HomeMy WebLinkAbout111411_ra02
BoCe Agenda
JEFFERSON COUNTY BOARD OF COUNTY COMMISSIONERS
AGENDA REQUEST
TO:
Board of County Commissioners
Philip Morley, County Administrator 1 '/
AI Scalf, Director, Dept. of Community Developmenl~
Stacie Hoskins, Planning Manager M
Zoe Aun Lamp, AlCP, Associate Planner fJU
DATE: November 14, 201I
SUBJECT: Dehberations on the Draft clitruite Action Plan
ATfACHMENTS:
I) Testimony from the public hearings and written public comments
a. Testimony from BoCC Public Hearing 10/17/201I
b. Testimony from City Council Public Hearing 10/17/2011
c. Information from notebook presented to Council by Elaine Bailey
d. Written comments received by City and County
2) Response to Public Comments
3) Government Leading by Example/Reauthorization of the Climate Action
Committee/Revised Work Plan
4) Draft Resolution
FROM:
"
STATEMENT OF ISSUE: '"
The Board and City Council will review public comments and determine whether or not to adopt the draft Climate
Action Plan as presented at the October 17, 2011 public hearing or propose alternative language. Both bodies will
also consider reauthorization of the Climate Action Committee and approval of the revised Work Plan. A copy of
the draft Climate Action Plan and the October 17, 2011 Agenda Request can be downloaded at:
hno:!/www.co.iefferson.wa.uslcommissionerslAgenda/2011 %20Attach/1 01711 raOl.odf
BACKGROUND:
The Board of County Connnissioners and City Council held individnaI public hearings on October 17, 2011 to hear
public testimony on the draft Climate Action Plan. The period for written public comments began October 5, 20 II
and ended on October 19, 2011. The testimony and written comments from both jurisdictions and a response
document are attached.
The City Council and Board of County Commissioners met in a joint workshop on July 21, 2011 to review the Draft
Climate Action Plan. During the meeting members of both bodies provided suggested changes and referred the
document to the CAC. Staff made the suggested revisions to the plan and sent it to the CAC members for review
prior to release for public review.
ANALYSIS/STRATEGIC GOALSIPROS and CONS:
While the City and County governments will each have a major role in carrying out the objectives and actions of the
Climate Action Plan, successful implementation will require many diverse partners, including neighboring
jurisdictions, non-profit organizations, business leaders, and neighborhood associations.
The proposed revised work plan lannches the committee into a public outreach campaign designed to inspire
1
BoCC Agenda
individual action and lead the community to significant reductions in green house gas emissions.
FISCAL IMPACT/COST-BENEFIT ANALYSIS:
The Action Plan proposes a phased approach. It addresses specifically what the City and County governments can
do to lead by example while recognizing that funding and resources are limited. It also recommends measures that
the community should consider, as well as outreach, education, and partnership opportunities.
Adopting a comprehensive, long-term plan puts the City and County in a better position to take advantage of funding
and other opportunities as they arise.
Department of Community Development stafIwork is covered by the department's annual budget For 2011 the
Department assigned.1O FTE to support the Climate Action Committee.
RECOMMENDATION:
Staff recommends the Board approve the resolution to:
. Adopt the draft Climate Action Plan;
· Approve the revised committee work plan as presented at the July 21, 2011 joint session; and
· Extend the Climate Action Conunittee to December 31, 2014.
REVIEWED BY:
fh~
""
tor Date
2
"
CB
t
BOCC 10.17.11
Climate Action Plan
10:01 am
Chairman Austin
Hearing Draft Climate Action Plan
AI Scalf, Stacy Hopkins, Kees Kolff, (Chair, Climate Action Plan), Zoe Ann lamp
Introduction - Kees Kolff
My report will be very brief. Sunday NVT article: Where did Global Warming Go? "Now that nearly
every other nation accepts climate change as a pressing problem, America has turned agnostic on the
issue." The bad news is that global warming has become a hot political issue in this country and we still
have no federal government policy to really address it adequately. The good news is that more and
more states, counties and cities' are really taking the initiative and forging ahead with aggressive plans to
save energy, reduce costs, create green jobs and build more sustainable communities, and I'm proud to
say that I live in one of those communities that is taking action.
The challenge of climate change, it's a problem I'm sure everyone has heard about. The scientific
evidence supporting significant climate change from fossil fuel consumption is increasing and so are the
consequences. The Wall Street Journal just reported that 10 extreme weather events across the United
States this year, over 10 billion dollars of damage each making this the worst financial year in terms of
effects of extreme weather. In recognition of these challenges and this problem, you and the City
Council have decided to go ahead and adopted a Joint Resolution to achieve a community wide
reduction of greenhouse gas emissions to 80% lower than the 1990 levels and to reach that goal by
2050. And this graph you have seen numerous times shows it. The green dotted line is the line that we
need to get on in order to get to that 80% reduction by the year 2050. And this seems like an enormous
task but, and it is, but I think if we approach it carefully and systematically and have some interim
targets which we have set for you as well as part of a plan, I think that it is achievable. To put this into
perspective, the Kyoto protocol has set only a 5% reduction for the planet by the year 2012. It's been
ratified by 193 countries to date, unfortunately the US is not one of them. And that's a fairly short term
goal. Washington State has set a 15% reduction goal by the year 2020. And that is in fact the first target
year that we are shooting for. They have also set a 36% reduction by the year 2035. And I don't know
how they came up with this number, but they set a 57.5% reduction by the year 2050. And this is for
state wide emissions reductions. Our goal at 80% reduction below 1990 levels is more dramatic than
that and that's because the best scientific evidence we have been able to look at suggest s that that is
really what is required and your are in good company. Many other cities and I think even the state of
Califomia has embarked on the same goal. Clallam County, your neighboring county, also has goal of
80% reduction. Jefferson County, our goal is to get to 18% below the 2005 levels which was our baseline
for our emissions data by the year 2020. So that's the size of the reduction that we are looking for, and
to remind you again, the state wide goal is a 15% reduction by 2020 but that's oftheir 1990 levels. And
again just to remind you we have a very detailed Inventory of C02 emissions from the county at large
the whole entire county including the government and the city sector of that...this is for the entire
county, county wide. And the city and county emissions are part of this total picture. And just to show
'(
you the difference for the county roughly county operations roughly 50% of your emissions are from
transportation in part because there is no large industrial sector the county government is involved in.
For the city itself, it is only 25% of the cities government operations emissions. And the biggest one in
the city its largest single source of their emissions is their waste water treatment plant which account
for about 38% of their emissions. But for the community at large, transportation is almost 40%.
Industrial is about 29%, and that's mostly Port Townsend Paper. Residential sector 23% and
commercial, 9%. And again we are looking for a reduction across the board for this county but our plan
focuses on the city and county operations to lead by example. So we have been following the local
communities for sustainability, ICLEI, Milestones, you made a commitment, you empowered a
committee to go forward and get an inventory of emissions (Milestone 1.) Then set targets and goals
(Milestone 2). And now we are at Milestone 3 to establish the local action plan. And we are looking
forward to your doing that as soon as possible so that we can actually get on with implementing the
local action plan (Milestone 4) and then obviously over time monitoring and evaluating progress with
feedback to make modifications as we go along and as we see what are the opportunities and what are
the challenges and requirements for going forward.
So how do we see this getting implemented? Well, first of all as I mentioned its government leading by
example. There is ample evidence if government leads by example the community is much more likely
to follow. Critical next step is public education and involvement. We have outlined a number of
community voluntary measures that these are recommended actions and we hope that in developing
the appropriate partnerships in our community that we can get the broad kind of support from business,
from individuals, from different agencies and organizations in order to go forward. Another important
step would be amending those policies that both the City and the County have which would help
implement additional, and not only these recommendations, but additional recommendations and there
is a recommendation in the work plan, the revised work plan we are presenting to you as well which
addresses that as a critical component. As I mentioned, ongoing and monitoring feedback and change.
One question that always comes up is the funding. Obviously budgets are tight for all jurisdictions these
days and in spite of that we do see that there are some grant opportunities and it should be noted that
if you have a plan, a specific plan in place, that is what allows you to then take advantage quickly of
grant funded opportunities that come will from a number of locations, whether it's government grants,
or private industry grants, or foundation grants. Another very important part of this is the reinvesting
the energy cost savings. There are dramatic examples around the country of jurisdictions that have
invested money to upgrade buildings, retrofit, increase energy efficiency. They are have paid back and
plus some. That money can be reinvested in the community to continue to do the upgrades and to lead
to reduced use of energy as well as to create jobs. And again we are looking at partnerships, all kinds,
and then bonds, tax incentives. It could also be used to in order to promote both voluntary efforts that
need to happen at the community level. And then again we see this as a real opportunity for job
growth. And more and more people are seeing the potential benefits. So very specifically the next
steps, the October 19th is the end of the public comment period for this round. November 7th we are
hoping deliberations by the County and the City, and we are anticipating, hoping for adoption November
14th. In order to continue this work which as you mentioned has taken several years to get to this point,
we are asking that the Climate Action committee work be extended until December 31st of 2014 and
'"
"
then there is a revised work plan for that. Phase I is the most urgent thing which needs to be completed
now which is the community outreach and engagement component. Phase II is to look at some of those
policies that I referred to particularly in transportation and land use that the City and County can
implement in order to facilitate even more creative local action on dealing with this problem and
realizing the opportunities. Phase III is to really look seriously at preparing for the changes that are
already occurring in the State of Washington. And to develop an adaptation plan so that we can be
prepared at this point the changes significantly hampered our local community but there is clear
evidence and if you go to the state Dept. of Ecology website, right up front they are making climate
change the ecological issue. In the opening paragraph they say climate change is the environmental
issue that we have to deal with. The State Dept. of Ecology is really working very diligently to address
particularly. And to work with the local communities to figure out what's appropriate for adaptation.
Then ongoing monitoring, evaluation and feedback.
And finally, a recent article in The Scientific American, a quote by John Kerry: "I'd like to say that dealing
with climate change is not going to require the greatest sacrifices, but it is going require the greatest
foresight Americans have ever had." I think that's what we are trying to do here. We are trying to give
you the tools so that in fact, in hindsight, in the future, we can say, today we had the foresight to deal
with this problem seriously. The Climate Action Committee is willing to continue to work with you to do
that.
Public Comment- Gene Farr, Port Townsend
I take exception to the statements made here introducing this Climate Action Plan. It's not going to save
dollars. Ittakes grants, and all sorts of taxes and things like that to make this thing work. It's going to be
a drag on the economy. The green jobs In order to be effective have to be subsidized, another drag on
the economy. This is a very dangerous proposal. And contrary to what was said here, as I pointed out a
month and a half ago when I gave testimony at one of your hearings then, there are severe flaws in the
modeling and the climate work that has been done out there. And more and more is coming in every
day.
We are finding renowned institutions like MIT, and data from NASA is countering much of this stuff that
has been promulgated out there. So it's very dangerous to assume that the climate change has been
caused by humans and that it will be catastrophic. A few examples of severe weather in one year do not
prove anything. If you look at the history of the severe weather, it's getting less severe as time has gone
on even though the temperature has crept up slightly. And that creeping up of temperature is more
correlated with solar activity than it is with human C02 use.
You finally got the glossary in the thing here right to include water vapor as one of the contributors to
global warming. It should have been at the head of the list because climate change, pardon me, the
greenhouse effect is dominated by water vapor. If human contribution of CO2 is only 1/10 of 1% of the
total greenhouse effect, it's miniscule. And to totally destroy our economy based on that 1/10 of 1% is
ludicrous. You shouldn't be doing that. And to expect grants, which is our tax money, that went off to
Olympia or Washington DC, where those bureaucracies scraped off their percentage, come back and do
..
some good here to underwrite inefficient technologies and bureaucratically chosen technologies to do
the job. If you want true sustainability, let the free market work. Let the free market sort out what will
replace our fossil fuels. Let's go ahead and use the fossil fuels because the trees love that C02 we are
generating. What little it is. OK, they love it. So it's time to let the free market sort out what is
sustainable, and get away from this ICUE, this international organization promoted by the United
Nations to promote their agenda 21. So here we have this foreign, this international group, trying to
drive what we are doing here. The U.s. is correct in not ratifying the Kyoto treaty.
Lawrence Cole, Port Townsend
I was just looking over the list of things this morning because as expected, there is a lot of refutation
going on of the science that has been generated over the last while around the dangers of global
warming specifically, the melting of the icecaps, the release of methane from the permafrost and so on
that is building up in the atmosphere. As far as I know, these are very Significant parts of the...in terms
of.... 97% of the scientists that have been involved in these studies are still very much on board with the
notion of climate change as produced by these kinds of things, not just the CO2 but all the things that
are impacted by this slow but increasingly rapid warming that is releasing so much more until what I
have heard the feedback loop on things like methane release from the permafrost all over the northern
hemisphere is close to the point where it is irreversible. And that the temperature change will be going
up and the catastrophic effect of that is huge. And so as far as I understand the sciences, essentially the
world wide notion of it Is incontrovertible. And so I think (inaudible) humans beings don't generally
function very well except In a reactive way after the shlt has seriously hit the fan. And we have an
opportunity to rise up into a different (inaudible) be more pro-active instead of reactive. So I urge us to
move in that direction.
Deborah Stinson, Port Townsend
I would like to say that I think at this point we should not actually be discussing whether or not climate
change is real or not. I don't think that is the question before us. I really think that the question before
us today is are we going to do something about it or not. And there are a couple different ways you can
look at that. The way we have presented it is that 99% of the...90% or so of the scientists that are
looking at this today do believe that global change...global warming is a significant threat and that
mankind's activities are contributing to that. And by following that line of thinking, we can say ok, are
we going to do something about it or not. If it turns out that that Is not true, that the other smaller
percentage of scientists are correct and that global warming is not a problem and we take action, I don't
believe that the actions we take are going have a negative effect. I think there is only a positive upside
on the proposals that we are making. It will only help us in reducing our reliance on decreasing fossil
fuel availability, global change...climate change is not the only issue we are facing, but we also facing
weak oil and other fuel shortages, we have this whole thing about energy and dependence and our
security and being reliant on other countries. So everything we can do to move away from that Is a
good thing. It creates jobs and that would be an upSide for our economy.
~
.
Deborah Stinson, cont.
If on the other hand, if it is true, and we chose to do nothing, the impacts are huge on a global scale as
well as local. You are looking at massive famine, droughts, an impact that none of us even want to think
about for our grand children and I think it would be totally negligent of us to ignore the science and to
put our head in the sand and pretend it's not real when we have the opportunity to make the
appropriate changes to ensure our future.
,
"
(f9
Public Hearing before City Council October 17, 2011
Public Comment:
Stan Willard: a physics and chemistry Instructor at high school and community colleges
and a dedicated scientist in that sense. He would like to say simply that you have
already made a commitment, don't waiver. If you knew what was happening 56 million
years ago with the Paleolithic locene thermal maximum, (that means a big heat wave),
the rate that the carbon dioxide was accumulating in the atmosphere was 1.7 peta-tons
per year. Now I don't think anybody knows what a peta-ton looks like but it's big. We
are currently emitting 9 peta-tons, almost a tenfold increase in that rate. It can only be
attributable to human activity. Thafs my comment.
Elaine Bailey: has put together a rather large informational packet here that has
scientific information, mainly on the carbon neutral question. I am really thrilled that the
people who have put this plan together have really worked so hard to address an issue
that is vital. I want to read the first part of my statement. We are all concemed with
energy reduction, climate change mitigation, and reducing GHGs. I am proud that many
in my community have worked so hard to put a plan in action. However the accounting
must include all sources of CO2. What we do now and in the next decade is vital. If we
had hundreds or even thousands of years to grow more forests before biomass was
bumed, excluding biomass C02 from your PTPC accounting figures might not be as
drastic a mistake as it is now. From the report I quote "the wood fuel that makes up
75% of their stationary energy use is considered climate neutral within the CACP
software and thus was not included as a direct source of C02 emissions. Before using
a conclusion that PTPC C02 from biomass Is climate neutral, a concept that was
misinterpreted from the older IPCC reports, one should read other authors [?,] M.C.
Jacobsen, who have soundly effectively challenged and shown that these faulty
assumptions will only lead to massive releases of climate changing Co2 from biomass.
Also the newer CACP upgrades do not include this statement. The software used for
this project must have been an earlier version. I inquired about the CACP system from
the ICLEI and there are free upgrades that include what they now call an information
item that recognizes that actual emissions are coming out meaning that emissions
associated with biomass should be reported. They db not have to be included in the
final accounting but this is a choice, not because the program excludes biomass C02.
Therefore the exclusion of accounting for biomass C02 from PTPC was not a condition
of the CACP software but a choice. And you have a choice - you have a choice to
stand forth and actually claim C02 to be C02. There is no difference biogenc or
anthropogenic. Our mother earth does not recognize semantic differences and this is
very important. [Gave large binder of material to Michelle who will bring it back in]
Kevin Clark: here to give qualified support for the final Climate Action plan formulated
by the Climate Action Committee. Though there may be some who genuinely believe
there is no climate change or no climate change that is not somehow naturally cyclical, I
am convinced that climate change is now a permanent reality mostly or totally caused
~
by the human introduction into the atmosphere of numerous greenhouse gases. In
dealing directly with this issue, the City, the Port and the County are courageously
accepting responsibility to face our duty as citizens and local government to take
actions to begin to remediate and respond to this global crisis. As a current Christian
and on behalf of my Christian ancestors I take primary responsibility for the ideology
that has lead to this permanent change in the hydrologic cycle. I repent of our reading
of Genesis so that domination "over creation" means that all creatures and all elements
of air, land and water are only here as resources or commodities for the satisfaction of
human wants. This latter description has, however, become part of the basis of our
economic theory. As such the non-human entities will be always only commodities for
the satisfaction of human wants. Accepting this economic theory means that we will
consume resources that will continue to more dramatically alter the hydrologic cycle.
The satisfaction of human wants is the only value that the economic system considers.
I applaud your decisive and bold actions in the report to address best the issues of
climate change and bring about an 80% reduction in the 1990 levels of C02 emissions
by 2050 with two caveats. Except in the Mayor's letter there is no mention of carbon
neutral. In a recent edition of this document - I believe it was a recent edition - you
referred to the CACP software which "ignores C02 emissions from the buming of wood
because by intemational convention C02 from wood is considered biogenic" -that was
page 10 - Wikipedia defines a biogenic substance as "a biogenic substance is a
substance produced by life processes." As far as I can tell with my limited time any
reference to biogenic has been removed from the final document. My issue here Is that
although the burning of wood is considered carbon neutral by international agreement
or by U.S. laws, my claim is that it is not. You deal bravely with climate change but not
with carbon neutral. The earlier version says that the PTPC accounts for 29% of the
total emissions and for 99% of the industrial subsection of emissions of Jefferson
County. As far as I can tell now the cOntents of the former Table 4 "Community and
Port Townsend Corporation Emissions" has been incorporated into Appendix C and all
other significant data references to PT Paper have been removed from the final draft.
On page 81 of the final document of the chart no reference is made to PT Paper as
leading to any percent if the industrial total in 2020, 2030 or 2050. I understand that if
you don't have to deal with the issue of wood burning and carbon neutrality but if you
did the report would be very different. But if it is indeed true that PT Paper is
responsible for over 99% of the industrial emissions for the county why have they been
erased from any significant data reporting and from any direct responsibility to reach
targets. Finally an economic question: is the satisfaction of human wants the only
value included in the final document? I say that because C02 affects all life.
Diane Haas: is in support of reduction of carbon emissions and all efforts in that
direction. I have only one copy of this but I will read one paragraph and give it to you
for your consideration. This is from the National Academy of Sciences National
Academy of Engineering Institute of Medicine and National Research Council and it's a
news release from May 2011. The new report reaffirms that the preponderance of
scientific evidence points to human activities, especially the release of carbon dioxide
and other greenhouse gases into the atmosphere has likely caused most of the global
warming that has occurred over the last decades. This and then I'm going to skip down
..
, "
and just say that substantial reductions of greenhouse gas emissions should be among
the most important priorities in the national response. [Submitted the full news report.]
Scott Walker: I am a member of the committee and certainly endorse what we put
together but as you have been told it deals with just 1 % of our greenhouse gas
emissions and that's what the government puts out. Then 9% comes from the mill, you
have heard comments from Kevin and Elaine about that. 40% of the greenhouse gas
emissions come from transportation which as you know has been my subject for 25 - 30
years here. And there's a crossover - Investment by government in significantly
enhanced transit, and more pedestrian and bicycle facilities is the way to reduce that
40% that the public puts out in all their driving. So we still have to turn to you to help us
get out of this mess.
Barney Burke PUD Commissioner and member of the committee. I want to commend
the City and the County for trying to address this issue. As you've found out it is not
exactly a collection of cheap and easy solutions. There are no surprises there, none of
the climate issues have easy solutions overall. Sometimes I get discouraged but then I
think it's like retirement planning - you can't do it all at once, you have to take the
actions that you can take and realize that some of the solutions are going to come along
over time. And , think one of the things that is encouraging to me is seeing that we're
less than 18 months from completing the transaction with PSE and when you look at our
figure here we'll no longer be producing electricity with coal or natural gas. So there is
something in the near term Mure that is an improvement in terms of our own carbon
footprint - there are many other things we've done. I would certainly echo Scott's
comments about the transportation aspects of this. So thanks for giving this the
attention it deserves.
Michael Tweiten I recently moved here in July with my wife and three children. I'm a
botanist and climate change researcher. I've been working for the University of
Wisconsin Center for climatic research as a research associate - remotely obviously -
for several years but I came here in my capacity as a citizen to speak about how this
research gets turned into action. I really appreciate the effort you are making in this
small town to really be a leader in climate change action and governance and how
desperately thafs really needed and I appreciate the courage you have to address
these issues. I know that this is an ongoing process and you're just beginning this
journey together and I appreciate that especially since the effort at the federal and the
international level Is so dysfunctional and has basically fallen apart. This is where it
comes down to and this action to help our planet and our species will move forward. In
the media it is said that the science is not settled often, it is almost a plank of the
presidential nominating process right now and I agree with that in some ways because
there are two major camps assigned to this in the climate change research. Those that
believe that climate change is proceeding incrementally and those that are increasingly
concerned that we are heading toward very dramatic tipping points in the climate
system where it will get out of our hands and these may be much closer than anyone
has believed before I'm not going to endorse either one of those positions but wanted
t
to say that that is really the debate. The debate is about how close we are to
something that is beyond our control and it is imperative for you to act on this and also
feel a sense of urgency because you are leading that way. Doing larger things first
might be a really good idea. I also wanted to say that by reducing our impact and our
footprint - it is good for that to be done at the govemment level because we can't all do
it as individuals. I personally have a long ways to go and many people have gone
online and calculated their footprint on various online calculators. I did mine and found
that if everyone lived like I did in my family it would take 3.2 earths to accommodate that
resource use. I felt really bad about that being an ecologist and someone who tums off
the lights all the time and switches out the bulbs and everything else but this site lets
you do it in different countries. I tried my same activities in the country of Ecuador
which has a fairly high human development index for Latin America and it would only
take .7 earths with the same activity and that is all about public infrastructure and
govemment action and military defense and other actions we take collectively not just
as individuals. So reading through this plan I really like the focus on growing the local
economy respecting population growth and how that comes about will make a big
difference in how our community actually reduces its impact as it develops. I appreciate
the focus on land use especially designated urban growth areas so that people don't
find themselves out in the middle of the woods having to use their car without being able
to connect into a transportation system and I also as a botanist like the emphasis on
sustainable forestry and getting our trees and our people to be working together to help
their common future. Mainly I just appreciate moving to a town where a lot of this is
going on and I appreciate your leadership in this issue.
Gretchen Brewer - first would like to congratulate you for taking on this challenge as it is
essential as all the previous speakers have said. I think there are incredibly good
people on the project and I am really surprised in a way that they were led to use
outdat6d software and I guess my question is - would be to them what version of the
software they were using. And encourage them to encourage you to press for the
committee to redo the exercise including the emissions from Port Townsend Paper
because I think if you do that you will see that by ignoring the emissions from Port
Townsend Paper we can do all we want but it pretty much becomes a feel good
exercise and doesn't get us closer to where we want. I would like to give you the
present 2009 emissions from PT paper and I will point out that they are not required by
ecology because they have a special status so are not required to report C02
emissions but Nippon in Port Angeles is comparable and if you do a comparison
currently PT Paper would release approx 281 mil pounds of C02 in a year. It doesn't
matter how you account for it, it has to get reabsorbed somehow. And with the biomass
project proposed that will double. Furthermore the greenhouse gas emissions they are
reporting they will reduce actually when you look at it they are not that significant. The .
amount they would reduce so they are actually doubling most of their greenhouse gas
emissions and I can give you more data on that later. For now I will give you their
emissions inventory so you can compare these numbers and again double them for
what it would be with the biomass project. [Gives report to someone]. That will be a
useful tool to compare to the numbers in the report. The other thing as far as
transportation that will happen his biomass project with diesel trucks - they say going off
.,
r
a certain mass of fossil fuel. That will reduce one half truckload a day but the increase
in biomass increases by 15 - 18 trucks per day 50 you get a net increase of 5500 - 6500
diesel trucks per year and that will add significantly to our transportation greenhouse
gases and thafs really hard to counter with our individual transportation choices. In
closing, the groundwork has been done and is incredible. I would like to see the
numbers redone and I really don't think we need to choose between jobs and good
health and good air. We are creative enough we can come up with a solution that
doesn't compromise our health and the environment.
. '\
k.c',,~,:"
~ ""'-
"
Online ref- not presente<j in printed fOrJl:l.
hl\p:llelimatesolutions.orglproggtms/NBI/foresby-stories-and-resourccs
Pg.3of4
f;1,:"e, '&.:It-J
B.wt<j f"cr1).-~
eM-~4,'ov
ht\p:llwww.nrdc.orwcnerl\Y/forcstsnoIfueUflIeslforests-nol-fuel.pdf
http://www.birdlife.olj1leu,rpdfslBioenerl\Y Joann.um Research.pdt
http://www.mafo~orglC'.;l)"bo)l.pdf
http://www.ml!forest...orQIDrfi54qy~r.pdf
hl\p:/lcn. wiklpedi~~viki/fl!rtjcul!lles
Ptinted references
1. http://www.stanford.edu/grouplefmhliacobsonl
2. hl\p:llnohiomas!Jpuminll.orgldocsll\!1edical health !elterFINAL2 pdf
3.Statemenl by William Bl;tkeleyMD
4. Testimony Before the S~ OIl Nationaal Parks, Foresls,alId Public ~...March 3,2009
Mark E.Hannon,Phd, RIcIutrdon$ Endowed Chair and Professor in FoieslSclence. Oe}lll.llrr1enlof Forest
&osystemund Society, OJ'!:80n State University.
S.IrttyJlwww.sclentificamerican.com/artide cfm~id_ood.bumin ll-power-olanl'!H:llrhon-neutral-billh-
~
6.lil\p:/lwww.pl.pi.nellw.p-comentllijlload.J2011l06la!a-energy-pnii<tv-posilion pdf
7. Copy ofPowerpolnt by Rot: Bill Moomaw, Tufts UniveJSity alId Ik Mary 8cx:llh, Massachusetts Energy
Alliance.
8. Dr. Mary Stuart; Sooth. ProfCllSional ProtlIe.
9. Letter to Denator BernIe Sandel'll from Professor Willliam Moomaw, PbD DiRCtor, Center for
International Envinmment and Resoun:e Policy, Thffli. University
Professor Lara SJrore,SJu,ppard. PbD. Department of Ikonomics, Williams College
Dr. Mary S. Booth, PbD, Partnership for Policy Integrity
10. Review of the Manomet Stud)' by Dr. Mary S Booth.
11. Letter to The HonombIe NllDi:y PelOSi and The Honomble Hany Reld May 17, 20] O.
from a laige contingent of uS Scientists and professms.
12. www.scienmag.oq:
vol.326 23 October 2009. Fixing a Critical Climate A""')Imtlng Error
'nmothyD. SelIrelWlgerelal... .
13. AmeriClJ)l Lung Association -June24,2009. Letter 10 Homomb]e Henry A. Waxman and The
Honorable EdW88!ll J.Markey.
14;btt:I'enropa.ngu.orgl'lvlew=mtlchl&uri=/joumalslgI/gI0803l2007mm31101l207GL03110]~=20
(Ill, JAcobson - on ~ causal link between carbon dloxldealld air pollution mortality. Mark A. Jl!f;OQson
]4a. h\1p:llenvironment.1Iresearehwcb.-owclYJarlilcclnews3240 I
Carbon Dioxide Increase causes air poI1titlon deaths.
15. hllp:llwww.pf-pLnellwp-conlenlluploadsl20J !/03/Hannou Searehinller Moommv-Leuer pdf
Pg.4of4
Letter to Members of the Washinton State Legislature, Prof.Mark E. Hannon, Research Scholar Timothy
D. Searchinger and Prof. William Moomaw
Mark E. Hannon
Richardson Chair and Professor in Forest Science,
Depal1ment of Forest Ecosystems and Society, Oregon State University
TImothy D. Searchinger
Research Scholar and Lecturer Princeton University,
Transatlantic Fellow, The German Marshall Fund of the U.S.
William Moomaw
Director of the Center for International Environment and Resource Policy
The Tufts Climate Initiative
Co..founder of Global Development and Environment Institute
Professor of International Environmental Policy
The Fletcher School, Tufts University
16. Bioenergy-GCB Bioenery(2011),doi: 10.1111/j.1757-1707.2011.012.x
CO2 emissions from bimas conbustion for hioenergy:atmospheric decay and contribution eo global
wanning. Freancesco Cherubini et all . Norwegian University of Science.
I ,,' ;J.
~:
.J
Stanford Unlversi'Y Professor - Mark l.)acobson
10/8/11 4:2 PM
i.. ;;4
I
Mark Z. Jacobson
Professor of Civil and Environmental Engineering
Director, AtmosJlherelEnergy Program
Senior Fellow, Woods Institute for the Environment
Senior Fellow, Precourt Institute for Energy
CUCK HERE FOR PROGRAM rN ATMOSPHERE I ENERGY
B.S. Civil Engineering, B.A. Economics, and M.$. Environmental Engineering (1988) Stanford University
M.S. (1991) and Ph.D. (1994) Atmospheric Science. University of California at Los Angeles
S<<:;entifie Ibwkgro~d
The main goal of J~bson's ~ch is to understand physical, chemical, and dynamical processes in the
atmosphere better in order to solve atmospheric problems, such as global w~ng and urban air pollution,
with improved scil,ntific insight and more accurate predictive tools. He also evaluates the atmospheric and
Pp.a1th effects of propQsed e~rgy- and transportation solutions to global warming and air pollution, maps
.ewable energy resources, and studies optimal methods of integrating renewable electricity into the grid.
To accomplish many of these goals, he has developed and applied numerical solvers to simulate gas,
aerosol, cloud. radiative, and land/ocean-surface processes. In 1993-4, he developed the world's first gas-
aerosol-transport-radiative air-pollution model with interactive feedback to weather on any scale, and in
2001, the fIrSt nested global-tbrough-urban air-pollution-weather-climate model. In 2000, he discovered that
black carbon, the main component of soot particles, might be the second-leading cause of global wa.nning in
terms of radiative forcing after carbon dioxide. This finding provided the original scientific basis for
proposed U.S. laws H.R. 17(j() (Black Carbon Emissions Reduction Act of 2009, March 26, 2009), H.R.
7250 (Arctic Climate Preservation Act, Oct 2, 2008), S.R. 110-489 (Black Carbon Research Bill, Sept 17,
2008), S.849.18 (Bill to Require the EPA to Study Black Carbon. April 22, 2009), and in part S.39731H.R.
6482 (The Diesel Emissions Reduction Act of 2010, DERA). In 1999 he discovered that strong UV-
absorbing nitrated and aromatic organic particles and gases (types of brown carbon) could explain observed
preferential UV light attenuation in polluted air and in 2001, provided the first global calculation of the
impact of such brown carbon on climate. His findings that carbon dioxide domes over cities and carbon
dioxide buildup since preindustrial times have enhanced air pollution mortality through its feedback to
particles and ozone served as a scientific basis for the Environmental Protection Agency's 2009 approval of
the flI'St regulation of carbon dioxide from vehicles in the United States (the California waiver). He has also
studied the effects of aerosol mixing state on atmospheric heating, the effects of biomass burning on
climate, the effect of hydrogen fuel cell vehicles on air pollution and the ozone layer, the effects of aerosols
on winds and precipitation, the effects of ethanol and diesel vehicles on air quality, the effects of agriculture
on air pollution, the effects of aircraft on climate and air quality, and the effects of urban swfaces on
nate. His group's development of the world's first wind map based on data at the height of modem wind
hltp://www.sta'hford.edu/lJtOUp/efmllJ)acobson/
Page 1 of
Stanf(lrd UnlversitV Pr(lfessor - Mark Z. Jacobsc>n
10/8/114:21 PM
~'\-~ ..
turbines has served as a scientific justification for the wind component of the Repower America and Pickens
Plan energy proposals. He also coauthored the first plan to power the world for all purposes with wind.
water, and sunlight (WWS). To date, he has published two textbooks and about 115 peer-reviewed journal
p...;cles. Several hundred researchers have used computer models that he has developed. In 2oos,he
1 .:ived the American Meteorological Society Henry G. Houghton Award for "Significal1t contributions to
modeling aerosol chemistry and to understanding the role of soot and other carbon particles on climate." His
paper, nEffects of ethanol versus gasoline9ncancer alJd mortality in the United States" was the top-accessed
article in Environmental Science and Technology for April-September, 2007. His paper, "Review of energy
solutions to global wanning, air pollution, and energy security," published in January 2009, is the top-
accessed paper ever published in the journal Energy and Environmental Sciences as of September 2011. His
paper, "Influence of future anthropogenic emissions 011 climate, natural emissions, and air quality" was the
top-accessed paper during May 2009 among all Journal oj Geophysical.Research journals.
Department of Civil and Environmental Engineering
The leny Yang and AkikoYama7jJ!ci Environment & Energy (Y2E2) Building
473 Via Ortega, Room 397
Stanjord University
Stanford, CA 94305, USA
Tel: (650) 723-6836
Fax.: (650) 723-7058
Email: lacobson@stanford.edu
ConicuIum Vita
r 'fTeDt PhD Graduate Students:
. Mary Cameron
. Bethany Corcoran
. Mike Dvorak
. Diana Ginnebauih
. Elaine Hart
. Maggie PalruIa
. Idania Rodriguez
. Eena Stp. Maria
. Eric Stoutenburg
. John Tefl Hoeve
Graduate Student Alumni:
. Cristina Lozei Arc~q
. Frank Freedman
. Ann Fridlind
. Gerard Ketefian
. Alice Ryan
. Ana Sandoval
. Amy Stuart
. Jordan Wilkerson
Irttp:llwww.stanford.eOu/group/efrnh/Jacobsc>n/
1'1qJe2of6
Stanfotd Un_ Professor - Mark Z.jacnbson
10/8/114:21 PM
.~, ~1:
CmTentPostdoctoraJ Researchers :
. Gemrd Ketefian
l.-1doctoral Researcher A1nmni:
. Cristina Lozei Archer
. Whitney Colella
. Ping Ding
. Jinyou Ljang
Testimony to U.S. House C.ommittee on Black Carlmn and Global Warming
Testimony to U.s. 'Qonse Committee on Air Pollution Health Imnaets of Carbon pjoxide
Testimony to U.s. EP A to Reconsider a Denied Waiver to Allow California's Control of Carbon
Dioxide
Testimo.I\Y to U.S. EPA on fro.gosed F.ndangerm\!nt Finding
TED Debate on Renewable Versus Nudear Power
Text~oks:
Fundamentals of Atmospheric MQdeling
Fundamentals of Atmospheric Modeling. 2d ed.
hllp://www.stanfotd.edu/group/efmh/jacnbson/
Page 3 of
Stanford Unl1/e.."" Professor - Mark Z. jacObson
10/8/114:21 PM
f' ,,1t
AtnunpMlk
pOHVTlON
---
-
Atrri()~phelic.-Eollution: Ristot:}'. S~illnce, and Regulatton
Air Pollution and GIQbl.}1 Warmin~: HistpQI. Science. and Solutions
Some papers organized by topic (please see Curriculum Vita for fnlllist)
I. Energy resources and effects on the atmosphere
a. Exptoilin~ Wind Ven;u$; Coal
b. U.S. and Global Windpower Distribution and Statistics
c. Effects of bvdroj!en fuel cell vehlcle.~ on air IlOnution. climate. and lllrlIlOspheric 07.(!ne
d. The effect \;In pbotchemlcal slJlOQ of convemnQ the U.S. fleet of easo1ine veh!(:Ie.~ to modern diesel v~hlcles
e. Effects of conveninll to ethanol (E85\ vehi(:l~ IIn air ooIlution and climate
f. Review of solutions to !!lobal warminl!, nlrlK'lIutlon. nnd e.l!lm!y SllCurity
g. A oatb. to Rasta/nable ener~ by 2031)
h. Effects of In'ie wind farms on ene'W In tbe almosohere
i. C.Alifornla offshore wind ener!!v potential
j. Power OIIlDut variations of co-located offshore wiad ltlr\lilJes and wave e1]e~ converters In C'.allfomla
I. Hlgh-resolution~sol ~olutlon near the point of en$slon
a. Evolution of nallQj)llnicle size and mix!a!! slate near the poiulof emission
b. Enhanced ~Iat\on due 19 evapomtion and its effect ol) nano.particle eVolution
III. Regional climate, UV. and~.effects of aerosols.
a. Developrilentand apollcation of a new air pollutjol) modelin!! svstem -- Part III, Aerosol- phase sil1)ufations
b. Develo.j)ment and aj)J)lielltion of a new air DOli uti!)!! model;n!! SYStem - Pl!rt II. Aerosol-modufestrueture and desill1l
C. Studyinj! the el'fects ~f aerosols on venieal ollQjplysls over an urban airshed
d. IsoJatln'l nitmted and Ilemmatle aerosols and nitrated aromatic gases as'sources of ultlllviolet li!!ltt abso'1)llon
e. Effects of aerosols on C'.aHfornia and South Coast climate
f. Wind reduction by aerosol IJ'Ini\'les
IV. Effee!s ofsoll moisture,lrrigation, and agrleulttn'e on regionallillltitate and air pol1ution
a. Effect of soil moisture on temoerah.fl'll. winds. and wflula~t concentmtlons in Los AnQe1es
b. The effecl~ of amcull\1TCon c;llrimte and nlr poUlltlon in C'..allfomia
V. Regional and nested global-urban studies of photQchemlcnl smDg
a. Development and anoHcation of a new air pollution modeHn~ system. Part I' CJlls-phase simulations
b. Development and application of a newllir pollution modeHn!! system Part III. Aem.'lO'-l'base simulations
c. GA TOR"GCl\4M:2. A slndv of dav- and 111~httlme O7.0ne lavers aloft. ozone in national IJ'Irk.~, and weather durinp the
SARMAP field eampaiQn.
d. The effect on ohotOehemieal smo!! of convertin!! the U.S. fleet of !!lISOline vehicles to modem die.qel vebicle.q.
http:J /_.stanfor<J.edU/grou~Jefmh/Jacllbson/
Page4of6
Stanford UnlVorsIty Professor - Mark Z. Ja<obson
10/8/11402 PM
f~ ~
e.On'thecausallink between carbon dio:ddeand pollution mortalil;y.
f. ThC! llnhancement of 1"",,' air DOllution by urban CO2 domes.
g. The l!,lolll!l-throueh-ufbl!ll3-D ~imuJation of near-e~pliqt gas photochemistry
I. Global direct radlatI\'~ f9R:ing of soot and'9tltClf Ilerosols lUld global liquid/solid aerosol composition
a. Aoljysicallv-ImoM ~ent of elemental carbon o.plies: Impllcatlpns forelobal directJorcine of aerosols
b. SIron!! mtllative headn~ dtieto.the01illini state of black carbon in atmosplierlc aerosol~
C. GIGbaI direct mdiatlve forcinj due to multicomDOnent anlhronooehic and natl1lll aerosols
,
vn. Multiple sIze-distribul:ioo Studies of the mixing 1lIatC' of aerosol/! 8Jld clouds
a. Modeline~ldation amonI' Jll'I1icles of different COJ1Ulosilion and size
b. Strone radiative heatine d~ !Dthemi~inl! state of black carbon in atmoSDh~c aet'osofs
C. Al)lllvsis of aerosol inteiJIl'tions with numerical techniques for solvi'\!l C()!llIUlation. nucleation. condensation,
diSllQlution. and revel8ible cllemistrv aTllOl]a multiple size distJjbuilon
d. Devell)pment of ml;(ed-nl1ase clouds from multiple aero.oroI si7.e di!ltributions and the effect of the clouds 01l1lel:OSo1
removal
e. Evolution ofn~cle size and II!jxin!1 Slllte near the point oremission
f. Climatll response of soot. accountinl! for feedback to cloud a~sorvij9n
g. Thy inl'lu~ce of future anthrQ1lO~enic emissions on climate. natuml emissio!l11. and air auality
VIII. Effects of aerosol particles anll~ gases onglobal climate
a. Control of fossil~fuel particulate blaek carbon 3IId o.r~nic matter. IlOssiblv the most effective method of slowing
eloMI warminll
b. The llI\Ort-term coolineoor1on\:-teqn ~obal warmine due to bipma9S burning
C. Clililate ~nse of soot. ~ntiol! for feedback to snow amlsea ice albedo and emissivity
d. Climate ~~!' of soot. accountin!! for feedback to cloud absomtioo
e. Short-tenn effet;:ts 'If controllingTossH-fuel soot. hiofuel soot and """"S. and methane on climate. the Arctic. anl!
~
f. Eff~ of all individual commercial aireraft f1i!!hts worldwid<< 00 climate. contmils. and air pollution
IX. Numerical tel:hniques
a. SMVGEAR: A Snarse-matrix. vectorize4 Gear code for atmosoheric; m~ls
b. Madeline C03l!ulaijpnamonl! particles of diljerent l;!>mposition and size
C. Simulating condensatlonal~w\\'lh. ~apomtiol1. and coaeulation o{aerosols usin!! a combinedmovine al19 stationary
size !'rid
d. Simulatill!! eauilibrlum within aerosols and noneouilibrltrm beJwcen eases and aerosols
e. Develonmentand anolication of a Ilew jlir pollution modelinll system -- Part U. Aero!;lJl-mQduJe structure and desil!ll
f. Comoutetioo oflllobal Dhotochemlstry with SMVGEAR U.
g. m t solve n 'onal n issolu'o I 'on whe ed to
reactions
h. lrttorovement of SMVGEAR IT on vector and scalar machines throueh absolute error tolerance control
i. StudV!o!! the effect of calcium and maenesium on size-distributed nitmte and amlll9'\ium with EOInSOLY U
j. GATOR-GCMM; A Illobal-throu!!h urbao scale air oollution and weather forecast model. I. Model desierl and
treatment of subJ!rid soil. vegetation. roads. rooftoos. water. sea il(!:.an<! supw
k. Analvsis of aerosollllteractions with numericaltechniaues for solvine cOl!eulation. nucleation. condensation.
dissolution. and reversible chemistry amon!! multiole size distrihutions
1. Develornnent of mixed-ohaseclouds from multiDle aerosol si7.e distributions and the effect of the clouds on ae~1
bIlp:l/www.stanford.edu/group/efmb/ja<:ab$on/
Page 5 6
Stanford UnlYenilty Professor - Mark Z. Jacobson
lO/8/114=ZJ PM
.~ 2'
removal
m. A rq)Jled method of pammet~rizin!! absomtion coefficienlsamonl! multinle""""" simultaneously from llne-bv-llne
;!lllll
D. Studvinl! """"n acidification with conservative. stable nUflIerical schemes for nonequilibrium air-ocean el\:chanee and
~.eouilibriUOO ch~lI1i~
O. A solution to. the omblem of non eam1lhriumacltl1b<- ~.-partlcle transfer at Ion!! time S1q)
p.NumtJ!i<;lll solution to droJ1l;l)a1CSCC1!~uPl\'lth a volume-cQnservhlg. positive-def'iOlte. and unl;OJlditionally-
stable scheme.
li'eatQresof G4TOR-GCMOM~ the mlXlel nsedfQr the above mtt1f~_
Courses. taught
. CEE 063/263C Weather andStOrn1A
· eRE 064I263DAir.Po]Jution: From Urban Smog tll Global Ch(!nF
. en WA Nr ~oDntion Modeling
. om 26JB NnmeneaJ Weather Prediction
http://_,stanfOr<i.\ldU/group/efmll/Jacobson/
Page 6 016
.
..
cv
EcoLaw Massachusetts
61 Grozier Road
Cambridge MA 02138
Contact Dr. William Sammons, 781-799-0014, drsammons@aol.com
Attorney Margaret Sheehan 508-259-9154, meg@ecolaw.biz
October 20, 2009
Senator Amy Klobuchar, Chair
Subcommittee on Children's Health
Environment and Public Works Committee
Hart Senate Office Building
Washington, D.C.
Senator Lamar Alexander
Ranking Member
Subcommittee on Children's Health
Environment and Public Works Committee
Dirksen Senate Office Building
Washington, D.C.
Re: Health Effects of Biomass Burning Under S. 1733, "Clean Energy Jobs
and American Power Act"
Dear Senators Klobuchar and Alexander:
As a pediatrician, I have long been aware of your efforts and concerns
for children's health and preventive measures that benefit children and their
families while reducing our Nation's medical care costs.
With Dr. William Blackley of North Carolina, Dr. Ronald Saff of
Florida, I write to inform you of the harm to children's health from biomass
burning, which is being promoted and subsidized under the Energy and
Public Works Committee's Clean Energy Jobs and American Power Act
(CRJAP A) as a method of producing electricity in lieu of burning coal.
On October 14,2009, the Hampden County Medical Society (MA)
published formal opposition to the construction of the Russell (MA) 50 MW
wood burning biomass plant on the grounds that it presents an unacceptable
1
f ~
public health risk. [A copy of the letter is enclosed]. Similarly, on July 14,
2006, the American Lung Association of Massachusetts stated "serious
concerns" about the "significant impact of this project lRussell Biomass
wood burning plant] on air quality"[enclosed]. The Florida Medical
Association issued Resolution 08-21 urging its state government to adopt
policies to minimi7.e the approval of new incinerators such as biomass
burners [enclosed]. The Oregon Chapter of the American Lung Association
has also come out against biomass combustion [enclosed]. These are only
some of the public statements from professionals around the country
documenting biomass burning and renewable energy incinerators as a source
of a new and growing public health threat.
Biomass burning is dirtier than coal and makes climllte change
worse. As citizens concerned about the public health impacts of air
emissions from biomass burning power plants on our communities, we have
studied permit applications and other public documents relating to biomass
burning power plant proposals in Massachusetts, North Carolina, Georgia,
Oregon, Indiana and Florida, and consulted with concerned citizens in
several other states about biomass proposals (including Maine, Vermont,
Texas, and Arkansas). Our review of current research publications, data
from company proposals, environmental impact reviews, and government
analyses leads us to conclude that these power plants, promoted as "clean
energy", will have a direct negative impact on the health of our Nation's
children: both immediately and cumulatively throughout their lifetimes, and
for generations to come.
Paradoxically, however, despite the substantial evidence in the public
domain of the harm from biomass burning, this method of power production
is given preferential treatment and lucrative subsidies in CEJAPA.
At a time when our nation is struggling to meet the challenges of
rising health care costs, the U.s. Senate climllte change legislation provides
federal taxpayer money to subsidize and promote biomass burning to
generate energy. The consequence will be the increased incidence and
severity of multiple cardiopulmonary diseases, premature birth,
developmental disabilities, and cancer. At a time when the Senate is
dehllting health care reform legislation. it would be ironic indeed if that same
body also chose to act in a way that harms public health and raises health
care costs. Our young children will bear both the financial and personal
health legacy of the provisions in CEJAP A that underwrite biomass burning;
the consequences for them will last a lifetime.
2
t'. ..
On July 7, 2009, David Hawkins of the Natural Resources Defense
Council testified before the full Senate Environment and Public Works
Committee. There, he warned about a "biomass loophole." Indeed, the
problem is broader and deeper than the specifics of his testimony suggests.
Here are four factors that ought to be placed front and center in the
calculus of considerations regarding biomass.
1. The air pollution and climate ..hHnge impacts of biomass
burning are worse than burning coal.
The Rimple fact is that the combustion of biomass (wood. trash.
construction debris. etc.) is "dirtier" thlln burning coal: per megawatt hour of
power generated, in comparison to coal, burning wood to produce electricity
generates 15 times as much carbon monoxide (CO, a toxic air pollutant),
significantly more CO2 (the most prevalent greenhouse gas), more NOx,
more So" and comparable amounts of particulate matter! [see plant data
chart]. Biomass burning also emits volatile organic compounds (VOCs) in
significant quantities. NOx and VOCs are two ingredients of the ground
level ozone that is dangerous to human cardiorespiratory health.
The particulate matter from biomass burning, especially PM 25 and
nanoparticulate matter, is an air pollutant associated with asthma, heart
disease, and cancer, for which no safe level is known. Information on the
hazards of particulate pollution is available from EP A at
http://www.epa.gov/particulates.
Appro)Cimately 150 biomass burning plants are in the permitting
pipeline in the United States, made economically attractive by subsidies and
tax credits under the 2007 Energy Independence and Security Act of 2007
and the Energy Policy Act of 2005, as well as the 2009 American Recovery
and Reinvestment Act.2 The incentives for biomass burning in CEJAPA as a
1 Based on study of permit applications from three approximately 50 MW wood burning biomass
plants In Massachusetts: Pioneer Renewable Energy (Greenfield. Environmental Nollllcatlon Form),
Palmer Renewable (Springfield) and Russell Biomass (RusseD)(Alr Permn Application). See also.
LIberty Green Renewables permit applli:atlon, Indiana, and Nortb Carolina Flbrowatt application. In
Massachusetts, the newest and "state of the art" proposed biomass power plant in Greenfield
Massachusetts will emit more C02, VOC's, and particulate, and nearly as mnch NOx per MWb of energy
prodnced as the 50 year old Mt Tom coal plant in nearby Holyoke, MA. A coal burning plant in Lyon,
MA, one of a gronp called the "filthy flve" by Massachusetts by environmental gronps, plans to switch
from boming coal to burning constrnction debris biomass.
2 Because biomass burning Is considered a renewable energy project, the federal government can
pay as much as 65% of the capital cost through tax subsidies. Americans pay more for the electricity
3
.--., -'
means of generating "renewable energy" will only amplify the harmful
public health impacts from these power plants if they proliferate.
2. Even though biomass burning is dirtier than coal, biomass
carbon dioxide emissioDS are ignored under CEJAPA.
Carbon dioxide emissions from the combustion of biomass are not
included in the total accounting of U.S. emissions, and therefore they are not
included under the carbon ClIP in CEJAP A. Based on a false assmnption
about carbon neutrality, carbon emissions from biomass combustion are
treated as if they do not exist under the EP A's regulatory system and the
provisions of CEJAP A: Therefore biomass power plants do not have to buy
emission allowances for carbon dioxide.' Similar provisions are contained in
the Senate's Energy and Natural Resources Committee "American Clean
Energy and Leadership Act" and in HR. 2454, the Waxman-Markey bill
passed by the U.s. House in June 2009.
generated by biomass power because It Is considered "renewable." The premium should be paid only
for "'clean" energy.
3 Section 700 of CEJAPA exemplS biomass bwniog from the Act's requirements for allowances and from
the greenhouse gas emissions cap. CEJAPA. i 700 (13)(A), Definitions (p.556) defines 0 covered entity as
"Aoyelectriclty source". However, i 7'22. (Probibition of Excess EmissIons), (b)(l) (p.442) says 1bal
biomass is power is not a covered saurce:
"ELBCr.RICITY SOURCES.-For 0 covered entity described ia section 700(13)(A),1 emissioa allowance
for eacb ton of carbon dioxide eqnivalent of greenhonse gas !bat such covered entity emitted in the previous
calendar year, excluding emissions resulting fn>m the emnbustion of- (A) petroleum-based or coal-
based liquid fuel; (B) natum1 gas liqnid; (C) renewable biomass or gas derived fn>m renewable
biomass; or (0) petroleum coke. (emphasis supplied)
Biomass em;.<rinn. 3Ill not included ia setting the cap limits noder CEJAP A (lhewfowthe cap
nmnberdoes nolinclude all U.s. GHG emissions. The CEJAPA cap number is nOlbasedon any particnIar
mudel (EPA did several models to determine the totaI U.s. emissions, all of wbieb actnaIIy greatly exceed
the "cap" as presented ia SRlOIAFI2OO9), bot it is establisbed tbrongb 0 mechanism described in CEJAPA
i 700 (8)(P. 55S), wbieb slates:
CAPPED EMlSSIONS.- The tenD 'capped emissions' means greenhouse gases to wbieb section
7'22. applias, inc1nding emissions from the combustioa of natum1 gas, petroleum-based or coal-
based liquid fuel, petroleum coke, or natum1 gas liqnid to whicb sectioa 7'22.(b)(2) or (8) opplias.
In sum,lbe effective cap is the number of allowances allowed (CEJAPA. i 721(e)(I), (p. 432)(Emissloa
allowances), set for 2020 014,873,000,000 tons of CO2 eqnivalent for the United SlnIes. However, since
biomass combustion does not bave to get allowances (noder i 7'22.), it is not inclnded in Ibe i72l(e)(l)
nnmber. In effect !bat reduces Ibe rednction of emissioas from 2005 levels from 20% to approximately 8%.
4
" "
The result of the cap setting process in CRJAP A is that 700,000,000
tons of C02 emitted in 2020 by biomass burning will be in "excess" of the
official cap set by the number of allowances.4 This means unreg1l1nted
biomass carbon dioxide emissions would be an addition of 14.4% "above"
the total allowance cap, or approximately 12.6% Qfthe total emissions in the
Nation for the year 2020 under CRJAPA if the "cap targets" are met.
Significantly, the regulatory loophole that allows biomass C02
emissions to be ignored makes it impossible for the United States to meet the
"cap" targets. Moreover, the existence of the biomass loophole makes
investment in biomass plants extremely lucrative because these power
plants, unIike their competitors (the coal plants), do not have to bear the cost
of buying allowances. In combination with the unmerited additional revenue
from renewable energy credits, the bill will create conditions that encourage
the construction of power plants that pollute at a level of CO2 greater than
the coal plants the bill seeks to displace. All this is being done under the
banner of combating global warming.
3. By subsidizing biomass boming, CEJAPA will harm the public
health by causing an increase in air pollutiou emissions, particuIarly
particulate matter, and ground level ozone that cause asthma in
children.
The effect on public health of the biomass loophole is two fold. First,
there will be an increase in the overall quantity of U.S. emissions of criteria
pollutants because there will be more biomass plants. Second, the resultant
exacerbation of climate change impacts from biomass plant emissions will
have dire effects on the health of children in this country and throughout the
world. The worldwide devastation that will be caused by population
displacement and the spread of infectious disease is difficult to quantify or
monetize given the extended time period it takes to realize the total effects of
rising atmospheric carbon dioxide levels on the planet.
4 This figure Is calculated by taking the graph at
htl;p:llwww.ela.doe.goY/olaf/analYSl~paperlhlomass/fil!Ure4.htmlthatshows projected
combustion based blom= power generation In 2020
would be 70,000 MW with a 20% RPS. The 50 MW wood burning blom= plant In Greenfield, MA
wl1I emit more than 500,000 tons a year of C02 (see Environmental Notification Form, p. E-2,
M=achusetts Environmental Polley Act FOe No. 14388.) Extrapolating this means that under a 20%
RPS mandate, In 2020 combustion based biomass would produce conservatively 700,000,000 tons of
CO2 emissions each year [see chart Included].
5
~ T
Likewise, even in the United States, the there will be significant
negative effects from prolonged exposure to increased levels of particulates
and ground level ozone in terms of cancer incidence and increased risk of
central nervous system developmental damage (Clean Air for California,
@2OO4 Environment California Research and Policy Center), and increased
risk of premature birth [http://www.epa.gov/oar/particlepollution].
In the realm of respiratory disease, recent findings show that the
exposure to higher levels of ozone and particulate matter canse asthma in
children (Lancet. 2002 Peb 2;359(9304):386-91). Previous data, on shorter
exposures at lower levels, showed that symptoms were aggravated and/or
prolonged (JAMA, 2003; 290: 1859- 1867), but now the evidence shows that
such exposure for greater duration at levels already occurring is cansative.
In addition, further research has shown that the effects of exposure has
not only a "trigger" effect, but also a sustained effect, which compromises
cardiorespiratory physiology for days (SOTA 2009, American Lung Assoc,
wwwlungUSA.org). The impact is greatest with children, and people of all
ages with pre-existent chronic disease. In California, the highest incidence of
asthma corresponds to the areas with the highest pollution levels [see SOTA
2009]. Nationwide, the American Lung Association estimates that the cost
of treating asthma in children is more than $21 billion dollars. In Atlanta,
during the 19% Olympics when the air pollution was kept lower than
normal primarily through transportation restrictions, treatments of asthma in
the emergency room dropped 55% and the nnmOOr of office visits for asthma
control decreased 61 % [lAMA 2001; 285:897-905].
With climate change, heat waves will also increase dramatically in the
next decade according to EP A projections, doubling in Los Angeles and
quadrupling in Chicago. Carbon dioxide and criteria pollutant emissions
from biomass burning will add to total U.S. greenhouse gas emissions and
therefore contribute to the heat waves. In the decade from 1992-2001,
deaths from heat waves exceeded the total from hurricanes, tornados, and
floods combined. The 1995 Chicago heat wave resulted in more than 600
heat related deaths over 5 days (Annals of Internal Medicine, Vol. 129 Issue
4). The California heat wave in 2005 was relatively mild, but resulted in
health care costs exceeding $132,000,000 (pacific Ecoinformatics, August
26,2008).
6
<. "
In addition, wildfires have become such a prevalent and severe
problem that the American Academy of Pediatrics has separate pamphlets
dealing with the acute and cbronic effects on children.
4. The Subcommittee on Children's Health should take measures
to limit public subsidies for biomass burning under CEJAPA in order to
protect children's health.
Rather than giving biomass combustion preferentialtteatment under
CEJAP A, especially in relation to coat, legislation to curtail biomass
combustion would have a significant impact on the climate as well as reduce
the incidence of air pollution related health care costs in children and the
population at large.
We urge the Subcommittee on Children's Health to carefully consider
amendments to CEJAP A to close the biomass loophole for the sake of our
children's health and that of the planet. This does not require major re-
drafting of the bill. Instead, language that simply closes the "biomass
loophole" by mllking the power producers accountable for producing "clean"
energy in order to obtain renewable energy credits will protect our children's
health from the lifelong negative impacts of the toxic air emissions from
biomass burning. The enclosed amendment provides language that would
effectively accomplish this end.
Closing the biomass loophole by counting CO2 emissions from
biomass combustion, and JIlllking the producers accountable for those
emissions, will also help ensure that CEJAP A does not make climllte change
worse and is substantiated by the science. We look forward to discussing
. our proposal with you.
Thank you for the consideration.
Very truly yours,
William Sammons, MD.
Board Certified Pediatrician
Subspecialty Certified in Behavioral and Developmental Pediatrics
7
-{' J
Cosigners:
William Blackey, MD.
Elldn, N.C.
Board Certified in Family Medicine
Ronald Saff, MD.
T$lll$lha~see, FL.
Board Certified in Internal Medicine and Allergy-Immunology
Cancer Action Network New York, Donald L. Hassig, Director
Massachusetts Breast Cancer Coalition
Floridians Against Incinerators in Disguise
HOPE [Help Our Polluted Environment] in Taylor County, Florida
Environmental Alliance of North Florida
Florida League of Conservation Voters
Energy Justice Network
Enclosures:
Hampden County Medical Society letter
American Lung Association Massachusetts letter
Florida Medical Association Resolution
Plant emissions comparison data
EIA projections of biomass electrical generation capacity
Legislation Proposal-Amendment to close biomass loophole
Cc: Senator Evan Bayh
Senator Sherrod Brown
Senator Maria Cantwell
Senator Thomas Carper
Senator Robert Casey
Senator Kent Conrad
8
~. ,~
You raise a good point.
In general, if you look at the most recent guidance under the LGO
protocol, it says that emissions associated with combustion of
biomass should be repor:ted as 'information items' - meaning that they
should be mentioned in a city or town's inventory report, but they are
not required to be included in the City's official roll-up or sum of
emissions.
By calling these emissions 'information items' we are recognizing that
actual emissions are being produced, but since wood is categorized
as a 'renewable fuel', or a fuel that is able to sequester carbon, the
combustion of wood is treated as carbon neutral, because the same
carbon that was sequestered by the wood is now being emitted back.
The oldest version of CACP may not have had the ability to record
'information items' - I think this was a new concept that was
developed when the LGO protocol came out.
If your town would like to upgrade to the newer version of the
software. I can walk you through that. Guidance is also available on
this link: http://www.icleiusa.org/tools/cacp-2009
Or, if you would like to calculate the emissions associated with wood
outside of the software, on Page 204 of the.LGO protocol, Table G-2
has the C02 emission factors for wood (first row). Also, Table G-3
has the N20 and CH4 emission factors for Solid Biomass Fuels.
Please let me know if you would like to go over any of this on the
phone (including whether you would like to upgrade to the newer
version of CACP - it is free for existing members).
. Sincerely,
Amruta
Senator Byron Dorgan
Senator Richard Durbin
Senator John Keny
Senator Herbert Kohl
Senator Frank Lautenberg
Senator Patrick Leahy
Senator Blanch Lincoln
Senator Claire McCaskill
Senator Jeff Merkley
Senator Barbara Mikulsky
Senator Mark Pryor
Senator Jay Rockefeller
Senator Jeanne Shaheen
Senator Arlen Specter
Senator Deborah Stabenow
Senator Tom Udall
Senator Mark Udall
Senator James Webb
Senator Sheldon Whitehouse
,
9
'.
, ,
William Blackley, MD says:
February 18, 2011 at 11:47 pm
Hi,
I know this looks like a personal discussion, and I don't even live in Florida, but I
want to throw in my two cents based the science I've read and common sense.
Ifbiomass burning was clean there would be no need for a smokestack to carry
away the toxins (to your neighbors) and no need for an air permit that allows a
maximum amount of toxins to be emitted. That pretty self-evident.
First: Someone claims (as an assumption) that burning biomass is "clean
renewable electricity. " and that "Biomass is the cleanest source, nearly zero, CO2
emissions offuel available in this region of the US."
There is no humanly way possible that burning biomass, tree, fossil or slash, can
be clean.
Emissions, like those from burning biomass, (and for that matter coal) have been
proven to increase health risks. Even small amounts of these toxins would
increase risk. Why add them when it is uunecessary?
When there is a weather inversion all the toxins would hang in a plume over your
ball fields, schools and homes. Your voting citizens and children would pay the
price in subsequent increased risks of asthma, cancer, chronic bronchitis, stroke,
heart failure, diabetes and multiply other diseases that have been proven by a
huge body of medical evidence to cause or increase medical risks.
Saying 'clean' and 'biomass burning' in the same sentence is an oxymoron. Same
with coal. The really clean sources of energy are solar, wind, water and hydrogen.
Burning is not a form of clean energy. We would be well served to put our money
on these clean forms of energy.
Burning is also not renewable. There is not enough downed wood created
annually to feed all the proposed plants. Duke Power is already requesting to
burn whole trees. When it is apparent that there isn't enough wood on fue ground
the plant would be clamoring for more to burn. These plants can say what they
want but utility commissions can expand the list of what is legal to burn. Is it
possible that lobbyists and legislators would have anything to do with those
actions?
., ,
Second: Someone said, "Only fossil carbon can increase the overall atmospheric
concentration of C02." That's a convenient and misleading myth spun by
companies that would burn biomass. They all have their own set of 'experts' who
have their own special interests in testifying and they typically use the 8th grade
diagram of carbon dioxide from burning being taken up by trees and oxygen
being released. That's true but stretch the time frame out over a thousand years.
Carbon dioxide (C02) released upon burning biomass is indistingnishable from
carbon dioxide released from burning coal. Like all C02 released, 50% of that
C02 would be taken up in 20 years, 30% in 200 years and the remaining 20% in
500 to 1,000 years. Humans don't have that kind of time. Slash and logs left on
the ground may take decades to a century to decay. Note that downed wood fixes
nitrogen, emits very little methane if decaying aerobically, adds to soil nutrient
levels, helps prevent run off, add cover for wildlife and acts a host for new growth.
The study that showed methane release was talking about land filled and
mulched wood waste. That's not what opponents of burning biomass have in
mind.
Third: Scrubbers and bagbouse filters would help remove some of the toxic air
pollution from burning biomass and coal. However, there are truly clean sources
of energy and Florida has a lot of sun, so why not promote those clean energy-
producing systems. Why build something that will release more toxins in your
environment?
Multiple biomass plants have been fined for excess emissions even with these
scrubbers and bagbouse filters in place. These scrubbers and filters are based on
zero human error, perfect maintenance, perfect scheduling, no mechanical
malfunction, no holes developing in the fabric, etc. Not only that they are not
even designed to capture some of the smallest and most dangerous nanoparticles.
What happens when the emission are exceeded? They are fined . . . and keep on
emitting toxins. . . and are rarely, if ever, shut down. Once they are built and
operating they develop their own set oflobbyists and connections with legislators
who fight to keep them operating.
Fourth: Can we trust our governments to protect us? Experts (and the
government agencies) allowed lead in gasoline and paint, DDT to be sprayed all
over the United States, Agent Orange (with dioxins) in Vietnam, formaldehyde in
<(, . y
houses, asbestos in gloves and multiple pesticides that are toxic to children. They
allowed dry clean solvent toxins, PCB in transformers, medical waste facilities to
bum mercury fillil1g'l, highly toxic plastics in our drinking containers and cooking
wear that causes epigenetic i1all)age. All these products were good for some
businesses but bad for human!': . . . just like burning wood would be.
FIfth: Most of the people opposing biomass burning are doing so for health and
enVironmental reasons. Why does the forestry industIy support burning ..
biomass? How about the Southern Alliance for Clean Energy? I believe they
support the forestry and biomass burning industIy. Someone is money off these
plants while the main stakeholders, the citizens, make no money and take all the
risks. These plants make waste, dump it in the air and we breath it Our lunge;
filter the air whether we like it or not A smoke stack is just like a giant cigarette
and none of the citizens will be able to leave the room.
Could you please publish your letters of endorsement from the Sierra Club and
the Union of Concerned Scientists in this newspaper. Please specifically ask if
they endorse your statement that "Biomass is the cleanest source, nearly zero,
CO2 emissions"
I have to ask why any citizen would promote increased toxic air emission?
Thanks, William Blackley, MD
@
< .
Testimony Before the Snbcommittee on National Parks, Forests, and Pnblic Lands of the
Committee of Natnral Resources for an oversight hearing on "The Role of Federal Lands
in Combating Climate Change", March 3, 2009.
Mark E. Ha111lon, PhD, Richardson Endowed Chair and Professor in Forest Science, Department
of Forest Ecosystems and Society, Oregon State University.
Introdnction
I am here to represent myself and offer my expertise to the subcommittee. I am a professional
scientist, having worked in the area of forest carbon for nearly three decades. During that time I
have conducted numerous studies on many aspects of this problem, have published extensively,
and provided instruction to numerous students, forest managers, and the general public.
Recently there has been an increasing interest in using forests as a way to remove carbon from
the atmosphere and store it over the long-te111l as part of a greenhouse gas mitigation strategy.
US forests currently remove an equivalent of 12% of this nation's carbon dioxide emissions;
there is excellent potential to increase and maintain this carbon "offset" as part of a bridging
strategy. The following testimony reviews, in terms as simple as possible, how the forest system
stores carbon, the issues that need to be addressed when assessing any proposed action, and some
common misconceptions that need to be avoided. I conclude by reviewing and assessing some
of the more common proposals as well as my general concerns about the forest system as a place
to store carbon.
My key points: I) Forests are leaky carbon buckets, 2) Forests can play an important, but limited
roles in sequestering carbon, 3) All carbon pools need to be examined when thinking through the
merits of carbon policy, 4) To increase the sequestration of forest carbon, we need to either
increase carbon inputs, decrease carbon outputs, or put forest carbon somewhere else, 5) Forests
are best seen as a bridging strategy in carbon mitigation, 6) Seemingly "good" forest carbon
ideas when examined at the stand level at a point in time dissipate when looked at the forest level
over time, and 7) With accelerating climate change, forests may shift from being part of the
carbon solution to being part of the carbon problem.
The Basic System: Forests as Leaky Carbon Buckets
Carbon is stored in multiple ways in the forest system: in the forest itself and the carbon
harvested from the forest. Living plants store carbon above- and belowground. The longer lived
the plants or their parts, the more that they store. This is why forests contain more live carbon
than grasslands: their parts have longer lives. When plants or their parts die they start to
decompose, but some carbon can be stored as dead biomass. The slower the decomposition rate,
the more that will be stored. This is why dead wood in a forest can be an important carbon store.
Decomposition of dead plants eventually leads to the fortnation of soil carbon, which due to its
relatively slow decomposition rate can accumulate to high levels. So despite a low live carbon
store, grassland can store a great deal of carbon in the soil because it produces many dead roots
that end up as soil. Harvest of wood and bark can also store carbon, but as with other parts of the
forest system, it is subject to carbon losses, specifically doring manufacturing, use, and disposal.
, >
In the case of biomass energy, the harvested carbon is theoretically stored as unused fossil fuel
carbon. Given the longevity of carbon dioxide in the atmosphere and the fact that this fossil fuel
carbon may be eventually burned, "carbon" biomass energy must delay the use of fossil fuels for
many decades to be an effective storage mechanism.
Photosynthesis, respiration, and combustion are the major processes that control how much
carbon enters and leaves the forest system. These proeesses interact to control the carbon store
of forest systems. Forests are biological systems and as such are "leaky" with regards to carbon.
That is. there is one way in which carbon comes in (photosynthesis) but many ways it goes out
(respiration of plants, decomposers, and consumers, combustion, leaching, and erosion). A key
concept to understand is that leaky systems can store carbon, but the amount they store is related
to the amount that is coming in versus the proportion that is leaking out. By analogy a bucket
with leaks can store water, bot to do so it needs a constant input of water . However, the larger the
leaks the less water that is stored regardless of the amount of flow into the bucket. The same can
be said of a bank account; one can spend money and still accumulate wealth as long as money is
put into the account. Returning to the forest system, photosynthesis is constantly causing carbon
to flow into the bucket or account. Inereasing the input of carbon by increasing the rate of
photosynthesis will increase the average forest carbon store. Decreasing the respiration rate of
plants or decomposers or the losses from combustion will also increase the average forest carbon
store. However, regardless of cause these net increases will eventually slow and then cease as the
forest system comes to a new balance.
Disturbance, be it natural or human-induced, influences the balance of carbon several ways.
Some disturbances, such as fire, directly release carbon to the atmosphere. All disturbances
convert living plant biomass into dead biomass, subjecting the forest system to additional
respiration losses (essentially more leaks). Disturbance temporarily reduces photosynthesis;
which means that the average carbon input to the system is decreased by disturbances because it
takes some time to restore the photosynthetic capacity of forests. The effect of disturbance
depends on the frequency and the severity (i.e., amount of carbon removed) of the disturbance.
The more frequent disturbances appear in furest systems, the more that is removed, and hence
less carbon is stured on average. Decreasing the interval between disturbances effectively
increases the number of leaks in the bucket. The same effect is true for disturbance severity; the
more severe the disturbance is in directly removing carbon, the less stored on average. Increasing
disturbance severity effectively increases the size of the leaks in the bucket.
The Effects ofNatnral Disturbances versus Harvest
Whether trees killed by fire or wiudstonn are salvaged makes relatively little difference in
carbon storage. Whenever there is a natural disturbance it is often suggested that harvesting
dead trees will release less carbon than letting them decompose naturally. This is based on the
assumption that natural processes will rapidly release carbon and timber harvesting will not.
This assumption is not supported by the likely rates of carbon release from these two processes.
Setting aside the fact that harvest and transport of wood currently requires carbon-based energy,
there is an inevitable release of carbon during the manufacturing and use offorest products.
Depending upon the type of wood product produced, the amount of carbon released during
manufacturing is equal to 25-50"10 of the harvested amount. In many cases harvested forests are
, ,
burned for site preparation, a process that removes approximately 5-10% of the forest's carbon.
Combined with manufacturing losses, this means that timber harvest reduces total forest carbon
stores by 10-25%. When products are in use, their life-span has a wide range from less than
several decades to centuries. This yields a rate ofloss of between I and 10% per year. Wlnle
surprising, these values are not that different for natural disturbances. Consider the amount of
loss during a fire, the natural disturbance that removes the most carbon. A common assumption
is that much of the wood burns in a fire, although if that were true there would be no debates
about salvaging wood. Analysis after fire indicate that, while small material can be totally
consumed, it is rare that harvest sized wood is consumed. Losses from roots and the soil are
minimal. Taking all the carbon stores of a forest into consideration, the range of carbon losses
from fire consumption is probably between 5 and 15%, generally lower than range for timber
harvest and products manufacturing. After the fire, the newly killed trees decompose. For the
US, the range of wood decomposition rates for the size of material harvested is between I and
10% per year. That is very similar to that of forest products! Although all these numbers are
approximate, they do indicate that salvaging fire-killed trees is not substantially better for carbon
storage than simply allowing the trees to decompose, and in certain situations might be
considerably less effective in storing carbon.
Things to Consider: Framing the Analysis of Carbon and Forests
There are a number of general things that should be examined whenever an action regarding
carbon and forests is considered. Unfortunately this has not always been the case.
I. All the relevant carbon stores need to be examined. Many projects are considered from the
point of view of just live carbon. This may be quite natural to do as we have the most data and
understanding of live trees. However, it must be realized that other important carbon stores in
forests do not behave the same as live trees. Dead trees, for example, often reach their highest
store after disturbance, whereas live trees reach their lowest store at that point By only
considering live plants it is highly likely that the rate of forest carbon uptake is overestimated, in
some cases by substantial amounts. A related issue is that the changes in all the carbon pools
need to be considered for a total accounting. For example, harvesting wood does increase stores
in the wood products poo~ but it also decreases stores in the live and dead wood pool in the
forest
2. The starting conditions are key and yet are often ignored. The starting and end points need
to be specified. Often a proposed action gives the end point, but not the starting point This
would be similar to describing a trip by only giving the destination. One will have no idea of the
direction or the distance to be traveled. For example, if one is plamling on establishing a short-
rotation forest plantation on agricultural land, then more carbon will be stored. Establishing the
same type of plantation by converting an old-growth forest will result in a net loss of carbon to
the atmosphere.
3. Our actions to increase carbon stores can take decades to have a positive effect. Not every
action in forests leads to an "instantaneous" response. It takes time to implement policy actions
because the area involved is quite large. This means that the effect of any proposed policy needs
to consider the long-term: many decades to centuries. Once treated forests take many years to
, >
adjust to any action that is imposed. For example, it takes years 10 decades for a planted forest to
establish full photosynthetic capacity. It also takes years to decades for the dead material created
by a disturbance caused by nature or hmnans to decompose away. TIlls means that temporal lags
can be expected in any projected gains. Thus, it may be eventually possible to gain carbon by
converting an older forest to a younger biomass energy plantation, but it may take many decades
or even centuries for this to occur. This is time we do not have.
4. Forests are potentially renewable, but this is not a fixed property of forests. It is generally
assumed that forest related carbon in the form of wood and biofuels are renewable. There is logic
to this in that trees can be harvested and can regrow. Resources that can regrow are potentially
renewable, but a resource is not renewable automatically because it is grows or is a tree. To
determine if a resource is renewable we need to compare the regeneration and removal rate. We
also need to understand that removal of trees can and does affect carbon pools other than trees
and these can decline when trees are harvested. Given we are considering the entire forest carbon
system, this mean that harvesting a renewable resource such as trees leads to an non-renewable
loss elsewhere in the carbon system.
5. Forests are systems that have feedbacks which can strongly influence carbon effects of
actions. For example, increasing the growth rate of trees can lead to higher carbon stores in
forests, but a larger live tree store also means that more plant material will die during the course
of forest growth or harvest. More dead plant material means more losses via decomposition or
combustion if there is a fire or harvest. This means that the gains from increases in forest growth
feedbacks to result in decreased net carbon increases in time. As another example, it has been
stated that forest fire frequency and severity will increase in the future. That may be the case, but
it also should be noted that it is generally difficult tu increase the severity and frequency of fires
for any length of time, in part because more frequent fires eventually lower the fuel level, and
fuel level is related to fire severity.
6. Estimating carbon effects of policies need to look at whole forests over time, not single
stands at a puint in time. The way a forest system behaves depends on how large an area that is
considered and how long a time period it is considered. Perhaps no other issue, termed scale by
ecologists, has lead to so much confusion and frankly wrong-headed notions in terms of forest
carbon management. It is perfectly true that young forests of a certain age do remove more
carbon in a course of a year than an older forest. This would be useful information if forests
never changed their ages. The high rate of uptake of some young forest occurs because even
younger forests have lost carbon. Since one can not have a young forest without have an even
younger forest, comparing the just one year in the life's forest is completely misleading. Recall
that when forests are disturbed by nature or humans the forest initially loses carbon. Over a long
time period forests gain carbon and eventually lose some of it when disturbed again. If the
average carbon stores of a young foresl is compared 10 that of an older forest, then one finds that
the older forest stores a good deal more carbon. Therefore one is unlikely to gain carbon from the
forest site if one converts from an older to a younger forest system. When one considers a small
plot ofIand, the carbon balance seems to moving from losing to gaining to losing carbon over
time. However, when one considers many plots of land that are going through these cycles at
different times, then one sees a relatively steady store of carboo. This is analogous to a bank in
which one person puts in funds and another removes them. As long as there is not a run on the
bank, the amount of funds is relatively constant (at least that is the hope). This is quite relevant in
terms of carbon policy, because small land owners will see boom and bust cycles in their carbon
stores and this may make buying their carbon credits very unappealing. If many smaIl land
owners aggregate their carbon projects, then it is possible for the buyer to see a steady store or
supply of carbon.
Using Forests to Sequester Carbon from the Atmosphere: increase carbou inputs, decease
carbon outputs, or put forest carbon somewbere else
US forests are currently removing carbon from the atmosphere and are likely to remain doing
this for some time, perhaps decades. Eventually, as in all leaky systems, the rate of carbon
removal is likely to slow and eventually cease. At this point the forest will be in rough balance
with the amount coming in about equal to the amount going out This "saturation" behavior is
one reason forests are considered a bridging strategy and not a lasting solution to the problem of
reducing greenhouse gas emissions.
To continue and enhance the removal of carbon by forests, it will be neeessary to take
direct actions. Put simply, to remove more carbon from the atmosphere with forests it will be
necessary to increase the average amount of carbon that forests store or increase the efficiency or
manufacture of wood products and the length of their storage in use. As stated above, the
average carbon store as well as the carbon balance of any forest is controlled by the amount input
via photosynthesis versus the amount lost via respiration (e.g., plants and other organistns such
as decomposers) and the amount lost via combustion. Both the average carbon store and the
carbon balance vary over time, in part, because the factors controlling photosynthesis,
respiration, and combustion vary over time. Therefore it is useful to distinguish between short-
term and relatively minor variations in forest carbon caused by yearly variations in climate
versus those cansed by changes in policy or long-term changes in climate. It is the latter two that
will change the balance and store of carbon in the long-term.
Before presenting the range of possible management options it is worth reminding ourselves
tbat carbon is not the only reason we manage forests. Forests provide humans clean water,
habitat for many animals, plants, and other organistns, harvested goods of all sorts, recreation,
and many intangible benefits. Not all these objectives will be compatible with maximizing
carbon stores in forests. Moreover, there are certain management actions such as thinning certain
forest types (e.g., PonderOsa pine) that may be necessary to maintain these forests despite the fact
that carbon stores will be decreased. We can not be so single minded about carbon that we
create a host of other problems.
There are many proposed steps and multiple viable strategies and that can be taken with regard to
increasing forest carbon. Admittedly this can be confusing for those looking for a "one-size fits
all" approach. On the other hand it does offer flexibility that will allow one to tailor approaches
with specific situations on the ground. Essentially one can increase carbon stores of by
increasing the input to the forest, decreasing the ontput from the forest, putting the earbon
from the forest somewhere else, or some combination of these. The following reviews
specific approaches that have been proposed recently:
. ,
1. Slowing that rate.of deforestation (i.e., the permanent removal of forests) will definitely
slow the release of carbon to the atmosphere. Depending upon the period examined,
deforestation is estimated to have added 20-30% of the increased carbon dioxide in the
atmosphere since the dawn of the industrial revolution. While deforestation for agricultural
purposes is generally low in the US, considerable forest land is being converted to housing and
industrial use, which can have the same effect as deforestation, particularly if clearing is
extensive.
2. Planting new forests is generally a good practice to increase carbon stores, particularly
on lands that once held forest many years ago. Much of our nation's current forest-related
carbon removal from the atmosphere is associated with the reestabIishment of forests in the
eastern US after agricultural abandonment. The best opportunities are on marginal agricultural
lands as the impact on food production is reduced. Planting forests on degraded agricultural land
can increase the store of carbon both above- and belowground (i.e., soils). Forests can also be
reestablished on lands with low stocking of trees after regeneration fuilures. Planting trees on
what have been traditionally grassland systems can lead to reductions in soil carbon stores, in
part because trees do not produce as many dead roots as grasses. Care needs to be taken in
assuring that these losses belowground do not exceed those gained aboveground
3. Biomass energy has the potential to offset fossil foel use and hence reduce carbon release
to the atmosphere under certain conditinns. .However, there are several fuctors that must be
considered before this potential is realized. Biomass energy is not necessarily renewable; it is
only renewable when the resource is allowed to fully regenerate. Forests, by their very long-term
nature, take years to regenerate their biomass and one can not assume that all forest practices
lead to a renewable resource. When using biomass energy, it must be borne in mind that one is
substituting energy and not carbon. Because biomass contains less energy per unit carbon than
fossil fuels, some fossil fuels are required to produce the same amount of energy, and so removal
of one unit of carbon from the forest results in less than one unit of fossil carbon from being
unused or stored. It therefore may take several cycles for carbon benefits to accumulate to the
point that they offset losses in the forest. This is why the carbon benefits of biomass energy can
be delayed if natural forests storing a more carbon are converted to plantations that store less
carbon. This suggests that if biomass energy is to be part of a forest strategy, it is best employed
with afforestation efforts or in forests that are already young. Although it is usually assumed that
fossil fuel use is decreased when biomass energy is used, this is not necessarily true. Given the
lifespan of carbon in the atmosphere, the delay in fossil fuel use has to be substantial to be
effective. Simply delaying the use a few years does little to reduce the rate of overall carbon
emissions. The argument that the increase in fossil fuel related carbon would have been worse
without biomass fuels would have merit if the issue was to just slow the increase in these
releases. However, the issue that confronts us is how to decrease the current release rate of fossil
fuel carbon.
4. Converting older forests to younger forests rarely stores more carbon. Such action
increases the leakiness of the forest bucket (recall major losses discussed above in site
preparation, manufucturing losses, and the increased :frequency of disturbance). An exception is
when a frequent natural disturbance is replaced by a less frequent harvest (which by the way
rarely happens). Another is when an inherently very slowly growmg natural forest is replaced by
,
a much faster growing plantation. That too is fairly rare. Two of the best ways to store more
carbon in forests is to extend the interval between harvests or take less per harvest Basically
both actioDS make the forest bucket less leaky. Depending on the length of the rotation or the
amount of harvest, one can either enhance or reduce the store in forest products. While longer
rotations can lower the average amount that is harvested, the material that is harvested tends to
be more suitable for long-term use and hence may store more as wood products.
5. It is possible to increase forest system carbon stores by increasing the growth rate of
trees. Depending on the forest, this can be achieved by using superior genetic stock, planting
faster growing species, fertilization, irrigation, or speeding the rate of tree regeneration. In most
cases the increases in tree growth do not offset the losses from converting older natural forests,
and in all cases it may take several harvest intervals before gains are fully realized in wood
products stores. Usually the goal of increasing the growth rate of trees is to shorten the interval
between harvests. If this practice is followed, then the gains of carbon ill the forest itself will be
minimaL On the other hand it may result in increased wood products stores, but that depends on
the types of products produced. It should also be noted that thinning of forests does not increase
the rate carbon is added to forests. It does allow the remaining trees to grow faster and become
larger faster, but one must remember that it does this for fewer trees. The claim that thinning
increases forest production is really based on the amount harvested, not the amount of carbon
entering the forest: these are two completely different things.
6. Redncing fuels in forests have few benefits from a carbon storage standpoint. Recently it
has been proposed that reducing fuels in forests would reduce fire.severity to the point that more
carbon would be stored in forests than allowing them to burn untreated. This practice can have
benefits for ecosystem restoration in some forest types (for example, Ponderosa pine), but there
appear to be few benefits from a carbon storage perspective. There are many reasons for this
result First, to reduce fuels one needs to reduce carbon stores, so there would have to be major
changes in fire severity and size to offSet these losses. Second, the difference in the effects of
severity on carbon stores is less dramatic than generally imagined. As indicated above, a very
light fire might results in forest losses on the order of 5% of total carbon in a forest, whereas for
an extremely severe fire these losses might be on the order of 15%. Third, one can not anticipate
where fires will occur, so a large proportion of the forest area needs to be treated. In contrast, a
small proportion of the forest area may burn in the next few decades, which results in more
losses from the treatment than the fires (besr in mind the total effect depends on both the area
involved and the average loss per area). The most likely case where removal of fuels will result
in a long-term carbon benefit would be if, without fuel treatment, the firt; severity increases to
the point that tree regeneration is greatly delayed. However, this regeneration delay has to be
substantial to have much of an effect
7. Forest products do store carbon; whether they actoaUy increase the forest system carbon
stores is a more complicated issue. Given thar the basic material of forest products, wood, is
approximately 50% carbon, harvesting wood and placing it into forest products can definitely
store carbon. However, this gain is at the expense of storing carbon in the forest, and it is
completely possible there will be no net gain in the total forest system carbon stores. Harvest of
wood removes carbon from the forest which means the parts of the forest that depended on that
carbon will decrease in stores. Manufucturing of wood into products results in a loss of carbon as
It'" ,
does the use and disposal of wood products. Overall, the effect of harvesting carbon is to make
the overall furest system leakier. Ifwood products are to be used to store carbon, then the
efficiency of converting wood into long-lived products needs to be increased, and the life-span of
these products needs to he lengthened considerably (see above). There have been proposals to
harvest wood from forests and store it in a location where it can not decompose by burial on land
or sinking it into oceans or lakes. I suppose this would he the "ultimate" wood product in terms
of carbon storage. Assuring that there is no decomposition may prove challenging: wood is
decomposed quite quickly in oceans, for example, organisms such as shipworms readily eat
wood as any naval historian can attest Wood is not the most concentrated form of carbon and the
sheer volume to he stored would likely dwarf those of current landfills and interfere with other
land-uses. Also it may not prove particularly popular. Finally, the harvest of wood causes other
parts of the forest to temporally lose carbon which would introduce time lags into the gains
offered by this scheme.
8. Substitution of wood for more energy intensive materinls has the potential to decrease
fossil fuel carbon releases, but how mueh of this potential will be realized is difficult to
quantify. It has been proposed that substitution of wood for more energy intensive materials will
reduce the rate that fossil fuel carbon is released into the atmosphere. While wood is generally
less energy intensive than many alternative materials, the difference between materials has been
decreasing and not all the energy for these is supplied via fossil fuels. Currently, steel and
concrete utilize three times the energy of wood. However, most buildings are mixtures of wood
and other materials, so the energy savings of a building primarily constructed of wood is 30%
relative to those primarily made of other materials. As noted above, harvest results in the release
of carbon from the forest and while not fossil fuel-related, these losses need to be deducted from
any gains. Many homes aud small commercial building already utilize wood to a high degree. It
is therefure not clear how large the substitution effect can become in the US. Finally, although it
has been stated by some that the substitution related carbon offset never decreases and accrues
each harvest. However, there are reasons to suspect this claim. This would only be true if
wooden buildings lasted forever or the supply of buildings increased without limit It is far more
likely that buildings will have a finite life-span and need to he replaced, which also means
wooden buildings can not increase without limits. Since that is true, then in time harvests are
maintaining the store in-buildings and there is no net gain in this form of carbon offset So
depending on how much carbon is actually offset, this might be part of a bridging strategy.
Concerns
Despite the reality that US forests are currently removing carbon from the atmosphere and the
great potential for forests to playa role in offsetting greenhouse gas emissions, I do have several
concerns.
Liqnidation of forest carbon stores can be the potential uninteuded consequeuce of carbou
policy. To have forest playa greater role than they do currently, we will have to do something
different than business as usual. We must assure that additional carbon is stored due to new
actions, a concept usually called "additionality." Despite the need for this concept, it must be
acknowledged that it means those with practices that have lead to the lowest carbon stores have
the most to benefit from changing their practices. The role of those that have already changed
,. .
pmctices or have always managed in a manner to keep carhon stores high has to be recognized
and encoumged. Little will be gained if the only way to have carbon store increases counted is to
first lower carbon stores. Given the time lags inherent in the forest system, this will be totally
counteIproductive.
Making sure carbon stores are real: the need for a national acconnting. verification, and
monitoring system. We must make sure that any gains in forest carbon stores are real, which
means they will have to be monitored and verified. This needs to be done at two levels. The first
would be at the level of specific projects. The second would be at a national level, which would
involve more than simply adding up all the projects, in part because there will be many forest
areas without carbon projects that need to be considered in the national balance sheet The often
stated claim that methods do not exist to monitor changes in forest carbon is completely puzzling
given that scientists developed these methods decades ago. There are many existing methods
and systems that can be modified to achieve the goal of monitoring and verification. They could
be substantially improved with further investments, but are sufficient to start the process now.
National guidelines or protocols, similar to those developed by California, would greatly aid in
assuring monitoring and verification is trustworthy. At least at the project level, where the goal is
to support a carbon credits market, these protocols can be flexible as long as there are discounts
or deductions for uncertainty about how much additional carbon is being stored. That way the
project managers can decide the tradeoff between the gain in carbon by lowering uncertainty
versus the cost of a more expensive and comprehensive measurement program. It should also be
noted that these estimates of carbon gains need to be conservative, because fuiling to count
stomge will do fur less environmental harm than over-counting. Another possible role for the
govermnent would be to support detailed studies of proposed projects to fully understand the
carbon impacts of the most counnonly proposed projects. While there is a great deal of scientific
research in this realm, it has not generally been of an applied a nature. It is unlikely that all forest
projects will be able to afford detailed measurements of all the carbon pools and processes.
These studies would allow others to more fully anticipate the likely carbon gains and costs of
proposed projects and in fact streamline the verification process because certain practices would
have been proven to work under certain conditions. Finally, it is important that a system be
established to rank the quality of the carbon as opposed to the quantity of carbon. This might be
similar to that used fur mting bonds; however, as we have all just learned to work this system
needs to be independent of those buying and selling carbon credits.
Despite the potential for forests to contribute to the challenge of reducing our nation's
greenhouse gas emissions, I do believe that the forest system's limits have to be fully recognized.
Even if we could double the current mte that forest's are removing atmospheric carbon, it would
amount to approximately 20% of the current fossil fuel release of carbon dioxide. This is quite
important, especially since it can be achieved with largely with today's technology. But clearly
forests can not be used to solve the entire problem.
My greatest concern: with continued warming forests can sWft from being part of the
carbon solution to being part of the carbon problem, Forests cannot continue to accumulate
carbon forever, so it can be part of a bridging strategy, but we need to use the time it buys us
wisely. This brings me to my greatest concern which involves the role forests will play if the
climate continues to warm as projected under a business as usual scenario. If we do not act soon
. ,
to reduce the rate the carbon dioxide and other greenhouse gases are released, we may create a
climate that will make forests start a net release carbon to the atmosphere. This could come about
in several ways, but many of the effects are likely to be caused indirectly by increased drying of
forests. This will mean that wildfires become more extensive and more severe, that insect
outhreaks become more extensive and more severe, and that even trees in so-called
"undisturbed" forests start to die at faster rates. If this starts to happen then the leaks from the
forest carbon system will increase and eventually less will be stored. Not all the carbon will be
released all at once as is often implied, it will happen gradually, but ifforests reach this point
then they will start to contribute to the problem we are trying to solve. Further, it may also
become part of a vicious cycle in which more tree die which releases more carbon which warms
the climate even more which causes more drying, which causes more trees to die, etc. Forests
are not the only part of the natural world that may act in this manner; thawing currently frozen
soils in the north could cause yet another vicious carbon release cycle to begin. To assure that
this does not happen we need to act on a number of fronts and to decrease carbon dioxide and
other greenhouse gas concentrations in the atmosphere as fast as we possibly can.
Summary
Forests are currently storing considerable carbon in the US and are currently offsetting
approximately 10% of the nation's carbon dioxide emissions. Forest systems can be managed in
a wide range of manners to sustain and perhaps even increase their ability to remove carbon from
the atmosphere. Some of the actions being proposed will definitely not store more carbon in
forests, but there are many that will. To assore that forest projects in fact remove atmospheric
carbon, it is essential that the actions conform to rigorous scientific principles, that incrcases of
stores be monitored and verified. Forest systems can be a good share of the nation's solution to
decreasing the accumulation of carbon dioxide in the atmosphere, but they can not be used alone.
It is highly likely tllllt unless other steps are taken that the positive role that forest could play will
become diminished and even switch to a negative one. We must also make sure that actions
taken to increase the role of forest as carbon stores does not create other problems in teons of
what we expect forests to do for us.
Permanent Address: bttp:/1www.scleufIO'....I~m1art1"'" .......?id=wood.burnlng-power-plants-
earbon-neutnIJ..hJgh-e
Wood.BumiIIg Power J>lants-.Carbou-NeutraI or HIgh Carbon Rm_~1
Environmental groups are pressing the EPA to backtrack on its plans to exempt biomass from climale
regulations, arguing that such a step would spark an uptick in unregulsted carbon emissions
By Dilla Fine Maron and C1imateWire rWednesday, April 6, 2011111
Image: CuJifornia Energy Ccmmissiol)
ADVERTISEMENT
Environmental groups yesterday pI ed U.s, ErA to backtrack on its plans to exempt biomass
from climate regulations for the next three years, arguing that such a step would prompt more
fuel switching to biomass and spar.k an uptick in unregulated carbon emissions.
The Natural Resources DefenseCouncil and Southern Environmental Law Center (SELC)
opposed a proposed rule from ErA thatwou1d allow facilities burnlngwoodywaste, landfills and
ethanol fio"um- to be exempt from carbon regulations for the IIeld: three years.
The proposal would .provide incentives to fuel switch. in order to avoid cIiIIlate regulations, said
Navis Bermude:t, deputy legislative director for SELC. The exemption would leave these emitters
unregulated, and could result in higher greenhonse gas emissions than using coaJ, she said at a
public hearing on the rule, echoing the sentiments of several other environmental organizations
that spoke.
At the heart of the matter is a controversy over carbon accounting and the length of time required
to replenish carbon reservoirs.
_1,
6...
f' .,
Past federal regulations have accepted the premise that facilities fueled by woody waste are
"carbon-neutral" - merely speeding up the carbon cycle that would naturalIy occur as plants
decompose.
But a study commissioned by Massachusetts last year and conducted by the Manomet Center for
Conservation Sciences indicated that bornlng wood for energy generalIy results in greater
emissions of greenhouse gases per unit of energy than ualng fossil fuel, based on the efficiency of
tapping each resource.
The study rested on a number of caveats -including geographic area, how forestlands are
managed and if tree refuse or entire trees were utilized, but its results suggested that moving from
coal plants to biomass could actoally booat Massachusetts' carbon emissions in the next aeveral
dllCQdes (Climate Wire, July 12, 2010).
That finding has been a touchstone for environmentalists concerned that the carbon footprint of
such plants is not being addressed.
EP A contends that providing a three-year deferral on the issue will allow it to perform scientific
analysis considering to what extent - if at all - these emitters should be included in regulations.
Some in industIy worry about uncertainty
The agency will examine the science around biogenic carbon dioxide emissions and develop a
rulemaklng on how these emissions should be accounted for in future permitting requirements, it
said in the proposed rule. The agency is accepting comments on the issue through May 5.
'. ~
Biomass advocates including the National Alliance of Forest Owners (NAFO) and the Biomass
Power AssocIation yesterday baRed EPA's decision to study the matter and reiterated that cllmate
regulations that kicked into effect in Jan11llIY and affect large statiomny sources should not apply
to them.
Support for biomass as a renewable enezgy source would be undermined by considering it a
carbon polluter, said Dave Tenny, president ofNAFO.
Tenny, whose group originally asked EP A for the exemption. argued that it would be impossible
to measure how woody waste would be used if it were not used in biomass facilities; thus any
calculations could not fully settle questions of carbon accounting.
Meanwhile, Bob Cleaves, president and CEO of the Biomass Power AssocIation, urged the agency
to move faster than the proposed 1:hrre-year timeline on its final decision to exclnde biomass - in
orderto provide JI1arket certainty forpotential biomass investors, he said. "DeJays willcause
regulatory uncertainty and economic harm in areas of the nation that continue to suffer from high
unemployment and anemic economic growth,. he said in prepared remarlm.
The hearlngcomes on the heels of an announcement last week from Domioion Vhginla Power
that it expects to CQnvert three of its VJrglnia coal-fired plants to run on biomass.
Domioion would have ri10ved forward with its fuel-switcbingplans regardless of whether EPA
granted the 1:hrre-year delay request, Dominion spokesman Jim Norvelle said in an emafi. The
company expects its biomass plants wDl be online by 2013 if its plans are approved, and said the
facilities would help the company meet VJrglnia's voluntary renewable portfolio standard.
r
Biomass advocates including the National.t\Dumce of Forest Owners (NAFO) and the Biomass
Power Association yesterday balled EPA's decision to study the matter and reiterated that climate
regulations that kicked into effect in Jan11lll'Yand affect large stati011lll'Y sources should not apply
to them.
Support for biomass as a renewable enerp.y source would be nn(lP.1'I1tined by considering it a
carbon ponuter, said Dave Tenny, president ofNAFO.
Tenny, whose group originally asked EPA for the exemption, argued that it would be inipossib1e
to measure how woody waste wonld be used ifit were not used in biomass facilities; thus any
""l""IAtions could not folly settle questions of carbon accountiDg.
Meanwhile. Bob Cleaves, president and CEO of the Biomass Power Association, urged the agency
to move faster than the proposed three-year time1ine on its final decision to exclude biomass - in
order to provide market certainty for potential biomass investOl'll, he said. "Delays will cause
regulatory uncertainty and economic harm in areas of the nation that continue to soffer from high
unemployment and anemic economic growth. n he said in prepared remarks.
The healing comes on the heels of an announcement last week from Dominion Virginia Power
that it expects to convert three of its Virginia coal-fired plants to run on biomass.
Dominion would have moved forward with its fue1-switching plans regardless of whether EPA
granted the three-year delay request. Dominion spo1cMTnAn Jini NorveI1e said in an email. The
company expects its biomass plants will be ouline by 2013 if its plans are approved, and said the
facilities would help the company meet Virginia's voluntsry renewable portfolio standard.
.
T AMERICAN
LUNG
. ASSOCIATION.
FIghting for Air
PUBLIC POLICY POSITION
POSITION TITLE:
DATE APPROVED:
Energy
June 11, 2011
Polhlyi'rineipIeon Energy
The use of energy is eSsential to the growth and filnctioning of the U.S. economy and for
the~l;fofJlfe~joyedin the United SfIItes. However, certain l!tIll.\'gy practices, fuel
SOUl'CeSand tet:hnologiesplace II heavy toll on human hea1th and the environment,
impilCtingthe lives ofmilJions of - penple, including those who are most vulnerable to
hlmn. 'rheAmeriea1l. Lung Association believes that protel:tion ofIung health and II
sollndU.S. energypolicy ate compatible goals that require an emphasis on energy
COIllIC1'Vlltin energy efficiency, and the use of cleaner energy resources, imlluding II
traIlsitionfromcoa1 and oil to cleaner alternatives. Our overarching principles ea11 for
the implementation of effective air ql.la1ity progouns and standards, transitioning to II
clean energy future, with II commitment to promote environmental iustice.
PrOll101:ing EffectiVe Air Quality Programs and Standant$
To ensure the protection of human health, the American Lung Association supportS the
rigorous enforcement of air pollution regulatious, and the strengthening of air quality
standards and abatement requirements.
The American Lung Association be.1ieves that all energy production facilities should use
state-of-the-art pollution control technologies to protect public hea1thand the
environment A1I facilities shouldl'l;leet the same rigorous standards of environmental
p.:afulmanee, including both new and .e){isting fuctlities.
Transitioning to II Clean Energy FutUre
The American Lung Association supports state and federal policies that wi1I drive the
deployment of the cleanest and most fud-efficient energy resonrces and technologies.
Such policies should promote the use ofnon-comhn.stion renewable energy, low carbon
:fuels (measured on II Iifecycle basis), eJq)IUlded trsm....illllion and smart grid technologies,
alternative forms of transportation, and energy storage. These progTlllllS and policies may
include financial incentives, fundi"g for research and development, and other meaSllre$ to
accelerate the deployment of alternative energy technologies.
The American Lung Association recognizes that tradeoffs may be inherent in the choice
of alternative energy technologies and the need fur clean, reliable, and cost-effective
1
. ,
energy supplies. The American Lung Association supports steps to m;niTn;7.e the
potential harm to human health inherent in these tradeoffs.
Foeusing on Environmental Justiee
The American Lung Association supports the protection of all people from the harm of
air pollution, especially those who suffer disproportionate exposure from local sources of
emissions. The American Lung Association recognizes that energy and transportation
sources of air pollution are often located near where many people, especially
communities of color or lower income,live and work. The American Lung Association
recognizes that, for many reasons, people in those communities also face a greater burden
of lung disease, making them even more vulnerable to these poIlutants.
The American Lung Association recognizes that many factors have contributed to the
disproportionate levels of exposure in these communities, including missing or weak
limits on emissions, poor enforcement of existing regulations, inadequate monitoring of
pollutants and !imited scientific research. The American Lung Association supports the
formulation, execution and enforcement of health and environmenta11aws and policies to
address these factors, clean up contributing sources and reduee such exposures.
The American Lung Association supports regular, thorough assessments of the impacts to
nearby communities from sources of dangerons air poIluUmts, including highways,
industrial boilers, power plants, and other sources of air pollution. The American Lung
Association supports the aggressive targeting of these sources for cleanup. The American
Lung Association will work to reduce the disproportionate health burdens borne by
economically disadvantaged and politically disenfranchised communities.
Policy Principle on the Electrlclty Sector
The production of electricity in the United States generates a significant share of the
nation's air pollution, threatening the health and lives of millions of people, including
those who are most vulnerable to harm. Coal-fired power plants, in particular, pose a
significant threat to air quality and human health. The American Lung Association
supports strict enforcement of power plant air poIlution regulations to ensure continuous
compliance and the strengthening of abateJnent requirements to ensure the protection of
human health. The American Lung Association supports public policies to mm;mi7.e the
human health, partico1arly lung health, impacts associated with the production of
electricity from fuel extraction to electricity delivery and disposal of wastes. No
com.mm;ty should continue to bear the burden of air pollution levels that harm public
health.
Energy Efficiency and Customer-Sited Energy Resonrees
The American Lung Association supports programs and policies to significantly reduce
demand for energy by increasing the efficiency of U.S. homes and businesses,
strengthening appliance standards, and reducing the energy consumption of consumer
products. The American Lung Association supports programs and policies to encourage
consumers and utility companies to expand investment in energy efficiency and energy
2
conservation measures to reduce air pollution emissions, to reduce household energy
expenses, and to stimulate new economic opportunities and job creation. The American
Lung Association supports programs and policies to encourage energy efficient design
and construction of residential, commercial, and industrial buildings while protecting
indoor air quality. The American Lung Association supports programs and policies to
encourage the development, deployment and integration of clean, non-combustion
alternative technologies in the residential, commercial, and industrial sectors. The
American Lung Association particu!llrly supports the promotion of technologies that
provide energy from non-combustion sources located onsite, such as rooftop solar and
ground source heat pumps.
Coal-based Electricity
The American Lung Association supports the phase out of conventional coal-fired power
plants as the nation transitions to a clean energy future. This includes support for policies
that: (I) require the installation and operation of state-of-the-art air pollution control
technologies and (2) encourage conversion to cleaner energy resources and/or permanent
retirement of coal-fired power plants. The American Lung Association opposes the
construction of new conventional coal-fired power plants. The American Lung
Association believes that the U.S. should not continue to expand its coal-fired generating
capacity because of the extensive scope of health risks associated with the use of coal and
the disproportionate impact on local communities. As part of the transition to a clean
energy future, the American Lung Association supports providing assistance to retrain
coal industry workers and to help impacted communities transition to other economic
opportunities. The American Lung Association supports measures to improve the health
and safety of coal mine workers, and the communities where they live, including
protection from harmfu1 air pollutants.
Advanced CoaI-based Electricity Technologies
The American Lung Association does not support the construction of new advanced coal-
based generating facilities, including carbon capture and sequestration and integrated
gasification combined cycle plants.
Natural G_based Electricity
The American Lung Association supports the increased use of natural gas as a
transitional fuel for the production of electricity, as a cleaner alternative to biomass, coal
and other fossil fuels. The American Lung Association supports public policies requiring
the ins1allation and operation of state-of-the-art pollution control systems at new and
existing natural gas-fired power plants. The American Lung Association supports
programs and policies to protect air, water, and other environmental resources during the
exploration, extraction, production, and transmission of natural gas, including hydraulic
fracturing.
Nuclear Electricity
Before nuclear generating capacity is expanded, the American Lung Association believes
that two key thresholds must be met First, the expansion of capacity must be
3
r ,
economically viable without direct government subsidies. Second, the nnclear :industIy
must demonstrate that it can reduce the continuing risks to safety and the environment
The American Lung Association supports measures to improve the health and safety of
uranium mine workers, and the communities where they live, including protection from
barmfuI air pollutants.
Non..combustion Renewable Eleetrlclty
The American Lung Association supports policies and incentives that will encourage the
development and deployment of clean, renewable energy resources that are not
combustion-based, including, but not limited to, wind, solar and geothermal. The
American Lung Association supports reforms to transmission and dis1nbution policies
that will encourage the expansion and delivery of clean, renewable, non-combustion
energy resources. The American Lung Association supports additional research and
development of advanced technologies that facilitate the expanded use of renewable
energy, including improvements to energy storage capabilities. The American Lung
Association supports improving the efficiency and output of existing hydroelectric power
facilities.
Biomass Combustion for Electricity
The American Lung Association does not support biomass combustion for electricity
production, a category that includes wood, wood products, agriculturaI residues or forest
wastes, and potentially highly toxic feedstocks, such as construction and demolition
waste. Ifbiomass is combusted, state-of-the-art pollution controls must be required.
Electricity from Waste
The American Lung Association does not support incineration of municipal solid waste
or other waste for electricity production. The American Lung Associa1ion supports
programs and policies to rednce the health and environmental impacts associated with
refuse disposa1 by: first, redncing the use of materials in production, pal'latging and
porchasing; second, reusing materials whenever posslble; and third, recycling or
composting as mnch of the rema;nder as pomble. The American Lung Associa1ion urges
the use of safe non-combustion aIterna1ives to dispose of a1l rem,,;n;ng waste. If waste
materia1s are combusted, state-of-the-art pollution controls must be required. The
American Lung Association supports the safe control of emissions from landfills and
composting facilities, and recommends that only clean vehicles, equipment, and vessels
be used transporting and managing solid waste materia1s.
Emissions Trading
Emissions trading and averaging can create disproportionate impacts on local
communities. The American Lung Association favors a transition to enforceable
pollution rednc1ion obligations for a1l facilities.
4
Policy Principle on the Residential, Commereial, and Industrial Sectors
The combustion of fossil fuels and biomass in the residential, commercial and industrial
sectors in the United StateS generates a significant share of the nation's air pollution,
tbreat""i1)g the health and lives of millions of people, including those who are most
vuJnerable to harm. The American Lung Association supports public policies to
mm;m;.'.e the lmman health, particularly lung health, impacts associated with the
production of heat for residential, commercial, and industrial use, including impacts from
fuel extraction to the disposal of wastes. The American Lung Association supports
regulation and enforcement to protect the air, water and other environmental resources
during the exploration, extraction, production and trHn"",i!l.<non of natoraI gas, propane,
and oil. The American Lung Association supports programs and policies to assist
communities and individuals to reduce their exposure to indoor and outdoor air pollutants
and to reduce their energy use.
Residential and Commercial Fuel Combustion
The American Lung Association supports programs and policies to encourage a transition
from coal, oil, and biomass use in the residential and commercial sectors to cleaner
alternatives. The American Lung Association supports the expanded use of natoraI gas,
and propane where natoraI gas is not available, fur heating residential and commercial
buildings, as a less polluting alternative to oil and other fossil fuels. The American Lung
Association supports effurts to expand and trurinmin inftasIroctore for natoraI gas
tr"'..:mi....;on and distribution. The American Lung Association opposes the use of
unvented heating appliances and stoves in homes and businesses because of the dangers
to human health indoors. The American Lung Association supports programs and
policies to reduce the sulfur content of heating oil, including the use ofbiofuel blends.
Residential Wood and Other Biomass Combustion
The American Llmg Association recognizes that pollution from the combustion of wood
and other biomass sources poses a significant threat to human health, and supports
Dleasures to transition away from using these products for heat production. The
American Lung Association caIls for effective enforcement of existing laws and
regulations governing the combustion of wood and other biomass sources, as well as the
expanded regulation of air pollution emissions from these sources. In particular, the
American Lung Association caIls on the U.S. Environmental Protection Agency to
significantIy strengthen its woodstove certification standards. The American Lung
Association encourages individuals to avoid burning wood in homes where less polluting
alternatives are available, and supports programs to replace residential woodstove with
cleaner heating options, particularly for low-income persons. The American Lung
Association strongly opposes the combustion of wood and other biomass sources at
schools and institutions with'vuJnerable populations. The American Lung Association
strongly opposes the use of outdoor wood-fired boilers for heating and other purposes,
and supports measores to greatly reduce emissions from or eliminate outdoor wood-fired
boilers. The American Lung Association recommends continuing research on the health
5
. ,
effects ofbuming wood and other biomass somces, and the technologies to reduce the
emissions associated with the combustion of these fuels.
IndU5trial Fuel Combustion
The American Lung Association ."ppuils public policies requiring the inl<fllllRtion and
openU:ion of state-of-the-art air pollution control systems at new w.d existing industrial
facilities, such as pulp mills, steel mills, and manufacturing facilities. The American
Lung Association strongly supports policies that encourage a transition from coal, oil,
and biomass use in the industrial sector to cleaner alternatives. If conversion in the short-
term is not possible, the American Lung Association supports public policies that require
the installation of state-of-the-art air pollution control systems, and on-going measures to
ensure strong enforcement and continuous compliance.
Policy PrInciple on the Transportation Sector
The tranBportation sector in the United States generates a significant share of the nation's
air pollution, threatening the health and lives of millions of people, including those who
are most vulnerable to banD. The American Lung Association supports measures to
significant1y reduce the air pollution cansed by cars, trucks" and other mobile somces.
The American Lung Association supports regulation and enforcement to protect the air,
water and other environmental resomces during the exploration, extraction, production
and transmission of tnmsportation fuels.
The American Lung Association supports programs and policies to assist communities
and individuals to reduce their exposure to mobile-somce air pollutants. The American
Lung Association recognizes that many communities and workers are disproportionately
exposed to emissions from tranBportation somces, at least in part becanse they live and
work on or near these somces.
The American Lung Association supports stringent. technology-forcing measures to
reduce emissions from mobile somces through the use of: (1) advanced low- or zero-
emission vehicle technology; (2) low-polluting alternative fuels; and (3) pollution control
equipment and efficiency measures to further reduce emissions from existing vehicles.
The American Lung Association supports reducing the suIfur levels in all gasoline,
diesel, aviation, and marine fuels, and toxic air pollutants from all mobile somces.
The American Lung Association supports improved federal, state and local policies,
planning and fimding measures that reduce mobile-somce emissions through sustainable
conununity planning and development The American Lung Association supports
programs to reduce transportation energy use and to provide greater tranBportation
alternatives.
Cars, Trucks. and SUYs
The American Lung Association supports a strengthening of the federal tailpipe
emissions standards and federal fuel economy standards for Iight-duty cars and trucks to
reduce conventional air pOllution and greenhouse gas emissions. The American Lung
6
,
Association also supports California's ability to adopt stricter pollution regulations for
light-duty vehicles and fuels, and supports the right of other states to adopt California
standards. The American Lung Association supports vehicle inspection and maintenance
programs and anti-idling programs to ensure low emissions throughout the vehicle life.
Heavy-Duty Vehicles and Equipment
The American Lung Association supports strengthening emissions standards for on-road
and non-road heavy-duty engines and fuels including those used in trucks; construction,
agricn1tural, and industrial equipment; and rail and marine applications. The American
Lung Association supports establishing stringent greenhouse gas and fuel efficiency
standards for heavy-duty vehicles. The American Lung Association supports vehicle
inspection and maintenance programs for heavy-duty diesel vehicles to ensure low
emissions throughout the vehicle life. To reduce the impact of in-use heavy-duty vehicle
and engines, the American Lung Association supports measures to reduce or eliminRtp,
engine idling, including school system anti-idling policies, truck-stop and port
electrification, and the use of auxiliary power units to supply overnight heating, cooling,
and other driver anlenities fur sIeeper-cab equipped long haul trucks.
The American Lung Association supports programS and measures to reduce emissions
from the existing fleet of on-road and non-road heavy-duty vehicles and engines. Such
programs and measures include (1) requirements that publica1ly-funded projects mandate
that all diesel construction equipment be retrofit with the best available technology to
reduce particulate emissions; (2) continued funding and implementation of EP A's Diesel
Emission Reduction Program; and (3) incentives to accelerate fleet turnover.
Transportation Alternatives
The American Lung Association supports efforts by state, regional, and local
govermnents to reduce our dependence on the automobile, while expanding access to
local goods, services and employment and improving public health. This includes
support for and increased access to public transit, pedestrian-friendly community
development, and expanded opportunities for walking and biking. The American Lung
Association recognizes that transportation needs may be different for urban, suburban and
roral areas.
Transportation Funding and Planning
The American Lung Association supports increased public funding for programs that
reduce air pollution emissions from transportation sources including support for public
transit, intercity rail, and other non-highway modes of transport. The American Lung
Association encourages Congress to develop a consistent funding mechani"", for these
critical investments. The American Lung Association supports the development of a
national transportation policy ftamework to guide investment decisions that includes
performance mefrics supporting sustainable communities. Such performance metrics
should (1) integrate transportation investment, land-use planning, and air pollution
reduction efforts, and (2) encourage development ofhea1thier, more compact, mixed-use
communities that support accessible and affordable transportation alternatives for
7
. ,
residents of all income levels. This framework must also include the fair treatment and
meaningful community involvement of all people with respect to the development,
implementation and enforcement of any impacts reIated to transportation planning and
policy to ensme everyone enjoys the same degree of protection from environmental and
health hazards and equal access to the decision-making process to have a healthy
environment in which to live, learn and work.
Bio-fuels for Transportation
The American Lung Association supports the increased use ofbio-fuels for transportation
if such fuels are produced from sources, and using methods, which result in a significant
net reduction in lifecycle emissions of air ponutants and carbon dioxide compared to
petrolenm fuels. The American Lung Association does not support increased use of
broadly available mid-range gasoline-ethanol blends (greater than 10 percent and less
than 85 percent ethanol) until such blends are proven to result in no net increase in air
pollutants and cause no damage to emission control systems on older in-use vehicles..
The American Lung Association believes that U.S. farm policies and transportation
policies should be aligned to encourage bio-fuels development using sources that will
provide the greatest net air quality benefit while not jeopardizing food resources.
Ethanol in Reformulated Gasoline
The American Lung Association supports the use of ethanol in reformulated gasoline to
redoce emissions from transportation sources. However, the American Lung Association
opposes increasing the allowable ethanol content in gasoline beyond ten percent, except
for specially designated Flex-Fueled Vehicles. The American Lung Association believes
th!If: air quality and public health may be harmed by the increased use of mid-range
blends of ethanol in vehicles and engines that are not designed to use such fuels. The
American Lung Association urges research and testing to ensme that these blends are
compatible with the emissions control systems used on older in-use vehicles and other
gasoline-powered engines. The American Lung Association urges EPA to adopt and
enforce stringent and effective regulations to prevent mistaken or inappropriate fueling of
vehicles and equipment not designed for such fuel
Flex-Fueled Vehicles
The American Lung supports the use ofESS, a blend of85 percent ethanol and 15
percent gasoline, for flex-fueled vehicles specifically designed to operate on this fuel
E85 vehicles are required to meet the Slime tailpipe emissions standards as other light
duty vehicles;"however, when using E85, E85 vehicles may have lower emissions of
some pollutants than gasoline- fueled vehicles. The American Lung Association supports
federal incentives for the purchase of E85 flex-fuel vehicles if and only if these incentives
require the use ofE85.
8
.
Mvanced Vehicle, Engines, and Fuels
The Amlltican Lung Association supports public andptivate sector incentiv. and
investrnertts for the researcb, development and demQDStrlItion of teclmologies that reduce
public health impacts from the tral'!SpOrtation sector lllId lead to broadly available and
affordable vehicles, equipment and. ib.eis with fewer Iifooycle emissions of air pollutants,
includingwcenhouse gases. Such technologies inclu$1Jut are. not limited to advanced
bl\tteries. elc:etrie vehicles and advat1ted biofuels. The American Lung AssociatiOIi
supportS more stringent controls on air emissionstrom electricitY production, and in
pm:tiQUiar the phase out on ooa1-fired generation to enable electricvehieles used across
the country to contribute to overall reductions in air emissions.
Marine and AiI'l:l'aft Engines
The American Lung Assoeiatjon supportS the. EPA request to the Intemational Maritime
Organi?atiOIi to liesignate U.S. coastal waters as an Emissions Control Area. The
American Lung AssoeiatiOIi encourages EPA to n.tiate morestDngeni emissions 1imits
and fuel requirements for aU ocean-going vessels regardless of national flag, to be
lmp!eml3nt<:<J at the earliest possible date, and to include meanirlgfu1eontrols on
emissions from these vesSels. The.AmeriCan Lung Association8\!Pports emissions
requirements for aircraft that are comparable in stringency to other mobile SOunre
emissionsst<mdards and supportS measures, including regulation, to reduce aviation
emissions. The American Lung Association encourages the phase-out oflead itJ. aviation
gasoline, and reductions in the su1fu:r content of aviation fuels.
For more information on 'these poDcles, see these resoun:es:
EnerllY Overview Document
Electricity Generation Backl!TOund Document
Heating Bacwoull.d Document
Transoorllltion Backl!;I"ClUnd Document
9
.
CCJ
.
>
..c
> >-
+-' Vi
+-' .- Q)
Vi +-'
.- ~ +-' U
U Q) CIJ C
.- > V'J ro
s.... .- :J .-
+-' ('\.. C ..c -
U (/) => u <C
OJ OJ U) ro >-
- +-' V'J b.O
OJ OJ 4-- Vi ~
s.... ::J ro OJ
s.... +-' f-- ~ c
::J S w
0 t:lO -C: -
ro +-' ro
c:: E 0 ~
+-' C
.- 0
OJ c:: 0 (U
t:lO 0 CO E
s....
::J ~ > c
OJ b
..c ro 0
~ - :2: !t-
.- .-
CO >
"'C ~ !...': C
0 0 UJ
-
::J !t-
o...
0
..c::
V)
V)
E
OJ
OJ
V)
fl...
OJ
~ ro
o~
c.. --
-c-c
c 0
CO 0
....., bO
ro ro
OJ..c
..c u
fl... ::l
~ V)
-c OJ
O~
0-
~
bO
C
--
V)
:::>
c
.-
-c
c
co
-
b.O~
C C
L1.J co
~~
QJ ::)
z..o
co
c
._ tIl
.-
c""C
~ 0
o 0
So~
~ I
tIl ~
CO CO
..cQJ
~>
tile
~e
OM
.....~
..... tIl
o co
~o.
..QQJ
<(-5
.
L-
QJ
..c~
~ .-
CO..c
b.O~
QJ .-
~ ~
~ ~
CO._
..c :::
~E
-g~
o QJ
~ L-
co
..cQJ
~
.- ~
~ 0
~ tIl
co >-
QJ-
..c -
tIl co
::) g
..... -
O~
>-;:,
c u
co""C
~ ~
.
.
C '"'C
o bO ~
..c c co
L..'- Q)
CO~-
U 0 Q)
>- Q) L.. L..
~..cbOQ)
:= ..... Q) -:5
co V)=
L- Q)..c .c
'5 ~ ~ 0
QJ Q) '"'C V)
c(jjQ)..c
L....c co
C Q)L.. ~
o Q) 0 ...,...
..0 L.. V) '""
L- .......c c
co co co co
U bOQ) ~
..... C Q) 0
o .- L.. L..
c..... bO
C L.. Q)
:J..c
o ..c .....
.-
~ '"'C .....
o.CCO
E co-:5
::) bO Q)
tIl C '"'C
tIl E'x
QJCO :J.Q
U'"'C
..cl
I-
.
-
:=QJ
~:2
Q) ~
Q) .-
L..'"'C
.....
~ C
Q)..8
C L..
<([3
I
. .
~-~~
-8"
~"
-'
>
U
e- O)
-
0 U
0 ::J
a. .- -0 +-' +-'
V) - .-
- c: ~ 0 -0 c: V)
re L- 0) 0) .-
0 t:: 0._ L- E ..c:
c: u +-'
e- O CO
0 ....., 0 L- c: c: 0)
e- o. +-' +-' L- ~
e_ V) 0
....., 0) V) ::J 0) CO
re 0 - V) 0) ..a > E
a. ..a CO c: L- 0
c: CO E CO b.O
S- O ~ c: u 0
- V)
0) S- O 0 L- eo -
....... a. 0) .- ..c ~ L- eo
c: c: ..c L- 0) V)
e- O) 0) b.O CO 0) -0 +-'
V) L- U :C~ c:
"'C c:
0) CO .- V) .- 0)
c: c: CO b.O 0) E -
..c: 0) -
re L- == ..c: 0)
....... > ::J >- 0) +-' c: ~
CO ..c +-' L-
- V) .-
re ..c: u V) E 0) V)
~ +-' .- .- >
c: +-' CO L- +-' 0 CO
0 0 CO 0) +-' .- L- 0 c:
..c: u ...'+- bO
L-
e- o. +-' +-' 0) +-' V) 0
....... - - c: .-
re a. V) -0 0) ::J +-' CO +-'
0) V) c: 0.
c: ::J L- L- 0)
+-' CO 0 0) 0) 0. E
V) CO -0 L- E
... +-' +-' 0 ::J
0) V) c: CO CO >- L- V)
....... - CO 0) V) CO ::J V)
- +-' <C 0. LU CO
re <C V) ..c:
.......
V) . . .
.
It-
l.- V)
V') :J e
V') 0 0
.-
m 0) V)
V)
E u .-
:J E
0 "'C 0)
0)
e- O)
..c I.-
- "'C
-
.- >- .-
"I- ~ X
0 ~ 0
.-
...., 0) "'C
V') ra
+-' ..c e l.-
e- ...., 0) :J
"I- 0) e ..... >- V)
Q) - I.-
U aD :J :J ..0
C l.- .- V) U 0
:J 0) l.- . .....
OJ 0 l.- e 0)
..e .- -
..c V) l.- E ra
0) 0) u
e 0
- I.- ~ "'C
0 -
m - e
ra 0 0)
C e 0) - ra ....,
0 0 U V) - ra
0- e 0- e 0)
e_ ...., 0) V) .- l.-
+-' ra "'C V) ra u
e_ e ra I.-
-0 e -
E -
ra 0) "'C 0-
-0 a. 0- ~
V) 0 u
<C 0- 0) o- ra ....,
...., "'C aJ - -
-
. .
.
OJ
E
o (/)
(/) OJ
OJ~
s- (/)
ra c:
OJ S
s- 0
~-o
...., u
.-
:>.s-
- QJ
QJ..c::
...., 0-
ra (/)
c: 0
~ E
-e....,
~ ro
c:
:::::>
Q)
'-
o
EbO
V) C
+J ._
.- C
E '-
Q) ~
+J..c
~-
..c~
....:- U
~ m
+Jc
~ m
Q).r;
C+J
C Q)
0-0
..c .-
,-X+J
m.Q ~
U-o_
+Jco.
o '-
C 0 Q)
V)..c $
.- '- 0
~rlo.
.
c
m
u
+J
~
..c
,>
~..c
~-o
C Q)
.- ..c
E '-
m ~
c..c
.- m
-OQ)
Q) '-
V) Q)
m..c V)
0) 0)
-0) 0 0)
+J '-
'- >+J
.~ '- +J
C ~ C
+J Q)
..8~E
'- U 0)
m m U
U m
0)0)-
.r; ~ 0.
1- m Q)
.-- +J '-
.
.
V)
V) +J
~ C
o 0)
.- c
'- 0
~bOo.
'- c E
0) .Vi 0
.r;~U
bOm-
.- U m
.r; c
.r;mo
U E .-
+J
E~ ~ :.c
V)-O
V) m m
Q) bO-o
U c
~._ c
-o-om
o ~ '-
'- u OJ
o.c~
bO.- m ro
c V) E 0
.- +J U
E ~ 0) V)
~+J+JO)
..c~.!!:!o
- ~
-OQU-O
o 0..- C
o t m
:> .~ m.r;
::::> m c.+-,
.
.
,
V)
-c
QJ
QJ
u
X
QJ
V)
V)
co
E
o >-
-- -
..c c..
L. c..
~ ~
-c
c:
CO
E
QJ
-c
QJ
...c
I-
>-
-
a.
a.
:J
V)
Q)
..c
of-'
"'C
Q)
Q)
u
X
Q)
V)
of-'
C
..!!! L..
o.Q)
>
cu 0
~ V)
&E
V) of-'
V) -
ro ~
E Q)
o >
-- Q)
CO V)
.
(/) C
t 0
0.0
a.L..
.~ rl
Q)C_
a. ~ ro
000
L.. U
:J(/)..c
UJ -~ of-'
V)... .-
ro Cv ~
Q)' U "'C
V) :J 0
L.. "'C 0
o Q)
~ ~L.. ~
10 0 ~
tlO of-' --
_ V) .~
-""""''+-
__ --" I
~ Q) 0
..c U
E of-' >-
~E..c
-- -g e ~
L.. '+- 0
a. "'C -Vi
V) 0 .5!!
.- 0
t= ~ ~
.
.
.
"T1
VI 2: I I I I I I Q
0' !!!.. 0 ~ '" ;.. --i n OJ ::;: !!! rn
m ~ ~ ~:E ~ =to 3' ~ o' ~ ~ fit
'" 5. 0 '" m "'..Q 0- 0- 9, 11) <'-0
lri -< ..... 3 ::J ; C 11) g i\l .;; ~ "'0
QJ r-t' mOQ ..., Q)..., ..., c VI
VI :J"" :J OJ 0 ~ Xj ~ Q) ;:+ ~.
;::;: ro r-t':J 0.. '< .c '< =: '< a.
a.' a.c c Q)~ ro
ore 0 -+I a rn::3 Q) 3
ro VI 0 r-t 0.. ::3
Vlo m::3 OJ:E 0.. ~
-. ..." VI'" r-t -'.c r-t'
..." .... -. - -.
VI VI r-t'::3 0 0.. C "'0
0- r-t' VI 0.. ::3 =: Q) _
ro:J"":J""l'!) rt~ m
n QJ QJ..., _. VI
QJr-t' <0 r-t m
c n m~. -::"<
VlQJ".....O ::3
m , ""'::3 n o'
00- ron c ro
-+10 moo.. VI
r-t' :J :J::3 :;' QJ
:J"" a. o!:l' OQ:J
ro -. VI Q. ::!:l a.
.., ~ .... 0 rr
'" -. .... 0 '"
OQ a. <:. 0..
' m S. :J
o -. n 8 m.
s: VI m ::3 _.
;=:t. VI r-t r-t'
--- 0- -. ..., VI
..Jc :J 0
0= n
-+10. m
m:J' m
~OQ c
r-t' C ,
m "'0 0
, "'0
:JQJ m
VI QJ
:J
.
.
OJ
-.
o
3
OJ
(/)
(/)
o CD
,.... -
::T'CD
CD n
...., ,....
....,
...., -.
o !:!.
...., ,....
CD<
~ :E
(/) =
m -
....,
<
-.
n
m
(/)
n
o
3
"0
ro
,....
ro
:E
-.
,....
::T'
.
.
::J -I n
~~~
r+ ""0 tn
~ Q. ~o
_0 OQ
""0 Q. ~
o ro
=tn
r+
-0 tn
n :::T
tn 0
o C
--n _
OJ a.
::J 0-
< ro
ro a.
::J .,
m _0
., <
OQ m
< ::J
tn 0-
0<
C r+
., :::T
n m
m or
n
r+
tn
OJ
::J
a.
- OQ tn n ;:::+
r+ 0 C 0 ~.
-0 0 0- ., VI
tn ., m
a. -. m
a.ntn
-. r+ tn
m - m
tn < ::J
r+ 0- ~.
:::TmOJ
OJo --n -
r+ ., r+
3 m 0
OQO ~ a.
:::T m 0
r+tng:.
n r+ m
OJ OJ
C ~ n
tn :::T ~
m OJ C"'
3 ::J 0
o a. ::J
_0
., ::J OJ
m OQ n
::T 0 8
~ C C
3 r+ ~
-0
::J
OQ
.
tn
m
tn
tn
m
::J
r+
-.
OJ
-
r+
o
OQ
m
r+,
r+
:::T
m
""0
o
-
-
C
r+
-0
o
::J
a.
OJ
3
OJ
OQ
m
.
r+
::r
OJ
::J
-
r-I-
-.
(J)
o _.
~3
Q-c
..., 0
0-...,
o r-I-
::l ~
Q.r-I-
-. r-I-
o 0
x
c:~
m OJ
OJ 3
::l 5.
Q.m
-0 r-I-
o ::r
=m
~ (J)
-. n
o -.
::l m
::l
n
m
.
.
n <::: - m ....
I I 0 < m OJ ro-br
~< -nV) 3 V) :::s m (I) n 3 n
.v <:: (3 -.:::r -.:::r (I) (I) m::r ::r
n>-.:::r3o 00 C:::r -0 OJo
;:j:' ~ So. 5 So. 30m ...... :::s ......
?" v. 0 a. .-+ a.. u c: ~ c: a. 0
::;:. g ~:E ~':E !:!". c:: ~. (I) 0' c:
m M m m ~ m 0 OJ Q. n "
n m (Dn 0 n :::s = r-+OJ 3 a.
=v. nO"OO oo-<:::S om
3 n ~~., ~......m 3,3
n> n> n' -. m -. m '" m OJ
.-+::S _.::s 3::S - OJ .'"
~:E~~O~~~ ~~5-
-<m n.-+ <.-+ r-+OJ 0 m
v. coo ~ 0 ::!.@ c: n 0'
fij v. ~ v. ''V C"' Q. , ~,
3 m c "0 c DO", n' m_
.-+ 3 m -< --...... ''''
n>-.:::r :E n nr-+ mum
::sn>"O 0 OJ::r n on
a...-+ d: 0 n> c: m r-+ ~ r-+
::;:. 0" g ~ (1Q (I) a. ~. ~ ~.
'" :E 'V I '" m OJ Q..., ::::::
. v '" .-+ · v (I) 3 -a.. .--.-
m~ -.:::r::s -<[OQ<
::s a. ., m OJ III m (I)
s. n> a. @ OQ m:::S m
(33 ~ fij m <' ~<
::s n> OJ a.. r-+ n-' ~ n'
3 (1Q - ::r ..--.- '"
m - !!?. OJ m -"101
mv. n m r-+ o III
::S.-+ ~ n 0 :::s:::s OQ
::00 0" s: c: m ~
o 0 n , c. m
c ::s E n III _
., a. -.... c: oj
-0' -n , ~ r-+
., , -. m
~. 0 m r-+ (I)
a. 3 :::s ::r
m r-+
.
m
-
m
n
t""t
..,
-.
n
-.
t""t
'<
~
-.
t/)
m
-
'<
.-
~
m
m
OJ
n
:::r
:::r
OJ
<
m
OJ
..,
m
t/)
"C
o
~
t/)
-.
c-
-.
-
-.
t""t
'<
t""t
o
c:
t/)
m
.
,
I
L
.
~
.. - ~
~.. ..
.. t?
I-
i,. ,..
,..
'"
'"
~
,..
,...
..
.
I)
""
S_
n
~
Iij~
'Ii:
o
'"
S
:::t
...
-
..
V-
I:::
(",
...;-
.
.
I
I
I
I
i
~ j
i a'
~ 3
:J: c'
g f
~ Ii
to i
g' ~
~ ~
n
:r
i
~
el
~
ii
CD
CD
V1
o
-
OJ
..,
o
(1)
n
OJ
r+
:r
-
o
~
~
3
m
X-
(i)
!!.
~
en
i
::f
~
~
3
or
..
..
'lIon>u:xls '((l!SqllS ~!=M JO
sw"llBd 01 pods"" tp!'" tJ!S1'H r.>A!1l !dd!SS!sS!W ~q~ U! oOfl1llIOO wlloJ;!O J1mU1D:>]JllB JO ~SlOq s;l!J!'Io~P!
:pltp I~pom MJ1KIs B llop= 's:lSllq~ :>Jd9JDW "l~0! O~ SID poon ~!?pom oo~nuad P"'l=BiXI .
q:>>B;JS;J.r araJSJfso3:1 ""CPO
'..""~BS!a lffiJ""O" 'JOq~B P""'I '''JlOS
{llU~BO ~tp ~ SOO!SS!lU" 00<1"10 pm spwmr ~~JO] ~~""P 01 pnPOlllS Jlh~ "1GB"""''''' j1lJ~J B
""pun mo-pJ!IlCl sstmT"!q 00 OO!l1lJ:)S!U!OJPV OO!l1lUJ.tO]OJ,(fu;,U!I "'P mooJ lllBp p;nA{llUB 'dnWD llupjJOiXI
(l'lWWOOJ!AO'fIlF!A\llo!'jJOiXI ..,,'ws P"'!'ln ~lIJ ll! ,no-pl!Oq SSBWO!qJO SlOEdtur 00,!,1O PO" I=Oil .
'S:>JlOs ~m""JJ!P ~B =!o.td """'00 SSBWO!q JO] oO!l1lJ:l~nOO= ooqm) o~ =!I
pm soo!Ss~ 00'1= (1ffil:l1l "l1ni1!l~ 01 ppom B podo~a 'srS.\{llUB '''o!"~ ooqJlO ,~!] ssmIlO!8 .
"~u;l ssmIlorq :>J1OS-a\l:nlJ wo:g Sl>Wmr 00 lllJ!so:>o.J 'b!]OO ,~ !=P"J pm
:>>lllS U! bmoo= JOJ ~~B:>OApB pm su~snq:l1lSs"N U! k>!]OO ,(fu;,m ~J1l JO S!"'1{llUB p;>SBq-O)mps
~J>!AOJd '(ll.ro'~~wo",!"mSSBW'A\A\A\) ~:lUll!JIV .rnr..ojJ Jl'lu;lWO"'!"U!I su~snlf.l'l'SS1lW: ~tp JO
>oponO] SV 'suosntp.SS"N OJ J,,,,ad SSlruJo!,! JO srs.lJ1lO" s:p.d1Il! StJr-um IS<lJOj PO" -OO!lnuod J!" 'OOljJ":) .
lIHiX10d SSVW0l8 dO SJ.:)ViIWI NO SISA.'lVNV ONV lDlIVHSHlI
'moz-lOOZ
'A:rOlBJOCJ1"l J1l>Flo]O!9. ""!JI'I"l ~loH SPOOiXI'r.l:lw::l =s.lSO)jJ "",o'ps mo,s:i\so:>'fl OJ A\OIPill""o.poP'SOd
'SOOZ~OOZ 'JJ!S"""rnn B!'JWOJo:) '''ltU!lsoI tpJ"3 'ttL ',ilmqBO!",SUs OJ "'O[J'i11"",v-IJVl',,,ud
'900Z4iOOZ 'Ja O~qsBA\ 'dnOJ~llo!'jJoA\ Jl'lo~orooJ!AU!I "S!Jmps JO!O"S
'LOOZ-900Z 'm(S1l(V 's>JmqJ!1lil '>jJOA\l'N '!I:>:lV ""r=s 'lJ.d {llUo!lBN '1 I -S~ 'sflloIO:T.> J1l"'~=~
'~=""d 01 LOOZ VYi! ':11=""1 ,?sooOJ )~S "'.pussy tpJ=U
'SOOZ '~mWPBOOa oO'!l"'\J:lSOOJ ~SJOqwy JO UA\O~ .,.pussy tpJ=U
'600Z J:lq=I@S OJ SOOZ "JDf 'oau!=OJ A:rOS!"PY smZ!ll:) "Iddns J"lBiXI 'J<>I:T.>J!G ",,~=XjJ
'600z '''''''''!IIV ,(fu;,U!I JIll="'!"U!I SUOSOtpTlS""N """J1lOV JOmos pm ""punoil
A.1I0.LSIH 'lVNOISSHdOUcI.LNw.>HlI
L861 'sll:>snq)BSS"N ':ISJOqmy 'SUOSUtpBSSllJ"l JO il!="!On 'eplltr] 11/I1:; 'MlOJodo.npuy 'Va
.661 'SUOSOq'JTlSS"N ':IS:r:llIIllY 'SUOSOq'JBSS"N JO ~n 'MlOJOJa ~U1lJd "VW
'I00Z '1]1lln 'trellcYJ '~"rnn "llllS qllln 'Aaoyoog "<flld
NOuV:>nOa
SO'!lm>~ SSBOJ"!lj wo:g suo~ JmJUllOO J!" snop=q pon ~1llUIlOO B!J"l!J' JO ~{llUB .
S!"'({llUB JJmCJ1'l!1lAB SPll.J SSBWO!,! .
00'!l=w2 =\00 SSBOJO!q WO'!) so~ "P!XOJP ooqJlO J~o ~lJ!lllJ'>l~p OJ ~{llUB apb~J!1 .
OJ llu~s ~S!lll:lpS W"ls.ls~ pm Is.l{llUB ,rn""U!I
H'IIdOUcI 'lVNOISSHdOlIcI
WO)'J!l'Wll@tpooq=s',Unm 'l!=
.LSZ-S88 !.L 16) "'1!'!oW . ZOOlO VYi! 'ureqpd 'PU Plomy tS
HLoog .LlIVf1LS AlIVW
(f?)
.---'
..
z
'GOO?: O. f!Jdy 'JJ!Cl.illJ= u""p :mlOH ''I' U!'~ SS1lUloN
JOj ~ =wpu,ure op,u..l!I JO uo!-ldopu OJowood 01 JO U~Sll4\ U! ""lO nllof mrwss,JlluoJ OJ.
'6OOZ' 'f:?: >un f 'ssumO!q "JlOS-olI.rer JO SUOplO!JdW! ~ro pm pmrw,p
P11J uo "044!=U03 "UO!'!A s;un:rtlil 4S"JOil" uO!-l=lI J'll1' uO!JllAJOSuOJ jO =WJJUd"o Sl1:mlq3'"'SllW: OJ.
'GOO?: 'liZ ,unf '"Vw 'pJ;l!J=~ 'Jtm(d .r;u"U'iI "lqu"",U"lJ: =u"!d JO suoplO!JdtlJ!
:>sn J04"" puu uoptl[[OO J!S uo PJOOII ~ S4WmtJJ;lAOt) JO jpunOJ I"UoFl"l1 ,bunoJ U!J'l1l1Uil OJ.
'6OOZ' '8(; >unf "V!lNb.\ 'S4300tlJ!"A\Od SS1lUltJ!q uo "Sn:lOcl" UO ~UT 0!PU1{
600<: 'u
AJU f 'SS1lUlO!,! 'j1OS-;>\l;relJO S4300tlJ! uO!lUnOO J!S J'll1' ~ J=Oj uo 'P=\I quO llm!S S44"suq3usSllW: oJ.
'GOO?: '~ JdqwOJd;>s 'S4300W! uopnnod
"!" ssumO!q uo 'AJ"P"S JlO!P"N S44:mlq3ussuN''P JO =!=UOJ 'I'JI"H j1llUdWUOJ!AITg: puu I"UO!Jooro3Q oJ.
"6OOZ' '8<: JdqwOJd;,s "SI300tlJ! JdA\Od SS1lUlO!q uo '"ptm(lluH ""'N smoil" 'Ul1lJlluJd l1Jcl4\ uo ~U! 0!PU1{
'600?:'L
J:>qo.pO 'pl"ElW"Jt) U! ,sn J041lA\ J'll1' S43Wtm uO!JUnOO J!1' Itm(d ssumo!,! uo ''PJI'''H JO PJUog PI"Elu"""t) oJ.
'600?: '6?: J:>qoPO iI!'J .r;u"w j1ll"l"'J
U! posodoro SS1lUl<l!q JO S43WtlJ! llO!JJn:lI=oJ ssmsp OJ :>a uOJllu!'jSU4\ U! JJU4s ~I JOJUWS 'P!'" 5O!J""N
'600Z" '6 JdqW;>AON 'uo~pood
"""'00 SS1lUlO!q JO S4:>1TdtlJ! uo 'uOlSO!] 'sJooll(S!ll;>l ""ll'o JO JJU4s pm lOOqu"SOl1 UU4S JOJw:>s "llllS olllug"!"!]
'GOO?: '81 J:>q=AoN "Pl"!J:l,,!ros U!
,m:."ug: "l'l"o.'''Wl1 JdWjl1dJo S43WtlJ! uopUUOO J!" uo llO!J""w 3!Jqud :JPuuOJ qlJl"'H 3!Jqud PJ3gllupdS oJ.
"GOO?: '?: J:>q="O 'pF'!J5tf!JdS "! .r;u"U'iI "lq=U"lJ: Jdmp'd JOj,~
suo!'SJlU" J!1' uo l/upI<lq uO!J=l1 pm UOPllAJOSuOJ jO ,wt.lT!Jl!d>O m:>smpllSsllJ'i! IS AUOlU!l"'J 3!Jqud
'600Z" 'I- ""qUT;}~O
"SS1lUTO!q "j1OS-albllj 1Stf!1lllu uoptljos,J JO 1300dns U! P""'Eo AUOlU!lSdJ ,{j:>pos J1O!P"N S44dSUq3USSllW: oJ.
"6OOZ' '51 J:>q=O 'Pl"gl/tf!JdS
"! JtJlljd A:J;gU'iI "jq"""'U"lJ: JdWjl1d posodoJd JO sPU<!ttf! uopnnod J!S uo 'u:>UII~I"SJO pnog A\OlP"'I oJ.
OIO?:. '\Jtm1J1lf'vw 'pPEI=~ ',,"3psnfljl!4\ sqof" dnOJ:l A3lOOo.pS Joqllj"oJ.
OW?: 'II f!Jdy
'qnO =!S "'P JO '("!JJllJ'>J'i! ,(uf 'P!'" '~ a:.pwg ,u "3U=JUOJ uO!l3V j1llu"wuOJ!Aug: 'uo!,",," P"lTAUJ
OIOZ" '51 j!Jdy '''pup,,! 'J,=p
pm 'soap ""lJI1A =uO!d "'I' JOJ "=11J,(fu.,oo U1QP U JU'jA\ uo 'VJ'i! 'I=qwy 's.:J"lOA wwo.4\Jo "nllSO-J oJ.
OW?: 'I?: (!Jdy .LA 'o:JOUOJ u~ JU UJtl!llbono.J ssuw"!lI "ISUp1lJlJ:r;>pun 01 uoPlllOOSOJd
OIOZ" '8 "unf'JO 'u0Jllti!qsu4\ iI!'J
,Ill""oo ""'P"N-Umnx1l4\ "! Jno-PJ!Itq SSUWo.!qJo suop1O!Jdw!:ltf!""'fA:>:I 'ElliS tmDXllA\ AJooH Ol uOPlll=d
OIOZ" '?:l: "unf'''!PU1{ ,UOqlp.nlg: 'WUljSAA\ "nllduO llJ!'" ""'fAJ"lU! 0!PU1{
OW?: "'{Ilf
'mq ,~ =q"n-Jn")l JO suO!llO!Jd",! ,no-P(!Ilq SSUWO!q uo S03!1jO "lw;,s ,J'!p{llW OJ 'P!'" s50!J""N
mOZ" '9 "JUf 'suo!,SJlU" UoqJU3
pus llu!pro ,=o.J JOj ,no-PJ!Itq ssumo!,! JO SUO!JU3!JdtlJ! uo 'J:>llu!,PJU"S tm..L 'P!'" V dg: 0.1 uoPlllOOSdJd
OW?: '''I '({Ilf'""nlloI"!O ItJlUdtUuOJ!Aug: s,-'!'>N ':T[oN q01{ 'P!.... "",!AJ04U! ~
mo?: 'H J:>qw;ncl:>s '='!F>IJ!o.ll AJmqtmpTlsns lIt'!'JS'lAMI JJ1UP AN
ssrosp Ol '~ tm..L 'P!'" 'BllIs uO!JUAJ:>SUOJ j1llUdWUOJ!AUg: JO 1=uW"O '1JO A ""'N 'PIA' ~N
SNOUV.LN3SlIl1d
'""4\ U!tJluno=nq "'], U! ",llm,p PAdI
-:>dlOSpullj pm 'uo!J!"OOwro AJ!'JIlwwro JUlljd uo Sjo:QUo:> 's"sSdJOJd Jll!q=f'U ITo.s lltJ!SS"SSll 'sm"lsAs=
ljtJln UJ:>qlJo.N "! ":>mM :>!BolO"?Alj pm lluyp.b uo:JO.Jl!" !!Os uo s:P"JJ" SSUJ:J plUum OA!SUAtJ! uo ApttlS
ho.JllJoqllj pm PI"EI U p04:>npuoJ :UO~ w",,,,tsw,, uo S43"E" ""pads OA!SSAIT! uo lPJSO= ~s-PJUN .
"S1tI"lsAsO~ ssonu "'JIlJ lluyp.b uollOJl!" ITos uo syO.Jluo.:> "Z!-IOJ:>~ Ol S:lddud p>ljS!Jqnd
001 wOOJ Ulup lltf!z!;muwns ""'TA"" "!l"'PuAs S POJ:>npuOJ ~u!J:>b u;;"itOJl!" uo. Slo.Jjuo:> JO "!S.\pmU-llI"N .
" .!
E
'SVC:-OtC::~ :nr.>WU<>>!""H aql ptJ1l .lllo!OYzl tl! S.1"JluOJd "ph ~!ll ""'Oj~
~U]llump s JO 8P:>JJa 'll""'lJ tJ1lUJllH ',001: "JI0,1\ "V ptJ1l 'trffJ8:J"1 V 1"1 '.l=">I' <I '0 'PU"IIOH V 'H
'tJ!alSc!g <I 'd 'uosqO(I 'd 'V 'allumoJ ')l 'S 'ptI1l'(aAat) 'J J 'tpoog 'S '}II'tPJ1l4'OH '/A <I '<I 'V 'puaStlA\O~
'Bv-9f:: 16 AllOJOYt[ JO Jl'lUll0[ 'S"!U'uudP uOlMallaA ptJ1l 'U!I!lJ!Sl'Atl! .u!UUWUJo~ JOJ suo!l~HdlD!
:sapads 1J!S1'1I =~ ='ll "! asn a~mosaJ ~dd8JJ:>A() ',OOC: '>IJ8lS 1"I'fpm iF>&PI1lJ 1"I'N "s 1"1 'tpoog
1)\:\:- ~ 1\::99 ~l.f.lO'lllo!H 'UJ~sdsroa adools-qUJljS lJ8lD uJatI1JOU U "! Sf!Os poUltl!WDp-(1l!UU'lT.ld
ptJ1l 'J1ltIUtJ1l "! .umc.1lf!1'AU pus =0= N ~~our ',OOC: 1P^'P11lJ 'N 1"1 puu ,>!rns 1"1 'f"s 'N 'tpoog
'LS'1S,~ :SL sqd~uo}ll '(1O!ll"I0~ '1ll8p aJUlllJ~!IJo SlS^J1ltIu ~!I"lllU.(s" :S=lsdSO~
!l'fU=~ "! S<llllJ ~h ~Jl!ll ssOJ\l uo SJOJlUO:) 'SOO<: 'J~lS"ll "H pus '>!J1lls 1"1'[ "s 1"1 'tpoog
'S J'S'6Be: J!OS pmlU8Jd 'Sf!Os lSOJOJ "! uO!ldmnsuo~
ptJ1l uo~opood ~!U8lb0tJ! uo =l1a lluJX!lD I!OS '9001: '900C: 'lJ8H 's pm ,>!ms 1"1'[ "S1"I 'tpoog
'B'vS-o~ts:~t All"!o~~ pm a:maps ]1QUaWUOO!A"H "SUO!JiOrrdds UO!l8A:r.>SUO~ 111!A\
ppow ad~sptl1l'( 11 :"!S"1I =m !dd!s"!SS'..N atjl "! mg ~1lJl!ll ~dS 'LOO1: lIatjdW8J 'J pm "m 'tpoog
SNOUVOrIaOd <IlIL\\llAHlI-llHHd
=1lW!I5a A"'I}-A\O! "! A\8g ~uaP! ':!~d ]8A\tlJPl.Jl!A' ~8A\ SSOWO!1I JFlSSUlIJo ~
'po",pow uaoq P8lJ U8ql asJOA\ ^,"'l!! "'" suq~ lS'llllu!fmpuo~ l!'Wad J!l' SSUWO!lI !pssol[ JO A\"!A"1I
'suo!l1lJn:>l~ suo!S~ J!1l Pus~pow
am pnJ a'll "! SA\8g ~! 'lUBJd SS1lWO!1I IF'ssnlI /AN OS pasodoJd JO] !'pow ^(ddns "'0] JO A\"!A>ll
'VW 'l>F'9=~
"! lUBJd ssuwqq AllJa"H a!lj8A\aual[ _UO!d /AN Lv posodOJd wOJ.l Sl~vdlD! J1'luawn<lJ!All'l JO A\O!A"lI
'VW 'ppgfupds "! .u~8J Afu:>"H aJC[1lA\OU"lI JaWJ1'd /AN Be: a'll JOJ pnJ
S1l 0lS1lA\ U091jOWOP pm U~MSUO~ JO l!upS<ll uO!l"lJ!W81uro pus ~s JO] SUllJd JO h1<t1boP"U! JO A\'l""l[
'(uo!l"=oJ J1!luawuOJ!AUH JO :nr.>wuudaa '1JOA A\aN OJ) 0l8pU8W a''!I8!I!''I s"~ asnolJll>"J~
J1'U0~1I Japun ~saAJ8lj SSllWO!<l JO] PJ1'Ptl1QS ,u!l!quu!"lsns l}tlJp JO suql1lJHdw! uoqJ1lJ uo J;m>'J
SJ:Jud'lUf fI11uawlZWf"U3 ao SZU3lUlUO:J D;mp.&ll
',A'tllS ,\:'HOd uoq""J pm A:!!I!lJUU!"lSOS SSOWO!IL. s,Ja3uaJ "WOU8}\! a'll JO A\O!^>1I '~>Od 'fS"~ "!V 0"1J
'5a[l1J ,,"lS8A\. pm "JaI!OlJ" pasodOJd s, V dH 00 SlU'WUJO~
s,~ VJ "! uO!SUP"! JO] suo1SS!= ltl1QOnOO SS1lWO!q uo uO!l1lWJUJU! JO uO!l8J!dwoJ '=Oi/ '1S1l~ J!V =IJ
"J'I1I ~ol!"~ 'ql JaPuu suo1SS!= ~~O!q JO uolSUP"! soy dH 00 S)uaWUJO~ sdJ, VJ "! uOlSUP"!
JOJ suo!SS!UJO uocp~ pol~roJd pm i.tJsnp,,! ssowo!<l uo uqlUWJO.J"! JO UO!l8J!dwoJ =i/ 'fS"~ "!V =IJ
"J'I1I ~Ol!"~ alp Japun SO~ ~~O!<l JO UO!snp"! S,VdH 00 Sluawwo~
::nHS 'll!A\ OO!"OP"! JO] ,,5al81S P>l!110 D.kllSllaljlUOS aql "! oO!l1lZ]I!ln SS1lWO!q =0] JO suo!llO!ldlD!
~ asnolJtl"'Ull PUSl''1= ~,= "'lIJ,JO A\O!""J ~?J 'JOl=J...."'1 IlllU.wUOJ!>'UH =tpnOS
"!UJ0.J!I8J
':!UBJd ssuwqq lllSl,A =nlI posodOJd WOJ.l SU,,!~ uoq= JO S~J1'UV '1l!=A!O J1l:l!1l0JO!1I JO} JOlUOJ
'lUBJd SSllWO!q JTI 'JOlua:)
,llhaoH "llj8A\aU>1I ~ /AN 91' posooOJd'ql JOJ oO!l~lOJd J1!luawoo'!^"HJo ~uawuudaa 11p?"Id
otp OJoJO<j l~d J!l' tll ~U>!(lllP dn~ u;>zpp JOJ SSOUl!^, lJad"H 'bsg 'uos?J"H '1"!N '41V ~sV
sdnOJ1l [U1lRU1UOrfAU<J sno.UIJA Jl:!IlsApnry
SIS)\.'1VNV S.wVdWI 'lV.LNHWNOlllANH
.
J1
"S66~-v66~ ',il!SlOA!'lfl "l<lS tJ1'lfl 'd!tlSA\olF'i1 s,l""PJS""d "::IJ.A
"966~ 'p:IM\n tf.U=' OJIXl!lsur tp.ml""ll J:lP""8 pun U'WO&.~fl OJ1llS lj1l1fl
"666~-966~ 'dJtlSA\OJF'i1 OJunp"'8 >:>oops WOJs,(S tp:Ill"f{ VSVN
"e:OOe:-IOOZ 'J.01ll.IoqU'] [IO]lloIO!g""!""W "IoH spoo&. 'J:ll""J SW:J1MSOOt[ 'd!'ISA\OIF'i1 !ll.I01JOP1SOd UOIF'W
"tooe:-I:OOZ ""!SlOA!'lfl "!'IUlUP) 'd!tJSA\oIPill"'oPOplSOd OJIll!lSur tiP"H
"I:ooe: 'p:I1l^\u pA1l:Q UO!lU,oq"IIOJ ,:m,ps J"lJo!luuJOJuI s,""wo&. i1SN/SVVV
"OtOZ "Jl!U1'AIASUU'd "! SSUWO!tl 00 uodo. pun 1f'l1l"S'>> OJ=uoll 01 '1UUJ8 Sl""tDA\Opot[ ZO!"H
smIV&V aNY S.LNVlID
"owe: "(lOf VI\! 'uOlsog '>:>.loil
'lsn~ "!V =0 "p .oil ",(pms A:l!IOd uoqJUJ pon ,\J!I!<JUU!SJsns SSlltIIo!lI l"woun.lll ,tP)O A\'!A"1I ".IIl'tpoog
"OWe: WdV "J'a 'uOlllUJlIsn&. 'dn0J8
lltn'(.O& J1'l""wuo:J!Aut[ 'S1S'.'!j "S"fl SU<ll=lP ,,!oqdooI uoq= '-"'lS1lS!]J 1m,",,0 "S"I!&. 11 pun ".IIl'lpOog
"6OO1:/SC:/S '3<l0l8 U01Sog 'p:l-do 1J"ld ,(11",,,,, u=ll UO llng po> V ".IIl'tpong
'6OO1:/~/S '<>>>>ZU8 ""!'ISdlDllH "I!'la 'p<>-dO "Ssuwo!tl uo SJ"'IUlUU "tJllln!ipmS 'UOSAWa'v pun ".Ill 'tpoog
DO4\. UHHSITlIlld Urnu.O
.
.
(j)
February IS, 20 II
The HoooIllble Senator Bernie Sanders
322 Dirksen Senate Office Building
U.S. Senate
Washington, D.C. 20510
, Hooornble Senator Sanders,
We appreciate your interest in biomass energy and thank you for co-sponsoring a briefing on this
very important issue. The more robust the dialogue on renewable energy, the more likely we are to
move quickly to a clean and sustainable energy future.
We understund that the panel presenting on February 17lh consists chiefly of proponents of small-
scale biomass, and we fully appreciate the differences in scale and potential impacts between these
small facilities and utility-scale biomass power facilities. We find it troubling, however, that these
proponents ofsmall-scaIe biomass energy have done little to address the potential impacts of utility-
scale power genemtion and large-scale wood-pellet manufacture on forests of V ermont and the
region. It is important that the audience hears the full story about what the current explosion in
proposed biomass electricity genemtion, pellet prodnction and "energy wood" means for Vermont's
forests, air, and carbon balance, and we ask that the following issues be dealt with in full at the
briefing:
Generating energy from wood emits more carbon than using fossil fuels
Biomass emits more carbon dioxide than fossil fuels per unit energy produced, and is never a "carbon
neutral" fuel. Biomass can theoretically be a "low carbon" fuel if it consists of materials that would
have decomposed and emitted carbon dioxide anyway even if they weren't burned (though burning
these materials for energy emits carbon dioxide instantaneously, as opposed to over many years, as
occurs during decomposition). I
However, as determined by the Massachusetts-commissioned Manomet Study, when living trees are
cut to provide fuel, this increases carbon emissions for several decades compared to using fossil
fuels.2 For utility-scale biomass power plants, it takes at least forty years to regrow the forest enough
to resequester net carbon emissions to the level that would have been emitted if coal had been
burned, and more than ninety years to draw down net carbon emissions to the level of natural gas.
The difference in net carbon emissions between biomass and fossil fuels is smaller for high-
efficiency thermal-only and combined heat and power facilities, but it still takes ten, twenty, or thirty
years for the carbon payback to occur. This means that even at small, efficient facilities, biomass
energy is actually tncreostng climate-warming gases in the atmosphere right when it is most urgent to
reduce our carbon emissions.
The Biomass Energy Resource Center participated in the Manomet Study. The conclusion that net
carbon emissions from biomass exceed those from fossil fuels for several decades created an
I No matter what the genesis of the fuel, uliIity-scale biomass power generation emits arouud 150"10 the CO, of coa~
and 300 - 400% the Co, of natural gas, per unit electricity genemted.
2 Commissioned by the State of Massachusetts to determine the carbon status of biomass power, the Manomet
Study's conclusions were incorpomted by the State into draft regnlations that restrict the eligibility ofbiornass
power lbr renewable energy credilll to those fucilities that can demonstmte lifecyc1e carbon emissions no greater
than 50% those of a natural gas fuciJity, over a 2O-year period.
.
uncomfortable situation fur BERe, $ince it colll1'lldicted BERC's previous claims that burning wood
was carbon ~tral. We hope that BERC willllDt downplay tIH: Manamet results at the briefing.
"ED8llW wood" demand alteady exdledS supply from Vermont's forests
In or~ to avoid using co~ial-grIIde timber and wood from old-growth forests for fuel, energy
wnod must be derived from two main sources:3
Lritlllinll. residues: The tops, branches, and cull trees left over after C(lnUnercial timber harvesting.
This materUd is sometimes considered to be a "low carbon" sourceoffuet, since ifleft in the forest it
would decompose over 10 - 25 yeI!tS (in contrast, however, homing emits this carbon
instantaIleously).
a us Forest Seryjce data fot Vetmon! shows that tIH: S\llte gCllCl'lltes about 522,000 green tons
oflogging residues annunJly. Almost. one-ha1f' of these may be available for use as fuel, or
261,000 tQII!l.
Low-erade trees cut soecifi~lly fur fuel. Unlike the.l'llSidues from fotestlyeperiltions, harvesting
Dew l1'eeSfor fuel dramatiunJly inct~ carbon emissions relative to fussil fuels over tIH: next 20 to
100 years, liecause this is not material that "would have decomposed llI1YWUY" - these are wbole trees
that were sequest~ng carbon, until they were cut.
lJ BERC's recentlUlalysiss of "net available low-grade growth" in Vem10ilt estimates that
894,900 green tons are available annually, after firCWOQd and otIH:ruses taken into account.
(This estimate is just 61 % of the 1.466,982 tons that BERC said were available in 2007/ an
estiJnaWtbat has ~ widely cited by biomass developers and BERC itself')
These combined SO!JICCS of fuel might be sufficient to provide fuel fora variety of small biomass-
burning facilities in Vermont, assuming that citizens and policy-makers are not troubled that
replacing oil and gas with biomass inereases carbon emissionS over CUrNut levels from fossil ~
use. However, as demonstrated in the following figure, demand for energy wood from existing and
proposed m.cilities in Vermont actually far exceeds supply, meaning forest cutting will need to
increase dramatically to meet demand. Demand for biomass fuel will far exceed even commercial
sawtimber harvests in Vermont.
J Some JlIilI residues are used for fuel by existing biomass plants in Vermont, bill it is genellllly accepted thaI this
material ollen has higher value uses. USFS data indicate that Vermont genemles around 200.000 tons/yr.
, It is important 10 relDln low-diameter material on-site. to maintain soil nutrient stocks alld build soil carbou. For
nutrient-poor soils, much more than one-half of residues should be retained.
· Biomass Energy Resource Center, 2010. Vem)<)nl Wood Fuel Supply Study. 2010 Update (available at
h!!J!;/ /www.biomnss.ccnlcr.uru,timalI~s/storit..'SIV1,VFSSt1Ddatc20 1 0 .odD
· Elleemive summary containing the 2007 estintateis available at
hHn:il\\~'W.bi(lmas..'lcentcr.on!{od(,,^,r \VOl'll Fuel S;unr1v Sludv I...'x~\'..summ:.rulf
.~ J'-
Wood demand at proposed fadlltlesln Vermont exceeds supply; demand atex!sting
and proposed facilities Ismore than doublethe supply
.',
S"'"WlJ...''' .
.
Re$idues plus "net avaUable
Il>w-grade growth" (NALGI
wood (SERe's numbers):
1,156,087 tons/yr
. Wood demand at proposed
. facUltIes: 3.251,!lOO tons/yr
.. . . Wood demand at exIstiJlg
. facilities: 744.000 tons/yr ·
Total demand: 2,495,900 tons/yr
o 'ocludes24,OOOtol'ls/yrforVTsthooI
blotnas$program
BurnIng wood for energy Increases ilIr pollution
ReplllCing fossil fuels with biomass doesn't jUst increase carbon pollution - it emits particulate
matter, nitrogen oxides, lI!Id r.Jarbon monoxide at similar or higher levels !ban from oil and coal
burning, and emissions mr exceed those from Illltural gas. The MeNell biomass energy plant is
already VerJDOnt's biggest polluter, but at least another three facilities are proposed in the state that
will rival it for pollution output .
EP A's dmft "boiler rule" s1lIndards7, issued as a legal reqUirement under the Clean Air Act, illustrate
this problem. While smaD biQmass burners are ~Ili 10 the same particulate matter emission limit as
coal, S the standards for"~r source" biomass i>unulrs allow them to emit:
. 8 times In* particulates !ban coal
. 66times more lICid gases than coal
. up to 80 times more carbon lnOnoxide than coal
. up 10 2,33 times more dioxins than coal
7 Federal Register, Friday, JtIlle 4, 2010. 'Environmental Protection Allew:y, 40 CFR Part 63. NntlOJJSJ emission
standards for bnzardous air pollutanls for lI1Ilior sources: industrial, commen:iaI, and institllliollllI boilm and pr=
heaters; proposed rUle. (BPA's final boiler rule is due 0111 in February 2011; the Agency bas indicated tballhe finlII
SlllIl<lards will likely be Wtaker than the rules as proposed.) .
8 In a lener to EPA on the boiler rule, the Biorasss Energy Resource Center bas requested tbaI EPA 10ll8elI the
standards even lbrlher, so thet theSllllllJ blll1lelS which EPA wants to perform as well as c:oaI burners wou1d be
llIIowed to emit more than X limes. the particulate pollotiOD limit thel EPA proposed for bolb QIllI and biomass.
,
. (the only pollutant regulated under this rule where coal emits more is mercury).
EP A based these proposed IilIlits on the "best performing" (lowest emitting) facilities that already
exist, so what this says is that EP A acknowledges that burning biomass is dirtier than coal, and that it
will stay that way for a long time under these new rules. Even so, the biomass industry has responded
by claiming that these minimal standards will put it out of business.
Where's the balance?
When taxpayers and ratepayers learn these facts about biomass energy, they ask why they are being
required tn subsidize something !hat's dirtier than coal in the name of renewable energy. We can
understand why schools, hospitals, tnwns, and even states want to reduce dependence on oil- we live
and work in these places too. Many people do believe that small-scale biomass energy may have a
limited role to play in displacing fussil fuels, but given the steeply mounting costs in increased forest
cutting, carbon emissions. and air pollution as the proportion of energy from biomass increases. it's
important to be realistic about what that role can be.
Many people understand at a fundamental level that a civilization that burns its forests for energy is
on the way out. Indeed all over the country, wherever biomass facilities are proposed, people are
objecting to the idea that furests -their forests - should be opened up to energy extraction. They
object when they learn that biomass energy isn't carbon neutral as they've been tnld, but that it
actually increases carbon emissions compared to fossil fuels fur several years, if not decades, with
only a thin hope that the carbon released will be resequestered in re-growing forests. 9 Citizens can do
the math - and when they see how low efficiency biomass power generation requires exploiting our
forests, they wonder why policy-makers aren't doing the math, too. They especially wonder why
policy-makers seem intent on providing an ever-increasing raft of taxpayer and ratepayer subsidies to
an industry that appears tn need them forever.
Wehope this letter will encourage balance, and we urge those who read it to dig a little deeper into
the full story on biomass.
Sincerely,
Prof: Willinm Moomaw, PhD
Director, Center for International Environment and Resource Policy, Tufts University
Prof. Lara Shore-Sheppard, PhD
Department of Economics, Williams College
Concerned Citizens ofPownal
Dr. Mary S. Booth, PhD
Partnership for Policy Integrity
· Are policy-rnnkers and landowners ready to guarantee that they won't recut forests for decades, until all the carbon
emitted by biomass burning has been re-sequestered? This is what is required for biomass to achieve "low carbon"
status.
Gf)
Review of the Manomet Biomass
Sustainability and Carbon Policy Study
Prepared by Mary S. Booth, PhD
For the Clean Air Task Force
July, 2010
Table of Contents
ExECUTIVE SUMMARY ................................................................................................................................2
INTRODUCTION ............................................................................................................................................ 5
MAIN CONCLUSIONS OF THE MANOMET STUDY ........................................................................................ 5
How THE MANOMET MODEL WAS CONSTRUCTED .................................................................................... 7
Assumptions npon which the study conclusions depeod ........................................................................ II
REVIEW OF ASSUMPTIONS ......................................................................................................................... 12
Large trees are used for biomass fue1.......................................~..............................................................12
Harvested forest stands must not be recut pending carbon sequestration............................................... 13
A high percentage of tops and limbs are used as fuel............................................................................. 15
Soil nutrient implications of taking tops and limbs for fuel................................................................16
Biomass harvesting only occurs on land already being harvested for timber .........................................18
Soil carlJon emissions are negligible.......................................................................................................18
Firewood harvesting is not impacted .................:....................................................................................19
Wood pellet manufacture incurs no more carbon debt than green chips ................................................21
Wood from land-clearing incurs little carbon debt.................................................................................22
CONCLUSIONS ............................................................................................................................................ 23
I
t !;
EXECUTIVE SUMMARY
The purpose of this document is to evaluate the science behind the Manomet biomass report and
the validity of the report's main conclusions concerning net carbon emissions from biomass energy,
relative to fossil fuels. The report comes to two maln.concluslons:
1. For utility-scale generation, net emissions are higher from biomass than fossil fuels.
WhElD biomass is used to generate electricity In utility-scale plants, the net emissions after
40 years, even taking forest regrowth Into consideration, are stilI higher than If the power
had been generated with coaL When biomass is used Instead of natural gas, net emissions
are stilI higher even after ninety years (exhibit 6-14, p. 112).
2. Net emissions profiles from biomass thermal and CHP plants may be better. The
Manomet study concludes that when biomass replaces fossil fuels for small-scale thermai
applications and In combined heat and power plants, net emissions by 2050 can be lower
than would occur if 011 had been burned, but are stilI significantly higher than If natural gas
were used as fueL
The study relIes on a number of assumptions to achieve these conclusions that minimize the
calculation of net carbon emissions from biomass power, meaning that actual emissions are likely
greater than the study concludes. Thus, the first conclusion of the report - that net emissions from
biomass are greater than from coal and especially natural gas even after decades of regrowth by
forests - is qualitatively correct, but it likely underestimates the magnitude of biomass emissions.
The second conclusion, that small-scale thermal and CHP biomass facilities may yield a carbon
"dlvldend" relative to fossil fuels after forty years is likely not correct, since actual biomass
emissions likely exceed fossil fuel emissions even under the thermal and CHP scenarios.
The study's major conclusion, that net biomass emissions are slgnlflcantly higher than If natural gas
were used as fuel even after ninety years of forest regrowth, Is especially notable for the New
England area where the majority of electricity generated comes from natural gas. Using biomass to
"reduce" emissions from the power generation sector wIll have the opposite effect, particularly
where biomass displaces power generation from natural gas.
The Manomet model estimates net carbon emissions for both biomass and fossil fuels as fuel
Iifecycle emissions minus forest carbon sequestration on a hypothetical acre which Is cut for timber
but not biomass (the fossil fuel/buslness-as-usual scenario), and one which Is cut for both timber
and biomass (the biomass scenario). As the forest regrows on the plot cut for biomass, the net
carbon balance transitions from representing a "carbon debt" to providing a "carbon dividend", as
carbon moves from the atmosphere into new forest growth. This "single plot" analysis of forest
recovery after cutting selVes as the building block for an integrated analysis, which assesses the~
cumulative Impact of a biomass Industry that cuts new forest for fuel each year and thus increases
the relative amount ofland that stili has a "carbon debt". The study unfortunately downplays the
cumulative effects analysis, instead focusing on the "single plot" analysis, which would only be
relevant to the calculation of carbon impacts from a facility that operated for a single year.
Some of the many assumptions upon which the Manomet study's conclusions rely are listed here;
all minimize the calculation of carbon emissions from biomass. The model is sensitive tu these
assumptions, therefore If anyone of them is violated in reality, actual emissions will be greater than
reported In the study's conclusions.
2
1. Large trees are used for biomass fuel. Because forest regrowth rates In the model are to a
large extent a function of the Intensity of harvest (with heavier harvests oflarger, older
trees opening up more space for regrowth to occur), the model achieves maximal regrowth
and resequestration of carbon released by biomass burning by assuming that relatively
large, old trees are logged for biomass. However, this is not representative of actual
biomass harvesting, which is more likely to remove low-diameter, low-value material.
Actual regrowth rates of forests where low-diameter material is removed will be much
slower than modeled.
2. Harvested forest stands must not be recut pending carbon sequestration. The model
additionally requires that once a stend has been cut, it must not be re-cut until It has
achieved a large proportion of the amount of standing carbon in an unmanaged stend The
Manomet report itself aclmowledges this Is unlikely.
3. A high percentage of tops and limbs are used as fuel. Because the tops and limbs of trees
harvested for timber under the BAU scenario are assumed to stey in the forest and rot,
producing carbon, the model assumes almost no carbon penalty for collecting this material
and burning It The model assumes that 65% of all tops and limbs generated on acres
harvested for biomass can be removed from the forest for use as fuel, supplying a relatively
large "low carbon" source of fuel in the model. Removal of this amount of tops and limbs
appears to be necessary to achieving the transition from biomass carbon debt to carbon
dividend In the model, but is not compatible with maintaining soil fertility and other forest
ecological functions.
4. Biomass harvesting only occurs on land that Is already being harvested for timber.
The study takes as Its BAU assumption that when land Is harvested for timber, all residues
are left in the forest, whareas a portion is collected for fuel In the biomass scenario. The
study draws no conclusions concerning carbon dynamics and regrowth in forests cut solely
for biomass. This assumption Is necessary for generating the "low carbon" fuel source of
tops and limbs from commercial timber harvesting that Is integral to calculating carbon
dividends from biomass in a timely way. Land cut solely for biomass would take a much
longer time to achieve a carbon dividend.
5. Soli carbon emissions are negligible. The soil carbon pool Is extremely large, and a
significant fraction oflt Is easily decomposed and evolved as C02 when soils are disturbed
by logging. However, the Manomet model completely disregards this source of emissions
that are associated with biomass harvesting. This assumption Is challenged by the author of
a major review on soil carbon emissions cited, and dismissed, by the Manomet study.
6. Firewood harvesting Is not Impacted. Although Indirect land use effects can be major
sources of greenhouse gas emissions from biomass harvest, and although the RFP for the
Manomet study requested that the study evaluate indirect iand use effects, the study does
not acknowledge that displacement of firewood harvest by biomass harvest could result in
"leakage" of firewood harvesting and more forestland being cut for firewood.
7. Wood pellet manufacture Incurs no more carbon debt than green chips. Although it Is
well-estebllshed that manufacture of wood pellets requires significant inputs of green wood
In excess of the heating value actually embodied In the pellets produced, as well as
significant fossil fuel expenditures, the study treats wood pellets as embodying the same
amount of carbon and energy as green wood chips.
3
!. 1
8. Wood from Iand-cIearlng incurs little carbon debt. The study concludes that woody
biomass from non-forestty sources, such as from land-clearing, will not entail any greater
greenhouse gas emissions than forestry wood. However, no modeling is conducted to
substantiate this conclusion. The study also does not discuss how wood from land-clearing
can be considered eligibie under requirements that biomass fueis be avaIlable on a
renewable and recurring basis, as required under the Regional Greenhouse Gas Initiative.
To the extent that these assumptions are not warranted, the Manomet study has underestimated
the net carbon emissions of biomass power, and poliey-makers should be extremely cautious about
accepting the study's optimistic conclusions concerning the point in time when biomass can start
providing a carbon dividend.
4
INTRODUCTION
The purpose of this document Is to evaluate the science behind the Manomet biomass report and
the validity of the report's main conclusions. The Manomet study is large, and covers much
background material on biomass policies in the United States and internationally. This evaluation
wlll focus only on the core conclusions of the study that deal with carbon accounting. Overall, the
conclusion of this evaluation Is that the Manomet study's basic approach to calculating net carbon
emissions from biomass Is valid, but it relies on a number of overly optimistic assumptions and
omits categories of greenhouse gas emissions from the study's lifecycle analysis. It Is highly likeiy
that net carbon emissions from biomass are actually higher than concluded by the Manomet study.
Organization of this paper
This summary reviews the carbon modeling aspects of the Manomet report. It begins by setting out
the two main conclusions of the study. This Is followed by an explanation of how the Manomet
carbon model was constructed.
Next Is a short list of the main assumptions of the model. upon which the conclusions depend. Thls
is followed by a critique of each assumption.
Once the assumptions behlnd the modeling are alred. this allows the conclusions of the Manomet
study to be assessed more thoroughiy.
Throughout, this summary paper relies extensively on text copied from the Manomet report Itself.
with page numbers included to guide the reader to relevant sections. Points of particular
Importance are highlighted.
MAIN CONCLUSIONS OF THE MANOMET STUDY
Regarding net carbon emissions from biomass relative to fossil fuels. the study had two main
conclusions:
1. For ntillty-scale generation, net emissions are blgher from biomass than fossil fuels.
When biomass Is used to generate electricity in utility-scale plants. the net emissions after
40 years, even taking forest regrowth into consideration. are still higher than if the power
had been generated with coal When biomass is used instead of natural gas. net emissions
are still found to be higher after ninety years (exhibit 6-14, p. 112).
2. Net emissIons profiles from biomass thermal and CUP plants may be better. The
Manomet study concludes that when biomass replaces fossil fuels for small-scale thermal
applications and in combined heat and power plants, net emissions by 2050 can be lower
than would occur If oll had been burned, but are still significantly higher than if natural gas
were used as fuel '
Prior to further discussion. It Is important to note that the results presented in the executive
summary of the Manomet report do not represent the full results presented in the body of the
report. Most Importantly, the study concluded that the net carbon balance of biomass energy
depended on the intensity of harvesting both for commercial timber and biomass removal itself,
and thus examined six different harvesting scenarios, reporting the carbon balance results under
each. Unfortunately, the results of only one of the scenarios Is presented In the executive summary.
5
~
. ,
These are the results for cumulative carbon impacts presented in the executive summary. Negative
numbers indicate that In the year specified, net emissions from biomass still exceed those from
fossil fuels:
Figur.. 4: CII'lIUIaI!',<, Carbon Dh'ldcod, from EioOla."
Rcp!arClllcnt of Fossil Fuel
Blomus<':ullllllal!w" R(1!...,!ion in Carboll Emiswns
(Net ofFon.,,1 Carbon ,Sequestratiun)
Oil (:r6) COol', (ii1~ G.....
yt....r 'fllernlall Iik"Clrk Iherm.1 lik'Clrk
CHP
21)511 25% .3')(. .13% 110%
2100 U% 19% J!t.'ll '('.~%
Below Is the full table from Chapter 6, from which the results presented in the executive summary
are drawn. The table presented in the executive summary repeats the results from Harvest Scenario
1. The assumptions behind these results are discussed In more detail below, but critical to placing
these results in context Is understanding that all harvest scenarios assume that biomass harvesting
occurs only on land already harvested for timber at varying IntensIties, and that a large proportion
of tops and limbs from commercial timber harvesting are available as "low-carbon' biomass fuel
Exhlblr 6-14: (:ulllul'lh'cC"b"" Oh1dl.'llds: 21110 10 2051J
Hanvst Fo.sil Fuel T.d......''''*'
Sr:cnario Oil ('6), (:",1. G",. (;,..,..
lhernwl EJct."trh.- 'ThC'fll$.,ll Eb:tric
I 22~ .31b'~ ~13~!il .Il\}>>;;
2 34Jl(\ ll~~ ~% "~l~.
,~ 8"6 :H''\t .3~"" .J~8'li>
< IS;" ~l.,qb ~2;.'hs .129'~.
5 16% .11% -21% .I!6'Jj.
" 7% .25'1(, .3{;.lli. ~11)3%
Exhlbll ('.15: CUlllulatlve Ulrbon Dividends: 2111ll It> 2U10
Itfn_ f.,.dl fuel r.clmoluSY
S.'~fld.riu Oil (#(,). OMI. G3$. G;1S.
11wS'nlo,1 EIe.:uit- Thermal Elcctrk
I -10% 19% 12% .63""
2 S6% 42% 36'S., -18....
3 .)1% 8~l(, 0% I .g61~,
of 43.... Z4'!b 17% .'\.1"-
~ J7l1>.. 16% ')>to ..(,?!f.
6 ;tJ"l. 8% ..l'.'il .s6~
6
.
How THE MANOMET MODEL WAS CONSTRUCTED
The Manomet model compares the emissions from biomass power for electricfty only, thermal only,
and combined heat and power plants against emissions from gas and coal in the case of electricity
only plants, and gas and oil in the case of thermal and CHP plants. Lifecycle emissions consist of
emissions at the stack from fuel combustion, as well as emissions associated wlth collection and
transportation of the fuel.
Net carbon emissions are estimated as fuellifecycle emissions minus forest carbon sequestration
on a hypothetical acre which is cut for timber hut not hiomass (the fossil fuel/business-as-usual
scenario), and one which is cut for both timber and biomass (the biomass scenario). Net carbon
emissions from fossil fuels and biomass burning are compared by calculating the amount of
lIfecycle carbon emissions which are sequestered into new forest growth under the two scenarios.
The model employs the Forest Vegetation Simulator, a model that uses Forest Service data on tree
growth and forest composition, to estimate the recovery and regrowth of the forest followlng
harvesting.
The report describes the approach:
In general, the carbon accounting model shonld be premised on some knowledge of
how lands wlll be managed in the future absent biomass harvests, and this becomes
a critical reference point for analyzing whether burning biomass for energy results
in increased or decreased cumulative GHG emissions over time. (p.99).
At the most general level, the carbon accounting framework we employ is
constructed around comparisons offossll fuel scenarios wlth biomass scenarios
producing equivalent amounts of energy. The fossil fuel scenarios are based on
llfecycle emissions of GHGs, using .C02 equivalents" as the metric (C02e). Total GHG
emissions for the fossil scenarios include releases occurring in the production and
transport of natural gas, coal or oil to the combustion facility as well as the direct
stack emissions from burning these fuels for energy. Similarly, GHG emissions from
biomass combustion include the stack emissions from the combustion facility and
emissions from harvesting. processing and transporting the woody material to the
facility. Most Importantly, both the fossil fuel and biomass scenarios also Include
analyses of changes In carbon storage In forests through a comparison of net
carbon accumulation over time on the harvested acres with the carbon storage
results for an equivalent stand that has not been cut for biomass but that has been
harvested for timber under a business-as-usual (BAU) scenario. Our approach
includes the above- and below-ground live and dead carbon pools that researchers
have identified as important contributors to forest stand carbon dynamics.
The conceptual modeling framework for this study is intended to address the
question of how atmospheric GHG levels wlll change ifbiomass displaces an
equivalent amount offossil fuel generation in our energy portfolio. With this
objective, the modeling quantifies and Compares the cumulative net
annual change In atmospheric C02e for the fossil and biomass
scenarios, considering both energy generation emissions and forest
carbon sequestration. In the fossil fuel scenarios, there Is an initial C02e emissions
spike associated with energy generation-assumed here to be equivalent to the
7
~ ~
energy that would be produced by the combustion of biomass harvested from one
acre-which Is then fonowed by a drawing down over time (resequestratlon)
of atmospheric C02e by an acre afforest from which no biomass Is removed
for energy generation. For the biomass scenario, there Is a similar Initial release of
the carbon from burning wood harvested from an identical acre of natural
forest. folloWed by continued future growth and sequestration of carbon In
the harvested stand. (p. 96)
In the modeled acre cut for biomass, the forest Is cut for timber at the same intensity as in the BAU
scenario, but then more trees are removed to provide biomass fueL Additionally, a portion (65%)
of the branches and treetops from thll trellS cut for timber are removed as fuel, and the same
amount of tops and branches from trellS cut for biomass are removlld as fuel, along with all trunk
wood. Themodlll thus assumllS that 35% of all tops and branchllS are left onslte, and that this
material rots and emits C02 oVllr tlmll. The Manomet study examines six alternativll harvesting
scenarios at various intensitillS of removaL
The analysis that compares the carbon sequestered over time on a single fOTllSt acre under the BAU
scenario, versus that on an acre cut for biomass, servllS as the basic "building block" of an Integrated
analysis that considers the summed emissions over time, and the summed regrowth over time. ThIs
can best be explained by Inserting the figuTllS 6-2a and 6-2b from the Manomet study. The first
graph shows the regrowth on an acre of forest harvllSted only for timber (BAU) and one harvested
for timber, with additional trees cut to provide biomass fuel. Because the heavier removal on the
acre cut for biomass actually increases the growth rate in the recovering forest, the two curves
eventually converge:
..0
r. I
WITH BIOMASS HARVEST
... ,
1M:
.,1
..'
....
..!
""
,"",.--.
, I~'-
&!r ; 12Doobi
.. ; I
I
n. I
',ft
..'
"U 1
..
Year after cutting
~ ~ m ~ ~ ~ m ~ q ~ ~ ~ ~ ~ ~ K m ~ w ~ ~
Figure I. Forest growth following harvest in the "business-as-tlSllll!"timber borvesting sceoario. and the sceoario which
harvesIs for both timber and biomass. This gmph is labeled 6-18 in the Mm1oml:l report.
8
,
The next graph shows the cumulative net emissions from biomass and fossil fuel combustion,
tracking the reduction in net emissions through time as the forest grows back. The single regrowth
curve represents the subtraction of the BAU curve from the biomass curve in the graph above,
essentially treating the carbon that would have been sequestered under the BAU scenario, which Is
now lost, as an "emission" that Is associated with biomass harvesting. Immediately following
harvest, the biomass scenario thus starts out with a "carbon debt" of an additional 9 tons of carbon
that are harvested for biomass fuel after the initial 11 tons of carbon are removed for commercial
timber. The point where the curve (which describes the net emissions from biomass burning)
Intersects the flat line (which describes the cumulative emissions from fossll fuel burning) is the
point In time when the net emissions of the two scenarios are equivalent. This occurs at
approximately Year 32 in this scenario.
"
Bb.'Th1i\ (arbo:'! nfbt
RC'IJ!i'Jt' to Fc>!:sll Fut!l
11 t" ~~. 7(, ~r:
,
iln1l:" of EqlJat :
Ctltntddlive C,Hoon Fhlx :
.
:
,
.
,
.
.
,
,
,
,
.
,
,
1~ ~ ~ ~ ~ M . >> ,~ ~
".""''/----
...
J.,
.l. t~
.
t
I
I
I
I
I
I
I
I
I
...
n
,
Caroo,O",dend
RcI.I.'JJ!toFaS5'J Fuel
:0
...
I
J
J
.' J
I
I
I
I
I
V
"
(nrtlon R<>l<,o:;cd
IroMSurning flY>s11 Flli>'lor (qul",'e"I energy
Chal~ In StVr'ed (.afi>:n): BiomJSi Stara Ca~bo1l mi "lVS BAU Staru:! Carbcn
}.-;
Figure 2. Biol11llSS ..rbon debt under lite biOll1llSS scenario. relative to..rbon emissioos ftom fossil fuel use, for foresl cutting
ftom a single year. The two lines cross al Year 32, a point where nel emissions ftom biOll1llSS have achieved parity willt net
emissioos ftom fossil fuels. Prior to litis point, biOll1llSS power represeots a carbon debt; aller this point, il provides a carbon
dividend, bul only for a single year's wordt of CUlling on a particular bervesled area. This graph is labeled 6-2b in the
Maaomet report.
It is important to understand that this curve only describes the recovery of carbon and the net
carbon balance on a single acre ofland barvested for biomass. The objective of the approach is to
track regrowth following harvest through time, to determine the year in which the net carbon
release from biomass is equivalent to the net release by an equ ivaJent amount of energy produced
by fossil fuels - the "time of equal cumulative carbon flux", which for this plot is approximately at
Year 32. However, this does not describe the integrated picture of carbon emissions from a biomass
facility, which operates continuously over many years and requires new forest to be cut every year.
The integrated picture is more complex and consists of a series of curves, one for each year of
cutting. Taking Manomet's graph of recovery on a single acre, above, and changing It to represent
9
~ ~
several years of cutting produces the following graph, which for the sake of clarity and spacing
treats the forest cutting episodes as if they happen every five years, instead of every year as they
would in reality:
,
"
,
".
1',
"
,
\0. :,t,
,
.
.
.
Y:ar:~er:W~~ t.' ;" ,o,~ ,f;;:';;::::~:?f~
/'" '...'" .,..< .../ . I
.......... ....... .,",,,,/ .,.,' .
" .-- ," / "... , I
"" '"" ,.' "
// ,,/," .
"",,/ "" ",,/ ",," ~ ';'00'1 DI''''10el'td I
" / ", .
// // // He;)t vc to Fo'),;'; fud I
/" .... /'., // I
/" ./...- // .
,/ ,/ ," +
, , ,
iimf'\offqlJ.lt
Curnul..ltivt." c.nrn.m flux
FllstJl/<lt<lll:atlilar32.
....__so_net
_OUllilaI1<IIngare
Utr>ns,1OIl%ofthe_of
_fuel_
"
I , , , . , "
: / .. / ..... (.l}~On !tE>I(lJ~d
.-~-"H~'dK'\~,"l"lx>>-+)eb{----- ---JI / / ./ VO'V) ,aU!f'll'lg Fossil Ft..c-I for EqujvJI~"'lt [OI::'''g)l'
I RelJ.tlvC' 10 Fos~il f.uct / I...: / .... / "
.. I , J/ ' ... , ..
"..n........__.......... .__,..n..'I' ' / , "
J / /,/ /' / .,'
I / ,.... 1/ .." / ....
"T.n.____n__.n --+--:.,--.,0 X" / "
// .,' ..,/, ,.', ,
..:t:::.::--~;:~;.~:;;~:~.;t~<., /
!J __4'.___....:..__.....*........::.__.-:..0' 4lhpJotcut:atYear
/ 32........-
OUllilaI1<IIngare
7"'Jl/<It all: at Year 32. ... alJout:r1lDnS.
--.ding.....
sliII20lDnS.:Ill2'lIofthe 155%01'__
_from_fuel_ _fuel_
'"
TotalaalJon ._.I'tI.....1Iqg BlYear31
undar_............after7
.cuItlnp": 1J3 tons, or1t7ll; oftbe
77lD11Semlaedhyfaosll fuels......
tile"""", pooIod [7 xl1 lDDs)
1':.
Figure 3. Iutegmted au:bon emissions for 0 hypothetical bi01llllss f""itity. assessed over 0 mnnber ofy..... Whereas dIe first plot
cut bes regrown and ncbieved parity with fossil fuel emissiollS by Yeer 32. this is not the case for on subsequent plots CUI. which
still hove carbon debts outstnnding, EmissiOIlS from lID IlClUlIl fucility. as assessed in this integml<d picllD'e. are considerably
higher thIlO for the single plot nnnlysis presented obove. At Y.... 32. net emissiollS from biomass in this bypodletical exnmple are
still 147"/0 of those from fossil fuels.
A central problem with the Manomet study is the amount of space the report devotes to discussing
the recovery of a single plot after cutting. and the relatively minimal of space used to discuss the
Integrated picture of total facility carbon emissions. This may be confusing to the typical reader of
the report who is unlikely to have time to review it In detail. As can be seen from the analysis
associated with the last graph. It takes much longer to achieve parity between biomass and fossil
fuel carbon emissions when more than one year of cutting is considered. Whereas the single year
analysis finds parity for biomass and fossil fuel emissions at Year 32, cumulative analysis of several
years finds that biomass emissions are stili 147% offossil fuel emissions at Year 32.
The Manomet report does make this point. However. the analysis of cumulative effects, which is
central to understanding the Impact of biomass power, is only found at the very end of the report,
where it is described as simply "another way" of looking at the data (this description also occurs In
the executive summary, after the explanation of single-year results),
10
, ,
Another way of comparing the relative contributions of carbon debts and carbon
dividends is to estimate the difference In cumulative net atmospheric carbon
emissions between using biomass and fossil fuel for energy at some future
point In time. Due to the importance of demonstrating progress In reducing
greenhouse gas emissions by 2050 as part of the Massachusetts Global
Warming Solutions Act; we have provided such a comparison for our six harvest
scenarios in Exhibit 6-14. (p.ll1)
Chapter 6, where the modeling results are described, devotes 15 pages to developing the results for
the single-year analysis, even presenting charts such as exhibit 6-13 that create the impression that
the time to parity under different forms of energy generation (thermal, CHP, and electric-only) is as
low as 7 years when oil thermal heat is replaced, a conclusion that would only be true if a biomass
facilit;y operated for a single year. then shut down. A single page Is devoted to discussion of the
integrated multi-year analysis.
In the executive summary, these same time-to-parity results for the single-year analysis are
presented before the discussion of cumulative effects, giving the Impression that these are the more
significant results. This Is a major deficit in the report, particularly since the actoal tlme-to-parity
results for the cumulative effects analysis are never calculated.
Assumptions upon which the stuqy conclusions depend
All of the assumptions listed below minimize the calculation of net carbon emissions from biomass.
To the extent that these assumptions are not warranted, the Manomet study has underestimated
the actual carbon emission impacts of biomass power, calling Into question its conclusion that
biomass will emit less net carbon over time than other forms of generation.
1. Large trees are used for biomass fuel. Because forest regrowth rates In the model are to a
large extent a function of the Intensity of harvest (with heavier harvests oflarger, older
trees opening up more space for regrowth to occur), the model achieves maximal regrowth
and resequestration of carbon released by biomass burning by assuming that relatively
large, old trees are logged for biomass.
2. Harvested forest stands must Dot be recut pending carbon sequestration, The model
additionally requires that once a stand has been cut, it must not be re-cut until it has
achieved a large proportion of the amount of standing carbon in an unmanaged stand.
3. A high percentage of tops and limbs are used as fuel. Because the tops and limbs oftrees
harvested for timber under the BAU scenario are assumed to stay in the forest and rot,
producing carbon, the modei assumes almost no carbon penalty for collecting this material
and burning It The model assumes that 65% of all tops and limbs generated on acres
harvested for biomass can be removed from the forest for use as fuel, supplying a relatively
large "low carbon" source of fuel in the model.
4. Biomass harvesting only occurs on land that Is already being harvested for timber.
The study takes as its BAU assumption that land is harvested for timber, and that all
residues are left in the forest In this case, whereas a portion is collected for fuel in the
"
~ -I.-
biomass scenario. The study draws no conclusions concerning carbon dynamics and
regrowth In forests cut solely for biomass.
5. Soli carbon emissions are negligible. The soil carbon pool is extremely large, and a
significant fraction of It is easily decomposed and evolved as C02 when soils are dIsturbed
by loggfng. However, the Manomet model completely disregards this source of emissions
that are associated with biomass harvesting.
6. Firewood harvesting Is not Impacted. Although Indirect land use effects can be major
sources of greenhouse gas emissIons from biomass harvest, and although the RFP for the
Manomet study requested that the study evaluate Indirect land use effects, the study does
not acknowledge that displacement of firewood harvest by biomass harvest could result In
"leakage" of firewood harvesting and more forestland being cut for firewood.
7. Wood pellet manufacture incurs no more carbon debt than green chips. Although it is
well-established that manufacture of wood pellets requires significant inputs of green wood
In excess of the heating value actually embodied in the pellets produced, as well as
significant fossil fuel expenditures, the study treats wood pellets as embodying the same
amount of carbon and energy as green wood chips.
8. Wood from land-clearing Incurs UttIe carbon debt. The study concludes that woody
biomass from non-forestry sources, such as from land-clearlng. will not entail any greater
greenhouse gas emissions than forestry wood. However, no modeling Is conducted to
substantiate this conclusion.
REVIEW OF ASSUMPTIONS
Large trees are used for biomass fuel
Because forest regrowth rates In the model are to a large extent a function of the intensity of
harvest (with heavier harvests of larger, older trees opening up more space for regrowth to occur),
the model achieves maximal regrowth and resequestratlon of carbon released by biomass burning
by assuming that relatively large, old trees are logged for biomass.
Alternatively, for some stands, and especially for slow-growlng older stands,
harvesting would be expected to Increase the carbon accumulation rate (at least
after the site recovers from the Initial effects of the harvest) and lead to relatively
more rapid Increases In carbon divldends.Determlnlng the time path for paying off
the carbon debts and accumulating carbon dividends is a principle focus of our
modeling approach. (p. 99)
Although biomass harvesting is often presented as a way of clearing out small trees in overgrown
forests, the model does not treat the smallest trees as an available source of biomass fuel, instead
setting a minimum diameter of 7 inches for trees to be cut:
Approximately 65% of the standing trees on Massachusetts timberland are 1"-5"
DBH; however, In spite of their large numbers, these sapling-size trees represent
only 5% of the timber volume on a tonnage basis (PIA Statistics for 2008). It would
,
12
..t_ 'l
be cost prohibitive to harvest trees In this size class based on our analysis. In
order to be competitive in current markets, biomass producers would need to
harvest trees with low stumpage value that are greater than 5' DBH. (p. 42)
The model suggests that the minImum size threshold for whole-tree harvesting
In Massachusetts Is In the range of 7.0-9.0 Inches DBH if the economic objective
is to deliver chips to a bioenergy plant at a cost of about $30 (or less) per green
ton.(p.41)
It seems that pre-commercial thInnlngs and small trees should be excluded as
part of the biomass resource In Massachusetts-as one logger In Maine told us
anecdotally, "the fastest way to go broke In the biomass business is to harvest 2-to-6
Inch trees... These model results clearly demonstrate the critical importance of tree
size and handling costs In the economics of whole-tree harvesting: whole-tree
harvesting appears to be cost prohibitive for sapling-size trees. (p.41)
The study concedes that some of the harvesting assumptions In the model could decrease the future
economic value of the forest:
However, new biomass marl(ets may cause the harvest oftt:ees that would
eventually develop into valuable crop trees Ineft to grow. A straight, healthy
10' oak tree that would someday grow to be an 18" high-value veneer log might be
removed too early In order to capture its much lower biomass value today. The
misuse oflow thinnings to remove biomass could also remove the future
sawtimber crop as well as the forest structure referred to earller.(p. 73)
Biomass harvesting is otten portrayed as a way to create a market for small, low-value understory
trees that are removed in thinning operations on commercial timber stands. However, removal of
such trees does not cause the same growth and recovery In forest carbon as removing large trees
does. Therefore, actual carbon recovery times are likely longer than represented by the harvesting
scenarios that Manomet modeled, meaning that carbon debts persist longer.
Harvested forest stands must not be recut pending carbon sequestration.
The model additionally requires that once a stand has been cut, it must not be re-cut until it has
achieved a large proportion of the amount of standing carbon in an unmanaged stand. However, the
study Itself acknowledges this assumption Is lli(ely unwarranted:
The scenarios we defined as "biomass" harvests (Biomass 40%, Biomass BA40,
Biomass BA60) maintein Wgh growth rates for several decades. Because of this
increased growth rate, even the heavier harvested stands can reach almost 90% of
the volume that could have been achieved in an unmanaged scenario. So, over a long
period of time, biomass harvests have an opportunity to recover a large portion of
the carbon volume removed during the harvest However, this assumes no future
harvests In the stand as well as an absence of any significant disturbance
event. Both are unlikely. (p. 86)
13
f "
Despite acknowledging that It is unlikely that having been cut for biomass, forests would be left
uncut until a required level of carbon sequestration had been achieved, some of the central findings
of the model depend on thls assumption. For instance, the table of cumulative carbon dividends
presented In exhibit 6-15, which describes the amount by which carbon sequestration under the
biomass scenario would exceed that under the fossil fuel scenario for the 2010 to 2100 period, Is
based on the assumption that these acres would not be re-cut over this period. Even assuming that
every one of the approximately 22,000 acres of private land cut for timber each year' were also
available to provide biomass, the assumption that no acre could be recut over the 2010 to 2100
period would take a cumulative 1.98 million acres offorest out of production pending carbon
resequestratlon. On a practical level, it seems unrealistic to assume that forests would be left uncut
for even much shorter periods, if only because of the difficulties of enforcement Presuming that
biomass fuel would be licensed In some way by the state, the permissibility of any source would
depend on future actions - i.e., the ongoing management of land Into the future to ensure carbon
sequestration - which seems much to ask for an already overburdened state government
The study does attempt to grapple with the kinds of protections and enforcement that would be
necessary to put in place at the state level, noting that many existing protections In forestry are
voluntary and are probably not sufficient:
Although In many cases BMPs are voluntary, water pollution control requirements
are not, and therefore landowners are compelled by law to adopt water quality
BMPs to avoid legal penalties. This may explain the relatively high rates reported
for national compliance (86%) and in the Northeast (82%) (Edwards 2002).
Biomass harvesting standards must address several management criteria such as
protection and maintenance offorest structure for wildlife habitat, soil nutrient
protection, and forest-stand productivity. These criteria, unlike those for water
quality, typically have no legal foundation to compel compliance. (p. 69)
The study concedes that the harvest scenarios upon which their results depend are probably not
realistic for other reasons, as well. For instance, the Forest Vegetation Simulator does not have the
flexibility to simulate the kinds of harvests that are actually conducted by landowners:
The impact of different silvlcultural prescriptions has been more difficult to evaluate
using the FVS model. The present set of scenarios uses a thin-from-above strategy
linked_to residual stand carbon targets for all harvests. These types of harvests
tend to open the canopy and promote more rapid regeneration and growth of
residual trees. While this silvlcultural approach may provide a reasonable
representation of how a landowner who harvests stands heavily in a BAU is likely to
conduct a biomass harvest, It Is less likely that someone who cuts their land less
heavIly would continue to remove canopy trees for biomass (unless they had an
unusual number of canopy cull trees remaining after the timber quality trees are
removed). More likely in this case Is that the landowners would harvest the BAU
timber trees and then selectively remove poor quality and suppressed trees across
all diameter classes down to about 8 inches. We hypothesized that this type of
harvest would result In a slower recovery compared to thinning from above.
Unfortunately, the complexity of this type of harvest was difficult to mimic with
FVS.
I The study states on p. 3) that an avemge of 22,000 acres of private land are harvested each year.
14
-Ie "
Although project resources were not adequate to manually simulate this type of
harvest for all FIA stands, we did conduct a sensitivity analysis for two stands with
average volumes. For each of these stands we simulated a BAU harvest removing
20% of the stand carbon, followed by removal of residual trees across all
diameter classes above 8 Inches down to basal areas similar to the target in Scenario
4. For these two stands, the results, shown In Exhibit 6-11, do Indicate a slowing of
carbon recovery profiles relative to Scenario 4, although two stands are not
enough to draw any conclusions about average impacts of this silvicultural
prescription. What can be said Is that stands harvested In this manner win
probably recover carbon more slowly than would be suggested by Scenario 4;
how much more slowly on average we did not determine; It is clear however that on
a stand-by-stand basis the magnitude of the slowdown can vary
considerably. (p. 109)
It Is unfortunate that despite acknowledging a number of uncertainties In the text, the Manomet
study stlll presents results for the time required for biomass scenarios to switch from incurring
carbon debts to providing carbon dividends as If there Is a high degree of confidence in the
modeling.
A high percentage aftops and limbs are used as fuel
Because the tops and limbs of trees harvested for timber under the BAU scenario are assumed to
stay in the forest and rot, producing carbon, the model assumes almost no carbon penalty for
collecting this material and burning it. The model assumes that 65% of ail tops and limbs generated
from timber harvesting can be used for fuel, supplying a relatively large "low carbon" source of
biomass in the model. The study states the rationale as follows:
]n order to project biomass supplies that can be used to meet potential demand
from new bioenergy plants, we have assumed that 65% of the tops and limbs from
harvested trees can be recovered on acres where silvicuitural prescriptions Include
whole-tree biomass harvests. This percentage was selected for two reasons: 1) It
leaves behind more than enough material to conform to the
ecological guidelines that have been spelled out in Chapter 4; 2) it recognizes that
a significant share of tops and limbs remain uneconomic due to timber breakage,
small pieces, and small branches. (p. 39)
However, the eco]ogical guidelines set out in Chapter 4 are quite general, an issue treated in
more detail below, and the reader is left with llttle confidence that firm ecological guidelines
have been set, much less conformed to. It seems likely that selection of65% as an allowable
level of harvest for tops and limbs, which are essentially treated as a low-carbon source of
fuel by the model, is actually necessary to achieve the switch from biomass carbon debt to
carbon dividend in a timely manner:
The harvest and use oftops and limbs for biomass can have an Important InUuence
on carbon recovery times and profiles: tops and limbs decay quickly Ineft in the
forest and so their use comes with little carbon "cost" which tends to shorten carbon
recovery times. Conversely, Iftops and limbs from a biomass harvest of cull
]5
f: -"
trees were left In the woods to decay, this "unharvested" carbon would delay
recovery times, effectively penalizing wood biomass relative to fossil fuels.(p.
109)
When tops and limbs are left on-site, all three scenarios show net carbon
losses between the initial period and the 10-year mark; in addition, carbon
losses In year 10 are substantia] relative to the recovery levels In the scenarios in
which tops and limbs are taken and used for bioenergy. (p. 110)
In other words, it seems likely that the Manomet study would not have been able to portray
biomass with even as favorable a carbon profile as it did, had a smaller percentage of tops
and limbs been considered available as fueL Given the several permutations on modeling
described in the study, It Is regrettable the study did not provide more detail about how
leaving more tops and limbs in the forest would affect net carbon emissions.
Is it feasible to collect tops and limbs? The study-in fact concludes that the practice is
economical only in conjunction with whole-tree harvesting:
As discussed in the wood supply analysis In Chapter 3, the harvest of tops and
limbs would likely be economical only when harvested witb whole-tree
systems. Biomass harvested in this manner can be used for any type of bioenergy
technology. However, biomass can also be harvested with traditional methods or
cut-to-length methods when these systems are preferred due to operating
restrictions and/ or landowner preferences. These roundwood operations tend to
be more costly, but yield higher-quality bole chips that are preferred by
thermal, CUP and pellet facilities. Importantly, leaving tops and limbs behind as
forest residues would increase carbon recovery times for bloenergy technologies
that utilize the bole chips that are produced. (p. 109)
The distinction between faclJities that use just chips from boles/ trunks and those that use whole-
tree chips Is an important one. Many small thermal biomass facilities depend on "higher quality"
wood produced from boles, wood that is cleaner-burning and more consistent in quality. Pellet
manufacture also preferentially uses bole wood. Questions of how preferentially harvesting for bole
wood wIlJ affect the total amount of trees cut for clean chips and pellet feedstock are just starting to
be explored, but given the Manomet study's endorsement of the thermal and CHP facilities that
prefer these higher quality wood sources, It is unfortunate that the study does not explore these
questions In more detaiL
Soil nutrient implications of taking tops and limbs for fuel
The tops and limbs of a tree are the repository of a large share of its total nutrients, and this low-
diameter material may actually represent a significant proportion of the biologically available pool
of soil nutrients. How much such material should be left after logging not only to maintain these
nutrient stocks, but also to protect solis against erosion and provide wildlife habitat, is the focus of
many questions concerning the responsible use of woody biomass. Regarding the importance of
leaving tops and limbs for forest ecological function, the Manomet study relies heavily on studies
from the Forest Guild, specifically the Evans and Kelty "Ecology ofDeadwood" report, which Is
Included In an appendix to the study. The Manomet study repeats the conclusions of Forest Guild
studies that there Is little consensus regarding how much material should be left:
16
< ,
A review of scientific data suggests that when both sensitive sites (including low-
nutrtent) and c1earcutting with whole-tree removal are avoided, then nutrtent
capital can be protected (see also Hacker 2005). However, there Is no scientific
consensus on this point because of the range of treatments and experimental
sites (GrlgaI2000). It is important to emphasize that the bnpact on soil nutrients
is site dependent Low-nutrtent sites are much more Ukely,to be damaged
by Intensive biomass removal than sites with great nutrtent capital or more rapid
nutrient inputs. A report on impacts of biomass harvesting from Massachusetts
suggested that with partial removals (i.e., a combination of crown thinning and low
thinning that removes all small trees for biomass and generates from 9 - 25 dry
t/ac or 20 - 56 Mgfha) stocks of Ca, the nutrient of greatest concern, could be
replenished In 71 years (Kelty etal. 2008). The Massachusetts study was based on
previous research with similar results from Connecticut (Tritton at al.1987,
Hornbeck et aI.1990). Leaching, particularly of Ca due to acidic precipitation, can
reduce the nutrtents available to forests even without harvests (Pierce et aI.1993).
However, the Ca.p mineral apatite may provide more sustainable supplies of Ca to
forests growing in young soils formed in granitoid parent materials (Yanai at al.
2005). (p.141 of Manomet report).
The Kelty study cited in the report concluded that removal of Just 9 - 25 dry tons of biomass per
acre, an amount similar to that contemplated in the Manomet harvesting scenarios, could lead to
soil nutrtent depletion that lasted seven decades. The Manomet study downplays this finding,
Instead call1ng for more study of the issue and formulation of site-specific guidance for how much
top and 11mb material can be removed:
In Massachusetts it will be Important to IdentIfY the soils where there are
concerns regarding current nutrient status as well as those soils that could be
degraded with repeated biomass harvests. (p. 75)
Despite acknowledging considerable uncertainty regarding the ecological sustainability of
removing a large proportion of tops and limbs, the Manometstudy does not present any
substantive data or nutrtent budgets to support the conclusion that 65% of tops and limbs can be
removed at all sites. However, the carbon accounting component of the study relies on at least this
much material being avallable, implicitly assuming that the maximum amount of tops and limbs can
be removed in every case.
Although the study does call for the creation of guidelInes on how much material should be retained
in the forest, there is littie discussion of how such guidelines could be practically Implemented or
the unusual amount of knowledge about a site's nutrient status and both past and future harvest
plans that would be required of foresters when deciding how much material to leave:
In areas that do not qualify as low-nutrtent sites, where 1/3 of the basal area is
being removed on a 15- to 20-year cutting cycle, it is our professional judgment that
retaining 1/4 to 1/3 of tops and limbs wlllllmlt the risk of nutrient depletion
and other negative impacts in most forest and soil types. Additional retention of
tops and limbs may be necessary when harvests remove more trees or harvests
are more frequent. Simllarly where the nutrient capital is defldent or the
nutrient status is unknown, increased retention of tops, branches, needles, and.
leaves is recommended Conversely,lfharvests remove a lower percentage of
17
,
basal area, entries are less frequent, or the site Is nutrient-rich, then fewer tops
and limbs need to be retained on-site. (p. 48)
Implementing such protections and ensuring sufficient material Is left: onslte to maintain soli
productivity would also involve foresters willlngly forgoing a revenue stream from which they
would otherwise proflt.
With regard to use of tops and limbs from timber harvests as a "low carbon" biomass fuel source,
the picture that emerges is that removal of at least 65% of this material is necessary for the
Manomet model to reduce the apparent carbon emissions from biomass, since this materia] Is
assumed to decompose anyway and thus to represent a negligible addition of carbon if it Is
combusted. However. the study Is notable to say with confldence or produce a body of evidence to
demonstrate that removal of this amount of tops and limbs wili not deplete soils or damage other
forest functions, instead stating that much more detailed study Is needed. In sum, it appears that
the goals of achieving low carbon dioxlde emissions from biomass fuel and maintaining soil
nutrient status may be incompatibie in many cases.
Biomass harvesting only occurs on land already being harvested for timber
The study takes as its BAU assumption that land is harvested for timber. and that all residues are
left: in the forest in this case, whereas a portion Is collected for fuei in the biomass scenario. The
study does no modeling and draws no conclusions concerning carbon dynamics and regrowth in
forests cut solely for biomass. Because the BAU scenario assumes that all sawlog residues are left: in
the forest, this generates a large amount of relatively "low carbon" material to be harvested as fuel
under the biomass scenario, because the FVS model treats this material as ifit decomposes
relatively quickly. Tbe fact that the study does not examine carbon dynamics in stands cut soiely for
biomass is a conslderab]e omission from the model; in fact, under such scenarios, carbon debts
would be considerably.longer than the Manomet study conciudes.
Soil carbon emissions are negligible
The soli carbon pool is extremely large, and a slgniflcant fraction of it is easily decomposed and
evolved as C02 when solis are disturbed by logging. However, the Manomet model completely
disregards this source of emissions that are associated with biomass harvesting.
Tbe study states
Our FVS model simulations captured the carbon dynamics associated with the forest
floor and belowground live and belowground dead root systems. Minerai soils
were not included In our analyses, but appear generally notto be a long-term
issue. A meta-ana]ysls published in 2001 by Johnson and Curtis found that forest
harvesting. on average, had little or no effect on soli carbon and nitrogen. However,
a more recent review (Nave et aI., 2010) found consistent losses of forest floor
carbon in temperate forest, but minerai soils showed no significant, overall
change In carbon storage due to harvest, and variation among minerai solis
was best explained by soli taxonomy.(p. 83)
]8
,
The preceding paragraph was sent to the lead author on the Nave study, to ask whether he agreed
with this assessment of his paper's conclusions. From his answer,lt seems that the significance of
the Nave paper bypassed the Manomet team. Here is Lucas Nave's answer In its entirety, as he
requested (emphases added):
"Thanks for asking about the meta-analysis paper we had in Forest Ecology and
Management. My coauthors and I went over every sentence of that manuscript to be
sure that we had the whole thing right, and now you've provided a great example of
what happens when one statement Is considered without the context of the rest of
the document.
We did indeed use those exact words: 'variation among mineral soils was best
explained by soil taxonomy.' However, we were not referring to the background
level of variation in the amounts of carbon (C) stored in different forest soils, which
is what is implied by the quote you sent (orig message below). What we were
referring to with that statement was that, when you assess the degree to which
forest minerai soils vary in their C storage responses to harvest, meta.analysis of
the entire database shows that the most Important factor controlling that
variation Is soli type (or taxonomic order). Hence, a more complete
characterization of our study results would have included discussing the two soil
taxonomic orders that consistently lost soil C after forest harvesting. and the fact
that following certain post-harvest management prescriptions can be used to
prevent those losses. In a biome-Ievel sense (ours includedall temperate forests), it
Is true to say that mineral soli C storage doesn't generally change following a forest
harvest. But that Ignores underlying complexity that matters when you're not just
talking about general concepts, but rather a specific location with an actoal biomass
haJvest/C accounting plan on the table. If our stndy Is nsed to suggest that it's not
necessary to include the minerai soli (typically the largest temperate forest C
pool) In a management plan that Includes C accounting; then It is being
misused. The authors of that section of the Manomet report wonld benefit
from closely re-reading our entire paper, which has more detailed, relevant
information concerning the effects of forest harvesting on mineral soli C
storage."
It thus appears that omitting soli carbon losses trom the Manomet model means that actual
biomass carbon debts are probably larger than the Manomet model concludes, and that
time to parity with fossil fuel emissions Is longer.
Firewood harvesting is not impacted
Although indirect land use effects can be major sources of greenhouse gas emissions trom biomass
harvest. and although the RFP for the Manometstudy requested that the study evaluate Indirect
land use effects,> the study does not acknowledge that displacement of firewood harvest by biomass
harvest could result in "leakage" offlrewood harvesting and more forestland being cut for firewood.
2 The RI'P for the sustaInabllity study published by the Department of Energy Resources states: "The analysis
will consider the carbon stack emissions of combusting biomass, the carbon absorbed by the forest growth,
and emissions associated with biomass harvesting. processing. handling. transportation, and address whether
there are any Indlrect land use Impacts and the appropriate account for the displaced carbon emissions mm
fossil foel otherwise used for energy."
19
.
To the extent that tops and branches and other low-value wood cut during timber harvesting are
currently being removed as Ilrewood, taking this material for biomass fuel could displace this
Ilrewood harvesting and lead to an overall Increase in forest cutting. The study also does not
consider the potential effects that use oflow-value wood for biomass fuel could have on Ilrewood
costs.
The study states that Ilrewood harvesting is a slgnillcant proportion of the wood removed from
Massachusetts forests. The sources of this wood, which include cull trees, dead trees, tops and
stumps of growing stock trees, overlap with the types of wood that are harvested for biomass fuel.
The Timber Product Output reports provide one estimate of fuelwood production in
Massachusetts; however, these data are derived from U.S. Census data rather than
collected directly from U.S. Forest Service surveys (the source of other TPO data).
TPO data Indicate that fuelwood production In Massachusetts In 2006 was 41.3
mUllon cubic feet (517.000 cords or 1.3 mllIion green tons), which would suggest
that It would have accounted for about 83% of the timber harvest In
Massachusetts (see Exhibit 3C-1.) According to this report, vIrtually all of the
fuelwood comes from non-growing stock sources, which Includes cull trees
(rough and rotten), dead trees, tops and stumps of growing stock trees, and non-
forestland sources of trees such as yard trees. (p. 136)
However, the study is mixed In its acknowledgement that biomass harvesting could displace
Ilrewood harvesting. stating In some places that there are no leakage effects of increased biomass
harvesting:
More Importantly for our analyses however, Chapter 6 assumes that the increase
harvest intensity for biomass energy wood doesn't change the disposition of
materials that would be harvested absent biomass extraction. (p.82)
Elsewhere, the study does seem to acknowledge that biomass harvesting could displace other uses
of wood, if not Ilrewood speclllcally, at least under a scenario where biomass is worth more:
This outlook assumes that biomass stumpage prices rise to $20 per green ton as a
result ofhlgher demand from bloenergy plants. A substantial increase in landowner
income brings more land into production. Forest biomass fuel becomes a primary
timber product, much as pulpwood is today. and we assume that bloenergy
plants can outhld their competitors for pulpwood and low-grade sawlogs and
that this material Is harvested more Intensively as well. (p.49)
The study seems to acknowledge the Impacts this CDuld have on Ilrewood harvesting on public
lands. but does not discuss this Issue for private lands:
The main vehicle for achieving the Increased biomass production on public lands
will be the diversion ofw;ood from other end uses: at the projected price levels
for biomass stumpage, bloenergy plants will be able to outbid their competitors
for low-grade sawtimber, pulpwood, and residential fuelwood. (p.S3)
However, public land is treated In the report as only a minImal potential source of biomass.
Nowhere does the study examine the question of whether increased use oflow-value wood as
20
, .
biomass fuel could increase firewood harvesting elsewhere, or whether there might be increases In
price for the flrewood resource upon which many households depend.
Wood pellet manufacture incurs no more carbon debt than green chips
Although it Is well-establlshed that manufacture of wood pellets requires significant inputs of green
wood In excess of the heating value actually embodied in the pellets produced, as well as signiflcant
fossil fuel expenditures, the Manomet study treats wood pellets as embodying the same amount of
carbon and energy as green wood chips.
Our analyses also considered the carbon debt characteristics of wood pellet
technology and CHP systems. In general, we find that carbon debts associated
with burning peDets In thermal applications do not differ significantly from
debts resulting from use of green wood chips. The differences relate primarily to
location ofGHG emissions associated with water evaporation from green wood
rather than the overall magnitude of the Iifecycle GHG emissions. (p. 106)
However, the conclusion that carbon debts wm not differ between green chip- and pellet-fueled
facilities wlll only be true If the two kinds of fuel require the same amount of tree harvesting, and
the same amount of production inputs in terms offossil fuel power, to produce the same amount of
thermal energy. Without delving into the complexities of where the energy to drive off moisture Is
expended (at the pellet plant, where wood heat or fossil fuels are used to dry the pellet material; or
in the case of green chips, In the actual combustion process), it is easy to see that this is not the case.
The pellet industry prefers the use of bole or trunk wood for pellet production, and thus requires
harvesting far more trees to acquire the same amount of wood than if whole tree chipping were
used Thus, even assuming that the only difference between green chips arid pellets was the
moisture difference in the product, the pellet industry would still require more trees to produce
product
The report cites a pellet industry-funded study' to support their conclusion that lifecycle emissions
from pellets are approximately equivalent to those from green wood chips:
Emissions for thermal pellet applications require the addition of emissions from
plant operations and for transport and distribution of pellets from the plant to the
flnal consumer. The limited analysis that we have seen for these operations (for
example, Katers and Kaurich, 2006) suggest that the increased efficiencies in boller
combustion achieved with pellets approximately offsets most of the Increased
emissions from plant operations and additional transport of pellets from the plant
to their flnal destination. (p.l04)
In fact, the energy and fossil fuels expended during pellet manufacture and drying do appear to be
considerable; where fossll fuels are used for drying, the study cited by the Manomet report shows
that drying and plant operation require about 13% of the energy Inherent In the pellet product
itself. To the extent that wood is used to provide process heat at pellet plants, this Is an additional
wood Input In the pellet manufacturing process that has not been accounted for by the Manomet
study.
· Katers. j. and Kaurich,). 2007. Heating fuellife-cycle assessment Study prepared for the Pellet Fuels
Institute, February, 2007. University ofWlsconsln, Green Bay. 54 pp.
21
.- ,.
The Manomet study also underestimates the amount of trees cut for pellet production because it
underestimates typical wood moisture content Their estimate that 1.575 tons of green wood Is
required to produce one ton of pellets at 6% moisture (p. 28), depends In part on the assumption
that the green wood chips used to make pellet fueis have a moisture content of 40%, an assumption
that does not match the standard Industry estimate of 45% moisture content for green chips. Even
the Katers and Kaurich study cited by the Manomet study Itself assumes that green wood has a
moisture content considerably higher than 40%:
Dry wood feedstock can generally be obtained from saw mill waste or other similar
industries that utilize kiln dried wood This study assumed that a dry wood
feedstock was available and drying the wood was not necessary, wbich would not
be the case for wood fuel pellets manufactured from green wood waste. Green
raw materials can oftan bave a moisture content in excess of 60%. Moisture
content will depend on time of harvest. relative humidity, as well as type of wood
harvested. For this study it was assumed that the wood had a harvested moisture
content of 55%. (p. 8, Katers and Kaurlch).
The industry standard is that at least two tons of green wood are required to generate one ton of
pellets, a calculation that Is used in the commercially available wood products database from RISI,
the global wood products information provider. The Manomet study appears to have significantly
underestimated the actual amount of trees that would be required to provide pellet fuels.
Wood from land-clearing incurs little carbon debt
The Manomet study concludes that wood y biomass from non-forestry sources, such as from land-
clearing, will not entail any greater greenhouse gas emissions than forestry wood However, no
modeling is conducted to substantiate this conclusion.
The report makes about 25 references to wood from land-clearing being a potential source of
biomass fuel, but at no point are the carbon implications of this source offueJ critically examined.
For Instance, the study states
Our carbon analysis considers only biomass from natural forests. Tree care and
landscaping sources, biomass from land clearing, and C&D materials have very
different GHG profiles. Carbon from these Sjlurces may potentially enter the
abnosphere more quickly and consequently carbon debts associated with
burning these types of biomass could be paid offmore rapidly, yielding more
Immediate dividends. Our results for biomass from natural forests likely
understate the benefits of biomass energy development relative to fadlltles
that would rely prlmarUy on these other wood feedstocks. (p. 113)
This conclusion, which Is not substantiated with any analysis, appears to rest on the assumption
thatall wood from land-clearing must decompose very quickly, as Is assumed for tops and limbs cut
during BAU harvesting. This assumption is not warranted If the current fate of wood from land-
clearing is notknown; It is also not warranted if indirect land-use effects are not taken Into account
with regard to firewood harvesting. To the extent that wood from land-clearing is currently used
for firewood, its use as biomass fuel could push timber harvest for firewood Into new areas and
result In an increase In forest cutting overall.
22
.
There Is also no consideration of the imposslbllity for wood on permanently cleared land to regrow,
which is the chief way that net emissions are considered to be reduced through time in the
conventional biomass harvesting model. In Appendix l-A, the study cltes the Regional Greenhouse
Gas Initiative (RGGI) Model Rule for the types of "eligible biomass", which, ifused at a facility,
generate emissions thatcan be deducted from the facility's total:
Elfgible biomass includes suswlnably harvested woody and herbaceous fuel sources
that are available on a renewable or recurring basis (excluding old-growtJl timber),
including dedicated energy crops and trees, agricultural food and feed crop residues,
aquatic plants, unadulterated wood and wood residues, animal wastes, other clean
organic wastes not mixed with other solid wastes, biogQS, and other neat liquid
biofuels derived from such fuel sources (quoted from the RGGl Model Rule, p. 122 of
Manomet report).
There is no discussion within the Manomet report of how wood from permanent land-clearing can
be considered "available on a renewable or recurring basis' as required under RGGI. Given that
biomass facillties currently proposed in Massachusetts are claiming they will use wood from land-
clearing as fuel, this is a serious omission in the report.
CONCLUSIONS
As disruptive as the results of the Manomet study could ultimately prove to the biomass industry,
the study's conclusions actually likely significantly under-represent the actual carbon impacts of
biomass energy. The conclusions that small-scale thermal and eHP biomass applications can repay
carbon debts and yield carbon dividends relative to fossil fuels by 2050, and that net emissions
from utility-scale biomass power exceed even those from coal after forty years of regrowth, rely on
a number of assumptions that minimize the apparent emissions from biomass. These include
assuming that large trees, rather than understory cull trees, are used as biomass fuel; that stands
cut for biomass are not re-harvested until carbon resequestration has been achieved (a process that
requires these stands be locl<ed up from harvesting for decades); that only those lands already cut
for timber are harvested for biomass; that a large proportion of "low-carbon" tops and limbs from
timber harvesting are available for biomass fuel and that removal of this amount of material wlll
not harm forest ecological function; that soil carbon emissions do not increase with harvesting; that
indirect land use effects, particularly leakage of firewood harvesting. do not occur; and that pellet
manufacturing does not incur a greater carbon debt than using green wood chips for fuel. ]n some
cases, the report itself acknowledges that these assumptions are not likely Justified; in other cases,
the report Is unfortunately silent on acknowledging the complexity of the carbon equation.
Even malting these assumptions, the Manomet study concludes that net biomass emissions at
utility-scale facilities still exceed those from coal after forty years, and are dramatically higher than
emissions from natural gas. The lesson for New England, which generates much of its power from
natural gas, is clear - relying on utility-scale biomass power to provide electricity to the grid causes
a net increase In carbon emissions which undermines the emissions reductions goals of the
Regional Greenhouse Gas Initiative. The best result that the Manomet model can produce for
biomass performance relative to fossil fuels is that biomass carbon dividends in 2050 are on
average 17% greater than from oil for small-scale thermal and eHP applications (averaging over
the six modeled harvest scenarios) - a result that probably also underestimates actual greenhouse
gas emissions from biomass power. In other words, this result depends on waiting 40 years to
achieve a reduction in net greenhouse gas emissions that is at best Is an extremely optimistic
23
If J
scenario, and likely within the range of model error. given the many assumptions upon which the
modeling relies. Over this 40 year period. much may happen to forests. Permanent forest loss due
to development is continuing apace at about 5,000 acres per year In Massachusetts, and climate
change, Including potential effects of warming stress and Invasive insects. may increasingly
threaten forest carbon sequestration. The results In the Manomet study should thus be viewed by
policy-makers as an extreme best-case scenario unlikely to be achievable in reality, and any policy
designed to promote small-scale thermal and CHP biomass should be further evaluated with
modeling that makes more critical and realistic assumptions. Further promotion of utility-scale
biomass should be discontinued Immediately as a threat to climate, and forests.
24
.
,
@
May 17, 2010
The Honorable Nancy Pelosi
Speaker
U.S. House of Representatives
235 Cannon House Office Building
Washington, DC 20515-0508
Fax: (202)225-4188
The Honorable Harry Reid
Majority leader
United States Senate
522 Hart Senate Office Building
Washington, DC 20510-2803
Fax: (202)224-7327
Dear Speaker Pelosi and Majority leader Senator Reid,
We write to bring to your attention the Importance of accurately accounting for carbon dioxide
emissions from bloenergy In any law or regulatlon designed to reduce greenhouse gas emissions from
energy use. Proper accounting can enable bioenergy to contribute to greenhouse gas reductions;
Improper accounting can lead to Increases In greenhouse gas emissions both domestically and
Internationally.
Replacement of fossil fuels with bioenergy does not directly stop carbon dioxide emissions from
tailpipes or smokestacks. Although fossil fuel emissions are reduced or eliminated, the combustion of
biomass replaces fossil emissions with Its own emissions (which may even be higher per unit of energy
because of the lower energy to carbon ratio of biomass). Bioenergy can reduce atmospheric carbon
dioxide If land and plants are managed to take up additional carbon dioxide beyond what they would
absorb without bloenergy. Alternatively, bloenergy can use some vegetative residues that would
otherwise decompose and release carbon to the atmosphere rapidly. Whether land and plants
sequester additional carbon to offset emissions from burning the biomass depends on changes both in
the rates of plant growth and In the carbon storage In plants and solis. For example, planting fast-
growing energy crops on otherwise unproductive land leads to additional carbon absorption by plants
that offsets emissions from their use for energy without displacing carbon storage In plants and soils. On
the other hand, clearing or cutting forests for energy, either to burn trees directly in power plants or to
replace forests with bloenergy crops, has the net effect of releasing otherwise sequestered carbon into
the atmosphere, just like the extraction and burning of fossil fuels. That creates a carbon debt, may
reduce ongolng carbon uptake by the forest, and as a result may Increase net greenhouse gas emissions
for an extended time period and thereby undercut greenhouse gas reductions needed over the next
several decades'.
Many international treaties and domestic laws and bills account for bloenergy Incorrectly by treating all
bloenergy as causing a 100",1, reduction In emissions regardless of the source of the biomass. They
perpetuate this error by exempting carbon dioxide from bioenergy from national emissions limits or
from domestic requirements to hold allowances for energy emissions. Most renewable energy standards
for electric utilities have the same effect because bloenergy Is viewed as a renewable energy even when
the biomass does not eilminate or even reduce greenhouse gas emissions. This general approach
. J. Fats"'ne, J. HID, TUman D., Polasky 5., Hawthorne P (2OO81,land Clearing and the BIofueI Carbon Debt, _ 319:1235-1238
, ~
appears to be based on a misunderstanding of IPCCguldance2. Under some scenarios, this approach
could eliminate most of the expected greenhouse gas reductions during the next several decades.
U.S. laws will also influence world treatment of bioenergy. A number of studies In distinguished journals
have estimated that giobally improper accounting of bioenergy could lead to large-scale clearing of the
world's forests'.
The lesson is that any legal measure to reduce greenhouse gas emissions must include a system to
differentiate emissions from bioenergy based on the source of the biomass. The National Academy of
Sciences has estimated significant potential energy production from the right sources of biomass'.
Proper accounting will provide incentives for these sources of bioenergy.
Sincerely,
2 T.D. Searthlnger, S.P. Hamburg,J.MeJiIfo, W. Chameldes, P.Havlik, D.M. Kammen.G.E. likens, R. N.lubowskJ, M. Obersteiner, M.
Oppenheimer, G. P. Robertson, W.H. Schlesinger, G.D. TIlman (2009), fixlng a Crftical Climate Accounting Error, ScIence 326:527-528
3 E.g., J.M. Mef:lillo, J.M. Reilly. n.w. KlekIlghter, A.c. Gurgel, T.W. Cronin, S. Patsev, as. Felzer, X. Wang. CA Schlosser [2(09), Indirect
Emissions from Biofuels: How Importantjl, Sdence 326:1397.1399; Marshall Wcse. Katherine Calvin, Allison Thomson, leon Darke, Benjamin
Bond'Lamberty, Ronald Sands, StevenJ. Smith, Anthony lanelos,lames Edmonds (2009),lmplJcatlons of Umltlng CO2 ConcentratIons for Land
Use and Energy,Sdent:a 324:1183-1186
It Natfonal Research Councll (2009), UquidTransportation Fuels from Coal and 8i0m0ss: TedmoIoglcal Status, Costs, and Environmental Impacts
(National Academy of SQe~. Washington, D.C.)
!" ~
WIUIam H. 5chIeslnger
(Member, National Academy of ScIences)
President
(Past President, Ecoleglcal SocIety of America)
Cary Institute of Ecosystem Studies
Mmbrook, New York
MIchael ADen
Director of the Center for Conservation Biology
Chair of the Department of Plant Pathology and
Microbiology
Unlverslty of California, RIverside
Riverside, California
VIney P. AneJa
Professor AIr Quality
Professor EnvIronmental Technology
Department of Marine, Earth, and Atmospheric
ScIences
North Carolina state University
Raleigh, North Caronna
GaryW. Barrett
Eugene P. Odum Chafr of Ecology
Odum School of Ecology
University of Georgia
Athens, Georgia
Mark Battle
Associate Professor
Physics & Astronomy
Bowdoin Cotlege
Brunswick, Maine
Sharon BIIUngs
Associate Professor
Department of Ecology and Evolutionary
Biology
Kansas Biological Survey
lawrence, Kansas
Mark A. Bradford
Assistant Professor of Terrestrlal Ecosystem
Ecology
Yaie School of Forestry and Environmental
Studies
Yale University
Donald Kennedy
(Member, National Academy of ScIences)
Bing Professor Environmental Science and
Policy
President, Emeritus
Stanford University
stanford, California
New Haven, Connecticut
PhIl CamHI
Rusack Associate Professor of Environmental
Studies
Earth and oceanographic ScIence Director,
Environmental Studies
Bowdoin College
Brunswick, Maine
E1Dott Campben
AssIstant Professor
School of Engineering & Sierra Nevada Research
Institute
University of California, Merced
Merced, California
Joseph CraIne
AssIstant Professor
DMslon of Biology
Kansas State University
Manhattan, Kansas
Stephen R. Carpenter
(Member, U.s. National Academy of ScIences)
Director and Professor
(Past President, EcologIcal Society of America)
Center for Umnology
University of Wisconsin
Madison, WIsconsin
SalUe (Penny) Chisholm
(Member, National Academy of ScIences)
Martin Professor of Environmental Studies
Massachusetts Institute ofTechnology
Cambridge, Massachusetts
eric ChMan
(Shared 1985, Nobel Peace Prize)
Dlrecl:or
Center for Health and the Global Environment
Harvard Medical School
Cambridge, Massachusetts
Norm Christensen
(Past President, Ecological Society Amerlal)
Professor of Ecology
Nicholas School of the Environment
Duke University
Durham, North Carolina
James S. Clark
Hugo Blomquist Professor
Nicholas School of the EnvlronmentfDept
Biology
Duke University
Durham, North Carolina
Jon CpIe
Distinguished Senior ScIentist and G.E.
Hutchinson Chair
Cary Institute of Ecosystem Studies
Mlllbrook, New York.
Gretchen C. DaUy
(Member, National Academy of Sciences)
Stanford University
Stanford, California
FrankP. Day
Professor of Biological ScIences and Eminent
Scholar
Old Dominion University
Norfolk, VIrginia
Seth DeBolt
AssIStant Professor
Horticulture Department
University of Kentucky
Lexington, Kentucky
, ~
Evan H. DeI.uda
G. William Arends Professor of Integrative
Biology & Director,
School of Integrative Biology
University of IHlnols
Urbana, illinois
SamlrDoshI
Gund Institute for E<:ological Economics
University of Vermont
Burlington, Vermont
Dr. Charles T. DrIsalIl
(Member, National Academy of Engineering)
University Professor
Department of Civil and Environmental
Englneerlng
Syracuse University
Syracuse, New York
Paul R. EhrDch
(Member, National Academy of ScIences)
Bing Professor of Biology and
President, Center for Conservatlon Biology
Stanford University,
Stanford, Callfornla
James Eblerlnger
Distinguished Professor of Biology
Dlrecl:or, Global Change and Ecosystem Center
University of Utah
Salt Lake CIty, Utah
erie c. Ellis
Assodate Professor
Department of Geography & environmental
Systems
University of Maryland, Baltlmore County
Baltimore, Maryland
Paul R. EpsteIn, M.D.
Assodate Director
Center for Health and the Global Environment
Harvard Medical School
Boston, Massachusetts
! ,t,
Paul Falkowski
(Member of the National Academy of Sciences)
Board of Governors' Professor
MarIne, Earth and Planetary ScIences
Rutgers University
New Brunswick, New Jersey
Adrian fInzI
AssocIate Professor
Department of Biology
Boston University
Boston, Massachusetts
Andrew J. Friedland
The Richard and Jane Pearl Professor In
Environmental Studies
Chair, Environmental Studies Program
Dartmouth College
Hanover, New Hampshire
James N. Galloway
Department of environmental ScIences
University of Virglnla
CharlottesvUle, Virginia
Frank S. GUUam
Department of Biological Sciences
Marshall University
Huntington, West Virglnla
Christine L Goodale
Assistant Professor
Department of Ecology & Evolutlonary BIology
Cornell University
Ithaca, New York
Nancy 8. GrImm
(Past PresIdent, ecological Society America)
Professor.
Department of Biology
Arizona State University
Phoenix, ArIzona
Peter M. Groffman
SenIor ScIentist
Cary Institute of Ecosystem Studies
MlRbrook, New York
Nk:k M. Haddad
AssocIate Professor
Department of BIology
North Carolina State University
RaleIgh, North Carolina
Charles A.s. HaD
College of environmental Science and Forestry
State University of New York
Syracuse New York
John Harte
Professor of Ecosystem Sciences
Energy and Resources Group
University of California
Berkeley, CalifornIa
Harold Hemond
W. E. Leonhard Professor of CIvIl and
Environmental Engineering
Massachusetts Institute of Technology
Cambridge, Massachusetts
Sarah Hobble
AssocIate Professor
Department of Ecology, Evolution, and Behavior
University of Minnesota
Minneapolis, Minnesota
KIrsten Hofmockel
Department of Ecology, Evolutlon, &
Organismal Biology
Iowa State University
Ames, Iowa
R.A. Houghton
Deputy Director and Senior Sclentist
Woods Hole Research Center
Falmouth, Massachusetts
Benjamin HouJton
AssIstant Professor, T errestrfal Biogeochemistry
Department of Land, Air and Water Resources
University of California at Davis
Davis, California
Robert W. Howarth
David R. Atkinson Professor of Ecology and
Environmental Biology
Cornell University
Ithaca, New York
A. Hope Jahren
Department of Geology & Geophysics
University of Hawaii
Honolulu, Hawaii
Dan Janzen
DiMaura Professor of Conservation Biology
University of Pennsylvania
Philadelphia, Pennsylvania
Daniel Kammen
Class of 1935 Distinguished Professor of Energy
Professor in the Energy and Resources Group
and in the Goldman School of Public Policy
Director, Renewable and Appropriate Energy
Laboratory
University of California, Berkeley
Berkeley, California
WIIDam s. Keeton
Associate Professor
Center for Natural Resources
Rubenstein School of Environment and Natural
Resources
University of Vermont
BurDngton, Vermont
Thomas H. Kunz
Professor and Director
Center for Ecology and Conservation Biology
Department of Biology
Boston University
Boston, Massachusetts
BevmlyLaw
Professor, Global Change Forest Sclence
Department of Forest Ecosystems & Society
College of Forestry
Oregon State University
Corvallis, Oregon
t. ~
John LIchter
Assodate Professor
Department of BIology
Bowdoin College
Brunswick, Maine
Gene E. Ukens
(Member, National Academy of ScIences)
Distinguished Senior Sclentist
(Past President, Ecological SocIety America)
Founding President, Emeritus
[Recipient, 2005, National Medal of Sclence)
Cary Institute of Ecosystem Studies
Millbrook, New York
Thomas loveJoy
Heint Center Biodiversity Chair
Heinz Center for Environment
Washington, D.C.
Daniel Markewltz
Assodate Professor
Warnell School of Forestry and
Natural Resources
University of Georgia
Athens, Georgla
Roz Naylor
Professor, Environmental Earth Science;
WIlliam Wrigley Senior Fellow, and
Director, Program on Food Security and the
- Environment
Stanford University
Stanford, California
Jason Neff
Assodate Professor
Geological Sciences and environmental Studies
University of Colorado at Boulder
Boulder, Colorado
Michael O'Hare
Professor of Public Policy
Goldman School of PubUc Policy
University of California at Berkeley
Berkeley, CaUfomla
., ,
Scott OUInger
Associate Professor of Natural Resources
Complex Systems Research Center
Institute for the Study of Earth, Oalans and
Space
University of New Hampshire
Durham, New Hampshire
Michael Oppenheimer
Albert G. Mflbank Professor of GeoscIences and
International Affairs
Woodrow WIlson School
Princeton University
Princeton, New Jersey
Margaret A. Palmer
Professor and Director
Chesapeake BJologlcallab
University of Maryland
College Park, Maryland
Todd Palmer
Department of Biology
UnIversltyof Florida
Gainesville, Florida
RIchard P. PhDUps
Assistant Professor
Department of Biology
Indiana University
Bloomington, Indiana
StuartPlmm ,
Doris Duke Professor of Conservation Ecology
Nicholas School of the Environment
Duke University
Durham, North Carolina
jennifer S. Powers
Assistant Professor
Department of Ecology, Evolution & Behavior
University of Minnesota
Minneapolis, Minnesota
JamesW. Ralch
Professor
Department of Ecology, Evolution & Organlsmal
Btology
Iowa State University
Ames, Iowa
Chantal D RaId
Assistant Professor of the PractIce
Department of Biology and
Nicholas School of the Environment
Duke University
Durham, North Carolina
WIDIam A. Ralners
Professor of Botany and
J.E. Warren Professor of Energy and
Environment
University of Wyoming
laramie, Wyoming
Heather Reynolds
AssocIate Professor
Department of Biology
Indiana University
Bloomington Indiana
G. Philip Robel bOil
University Distinguished Professor
W.K. Kellogg Biologk:al Station and
Department of Crop and Soli Sclences
Michigan State University
Hickory Comers, Michigan
Steve Running
Regents Professor and Director,
Numerical Terradynamlc Simulation Group
Department of Ecosystem Sciences
University of Montana
Missoula, Montana
lee Schipper
Project Scientist
Global Metropolitan Studies
UC Berkeley
And Senior Research Engineer
Precourt Energy Efficiency Center
Stanford University
.. I).
Stephen H. Schneider
(Member, National Academy of ScIences)
Melvin and Joan lane Professor for
Interdisciplinary Environmental Studies,
Professor, Department of Biology and
Senior Fellow, Woods Institute for the
Environment
Stanford University
Stanford, California
Dan Sperling
Professor and Director
Institute of TransportatlPll Studles
University of California
Davis, California
H.H. Shugart
W.W. Corcoran Professor
Department of Environmental ScIences
University of Virginia
Charlottesville, Virginia
jennifer L Tank
Galla AssocIate Professor of Ecology
Department of Biological ScIences
University of Notre Dame
Notre Dame, Indiana
Pamela Templer
Assistant Professor
Boston University
Boston, Massachusetts
Kirk R. Smith
(Member, National Academy of ScIences)
Professor of Global EnvlrPllmental Health
Director, Global Health and EnvIronment
Progr&m
School of Public Health
University of California
Berkeley, CalifornIa
JohnTerborgh
(Member, National Academy of ScIences)
Nicholas School of the Environment
Duke University
Durham, North Carolina
Robert Socolow
Department of MechanIcal and Aerospace
EngIneering
Director of the CarbPll Mitigation Inltlatlve
PrlncetPll University
Princeton, New Jersey
Thomas P. Tomich
W.K. Kellogg Endowed Chair In Sustainable Food
Systems
Director, UC Davis Agricultural Sustainabillty
Institute
Director, UC SUstainable Agriculture Research
and Education Program
Professor of community Development,
Environmental Science & Policy
University of CalifornIa
Davis, Caiifornia
Stanley D. SmIth
AssocIate Vice President for Research
Professor of ute Sclences
University of Nevada
Las Vegas, Nevada
John Sperry
Professor
Biology Oepartment
University of Utah
Salt lake CIty, Utah
Alan R. Townsend
Professor, Institute of ArctIc and Alpine
Research and
Department of Ecology and Evolutionary
Biology
Director, Environmental StudIes Program
University of COlorado
Boulder, COlorado
.
Ross A. Virginia
Myers Family Professor of Environmental
Science
Director, Institute of Arctic Studies
Dartmouth College
Hanover, New Hampshire
Thomas R. Wentworth
Alumni Distinguished Undergraduate Professor
of Plant Biology
North Carolina State University
Raleigh, North Carolina
Diana H. WaD
(Past President, Ecological Society of America)
University Distinguished Professor
Director, School of Global Environmental
Sustainabllity
Colorado State University
Fort Coliins, Colorado
Donald R. Zak .
Burton V. Barnes Collegiate Professor of Ecology
University of Michigan
Ann Arbor, Michigan
Matthew Wallenstein
Research Scientist
Natural Resource Ecology laboratory
Colorado State University
Fort Collins, Colorado
Cc: Carol Browner, White House Office of Energy and Climate Change Policy
Lisa Jackson, Environmental Protection Agency
Steven Chu, Ph.D, Departme'nt of Energy
John Holdren, Ph.D, President's Council of Advisors on Science and Technology
complcment prior snldies tllllt highlight the
importance of short- and medium.lived pol-
lumats (14-17).
The top 10 pollutant-gencrating uctivities
contributing to net RF (positivc RF minus
n"b>ntivc Rf) in year 20 arc shown in tile bot-
tom chnrt. page 526), wltich mkes into account
the emission of multiple pellutants from each
source activity (18). The seven sources that
appear only on thc left side (purplc bars)
would be overlooked by mitigdtion strategies
fOClL,ing exclusively on long-lived pollutants.
The distinctly different sources of near-
term and long-tenn RF lend themselves to
the aforcmentionnd lWOi>ronged mitigation
approach. TIlis dccoupling is convenient for
policy design and implementation; whercns
the imporrnnce of long-term climatc stnbi.
lization is clear, the perceived urgency of
ncar~tcml mitigation will evolve with our
knowledge oflhe climate system. Addition-
ally, optimal near-tcnn mitigation strategies
will reflect decadal oscillations (19), seasonal
and l"b~ona] variations (20. 21). and evolv-
ing knowledge of aerosol-climate effects (22.
23) and methane-atmosphere intemctions
(22). ..considcmtions unique to the near term.
TItus, short. and medium-lived sources
(black carbon, tropospheric ozonc, and
mctbanc) must be l"b'lllaled sepamtely and
dynamically. TIle long-term mitigation ti'eaty
should focus exclusively on steady reduction
of long-lived pollumnts. A separate treaty
for short- and medium-lived sources should
ine1nde .'ta11dards Ulat evolve based on peri-
ndie recommcndations of an indcpendent
hltcrnational scientific panel. TIte from.work
of "best available control technology" (strict)
and "lowest achievable emissions rate"
(slrictcr) from the US. ClcaaAirAct(24)cau
he used as a mudd.
Such a two-pronged ins1itntional frame-
work would reflect Ule c'Volving scientific
understanding of ncar-term cliD1llte change,
the scientific certainty around long-tenn cli-
mute change, and the opportunity to sepa-
mlely adjust UIC pace of near-tcnn and long.
tcnn mitigation efforts.
Referentes and N_
1. D.A.rcheretal..AmW.Rev.Et11thPiDntt.5ri 37.117
(200'>).
2. Thee-foldlngtlme{requiredrodecreasetu31%1>forlgi-
nalaltborne amounO is on the order of days tnweeks for
sh.rt-lWed polIu_le.g.. b1ackanrl org;mk_
tropOSpheric o:one. and sulfur dio:dde). a decade for
medium-lived (e.g., mrilane and.some hat<<arbons),
anrlacetJtuTyfutlong-liYed fe.g., nilrOUS01ide. some
baloc.atbons). eOl takesroughly a centuJy to reatb 3JOh,
then decays I'llOl"e stowly over mH1eJlnia.
3. ('P'Al<Mu1len,).l'b"""'.&I,.C1imnleC_Sdence
Compt!1)dium2fJ(J9(U.N.Enviror4nentProgfilmn~Nid1obi.
_Prlnr,2OO9);_.org1<anpendlum2Oll91.
4. S. Solomonetal., Oimt'lteOmnge 2007: The Physico]
Science Basis: (on!ributftm oj Werking Group I te the
F<mnh Assessment Repqrl fJ/ the {PC( (Cambridge Unw.
Press. New York, 2007).
5. s. Rahmstod e1 01., Science 316,709 (2007).
6. }. B. Smith etal.,Proc. NtJtl.At11d. Sri U.s.A 106. 4133
(2009).
1. A. Sokotovetol.,). C11m. ZZ: 5115 (2Q09).
8. t Stocker. Qwt. SeL Rev. 19. 301 (2000).
9. T.M.lentone1al.. Pr<<.Natt.Acad Sd. USA 105,
1786 (2008).
10. ).Ilal$en "'oJ.. OpenArmos. Sd1. ~. ~17 l20D8).
11. RFlsapropertyoftheclima:reatapoirdintime.
Increases in Rf create pfanetaty en~illlbalanre, with
more In<omlng snlnr radiation than outgoinll hllrarerl
radlotlnnanrlawannlngellectnnlh>system.
12. 1. F. Stoder. A. Sdmtittnet, Nature 388. 862 (1997).
13. R. B. Alley et 01.. Science 299.2005 (2003).
14. J.Hanse11etal..PhItt'iS. Tram. R.5Dc. l.DndOllSet.A 365.
19~5l2l107).
15. P.I(. Quinnff m..AlmDS. Chf!fTJ. Phys. 8.1723 (2OOa).
th. M.~.)n<nbsnn.JGeophys.R"'A/mOS.107."19
llOO2J.
17. F. <.Mnnre, M. c. Ma(Cra<kerl.In/l.J S/trIteglc(honge
_.1. 42 (2009).
16. D.~, T. CBond. D. Streets, N. Ung~. Geophys. Res.
Left. 34.lOS821 (2007).
19. It Trenberth etal..l:n(4), pp. 235-336.
20. D.-Koch, T. Bond. O.Streets. N.UngeJ. G. vanderWerf.}.
6ecphys. Res. 112. 002~05 (2007).
21. A. Stnbl, J GeopIJrs. Res. 111, 0113116 (21)06).
22. P. Fnrster '" d. m (4). pp. 129-234.
23. V. Ramanathan. G. Carmk:bael Ntl1. Geosd. 1. 221
llOOB).
24. V.s. Clean Air Act. mw.epa.gO'ltlaar/c.aal.
CLIMATE CHANGE
...-r-'" "
(t~)
POLlCYFORtJM
2S. Tbf! sam~ allillysis applied to the lP<es SRE5 marker
scenarios tAl. Al. B1. and 82) (26) producesmults that
taU largely within the bDunds of these tml scenario$ (fi!I.
511.
26. N. Nakit~t. R. Swart, Eds.. Special Report on Emis-
~..._ (JP((,Cnm_ UnIv. """ Cam-
bridge, 2000).
27. DatafayearZOOORfambasedon(14).emissfonsilte
from (28). decay I'attS am based on tbe lifetimes on p. 212
in (22) and hlstorlcat C01 decay is cmwlated a(Cording to
p. 824 In (29). GtOl'lth rates. are from f28}am1 (JO).Zero
groMb of emissions assumed for Be. OC, SOl' and f'talo.
carbons Eac!lyear'sRffor sftoJHivai pollutants (ar. ac,
0,. SO}isdueonlyto emiss10nsln that year; thus. theRf
does nota<<UtlWlatefromQJ'leyear to tbellelt. Theron-
tributions of bla<k carbon and 020J'te8re-(onsavatlve. as
tha'l do net reflect ment uear..([oub!eestimates of black
carbon's Rf (23) Illfrecen! estimates of ozone's Indlred
tandslnkeffect (JIJ.
28. ElJGAR3.~(_p.nII_lrendclll.
29. 6. Meehl et at. in (4), pp. 747-845.
30. QimateAnalysls Indicaton Tool v6.0 (bttp:flcaiUni.org).
3L S. Sitcb. P. M. Cot. w. J. Collins. C. Huntingford. Nctuft
448, 791 (loo]).
32. t C. Bond e1 oJ., Global ~wn. Cyr/e$ Z1. 682018
(2007).
33. n1e <luthl)t tbanksJ. Harte for prarlding encouragement
anrlaitlq",.
Supporting ant.,. Material
vmt!Lscle-ncemag.crylcgi/contentlfuUl326159521526lDC1
10.1126&ien<e.1177042
Fixing a Critical Climate
Accounting Error
TOJIotby D. Searchloge~1' SI8Vll1l P. Humburg," Jony Melillo.' William Chamoides,'
P8Ir HD1Ilik.' DODiol M. Kammon.' G008 E. l.ikoll8,' Robon N.l..ubowskl.' Miclmel Oboraleioor,'
Mioboel Opptloheimor,' G. PhIlip Robmtson.' William H. SeIllesiagerl G. DavId liimoo'
Rules for applying the KyollJ Protocol and national cap.and.trade laws contain a major.
but flxable. carbon accounting flaw In assessing bioenergy.
not count changes in emissions from land
use when biomass for energy is harvesled or
grown. TIt;s nccounUng erroncously trcalB all
biocncrgy as carbon neutral regardless ofUle
source ofUle biomass, which may cause large
differences in net emissions. For example, the
clearing of long-cstablished forests to burn
wood or to grow energy crops is counted as a
100"10 reduction in energy emissions despite
causing large releases of carbon.
Sevcral recent studies cstimate that ulis
error, applied globally, would create strong
incentives to clear land as carbon caps
tighten. One study (2) estimated thaI a global
CO, targct of 450 ppm undcrthis accounting
would cause biocne'b'Y crops to expand to
displacc virtually aU the IVorlds nalural for.
ests and savannabs by 2065. releasing up to
37 gigalOns (Ot) of CO, per year (comp&-
www.sciencemag.org SCIENCE VOl.326 23 OCTOBER 2009
l'ublkhedl!YMAS
527
The accounting now used for assessing
compliance will, carbou limits in thc
Kyoto Protocol ond in climate legisla-
tion contuins a fdt'.rcuching bul fixable flaw
tbat will severely undcnninc greenhonse
gas reduelion goals (1). It docs not count
CO, cmilled from tailpipes and SI1lokcstncks
wllCO hioencrgy is being used. but it also docs
lPrlttCeton University, Princeton, NJ 08544, USA. 1Environ.
mental Defense Fund, Boston. MA 02108. and Washing--
ton, 0( 20009, USA. )Marine BfologitallabotatoJy, Woods
Hole. 1M 02543. USA. .Duke University, Durham, NC
27708, USA. ~tnternationat Institute for Applied Systems
Analysis, Laxenburg 2361. Austria. 6UoiveJSily of Califor'
nla.t Berkelay. Berkelay. CA 9472O.lJSA. 'Ca/Y Institute nf
Ecosystem Studies. Millbrook. NY 12545. USA. $Michig.m
Stare University, Hkkory Comers. AU 49060, USA. 9Univer~
sily .llllmn-.. St PnuI./IIN S5108. USA.
*Authors for correspondence. E.maU: shamburg@edf.org
(S.P.H.); l1eard1i@prln<eIl1n.edu(tO.S,).
I pdLlCYFORUM
rable.to toilll humnn CO, emissiOilS today).
AnOlher wily predict$lhal. based. wlely OIl
economic cOl\SidernlloilS, hioencJl!y .could
displace 59% of the world's llBIurallbresl
.cover lUld rei..... an additlonal 9 Gt of CO,
per yea( to achieve a 5O"!.t .eUl~ In green-
house ~ by 2050(3). Thercason: Whlm
bllJl;acrgy frolllBnY biomass is counted lIS
catb<ln neutnd. tconomics favor large-scale
land c:onvetSlbD for bioene'W tegIlI'dIcss of
thc aCl\l8I net emis$jbDs (4).
The potential of biocnergy to reduce
gn:enhouse gasemissionsinherenily depends
enlbesourreofthebioJllllSl<and ilSlIellimd-
liseelfects. Replacing fussil/iJe1s with bi<)"
ene.tioes not by itself rednee carbon
emissions, because dlOCO, rel....d by tail-
pipes lUld smoke:llaCk5 is roughly the SlU1lIl
pet unit ofenelj;yregatdJcssQflhe souree
(1, 5), Emissions. from pti;\dJleinll andlor
refiniag bio/iJelsalsn typlcallyClleeed those
fOr petroleum (J, 6). Bjocnergy therefore
reduces gnlIl1\house emissions only iflbe
growth nnd harvesting of the biom!lSS for
""ergy CllptureS carbon abqye and beyond
Whal would be sequestcrc<l anyway and
Ihereby offsets emissions ftom CI1CIJlY use.
This additional carboa mnyresuJt from
landntilllBgl1menl changes thlll increase
p1anlllptake or from the use ofbiOJnass
tbat WOuld olherwise decompose rapidly.
Assessillllsucb carbon gains requires the
SlIme aeeolDlllng principles used 10 assign
credits for olbt:r laIld-based carbon ofli<cls.
Foro:<mnple, If unproductive land Stlp-
ports fast-growing grasses for bfocncrgy,
or if forestry improvemeDlS increase Iree
growlh rale&, tho additional carboa absorbed
offill,ts emissions wben burned for energy.
EnelJlY use of manure or crop Ilnd limber
residues may also capture "addllional" car-
bon. Ho\V~er, harvesting wslll!1! foroslS
for clectricity adds net carbon to the air.
ThaI remains lrlIC cvetf if limited barves1
mles lcavetheoarbon stoelu<ofrcgrowtng
foresls uneba1'Jge~l1eeallSc IbO$ClltO<:ks
lVOuld olherwlse IirorelIse lUld wntrlbute to
the Il:lTeSlrial carbon sink (/). If biocnelJlY
crops displace forest..... gJ;lISSlund. dlCc:ar-
bon rolCllscd ftom soils atId vegetation. plus
lOSt future sequestraliou,gencrnlCS carbon
debl. wbieh counts againsl the earboo the
crops absorb (7, 8~
The InlergoVernmelllal Punel on Climate
Change (IPcq h;Js long realized tbat. bie-
C1IC'W$ greenhouse effeel;l vary by sonree
of biomass Ilnd land......effCets. It also roc..
lI!!ffizes that when foreat& or olhcr planis are
harvested for bilJl;aergy.lbe n;suItingCllrboa
rolc:ase mast be eouDled either lIS land-use
emissions or energy emIssions bnt nol bolh.
To avoid doubl(M:nuntlng. the wec assigns
the CO, to the Iand-USCJll;COunls nod exempts
bioenergy emissiollS frgtD llOl'IJlY m:conots
(5). Yet il warns. beoause"fossil!ltelsubstllo-
tlon isalready'l'eWIIt'dl:d- by tbis exemptlon.
"to avoid ~tliJ1g . .. any changes In
biomass stoeks .m Innd$. ... resUlting from
the prod~on ofbiofnels would need to be
lneiudCd iathe uccounts"(9).
This symmetrical appt'Olll:b '\Wrks fur
the reporllngunder Ibe UIritedNutlous
Framework Convemion on Climate Change
(UNFCCC) because vlrtnnlly all conolries
report emlssious ftom both land Ilnd euclJlY
ose. For example. if fOrests arc elCllrcd In
So~1 Asia 10 produte palmbiodlcsel
burned lnl!IlI'GJlC, fll1nlJ'O ~ exclude Ihe
lailpipe emissions lISAsln ll:j)ort& tJlC large
oet carbon release as Inrid-use emissions.
HOWCVCf, exemptlng emissinns liortt bin-
.eaergyuscis improper for greenhouse gas reg-
ulatlonS ifland-use emissions are not included.
The Kyolo Prolocol caps the energy emis-
sions of deyeJopc<l <>>untries. Butlbeproto-
eol applies IlOlImIts to land use or any other
emissions liortt develnpiog countries, lUld spe-
clnI erodltlog ru1es for "forest l11lUlUIlement"
allow developedeounlriellto ~ out dIcit
own land-use emissions as well (1, If)~ 111DS,
malntaintng the excmptlon furCO,emi1lcd by
mocuC'W use under the prolocol (I /)wroll!llY
_ blocUClJlY liortt aU biomass sourecsns
earbPl> D.eutral. even if the source involves
eJ~furests for electricity in Europe or
eonvertbtgthem to blodiesel crops in Asia .
Tb1stU:cotmtlng error halloarricd overinto
lbe European. Unions cap-and-trade law nod
the climate billpnssed by tllC U.S. House of
RepreSentatives (I, 11. /j). Both regulate
emissions from energy but nol lnod use Ilnd
lhen errollCOllsly ~ CO, emilled from
blllCJlClJlY use. ~nlbeoJy;the Ii;;c"unling sys-
tem would work if caps ~ aU land-use
emissions nod sinks. However, this approach
is botb ICClmically nod politically cballengillS
as it is cx)remely hard 10moaaure a1llnrid-use
emis$jbDs Ilr 10. distingoi$.Junnan nod nutu-
ml causes ofmany emissions (e.g., fires).
The stmighlforwanl solmion is 10 fix the
=ntlnll ofbioenergy. Tbllt ~ tracing
the aetuall1llws ef carboo aad CO!IIlling emis-
sions liortt lailpipes mul6Ulokestnclu< whether
from fossil ~ or biucnergy. lnstead of an
assumption lbel all biomass ,,1lSels cl\CIJlY
emissions.l>iomassshouldrecclve ctedit In dIe
cxtenI that its 0liC resultsmaddllional carbon
from enhanced plnril growth or frolll the use
of lCSidues or mowastes. Under anyerodltlllS
s}'Slctl1, credits rtllIill retlect nel e!1lIJlb'US m eor-
bon sloek." emissions ofnou.cO, greenhouse
gases. and leakage emissions reSulling liortt
cballgcsin land...... activitles to replace crops
ortimberdivertcd to blocae'W (/).
Sepanllely.Europe Ilnd lbe United Slates
bave established ICgnI reqtriremeuts for min-
imum use of biofuels, wbieb assess green-
bouse gas conscqueaecs bnscdorilifkytle
linalyses thaI reflecl some Iand-us'l eJ1'ects
(1, 14). Suebassessments vary wIdely in
comJlnlhenslveness. but nouc considers bin-
fuels free from Inrid-boscd emissions. Yet
Ibe carbon cap necolDlling ignores Iand.use
emissiollll a1toged1Cr. erentillS';ts own I;n'ge,
pc~rse incentives.
Bioenergy CllO provide much energy
and help 0lCC1 greenhOUse caps, but eorrecl
aecnuntlog I1\IISt provide lhe right tnCC1ttlvcs.
fteflmlnces and Notes
l.~roleTeOO!SWPJ>lllth1gt\ll:_.lthl'
FcIlqf"""'....""loundhlt\ll:WPJ>lllth1g._
-.
2. A!.Wbe.,...;_~~..lmClOO9l.
3. ).M.MelltlGe1ol.,lJn_ii1Ientfd~€~
~.f.GIoIiDIBIOfI1d"'O/J1amlMJTlolotPJogram
1f<J>olH.r1...llal""'__o!T"~.
CambrIdge...... 2DlWl.
.. ---.,._tneqq-.ologyi'tJ>Pet-
_1<>Soppo1toflheG8P1an.fktJan:_ end
Stmt1gJes 'o-2D5f) (Ofgardl:almn for EcOt;omic Coopeta~
tfonamlDm>l_roECllIllEA, _ 2008~
5. lP(c.2fJlJ/JJP<<liuiddinelfoil!D_~
_or<P/lledbyt\ll:__Gas
I_P~It_"'I"GlobaI_
ialSItal<9'" UGES), rol,o.I_. =1.
6.~_'I\,A!.Otto,hllilofrW:_o/C",.
_"'ond__oithC1io1l1Jf09l1Jndu.e:
Pr<<edIngs oftheSdlmlJi<C_",,_ot
d"'E~.R.W.nowallh."""s.IlrIo1g"',!lh.
(ComeII um.. """" Irhac..liY.2Oli91,~ 111-109.
7. t~"al.._319;123812e08).
a ).FargIone.).IIl1\O.TIImao.5.PoIasly.P._.
Sdmxe 319. 12)512003).
9.11.l\>1sonetol.fclo..Jtmdu".ImttI4JstC1it1JtD'.
tllldf_lIPCC.CilmbridgeUil...""""Cilmbridge.
_.
10. UNfCCC._.I1he~."'rhiI_",
Itt__AtI/oIJ_/J11heQ:l/'Il'CCCI
Cl'J2OOQlf.I3IArld.1.UIlfCcc._.2Oli2l._
dl.UD,paJtZ.
11. UNf(Cc. Updated UNFCCC te()Ontng guIdtIl1Ies on
onnuIlI/l1.m7tod<sfollowing/ncotp<<o/ltm.f1heptaV/-
_ot_14/CRl1!FCCCJSubsI1IlalJllo<Iy fat.
S<lenl!llt...rl<<hnologlul_(SB5TAl/2OO619.
-,2006].f.21.
12. ~C__20/}3181IECoftbe
_'",UomeotandofIbeCoundJof13/ktobet
MJ.OIlIrlIllJllIlInalolthe_~niooL215.
25.1D.ZOO3.
13. n.._a..nens.,.andSetorllyll<tol2llll'l..
tUl.Z454.U1tl1Cong.,1slSe<1.t>s""""byU.s.
.....oI~JW'2OO\'l.
14. tD.5earthblgtr~tnlt/cftltls;fAm""........tatt'onse-
quences o11dlntftdtfltJm withChonglng 1.Jmd Ihe:
Pt<<edlngsC/IMSdeD/I}icC_""_.f
1heE_R.\'i._Iltand 5. BrIng.... Ed.
(Comen OnlY."'"" 1Ilia...1lY.1OIl9),pp.~S2.
15. Tlto""""""P'..._forthewpportoftheGmt;m
__oItheUnl1e<lSl;ltes.
SUpportblg Online_I
.....~'"'DI'llll<DlIl..tlrulll326/5951J5l71l1C1
lO.1126JsdentEl'.t118797
528
23 OCTOBER 2009 VOL 326 SCIENCE www.sciencemag.org
l'ubfls/tettbyMAS
...
,..
g
d
...
j
<::
o
e>
o
m
'"
~
<.l
t:
OJ
'iJj
~
E
,g
'Iii
8
I
c.Omplement prior ,1udics that highlight tite
importance of short- and mediulll-Iived pol-
lutants (/4- 1 7).
TIle top I 0 pollutant-generating activhics
contributing to net RF (positive RF minus
negative RF) in year 20 are shown in the bot-
tom ebart, page 526), which takes intoaccouot
lile cmis>ioo of multiple pollutants from cach
source nctivity (/8). TIle seven sources that
appear only nn the left side (purple bars)
wnuW he overlooked by mitigation strategies
focusing exclusively on long-lived pollutants.
TIle distinetly different sourees of near-
term and long-term RF lend litemselves to
the aforementioned two-pronged mitigation
approach. This dccnupling is convenient for .
policy design and implementation; whcrcns
the importance nf long-term climate stnbi-
IilOtion is elenr, the perceived urgency of
ncar-ternl mitigation will evolve with our
knowledge of lite climate S}'lllem. Addition-
ally, opthnal ncar-tenn mitigation strategies
will reflect dccadal oscillatiOllS (/9), seasonal
and regional variations (20, 21), and evolv-
ing knowledge of acrosol-elimate effi:cts (22,
23) and methane-atmosphere interactions
(22)---considerations unique to dIe near term.
TIms, shnrt- and medinm-Iived sources
(black carbon, tropospheric ozone, and
methane) must be fC!,'Ulated scpamtely and
dynamically. The long-tcnn mitib>ation treaty
should focus exclusively on stcady redaction
of long-lived pollutants. A scparate treaty
for short- and medium-lived sources should
iuelnde standards that evolve based on peri-
odic recommendations of an independent
international scientific panel. TIle framework
of"bcst available control technology" (strict)
and Ulowest achievable emissions ratc~
(stricter) fromtbe U.S. Clcan Air Act (24) can
be used us a model.
Such a two-pronged institutional flume-
work lvould rcflccttbe evolving scientific
tmdcrstanding of ncar-term climate change,
the scientific certainty around long-term cli-
mate change, and tbe opportunity to sepa-
rately a<!iuS! lire pace of ucar-term and long-
tcnn mitigation efforts.
References and Notes
1.0. Arther et aJ..Annv. Rev. Earth Pranet. Sd. 37. 111
(2009).
Z. nll!e-foltllng time (requited to d<<re-ase 10 31% of orlgf.
nal airhome amount) Is on the on:fer of days to weeks for
.hotHlved~C..g._andurgankcarbon.
tropospheric ozone. and sulfur tltoxidel, a d<<a:de for
medlum-IWed (e.g.. methane and some balocarbonsJ,
- and a ,century for loog'IWed (e.g.. nttrousoxlde. some
balocatbons). COl takes roughly a century to readl37~~>
then decays nwre s!owty over miflennia.
3. UMclJuIlen.~_.""-C~C/JonyeSdeoa>
CompenrJivm2009lUJI.EnWonmen1Programme, _.
EarfhPrlnt. 2009); mwwnep.otgkanpendium2009/.
4. S. SoIonwnerot., a/mote Change 2007: The Physical
Science Basis: (ontribUlioll oj Working Group 1 to tM
Fourth Assessment Re;xnt 01 tile IPCC (Cambridge Unlv.
Press, ~wYOtk. 2.001).
5. s. Rahmstorf et aI., Sdena 316. 709 (2Ol}7).
6. ~B.Smlthetol.,P1oc.Ncd.AtorLSciU.5.A.106.4m
(2009).
7. A. 5okoIOYctot..J.Gim.22. S175(2009).
8. 1. Stttcker. Quol. Sd. /let. 19, 301 (200()).
9. tM.lerrtofJ elat., PIO(.Hatl.Atad. Sd. USA 105,
1766\20081.
10. J. Hansen et 0/., OpcmAlmos. ScL.J; 2. 217 (2008).
11. RFlsapropertyofthedlmateatapoinlintim:e.
tncreasesin RFueatelrlaretaryenergyimbatan<e, with
more Incoming solar radlativn Utan outgoing infrared
tarllation and a \\'ill'11ling effect on the SfStem.
12. t F. 5todtet,A.SchmIttner,Ntrture 388,862 (1997).
13. R. a Alley erol..Sdtnce299, 2005(2003).
14. ]. Hansen et ol.,PMos. Trans. R. Soc.l.Dntkm Set.A 365,
1925 120071.
15. P. K. Quinnetal...Nmos. Cbtm. PltyS. 8,1723 (2008).
16. Atl.)aa>bsot>.tGeophys.Res.At_l07.4410
(20021.
17. F.C.Moore;At(.^","acken.IRtLtSlrotegkC/Jonye
Mgmr.1, 4212009).
18. D. Koch. T. C. Bonrl. D. Stree-Is, til.Umler. Grophys. Res.
lett. 34. lOS821 (2007).
19. L Trenl>erthetal., in (4), pp. .235-336.
20. D. Koch, T, Bond, D.Stree3, N. tJnger.G.vanderWerf,J.
Geophys. Res. 112. 00"05 (2007).
'1. A. S1<>hl.J. GeDphys. Res. 111. 011306 (2006).
22. Po FooteJetot..in (4).pp.129-234.
23. Y. Ramanathan. G. Carmichael. NaL Geosd. 1. 221
\2008).
24. U.s.OeanAit"Act.\Wm.epa.flavloa:rI<aa/.
CLIMATE CHANGE
POUCYFORUM
25. TIle same analysis applied to fhe lPeC'S s.RES market
scenarlos(A1.A2.S1. anti Bl) (16) prodoces results that
faIl largely within the bounds of these two S(~narWs (f19_
S11.
26. N.Naki!enovIt,R.Smrt.Eds..SpedalRi!portOflfmfs.
stems Scenarios (JPCc. Camblidga Univ. Press. earn-
brl""~'OOlJ).
27. Datafotyear2COORFarebasedon0:4l.emhslonsare
from f28).decaytalesare baserl01'1 theUfetbnesonp. 212
in (22) and hislotl:cal COl decay is calculated acC01dIng to
p. 824 in (29). CifO'i'lth rates are !rem (28) and (30). Zero
gromh of emissions assumed for BC. oc. SO,.and hah:J.
carbons Eath yeat'S Rf for short.UYed pnUutants(BC. DC.
OvSO,>lsdue~tnemissionsinthatyear;thus,theRf
does no! iKCUllltdate from me year to the next. The con-
mbutioos at black carbon and 010ne are conservat!w. as
tbeydonutrefIedrecentnear--cloubleestimatesofblad:
carOOn'sRF(23) norrerentes1imatesofOzone'slndirert
Iandslnl.ellOO(31).
28. EDGAR 3.2 l__.nli....rlntodelll.
29. G. Meehl et at. in (4). pp. 747-845.
3D. Oimate Analysis Indkators Tool V6.(){http://<aitmJ.org).
31. S. SI.h. P. M. Cox, W. ~ Colllm. C. HllI1lln1iford, Not"'"
448. 791 (2007).
32. T. C. Bond et aJ.. GltJbr;1 Biogeot1mn. Cyrles 21. 682018
(2007).
33. lhoauthorthanks).lIamfwpruvldlngem_
and oitill...
SUpportlng Online Materiat
Wlm.St~Ilmna9.otWcgII(ontent/ltlIlt3261S952/S261OC1
1O.1126/sdeme.1l77042
Fixing a Critical Climate
Accounting Error
TImothy D. SaarclJintJa~,. SteVllO P.1Iamburg,'" Jeny Melillo.' William Chameldns,'
Petr Havlik,' Denlel M. Kammeo,' Geoe E. Ukeos.' RobeD N. Lohowskl,' Micbael Oberntelner,'
Micbnel Oppel1belmer,' G. Philip. Rol1ettsoo,' Williem H. Scblesinger.' G. Dovid lillllllll'
Rules for applying the Kyoto Protocol and national cap-and-trade laws contain a major,
but fixable, carbon accounting flaw in assessing bloenergy.
The accounting now used for assessing
compliance with curben limits in tlte
Kyoto Protocol and in elimatc legisla-
tion contains a fnr..rcaching but fixable flaw
that witJ severely undermine greenhouse
gas reduction goals (1). It docs not count
CO. emitted from tailpipes and smokcsllleks
when biocncrgy is being used, but it also docs
lPr1oceton UnM!rsiI)', Princeton, NJ 08544, USA. lEnvlron-
mental Defense Fund, Boston, MA 02108, and Washing-
ton, DC 20009. USA. 'Marin<! Blologicallabool1<>ry. Woods
Hole, MA 02543. USA.. 4Duke University, Durham, NC
27700, USA. ~lntematif:lnallnstitute for Applied Systems
Analysis, laxenbuI!I2361, Austria. 'Universlly 01 CallIor-
nia at Berkeley. Berkeley. CA 94720. USA. 'carylosbtuteol
Ecosystem StudfM. MfUbrook, NY 12545, USA. aMfchfgan
5IDle Universlty, lIitkory Comers. Ml49060, USA. 'Univer-
sityo! M_. 5l Paul, MIl S5108. USA.
-Autlwrs fm (orrespondence. E-mail: shamburg@e:df.org
(s.P.HJ; tsearthi@plinceton.eduIT.D.sJ.
not count changes in emissions from land
use when biomass for enCfb'Y is harvested or
grown.TIlis accountiug erroneously treats all
biocnergy us carbon neutral regardless of the
so...ce of the biolllllSS, which may cause large
differences in net emissions. Forex.mnplc. the
c1cming oflong-eslllblished forests to burn
wood or to b'l'OW energy crops is counted as a
100'4> reduction in energy emissions despite
causiog large releases of carbon.
Seveml receot st1ldics estimate that this
error, applied globally, wnuld create strong
incentives to clear land as carbon caps
tighten. One study (2) estimated that a global
CO, target of 450 ppm under this aecOlmting
would cause biocncrgy crops to expand to
displace virtually all the wnrld's natural for-
ests end savannahs by 2065, releasing up to
37 gigatons (Gt) of CO, per ycar {eompa-
www.sciencemag.org SCIENCE V01.326 23 OCTOBER 2009
PublishOObyAAAS
527
I POUCYFORUM
rablc to totalltumanCO. emissl"",, tollay).
AotlIher sttidy predicts thaI, based solely on
economic eonsidllrntioo!l. b1OO1\Crgy could
displace 59"4 of the world's I\lllIIrnI forest
cover and rei_an llddltional 9 {it "fCO,
per year to achieve a 50%wcut" ingrecn-
1l\lWiC ~ by ZllSO (3). The reason: Whco
Dioomm!Y from any biomass is counted as
emboli ucutml,ecouomlcs favor lallie-scale
11lJld conversion fur l>ioen<>rgy reg\lrdJcss of
tlte actUal act cmisllions (4),
The potential ef biocnergy to redllCe
grecnhow;c gascmissions inlterentiy depends
oolite SOlIl'ce of the biomassand its net Iand-
use effilc1S. Replacing fussil fuels with bie-
energy d_not by itself redw;<: earb'm
cmissloD!l. because lite CO, released by tail-
pipes andsfuokeslacks is ioIIgbly the same
per unit of energy regardless ofthe $(Jllree
(T, 51. Emissions from producing aoel/or
refining biowels also typically exceed those
for jleIloIcum (I, 6). Biocaergy therefure
reduces greenhouse emissions only If tbe
growtb $d barvesting of the biomass fur
energy captures carh9n above and bcypnd
whal would be sequestered anywaY and
t1u.'reby offsCls emissions from energy use.
This adliitioncl carbon may result from
land managementehnnges tbBI increase
plant uptake or from the use of biomass
that would otherwise decompose rapidly,
Ass_mg such carbon galos reqlrircsthe
same accounting principJcs used to assign
credits fur other land-bascII cnrbonotlScts
For cxnmple, if unproductive land sup-
ports tiJst-growlng grasses for blOCDClllY,
or if foJi:Stry Impl'OvemenlSincl'case tree
growth rates. the additional carbBnabsorbcd
offsets emissions wben burned for coCll!Y.
EDergy ll8C of manure or c:ropand titilber
resldiu:s II\lIY also capture "additi"nal" car-
bQn. How..'VCf, harvesting existing furestS
forelcctricityadds net carbon to the air.
ThaI rcmainslluc.evcn if limited harvest
mrcs letl\'a the carbolll;lllcks of regrowing
forests uneltnnged. bcCOJlllC those stocks
would othcrwIsc iucrease and coutribute to
the terrestrial carbBu sink (1). If b10CDClllY
crops displacefurest or gmssJand, the car-
bon released livm soils and vegetation. plus
lost future sequestnrtion,gcm:ratcs cat'bcln
"chI, whlch enunts against Ihe carlton the
CroJlS absOrb(7,lI~
Tbe In!elllovemmcalal Panel ou Climate
Cb;mge (IPee) has I"ng rcalized that hie-
encrgy's greenhouse e!TeelS vary by sourec
of biomass and lartd-usc effeelS. It also rae.
pgnizes that when furests OI'.other plants are
batvcStcd for hiocllCl'lJY, the resulting carbBn
release must be cOlmled either as lund-use
emissions or energy emissions but not both.
To nVoid.doublc-counting, the lI'CCassigns
theCO, fO lbe land-use accouatsand exempts
biocncrgyemissillus from cncrgyaccounlS
(S), Yet it warns, bccausc"fossill\lel substitu-
tioOisalrcndy 'rewarded'" by this exemption,
"to avnidUlldcrrcporting . . . any changes in
biomass stOCks ."n 1!lDds . . . resulting flom
the pro4uctiou ofbiofuels would need to be
Included in the a<:eolllllS" (9).
ThinymmelriellJ approach worb f<l1'
the reporting tmder lhe United Nations
Framework ConvcutiQll UI1 Climate Cltnnge
(UNFCCC) because virtually all wuutries
report eml5sions livm both land and energy
tt$c. For eXllIll]lle, if forests are cJCIl1'cd in
Southeast Asia to prodw;<: paJm .biodiescl
burned in Europe, Europe can exclude the
tailpipe emissious liS Asill reports the IlIll!c
net carbBn release as land.usc amissilln.. .
. However, llXCrnpting emissions from bie-
encrgyUS<.'is improper for gR:Ollbousc gas tcg.
ulations IfJand..usecmlssionsare not in<:1udcd.
The Kyoto PrOtocol caps the cacrgy emis.
sions of d.....lPpcd countries. Buttbe pTlJlo..
eol applicsno limits te land llSC or any other
emissiousfromdcvclupingCOlllllries; 1lJld spe-
cial crediting rules for "forest lIIlllIllgcmenl"
allow developed C<lt1IUI'\l.'S lOc:ancel oUt titeir
own land-usc emissions as weU (I, 10). Thus.
maintnil)lng the CXl.'IDJlIlon fur CO, emillcd by
biocaergyuscundcr the proIt>OOl(/J} \1Iroogly
tJ<:ll\ll bi!iuuergy from all biomass sources as
C1lrl1<l1l ncutra~ evert If the source involves
clearing forests for clcctrieity in Europe or
eonwrting them to bIodicscl crops in Asia.
ThIs accouutingctrorhnscarried over wo
the European Unioa's ~-trOOc: law and
tile elil11llle bill passed bylbe US.l:loUSc of
ReprescntaliVcs (I, 12, 13). BQthn>gUlate
emissioils from energy but Ilolland use und
then erroocuilsly exempt CO, ell1illed from
bioenergy use. In theory, the ai:countiug sys-
tem would work if caps c:overt:d aIlland-use
emlssioninlad sinks. However. this approach
isl>olh tcchulcally and politically ebalJcugiDll
as it is uxtrcn\cly hard to mCllllClC all land-use
emissions or to dlstingnish buman and l1llltr
tal causeso'fl11lll1)l emissions (c.g.. fires).
The straightfOIW>U'llsolutiou is to fix the
accounting ofbiocnorgy. That mcuns tracing
the actual ilows of cmbon and UOIIOling emis-
~101lS from miJpipes and smokestacks witctltGr
lfum fussil CIlCl'IJY Qf bloencrgy.lnslend oran
lIS!lIDIlpliuu IImt all biomass offsets enclgy
emlsslOU!l,biomassshould rcceivec:redillo the
extent that its use rcsullS m additional earlxm
livm enhanced plant growth or from the asc
of residueS orblowastes. Under any crediting
systcm,c:redils mllS! refJccl net changes in car.
bon stoCks. emissiunsofuoa-CO,grecnhouse
gases. aad leakagc emissions rcSnlting from
changes in land-use activities to replace crops
Qf timber diverted to b11lU11l:rgy (I).
Separately, Europe and the Uultcd States
itavll established legal requirements for miu-
Intum use of blofueJs, which assess green.
house gas eouse(\l.tCl1CCS based on life-<:ycle
analyses that @llnct some Iund-use c!'fects
(/, 14). Such assessmenlB vary widely in
compreltcnsiveness. bot none considcrsbie-
lIlels free from land-based emissioils. Yet
the Cm:bun cap accounting ii!1l<lJeS land-use
emissions altogl>lbcr, crcatlnglts own ltnge.
perverse Incentives.
aioenergy enn provide mueb enelllY
and bcIp \l1CCt grcenltOUllC taps, bot correct
lICCUUating nlllst provldl: the right incentives.
llelereuteS '"'" Not...
1._"""""",~6,,_Q/lllls
l'llIkyF.....'.."'~Ill1l>elU~_
moIOrIaL .
2. M;Wls<eI<rI.Sdeoo1lZ4.Ue3l2l>>91.
1.1.M;A1eUIloel<rl.U_f~C_
ipJenlI<oj. GIoIlo1 BiofuelPfD/It!ii1i l&\lll<\fm ProgJam
IWplIlt_Mal1lI<__<>Ir.dmotow.
CamIlrfdgv.1llA.2U091.
4. _En<tIlJ~_lIl'kdmDI<I!/1"""""
m..:IlISuppM./I1>rGeI'lllDO/A<tItm:_tmd
~/D2fJWI_lilmforf'_c.._.
!loP and lle\<l_loEClllliEi\, -. 2008~
S. '1'CC.20JJ6IKC~/"'__6Dt
_..._edbyll>.NalfDnal_GM
__I_"htr~!nYIronmeA-
~$lratl!QIes(JGES).tokyo._.llill1L
6. UI,oich.al.M._Ill/liiifO<J$:EnvIromntnJoIC...
mplOtIffl.",,~ChongingI.mltJUse
_mIings O/t1Jo5dentl/kC....."...._oJ
rhe Environment. R. W. tkAYarlh, and S. 8rifigeiu" Eels.
(C_ ""'.1'1.... ~bac~ NY. 200'1). pp. .'-1(J9.
7. I. SoOlChlng"otol.Sdtm:.319.1238l2OO!J).
a PpllIlolle.I.HIIl.1l,TiImao.s'l'llIaUy,'_
Sd<me 319, liS 12tl1l3l.
9. R._otol.!lb..lIl1ldu..ImltJ.U<oCllanj<.
"""f<mI'101'CC. ClmbrldgoUohr. -.~.
_.
10. UllFC((.l1<ponO/t1Jo",*",,""'t1Jo_..
"'__Mli.._byI1>rCOPlFCCC!
CPI2OOlllJl3tMd.l. UNFC((, -. 2C021. Add...
clum.pan2.
11. UIl1CCC.UpdotedUNK((tllpDltlnggu_..
.-_"f<rl1miingint__'ftJ>eprO!l/-
</tins D/ dedslon l4IaU1 IfCC<:JS\d>>h1ialy 8Cdy lot
5dm1lIfl<....T~"'''''~.
_._~..23.
12._CommlssloD._2OII3I81'>CO/the
_hdlammr""".IU>eCOWldlD/13_
2IJfJ3.01ll<~llDllll>llloll!>e_UnlOllI27S.
l'l.JO.2003.
U. 1beAmerkan Clean Entr-g:y Md Stc.ttJl1y Ad of 2009,
H.l.2454. 1I1~, 0>n9. '" So<> (as~ by us.
_Ol""""",_J>;Iy2CU9!.
14. to.SOaI<hIllg,,;IllBiDftlds:_..-oJa,n,..
_"""t~wltltChol1gingUirlllUse:
_nti'oIl11<-'C_"_,,,
J1>e_~R."_""'s'Ilrinil<'zu.Ed$.
(ComeII UnIv. -.'_ll'OC09I. pp. )1-52.
15. ltteauth"u~thant.ifortlttsuppl:Jft-oftbt'Gel'ltian
_UFtollloliboUnll<dStalei.
suPJlOltlarl. Onlln& MalerlaI
mm.~.oi'gJ(911(cm1~9S2f527ro.cl
10,1126fsdePte.ll18791
528
23 OCTOBER 2009 VOL326 SCIENte www.ll$n<:emag.org
PubIbhod/7yMAS
...
...
5l
o
...
f
{l
6
e>
o
g>
.E
'"
<>
C
Ql
~
!
E
g
1il
1il
I
"
::I; AMERICAN LUNG ASSOCIATION(~ (9
I Fighting for Air
NATIONAl HEADQUARTERS
Charles D. ComO!'
President &
ChIef Execu1lve OffIcer
1301 Pennsylvonla Ave., NW
Suite 800
Washington, DC 20004-1125
Phone; (202) 785-3355
Fax: (202) 452-1805
61 Broac.lwqy, 6th Floor
New York, NY 10006-2701
Phone: (212) 315-8700
Fax: (212) 315-8800
www.lungUSA.org
Stephen J. NOlan, Esq.
Chair
Mary H. Partridge
Chalr-elect
Bruce A. Hertlng
Past-Chair
H. James Gooden
secretary
Terrence L Johnston
Treasurer
Albert J. Rizzo, MD
Nationwide Assembly
Speaker
June 24. 2009
Tlleflooorable Henry A. Waxman
ChlIirinan
House Committee on Energy and Commerce
United States House ofRepresentl11ives
Waslrlngton, DC 20515
The Honol'llble Edward J. Markey
CbaInnan, SUbl;ommittee on &ergy and the Envlro!UJlent
House Committee on Energy and Commerce
United States House ofRepresentati\'eS
Wasltlllgton, DC 2(l$IS
Dear ChaInllal:i Waxman andChllinnan Markl!y;
As you Cl>>lSider leglslatiOllIo address global climate change and energy poliey. the
Anterican Lung Association urges you to use thisopportunlty to target widespread
pollutants that can both directly harm lung health of millions of Americans and worsen
ljIobaJ climate change. At a mfulmum, we urge you to selcet mechanisms that prevent
increlJses in ambient air pollution and hazardous air pollutants.
Over 186 million Americans continue to live and breathe in areas with unhealthy air in
the United SUItes. The American Lung Association SUJlIlOI'lS aggressive strategies to
reduce greenhouse gasemlssious that maximize eo-benefits of reducing criteria
pollutants and pro'(ide near-term poblic health henefits.. These strategies include
ambitious progIlllllS to reduce the country's dependenceoo fossil fuel combustion and
promote cleaner alternative vehicle technologies and fuels. These require iealch;mges;
substantial increases in clean renewable energy resources; a transformation of the land
use planning process to emphasize SlIIart growtlt policies that promotl) alternatives 10
driving,1lnd. as well, significant reductimts In power plant and indu$lrial emissions.
We urge yon 10 .consider approaches that target two critical two critical pollutants well
within reach-black carbon and ozone. BlaCk carbon, or diesel SOOI, and 0Z01l1: not only
significantly impact global wanning but also endanger pnhlic hea1tb. Black carbon from
diesel, a mixture of 40 different toxic substances. increases the risk of developing lung
cancer. O2onl:, the most commonly encountered ponutant in America's cities. damages
long capacity and aggmvates asthma. Both pollutants sead people with asthma and other
chronic lung diseases to the hospital and emergency room. Both em short the Jives of
thousands of people every year. Because black carbon particles and ozone have
significantly shorter life-spans in the atmosphere than carbon dioxide. immediate
controls can make a near-term difference in the level of global warming. as well has have
immediate health benefits.
. .
Chainnan Waxman and Chainnan Markey
June 24, 2009
Page 2
The legislation should support state and local air pollution control efforts and include strong controls on
major sources of emissions. Please include stronger controls on coal-fired power plants and other major
industrial sources that also reduce sulfur dioxide, nitrogen oxides, mercury and other toxic air
contaminant emissions.
The legislation should promote clean renewable electricity, including wind, solar and geothennal. TIle
Lung Association urges thaI the legislation not promote the combustion of biomass . Burning biomass
could lead to significant increases in emissions of nitrogen oxides, particulate matter and sulfur dioxide
and have severe impacts on the health of children, older adults, and people with lung diseases.
TIle American Lung Association thanks you for the opportunity 10 share our perspective.
Sincerely,
/"'// .
( '( / .
(o' /.
\. .' c. (./..,
_" ",. t.1; \..._~
Charles D. Connor
President & CEO
.
,
(fY
b!tP:/Ieuro~.orw?view=articIe&uri=/journals/gYgIP8_Q
3/2007GL031101l2007GL031101.xmI&t=2008,Jacobson
On the causal link between carbon dioxide and air
pollution mortality
Mark Z. Jm:obson
Depart:nrent of Civil and Environmental Engineering,Stanford University,
Stanford, California, USA
Greenhouse gases and particle soot have been linked to enhanced sea_level,
snowmelt, disease, heat stress, severe weather, and ocean acidification, but the
effect of ~bon dioxide (CO2) on air pollution mortality has not been examined or
quantified. Here, it is shown that increased water vapor and temperatures from
higher CO2 separately increase ozone more with higher ozone; thus, global
warming may exacerbate ozone the most in already_polluted areas. A
high_resolution global_regional model then found that CO2 may increase U.S.
annual air pollution deaths by about 1000 (350-1800) and cancers by 20-30 per 1
K rise in C02_induced temperature. About 40% of the additional deaths may be
due to Ozone and the rest, to particles, which increase due to CO2_enhanced
stability, humidity, and biogenic particle mass. An extrapolation by population
could render 21,600 (7400-39,000) excess CO2_caused annual pollution deaths
worldwide, more than those from C023nbanced stortniness.
@
http://environmental'''''''''''hweb.org/cwslarticle1newsl32401
Ian 11,2008
Carbon dioxide increase causes air pollution deaths
Each degree Celsius rise in temperature caused by increased carbon dioxide
levels could cause about 1,000 deatbs from air pollution each year in the US,
says Mark Jacobson of Stanford University, US. The gas boosts
concentrations of surfaeeozone, particles and carcinogens, all of which are
detrimental to human health.
Around the world. air pollution deaths each year induced by additional carbon
dioxide could amount to 21,600 per degree of temperature rise. That's a greater
.
number than is likely to be caused by man-made, climate change-related
storminess.
This is the first time that a link has been made between carbon dioxide levels and
deaths from air pollution. Heightened levels of carbon dioxide raise atmospheric
temperatures and water vapour content, in turn increasing ozone and particle
concentrations. The ozone increases in particular occur in locations where ozone is
already high, says Jacobson.
"More than 30% of these deaths occur in California, which has six of the 10 most
polluted cities in the US," Jacobson told enviromnentalresearcbweb. "This is
significant since the EPA (Environmenal Protection Agency) recently denied
California a waiver [to its ruling against states setting specific emission standards
for carbon dioxide] based in part on (a) no special circumstances occurring in
California, (b) no studies isolated carbon dioxide's effect on air pollution. and (c)
no studies quantifying the health effects of carbon dioxide. This study addresses
all three issues. "
Jacobson says that the deaths are already occurring, since global temperatures, on
average, are about 0.80Celsius higher than in pre-industrial times.
"Based on the results of this study, I would think the EP A should revisit its
decision since California does have a special circumstance based on the scientific
results found here, namely that climate change will worsen air pollution the most
in areas already polluted, n he said.
Around 40% of the extra deaths are likely to be caused by higher ozone levels,
which can cause respiratory and cardiovascular illnesses, with the rest accounted
for by increased particle concentrations. Higher carbon dioxide levels ‐ and
the associated increases in water vapour and temperature - can enhance the
stability of particles, raise biogenic particle mass and enable particles to interact
with airborne chemicals, increasing their toxicity. The study also found that
cancers may increase by 20-30 for every one degree rise in temperature caused by
carbon dioxide.
To obtain his results, Jacobson used the nested global-urban climate-air pollution
-ct ,t
3D model GATOR-GCMOM. This incorporates emission, aerosol, cloud,
meteorological, radiative, transport and surface processes as well as gas chemistry.
Jacobson, who reported his work in Geophysical Research Letters, ran two
global simulations, setting carbon dioxide levels to pre-industrial values in one of
them and comparing the results.
About the author
Liz Kalaugher is editor of enviroomentalresearchweb.
.
.
.t1:0
0Y
Mark E. Hannon
Richardson Chair and Professor in Forest Science,
Department of Forest Ecosystems and Society, Oregon State University
Timothy D. Searchinger
Research Scholar and Lectcrer Princeton University,
Transatlantic Fel1ow, The German Marshall Fund of the U.S.
William Moomaw
Professor of International Environmental Policy
The Fletcher School, Tufts University
Fehruary 2, 2011
Dear Members of the Washington State Legislatcre,
Several new wood-burning hiomass electric power facilities are planned for Washington State.
Recently, the Washington Department ofNatcral Resources provided you with a report stating that
genemting power from biomass reduces greenhouse gas emissionS.! We write as climate researcbers
coucerned about the approach to carbon accounting endorsed in that report.
A critical conclusion of the report is that biomass of all kinds, including harvested trees that would
otherwise remain standing, should be treated as a "carbon neutral" fuel, an assumption tlte authors
ascn"be to the Intergovernmental Panel on Climate Change (!pCC). However, this conclusion is based
on a misinterpretation oflPCC accounting, and is inconsistent with the best science of forest carbon
accounting. Cmfting a biomass policy based on this report's conclusions could lead to an increase in
total carbon emissions from the power sector, an increase that would be incompatible with
Wasbington's goals of decreasing greenhouse gas emissions to 1990 levels by 2020, and to no more
than 50 percent of 1990 levels by 2050.2
The DNR report stales:
The Department of Natural Resources supports the approach wherein a neutrality
determination for a State's greenhouse gas emissions from forest hiomass energy
production is made so long as the state's forest carbon stocks are either stable or
increasing. This is the case in Washington's forests. In addition, forest biomass
energy prnduction can have positive greenhouse gas results to the extent that it
displaces energy production from fossil fuels.
This approach ignores critical factors and makes it likely that greenhouse gas emissions will increase
for many years where biomass replaces or displaces fossil fuels. Biomass has a lower energy density
than fossil fuels,3 and is inefficient because its generally high moistcre content requires that energy
be expended to evapomte water before useful energy can be obtained. Because wood burns at a lower
I December 2010 update from Washington Stale Department of Natural Resources: the "Forest Biomass Initiative".
2 RCW 70.235.020: Greenhouse gas emissions reductions - Reporting requirements.
3 At about 213 !b C02Immbtu, bone-dry wood produces 182% the C02 of natural gas, which produces about 1 17 Jb
C02lmmbtn. Differences in facility efficiency account ror an even greater gap in stack emissions between biomass
and natural gas.
,>
temperature than fossil fuels, the efficiency of electricity production is also lower. This means that in
practice, burning biomass emits 150 percent the carbon dioxide of coal, and 300 - 400 percent the
CO2 of natural gas, per kilowatt-hour of electricity generated. .
If the biomass burned is truly from "waste" wood normally generated in the course of timber
harvesting, then these combustion emissions are approximately equivalent to what would occur over
the course of natural decomposition, although they are emitted instantaneously instead of over a
longer time period as occurs in nature. However, if fuel is obtained by harvesting trees that would not
otherwise be cut, a position that appears to be rationalized in the DNR report, then the carbon
"payback period" is decades to more than a century, even if the harvested trees are replaced. The
report's approach to carbon accounting does not acknowledge this, instead assuming that the carbon
from trees harvested for fuel does not need to be re-grown in place as long as forest carbon stocks
remain constant within the state as a whole.
Forests in the northern hemisphere are on balance growing and accumulating carbon for a variety of
reasons, and that ongning growth is helping to hold down the rate of global warming. The DNR
report's assumption that as long as fOreal carbon stocks remain constant, the amount of CO2 being
emitted by bioenergy is balanced by forest carbon uptake4 disregards this ongoing increase in carbon
storage. Using wood for power generation that would otherwise be added to furests thus not only
increases the mte of CO2 emissions per kilowatt-hour but also reduces the critical fOreal carbon
"sink". If forests harvested for energy are allowed to re-grow, that re-growth absorbs carbon dioxide
and helps to offset the carbon released from the initial burning of the trees for energy. But paying
back the carbon released will nearly always take many decades, and in some cases centuries.
For the DNR scenario to work, where constant forest inventory guarantees biopower carbon
neutrality, forests would need to somehow "compensate" for the net increase in carbon emissions that
occurs when trees are cut and burned fur energy. However, taking credit fur fureat carbon uptake that
is happening elsewhere (that is, not on the plot that was cut for fuel, but on other forests) is not
legitimate, because cutting and burning trees in one place does not by itself increase forest carbon
uptake elsewhere. In fuct, applying the carbon gains of other forests within the state to the credit of
biomass fuel amounts to double-counting, because these gains in other forests are already accounted
for in the carbon balance. DNR's approach is similar to declaring that every business in Washington
State is profitable, even a business that loses millions of dollars, so long as the State's businesses are
profitable in aggregate. In short, the proposal is an accounting scheme with no accountability.
The DNR report claims that the IPCC treats biomass as carbon neutral as long as forest stocks in a
countrY de not decrease, but this is not correcl The IPCC did not assume that the burning of trees has
no effect on global warming. The reference is to guidance provided by the IPCC on countrY-level
reporting of all greenhouse gas emissions, which requires that countries report in separate sets of
books not only their energy emissions, but also their emissions from land use change. In effuct, once
trees are harvested for any PUI]lOSC, IPCC rules require that their carbon be reported as a land use
release. Because that carbon is already counted, and to avoid double counting, the IPCC rules
appropriately provide that the carbon should not be counted again if the trees are burned for energy.
It is true that on a national basis under the IPCC guidelines the emissions from harvesting trees may
be offset by positive land management elsewhere. But that is allowed because a national accounting
system intentionally looks at the net sum of positive and negative effects. To evaluate whether any
4 Page 31 of the report
. .
particular bioenergy activity increases emissions, its consequences must be assessed alone rather than
hidden by the total mix of a nation's or state's total emissions.
Will Washington's growing biomass power sector rely on increased forest harvesting for fuel? The
number and scale of biomass facilities proposed in Washington strongly suggests that new trees will
have io be cut to provide fuel for these plants, because Diill residues and logging residues are
inadequate. A National Renewable Energy Laboratory reportS establishes that there is only a
negligible amount of mill residues in Washington left unused. As for forestry residues, a recent state-
level biomass inventory6 estimates thai there are about 3.5 million green tons of residues generated
annually in Washington State. However, only about half of this, or 1.75 million tons, is really
collectable due to the need to retain material onsite for soil fertility and the logistical constraints of
collection. In contrast, the combined wood demand of just the biomass power facilities proposed in
Washington is more than 3 million tons of wood peryear;7 and new wood pellet plants and biofuel
plants will require another several hundred thousand tons per year, for a combined demand that is
currently two to three times the realistically available supply oflogging residues in the state.
The amount of new biomass generation currently proposed in Washington would amount to less than
I percent of the state's electricity generating capacity . Yet even this relatively small amount of power
generation seems likely to put new demands on Washington's forests and their delivery of multiple
ecosystem services including timber. This will transfer standing forest carbon into the atmospbere,
thereby increasing carbon emissions from Washington's power sector. Simply declaring biomass
power to be carbon neutral does not malce it so. Policy must distinguish among sources ofbiornass if
it is to reduce greenhouse gas emissions. We urge you to insist that any use of biomass for fuel
require proper carbon accounting that accurately reflects the impact of biomass carbon emissions on
achieving Washington State's climate goals.
Thank you for the opportunity to communicate our concerns regarding the impacts of increased
biomass electricity production in Washington.
~~~~~,
{,
,
,
i
I
.: //l'" ,/( ')
"
i
~. t r ;/
Z;,'. K" J
~ . ,<". AI
7~.,,>-..~~'
, Milbront, A. A geogmphic perspective on the current biolllllSS resource a\lllilability in the United States. NERLffP-
560-39181. December,200s.
6 Washington Stale Department of Ecology and Wasbington Slate University. BiolllllSSlnventory and Bioenergy
Assessment. December 2005.
7 A general rule of thumb is that it requires around 13,000 tons of green biolllllSS to deliver one megawalt of electric
power to tbe grid for one year.
f
.
fj~f ~toioG'" w~, ~tl;7Ao/:; "~J?lrJ " ~ " ~\ . ; ,; ~~
riIOENERT&Y' ~":; ~ A~'"' ,
GCB Ilioenergy (2011), dol: 10.1111/j.1757-1707.2011.01102.x
@
CO2 emissions from biomass combustion for bioenergy:
atmospheric decay and contribution to global warming
FRANCESCO CHERUBINI", GLEN P. PETERSt, TER]E BERNTSENH.
ANDERS H.STR0MMAN".nd EDGAR HERTWICH"
meportmmtof Energy tind Process Engirreering, Norwegftm UnlvttsityofSdenceandTer:1mo/ogy (NTNUJ, No-7491 Trondheim.
NIJT11IfI)J, teenier fr1r IlderntltiDnaI Clil1l6le ttnd EmJIromnental ReseMth -Oslo (CICERO). OSlo. NIJT11IfI)J. fDeparlme1/1 of
Geosdel1ce$. Unlilerslly of Oslo, NIJT11IfI)J
AbstIad
Cubon dioxide (co.> emllIsioJlS .&om biomas~ combllstlon are tradiliO!t8lly assumed
climate neutral If the bioenergy sy$Iemi. carbon (C) ftux neutral, Le. the CO. rel-.:l
.&om "Iomel combualion approximately eqDllI$' the amount of CO. sequestered In
"iomass. ThJs amveutiou, widely adopted In life cycle _men! (LeA) stwiles of
bioenergy$Y5fems, undereatimulea the !:llinate Impact of bioeumgy; BesIdes Co. eJltis..
sIons.&om ~I C 1_ co, emissions .&om C JIux neutra1 ayalemB (lhaIls from
temporal)' C losses) also <ontribute 10 climate change: bef9re belng.:aptured by biomass
resrowIh, Co. mole<olea spend time In the atmosplwrEl and conbibule 10 global
warming. In thla paper, a methocllo ""fImAtP the climate Impact of CO. emiasiomi .&om
biomass combustion Is proposed. Out method uses co. iDlpuJse response functions
(JRf) from C cycle models In the eJabomtion of atmospheric decayfun<tiona for blol1'1llS$,
derived co. emlssions. Thelrcontribulionslo g10blll wamling are then quantified with a
uni!-J>ased Index, the GWP.,.. Sin.. thla Index ia expte&SOd aa afun<linn of the rotatiqn
period of the bl_, our results <an be applied 10 CO. emissions .&om combustion of
aU the dllfereul biomaas species, from annual roW' crops 10 slower gRlWing boreal forest.
Keywords: bl__rgy, l:8rbOn neutraL COz accounting. global wam>ing potentlal.LCA
!le<eiverl14 October 2/l1i1; reIIised wrsion _iotd 31/anWlnj 2011 and ampletl 7Fe/muJry 2011
lnIrod'!lction
BnckgTIIU1Ul
In 1991, the fitst comprehensive guidelines for esllmat-
Ing national greenhouse gas (GHClemlssions and sinks
compiled by the OrganIzation for Ec:onoml< Coopera-
tion and DeVelopment (OECP) states that 'Co. emls-
sions resu1tlng from bloenergy <OllStlmptioD &hould not
be Included In a country's offidaJ emll;sIlm Inventory'
(OECD, 1991). ThIs convention is motlvaied by the
considemtion of the carbon (C) neutrality of bloenergy:
because growing forests sequester C. then aa long as
iU'e8S harvested for biomass are kept forested. the C Is
again absorbed In growing trees and consequently the
nelllnpact on GHG emJsslons Is zero (Manmnet.2010).
For this reason, m national GHG Inventories dired
carbon dioxide (~) emissions !rom bloenergy are
not rep<lI'ted In the e!nl!l'!lY sedor (as for fossIls) but In
CorrelpC>nden<e: _0 ChmlbW, tel. + 4?7 3591l942.
__mall: francesco.che_.no
@ 2011 llIad"..,U PubUsldng Ltd
the land use, land-use c:hange and forestry (LULUCF)
"""tor, according to coWlUy...peclfk regulalions
(UNFCCC, 2003; IPCC, 2006). SteJnming from lhls con-
vention. prllnary resellt<'h Jir., cycle assessmenl (LCA)
studies tend 10 llnpllcitly ll55UIlle Co. emissions from
blo_ <ombllStlon climate neutral If the bloenergy
sySlllm is C flux neutral, I.e. co. emlSslons from tem-
porary C lo&ses are traditionally ignored.
In LCA studies of bioel\ergy sys/!lmS, the OECD
convention is llnplemented following. two basic a<-
counting procedures. The majority of <ase slndies
ignore the co. flux within a bIoenergysystem, assum-
Ing that co.l!bsorbed ""PJaIs Co. emitted; so giving a
net flux baJan<e of zero; lhese studies sllnpl)' assign a
global warming potential (GWP) equal to zero 10 dire<t
co. emJsslons (e.g., Carpentieri e/ al., 2llO5; Petemen
Raymer, 2006; Hno e/ .1.. 2llll8; Kim & Dale, 2llll8). Other
studlIla follow the Ec:olnvent database (Werner et at,
2003) and offset co. emissions !rom biomass <OJltbua,.
lion wllhall upstream sequestration credlllhatisnearly
<<iual to the c:ombu&lion emission. In lhls c:ase,a GWP
equa11n 11s assigned to Co.. wl!kh Is considered 10 be
1
2 F. CHERUBINI elnt.
offset by the sequestration of the same amount of Co..
that occurred to grow biomass CReljnders & Huijbregts,
2008; Luo et al., 2009).
These accounting conventions are 50 widely adopted
that in the majority of LCA studies it Is not even
mentioned whiclt one of tlte two Is used (van der Voet
et nl., 2010; O,erubini & StrolIUllllIl, 2011). A recent
paper reporls that in only four of the 67 case atndies
reviewed the exclusion of the dinlate effect of biomass-
derived Co.. emissions Is explicitly indicated, wltile In
two cases it is clearly mentioned that emissions and
removals are botlt included and offset (van der Voet
et 01., 2010). Most of tlte studies generally find a reduc-
tion in the contrlbution to dinlate dlange when ble-
energy systems are compared to fossil reference
systems, provided that permanent dlanges in terrestrlal
C pools are minimized (Quirin et 01., 2004; Searcy &
Flynn, 2008). One of the main reasons for tills result is
tlte absence in GHG balances of tlte dinlate impact of
co., emitted from biomass combustion.
Botlt in past and recent literature, an increasing
perception of tlte inadequacy of t!tIs accounting c0n-
vention and its implementatlon In LCA can ba identi-
fied. Already some years ago, IlOrjesson & Gustavsson
(2000) did not presume wood to be C neutral and
a=unted for co., emissions from biomass as tltnse
from fossils. Rabl et 01. (2007) advocated 'thet emission
and removal of co., ba accounted explicitly at eacl,
stage of the life cycle' . Even if they rea1ized that tile net
effect at the end would be almost zero, they claim thet
using t!tIs approacl, allows a dynamic modeling of
emissions and removals. 0tIlers have questioned tlte
distinction between fossll and blomass-derived co., in
national GHG accounting. empllllSizlng tllat 'all Co.. is
equal In the abnosphere' and IPCC only provides vague
guidance concerning this crucial matter, and further
detailed analysis would be Illghly desirable to accu-
rately account for all Co.. fluxes (M5lIersten & Grilnk-
vist, 2007). Johnson stales thet we should say 'goodbye
to C neutral' for bioenergy from forests Oohnson, 2009),
while other researchers have focused on fixing 'a critical
dinlate accounting error' (SearcIlinger et al., 2009;
Searcltinger, 2010). Searcltinger et 01. (2009) moved a
step forward, stating tllat 'replacing fossil foels with
bloenergy does not by itself reduce C emissions', since
the Co.. released by tailpipe emissions 'is roughly tile
same per unit of energy: In order to mitigete climate
cl1ange, bloenergy must ensure thet 'the growth aod
harvesting of tI,e biomass for energy captures more C
above and beyond what would be sequestered anyway
and tl1ereby offset enllssions from energy use'.
A further distinction can be seen between LCA besed
on forest wood and fast growing biomass species (an-
nual crops and Iiguocellulosic energy crops). Studies
i ,,'1
which focus on bloenergy from fast growing biomass
generally tend to account for permanent cl1anges in
terrestrial C pools only, while basically Ignoring tlte
climate impact of co., from temporary dlanges (I.e.
biomass llarvested for bioenergy and tI,en regrown).
TIlls is a reasonable assumption for fast growing spe-
cies, but may not apply in tIte case of blofuels from
slower growing biomass, like forests OoImson, 2009;
Marland, 2010). A forest may take up to 100 years tomregrow, and the system can be delined C neutral only at
tI,e end of proper time bouodarles: Co.. is emitted in
one point In time when biomass is burnt but tlte
sequesiratinn In the new. vegetation is spread over
several years, depending on tile specific rotation period.
Even if in tltese cases the fact thet C neutral does not
mean climate neutral Is straightforward, tills aspect bas
been seldom considered In LeA, despite tlte importance
of the issue being thoroughly acknowledged from the
early 19905 (Harmon et al., 1990; Marland & SChlam....
dinger, 1995; SchIamadinger & Marland, 1996b). Studies
tllat considered tIte time dimensions of forest growih
are essentially studies of forest C dynamics. These
atndies usually report an increase in GHG emissions
of forest bioenergy systems in tile short term, in favor of
a decrease in net GHG emissions in tile longer term; in
some cases, a specific C deficit and pay-back time (up to
some decades, depending on sJre.specific parameters
and reference system) Is Identified (Marland & SchIa-
madinger, 1995; SchIamadlnger & Marland, 19%b;
Manomet, 2010; McKeclmie et al., 2010). Manyanalyti-
cal models are avaJlable to perform t!tIs type of tempor-
al analysis (Scltlamadlnger & Marland, 19960; Masera
al al., 2003; ScIlelltaas et nl., 2004; Kurz cI nl., 2009). A
common feature of tltese assessments is to show results
as a trend of cumulative Co.. emissions over century
timescaIes, and do not elaborate yearly unit besed
Indicators. TIle work performed in tills paper bridges
thjs type of aualysis witlt LCA methodology, providing
a methodology to estimate the contribution to global
warming of co.. flux neutral bioenergy systems in
terms of GWP, so to provide an Index which can be
promptly included in LeA.
Aims and objectives
All Co.. emissions, both from combustion of fossil foels
or biomass, alter tI,e C cycle and hence the earth's
radiative balsnce, tltus causing a climate impact that
should be estimated. Our main aim in t!tIs paper Is to
quantify tIle climate Impact of blomass-derlved Co..
emissions witi, a unit-besed Indicator to be used in LCA
or C accounting atndies. We focus on a single biomass
rotation where an existing aboveground C stock, eitllet
a crop or a forest, Is harvested for bioeuergy and later
:D 2011 Blackwen Publlsblng LId, GCB Bioenergy, doi: 10.1111/j.1757-1707.2011.01102x
, .
GLOBAL WARMING POTENTIAL OF CO. FROM BIOENERGY 3
allowed to regrow. We use this schemalll: case to retain
the focus on the key resean:h question, without adding
the complexity and additional assumptions linked to
the possibilities of using specific factors like local con-
ditions and biomass management strategies.
ThIs paper ls structured as follows. The current
method used to estimate the atmospheric decay of
anthropogenic co. emissions ls firstly described to-
gether witll a metric for measuring their contn'bution
to GWP. Afterwards, the cfimate hnpact of Co. emis-
sions from biomass combustion (bIo co" from thls
point forward) ls Investigated through the formulation
of proper atmospheric decay functions, which are used
In the GWPbIo Index. FInally; results are presented as a
function of the biomass rotation period, and the most
relevant hnplications related to this methodology are
discussed In the finaJ section.
Materials and methods
Anthropogenic C02 emissions
C cycle climate madels. Co. emissions play a key role
In the earth's C cycle and cfimate system. Those Whlcll .
are classified as anthropogenic (i.e. from fossil fuel
combustion, cement production, deforestation and
land-use cl18nge) are one of the main responsible for
anthropogenic climate cl18nge (Forster et al" 2007).
Complex C cycle cfimate (CC) models, which establish
the link between atmospheric co. concentration and
anthropogenic C emissions by modeling uptake and
excl18nge fluxes of tile atmosphere with the oceans and
the terrestrial biosphere, are used In model the thoe
evolution of airboroe Co.. In order to make analysis
easier for smaller case studies, such as LCA, Impulse
response functions (IRF) are often used to represent
Co. atmospheric decay under given assumptions
(Thblello & Oppenhehner, 1995; JOO8 & Bruno, 1996;
Enting et al., 2001).
The oceans play an hnportant role for tile removal of
anthropogenic C They are generally distinguished Into
the upper layer, which has a vel)' fast tornover rate
(Wanninkhof, 1992), and the deep ocean, to whlcll C Is
transported thrOUgll oceanic circulation (J008, 2003).
ThIs latter process Is tile limiting factor for the ocean's
uptake capactty, which Is determined by ocean volume
and sea water chemistry. TIlls uptake capacity Is
only reaclted after several centurles, and It takes
millennia to eqw1ibrate ocean water and sediments
after a pertorOOtion In oceanic C content. COOnges In
the land biosphere and In the upper ocean Influence
atmospheric Co. concentrations on seasonal to century
thoe scales. Several models dealing with the C cycle
In the oceans have been formulated (Oeschger et al.,
1975; Siegenthaler & JOO8, 1992; Blanke & Delec1use,
1993; Caldeira & I<asting, 1993).
Modeling tile terres1rlal components of the C cycle ls
more challenging because of tile natural variability of
some basic parameters (Enting et al., 2001). The must
common way of modeling terrestrial C transfers ls to
use diacrete compartments as leaves, branches, soil C,
etc., characterizi,c) by an Inttial C content and tornover
thoes. The C transfers from tile air to tha plants ls
described by a net primary production, which may
depand on specific parameters like tempemture, nument
levels, water supply and others. TI", terreslriaI part of the
different cfimate modeIs usually differ In the number of
physiological comparhnents, feedback effects and tile
degree of disaggregation (FriedIIngstcin et al., 1994, 1995;
PrentIce et al., 2llOO; Cramer et al., 2001; M<:GuIre et aI.,
2OOl).
Atmospheric deem). Thanks to tbe elaboration of tllese CC
modeIa It Is possible to predict tile atmospllerlc decay of
Co, emissions (Maier-Rehner & HasseImann, 1987;
Lashof &: Ahuja, 1990; Caldeira & I<asting, 1993; Joos
efal., 1996,2001; Entlnget al., 2OO1}.1n all the cases, Co,
does not follow a simple decay according to one single
lifetime (as it is for the two other main GHG, N.O and
01,), but Its decay is described by several thoe
constants and there is a fractlnn of tile Initial emission
that always remains In the atmoopllere. The fraction
of Co. remaining In tile air following a co. release
depends on future atmospheric Co, concentrations,
because the partial pressure of co. In the ocean surface
ls a nonIinear function of surface lotal dissolved inorganic
C concentration (Caldeira & Kastlng, 1993).
The analytical fonn of tbe atmospheric decay of
anthropagenic Co. Is given by a superposition of a
number of exponentlals of different amplitude A, and
relaxation thoe Tf
f...
yco,(t)=An+LA~-fl',j. (1)
M
The value of tills function at any tinte represents the
fraction of the Initial emission which Is still found In the
atmospltere, and tile removed fraction corresponds to the
ocean/blosphere uptake. The amplitude An represents
the asymplotlc sirboroe fraction of co. which remains In
tile atmospbere because of the equillbrIum response of
the ocean-atmosphere system. TIle amplitudes Ai may be
ink< p,eted as the relative capacity of the other sinks,
whicll are filled up by tile atmospheric Input at rates
cbaracterlzed by the relaxation tinte scales Tf. These tinte
scales determine tile redistn'butlon of antluupogenic Co.
@2011 BIacl<weII Publishing Ltd, GCB BfOlm"8!J, dol: lO.11l1/P757-171l72011.01102.x
4 F. CHERUBINI etal.
emissions in the climate system and are linked to the lime
scales of the natural C cycle. Because of this exponential
decay !rend, more than half of the initial input Is removed
from the atmosphere within few decades after emissions
through uptake by the upper ocean layer and the fast
overturning resezvoirs of the land biosphere. However, a
certain fraction is still found in the abnospllere after 1000
yeatS; this fraction is only very slowly reduced further by
oceaIHJedimeut inleIactlon and the weathering cycle
(Archer et al., 1998).
Metrics for climate change
The climate bnpact of GHG emlssions needs to be
compared with a consistent metric. In this paper tIle
GWP Is used, rather tIlIl1\ other possible metrlcs (Fugle-
stvedt et 01., 2003; Shine et 01., 2005). This metric was
developed as a relatIve measure of the potential effects
on climate of a GHG compared witIl Co... GWP lleavily
relies on the corn:ept of radiative forcing which gives
the perturbation of the earth energy balance at the top
of the atmosphere by a clbnate change mechanism. The
cumulative radiative forcing for a pulse emission,
which is often referred to as the absolute global wann- .
ing potential (AGWP), is given by tile integral over thne
of the product between the radiative efficiency of tIle
gas (~) and the decay function, yet), that defines the
fraction of the gas remalnlng In the atmosphere after a
unit pulse (Co)
AGWP = Co /.'" .y(l)dl, (2)
where tile radiative efficiency (~) of Co.. is (Forster et 01.,
2007)
([CO;])
"<:0, = 5.351n [CO.] .
(3)
Where [C~I is tile concentration In the atmosphere
after small perturbation and lCO"I Is the initial concen-
tration of Co.. In the atmosphere. If the background
concentration of 378 ppm provided by the lPCC report
is used, and a perturbation of 1 ppm Is applied, tIle
t~ 1
value of the radiative efficiency for Co.. is 1.41 X lO-s
Wm-2ppb-l.
Since the decay of a Co.. pulse emission bas a non-
zero asymptote, its integral from zero to infinity is
infinite. To avoid this, several attempts to define an
effective residence thne for Co.. in tile air have been
formulated (Houghton el al., 1990; Lashof & Ahuja,
1990; Rodbe, 1990; Moore & Braswell, 1994). In the
1990s, the lPCC Introduced finite thne horizons (THs)
(20, 100 and 500 years) for integration in the GWP,
where the Co.. decay functIon by Jaos et 01. (1996) was
used (SchimeI el 01., 1996). As specified by the lPCC
Itself, tlle5e different 1Hs should not be considered of
any scientific significance (Fuglestvedt et 01., 2003; for-
ster et 01., 2007). GWPs were then elaborated for all tile
different GHGs (denoted as " according to this equation
GWP AGWP, Co J:' ~,y,(t)dl
,= AGWPco, Co Joni "<:o,yco,(l)dt' (4)
GWP then acts as a metric able to aggregate emission of
the various gases to a common unit (kg CO,,-eq.). In
Table 1, GWPs for given 1Hs are shown for tIle tllJ'ee
most bnportant GHGs, together with their lifetime and
radiative efficiency.
CO2 emissions from biomass combustion
The atmospheric decay of Co.. emissions from biomass
combustion can be predicted with the IRF from C
climate models only if biomass is not replanted (I.e.
deforestation), or a LUC occurs. Even if consistent
results were achieved in upgrading the modeling of
the biosphere compartment (Gerber et 01., 2004), Ihe basic
principles remain unchanged: if biomass is replanted,
emissions from combustion are neutralized by CO" re-
moval during regrowth; if biomass Is not replanted, bio
CO" emissions become anthropogenic CO" (Strassmann
et .1. 2008). TIleIl, a new IRF needs to be elaborated to
predict the atmospheric decay of bio CO".
Modeling assumptions. TIle met1lod developed in this
paper is applied to a well-defined schematic case
study thet is suitable to demonstrate tile approach
Table 1 Lifellme. radlallve effldency, and global wanning potentials (GWPs) for different time horizons of the three most
Important greenhouse gases (GHGs)
GHG
Carbon dioxide (COz)
Methane (Cfl,J
NitrotlS oxide (N,O)
Radiative cffidency
Ufellme(years) (Wm-2ppb-1) GWP 20 years GWP 100 years GWP 500 years
na 1.4 x 10-5 1 1 1
12 3.7 x 10-4 72 25 7.6
114 3.03 x 10-3 289 298 153
00, not available.
<ij 2011 Blackwell Publishing Lid, GCB Bioenergy, dol: 10.1111/).1757-1707 .2011.1l1102.x
I .
GLOBAL WARMING POTENTIAL OF CO2 FROM BIOENERGY 5
proposed (see Fig. 1). It is assumed that all biomass is
burnt in one time step so that the Co., emission is
modeled as a pulse. The biomass harvested is from an
even-aged vegetation stand (representIng the slarling
condition) wInch is dear cut sod the Iaod is
Immediately revegetated with the same biomass
species after harvestIng. We assume that the regrowth,
at the end of the rotation period, captures the same
amount of Co., that was released by combustion (I.e.,
we assume the entire process is C flux neutral). Only
one rotation is assumed. Co., emissions from loss of C
pools other than abuveground vegetation. like soil sod
litter, are not considered at this stage.
According to the most common praclice in biomass
growth modeling (Swanow et 01., 1990; Rossi et aL,
2009), the rate of biomass growth (or regrowth, in our
case) can be modeled as a nonnaI distribution
(Gaussian), expressed as atmospheric C uptake in
vegetation as a funclion of the rotation period of the
biomass. This is a probability density function that has
the following analytical form:
g(l) =~e-(t-p~/2<i', (5)
v2"","
whare the parameters I' sod 0 (mean sod variance) can
be used to represent characteristics of forest growth. It is
assumed that the mean occurs in the year with tIle
maximum C uptake and is taken as half of the
rotation period VI = r /2). TIle variance determines tIle
width of tIle distribution, sod it is hare assomed to be
equal to half mean (0 = 1'/2).
Colclllalion procedures. The concentration in the
atmosphere of bio co., over time can be descn'bed by
~.. .Rotatd:Wpeood,t --_.._~
(a) (e)
u
n
(b)
lima (yearn)
F11} 1 Slmpli/icd scheme of ti,e carbon flux neutral system
modeled In this paper. (a) Biomass SIand .1 _y state; (b) all
abovegtou11d carbon Is harvested aud emllted 10 the atmosphere
asCQz. Simulfaneousl~ the same biomass is repJanted and starts
growing by sequestering the co. released from combustion; (e)
the oame quantity of Cllrbon originally released Is sequ_
once again In the vegetaHon at the end of the mlallon.
means of an IRF whid, refers to the reaction (as a
function of time) of any dynanric system in response
to some external change. In our case, this means that tI,e
atmospheric decay of bio Co., is derived through
rombioation of the biomass regrowtI, sink (tile
Gaussian curve, modeled as a negative emisslon) with
the IRF modeling the removal of Co., by the ocean and/
or terrestrial biosphere sinks. In mathematical terms,
tIrls is a convolution between two funclions, based on a
conventlnnal and widely used approach (Siegenthaler
& Oeschgel; 1978). TIwn, the atmospheric co., con-
centration fil) after a pulse emission can be re-
presented as the sum of earlier emissions g at time
I' multiplied by the fraction still remaining in tile
atmosphere after time I-I'
f(l) = lICeD(I') - g(I')Jy(1 -I')dt', (6)
whare CD is tI,e pulse emission of bio Co., to the
atmosphare, .1(1') is the delta function (wllld, is zero
everywhere except at the origin) g(1') is the rate of
biomass regrowth which removes the Co., originally
released, sod y(t) is the IRF from the C cyde climate
model. EquatIon (6) can be written as follows:
f(l) = l c"o(t')y(1 -I')dt' -l g(t')y(l- t')dt'. (7)
Since Co = 1, we can write
f(l) = y(l) - 1.' g(t')y(l- t')dt'. (8)
This equation describes the almosplleric decay
of a pulse of blo co., over time. The term represen-
tieg the biomass regrowth, g(l'), is defined in Eqn (5),
wIllie tIrree alternative options are possible for the
IRF y(1):
1. Following the OECD convention, bio co., emissions
are removed from the atmosphere by the onsite
biomass growtl,. If this closed I"""p""tive is
adopted, bio co., will decay from the air only
because of tile biomass regrowth. TIrls means that
there are no contributions from the rest of tile C cycle
romponenls, sod y(1) = 1. Since it is totally unphysi-
cal to neglect any Co., uptake from the oceans or
other sinks, tlris option is considered hare only to
analytically demonstrate the inadequacy of tile
OECD convention through the inconsistent results
obtalned. TIUs approach will be referred to as tI,e
vegetation IRF (V]RF).
2. As we have mentioned previously, oceans playa key
rule in the removal of Co., from the atmosphere. In
this second case, tI,e ocean sink is added to the
<1) 2011 Blackwell Publishing LId. GCB Bioenergy, doi: lo.1l11/j.I757-17J17.2D11.o1102.x
6 F. CHERUBINI elal.
veg<!lation regrowth sink by considering a proper
climate model, so giving a specific pro/l1e for the
abnospheric decay of bio CO;" the ocean and vegeta-
tion IRF (OVlRF).
3. As considered In CC models, when a Co. molecule
is released to the atmosphere can be removed by
both the ocean and terrestrial biosphere. In this case,
a complete IRF is used and the resulting atmospheric
decay is referred to as the full IRF (FIRF).
In all the cases, the resulting function fil) is used in Eqn
(4) to get an Index of the relative climate impact of co.
emissions from bInmass combustion
GWP _ AGWPbIoco, Co 10m aco,f(t)dt (9)
bIo- AGWPco, CoJ;;"ot;o,y(l)dt'
VIRF. In tills case, the biomass C cycle is IndependentIy
modeled as a closed system, from combustion to
removal by vegetation regrowth, which is tile only
sink considered. TIlls option appears consistent with
the convention currentIy used In bioenergy LCA, where
co. emissions from biomass combustion are assumed
to be offset by biomass growtIl.
In mathematical terms, tills means thet y(1) = 1, aod
Eqn (8) can be written as
f(t) = 1 -1' g(I')dt'. (10)
The integrsI of this function is the cumuIstive density
function, which is the total C accumulated in the
biomass stand along the full rotation. TIlis integral can
be expressed in terms of the error function erf, so that
Eqn (10) becomes
f(I)=I-Hl +erft~)],
erf(l) = ;"1' e'"'" <Ix.
(11)
TIlls allows the calculation of the atmospheric decay
for Co. emissions from combustion of differeni
bInmass species, according to the rolation period r.
OVIRF. TIlls case models tile removal of bio Co. from
the atmosphere because of two compartments, tile
oceans and the vegetation sink due to biomass
regrOWtIl. TIle rest of the terrestrial biosphere is not
considered here as a possible sink. The same approach
has been considered in the past to predict tile
contribution to climate change of co. ernlssions from
a forest fire (Randerson et 01., 2006). As in the VIRF case,
the vegetation sink is modeled witIl the GaussIan
t'
distribution, wlu1e a proper CC model Is to be used to
predict the atmospheric decay due to ocean uptake. TIle
IRF of scenario It4 from tile ocean model described In
Caldeira & Kasting (1993) is selected. TIlls Is a box-
diffusion ocean model appropriate only on lime scales
lower than 1000 years, when interaction with sediments
and rock cycles Is of secondary importance. in this case,
atmospheric Co. content Is stabilized at 550ppm by
year 2150, the 1990 groWtIl rate in atmospheric co.
content is 1.66ppmyr.' and the growth rate at the
stabilization date is zero. The IRF resulting from this
ocean model has the analytical form of Eqn (1), whose
perameters are reported in Table 2 aod profile Is sllOWn
in Fig. 2-
If Eqn (1) is included in Eqn (8), we have
f(I)=Ao+ fA,..."" - {' ~e.(f.'rzf(JJ.,"f
M io v2nrfl.
(An + fA;e.'.f''')dt'
M
(12)
TIle integral is estimated by numerical approximation.
FIRF. Co, emissions from biomass combustion are here
considered to be removed from all the possible sinks,
the oceans, the terrestrial biosphere aod the onslte
biomass regrowth. TIlls integrates bio Co, enlissions
into the global C cycle. A complete IRF should be
therefore used. Among tile existing models, the IPCC
FourtIl Assessment Report selected the IRF derived
from an updated version of the Bern 2.5CC model
(Forster et 01., 20(7). in this paper, the same IRF is
considered. A detailed description of tills model can
be fuund elsewhere (joos el 01., 19%, 2001). TIle analytic
furm of this IRF has been shown in Eqn (1), while its
Table 2 Parameters to be used In Eqns (1) (Bern CC model
IRFl and (12) {ocean only IRFl
Ocean only Bern 2.5CC
Parameters IRF mode11RF
An
A,
A,
A.
^'
0.297
0.321
0266
0.lJ83
0.033
335.8
18.4
2.8
0.8
0217
0.259
0.338
0.186
Tl
T,
Ta
T4
172.9
18.51
1.186
IRE Impulse response luncliOll.
ID 2011 Blackwell Publisbing Ltd. GCB B_ergy. dol: 10.1111/j.I757-1?U7.2011.ll1102.x
r ~
GLOBAL WARMING POTENTIAL OF CO2 FROM BIOENERGY 7
...
..s
..1" (kean-flnly lR.t
.j 0.7
"
~ o.G
"
'E
'!. 0.5
!
g 6.4
.
0'
;.. ll.3
- Helm l..~.e mfNkoJ lIU"
"""-,
0.2
0.1
o
o
'-'"
...............
......,
..........
'.,.........,-....-.
100
:roo
.tOO ..... SOIl
'111D("()'f1m)
600
700
8UO
Fig. 2 Atmospheric decay of a pulse co. emission a<:cotdlng to the !WO different complex carbon cycle climate (00 models
considered.
parameters are reported In Table 2 and !he curve is
shown In Fig. 2. TIte profile of this function should not
be dlrectly compared with that of the ocean-only IRF
presented In !he previous section, because !hey are
based on different conditions and parameters (even
though a slowest decay is predictable when oceans
are the only sink).
In this case, Eqn (8) can be expllcitly written as
follows:
f(t) = (AO+ ~A",-tl')
_ r' ~e-W-'/2i'fM'>'(Ao+ fA...-t-rl")M.
10 ~ ~l
(13)
The inlegraI is estimated by numerical approximation.
The lncIusioo of the terrestrial biosphere component
among the sinks allows the uptake in tile natural
biosphere, but will potentially include a (small) form of
double counting of lhe vegetation cum!"" Inoent since also
the onsite vegetation regrowth is considered. However,
this should not be the case because the Bern 2.SCC model
only considem lhe potential co, uptake from stimulatioo
of plant growth by elevated atmospheric Co.. levels
aud enhanced nutrient supply, aud 'does not Include
fonnulation for forestry management nor bioenergy
production' (Slrassmann et ol. 2008).
Resnlts and discussion
Bio CO2 atmospheric decay
In Fig, 3, the tI>ree different IRF describing the decay of
bio Co.. emissions from tIle atmosphere are oomparad
for selected rotation periods of 1, 10, 20, 50 and 100
years, as weD as when r ~ 00 (that is trees are not
replanted). The decay of anthropogenic Co.. according
to tIte Bern 2.5CC model is also shown for comparison.
This decay appiles In case of deforestation or perma-
nent terrestrial C losses.
For V1RF, OV1RF and FIRE tIle longer tIle biomass
rotation period, the longer is tIle mean stay of Co.. in
lhe atmosphere. TIle effect of the rotation lengtIl on the
FlRF-based decay is shown In Fig. 4, where the bio CO2
fraction remaining In the air after a pulse emission is
reported as a function of time and biomass rotation
period. In lhe long term, aD lhe decays asymptotically
tend to zero, since a C flux neutral system is modeled.
As already mentioned, the V1RF curve is based on the
OECO convention of a closed cycle for biomass-derived
Co.. (from combustion to uptake In new trees). TItero-
fore, the resulting atmospheric decay simply represents
tIle Inverse (from an atmospheric point view) of lhe
sigmoid cumulative C accumulatioo curve describing
biomass regrowth. This is clearly Inconsistent witIl CC
models: If trees are not replanted bio co, would never
decay, as silOwn In Fig. 4 (VIRF) with r -+ 00. SUcll a
result is obviously a paradox, and can be seen as an
@2011 Blackwell Publishlng Ltd, GCB B~dol: 10.1111/j.I757.17D7.201I.o1102.x
8 F. CHERUBINI elal.
1.1
...
t ..
0.7
i ...
o.,
IU
..
~ o~
...
'"
...
0
0 10
j
}; t.6
S
..
I:
8'
...
g
! ...
~
I ...
~
s' ...
0
...1
VlIlf
.an on so
n.(I)(yfm)
0Jl
'i' :)
-......
-,....to
"'=- raU
-r=>5IJ
_ f'urGO
_ t'---<o't
- fk1'I:i2-<trmtJtbJ
100
uo
o
.....
TI"'(IH~fO"'1
,...,. roo f
-,.""10
~- r"" 2D
- r"'SO
-,.",-100
-r-....'t.
- Ik'ro UC'c ntUtkJ
_r"'l
-- r~IO
~~ "",-20
_I'''''!UJ
-,.:::.100
- f'-. dUern2.5Ct.~.fWlIIclt
TImoCOll<m)
Fls. 3 co, oimosp/l<rJc decay followlng the vmF. QVIR!' and FIRF moIhod for selected rolallan pmods (I; years). VlRF. _milan
Impulse _!undion; OVlRF, ocean and ""JlflalIon Impulse _Iundio", FIRF. IuU impulse response function.
FlRF
,O2()11 BlackWell Publishing U<I. GCB ~ dol: IO.I1lI/P757-17ll7.2011.onm.x
.. ~
GLOBAL WARMING POTENTIAL OF CO,. FROM BIOENBRGY 9
,.0
-....
=...
c:=J u
_u
CDU
-..
_t.G
-,
,
I
I
I
I
1
1
I
I
...
\1 ::
If.
,
... 50
'.. ~
'30 "'~
'20./1
~ ~
'1D ~;1'
~1j;
'-40-" -
. GO-.
'....--.,.:: - 100'
FIg. 4 Wo co. AUl105pllerk _ AS A _ DI_......
blo...... n>tallon perio<l fur ll1l> FIRF ...... FllH\ fun. ~
~illn<Ifon.
a:naIyIlcaI--derived evidence of the physIatllna~
of the OECO convention.
the profile oI the curves from OVIRF and FIRF are
similar, since they are both the outrome oI a convolu-
tion operation beI"eeh the Gaussian and an exponen-
tlaI funcllon. As It would have. been e<pecled, the
OVIRFd<icay is slightly longer than the FJRF, where
the Co, lIeqU!!Slmtion is favored by the Inclusion oI the
terrestriaI biosphere slnk. This can be appnlclalec;l by
looking at the points when> the curv~ turn to negallve
valW!S:forr = 100 years, the OVIRFbecomel negative at
t ~ 71 years, whlle the FIRF at I ~ 65 years. ~
r - 00, the curves are equaI to the '''''l'''''t1ve fom:Jfon
y(t) derived from the CC model considered. inEqns (12)
and (13), for the OVIRF and FIRF case, tespectlveiy.
Among the three methods, the FIRF appears as the most
physlcally and logically consistent, and the curve for
r - oocolncldes willltbe anthropogenic CO. d~Y'
At 6rst sight, the presence of negallve values In the
atmospherle decay prQIlIes of OVIRF and EmF may
appear as a contradietlon, because tbeamoUlilof Co..ln
thealtnosphere is lower than the level before tbe emis-
sion. The reason for this is that atmospberle co. is
taken up in dIffimmt blogeoehemitl>l sinks at different
ll:me constants, as mathli!ll1lltlcally ~led by Eqn
(1); as impl1dtly assumed by I!qn (8), the same time
constants are also applied to co. uptake In biomass
regrowth. Soon after the emission, when the biomass
grOwth rate is stlU slow, a significant fraction of the Co..
originaDy released ill quickly stored In the ocean upper .
laYeJ:The foIlowlng transport oI t1tis C to the deep
ocean Iayel'!! Is slower, and when the uptake by the
onsltel:1i_ regrowth increases, the C lnit:IaIIy sloted
in the ocean upper layer Will be released bad to the
atmosphere ata low rate to compensate the InillaJ
overabsorption (out-gasslng). In the long term, the air-
borne fraetlon oI bio Co.. iq>plOOebes zero.
Tlte GWPbIo illde:r /l/1d its i/lkrprellltW/1
The curve; of FIg. " areused to get the climate effect of
co. eotissions from bI_ combustion after their
inclusion in 1lqn (9). This is a metric relative to. the
climate effl!ci of anthropogenic Co.. and based on the
IniegratiOn up to a defined TH. in Table 3, the CWP...
index Is reported as a funcllon oI the biomass rolati!>n
period for the VIRF, OVIRF and FIRF. TI""", results are
shown for lha tbreemost common 1Hs (20, 100 an4 SOD
yeatS). The use oI tills Index Is Identical to the other
GWP equlVa.1ency factors: It Is to be multipUed by the
dire<:t CQ, emissions from biomass rombustlon to get
their relative contributIon to global warming in terms of
kg COz-eq. This allows an estimate of the climate impact
oI co. flux neutral systems in LCA and other similar
methodologies. Results are intended to begeneraUy
applied to an bIomass sources (speclfled with the rota-
tion periOd) from annual row crops to fast growing
biomass, trOpIcal, temperate and boreal foresls. l'o1'
annual crops and for short rotallon ~pedes, the rotation
period is usually very sitort, from 1 to 5 years. The
resulting CWPblu Is small, $ce the average lifetime of
bin co.. In the atmosphere In this case Is so short that
the contribution to global warming islimiied. When the
rotation period becOlllllS longer, e.g. from fast growing
~pecies (r = 5-20) to trOpIcal (r = 25-50), temperate
(r=55-80) and boreal (r=80-100) forest, the climate
impact increases atCOrdingl)< The fad that GWPbIu Is
larger for longer rotation periods should not be over
interpreted: it only means that short rotation biomass
(e.g. annual crops, short rotation coppice) ha~ less
climate Impact t!IlUI long rotation biomass (e.g. forest
wood) per unit of Co.. emittedfrom tbe CODll>l1$I:Ion of
the biofueL Belorederiving general conclusions, t!Iere
are many other aapeclltto be considered Uke effideney
in biomass convenllon proc:esses, number of rotations,
seleetion of proper time and spatial ~, land.
use changes and other life cycle implltatlons (1!ke
material and energy inputs for c:uitivatlon, harvellting.
processing and transport). Land-use changes could also
include facto.-.; sodtas dtangell in surface albedo (in
partleular at latitudes wlt!I seasonal snow cover),
change in soli C ronlent, and thanges in fluxes of heat
and humidity between the1lUrface and the atmosphere.
Misleading conclusions am Clnly be avoided by lIt-
tDunting fot aU climate forcing agenlS, Uke GHG entis-
slons, removals and, in Slllt\e cases, substitutions,
wlt!Iln a IIfe..eycle perspective, preferably using case-
,. 2OIIllIad<well I'tlbIisblng Ltd, GCB ~ dol: lo.11l1/j.I757-17D7.201I.oU02.l<
',~
]0 F. CHERUBINI ela/.
Table 3 GWP"", Index calculated with the tIuw dlfferen. methods and for three different time hmizons; 2IJ, 100 and 500 yearn
VIRF OVlRF FlRF
GWPbIo GWPbIo GWPbIo GWP",. GWPbIo GWPbIo GWPbln GWPbIo GWP""
Rotation r (years) TIl~2IJ TIi~l00 TIl~500 TIl~2IJ TII = 100 TIl~500 TIl =20 TIi=loo TIl=500
1 0.04 0.01 0.00 om 0.00 0.00 0.02 0.00 0.00
2 O.os 0.02 0.01 0.05 0.01 0.00 0.04 0.01 0.00
4 0.15 0.04 0.01 0.11 0.02 0.01 om 0.02 0.00
6 023 0.07 0.02 0.16 D.04 0.01 0.13 0.02 0.00
8 0.30 0.09 0.05 0.21 0.05 0.01 0.18 0.03 om
10 0.38 0.11 0.03 0.27 0.06 0.01 0.22 0.04 0.01
12 0.45 0.13 0.04 D.32 0.07 0.01 0.27 o.os 0.01
14 ll.53 0.15 0.05 0.38 0.08 0.02 D.32 0.06 0.01
16 0.60 0.17 0.05 0.44 0.09 0.02 0.37 0.06 0.01
18 0.68 0.19 0.06 0.50 0.10 0.02 0.42 0.07 0.01
2IJ 0.75 0.22 0.07 o.ss 0.12 0.02 0.47 0.08 0.02
22 0.82 0.24 0.D7 0.61 0.13 0.03 0.52 om o.oz
24 0.89 0.26 0.08 0.66 0.14 0.03 0.56 0.10 0.02
26 0.95 0.28 0.09 0.71 0.15 0.03 0.61 0.10 O.oz
28 1.00 0.30 0.09 0.76 0.16 0.03 0.65 0.11 0.02
30 1.05 0.32 0.10 0.80 0.18 0.04 0.68 0.12 O.oz
32 1.09 0.34 0.10 0.83 0.19 0.04 0.71 0.13 O.oz
34 1.13 0.37 0.11 0.86 0.20 0.04 0.74 0.14 0.03
36 1.16 D.39 0.12 0.89 0.21 0.04 0.76 0.15 om
38 1.19 0.41 0.12 0.91 0.22 0.05 0.79 0.15 0.03
40 1.21 0.43 0.13 0.93 0.24 0.05 0.80 0.16 0.03
42 123 0.45 0.14 0.95 0.25 0.05 0.82 0.17 0.03
44 1.25 0.47 0.14 0.97 0.26 0.05 0.83 0.18 0.03
46 1.27 0.49 0.15 0.98 0.27 0.06 0.85 0.19 0.04
48 1.28 0.52 0.16 1.00 0.28 0.06 0.86 o.2IJ 0.04
50 1.30 0.54 0.16 1.01 0.30 0.06 0.87 0.2l D.04
52 1.31 0.56 0.17 l.oz 0.31 0.06 0.88 0.21 0.04
~ 1.32 0.38 0.18 1.03 0.32 0.07 0.89 0.22 0.04
56 1.33 0.60 0.18 1.03 0.33 0.07 0.89 0.23 0.04
38 1.34 0.62 0.19 1.04 0.34 0.07 0.90 0.24 0.04
60 1.35 0.64 0.20 1.05 D.36 0.07 0.90 0.25 0.05
62 1.35 0.67 0.2IJ 1.05 0.37 0.08 0.91 0.26 0.05
64 1.36 0.69 0.21 1.06 0.38 0.08 0.91 0.27 0.05
66 1.36 0.71 0.22 1.06 0.39 0.08 0.92 0.28 0.05
68 1.37 0.73 0.22 1.07 0.41 0.08 0.92 0.29 0.05
70 1.37 0.75 023 1.07 0.42 0.09 0.93 0.30 0.05
72 1.38 0.77 0.24 1.08 0.43 0.09 0.93 0.30 0.06
74 1.38 0.79 0.24 1.08 0.44 om 0.93 0.31 0.06
76 1.39 0.82 0.25 1.08 0.46 om 0.94 0.32 0.06
78 1.39 OM 0.25 1m 0.47 0.10 0.94 0.33 0.06
80 1.39 0.86 0.26 1.09 0.48 0.10 0.94 0.34 0.06
82 1.40 0.88 0.27 1.09 0.49 o.tO 0.94 0.35 0.06
84 1.40 0.90 0.27 1.09 0.51 0.10 0.95 0.36 0.06
86 1.40 0.92 0.28 1.10 0.52 0.11 0.95 0.37 0.07
88 1.40 0.94 0.29 1.10 0.53 0.11 0.95 0.38 0.07
90 1.41 0.% 0.29 1.10 0.54 0.11 0.95 0.39 0.07
92 1.41 0.98 0.30 1.10 0.55 0.11 0.95 0.39 0.07
94 1.41 0.99 0.31 1.10 0.56 0.12 0.95 0.40 0.07
% 1.41 1.01 031 1.10 0.58 0.12 0.% 0.41 0.07
98 1.41 1.03 0.32 1.11 0.59 0.12 0.96 0.42 0.08
100 1.42 1.05 0.33 1.11 0.60 0.12 0.% 0.43 0.08
GWP, global warming potential; VIRE vegetation Impulse response function; OVIRE ocean and vegetation impulse response
function; FIRE full Impulse response function; 111, time hmizon.
<D 2IJ11 Blackwell Publlshlng Lbl, GCB Bi=1&!b doi:.I0.1111/j.1757-1707.2011.01102.x
. ~
GLOBAL WARMING POTENTIAL OF CO2 FROM BIOENERGY 11
.specllic paramelets. ~re, Table 3, c(0$ noteX?u..
dlly mean that one biomass llOUJ'<e is b!ilteT than others:
a lower value of the indO)( does not necessarlly reflect a
lower climate impact of the whoW 1>Ioemlrgy system.
FIgure 5 shows the value of the GWP"", index as a
function of the biOtNSS Itllallon period fur the three
different cases and fur the three selected Tlis. '!'he
<:urves have an ""JXIRIl1ttialllend to a maxlmum, wbich
bas the same value fur eadi method.and can be better
appreciated fur TH =20 yearS.
The GWP"", is bigger' fur shork!r TH, because this
indO)( considers the area below the decay curve of bio
co. relative to that of antbropogenkeo,.. The latter has
a fast decay In the firslyears soon after theemfsalon and
then a $low asymptollc trendtpWards the ocean/almo-
llphere equlllln:lutn, wlUle blo eo,. decay tends to zero.
The fIlct that GWl\,. are higher furTH = 20 yean;.l>lther
than for TH = 100 or 500 years confirms that bipeDl!rgy
is a climate cl\ange mitigation strategy particularly
effective fur Iqng..termtllrg$.
The VIRF-based GWP"", Is larger than one for smne
droumslances. This is a dlrect consequence of the
OECO conventlon on whldi the VIRF decay Is based:
the O)(c1usloo of the ocean and terresIrlal bIo!lphere
uptake other than the onsile regt<>Wllt can make the
Qlmate impact of bIo Co. approxllnately 1.5 lilneS
higher than that of anthropogenk: Co... This result Is
further eyldenl:e about the shmtcomings of the exlstlng
a5l;1Ittlption 00 the closed cycle for blomass-derived
eo,. emissions.
1.60
1.40
\'DtJHt-tu
\1JlfTU"UilJ
....~ \UU ,n-ffO
-,_. O\uu fU--ltP
- -- lnlRflQ:..rw
= '"'"', 0\00 'n.su
-nunhia-
-nl!fut..1IIQ
~m'O_
uo
1.00
o.w
,.
.....
"
.'
"
.'
"
"
.'
"
.'
.'
"
.'
"
"
"
.'
.'
.'
.'
..- ~-
.... ...-
....1ll"l:......j!liII "".........
.' _ "_r:cl=~ .:""____F=_~"""'
-~~
titIP"p"'--
",-
-.....
",'"
tJ;iJJ~'iiii!i. "'...."'......
c:::o-#" .t~fi..........,...,,,..
..."'..................
- "':"'~_,-~~""'- - =' - ~-o."::: :".
:l
"tJ.8lI
~
0.60
0.40
0.00
o
10
w
JO 40 50 60 '10
Ilmol.... ptrlod 1r."_1
90
, ConcernIng the OVIRF-based GWP... values slightly
higher than one can be ob1lllnedfur TH '" 20 years wtth
Itllalloo periodSlDnger than 50 years. The tcason can be
seen in the COl'l'esJl<lIld graph in Fig. 3: In the first
~ soon after the ~nllssIon. th~ OVIRF with r larger
than 50 years has a .$lower decay than the decay fn>m
the Ber112,SCCmodel (used as ~ In the metric),
thus affactlng the GWP"", fur TH. = 20 yeaJl!. By con..
trast, the'F1RF-based GWl\to JndO)C tlUIges from 0 10 1,
since the same 1RF Is used as y(t) III Eqn (8) and
reference In the melric. In this case, tIie climate impact
derived from biomass c:ombuslfon and subsequently
teabsorbed in the ocean and terrestrial sInl<s am nWer
be higher than the impact of the _ quanHty released
by fossiUuel combustion or deforestallon. Owing to the
c:onsi4eralIon of alI.lhe C cycles with terrestrial and
ocean sInl<s, the FlRl' ntethod has the _ consistent
results which should be used in bkJeilertly LCA sllIdI""
to esll1tlme the climate Impact .of Co.. ~ from
biomass combustion.
Cllncluslons and nm out1ook
The work I-fw....d in this paper brings a new con-
bibullon to the rising discussion on the proper account-
ing Of eo,. eml5sl0nll from biomass combustion in
bloenergy systeinS. Even If percelved lll;. urgerrl, a
methodology able to quantify the effective cIInuu!l lm-
pact of biOlUll$S.,dlllived Co.. e~ with l1l1it-based
lndlcalUrs was llOt elaborated by LCApractiIloners. The
,~..~.. .
-- ~ ' .
"
...,. ~"..,,~..,.~"'.~". ~.~..~,.
r"' =..,.,.~~."... """'''''' -''''''''--."'''', .~::
"",,"-
80
100
FJs. 5 GWP... fur TH equal 1020, 100 and 500 yean; "",a _on of lI1e l>IOmlls> n>tall<m .perIod. ~ global Wll1'inlng polenllal: TH,
Ilme horizon.
," 2011 Illa<kweU Publlsbh1g Ltd. GCB B~dol: lo.llIl1j.1W-l7D1.20ll.lI1lO2.x
12. F. CHERUBINI "tal.
most important conhibutlons of this work are the
formulation of IRF for the atmospheric decay of
Co. emissions from biomass combustion and the
adoption of an index, the GWP_ to estimate
their climate Impact. Three methods were formulated,
the VIRF, based 00 the closed cycle of bio COz, the
OVIRF, whicl, includes the ocean uptake, and the FIRF,
whicll considers the foil C cycle wlth ocean and terres-
trIal sinks. The FJRF.based GWPbIo is the most reliable
and accurate optloo, given its complete conslderalioo
of all the C compooents and biogeochemical sinks.
The GWP equivalency factor currently used for co.
enllssions from biomass combustion in LCA should
be revised: rather than a value of 0 (when the
OECD convention is strictly followed) that underesti-
mates the climate Impact of the bioenergy system, or
1 (as performed by studtes considering the initlai
co. sequestration during plant growth or by studies
based on forest C dynsmics) that overestimate the
climate impact of bio COz, this work proposes a figure
between 0 and 1, depending on the rotation period
of tile biomass harvested. This is a first step towards
tI,e overeoming of the inadequacy of Co. accounting
in LCA and the development of an accurate and
standardized procedure.
This work aets as starting point for foture research
activities and investigation of specific case studtes. In
order to keep the focus of the paper on the development
of a methodology to quantify the climate effect of bio
co. emissions, a scllenlatic case based on one single
rotation and witl, well defined initial conditions and
parameters has been selected. The theoretical basis and
calculations developed here can be expanded to model
more specific case studies, with customlzed biomass
growth cmves, multiple relations, particular manage-
ment strategies, different starting conditions (e.g. affor-
estation rather then deforestation) or other specific
factors. These outcOOle5 can also be integrated witllln
software tools modeling the climate effects of biomass
production on terrestrial C pools and the environmental
Impact of bioenergy systems.
Besides LCA-based applications, of particular interest
is the possibility to include the onlcomes of tills work in
national GHG accounting mecll8nisms, so to revise the
OECD convention presented at the beginning of this
paper. The FIRF for bio Co. is suitable to be combined
with the existing accounting of C stock cllanges to
develop a robust and thorough C accounting frame..
work. TIlls application may have significant Impects on
national GHG reporting for bioenergy production, and
consequently needs to be investigated further to explore
advantages and disadvantages. Implications at a policy
declslon level can be also relevant: new strategies taking
into accounl the climate Impact of Co. emissions from
'I>
the temporary C Joss needs to be established in order to
read, the intended climate policy targets.
Acknowledgements
The wnrk was funded by the Norwegian research council
through the 'Bio-energy Innovation Cenlre-CenBlo' (Cherubini,
5tn>mmsn and Hertwich), 'lhlllSport and Environment - Mea-
sures and PoUcics' (Peters and Berntsen) and 'Terrestrial C
sequestration potential In Norway und... present and future
climate' (Peters). We tlmnk Ollar Mlchelsen, Ryan Matthew
Brlgh' and GoolIroy Guest (NTNU) for tit. fruilful discussions
and thcir critical review of this work.
Referen<es
Archer D, Kheshgi H, Maler-Reimer E(l998l Dynamics 01 fossI1
fuel neutralization by Marine eacQ,. Glcbnl Biogtothemlerl
Cycles, 12, 259-276-
Blanke B, Defucluse P (1993) Variability 01 the lropiea1 Atlantic
Ocean simulated by a general drcu!allon model with two
different mixed-layer physics. Iournol of Physim/ OceanOjll7lphy.
23, ]~1388. .
Illlrjesson P, Guslavsson L (2000) Greenhouse gas balances In
buDding construction: wood versus ~ from life-cycle
and furest land-use perspectives. Energy Policy, 28. 575-888.
Caldeira K, Kastlng IF (1993) Insensitivity of global warming
potentials to carbon dtoxtde mnission scenarios. Milum, 366.
251-253.
Qlrpentierl M, Corti A, lombardi L (2005) Life cycle assessment
(lCA) of an Integrated biomass gaslfication combined
cycle (lBGCC) witlt Co, removal Energy Conversion 41Id Mon-
agemen.. 46, 1790-]Bll8.
Cherubini F, 5tn>mmsn AH (201]) U!e cyde assessment of
bioeuergy systems: state of the art and future chsllenges.
Biorcsmm:e Tec1mology. 102. 437-451.
Cramer W. Bondeau A, Woodward Fl et al. (200]) Global re-
sponse of terrestrial crosystem structure and function to COz
and climate change: results &om six dynamic global vegeta-
tion models. GloIJaI CltllI1ge Biology. 7, 357-373.
EnlingIG, WigleyTML, Heimann M (2OOl). Futnre emissions and
cuacenlraJimlS of curiam dkttide: key =/almospfn:repmuI ""...
Iii""" Techniea1 paper no. 3], CSlRO Divislon of Atmospheric
Research.
Forster P, Ramaswamy V. Arlaxo P et aT. C!1J07) Changes In
abuospherlc constituents and In radlalive Iorring. 1m Clha.,.
Oumge 2007: TIre Physical Sdmce Basis. ContribuIfon of Working
Group I w Ute Fourth Assessntent Report of /lie Intergovernmental
Panel on Clhmlte Change (ed. Solomon $), InIergovernmental
Panel on OImale Change, Cambridge, UK.
FrIedllngsteln P, Fung J, Holland E, John I, Brasseur G, ErIckson
D, Sclrlmel D (J995) On the amtribution of Co, _tlon to
the missing biospheric sink Glcbnl Bicgl!lld_ Cydts, 9.
54]-556.
FrIedllngsteln P, Mllller IF, Brasseur GP (]!)94) Sensitivity of tile
terrestr!aI biosphere to climatic changes: Impact on the carbon
cycle. E11lJiromnental PoI""iDn, 83, ]43-147.
@2011 Blackwcll Pnbllshlng lid, GCB Bioeuergy, dot: ]O.111]/j.1757-17117.201].Ol102.x
t .
GLOBAL WARMING POTENTlAL OF CO2 FROM BIOENERGY 13
Fuglestvedt IS, BErntsen 11<, Godal 0, SauilOn R. ShIne KP.
Sko:Ivin T (2008) Metrit:s 01 c1_ clumge: llSSellSing rodia-
live fnrdng and emissloo indices. Climate Challge, 58, 267-331.
GorberS, loos p, PrentlreC (2lJ()4) Sensitivity 01 a dynamic global
'.....tluA model to climate and atmospberic; Co... Ghlbal
Change BiD~ ro, 1223-1239.
Hannon ME, Ferrell WI<. Pranl<lin JF (1990) Effects on carbon
storage of con_ 01 old-growth forests to yoang forests.
Science, 247J 699-702.
Hoagbton JT, lenkIns Gj, Epbmums 11 (1990) CHlI1Dle Cllange. The
IPCC Screntlflc Assessment, New York, USA.
Hoo H, Wang M, Bloyd C, Putscbe V (2008) Ufu.cycIe assess-
ment of energy use and greeabouse gas emissions 01 soybean-
derived bindleseJ and renewable fuels. Envlnmmenlaf Science
alld Tecllnology, 43. 750-756.
IPCC (2006) Gllldellnes for Natianal Gremlro,lS< Gas lnuentaries,
Volllme 4-AgrladtIlTO. ForesIry and atller Imrd l1se.lntergovern-
menial Panel 00 CUmote 018llge, Hayomo, lapan.
lobnaoa E (2009) Goodbye to carbon neutral, gelling biomass
footprints right. EJIlHmnmtlrtallmpad Assessmml Review, 29..
165-168.
loos P (2008) The anthropogenic pertorbaHon 01 atmospheric
co" and tlle climate system. In: _ _, dcvelapnrenls in
blnlec1Inalogy and l>ioengin<erillg. Special/;sne; Blolec1loalogy ond
1IIoeogin<eriag ir{ co" jimlloa (edo BboHocll8l')'ll SK, Mal 11<,
OlllkrabarU Sl. Trivnndrum. India, 183pp.
loos F, Brnno M (19%) Pulse response functloan arecost_t
tools to model Ule link between carbon emissIoas,_ospbetic
co" and gIubnI warming. Plrysi<s and Chemisl'll of IIIe f.nrtIl, 21,
471-476.
JOO$ F, Broao M, FInk R, Stocker TF, 5iegentlWcr U, Le Quere C,
Sarmiento IL (19%) An efficient and accumte representation of
complex oceanic and bioopberic models of onlbrnpogenic
carbon uptnke. Tellus,48B, 397-417.
Jons P, Prenllce IC. Sitch S of 01. (2001) Global warming_
on terrestrial. carbon uptake under !be Intergova-nmenlal
Panel on Oimate Oumge (II'CC) emission ~ Glahnl
BWgeocIomriml Cycles, 15, 891--907.
Khn S, Dale BE (2008) Llfu cycle ~"'d of fuel elbanol
derived from com grain via dry mllling. Bioresmm:e'll1c1malogy,
89, 525lJ-.5260.
I<wz WA, Dymond CC, White TM of 01. (2llO9) CBM-cF83, a
model of carbon-dynamica In forestry and land-use c1umge
implemenHng IPCC standards. Eal/ogiml ModelHng, 22fl,
480-504.
LasImf DA. Almja DR (1990) Relative contribuUons 01
greenllOUSO gas emlssku1s to global warming. Nohrre, 344,
529-031.
Loo L, van dot Vuel Il. Huppes G, Udo de Ha.. H (2llO!>)
A1JocaHoa lssu<lS In leA meil1odology: 0 case study of com
Slovot.1Jased fuel eIbanoL '1lre 1u_1 Jmlmal of LIfe Cyde
Assessment, 14, 529-539. I
Moler-Reimer E. Hassebnono K (1987) Tmnapott and storage of
co" in Uu> ocean - an Inorganic ocean-cln:ulaHon Carbon
Cycle ModeL Climate Dy/lllmics, 2, 63-90.
Mnnomet (2010> Biomass SustalnablHty and Carbon Polley
Study. In: _'amls BimnnssSnstoinobilihJondCnrlrou Pnlicy
Study; Report 10 IIIe Cmnmlllllmlllll of _lu,sells Department
of Energy Resollre"" (ed. Walker n, Colllributon< CardeJUc:bio,
P, Co1ncs, A, Gunn, J. Kittler, B, Perschel, R, Recchia, C, Saah,
D, and Walker, T. Manomet Center for Conservation ScIences.
Brunswick. ME.
Marland G (2010) Aa:oonHng for carbon dioxide emlssIoan from
bioenergy systems.fonrnnl of llrdnslrlol Ecnlogy. 14, 866-869.
Morland G, Scblamadlnger B (1995) Biomass fueJs and forest-
management strategie!< Imw do we mkulate lbe greenbouse-
gas emissions benefiis? Energy. 20, 1131-1140.
MIlSI!I'Il 0, Garea-Callgarls JF,Kanninen M eI al. (2008) Modelling
carbon scq.-aHon In nlforostaHoa, agrnforesiry and forest
management pmjects: !be C02FlX V2 approadl. Ecnlngiml
Model/i/1g, 164. 177-189.
McGuire AD, Sitch S. Oeln IS of 01. 1200Il Carbon balance of !be
terrestrial blospbere In Iba 1'weniletb Century: nnaJyses 01
Co,. climate and land use effects wilb four process-basnd
ecosystem mndels. Glahnl BWgeocI_ical Cytles, 15, 183-206.
McKeclmfe I, Colnmlm S, CIu:n I. Mabee W, Maclean HL (20]0)
Forest bioenergy or forest carbon? A",."..mg trad....,ffs in
greenllOuse gas miHgaHon with wond-basnd fuels. Envinm-
mental SdOl101aJrd Tec1Inalogy, 45, 789-795.
MlllIenolen K, GrIlnkvlst S (2OOn AD co" Is nqualln !be atmo-
sphere - a commenI on CDM GHG accoan6ng standards for
me!bane recovery and oxldaUon proj<!cts. Energy Pnlicy, 35,
3675-3680.
Moore S, Sraswcll BH Cl994l The lifelime 01 exCl?SS atmospllllric
carbon dioxide. GIDbaI Biagelld1enlicnl Cycles. 8, 23-28.
OECD (1891) Estill1Dlion of gmmlll1l/S(f gas emissiollS nod sinks. Final
report from Iba DECO experis meellng, ]8-21 February, ]891,
OECD. Paris.
o.scbger H, Siegenthaler U, Scbotterer U, GngeJmann A (1975)
A box dIffusIon model to siody Iba carbon dioxIde excI18llge
in nature. Tel/lIS, 'Zl, 168-192-
peteJaen Raymer AK (2llO6) A compmiscm 01 avoided green-
!muse gas emissions when uaing different kinds of wood
anergy. BiDOtOllS and Bioenergy, 30, 605-617.
Prerillce C, Heimann M, Sl1cb S (2000) The catbon balance of lbe
terrestrial biosphere: ecosystem mndeJs and atmnsplteric ob-
servaUons- EtoIogimi Applicnliol1S, 10. 1583-I5'lJ.
QuIrIn M, Gartner SO, Pelmt M, Relnbardl GA (2004). CO,
miHgellon IllrangJI binftlels i/1 tile Imnspnrl S<<Ior: _s mu!
perspecllnes. In: L f. E. a. E. R. OFEU) (Ed.), Main Report.
Heidelberg. GermanI' 57 pp.
Robl A, Benoist A. Dron D, Penpor6er S, Spndaro IV, ZougIurlb A
(2llO7) How to account for co" emlssIoan from biomass in an
LCA-Inlernnlinnnl Jmmml of Ufe Cycle Assessmenl, 12, 281.
Rand"""," )T, Uo H. F1anner MG eI al. (2llO6) The bnpact 01
boreal forest fire on _ warming. Sdence, 314, 1130-1132.
Reljndem L, HoJjbregta MAl (2008) Biogenic greeabouse gas
emlssloan linked to !be life cycles of biodleseJ derived from
European rapeseed and Brazilian soybeans. Jmmmi of Cleaner
Pnrdllcliml, 16. 1943-1948-
RodIm H (1990) A comparison of tile conlribuHon of various
gaa<lS to lbe greeabouse effucl- Scimce, 248, 1217-1219.
Rossi S, Tremblay M-I, Morln B. Savard G (2009) GrowU, and
producUvily of blsck spruce In even- and uneven-aged slands
at Hle IJmlt of Ule cIcnnd boreal forest Fores! EtoIogy aad
Mn/lllgenrent, 258,2]53-216].
(\) 2011llJsckweJI Publishing Ltd. GCB 8ioenergy, do" lo.1l11/j.]757-I71172011.o1102.x
14 F. CHERUBINI etal.
Schelhaas M), van Esch PW, Groen TA (2l)O4). COlFIX V 3.1 - a
modelling framl!loork fur qualltlfyhlg _ sequestralion ill
fares! _ysJcms. ALTIlRRA Rcpart 1068, Wageningen, the
Netherlands.
Schimel D, Alvas D, Enllng 1 et 01. (19%) Radiative Iorclng of
climate change. In:. Climnte arouge 1995. The Sdf'1tt:e of Climate
ClJtwge (eds Houghton IT, Meita FiIho LG, CalIander BA
et al.), pp. 6!H31. Cambridge University Press, Cambridge.
Scltlamadlnger B, Marland G (199601 The role of forest and
bloenergy slraIegIes In the global carbon cycle. BlollUlSS aad
BfoeneT81h 10, 275-300.
Schlamadinger B, Marland G (1996b) Full fuel cycle carl>on
balances of bloeneIllY and fmestry options. FlleI alld EJmg!J
Abstracls,37,197-197.
SearclUnger T (2010) Biofu.1s and Iha ncod for addltionel carbon.
EllviranmentaI Researclll.eIlers, 5, 024007, dot 10.1088/1748-
'1326/5/2/024007.
SearclUngcr TO, Hamborg SP. MelIllo ) cI a1. (2009) FIxlng a
aiticnl climate accounting error. ScIence, 326, 527-528.
Searcy E, Flynn PC (2008) Processlng 01 straw/rom stover:
comparlllon of Ilfecycle emissions. Inlernalional JOlin/a! ofC"",
Energy, 51 423-437.
Shine K, Fuglcslvadt J, HaUemorlam K, Stuber N (2llO5) Alter-
I1lltivas to Ull! global warmlng potential for cnmparing climate
impacts of emissions of greenhoose goses. Clhnntic Otnllgl>, 68,
281-302.
~
Siegenthaler U,)oos F (1992) Use of a simple model foratudying
oceanIc tracer distributions and the global carbon cycle. refIllS,
448, 186--207.
S1egentheler U, Ocsdlger H (1978) Predlclingfutnre atmospheric
carl>on dioxide levels. ScIeme, 199, 38f1..395.
5mossmann KM, )oos F. Fiscber. G (2008) Simulating effects 01
land use changes on carbon fluxes: past amtrlbutions to
atmospheric COz: increases and future commitments due to
Jossas of terrestrial sink capadly. Tei/lls B, 60, _.
Swallow SK, Parks Pl, Wear DN (1990) PoUcy-relevant nonron-
vcxlnas in the producticn of multiple forest benefits. jallma! of
Environmental f.ammnics ol1d Mmmgemcnt~ 19,264-280.
'fubleIlo FN, Opjlenheihner M (1995) impnJse.relponse functions
and anlhropogcnlc co,. G<ophys/a1/ Research !.eIters, 22,
413-416.
UNFCCC (2003) Esthnnting, reporting, aod accounting of llnrvested
wood products. Tedmlcal paper FCCC/TP2llIl3/7.
van der VO<! E, Lifset Rj, Luo L (2010) Ufe-<y<:le assessment of
blofuels, convergence and divergence. Biofuels, 1, 435-449.
Wannlnkhol R (1992) Relatlnnship between wind speed and gas
exchange over the ocean. j=/ of Genp1z!Jslco/ ResearclJ -
Oceans, ~, 7373-7382
Werner 1\ Altl,.,us H-j. Kfumlger 1; Rimier K (2003) Ufe Cycle
Inventorica of Wood as Fnel and Construction Material. FInal
report eco1nvent 2000 No.9, EMPA DObendorf, Swiss Centre
for Llfu Cycle Inventorlcs, Oilbendorf, 01.
;jj 21111 Blackwell Pnbllshing Ud, GCB BI_ dot 10.1111/j.I757-1707 .2Ul1.01102.x
.~.
Climate Action Plan - Public Comment
(d
;...
I
I.
..
Date Name Format
1 10/17/11 Chris Marrs Letter
2 10/17/11 Brian Goldstein E-mail
3 10/17/11 PhIIID Morlev E-mail
4 10/18/11 Richard Dandridge E-mail
5 10/18/11 Fran Post E-mail
6 10118111 Crlscln Hollinshead E-mail
7 --:- 10/19/11 Joanna Loehr E-mail
8 10/19/11 Crala Durean E-mail
9 10/19/11 Jim Bower E~mail
10 10/19/11 Ron Graaorv E-mail
11 10/19111 Gretchen Brewer E-mail
12
13
L
,.
I.
I.
I
,"
r
I.
..
,
\\citynlIlll \group\eity admin\Clerk\Council Packets\201 1\1 10711 IClimate Action Plan - Public Comment
Ustdoc
To whom it may concern,
~
I
I
I
October 17,2011
rro writing in regards to the Jefferson County climate plan:final draft, specifically C02
emissions being considered. In regards to the Port Townsend Paper Company emissions being
considered carbon neutral also it appears the plan gives no consideration to the 25 MW
cogeneration addition. This is Big. Tho mill bas a large foot print. It seems it's all how you
wish to interpret the methods used to calculate their CO2. The mill bas been and still is the
sacredcow. We all needjobs, but P.T.P.C. could do much more to reduce their emissions. WIth
a little bit of guts on your part.
l"ve spoken to Freddy Ley at the Dt.pw.twent of Ecology about Port Townsend. He told me
"Port Townsend is a bea.uIiful place, but he would notJive here." That when contacted by
someone interested in living here he would advise them not to, due to the P.T.P .C_ This speaks
volumes:
Plesse don't rubber stamp this. Stop treating the mill like a special.inte.rellt. There ~ more
people in this County'then those at the mill The mills emissions are effecting our heaI1h and our
prc.,!JCIly. 'Please do the right thing forthe people whom you work for. '
Sincerely, ~~
Chris Marrs
157 Haada Lass Rd.
Port Townsend. Wa98368
"
.
"
.
;.
Joanna Sanders
From: Brian Goldstein [bgoldstein@co.jefferson.wa.us]
Sent: Monday, OCtober 17, 2011' 4:44 PM
To: CltyCouncn; Jeffbooc,
Subject: en mate ActIon Plan Support
Jefferson County Commissioners
Port Townsend City Counell
1~'.
I want to show my support for the CUmate Action Plan prepared by the Climate Action Committee. As
'the Resource Conservation Manager of Jefferson County, I am well aware of the challenges facing our
County, and our nation, with respect to the unsustainable use of natural resources. By taking a
leadership role In resource conservation, we can help lead the paradigm change needed to curb
consumption and begin to slow global impact. This change wlll not happen organically; it requires a
conscious, planned approach to behavioral change by all citizens.
I reallze this Is a time of austerity for the Clty and County, with declining revenues. And that enacting the
ClImate Action Plan requires resources. I'm convinced that a small Investment in the right level of
leadership can yIeld large dlvidends,.slnce there are many of us that are passionate about sustainable
living and can lend a hand. Please know that I consider allocating City and County resources In
supporting the ClImate Action Plan a top priority.
.'
Thank you,
Brian Goldstein
4156 Wilson St
Port Townsend
"
"
10/1712011
COPIED TO COUNCIL
101'7/11 l'
Joanna Sanders
From: Pam Kolsey
Sent: Monday,Oclober17,20115:16PM
To: Catharine Robinson; David KIng; George RandeIs; KrIs Nelson; laurie Medllcotl; Mark Welch; Michelle Sandoval
Cc: David TImmons; John Walts.
Subject: FW: Comment on Public Hearing draft Climate Acllon Plan
Pam Kolsey, MMC
City Clerk
City of POTt Townsend
250 Madison street #2
Port Townsend WA 98368
360-379-5045
pkolacy@c/tyofptus
From: Philip Morley [mallto:pmorley@co.jefferson.wa.us]
sent: Monday, October 17, 2011 5:09 PM
To: kkolff@olympus.net; Judy SUrberi Zoe Ann lamPi Pam Ko!acy
Cc: Commissioners; AI Scalf; 5tacle HoskIns .
SUbject: Comment on Public Hearing draft Clrnare Actlon Plan
Dear Kees, Judy, Zoe Ann, and Pam;,
The County Commissioners very much appreciated Kees Kolff's presentation today about the Climate
ActIon Plan, which Is the subject of separate Public Hearings before the Commissioners and CItyCoundl
today.
At the Joint Meetlng of the CIty Coundl and County CommIssioners on July 21, 2011, Commissioner
Sullivan distrIbuted and dISCussed substitute language for paragraph 2 of Chapter VI. B. Urban Form and
Transportation, which was favorably discussed by the Joint meeting attendees without dissent, In the
same manner as other changes agr~ to that day. Howevertoday's hearing draft does not accurately
reflect Commlssloner Sullivan's language as It was considered by the combIned bodies.
In discussIon of thIs discrepancy this afternoon, the CommIssioners feel the language considered at the
Joint Meeting must be carried forward, but that there Is also value in the sept. 22 hearing draft. The July
21l8nguage, which was considered by the Jo1nt Coundl/Commissioners, lIsts the areas already identified
as suItable for more Intensive development, while the later draft keeps the door open for potential
future additions.
To honor our joint process and the results of the July 21 Joint Meeting, and also take advantage of the
subsequent draft, compromise language that combines both versions Is shown below, and is submitted
for Inclusion In the City Coundl's public hearing record for consideration:
In general, concentratlng development within established community and economic centers will
produce fewer harmful effects than development outside these centers. For this reason, the
County, In coordInation with the eQty should emphasize the need for future development to
occur within urban growth a'reas (UGA's, and to a scale appropriate to preserve their rural
character, the community and economic centers of Glen Cove, the Jefferson County
International Airport, Port Ludlow, Qullcene, end-8rinnon. and other areas suitable for more
IntensIve development as Identified In each jurisdictIon's Comprehensive Plan.
[underline/strIkeouts above show changes proposed to the July 21 language discussed at the JoInt
10/1812011
!.
~
I
I'
I
I.
};
,
>.
r
\.
i.
I
i
I'
I..
,
I
I
I.
I
I'
I
r
.
I.
;.
-
Council/Commissioner meeting]
Thank you for considering this compromIse language.
Phmp
Phlllp Morlev
Jefferson County Administrator
pmorley@co.Jefferson.wa.us
(360) 385-9100 x-:l83
This is a reminder that a/l ernail to or from this ernoil address may be subject to the Public Records Act contained
in RCW 42.56. Additionally, 0/1 emoil to and from the county is captured and archived by Information Services.
.:
10/1812011
Joanna Sanders
From:
Sent:
To:
Subject:
RIchard Dandridge [dandr@u.washlngton.edu]
Tuesday, October 18, 2011 2:37 PM
CllyCouncll
SuppOrt the CUmale Action Commlllee!
Good Afternoon Council members,
~
j
,.
~ .
I
J.
I
j.
Last week I helped celebrate my grand daughters 6th birthday. I'm extremely worried about
what her world will look like when she is my age, some 50 some years from now. We won't
have to live in that world but we should be doing everything in our capacity now to help
mitigate the climate changes she will be forced to live with because of the way that
generations before her lived. .
Sincerely
Richard Dandridge
Citizen at Large member Climate Action Committee
(
I.
i
,
i
The Point of Power is Always in .the Present Moment
"we'd better work in the currencies we can muster: bodies, spirit, passion" McKibbon
,
1
,
,
.
Joanna Sanders
From; Fran Post [franposl254@gmE!D.com)
Sent: Tuesday, October 18, 2011' 3;51 PM
To; CllyCouncU ,
J' "
Subject: Tonlghfs council meetln~; ~Iotlal Warming
Dear City Councilors,
I cannot attend tonight but undeI'$lld you will be considering actions to reduce our city's C02
emissions by 80% below 1990 1~1sby the year 2050. '
!'
..... .
It is l>1>pat ent to me that our world 'is in great distress on many froirts, all caused by human
activity, including excessive carbon emissions. Most scientists are convinced that this is leading
to global warming. I have ~ reading. hearing and learning about this issue for decades now
and I am convinced as well.
What can a tiny tOW!11ik:e Port Townsend do about this? Well we have all seen how the actions
of a few, over time, can lead to cliange. Though quoted so often is has become, trite still
Margaret Meade said it best: "Never doubt that a small group of thoughtjU~ oommitted people
can change the world. Indeed, it is the only thing that ever has. n
Time is running out and so I urge you to adopt the plan formulated by the Climate Action
Committee. Thank you, Fran Post
10/1812011
Joanna Sanders
I-
t
r
I
From:
Sent:
To:
Subject:
Crispin B. Hollinshead [cbhoUfnshead@blgrlverllnes.com]
Tuesday, October 18.20114:37 PM
CltyCouncn
support for proposed Climate Action Plan
Council Members,
I,would like to go on record supporting the proposed Climate Action Plan. I want to
applaud you decision to even begin to address this very difficult issue. It is important
to appreciate that, while the plan is a modest beginning, considering only 1% of the
town's C02 emissions, it is important to make a start. - DLeading by exampleD is a
wonderful mission. This leadership will not only be for the local residents, but for
other communities that are beginning to address this problem. We can become a model. I
urge you to adopt this-plan, and authorize the extension of the committee.
Sincerely,
Crispin B. Hollinshead
2708 Gise St.
Port Townsend, WA 98368
360-379-5424
1
.
Joanna Sanders
~.
j.
.
From: Joanna Loehr [joannal@olympus.net]
Sent Wednesday, October 19, 2011 4:54 PM
To: CltyCouncil
Subject: Climate AcIlon Plan
j
i'
i"
~
t'
[..
I
r
i
'.
i;
t:
i'
To the Port Townsend City Council:
This letter Is in support of the Climate Actio Plan for Port TownsenOlJefferson County,
Washington that was presented for your approval on October 17, 2011.
This plan represents a tremendous step forward. I am grateful to everyone who
expended an effort to bring this plan to fruition, from our elected officials to govemement
employees and the members of the Climate Action Committee who worked so diligently
to make this a reality.
The Climate Action Plan truly represents a series of actions that we can take as a
community to both help lessen the impact of climate change as well as to get us
thinking about what more needs to be done In the future. This is an enormous
undertaking. We feel relief that the process has already begun. However, we know that
the stakes are huge and that we must keep Il1creasing our efforts over time. The future
of our economy and our nation depends on the steps we take now.
So much success depends on our ability to shift our collective mlndsets. The Climate
Action Plan gives us a discrete set of guidelines for how we can do this in a practical
matter and shows us that there are Important things we can do. I hope you will continue
to support these efforts In educating yourselves and your constituents; that you continue
to be "Governments Leading by Example."
Sincerely,
Joanna Loehr
5837 Hill S1.
Port Townsend, WA 98368
360-385-6579
joannal@olvmDus.net
.,
..
1012412011
Joanna Sanders
,
to-
r
From: Pam Kolaey
Sent: Thursday, October 20, 2011 9:23 AM
To: Joanna Sanders
Subject: FW: Climate Action Plan
;
j
L
I
Pam KoIatJy, MMC
City Clerk
City of Port Townsend
250 Madison street #2
Port Townsend WA 98368
360.379-5045
pko/acy@cityofpt.us
"
I'
i
I
I
!
From: jeffbocc [maIJto:jeffbocc@co.jefferson.wa.us]
Sent: Thursday, October 20, 20119:17 AM
To: ZOO Ann Lamp; Judy SUrber; Pam Kolacy
SUbject: FW: Ormate ActIon Plan
..
FYI...
Julie Shannon
Executive Secretary
Jefferson County Commissioner's Office
360 385 9100
ishannonliilco,ieffers()IL wa.us
From: craIg Durgan [mallto:durgan@olympus.net]
Sent: Wednesday, October 19, 2011 5:38 PM
To:Jeffbocc
SUbject: Olmate Actfon Plan
Dear Commissioners,
ThIs Is my wrltten comment regardlng the Climate Acllon Plan.
I am opposed to the adoption of this plan.
Regards,
Craig Durgan
10/2412011
.
Joanna Sanders
,
,
'".
From: Pam Kalaey
Sent Wednesday, October 19.2011 4:37 PM
To: Joanna Sanders
Subject: FW: Climate Action Plan '.
;'
Pam Kolacy, MMC
City Clerk
City of Port Townsend
250 Madison Street #2
Port Townsend WA 98368
36(J.379-5045
pkolacy@cityofptus
L
i.
L
i.
,
~, .
i:
,.
i
i
.....
f
i"
From: jeffbocc [mall1D:jeffboa:@co.jefferson.wa.us]
Sent: Wednesday, October 19, 20114:34 PM
To: Zoa Ann LamP; Judy SUrber; Pam Kolacy
Subject: fIN: Climate ActIon Plan
FYI...
Julie Shannon
Executive Secretaly
Jefferson County Commissioner's Office
360 385 9]00
ishannonf{D.co.iefferson.wa.us
v
r
From: Jim Boyer [maDto:j2010b@gmaIl.com]
Sent: Wednesday, October 19, 20114:18 PM
To: jeffbocc .
Subject: Climate ActIon Plan
Commissioners Jobnson, Sullivan & Austin,
To the framers of the U.S. Constitution, property was as sacred as life and hoerty. The
inalienable right to own - and control the use of - private property is perhaps the single most
important principle responsible for the growth and prosperity of America. It is a right that is
being systematically eroded by mernal forces that many have not [yet] learned to recognize.
Regardless of how it is spun, the goals of Agenda 21 are clear. The offshoot of that plan created
as ICLEI bas been creeping into every facet of American life even to the point of some cities and
counties paying dues to the UN. body that designs the roles oriented toward broader control over
privately held property and subsequently to eliminate it altogether. Such allegiances may violate
laws against making treaties with foreign powers.
UN. Conference Report excerpts,set forth their official policy on land. The Preamble says:
"Land...cannot be treated as on ordinary asset, controlled by intlividtmls and subjact to the
pressures and inefflciencies of the 11J41'kef. Private land ownership is also a prl:ncipa1
instrument of accumulation and concentration ofwealth, therefore contributes to socio1
injustice. " .
'.
10124/2011
,
,.
~.
The PJ:eamble is followed by nine pages of specific policy recommendations endorsed by the participating nations,
including the United states. Some oftbose recommendations read as follows:
Recommendation A.t
I
I.
.
(b) All countries should establish as a matter of urgency a national policy on human settlements,
embodying the distribution of population...over the national territory.
(c)(v) Such a policy should be devised to facilitate population redistribution to accord with the aV811ability
of resources.
j.'
I'
I
f
Recommendation D.t
,
(a) Public ownership or effective control ofland in the public interest is the single most important means
of...achieving a more equitable distribution of the benefits of development whilst assuring that
environmental impacts are considered.
(b) Land is a scarce resource whose management should be subject to public surveillance or control in the.
interest of the nation.
Cd) Governments must maintain full jurisdiction and exercise complete sovereignty over such land with a
view to freely planning development of human settlements....
Recommendation D.2
(a) Agricu1tura1land, particularly on the periphery of urban areas, is an important national resource;
without public control1and is prey to speculation and urban encroachment.
(b) Change in the use of land...should be subject to public control and regulation.
(c) Such control may be exercised through:
(i) Zoning and land-use planning as a basic instrument of land policy in general and of control of
land-use changes in particular;
(Ii) Direct intervention, e.g. the creation ofland reserves and land banks, purchase, compensated
CAplOpriation and/or pre-emption, acquisition of development rights, conditioned leasing of public
and communa1land, formation of public and mixed development enterprises;
(Iii) Legal controls, e.g. compulsory registration, changes in administrative boundaries,
development building and local permits, assembly and replotting.
Recommendation D.3
(a) Excessive profits resulting from the increase in land value due to development and change in use are
one of the principal canses of the concentration of wealth in private hands. Taxation should not be seen
only as a source of revenue for the community but also as a powerful tool to encourage development of
desirable locations, to exercise a controlling effect on the land market and to redistribute to the public at
large the benefits of the unearned increase in land values.
10/24/2011
,
.
(b) The unearned increment resulting from the rise in land values resulting from change in use ofIand,
from public investment or decision or due to the general growth of the community must be subject to
appropriate recapture by public bodies.
Recommendation D.4
(a) Public ownership ofIand cannot be an end in itself; it is justified in so far as it is exercised in favour of the
common good rather than to protect the interests of the already privileged.
Recommendation D.5
(b) Past patterns of ownership rights should be transformed to match the changing needs of society and be
collectively beneficial .
(c)(v) Methods for the separation ofland ownership rights from development rights, the latter to be
entrusted to a public authority.
In order to push the action items of Agenda 21 through local ICLEl efforts the advocates of this movement toward
social justice decided upon and recommended the use of passive sounding terms that have become common place
in local governmental discussions. Among them are:
Precautionary principle
Sustainabillty
Buffers
Smart Growth
Public - Private partnership
Visioning
Stakeholders
Affordable housing .
Anti-sprawl
Consensus
L
i
i
1
The driver, the agreed to theme with which to expand participation in the U.N. program was "Global Warming."
Opposition to the unproven and widely challenged hypothesis of anthropogenic global warming over the years has
led to it's theme moniker being changed to the more ambiguous and benign term "Climate Change": While the
name is harder to dispute, the ideas behind the U.N. program have not changed.
As the public has become aware of the troth behind the regulatory and often unconstitutional process taking place
around them actions are being taken against this unscrnpulous plan and it's undermining of the US Constitution.
Last summer citizen pressure caused the City of Spokane to drop it's ICLEI ties and more recently, our neighbors
in the City ofSequim and ClalIam County have done the same.
For Jefferson County to publish it's coonection with ICLEI on it's official web page and is a clear indication that
this course of action is founded on an unproven theory and that implementing new regulations binding our citizens
to contracts signed in conflict with laws gojding treaties and American Constitutional rights. The fact that this plan
has been developed in collaboration with the City of Port Townsend which may be violating constitutional law by
creating a treaty in paying dues to the international organization is another reason to reject this proposal.
Add to all of this, the fact that the county is suffering deep economic problems and it should be recognized that this
ill founded effort is not putting the interests of our citizens in their proper place. SuborrlinAnng the county you
were elected to protect to the devices of an organization that is set on implementing an interoational process for
10/2412011
controlling people and property flies in the face of all we believe in.
This Climate Action PIan should not be given your approval.
t
,
i-
Tun Boyer ,
Port Ludlow
,
,-
i:
j.:
r
I
I-
I
I
,-
I:
I-
I-
I
I
I-
10/24/2011
.
:"(
Joanna Sanders
From: Pam Kolacy ,
Sent: Wednesday, October 19, 20111:24 PM
To: Joanna Sanders
Subject: FW: CUmate Change
,
r
I
r
\
i;
Pam Ko/acy, MMC
CIty Cleric
City of Port Townsend
250 Madison Street #2
Port Townsend WA 98368
36a-379-5045
pkofacy@cityofptus
"
I,
From: ~ [maRto:jeffbocc@co.jeffeJ'SQn.wa.us]
Sent: Wednesday, October 19, 20111:25 PM
To: Zoe Ann Lamp
Cc:; Pam KoIacy; Judy SUrIlilr
SUbject: /W: aJmate Change
FYI ... Please see emaII below.
.TuIie Shmmnn
Executive Secretary .
Jofi'erson County CnmmI..nnQCl's Office
360 385 91QO
j~hslnnt\T1f1m...n.iefferson.wa.us
From: Ron Gregory [maDto:buJlder@cablespeed.com]
Sent: Wednesday, October 19, 201112:49 PM
To: jeffboc(.
SUbject: Ofmate Change
--
'.
The Jefferson County Republican Party does not support the adoption of the
proposed UClimate Action PlanA, The Letter from Michelle Sandoval and
Commissioner Austin is a flawed perspective ignoring the real problems in
Jefferson County. The problems that neither the city or the county have
addressed are jobs and budgets in their area of responsibility. If the mayor
and commissioner Austin wish to participate in the foolishness that is Aclimate
change" that is their optio!\. They have no right to ram an unnecessary, costly
pOlicy and regulations to force residents to accept a flawed program promoted
by their political alliances!
1012412011
'.
-.
The Executive Summary in the so called .Climate Action Plan" is the wish list
of the no growth county contingent of who I identify as "earth muffins.. The
estimates in the Summary are neither acculturate or truthful. The "Summary"
is a template of the Kees Koff vision that reasonable people soundly rejected
when this so called vision statement first came to light. The Koff treatise was
rejected at the front door, so now it has entered through the back door of the
county court houSe with the Democrat Commissioners giving their stamp of
approval to the ICLEI agenda.
i
I
I-
i'
1--
Climate action is a component of the United Nations, Agenda 21. ICLEI is an
international organization created by the United Nations to gather local
governments around the world to commit to sustainable development. ClaUam
County had signed on and paid its annual dues of $1,200.00. Today, the city and
Sequim and Clallam county bowed out of ICLEI. One must ask why is Jefferson
CoiJnty willing to commit to the United Nations Agenda 21 when our neighbors
now say no? Our county commissioners have spent their time and taxpayer
money promoting regulations which kill growth and opportunity for Jefferson
County. ENOUGH IS ENOUGH III
Ron Gregory
Port Ludlow
- - -
~~.#Uj,.~lrtI~ff!l:~?malI~:~lfta'8~jtIB~I__.--
~ ..'
- -
--
-- -
".. :....... ,
,-
10/2412011
I
,-
~
.
Joanna Sanders
i.
From: G Brewer PTAW [ptawdlrector@mallhaven.com]
Sent: Thursday, October 20. 2011 10:24 AM
To: Joanna Sanders
Cc: jeffbocc@co.jefferson.wa.us; CltyCouncll
Subject; Re: Comments on Draft Climate Action Plan
Attachments: Main Sheet PTPC 2009 Reported Emlssrons- TRI and ORCM.xfs; ATTOOOO1.hlm
Hello Joanna-
Thank you for alerting me. The umeadable graphic was unimportant, a logo. The other, the
Report of Toxic ReleaseS for 2009 is PTPC's reported emissions for that year.
The comments can stand alone. The Report of Toxic Releases. 2009, is a supplement, intended
to provide a lefe1enCe for comparison to other pollution sources evaluated in the report. The
information in the chart may be a bit daunting (I tried to lay it out for clarity), so in any regard,
I'll be glad to go over it or answer questions about it with any member of the boards or staff.
If it's Unreadable, let me know. .
For completeness, my comment letter is pasted below, and the 2009 Report of Toxic Releases
for PTPC in .xIs format is attached.
l-
i
1
t
;
i.
I
[
I.
i
I
I,
I
j.
,
I
I
,
I
I
Thanks again for alerting me, and please let me know if it needs to be in another format.
GrelIlhen Brewer. DIrector
PT A1rWalllhem
PO Box 1653. PortTownoondWA98368
360-379-1239
-NOTE NEWEMAlL ADDRESS - CLARIFIES THAT YOU'RE SENDING TO AN INDIVIDUAL -
olawdlreclor@mallhll1l8n.com' ptalrwalchers.org
On Oct 20, 2011, at 9:30 AM, Joanna Sanders wrote:
We received your emall. Unfortunately, only two documents could be opened. One was an
unreadable graphic and the other a Report of T oxle Releases for 2009.
As you know the comment period ended yesterday. Since we can't eccess what you sent; If
you would like to submit wrlttan commant, we will accept it in City Administration Clerk's
office (2nd floor) unt115pm today.
Joanna Sanders, CMC
Deputy City Clerk
(360) 379-5083
10/2412011
'j-;
, .......
.......;
'..., '
, ,
"
, "
. :.w "." .' :..~
, ,
, ,
, , '
:..., ' '
."1
."'.
:
.', i
..~ . M ." :.'
....f~
: ..., "
:'.
:
, '!
.
. . ~ ... 1..,
, "
.... ....i\
, ...,
.'. ~
" i
:...! ,"
.'j'
~ .'
';
, ,
.. '..i
, ,;
..~ . ~ ... ~"
. ":;:
: ...,
....
t "I
.... ~ w .
'j;
, '
:..J. ..
;.'
.~::
" '
",.
.
..~ . ~ .'. ;...
"
.....:
-....:....._-~~--.... ..',
.... ".
,
[TiT-'-';I[ T~I'; Ililll' !~~
! l j~1 ! I~ I L11H! I! I! i ;1 II
I ;! 1,0' ,,' '-H I I
1 i If- III Ii -I: .-f 11('11 : i '. Ii;
I 1,1 l~ ' I ,I '
I ",I, ~ III I! I ' I I
1 'I I !I~l-!J : I ,!-JJ1.1l! I I
z ~I'~ ~ I I ! II I ,
~-Hi i 1"1-.0 I I I ,~I s;!'fjltil !!lg",I::l:~~5
o ! i ' ~ ~ -g I' !~i i~ ~$~g ~
~ ~ I, III i ill I I II~i I II I
ffi ffi I ~; ~L ~ ! Ig" : I 1111 ~ i!
D.. (/)z f.." I w' g -)1 I- ; i......j...,. I I- I ~
1 I J~~S 000 oOij~cc
c: s: I ,8 i i ;;!! I lill "l. ill;;! I(;;r::s-
o II II~" e .l! i'5 ! I ~ 11l i'5 ....
01- f f;iJ!!;; C S "I s '"
laJ:~ f-t11 r~ji'l il I ~~i2 ~'IR.til~~"'~R.o~
. CI) 10. ! !~ 11~ I I I l~ ~ ~ ; ~ ~ "
~l~ I ! I 't~!1 ~ _I I j 11m :_~ ~ N
1-1::1 Hl1 ~ hili I~!~ ~!~ ~ ~ ~ Ii! '" !Hl !: 0; .., ~
~ ~ 11111111 ~I l~l' I!I~ ! ~ ~ ! ~ 12 ~ ~ $ *
o 8 "lll':g ~Il 1 Ia: III t:<!(l a: !;,
'~I~rl-l i~!;l' I i,~H II rl.N8'~1 ,-- i '", I' II.' -f-
ffi 111111'1~i 'Ii t ~ 1 <
CI)" '15 ~ i I I~ 1 :> I' 81 I
m I I J ! t II ,II 8 ~: ~ il '
0:: I ~ ~ I 'II~' "ii ~ ~ e
I c..> I ~ 'l; fa I It li:n ,~ I 8 ; ~
x 0) 8i i ~ I !:; W lHen ~ ~ ~
~~ ~ ~SQ~
00:: N i ~ m~ 16 ~~Il! ll!~~ ~~~~8
~ @If ~t ~ ~i~, ,) ~II ~J~~~~~!~i~~
210:: i J..i",5~ 2 ~'l;~! I ffi"'''' ~ ~~~~~e!?::;~~
U,!HO e i5 1;1 .'Il < ... <( ~ ~ :1l ~ i5 lei:;: ~ i :; ~
0:: 1 u.. ~ ~lo i~ f2 ~ tJi8 It' s g g ili :5 i
i
~~.'Ele:.~ Q[a ~~=
Si~ ~l.~&:;~ g.'El g
g~.a. a!'a~O~(D
p..q ~ '" S' tx1~ S' a. ~i" S'
~ ~ l'i ~. ~ < e ~ ~ o' a.
p.j;l-oi:l:I=fB "'l:l~~
~a8 ~'l$ g'g ~aa ~
<-+g i iif~~g-O'sS~'
~~<~I>"I>"U}S80g.
o ~ lf9,. s. e:.
e. . t::t.QQ & 0 B ;;Ii l:l g -
~ ~.1J B.g [g a [~ B
~ ~ ;;Ii ~ ~ ~ ~ ~ m ~~.
B ~ 8'< g. a p. 9 ~. ~s.
. a '< S' 1;l S' ~ e: S' ~ (D
;;l~ a.a cTOQ:::::~ l:l =g.
(D o' p.. p. g. f*.$! ~ J" ;;l S"
t:tlJ"::r:S'OQ.go5lS'(D I
nS'(D a.sc.og,(D S S'
Qa'a. 0&lo'785l~
'" p. iifcT......(D
~ e: <e:.~:~l
O! '" (D "'P-
.... ~
tll........
o~!2
na.....
nS-.J
~
a.
~i~~
B ~",OQ
g.(D<tg
~~ ~8
~ OQ l:l
""'(DO
~ ~.a
<co~
(D ~ -
.. !iJ fl
......(DJ>;'
n p. 0
~cT""
......'< 't:l
~ II>" i
a ~
s.. <-+
'" ~ 0 tll~'~'~a o-l
oel B.....o l:l1>"0-P-
. ~ ~ ~l ~ a ~ ~ ~. s'
o' ~~ 0"'=.2.<
o ~. 0 '" 1::. '< !
!:lg.Pp..p.~~s
g:~~>~ooB
(D (JQ P- s;<cT cT ::\. ....
6:1;lgoe:.e,[g
,<g(De,~(D(D~
~ lor ~
~ a ~~ 8. i i ~
~il 0 ~ ~!' ~
B~ ~~.(D~(D
~ S'U}::::o@Ja
'g f ~ 9. if e.. '< 0
a- oB~~9.~
..... S' .... g p ~ c.,<
~(Da p.~g~
S'~ ~ ~~ft~g
~i"!l.P~~O(DS'
~ co S'~i!il ~'"
~"'a.!B.~p.s:R
~~(D~~g..a
< ~a.'<
~ rtlQ
'"
....
@
~.
"
]~g-B';:g
"Oon8.td
l~.g ~~
cT(JQ q l:l n
i[[~IO
~. n (D
~i"!l. ~.'t:l
ng,qg.
i.S'~:::::"
(D 0 co
. 8 ~ i
~~ ~8'
aB5lg
~n;t ,g '<
o CD ~. a
ai~ l:l ~.
S'~ <
8",8a
oa~a.
~a.BS'
lOS'i;t(D
t::t. (D "" 0
gl>"o~
~cTcT
~S'~ ~
~~-.J
9. @J <' I>"
q P.a~
[S' a s'
8 S' $~
c:(DcocT
l:l,g-(D
q ::l.~ S'
::l:(D",
'" B 0 (D
~8ig-
j ~.[
g.oo
Bl:l....
g ~Q
'""' ~.ij
~g'<
g.g.Q
a~ ~
"-'0...._
e:.al:l
00.....
l:l cT 0
(JQ~~
~. :0
S'- '"
S'l:58.
(D....n
l-t .........
9J . q
'8 n
~ g
(D F
f
" 1. .. · gJl oS~
m
.J~ ~ i ~ -~ ] ~ .,.~ ~
. 0\ ",.0 ~ oS 13 0 ~
....;...~!a~]~ 'l31~
.... .~ 0
o cJ N<QoS"'''' ~ ~ ~ .~
.,00 '"
i~ .s~~1;j!3l!5 Jl[(l~ .~
co!N I ~ 0 ~ cJ ~ . >LI
,g < ~. .~... 1-< 8 .su~ CJ
., en < .~ S
oS.~ ::.' ts !3';;J ~!3 i'i ~ ot.) ~
.s ~~ 1~~~ ~.~tj:l ~ .s .~ B tt'l
0
-= ~ S' S gj 0 ., g'a ~ if8!S 0
0"'..... . 1'1'", 8 oS .= N
..Q >>..... 13 0 ., tIl ..Q ';;J ....
=.....1 1;j '6"'00 N'l~ 1;j 0
-a-~ . .?; ~ p.l3= Ii !il !J ~ ~ ... oS
o '0 "" .~ 0
o ., ij S6'~~8~ir~ ij .s .S ij
[(l [;:! ... .:a ., u ~ .~ ~u !il.'lil
~ 13 0 .~ 13 p. e? ~ .S ~ ~"a;1 .S
o1;jtIl 'Oil....'" as 0 ij"a j co 0 [(l
"fa il ,.Q!3"CJ~ f:l .13'.g <Q ]
!3lloo ..9 [:a...Z [. '" !3 < .~ ~
CJ OOij .s~ .,
~11!f ~..9]:o13~., .g jJtgj [(l
..Q
~~~ ...l ~'a fj'a ~.~ 13!3 j" ~ [(l ~
~",~lt~o",u ~ "'~
1
.,
!il
13
.,
1;1
s
.~
<S
~ ~
~ t
..El ..El
1;j 1;j 1;j
s s S
t-- ~ut--lout--IO]t--
,.....".aU......- u_. ~_
O~OO 0000
-.z::sj:Q......;..l~,..... u......
I
..El
oj
8
~
~
N
.J
00
1
.g
o
]
s
l3=
~
00
<"l
..t
g
13
]
Ii
iil
.,
7J
tIl
.,
.~
m
'"
S'1~8ej"f!t:i:
~ ~.aa!f~
.P i!l. ~a ..... '" ....
",0 o~..,
l!ll:l!il ..:;J /!l ~
c:>. c q' cT c
..... ~ ~ ::::~......
'" 0.0..,00
o cT - ....,.., ....
oo.....C$.(,..,;;OPO'Q
CO I'f. C afJl 0
~ Ii! g' ~ 0. ~ ~
~. gj Ii 13 a 5 PI"
5.~0Cl1:l~g.l!l
t:l c ~ (1 ~.0Cl c:>.
"'t:l~O""'fJll:l
~ ~ t:i:J ~ '0 ~
c l:t. ~ t:l!1 8.
zgcS'!;;o$l.
os>~~a""'g.
8 g. (1 Ej. ~ go c
I:lqf5'~1fcTgo
s; S. ~ <> ~ ~ ~
~ ~ S. g. c s: 0
8.. c o..g c UI
I:l c .....
~8..8..
~1~~[!;~II!r.frl
8.S' (10 ~'O c a 0 COCl'o '"
!l !il 0.:;J -<" a ~ a ~ ~ a.,g ~ go
~ a.~ g>g. ~ c ~ ~ C1 ~ G!'tl ei"
c C1~ ~ l!l-<" ~ g. !;J c:>. P. g' ~ a
go€;a [cT;.~C [l!l ~g-S'
"dg.. !it1't5 ~.",,~8..c:>.c 1:l.:;J
::d ~ g; ~ ~ !.,; Pi ~ S' ~ ~ i So
(18..O~ l:l al~.fJl g.~ ;:f!~
C1'o . lO B 0 <> 0 cT c::
.9 ~ ~ a- g.. ~ .' go-a o. ~ g ~
i g g 2: ~ f~ ~ Si ~ ~ [a a-.
g a. G s.. fJl g ~ o. ~ ~.-<" ~ a.
cT ~ ./>. '0 ...., '" '" ~ e..!:i .,. fJl ~
<<o':eg"O€5-- C:::8~'t:la:!:T
./>.OS'~.fijl:ll:laz cr1!",s.
~ ~ $l. a. ~ go a.~ 1f g S. ~ ~
\OER~C '" ~1:l0Cl'"
~~S'gg.~g,g ca~!tcT~
0.0Cl c:>. 0 t:l "..... N [ C
'^ .."'0",,,'" 0 .
~ "'.......... t:l" 0
" g. 8.. c:>. UI . 0Cl
~
.,
-\0
a~
~~
......
......
. bl ct
5 g.
0.0
-I:l
<<
~
ai
[g.
10Cl
~~
~o
c::J...
'0 ~.
II
. .
~ go~ ~ ~
I ~'i~ ~
$IlS'.....~8..
~ S. ~ ~.
>< " g..0Cl
~gG~
o. '" ~ c
;i~1
I ~ ~.~
,,~t7~
"'d o. c -<
a I:l '" ~
<Ill cT 0 i!l.
$i g,~g
maills,
~"'''~
~.g ~ "
tl>~d(1
;g.cT>
><_<>(1
....... "d
f
..
s~
us
.s~
~.S
tlj .,
S'"d
.~.~
.,~
-E .g
! !
.s 0; <Ii
'"d.,l'l
P 8 0
o o.s ~
il:..... .~
;;:: ~ ~
. ~ 0
] M.~
., '"
-E .~
5 ~ 5
l'lON
l'l.~ 0
o '"
1.~~
't: ~ 8 'Iii .,
.B j p t c:>.-E t..8
...... ,J:J -""'.....'"d
.,...... ~o;o.~.s
.....u g t~'gl::dl >-
~oS.g ~ a 15" 8-0 <Ii
~ .s ~o '"d }.! .s ~ .E!
5bb.O!3~g.,~o~ca
.1iJ.a 0 g il: t.S E <;! .,
: ] u 0 '5 o:fl t! o.~-E
~! oS ~ ~b.O.E 18 ~ ] .13
..c: '"d .8. .,., CD !:l 'g
., a:E :;l'l~lI)t
t CD 0 l'l'"d
..c: .... ~ ;:. ,J:J th.1il l'l .~
'g,gull]ll g fJ~ g
.s 5 CD,g t :?l 'g P.. (J ~
....1::l-E5S~'"d~1(ja
~ ~.~ I::l ~.~ ij ~ b.O'g
.~!;j '" 5.... ~-5'g.~ ~
.,.,!f'g OR ~'"d!:i~
-Eil:_ill<;! ~5,J:J~
~i~~l~~~~t
l'l :g o.~ 0 -E R 0 ~
Zo l'l .....~ ~.~..... 1iS.~
O......,J:J ....,J:J 0 ....,J:J
.... l'l :<a
o 0 'Q
"~oS CD..j:l ~ 'Iii
>-ij.... ~ e'<9.a
]ii:~~fra;;:
~go.,8filo
g.:gSoSo1(j8
o!E<<P..8~go!'l
"'..... O.[j ~o
<;!OOtho .......
.l'l'iil::l~!E<ij15
~ .~.8 0 '"d >- il: .or
o ro.::i !:l o,J:J ..... a
..o-U~~L.O
'ill ::a r' l'l CD
~~oS'g~~:o-E
CD.,....gj~ :aCD
::loS 0 l'l ~'g 0,J:J
ill '-" 0 01 '" 0
eu OC;".j:l.s .<;! ~ !3
~~~~~i~.~~
o .... c:>. l'l"M '" . M-"
.....tlj 8., ~M~
~ -E g CD.S $ 'E! 8.s
~g'g-El ~ 0'2 ~
l'l ., 0; 0 ::< 0
~.o rs..o.1iJ Jj u .1iJ
MM:.o:~t(')r;n+J en
~ CD 5 liS~pl ~g::.a
(/.l-ES,J:JN130~13
ag
j.g bil
o (J.El
CD.....t:
'iilgfr
j'"d ....
00",
I ~~
t::.... ....
o 0 .,
l5:bllg.
~"~~
'g,J:Jt::
~ I I
p~<;!
0'] ~
.El....l'l
'iil
~
013
~.~ g
~!30
-.....u
~
-
u
.~
:.i
-0
t:
o
~
.El
(.)
.M
-
.g
~'g
;:.f:j
.M 0
1(j.....
..c:s
~8
I l'l
'g]
c:>......
g..M
.sj
1;i ~
~ l'l
013 0
~.~ !3 ~.~
~ !3 r~ ~ !3
~ +ol'-'-_
~
::r:
~
.M
o
r-:
~
~
8
(/.l
00
\
0($
..... ..... ..... ..... ..... ..... ~
!^ ~ V.l !'J . ..... p
i~ '"<:I C;1 [ J ~ C;1
S; ::I. I
~[ '" ~ '" t
~ ~ f C;1
(1) ::l. f. i ~ ~
~ a. (1)
....
B
~..... l~[~ f~ ~il.~ ('),.....(').........(')
g o go go
-:QC; . -.1 .-.1 ~ S .~a i.~a
..... ..... ..... l@:o @:o @:o @:
..... ..... ..... .....
...... ...... ..... ...... 8.~ ~ ~
. a- a- a-
S' ~1 i [ S' 8'"<:1 ~~ ~~S'
.g 0'1'""" '"<:18 g-~~
~~ .~j B '"<:I
'g ~i i lot. 0 =:I g.:g
~:g..;. .::1- l!.~S'~
::I- g.m m :E !'t.O ::l-
I ,"""NO I.lt .g 011 1
19,~S.~ =:I .
m. ~r lirl>i'"F .gi"6
lot. g~~Ei 0'" . Cll """d ~
1 0.0 s:...~ .
::I-~;:;:g g gg i:!!a Ii ~ '"
~ g.~~B8 ~ go =:I. Q.. ~. S"
=:I <: ......til =:I "'[g;s~g.
'" . ~ i ] (1)(1)0~
8 . ....
!J:i ~ . '" =.~~.. ~O'I
g. c",.8 lot. 8 ~ .... (1)
~. .g 1 ... I
~ 8-0 ~
~ til 1
fR .
rnpt-......a' rn ~ t.d~~'g g,:E rn
(1) g ~ g. ",.8. a R g. ~
~_t-.)$>>
N~~g.. .i a f!l. g 0 'It:
.... ~ 0 ..... t:%"..J:Ii! t::S U')
i1~i ifitil. l!.!'t.ota
~ .0'1 i ~ ~ ~ i ~
8' .... a (1) ~ ",. e1. 8 ~
It 8J i (J)~st .f!i.~~"""'"
~ >'" 00 8-
(') [f;l it til o.
~~.5.~ ta J:t. '" a-!t<
. =:I ~ g. a- fR ~ it 8. .'"
~~~ ~ :g &: g. [ ~. g. S.
'< a ~ il ~ 8' S-i. 8:
~~'"<:I g.
~S; ~ "'~~f~O'Ig.
'" fR .
8."'''' ~~.","'(')~F
a"8.~ e.s.8r~~
,<S-g Q.. ~ Q.. ....,
~~.~ af~~f.f
8Q..
S.1i a- ~ , q ~. i ~.
pt-08. O'I"'~~ '"
'" ::l- e" . fI.l (l) .....
~. S- ~ ~
S- '"
f
...
'5
~ ~
~ J
f f
~ ill
>. :El
.rJ II)
] 1~
I I ~
1:: g 1:: ~ .
l(;:lO ]
~.~ f.rJ 8-
,s 8,s]0'
g
p.
Jl
bl)
.S
i
II) ~13 ....
- l;l~ 0
~ ..i:l~""" S....t1
'1 u.:::lJ";Q ~o8
. II) [{i...:l !:l.!!l S ;El
N ~ ~ ~ ~.~.~ ~
lI)<dgu~E-<SIl).s
~'5 [{ir)'~-g'O ~~
..13 ~ ~ ~ .~"'!t:l c:l -0 '",
.... ...... .., II) .:5' ::s
a .S <'l.. 1il""" t.~ t5
a.13 ~ .M 8 -$ ~j:E 'COr)
.S ~ ! ~ ] ..:...... El.~ II)
13::s< 0 .g.~.g iJl~.s
~ ~.J~ fil ~ ~ ~ ~ E
OCc:lO-.g-o .<a13
soo:g"" bl)S.rJ!il
::5 ~ ] ~ .i 10~:~ ~ ~
] ij o~ 1;1 g< [{i ~ ~ 'ij p.
..s 8 .;.@ 'Q ~ bl)r~ bl)~
C;la..,->II)13'"' 8. Po<
......oij)~~!il_oooc:l
~i ~.s.s~ ~~.s'~
~~~'l:;o~ :;lJ;i.s fil<
....
<2
S
~
g
II)
t;
C;l
I
i
.,... 6 bl)
.... > c:l
~ a.'~
g<!3~
l:l...'. <a
1J";Q.g
ltl'bb
...... u
~ I oij
.a ...... bl)
~ ~ g.
86.s
~~fil
........ ...... ...... ....-(
........ ........ ...... ...... ......
--- --- -.... --- '-
~1~'S~'S~'S~'S
e; e;Fle;Fle;F1e;F1
....-( -5......6j......H).....c5
,;
~
~
11
:>..
o
e
\0
]
]'
~
......
=II:
[{i
~
00
8 1 ij
.... <d
.<2 0 ]
~ I c:l ~~
~g~~.g
2 ~ l>iJ...:l II)
~ 6hO~~
1 II) a I .S
.... 13 ..... .9
l]~~~
::s ~G:: o-a I
UJ._ I 8..........
o&S ~
c:l :>-.6-$-0
ill 1;]:s! ~ !6
is 8 !'! Sh<
-
-
--
~:a
~6
tl ]~ R ~ j
..c:l.3
0
Po< o~] ; 0
bl) l:Q
! "'- 's o@ c:l
01:: 0 U ~
u~.Q .....
\0 r..: 00 '" 0 ......
...... - ...... ...... <'l <'l
"'
(j)
"
Jefferson County/City of Port Townsend
Climate Action Committee
TO:
FROM:
DATE:
RE:
Climate Action Committee
Chair Kees Kol~ Zoe Ann Lamp and Judy Surber
October 17,2011
Government Leading by Example - Reauthorization of the Climate
Action CommitteelRevised Workplan
Background:
Our original Workplan (adopted by BoCC/CC on January 12, 2009) proposed to develop
a Climate Action Plan that included measures to reduce GHG emissions from both the
Govermnent Sector and Community Sector. It was acknowledged that this would be an
ambitious undertaking.
We have successfully completed many of the tasks on our original work plan; however,
we have come to recognize the importance of intensive community outreach to gamer
support for Community Action. This shift recognizes that encouraging voluntary action in
the short-term is more valuable than a detailed set of policies or regulations requiring a
formal adoption process that is likely to meet with significant opposition.
Recommended Action: We propose 1) Approve and implement the measures for
"Govermnent Leading by Example" as soon as possible 2) Adopt Revised Workplan
which includes tasking the CAC with facilitating action and launching a Community
Outreach Campaign.
Given that local government contributes less than 1 % of the emissions - will
implementation of the government seetor measures be worthwhUe?
''Local govermnent action has symbolic value that extends beyond the magnitude of
emissions reduced. Govermnent action demonstrates the savings potential, ease of
implementation, and social value of energy saving measures to the community at-large.
When awareness of the issue is raised via targeted and well-publicized efforts, the
experience gained by the local govermnent can inform and inspire individual action,
leading to substantial community-wide reductions in energy use and greenhouse gas
emissions."
A recent survey conducted by the City of Portland found that 80% of respondents felt
local govermnent leading by example was "very important".
Rev. 10-17-11
-1-
.
Can a public outreach campaign make a difference?
Everyone contributes to the problem of climate pollution in a measurable way every day.
Educating the public on the causes and effects of climate change and the importance of
adopting new habits is essential for citizens to reduce their carbon footprints.
Over 17 years ago Portland began working to combat climate change - and as of2008,
local carbon emissions were 19 percent below 1990 levels on a per person basis despite
rapid population and economic growth.
Since 1990,
. Portland's recycling rate has tripled
. The mnnber of bicyclists crossing bridges has increased five-fold, and
. Bus ridership has doubled.
Revised Work Plan - Overview:
Shifting the focus to Government Leading by Example and Community Outreach:
Phase I:
1) Implement "Government Leading By Example" ConservationlEfficiency
Measures as recommended by the CAC: These actions measures may be implemented
as resources allow.
2) Community Outreach and Engagement - Task the CAC with launching a
community engagement campaign which builds on existing efforts, fosters partnerships
and develops new initiatives. Raise public awareness, engage community members,
promote successes, deliver calls for action, and inspire behavioral change.
Phase ll: Climate Action Plan Transportation & Land Use Policy - In coordination
with Planning Commission - City/County staff shall review CAC recommend revisions,
and make recommend additional amendments, to the Comprehensive Plan and
Development Regulatious. (Note: The GMA mandated Comprehensive Plan update has
been extended to 2016: ESHB 1478).
Phase ill - Climate Change Preparation/Adaptation Plan - Carried over from original
workplan.
Rev. 10-17-11
-2-
...
,
"
Climate Action Work Plan 2011-2014
Bacmound:
In 2009-2010 the Climate Action Committee completed the following tasks:
..J Approve Inventory of 2005 Emissions
..J Set Interim Targets
..J Identified Strategies and Measures to Reduce Emissions from City/County
operations "Government Leading by Example"
Resource Conservation Manager Position Created (June 2010) - The Interloca1
Agreement Between Jefferson County, the City, PTSD, Chimacum School District, and
Fort Worden State Park for RCM Services dated June 14,2010 calls for a full-time
equivalent (FTE) to materially reduce operating costs through resource conservation for a
period of three years. Duties outlined for this position implement several of the measures
to reduce GHG that have been identified by the Climate Action Committee. The RCM is
also tasked with assisting the parties in securing additional grant ftmding and rebate
programs that support relevant energy efficiency projects. The CAC and RCM will
mutnally benefit from close coordination.
Climate Action Work Plan 2011-2014
Phase I
1. Implement "Government Leading By Example" (Exhibit *) - Department
heads and the Resource Conservation Manager shall be responsible for
implementing these actions as resources allow. The potential is bolstered by the
recent Interloca1 Agreement Between Jefferson County, the City, PTSD,
Chimacum School District, and Fort Worden State Park for Resource
Conservation Manager Services dated June 14, 2010 which calls for a full-time
equivalent (FTE) to material reduce operating costs through resource conservation
for a period of three years. Duties outlined for this position implement several of
the measures to reduce GHG that have been identified by the Climate Action
Committee. The RCM is also tasked with assisting the parties in securing
additional grant ftmding and rebate programs that support relevant energy
efficiency projects. The CAC and RCM will mutnally benefit from close
coordination. The RCM shall monitor energy use from stationary sources, water
and solid waste. Fleet managers shall monitor energy nse from transportation (i.e.,
fuel nse in vehicles/vehicle miles traveled).
Rev. 10-17-11
-3-
\
-.
2. Community Outreach and Engagement-
The CAC shall launch a community engagement campaign which builds on
existing efforts, fosters partnerships and develops new initiatives.
Goal: Inspire individual action, leading to substantial community-wide reductions
in energy use and greenhouse gas emissions. - Raise public awareness, engage
community members, promote successes, deliver calls for action, and inspire
behavioral change.
With BoCC and City Council approval, the membership of the CAC shall evolve
to include representatives from the following:
Jefferson County Builders Association - Built Green
Jefferson County Public Health - Green Business
Local 20/20 - JeffersonCAN
RCM
The CAC may make additional membership recommendations to further the
outreach mission. Partnering with other organizations and interest groups will be
imperative for reaching a broader audience. For example, key partners may
include government/non-profit/and grass-roots organizations specializing
ineducation (e.g., K-I2/WSUlPeninsula College!Goodard College); land
conservation, business (e.g., Chamber of CommercelMainStreet); alternative
energy, food security, and water resources (e.g., WRlA, PUD).
Research has identified a set of tools to promote behavior change: obtaining
commitments, using prompts, lrt:ilizing social norms, designing effective
communications, providing incentives, and removing external barriers.
Depending on the audience and available funding, a variety of outreach materials
may be produced (e.g., expanded websites, electronic newsletters, ernai1
messages, brochures, print ads, flyers, and postcards for direct mailings;
newspaper articles; workshops, festivals or fairs, curriculum or lesson plans for
grades K-12).
At a minimum, the CAC shall:
. Partner with local media to publish articles and a regnlar newspaper colwnn with
information about sustainability and maintain a reference list and links on the
website. (B-1.14)
. Engage and inspire other public institutions and private businesses to incorporate
climate protection action into their daily affairs.
Rev. 10-17-11
-4-
"
~'
. Partner with local non-profits/educational institutions to develop and Jf.?vide
classes for clean energy, gardening, agriculture, sustainability skills. 1.15)
ResourceslMode1s:
htto://www.icleiusaorgfaction-centerllearn-from-others/small-communities-
toolkitleducation-and-outreach
htto:l/www.skacitcountv.netlCommonlAsu/Default.aso?d=Sustainabilitv&c=General&o=
helo.htm
10% Challenge started by the Alliance for Climate Action in Burlington, VT, this
program asks participants to commit to reducing greenhouse gas emissions by at least
10%. Keene's program focuses on businesses. htto://www.1 Ot>ercentcha11enge.orgl
PHASE II - Climate Action PIan Transportation & Land Use Policy
(For Inclusion in the 2016 Comprehensive Plan Updates)
In coordination with Planning Commission - City/County staff shall review CAC
recommended amendments and may recommend additional amendments to the
Comprehensive Plan and Development Regulations.
Regulatory amendments requiring amendments to the Comprehensive Plan /Development
Regulations are subject to the approval process codified in Jefferson County Code Title
18; Port Townsend Municipal Code Title 20. The process includes public hearings and
recommendations by the County/City Planning Commissions.
Amendments to be considered may include but are not limited to:
. implementing a city and county energy code for commercial and residential
construction that exceeds current W A state code (e.g. greater insulation, passive
solar, Passive House and small footprints)
. For new buildings, site development and substantial remodels, consider
establishing a minimum compliance target for LEED Silver or similar level for
Built Green (or in another green building standard).
· Encourage increased urban density through code revisions for items such as
setbacks, height restrictions, cluster and mixed - use development.
· Consider further reductions in off-street parking requirements in order to increase
density and further promote transportation choices
. Increase non-motorized transportation infrastructure by completing Non-
Motorized Transportation Plans (NMTP) plans for areas in the county.
Rev. 10-17-11
-5-
-\
Phase ill - Climate Change Preparation! Adaptation Plan
(Year 2012 - Following the 2011 State Plan)
This phase involves an eJ<amination of the probable impacts of future climate changes
(e.g., increased risk of drought, sea level rise, flooding, forest fires, disease, increased
storm damage, and other impacts) and developing strategies to attempt to mimini7.e these
impacts. -
Key resources: Preparing for Climate Change - A Guidebook for Local, Regional, and
State Governments.
Rev. 10-17-11
-6-
,
4.
\/
(!)
STATE OF WASHINGTON
County of Jefferson
City of Port Townsend
Joint Resolution of the
Board of County Commissioners
And the Port Townsend City Council
Adopting the Joint City of Port Townsend
Jefferson County Climate Action Plan &
Approving Revised Climate Change Workplan
}
} County Resolution No.
} City Resolution No.
}
}
}
The Board of County Commissioners (BoCe) of Jefferson County Washington and the
City Council of Port Townsend Washington do hereby jointly resolve as follows:
WHEREAS, a near total consensus of the world's leading climate scientists has
concluded that global climate change is occurring and is caused in large measure by the
emission of carbon dioxide and other greenhouse gases from carbon-based fossil fuel use;
and
WHEREAS, climate change poses a significant threat to our forestry, fisheries, water
supplies, and coastal resources and impacts are likely to include flooding, summer
droughts, loss of shoreline, forest fires, diminished fish and wildlife habitat, increased
storm damage, decreased snow pack, and increased disease vectors and invasive species;
and
WHEREAS, the impacts of climate change will have far reaching effects on public
health, local economies, food production, water supplies, and power production; and
WHEREAS, the Intergovermnental Panel on Climate Change estimates that global
greenhouse gas emissions must decline 50 to 85 percent from 2000 levels by 2050 to
avoid catastrophic climate disruption; and
WHEREAS, many jurisdictions throughout the nation, both large and smaIl, are reducing
global warming pollution through programs that provide economic and quality of life
benefits such as reducing energy bills, preserving green space, implementing better land
use polices, improving air quality, promoting waste-to-energy programs, expanding
transportation and work choices to reduce traffic congestion, and fostering more
economic development and job creation through energy conservation and new
technologies; and
WHEREAS, Jefferson County and the City of Port Townsend have jointly committed to
addressing energy use and climate change, and have made a joint commitment to achieve
City Resolutibn 09-_
County Resolution _
-,
"
a community-wide standard of cutting green house gas emissious to levels 80% lower
than 1990 levels by the year 2050 (County Resolution 44-07 and City Resolution 07-
022); and
WHEREAS, Jefferson County and the City of Port Townsend appointed a citizen Climate
Action Committee in March 2008, charged with developing a Climate Action Plan which
would provide recommendatious for achieving a community standard of cutting
greenhouse gas emissions to levels 80% lower than 1990 levels by 2050 with preliminmy
reduction targets to be set for earlier years; and
WHEREAS, the Climate Action Committee, representing a broad range of interests
including industry, economic development, education, transportation, power, faith,
building, environmental, and other interested members of the public met more than
twenty times to review research conducted by staff, brainstorm ideas, receive input from
the public, and draft the action plan; and
WHEREAS, a series of three public open houses were conducted October 13 - 15, 2008,
in Port Townsend, Brinnon, and Chimacum to inform the public of the adopted goal and
solicit input on potential measures; and
WHEREAS, a Public Discussion Document dated June 9, 2009, was vetted by BOCC
and City Council on June 17, 2009. This document was then presented at a series of open
house events June 29 - July I, 2009 in Port Townsend, Brinnon, and Chimacum which
included informational displays and an audience participation activity.
NOW THEREFORE BE IT RESOLVED AND HEREBY ORDERED THAT:
Section 1. The Board of County Commissioners and the City Council express their deep
appreciation for the time-consuming and detailed work of the Climate Action Committee
and staff in development of the Climate Action Plan.
Section 2. The Board of County Commissioners and City Council adopt the attached
2011 Jefferson County/City of Port Townsend Climate Action Plan (Exhibit A) and
direct their respective staff7resource conservation manager to implement measures for
"Government Leading by Example".
Section 3. The Board of County Commissioners and City Council approve the Revised
Workplan dated September 16, 20ll(Exhibit B, attached) which includes:
. Phase I: Implement "Government Leading By Example" & Community
Outreach and Engagement
. Phase IT: Climate Action Plan Transportation & Land Use Policy
. Phase ill: Climate Change Preparation! Adaptation Plan
City Resolution 09-_
County Resolution _
-('
,
l
.
Section 4: The term of the Climate Action Committee is hereby extended for the
purpose of facilitating action and lannching a Community Outreach Campaign as directed
in the Workplan (Section 3 above).
This resolution shall become effective upon adoption by the Board of County
Commissioners and the City of Port Townsend.
APPROVED AND SIGNED THIS
day of
.2011
SEAL
JEFFERSON COUNTY BOARD OF COMMISSIONERS
John Austin, Chairman
Phil Johnson, Member
David Sullivan, Member
Attest:
Approved as to form:
Raina Randall, Deputy Clerk of the Board
Jefferson County
David W. Alvarez, Chief Civil DPA,
Jefferson County
APPROVED AND SIGNED THIS
day of
.2011
Michelle Sandoval, Mayor
City of Port Townsend
City Resolution 09- _
County Resolution _
-;
"\
Attest:
Appruved as to form:
John P . Watts, City Attorney
Pamela Kolacy, MMC, City Clerk
City Resolution 09- _
County Resolution _