is a quote from the Healthcare Professionals For Clean Environment in their letter to Governor Charlie Crist of Florida regarding a proposed biomass incinerator for Gadsden County, FL.

“As you know full well, biomass incinerators of this type will produce extraordinary amounts of air pollution to include dioxin, one of the most toxic and carcinogenic organic chemicals released into the environment by industry. In addition, this incinerator will be 0.3 tons (according to the ADAGE permit application submitted to DEP) shy of being a major source of a particular hazardous air pollutant (hydrogen chloride) according to the FL DEP’s own regulatory guidance concerning the 10 ton threshold for any single air pollutant. This incinerator will also significantly contribute to the total particulate matter volume which already plagues much of North Florida. We are compelled to point out that particulate matter (PM) concentration directly correlates with a whole host of upper respiratory ailments to include sinusitis, rhinitis, pharyngitis, laryngitis, as well as the common cold. More serious respiratory diseases such as lung cancer, emphysema, pneumonia, tuberculosis, pulmonary edema, sarcoidosis, pleurisy and adult respiratory distress syndrome are all greatly aggravated by the various pollutants emitted from biomass plants. Chronic respiratory conditions such as COPD, CREST, asthma, bronchitis, reactive airway disease, as well as numerous inhalant allergies will likewise see an increase wherever these irritants exist above certain thresholds. Likewise, illnesses such as influenza and its many seasonal variants will always be exacerbated when the ambient air is fouled by these particulates and chemical emissions.”

The profound medical repercussions and health impacts of this form of incineration and crude energy production cannot be understated. Medical organizations from around the country have been weighing in on this matter for as long as biomass marketeers have been submitting their sales literature to the many small, economically depressed communities that are vulnerable to such ill-conceived proposals. The twenty to thirty long-term jobs, which are created by these biomass propositions, will be taken by many who will inevitably experience dangerous levels of exposure to the aforementioned chemicals. Therefore, they will suffer adverse health conditions, which will then contribute to the local medical burden, as well as significantly increase the healthcare costs associated with lifelong remediation.

In an age when the nation is moving toward more enlightened energy platforms concerning production, dissemination and utilization, it is quite anachronistic that some would have us go back to the Stone Age. Burning trees and the like is, after all, what was done before there was solar, wind, oil and gas, coal, nuclear, and hydroelectric power. Why in the world, with a global population approaching 7 billion, would we want to go back to energy sources that are as primitive as they are downright dirty?!

Dr. Tom Termotto, BCIM
National Coordinator – COALITION AGAINST CHEMICAL TRESPASS
Member – Floridians Against Incinerators in Disguise

Dr. Edward Holifield of Tallahassee, FL poses the question to the Gadsden County Commission during a presentation on the Biomass BioMess proposed for Gretna, Florida by the Concerned Citizens of Gadsden County, Inc. The latest black infant mortality statistics in Gadsden County are 15.6 per 1,000 live births – that’s more than twice the state average. Dr. Holifield presents a study by Kenneth Chay and Michael Greenstone linking air pollution to infant mortality.

[youtube=http://www.youtube.com/watch?v=RntFPvu1czs]

[youtube=http://www.youtube.com/watch?v=GuTVp8oGbpk]

Below is a parliamentary question, with a response from a Minister for Energy and Climate Change.  He cites government estimates of how many people will die from air pollution in the UK as a result of the government’s biomass expansion program (they obviously don’t see this as a reason for a policy-rethink).

Note that PM 2.5 is still not regulated in the UK, the State of Florida or the U.S.

Over 75,000 physicians in the Florida Medical Association, Hampden District Medical Society, American Lung Association, Capital Medical Society agree that particulate matter – PM, PM10 and especially PM2.5 cause significant health problems, diseases and death in our society. Medical professionals across the country are begging our elected officials to listen to their concerns and limit or halt Biomass Incineration projects.

“Mr. Tyrie: To ask the Secretary of State for Energy and Climate Change what recent assessment he has made of the effects of the use of biomass boilers installed to meet Renewable Energy Strategy targets on (a) air quality, (b) levels of particulate emissions and (c) levels of (i) morbidity and (ii) mortality.

Jim Fitzpatrick:
(a) The Government have, in support of the development of the Renewable Energy Strategy (RES), carried out modelling of the effect of an increase in the use of biomass for heat and power on the emissions, ambient air concentrations and public health impacts of fine particles (PM2.5), coarser particles (PM10) and nitrogen dioxide. The key air quality results of this analysis are given in the Renewable Energy Strategy on page 121.

(b) As part of the analysis the increases in the emissions of particulates were estimated over a number of different scenarios. For PM2.5 these were between 0.75 and 9.1 ktonnes from a baseline in 2007 of 82 ktonnes. For PM10, emissions were estimated as being between 1.3 and 9.5 ktonnes from a 2007 baseline of 135 ktonnes.

(c) (i) The impacts on morbidity resulting from the uptake of biomass as a renewable energy source were not assessed.

(ii) The mortality health impacts of these scenarios were estimated to be between 340,000 and 1,750,000 measured as the number of life years lost in 2020 from the impact on air quality of increased biomass combustion.”

The Clean Air Act Amendments (CAAA’s) enacted in the mid-1970′s marked our nation’s first attempt to regulate levels of air pollution to protect the health of it’s citizens. The CCCA’s established a threshold for pollution concentrations and designates counties as either “attainment” or  “nonattainment” and provides for more strict regulations on polluters in “nonattainment” counties.

Chay and Greenstone used EPA data, and County and City Data Books data file largely based on the 1970 and 1980 censuses which offered them the overall view of housing and county characteristics upon which their study was based.

IX. Conclusion – (page 43-44)

This study has exploited the air pollution reductions induced by the Clean Air Act Amendments to provide new evidence on the capitalization of air quality into housing values. The evidence suggests that TSPs nonattainment status is causally related to both declines in air pollution and increases in housing prices during the 1970s. Using the county-level regulations as an instrument, we estimate that a 1 mg/m3 reduction in TSPs results in a 0.2–0.4 percent increase in mean housing values, which is a –0.20 to –0.35 elasticity. These estimates of the average marginal willingness to pay for clean air are robust to quasiexperimental regression discontinuity and matching specification checks. Further, they are far less sensitive to model specification than cross-sectional and fixed-effects estimates, which occasionally have the “perverse” sign. The estimation of a random coefficients model provides modest evidence that the marginal benefit of reductions in TSPs is lower in communities with relatively high pollution levels, which is consistent with preference-based sorting.

Welfare calculations suggest that the mid-1970s TSPs nonattainment designation provided a $45 billion aggregate gain for homeowners in nonattainment counties. This gain is large, but the net effect on welfare is unknown since reliable estimates of the social costs of these regulations are not available. Regardless of whether the TSPs nonattainment designations pass or fail a cost-benefit test, this paper’s findings suggest that individuals place a higher value on clean air than has previously been recognized.

David Gardner, Director of the Gadsden County Chamber of Commerce was recently quoted in the Tallahassee Democrat as saying “Wednesday’s announcement in Gretna was the culmination of three years’ worth of effort, including the determination of an appropriate site and building community support.”

The Gretna Biomass Incinerator will be located on property adjacent to an elementary school with a 100% minority student population, a nearby residential neighborhood and a women’s correctional facility located directly across the street.

Reginald James, Superintendent of the Gadsden County School District stated during the presentation that CCGC was the first to bring the information pertaining to the Gretna Biomass Incinerator to the attention of the School Board.  After 3 years of “building community suport”, no effort had been made by Gadsden County, Chamber of Commerce or City of Gretna Officials to properly inform the school board or the community – we are still waiting.

Part 2 to follow.

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The project was constructed using what was  at the time, “state of the art technology”. Throughout the period during 1987 – 1988, the project received numerous Technology Innovation awards (Page 6 from Permit Files pdf) from the Governor of Florida, the U.S. Department of Energy and the ASME (American Society of Mechanical Engineers). By 1990, the plant had been shut down due to continuous violations of air emission standards and making residents physically ill.

The plant continued to operate illegally, knowingly in violation of it’s operating permit (Page 6 Complaint Files pdf)  – verified by inspection from the Department of Environmental Regulation.

After suffering and fighting with the Florida Department of Environmental Regulation and Southern Electric International for several years, the residents of Gadsden County had finally rid themselves of this polluting industrial behemoth.

In a letter dated January 15, 1985 to the Florida Department of Environmental Regulation, (Page 67-68 of the Permit Files pdf) Mary Wolter Glass, Vice President for Alternate Gas, Inc., the developer of the Biomass Incinerator assured the DER that due to the technology being used, carbon monoxide, Nitrogen Oxides and Sulfur Dioxide were not expected to occur. She stated that emissions of Carbon Monoxide and Nitrogen Oxides were small enough to be considered negligible, and Sulfur Dioxide can be rated as zero.

Residents began to complain of a blue haze in the air, acrid smelling stench in the air that smelled like creosote, sticky black soot all over their property and homes increased carbon monoxide levels were making residents physically ill – suffering from headaches, nausea and sore throats (Page 6 Complaint Files pdf). A 1987 report produced by the Sierra Club listed Quincy, Florida as having the ninth worst acid rain samples in the nation according to a letter to the editor to the Gadsden County Times by Quincy, Florida resident Mary Howard Edwards (Page 39 of Complaint Files pdf)

Fast forward to 2009 -

ADAGE and the City of Gretna announce plans to build a Biomass Incinerator in Gretna, Florida in close proximity to Gretna Elementary school, residential neighborhoods and a women’s prison. ADAGE has no track record of ever constructing a Biomass Incinerator anywhere in the United States. The model that they point to as to be the closest existing facility in Lockerbie, Scotland was built by another corporation (E.ON). ADAGE HAS NO WORKING EXAMPLES OF THEIR PROPOSED BIOMASS INCINERATORS. We are supposed to believe that everything is going to be fine, just like it was back in 1985, because it all looks so good on paper!

There are hundreds of pages of documentation from the 1985 BioMess available below, including letters written by residents, newspaper articles, Air permit files, Emission Compliance files, punitive actions against Southern Electric by the DER, etc.

Download the historical documentation of how the residents of Quincy, Florida suffered from Biomass Incineration below:

Complaint Files

Compliance Files

Enforcement Files

Permit Files

Dear Sir/Madam:

Your website contains false information about the carbon neutrality of biomass combustion used to generate electricity. It states,

“Biopower to the People

The ADAGE biopower process uses wood debris from forest operations to generate electricity. This green electricity is carbon-neutral energy that reduces our reliance on fossil fuels and associated greenhouse gases. Click on the image above to learn more about how our process works and positively affects local communities and the environment. http://www.adagebiopower.com/process.php”

The claim of the carbon neutrality of biomass burning is unsubstantiated by science, and has been debunked by a team of leading scientists,  writing in Science, 325:529, October 23, 2009, who state,

“However, exempting emissions from bio-energy use is improper for greenhouse gas regulations.  Replacing fossil fuels with bio- energy does not by itself reduce carbon emissions, because the CO 2 released by tail- pipes and smokestacks is roughly the same per unit of energy regardless of the source ”

“Thus, maintaining the exemption for CO 2 emitted by bioenergy use under the protocol (IPCC) wrongly treats bioenergy from all biomass sources as carbon neutral. For example, the clearing of long-established forests to burn wood or to grow energy crops is counted as a 100% reduction in energy emissions despite causing large releases of carbon.”

“However, harvesting existing forests for electricity adds net carbon to the air. That remains true even if limited harvest rates leave the carbon stocks of regrowing forests unchanged, because those stocks would otherwise increase and contribute to the terrestrial carbon sink.”

It has come to our attention that ADAGE is using false claims of the carbon neutrality of biomass burning to promote its power plants including the plant in Gretna, Florida, and to seek and obtain federal subsidies.  Please provide a response to this email that explains in full the scientific basis for ADAGE’s claims that biomass burning reduces “our reliance on fossil fuels and associated greenhouse gases.”  Please include in your analysis the fossil fuels used to harvest, store, process and chip the wood fuel supply for the Gretna power plant, and the volume of carbon dioxide emissions from the smokestack of the plant.

The Biomass Accountability Project, Inc.

Margaret E. Sheehan, Attorney at Law

cc:  Floridians Against Incinerators in Disguise

Gainesville Sun Letters to the Editor – Published: Wednesday, December 30, 2009

In his Dec. 20 column, Ron Cunningham listed some of the reasons wood for GRU’s biomass generator may be too expensive for us to buy when that unit is ready to produce electricity. He suggests the local community could buy a forest to supply fuel for the plant “just in case” prices reach a level we cannot afford.

He says we might even persuade the state to allow harvesting fuel wood on the forest land it owns in the county.

It’s a good thought, except that there isn’t enough available forest land in the county to help us ratepayers much. The plant will burn nearly 2 tons of wood a minute, and it takes over an acre of productive Florida timberland to grow that much wood in a year.

The county owns and manages 6,100 acres of productive timberland, while the state owns about 5,500 acres outside Payne’s Prairie. Together, state and county-owned forests might fuel about seven and a half days of biomass generator operation each year, assuming they were sustainably managed and produced as much wood per acre as the commercial timberlands in the county do.

Even if we clear cut the whole 11,700 acres of county and local state forestland to fire the plant in an emergency, the total harvest would supply the generator for only about nine months.

It would take about 880 square miles of sustainably managed Florida timberland land to supply all the wood GRU will burn in its generator in a year. There are only 874 square miles of dry land in the entire county.

Few people understand how much wood electricity generation requires, and how slowly it grows.  It would take 850 square miles of sustainably managed Florida forest land to supply all the wood GRU will burn in its generator in a year. That’s one of the reasons many of us have opposed it since the idea first surfaced.

Dian Deevey,

Chair,

Alachua County

Environmental Protection

Advisory Committee,

Gainesville

• 310 Truck Trips per day (total) – trucks with an average weight of 30 tons hauling wood, ash, ammonia and dry sorbent.
• Wood will be delivered by truck 125 trips per day (Fully loaded trucks with a weight of 40 tons)
• There is not enough wood debris available to fuel these Biomass Incinerators – they will be burning whole trees and our county will be deforested rapidly.

Your air will contain the following:

247.5 tons per year (TPY) of carbon monoxide (CO); 236 TPY of nitrogen oxides (NOX); 140 TPY of particulate matter (PM); 110 TPY of PM with a mean diameter of 10 micrometers (μm) or less (PM10); 26 TPY of sulfuric acid mist (SAM); 150 TPY of sulfur dioxide (SO2); 60 TPY of volatile organic compounds (VOC); 0.175 TPY of lead (Pb) and 9.7 TPY of hydrogen chloride (HCl).

Information obtained from public records and permit applications for the Hamilton County Biomass Incinerator Project – the first of ADAGE’s announced Biomass Incinerators projects. It has been reported that ADAGE has plans to build 100 of these Biomass Incinerators across Florida, South Georgia and Texas.

I thought you might be interested to see the “Dear Congressman” factsheet I prepared back in April when I was in DC. Linking RECs from biomass to REAL carbon emissions is the last point on the sheet, but as it points out, this can only be done after true carbon accounting determines what the emissions are. It concludes “Renewable energy credits should be scaled accordingly”.

Burning woody biomass derived from native forests to generate energy will drive forest cutting to unsustainable levels and increase net greenhouse gas emissions. It will also increase dangerous air pollution. We encourage you to withdraw support from granting biomass unconditional renewable energy credits in the Clean Energy Act.

Some real numbers on biomass plants from Massachusetts: a case study

• Number of biomass plants proposed: 4 – 5; Megawatts generated by proposed plants: 165[1]
• Wood required: 2,145,000 tons per year; Minimum acres cut per year: ~ 45,000[2]
• Equivalent number of trees cut per year: more than 9,000,000[3]
• Amount of CO2 emitted: over 2,000,000 tons per year
• Percent of Massachusetts energy to be generated: ~1%
• Increase in CO2 emissions from the energy sector: ~10%

Air emissions from three Massachusetts plants currently in the permitting process:

• 492 tons of NOx per year, which forms ground-level ozone
• 98 tons of hazardous air pollutants
• 165 tons of fine particulates

Biomass is not carbon neutral

When a 75-year-old tree is cut and burned, then it will take 75 years to re-sequester that carbon. The Intergovernmental Panel on Climate Change recognizes that forest cutting and burning increases carbon emissions, and that carbon released takes decades to re-sequester.

Biomass over-exploits forests and degrades their vital carbon sequestration capacity

A single 50-megawatt biomass plant requires about 650,000 tons of fuel a year. Brush from logging and other waste wood will not be enough to support large biomass plants – new trees will have to be cut. Research shows that forests sequester carbon best when undisturbed, and that recently cut forests are major sources of CO2.

Support these reasonable fixes in the Waxman Markey Clean Energy Act:

1. Require biomass combustion for energy to undergo the same lifecycle analysis required for transportation biofuels, accounting for all CO2 emissions from harvest, transport, and forest disturbance
2. Require that the assumption of carbon neutrality for biomass be qualified by consideration of the time required to re-sequester carbon released by burning. Renewable energy credits should be scaled accordingly.

[2] Using numbers from State of Massachusetts reports: it requires 13,000 tons of green woody biomass to fuel 1 MW of generation. Existing forestry residues in MA: 110,000 tons per year. Assume moisture content of green wood is 45% (so dry weight is 55% of green weight). Maximum amount of wood that can be extracted per acres (heavy thinning, leaving only large lumber-quality trees): 25 dry tons. Summary: [(13,000 tons  x 165 MW) – 110,000 tons] x 0.55 = 1,119,250 dry tons; divide by 25 dry tons/acre = 44,770 acres. At lighter harvest levels, more acres of cutting would be required. Use green wood weight and divide by 434 lbs, the average weight of trees too small for sawlogs: 9,377,880 trees.

[3] Massachusetts’ biomass availability study includes “forest residues” from 14 counties of surrounding states to make up supply for biomass plants. Our analysis does not assume that wood in other states is available to Massachusetts, or that it is economically viable to collect it. We calculate fuel use based on whole tree equivalents, since existing plants are already burning whole trees and planned facilities have whole-tree burning written into their permits.

check out our website:
www.massenvironmentalenergy.org