The following is a letter I wrote to the EPA considering new rules for biomass energy generation. Biomass energy plants must have a chain-of-custody system to ensure sources of biomass are sustainably harvested and contribute to net carbon sequestration from the atmosphere.
Conventionally-termed biomass energy is really transforming solar energy which is stored in logs and other cellulose into electricity or heat which is then used for human purposes. One advantage is that it can use carbon on a short cycle, rather than needing carbon from fossil sources. Fossil carbon combustion adds carbon to our biogeochemical cycles and has disrupted our climate by trapping heat through the greenhouse effect of CO2 and related gasses in the atmosphere. Short-cycle carbon use from agriculture and forestry resources can support our economy with energy without adding more carbon into the system, if managed prudently. We already have a lot of carbon we should be pulling out of the atmosphere into soils, accumulating carbohydrates and other long-term storage.
To the EPA:
I support biomass as an energy generation scheme that may be better for our environment than burning fossil fuels. I strongly urge you to ensure truly sustainable chains of supply of biological carbon to biomass energy facilities. This cannot include plastics and most trash, nor wood and woody wastes from unsustainably harvested forests. If biomass energy generation is to be labeled “carbon neutral” in terms of carbon loading of the atmosphere, it must be proven so!
EPA’s greenhouse gas rules must fully account for all greenhouse gas emissions from incinerators that burn “biomass” and from “waste to energy” facilities. Industry claims that burning biomass and garbage is “carbon neutral” are not supported by science or common sense.
The industry effort to distinguish “biological” or “biogenic carbon” from carbon emitted by burning fossil fuels is a false distinction. So much carbon has already been taken from underground fossil stores and added to above ground “carbon pools” that ecosystems are saturated and unable to re-sequester or cycle it all, already. Compromising our stressed ecosystems by burning trees and garbage for electricity will make climate change worse and harm human health.
Please ensure that CO2 emissions from biomass and waste to energy incinerators are fully accounted for in the Tailoring Rule.
Thank you for your work to limit surplus carbon pollution in our ecosystem and atmosphere!