Burning Issues with Biomass

by Mike Ewall

Green ener­gy to bring us wind mills AND incinerators

While the new green ener­gy mar­ket­place is bring­ing a 10 megawatt wind farm to south­west Penn­syl­va­nia, it has also tar­get­ed poor, minor­i­ty com­mu­ni­ties in the state of Delaware with a 22.5 megawatt con­struc­tion and demo­li­tion waste incin­er­a­tor.¹

A few years ago, if a cor­po­ra­tion want­ed to build a con­struc­tion and demo­li­tion wood waste incin­er­a­tor in your com­mu­ni­ty, they would come in and tell every­one that you’d be get­ting a “co-gen­er­a­tion plant to burn clean wood chips.” Now that there is a green ener­gy mar­ket­place devel­op­ing due to elec­tric util­i­ty dereg­u­la­tion, these same incin­er­a­tor push­ers are now com­ing into com­mu­ni­ties pro­mot­ing them­selves as “green ener­gy bio­mass co-gen­er­a­tion pow­er plants” that would “take pol­lu­tion out of the air.“²

This is only the begin­ning. There are pro­pos­als in many oth­er states to burn all sorts of things in order to pro­vide “green” power.

The term “bio­mass” has been used to include all sorts of com­bus­tion schemes, such as:

• Incin­er­a­tion of wastes, includ­ing…
  
  • Munic­i­pal Sol­id Waste (Garbage)Sewage sludgeTiresWood waste (construction/demolition, urban tree trim­mings, paper and lum­ber mills wastes, etc.)Agri­cul­ture crop wastes (often laden with tox­ic pes­ti­cides)Ani­mal fac­to­ry wastes (cor­po­rate hog fac­to­ry wastes, dairy fac­to­ry wastes, chick­en feces & bod­ies, etc.)
• Burn­ing of “ener­gy crops” (tree or crop farms) 
• Cut­ting down trees from forests to burn in indus­tri­al wood burn­ers
• Digesters (Anaer­o­bi­cal­ly com­post­ed ani­mal fac­to­ry waste, sewage sludge…) 
• Com­bus­tion of con­t­a­m­i­nat­ed land­fill gas­es

Every­where you check, there are dif­fer­ent def­i­n­i­tions of “bio­mass.” One def­i­n­i­tion of bio­mass is pro­vid­ed by the Nation­al Renew­able Ener­gy Lab­o­ra­to­ry³:

“Bio­mass: Organ­ic mat­ter avail­able on a renew­able basis. Bio­mass includes for­est and mill residues, agri­cul­tur­al crops and wastes, wood and wood wastes, ani­mal wastes, live­stock oper­a­tion residues, aquat­ic plants, fast-grow­ing trees and plants, and munic­i­pal and indus­tri­al wastes.”

In gen­er­al, bio­mass can include any­thing that is not a fos­sil fuel that can be argued to be organ­ic. Tires and sewage sludge are rarely, but some­times, includ­ed as bio­mass fuels. Some­times (par­tic­u­lar­ly in fed­er­al leg­is­la­tion) cer­tain types are specif­i­cal­ly exclud­ed, such as old growth tim­ber, garbage, and treat­ed wood. Some­times land­fill gas and “bio­gas” digesters are con­sid­ered to be in sep­a­rate cat­e­gories from biomass.

“Alter­na­tive” vs. “Renew­able” vs. “Clean & Green”

All of the above terms are often used inter­change­ably, but can mean dif­fer­ent things. Just the term “renew­able” can mean dif­fer­ent things in states, fed­er­al ener­gy bills and pro­grams, and cer­ti­fi­ca­tion pro­grams like Green‑e.

“Alter­na­tive” is gen­er­al­ly used to mean “not fos­sil fuels and not nuclear.” This leaves the door open for all sorts of incin­er­a­tion to be con­sid­ered “alter­na­tive energy.”

“Clean” and “green” are rarely, if ever, defined. They are terms of gen­er­al envi­ron­men­tal ben­e­fit and have no gen­er­al­ly accept­ed mean­ing.⁴

“Renew­able” is the term that is used in state and fed­er­al leg­is­la­tion, in gov­ern­ment ener­gy pro­grams and in the Green‑e cer­ti­fi­ca­tion pro­gram. Almost uni­ver­sal­ly, def­i­n­i­tions of renew­ables include “bio­mass” as well as land­fill gas. There­fore, renewa­bil­i­ty does not usu­al­ly mean clean or green. It’s only used to describe whether an ener­gy source is replen­ish­able and replen­ished on some rea­son­ably short time scale.⁵

Renew­ables aren’t nec­es­sar­i­ly clean­er than non-renew­ables. Since bio­mass incin­er­a­tors are allowed to be con­sid­ered renew­able, they are giv­en an advan­tage over clean­er (but still not that clean) fuels like nat­ur­al gas⁸, which is a non-renew­able fos­sil fuel.

Bio­mass = com­bus­tion = pollution

All bio­mass com­bus­tion tech­nolo­gies put pol­lu­tion in the air in order to make “green ener­gy.” Most of the bio­mass wastes/fuels con­tain chlo­rine or oth­er halo­gens and would cre­ate diox­ins and furans when burned. Any­thing that cre­ates pol­lu­tion in the course of pro­duc­ing elec­tric­i­ty should­n’t be con­sid­ered green, clean or renew­able. Wind and solar, even though they have some envi­ron­men­tal impacts in their con­struc­tion (like the tox­i­cs used to make solar pan­els), don’t have to keep pol­lut­ing in order to make electricity.

Any­thing that has envi­ron­men­tal­ly-dam­ag­ing emis­sions that can be mea­sured per kilo­watt is not deserv­ing of the var­i­ous advan­tages grant­ed to renew­able ener­gy sources.

Poli­cies designed for renew­able ener­gies will end up sup­port­ing incineration.

There are five main advan­tages avail­able to tech­nolo­gies that are labeled “renew­able” ener­gy: tax cred­its, sub­si­dies, research, Renew­able Port­fo­lio Stan­dards, and pref­er­en­tial pric­ing afford­ed to “green power.”

Pres­i­dent Clin­ton signed an Exec­u­tive Order in August 1999 to triple bio­mass ener­gy use over the next ten years.⁹ There are over 20 bills in both the U.S. House and Sen­ate which would pro­vide some sort of advan­tage to bio­mass burn­ing. Most of these involve research pro­grams or tax cred­its for renew­able ener­gy (includ­ing bio­mass). A cou­ple of these have already passed.¹⁰ Renew­able Port­fo­lio Stan­dards (RPS) are a won­der­ful way of boost­ing the mar­ket for renew­ables, as long as there is a clean def­i­n­i­tion of renew­ables. How­ev­er, if a dereg­u­la­tion bill con­tains RPS and includes bio­mass as a renew­able, they can effec­tive­ly boost the mar­ket for incin­er­a­tors as well. Such bills exist in a few state-lev­el dereg­u­la­tion bills and a cou­ple fed­er­al bills (includ­ing a bill spon­sored by the Ratepay­ers for Afford­able Green Ener­gy (RAGE) cam­paign¹¹).

Dis­place­ment is used to jus­ti­fy most of the things that can’t stand on their own merits.

Some bio­mass pro­mot­ers try to claim that they’re improv­ing the envi­ron­ment. Philpow­er, for exam­ple, said that they would be “tak­ing pol­lu­tion out of the air.” No known tech­nol­o­gy pro­duces elec­tric­i­ty by suck­ing pol­lu­tants out of the air. The only pol­lu­tion reduc­tion that can result from elec­tric gen­er­a­tion is if a dirt­i­er tech­nol­o­gy could be dis­placed by the capac­i­ty that a new and clean­er facil­i­ty is pro­duc­ing or our favorites “con­ser­va­tion and efficiency.”

There are sev­er­al prob­lems with try­ing to make the dis­place­ment argument.

Who gets the cred­it for dis­place­ment? If a coal plant clos­es, how do you prove which gen­er­a­tor pro­vid­ed the ener­gy to replace it?

Dis­place­ment may not be effect­ed any­where near the cus­tomers whose envi­ron­ment is sup­pos­ed­ly being improved. Increased gen­er­at­ing capac­i­ty in one grid could real­ly be off­set­ting elec­tric gen­er­a­tion in a neigh­bor­ing grid, sev­er­al states away.

Dis­place­ment may not be occur­ring. With ener­gy demand increas­ing year­ly,¹² new gen­er­at­ing facil­i­ties may sim­ply serve the addi­tion­al demand, with­out replac­ing any­thing. Putting any “renew­able” facil­i­ty online does­n’t imply that it exceeds the year­ly increase enough to dis­place anything.

Bio­mass com­petes with wind, solar, hydro­elec­tric and geot­her­mal for the renew­ables mar­ket. Wind is becom­ing one of the cheap­est ener­gy sources (alto­geth­er) and is about 10 times cheap­er than solar. Bio­mass is the cheap­est Green‑e renew­able except for where there are good wind sites. We are like­ly to see many more bio­mass burn­ers because they can be built in many more places than good wind sites can be found. Since there is already a mar­ket for incin­er­a­tors (based on the eco­nom­ics of the waste indus­try), bio­mass com­petes most direct­ly with wind, the clean­est and most promis­ing pow­er source.

Since there is already a well-devel­oped incin­er­a­tion indus­try, bio­mass is like­ly to uti­lize most of the leg­isla­tive ben­e­fits. Elim­i­nat­ing bio­mass from renew­ables def­i­n­i­tions means that wind (the clean­est option, and one of the cheap­est) would get bet­ter funding.

Pro­po­nents of bio­mass and nat­ur­al gas have both argued that their tech­nolo­gies are a tran­si­tion­al step to clean­er tech­nolo­gies like wind and solar. How­ev­er, increas­ing reliance on com­bus­tion tech­nolo­gies does not real­ly pave the way for wind. No ener­gy com­pa­nies have estab­lished these tech­nolo­gies with a timetable for replac­ing them with clean renewables.

All bio­mass tech­nolo­gies except for land­fill gas burn­ers involve truck­ing fuel/waste to and from a cen­tral­ized machine over the life of the oper­a­tion. These burn­ers are cap­i­tal inten­sive machines, amor­tized over 10–20 year cycles, that by resul­tant eco­nom­ic demands, require a cer­tain ton­nage per day to main­tain the required return on investment.

Waste Incin­er­a­tion

Waste incin­er­a­tion is the worst cat­e­go­ry of bio­mass. Pro­vid­ing increased waste dis­pos­al capac­i­ty wors­ens the waste prob­lem by low­er­ing the costs asso­ci­at­ed with waste gen­er­a­tion. It also destroys resources (some of which are best recy­cled or com­post­ed), and turns them into tox­ic ash and tox­ic air emis­sions. The wastes which can­not be reused, recy­cled or com­post­ed clean­ly ought to be land­filled rather than incinerated.

What makes waste dan­ger­ous is not its vol­ume, but its tox­i­c­i­ty. Peo­ple don’t usu­al­ly die from waste phys­i­cal­ly falling on them, but expo­sure to the tox­ic con­stituents of wastes can cause all sorts of health and envi­ron­men­tal prob­lems. When wastes are incin­er­at­ed, their tox­ic con­stituents are lib­er­at­ed into breath­able air emis­sions. Tox­ic haz­ards asso­ci­at­ed with the wastes increase as heavy met­als are released and halo­genat­ed chem­i­cals (chlo­rine, flu­o­rine, bromine…) are con­vert­ed to high­ly tox­ic organ­ic forms like diox­ins and furans. Waste incin­er­a­tion is the largest known source of diox­in (the most tox­ic chem­i­cal ever stud­ied). The ash that is left then has a high­er sur­face area and is more dan­ger­ous in a land­fill, where the tox­ic con­stituents can leach out more read­i­ly than if left unburned. In recent years, incin­er­a­tor ash has been pro­mot­ed for such appli­ca­tions as ingre­di­ents in cement, fill for reclaim­ing mines, fer­til­iz­er, indus­tri­al tile and road base. These are even more dan­ger­ous options than land­fill­ing, as they bring the con­t­a­m­i­na­tion clos­er to where they might harm people.

Munic­i­pal Sol­id Waste (Garbage)

Often “sol­id waste” is in com­pa­ny’s def­i­n­i­tion of bio­mass.¹³ Rep­re­sen­ta­tives from the sol­id waste indus­try have lob­bied allow garbage incin­er­a­tion to be con­sid­ered “renew­able” but flash­ing mon­ey won’t make it any more green. Nation­wide, garbage incin­er­a­tion com­pris­es 28% of exist­ing biopow­er capac­i­ty. In the extend­ed Mid-Atlantic area (Vir­ginia to New York), garbage incin­er­a­tion makes up 66% of exist­ing biopow­er capac­i­ty.¹⁴ Ener­gy mar­keters have a lot to lose if garbage incin­er­a­tion is not con­sid­ered renewable.

Sewage Sludge

There is no such thing as clean sewage sludge. Sewage sludge is a com­bi­na­tion of human waste, house­hold chem­i­cals, stormwa­ter run-off (includ­ing leaked auto­mo­tive flu­ids), and com­mer­cial and indus­tri­al wastes.¹⁵ Cor­po­ra­tions are per­mit­ted to dump tox­ic chem­i­cals¹⁶ and even radioac­tive mate­ri­als¹⁷ down the drain to be “treat­ed” at sewage treat­ment plants which aren’t designed to treat tox­ic chem­i­cals. House­hold chem­i­cals can be fair­ly tox­ic. Every bot­tle of sham­poo, con­di­tion­er, antibac­te­r­i­al (pes­ti­cide) soap¹⁸ and oth­er house­hold chem­i­cals like liq­uid plumber and bleach ends up down the drain. High school and col­lege chem­istry and art class­es also con­tribute to the tox­ic muck that is sewage sludge. Excret­ed phar­ma­ceu­ti­cals get flushed down toi­lets, lead­ing to a grow­ing glob­al prob­lem of phar­ma­ceu­ti­cal pol­lu­tion in water­ways.¹⁹ Even the flu­o­ride acids which are added to water and the lead which flu­o­ride helps leach out of pipes²⁰ ends up back down the drain and in the sludge.

Burn­ing the tox­ic stew of sewage sludge pro­vides a con­ve­nient way to make these tox­ic chem­i­cals breath­able. There is noth­ing green about sludge incineration.

Tires

[See our new page on Tire-Derived Fuel for more detailed information.]

Tires con­tain many tox­ic con­stituents which make burn­ing them quite haz­ardous. Halo­gens in tires cause very haz­ardous emis­sions when burned such as diox­ins, furans, PCBs, and chloroben­zenes. Tox­ic met­als such as mer­cury, lead, arsenic and chromi­um are also released when burn­ing tires.²³ Many oth­er haz­ardous air pol­lu­tants are released from burn­ing tires. Stud­ies have shown tire burn­ing to be dirt­i­er than coal.²⁴ While not wide­ly pro­mot­ed as bio­mass, tire burn­ing has been con­sid­ered in some fed­er­al bio­mass ener­gy research pro­grams.²⁵

Wood waste (construction/demolition, urban tree trim­mings, paper and lum­ber mills wastes, etc.)

Wood waste is a very broad cat­e­go­ry. It includes — but is not lim­it­ed to — wood pal­lets, con­struc­tion / demo­li­tion wood waste, land clear­ing and right-of-way tree trim­mings, Christ­mas trees, tree and shrub trim­mings, paper and lum­ber mill waste, and wood prod­ucts indus­try wastes.

Wood from sources like tree trim­ming can be con­t­a­m­i­nat­ed with pes­ti­cides which may add tox­ic inputs to a burn­er. Wood waste is not the same as wood cut fresh from a for­est. Wood waste can come con­t­a­m­i­nat­ed with wood preser­v­a­tives, binders, paints, glues, plas­tic lam­i­nat­ing mate­ri­als or oth­er non-wood mate­ri­als. It can also mean par­ti­cle­board, flake­board, ply­wood, fiber­board and man­u­fac­tured wood which may have plas­tic lam­i­nates, chlo­ri­nat­ed adhe­sives, or phe­nol and urea formalde­hyde resins. Oth­er prod­ucts which have been allowed to be burned in indus­tri­al wood burn­ers include pel­letized wood pulp from mills which may use chlo­rine bleach. Wood pal­lets have been dis­cussed as bio­mass fuels. It is unrea­son­able to expect that the met­als sta­ples and nails are removed before incin­er­a­tion in indus­tri­al wood burners.

Paint­ed wood may include lead or mer­cury (par­tic­u­lar­ly in demo­li­tion debris). Mer­cury has been used as a fungi­cide in paint. Treat­ed woods are usu­al­ly coat­ed with either cre­osote, cop­per chromi­um arse­n­ate, or pen­tachlorophe­nol.²⁷ Pen­tachlorophe­nol is a chlo­ri­nat­ed com­pound which will form diox­ins and furans when burned. Burn­ing wood treat­ed with cop­per chromi­um arse­n­ate (CCA) will release arsenic and chromi­um VI. Since cop­per serves as a cat­a­lyst in diox­in for­ma­tion,²⁸ any small bit of CCA-treat­ed wood will great­ly esca­late diox­in emis­sions from indus­tri­al wood burn­ers. Some wood burn­ers that are per­mit­ted to be tak­ing “clean” wood wastes have been allowed to accept a cer­tain per­cent­age of chlo­ri­nat­ed wastes, since wood waste sup­pli­ers are unable to com­plete­ly iso­late all vinyl-coat­ed mate­r­i­al.²⁹ In construction/demolition wastes, there is like­li­hood of PVC (polyvinylchlo­ride) con­t­a­m­i­na­tion from many sources com­mon in build­ing mate­ri­als. For exam­ple, all house­hold elec­tri­cal wire sold in the U.S. is coat­ed with PVC plas­tic. Since this wire is made of cop­per, it’s an extreme­ly dan­ger­ous mix­ture to have burned, since the cop­per will cat­alyze increased diox­in for­ma­tion out of the PVC.

Indus­tri­al wood burn­ers are not usu­al­ly out­fit­ted with advanced pol­lu­tion con­trols. Some are equipped only with elec­tro­sta­t­ic pre­cip­i­ta­tors (ESPs), which are known to boost diox­in emis­sions by retain­ing the exhaust gas­es in the tem­per­a­ture range where diox­ins are formed.³⁰ In addi­tion to diox­ins, furans and tox­ic met­als, indus­tri­al wood burn­ers also emit formalde­hyde, phe­nols, ben­zene, naptha­lene (present in cre­osote), and chlo­rine, not to men­tion NOx, SOx, VOCs, and par­tic­u­late matter.

Waste wood that is tru­ly clean ought to be reused or made into paper, but not burned. Indus­tri­al wood burn­ers, even if they start off burn­ing a rel­a­tive­ly “clean” sup­ply of wood wastes, often end up seek­ing to burn more haz­ardous types of waste. In some cas­es, wood waste facil­i­ties have sought to burn wood tar waste.³¹ In oth­er cas­es, state agen­cies have allowed indus­tri­al wood burn­ers to dis­pose of their oily water by spray­ing it on their wood fuel.³² Some states active­ly encour­age indus­tri­al wood burn­ers to burn waste tires.^{33, 34} It has been argued by some cor­po­ra­tions that they need to co-fire tires in order to become “lean­er and mean­er” in the dereg­u­lat­ed elec­tric mar­ket.³⁵ Many indus­tri­al wood burn­ers are already per­mit­ted to burn tires, treat­ed wood waste, black liquor solids and/or paper sludges.

Many paper or lum­ber mills, fiber­board plants and oth­er indus­tries that process wood, paper or pulp have incin­er­a­tors for waste that is cre­at­ed pri­mar­i­ly or entire­ly on-site. In some cas­es, these incin­er­a­tors pro­duce excess elec­tric­i­ty that is sold to the grid.

In lum­ber mills, the fuel is most­ly saw­dust and wood scraps. These wood wastes could be recy­cled or com­post­ed, instead of being burned for elec­tric­i­ty which pro­duces large amounts of par­tic­u­late mat­ter as well as NOx and SO2.

In paper mills, chlo­rine com­pounds are used as bleach­ing agents. Some paper com­pa­nies burn their black liquor (pulp­ing liq­uid that they cook wood chips in). This liquor is chlo­ri­nat­ed and pro­duces diox­ins and furans when burned. The Cham­pi­on Inter­na­tion­al paper mill in Pigeon, Ten­nessee invent­ed a bleach fil­trate recy­cling process which is used to get more ener­gy and heat recov­ery from their boil­ers. Accord­ing to Cham­pi­on’s fig­ures, their process leads to a 42% increase in chlo­ride con­cen­tra­tion from fired black liquor. This dirt­i­er process is now being used by oth­er paper corporations.

Fiber­board plants use formalde­hyde (a haz­ardous air pol­lu­tant) and oth­er tox­ic glues such as iso­cyanate. Although soy-based adhe­sives are avail­able as alter­na­tives, fiber­board cor­po­ra­tions have been reluc­tant to switch to them. The tox­ic con­stituents of these glued and oth­er­wise treat­ed wood prod­ucts make them unsafe to burn. Par­ti­cle board and oth­er processed wood prod­ucts can come con­t­a­m­i­nat­ed with chlo­ri­nat­ed plas­tics that are burned since they’re not eas­i­ly removed.

Wood waste incin­er­a­tion is one of the pri­ma­ry types of bio­mass that is being accept­ed as renew­able in the Green‑e pro­gram. The Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee rec­om­mend­ed includ­ing the sale of ener­gy from incin­er­at­ing wood wastes that are sup­pos­ed­ly not treat­ed, paint­ed, stained or con­t­a­m­i­nat­ed with vinyl or nails. How­ev­er, the bur­den of proof for enforce­ment of these lim­i­ta­tions is left up to the com­mu­ni­ties who must live near these wood waste incin­er­a­tors, as Green‑e has no means to enforce site-spe­cif­ic restric­tions they cre­ate.³⁶

Agri­cul­ture wastes

Agri­cul­ture wastes include, but are not lim­it­ed to, orchard tree crops, vine­yard, grain, legumes, sug­ar, and oth­er crop byprod­ucts or residues as well as nuts, shells, hulls, and oth­er food pro­cess­ing wastes.

Crop wastes ought to be tilled back into the soil to pro­mote soil health, tilth, fer­til­i­ty, and nur­tur­ing of the organ­isms remain­ing with­in the soil. In the cas­es where this is imprac­ti­cal, crop residues ought to be com­post­ed or recy­cled into paper prod­ucts, not destroyed in incin­er­a­tors. Pes­ti­cides applied to crops may form diox­ins when burned.

Ani­mal fac­to­ry wastes — [See our sec­tion on poul­try waste incin­er­a­tion for more details]

Fibrowatt Ltd., a British cor­po­ra­tion, has been seek­ing to build chick­en and turkey waste incin­er­a­tors in Mary­land and Min­neso­ta, respec­tive­ly. Fibrowatt is 20% owned by Fos­ter Wheel­er, the incin­er­a­tion giant. They have hired Carl Strick­ler as their lob­by­ist. Strick­ler served as the Vice-Pres­i­dent of Read­ing Ener­gy when they got kicked out of Mor­risville, Penn­syl­va­nia for try­ing to build a con­struc­tion & demo­li­tion wood waste incin­er­a­tor in 1997. Strick­ler has shown up at a Mid-Atlantic Green‑e bio­mass meet­ing on Decem­ber 7th, 1999 and has been allowed to par­tic­i­pate even though envi­ron­men­tal jus­tice activists were kicked out of that meet­ing. The rec­om­men­da­tions of the Mid-Atlantic Green‑e bio­mass com­mit­tee were adopt­ed on Feb­ru­ary 25th, 2000 when the Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee approved all ani­mal waste incin­er­a­tion as renew­able, over the objec­tions of sev­er­al envi­ron­men­tal groups.

Fibrowatt helped Delaware’s Sen­a­tor Roth extend a renew­able ener­gy tax cred­it (which usu­al­ly ben­e­fits only wind pow­er) to poul­try waste burn­ers in a 1999 Tax Relief Bill.³⁸ This 1.7 cent per kilo­watt-hour sub­sidy will help make it afford­able to import wood chips to allow the poul­try waste to burn effec­tive­ly.³⁹

Based on Fibrowat­t’s emis­sions num­bers, the evi­dence shows that poul­try waste burn­ing is rough­ly as pol­lut­ing as coal (or high­er than coal in some cas­es) for many pol­lu­tants, includ­ing NOx, SO2, car­bon monox­ide, par­tic­u­late mat­ter, hydrochlo­ric acid, anti­mo­ny, man­ganese, and mer­cury.^{40, 41} We’re sup­posed to believe that these emis­sions don’t mat­ter because the green­house gas­es and oth­er pol­lu­tants are already in the envi­ron­ment and are being “recy­cled” as they move from chick­ens to smoke­stacks to chick­en feed to chick­ens again.⁴²

The Del­mar­va (Delaware/Maryland/Virginia) Penin­su­la, which lies between the Chesa­peake Bay and the Atlantic Ocean, is over­run with chick­en fac­to­ry farms. There is far more chick­en waste pro­duced than can be used by local farm­ers as fer­til­iz­er, lead­ing to exces­sive nutri­ent runoff into the Chesa­peake Bay. Pel­leti­za­tion is a clean­er alter­na­tive, which can allow the waste to be dried and shipped to oth­er parts of the coun­try where fer­til­iz­er is in high demand. How­ev­er, Per­due’s plans for a cen­tral­ized, large-scale pel­leti­za­tion plant in Mary­land have been opposed by local res­i­dents due to odor and truck traf­fic con­cerns.⁴³ As long as there is an unsus­tain­able lev­el of chick­en pro­duc­tion in the Del­mar­va, small-scale pel­leti­za­tion should be used to han­dle excess waste. Incin­er­a­tion should not be accept­ed by the envi­ron­men­tal com­mu­ni­ty as an out for an unsus­tain­able indus­try. Delaware and Mary­land envi­ron­men­tal groups have been strong­ly opposed to burn­ing chick­en waste.^{44, 45}

Rather than con­sid­er it a waste prod­uct, Min­neso­ta farm­ers are will­ing to pay for poul­try manure as fer­til­iz­er. In Min­neso­ta, organ­ic farm­ers are con­cerned that Fibrowat­t’s pro­posed turkey waste incin­er­a­tor will dri­ve up the price of poul­try manure by burn­ing near­ly half of the state’s sup­ply. Both the Min­neso­ta Farm­ers Union and New Ag Amer­i­ca have issued res­o­lu­tions against pub­lic sub­si­dies for the incin­er­a­tion of poul­try manure. In Min­neso­ta, sub­si­dies exist for sup­port­ing renew­able ener­gy, includ­ing bio­mass, though poul­try manure does not qual­i­fy as bio­mass.⁴⁶ Fibrowatt has 8 reg­is­tered lob­by­ists in Min­neso­ta who have been seek­ing to change that def­i­n­i­tion so that the com­pa­ny would be eli­gi­ble for state sub­si­dies worth $140 mil­lion in addi­tion to the $55 mil­lion they’d get from the fed­er­al sub­sidy that was made law in 1999.⁴⁷

Burn­ing of “ener­gy crops”

Ener­gy crops involve plant­i­ng some sort of tree or crop, cut­ting them, burn­ing them for green ener­gy, then replant­i­ng, etc. Quick-grow­ing crops such as wil­low, alfal­fa, sorghum, poplar, switch­grass or oth­er crops or trees would be farmed in “ded­i­cat­ed” monocrop plantations.

To mit­i­gate the green­house pol­lu­tants that this would put out, the facil­i­ty would replant the trees or crop and con­sid­er it renew­able. Accord­ing to the Nation­al Renew­able Ener­gy Lab­o­ra­to­ry, “[b]urning new bio­mass con­tributes no new car­bon diox­ide to the atmos­phere because if we replant har­vest­ed bio­mass, car­bon diox­ide is returned to the cycle of new growth.“⁴⁸ Even con­gress has not stat­ed that bio­mass use is a solu­tion for glob­al warm­ing. They state in the Nation­al Sus­tain­able Fuels and Chem­i­cals Act of 1999 that bio­mass pro­vides “near-zero net green­house gas emis­sions.“⁴⁹ No com­bus­tion tech­nolo­gies do any­thing to mit­i­gate green­house gas emis­sions. Ener­gy crop projects only move green­house gas­es around.

This log­ic behind the “car­bon cycle” glob­al warm­ing argu­ment could almost be used by a coal plant if they could plant enough trees to off­set their green­house gas emis­sions. The main dif­fer­ence would be that a bio­mass facil­i­ty would plant in the same place they cut. Shell Oil and Mon­san­to have actu­al­ly teamed up to cre­ate genet­i­cal­ly-mod­i­fied, quick grow­ing “ter­mi­na­tor” trees that the oil indus­try could plant to off­set their green­house gas emis­sions.^{50, 51}

The U.S. gov­ern­ment and pri­vate indus­try have also been research­ing genet­i­cal­ly mod­i­fied crops, but for bio­mass ener­gy pur­pos­es. A Novem­ber 1995 arti­cle on the genet­ic engi­neer­ing of poplar trees stat­ed, “[i]n addi­tion to wood and fiber uses, the [U.S. Depart­ment of Ener­gy] and [the Elec­tric Pow­er Research Insti­tute] are inter­est­ed in the poten­tial for genet­ic engi­neer­ing to increase the eco­nom­ic effi­cien­cy and reduce envi­ron­men­tal impacts of woody ener­gy crops, nec­es­sary to make them more com­pet­i­tive with fos­sil fuels.“⁵²

Ener­gy crop pro­po­nents argue that they need to use chem­i­cal her­bi­cides in the first year in order to estab­lish a tree crop so that weeds don’t choke out saplings. Hav­ing reject­ed the organ­ic cer­ti­fi­ca­tion stan­dard, there is no pro­tec­tion to ensure that chem­i­cal inputs are not used for the dura­tion of the pro­duc­tion of an ener­gy crop. There is also noth­ing pre­vent­ing the use of sewage sludge or oth­er haz­ardous wastes as fer­til­iz­ers on ener­gy crops. These tox­ic inputs would increase the haz­ards of incin­er­at­ing the plants exposed to them.

Hybrid poplar plan­ta­tions are being wide­ly pro­posed for biore­me­di­a­tion projects at munic­i­pal and indus­tri­al waste oper­a­tions. Trees would be plant­ed at con­t­a­m­i­nat­ed sites to uptake tox­ins from the soil and water. When the trees are removed, the tox­ins go with them. What then hap­pens to the trees is less clear. If these trees are can­di­dates for bio­mass burn­ers, their emis­sions would be enor­mous­ly more tox­ic than for­est or “ener­gy crop” trees. Read more about the merg­ing of the phy­tore­me­di­a­tion and bio­mass ener­gy crop indus­tries here: Burn­ing Tox­ic Plants for Green Ener­gy: The Merg­ing of the Phy­tore­me­di­a­tion and Bio­mass Ener­gy Crop Industries

Since ener­gy crops are unlike­ly to be plant­ed on lands being used for food crops, mar­gin­al lands which may not have been farmed will be tar­get­ed. These lands tend to be more sen­si­tive, have weak­er soil and more ero­sion prob­lems. Some (par­tic­u­lar­ly wil­low) are like­ly to be plant­ed near streams since they need a lot of water. Wet­lands and flood­plains may be at risk. Water and fer­til­iz­er use as well as the use of fos­sil-fuel-depen­dent farm­ing machin­ery make the sus­tain­abil­i­ty and green-ness of these projects questionable.

The large-scale use of bio­mass resources has the poten­tial to gen­er­ate incen­tives for unde­sir­able land use and land man­age­ment prac­tices. Pro­duc­tion of ded­i­cat­ed bio­mass crops could at some point com­pete for agri­cul­tur­al land (or increase har­vest­ing pres­sures on for­est land).⁵⁵

When the pro­posed plan­ta­tion land­mass or prices to plan­ta­tion share­crop­pers proves inad­e­quate, this leads to whole tree chip­ping (tops and all), incur­sions into remain­ing native forests, expan­sions of plan­ta­tion lands, increased clearcut­ting on lands oth­er­wise selec­tive­ly cut, cre­ates mar­kets for all junk trees, and encour­ages in-woods chip­ping which can ulti­mate­ly lead to stump har­vests to try to meet the demands of the burn­er. Bio­mass ener­gy pro­duc­tion will encour­age clearcut­ting, con­ver­sion of native forests to bio­mass farms, and pro­mote nutri­ent drain­ing short rota­tion bio­mass pro­duc­tion on Con­ser­va­tion Reserve Pro­gram lands (CRP). CRP lands are the focus of ener­gy crop research and most often are lands that should nev­er have been cleared or are lands that have suf­fered exces­sive abuse in the recent past. These lands are best suit­ed for recov­ery to native plant com­mu­ni­ties, rather that be put into increased demands of inten­sive bio­mass har­vests. There is no doc­u­men­ta­tion of the sus­tain­abil­i­ty of repeat­ed bio­mass removals on most soil types. To the con­trary, most doc­u­men­ta­tion points to nutri­ent loss­es, soil deple­tion and decreased pro­duc­tiv­i­ty in one or two gen­er­a­tions.⁵⁶

Cut­ting down trees from forests to burn in indus­tri­al wood burners

Trees may be renew­able, but forests are not. Bio­mass burn­ing can be dev­as­tat­ing to forests. The major use of wood in the U.S. is not lum­ber or paper, but ener­gy.⁵⁸ Putting for­est growth into a boil­er denies its use for paper or lum­ber. An acre sus­tain­ing elec­tric pow­er is not avail­able for oth­er wood prod­ucts.⁵⁹

Log­ging slash left to decom­pose on site is not wast­ed wood. It pro­vides an excel­lent source of car­bon and nutri­ents for for­est soil, bad­ly need­ed after the extrac­tion of large quan­ti­ties of bio­mass in the form of logs. Tree tops in par­tic­u­lar are very rich in nutri­ents. If log­ging slash is used for green ener­gy, it may give rise to the “vac­u­um clean­er” effect. Instead of going into a site and haul­ing out logs, tim­ber oper­a­tors would be encour­aged to “vac­u­um” up and remove all woody mate­r­i­al. Chip­ping trees for elec­tric pow­er gen­er­a­tion is a ter­ri­ble, low val­ue waste of a resource that should be treat­ed as pre­cious. For­est land is far more valu­able unused than it is if used for wood chips.

The log­ging indus­try and their friends in the main­stream envi­ron­men­tal com­mu­ni­ty claim that that log­ging forests for bio­mass enhances for­est health. This has been used to jus­ti­fy indus­tri­al wood burn­ers like the McNeil Gen­er­at­ing Sta­tion in Burling­ton, Ver­mont — a plant which has been con­tribut­ing to asth­ma prob­lems in the neigh­bor­ing com­mu­ni­ty. Log­ging con­tributes to increased flood­ing, habi­tat destruc­tion and loss of native species.

Digesters (Ani­mal fac­to­ry waste, sewage sludge…) — [See our new sec­tion on anaer­o­bic digesters for more details]

Anaer­o­bic digesters are con­tain­ers that decom­pose wet organ­ic mate­r­i­al with­out the use of oxy­gen. This process pro­duces methane which can then be burned as fuel. Ani­mal wastes and sewage sludge are the pri­ma­ry wastes which are being looked at for diges­tion, but essen­tial­ly any wet organ­ic mate­r­i­al such as food pro­cess­ing waste could be digested.

To eco­nom­i­cal­ly sell elec­tric­i­ty, digesters must be placed on large oper­a­tions. About half of the 36 ani­mal waste digesters in the U.S. that sell elec­tric­i­ty are on Con­fined Ani­mal Feed­ing Oper­a­tions (CAFOs).⁶⁰ In oth­er cas­es, ani­mal waste could be trucked in from a num­ber of farms to cen­tral­ized digesters (such as one for chick­en waste being fought in West Vir­ginia). It is unclear how digester use will affect the waste dis­pos­al costs and eco­nom­ics of CAFO operations.

Unad­dressed is the mat­ter of whether the heavy met­als, tox­ic chem­i­cals, and some­times even radioac­tive con­t­a­m­i­nants present in sewage sludge migrate into the gas formed in a digester.

Combustion of contaminated landfill gases

“Land­fill gas” is not the same thing as “nat­ur­al gas” or “methane.” Land­fill gas is rough­ly 50% methane. The remain­der of land­fill gas is most­ly car­bon diox­ide with “trace amounts” (usu­al­ly under 1%) of con­t­a­m­i­nants known as “non-methane organ­ic com­pounds” or NMOCs.⁶¹ There are some­times over 100 of these tox­ic con­t­a­m­i­nants, includ­ing such chem­i­cals as ben­zene, toluene, chlo­ro­form, vinyl chlo­ride, car­bon tetra­chlo­ride, and 1,1,1 trichloroethane. Since almost half of these con­t­a­m­i­nants are halo­genat­ed, diox­ins and furans will be formed when these gas­es are burned.⁶²

In order to green­wash land­fill gas uti­liza­tion projects, some pro­po­nents have urged their col­leagues to describe land­fill gas as “nat­ur­al” gas and to describe the burn­ing of it as “like recy­cling.“⁶³ The land­fill gas indus­try, aid­ed by EPA’s Land­fill Methane Out­reach Pro­gram, is push­ing for pas­sage of House Bill 3466, which would extend renew­able ener­gy tax cred­its to land­fill gas burn­ers.⁶⁴

It’s a very dif­fer­ent thing to ask “what is the best way to man­age land­fill gas?” than to ask “how should we pro­duce green, renew­able ener­gy?” If you ask about the best way to man­age land­fill gas, the answer is along the lines of “before you do any­thing with it, fil­ter out the tox­ic con­t­a­m­i­nants and treat them with a non-burn tech­nol­o­gy.” If the ques­tion is how to pro­duce clean, renew­able ener­gy, the answer is more like “use tech­nolo­gies such as wind and solar that don’t cre­ate pol­lu­tion in the process of mak­ing energy.”

For a more detailed look at land­fill gas, see the Primer on Land­fill Gas as “Green” Ener­gy.

Co-firing:

Take almost any of the above bio­mass wastes/fuels and mix them with any oth­er fuel (coal, nat­ur­al gas, oil, or “bio­mass”) and you have co-fir­ing. Green ener­gy mar­keters have pro­posed pip­ing land­fill gas to nat­ur­al gas boil­ers in order to be able to sell the land­fill gas por­tion of the ener­gy. Oth­er exist­ing or pro­posed co-fir­ing projects involve burn­ing any of the fol­low­ing with coal or wood waste (though not as green ener­gy… yet): liquor solids, wood waste, nat­ur­al gas, fuel oil, paper sludge, med­ical waste and/or tires. The “renew­able” part of a co-fir­ing project would be allowed to be sold as Green‑e cer­ti­fied pow­er if they approve co-fir­ing. Co-fir­ing with coal could allow coal plants to reduce emis­sions of cri­te­ria air pol­lu­tants (though their tox­ic emis­sion would like­ly increase, depend­ing on the co-fir­ing mate­r­i­al), allow­ing them to avoid hav­ing to shut down or install bad­ly need­ed air pol­lu­tion con­trols. To date, con­cerns over how co-fir­ing might be used to extend the life of coal burn­ing pow­er plants have kept the Green Pow­er Board from approv­ing co-firing.

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FOOTNOTES:

Note: Links to exter­nal web­sites list­ed below are often fol­lowed by a “local copy.” These links are pro­vid­ed in the event that the con­tent on the exter­nal web­sites is changed, moved or oth­er­wise unavailable.

1. After get­ting kicked out of four poor, minor­i­ty com­mu­ni­ties in north­ern Delaware state in 1999, Philpow­er Cor­po­ra­tion is cur­rent­ly (3/2000) seek­ing to locate in a white sub­urb in the same coun­ty, and is fac­ing stiff opposition.
2. Philpow­er Cor­po­ra­tion Pub­lic Meeting/Hearing in Delaware, June 23rd, 1999.
3. Bioen­er­gy Glos­sary pro­vid­ed by the Nation­al Renew­able Ener­gy Lab­o­ra­to­ry. http://rredc.nrel.gov/biomass/states/bio_glossary/glossary.html
4. Nation­al Asso­ci­a­tion of Attor­neys Gen­er­al “Envi­ron­men­tal Mar­ket­ing Guide­lines for Elec­tric­i­ty” Pre­lim­i­nary Draft, May 24, 1999 http://www.penweb.org/energy/naag-guidelines.html#3b

5. Ibid. http://www.penweb.org/energy/naag-guidelines.html#4a
6. Green‑e web­site, “Help­ful Def­i­n­i­tions” http://www.green‑e.org/what/defs.html
7. Low Impact Hydropow­er Insti­tute http://www.lowimpacthydro.org/
8. Nat­ur­al gas includes many con­t­a­m­i­nants such as organometal­lic com­pounds and radon. Com­bus­tion releas­es many tox­ic met­als includ­ing lead and mer­cury as well as dozens of Haz­ardous Air Pol­lu­tants. Nat­ur­al gas lines can also be con­t­a­m­i­nat­ed with PCBs. See http://www.penweb.org/users/palm/air.html and http://www.penweb.org/users/palm/links.html
9. Pres­i­den­tial Exec­u­tive Order 13134, Devel­op­ing and Pro­mot­ing Biobased Prod­ucts and Bioen­er­gy, August 12, 1999. http://www.pub.whitehouse.gov/uri-res/I2R?urn:pdi://oma.eop.gov.us/1999/8/13/4.text.2

10. House Bill 1180 (Tick­et to Work and Work Incen­tives Improve­ment Act of 1999) passed on 12/17/1999, becom­ing Pub­lic Law No: 106–170. This bill extends the sec­tion 45 IRS renew­able ener­gy tax cred­it for wind, closed-loop bio­mass and poul­try waste to facil­i­ties placed in ser­vice by 1/1/2002. Also, House Bill 1906 (Agri­cul­ture, Rur­al Devel­op­ment, Food and Drug Admin­is­tra­tion, and Relat­ed Agen­cies Appro­pri­a­tions Act, 2000) passed on 10/22/1999, becom­ing Pub­lic Law No: 106–78. This bill pro­vides research dol­lars for 6 ener­gy crop projects. Sen­ate Bill 1792 (the Tax Relief Exten­sion Act of 1999) passed the Sen­ate on 10/29/1999. This bill would extend the sec­tion 45 IRS renew­able ener­gy tax cred­it to a wide range of bio­mass tech­nolo­gies for facil­i­ties placed in ser­vice by 1/1/2001.
11. Ratepay­ers for Afford­able Green Elec­tric­i­ty (RAGE) is a nation­al cam­paign run by Ralph Nader’s Crit­i­cal Mass Ener­gy Project. They are doing some excel­lent work in oppos­ing nuclear bailouts and oth­er hor­ri­ble effects of dereg­u­la­tion in the states. How­ev­er, in reac­tion to many awful nation­al dereg­u­la­tion bills, they have spon­sored their own bet­ter ver­sion. While the bet­ter ver­sion includes Renew­able Port­fo­lio Stan­dards (mak­ing sure that ALL util­i­ties must have a cer­tain amount of renew­ables in their mix), it allows all forms of bio­mass short of munic­i­pal sol­id waste or black liquor incin­er­a­tion to be includ­ed in the def­i­n­i­tion of renew­ables. A copy of their bill (H.R. 2645) can be found at: http://www.penweb.org/energy/hr2645.html RAGE’s web­site can be found at http://www.citizen.org/cmep/RAGE/
12. The U.S. Depart­ment of Ener­gy expects nation­al elec­tric­i­ty sales to rise by 2% in 2000, and anoth­er 1.6% in 2001. http://www.eia.doe.gov/emeu/steo/pub/h1tab.html
13. Green‑e web­site, “Help­ful Def­i­n­i­tions — Bio­mass” http://www.green‑e.org/what/biomass.html
14. Oper­at­ing Biopow­er Capac­i­ty (1999), by Fuel Type, World Elec­tric Pow­er Plants Data­base, Util­i­ty Data Insti­tute / McGraw-Hill Com­pa­nies, June 1999. The extend­ed Mid-Atlantic area includes Vir­ginia, Mary­land, Delaware, New Jer­sey, Penn­syl­va­nia and New York.
15. “The Sludge Hits the Fan,” Chap­ter 8 in “Tox­ic Sludge is Good for You — Lies, Damned Lies and the Pub­lic Rela­tions Indus­try” by John Stauber and Shel­don Ramp­ton. Avail­able on the web at http://www.ejnet.org/sludge/

16. U.S. Envi­ron­men­tal Pro­tec­tion Agen­cy’s Tox­ic Release Inven­to­ry (TRI) data­base can be used to track a small por­tion of the tox­ic chem­i­cals dumped down the drain by indus­try. This data­base can be searched at http://www.rtk.net/triinputtransfer.html See http://www.ejnet.org/sludge/ for tips on how to use it effectively.
17. “Nuclear Reg­u­la­tion: Action Need­ed to Con­trol Radioac­tive Con­t­a­m­i­na­tion at Sewage Treat­ment Plants,” U.S. Gen­er­al Account­ing Office, Let­ter Report, 05/18/1994, GAO/RCED-94–133). http://www.ejnet.org/sludge/radioactivity/gao_radsludge.txt
18. Tri­closan is a chlorophe­nol chem­i­cal with sim­i­lar struc­ture to diox­in. It is a pes­ti­cide that is reg­is­tered with EPA as such. For more infor­ma­tion, see http://www.lindachae.com/triclosan.htm or search through the diox­in list archives (par­tic­u­lar­ly in 1998) at http://lists.essential.org/dioxin‑l/
19. “Drugs In The Water,” Rachel’s Envi­ron­ment & Health Week­ly #614, Sep­tem­ber 03, 1998. http://www.rachel.org/bulletin/bulletin.cfm?Issue_ID=501&bulletin_ID=48

20. “Study Finds Cor­re­la­tion Between Flu­o­rides in Water and Lead Lev­els,” Dart­mouth News Press Release, August 31, 1999. http://www.actionpa.org/fluoride/lead.html
21. Note 13 supra.
22. Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee meet­ing, Feb­ru­ary 25, 2000.
23. Green­peace, “Tire incin­er­a­tion and Tox­ic Emis­sions: New data from the Modesto Incin­er­a­tor, West­ley, CA.”
24. Lone Star Chap­ter Sier­ra Club, “Com­ments on Res­o­lu­tion 97–425 to Autho­rize Tire-Derived Fuel Use in Cement Kilns and Util­i­ty Boil­ers for Ener­gy Recov­ery,” sub­mit­ted to Cal­i­for­nia Inte­grat­ed Man­age­ment Board, Octo­ber 22, 1997. The com­ments showed there to be increas­es in the fol­low­ing pol­lu­tants emit­ted from co-fir­ing whole tires with coal vs. burn­ing only coal: NOx, SO2, CO, par­tic­u­late mat­ter, chlo­rine, ben­zene, diox­ins, PAHs, chromi­um VI, cop­per, lead, mer­cury, and zinc.
25. “Sum­ma­ry of the First Annu­al Bio­mass Resource Assess­ment Review Task V,” August 24th, 1995. http://rredc.nrel.gov/biomass/portland.html At the end of this meet­ing report, they list­ed research pri­or­i­ties, in which burn­ing tires was list­ed as a low research pri­or­i­ty which did­n’t receive any votes, but which is “impor­tant and should not be over­looked entirely.”
26. Note 22 supra.
27. Feld­man, Jay, M.A. and Ter­ry Shis­tar, Ph.D., “Poi­son Poles — A Report About Their Tox­ic Trail and Safer Alter­na­tives,” Nation­al Coali­tion Against the Mis­use of Pes­ti­cides, 1997. http://www.ncamp.org/poisonpoles/

28. A com­pi­la­tion of sci­en­tif­ic stud­ies on met­als serv­ing as cat­a­lysts for diox­in for­ma­tion can be found here: http://www.ejnet.org/dioxin/catalysts.html
29. Karakash, John, CRSS Viking Oper­a­tions Inc., let­ter to Richard Maxwell, PA Depart­ment of Envi­ron­men­tal Resources Air Qual­i­ty Man­age­ment Divi­sion, March 22, 1993. This let­ter states that a wood waste sup­pli­er to the Viking wood waste incin­er­a­tor in Northum­ber­land Coun­ty, Penn­syl­va­nia is “unable to com­plete­ly iso­late all vinyl-coat­ed mate­r­i­al.” The PA DEP has allowed both of the main sup­pli­ers to this wood waste burn­er to sup­ply wood waste with an aver­age .04% chlo­rine con­tent (16 pounds per 20 tons of waste).
30. The fact that ESPs mag­ni­fy diox­in emis­sions has been doc­u­ment­ed in Waste Not issues #45, 262, 275 and 309. Excerpts from these issues and links to some of them can be found online at http://www.ejnet.org/dioxin/esp.html
31. Maxwell, Richard, PA Depart­ment of Envi­ron­men­tal Resources, note to John Karakash, CRSS Viking Oper­a­tions Inc., 9/15/1994.
32. Maxwell, Richard, PA Depart­ment of Envi­ron­men­tal Pro­tec­tion, let­ter to Steve Hen­ry, Viking Ener­gy of Northum­ber­land, “re: Oily Water Waste,” 8/1/1998.
33. Illig, Richard, PA Depart­ment of Envi­ron­men­tal Pro­tec­tion Resid­ual Waste Coor­di­na­tor, Inter­nal Mem­o­ran­dum “re: MMI at Viking Ener­gy of Northum­ber­land Sep­tem­ber 26th, 1995,” 10/5/1995. This memo states: “Cur­rent­ly, Viking is exper­i­ment­ing with the burn­ing of oth­er mate­ri­als at their Michi­gan facil­i­ty. Some of the alter­nate fuels con­sid­ered include cre­osote wood and tires among oth­er mate­ri­als. The Northum­ber­land facil­i­ty is also encour­aged to con­sid­er the use of wastes as alter­nate fuels.”
34. Penn­syl­va­ni­a’s Waste Tire Recy­cling Act encour­ages the burn­ing of tires. See the PA Depart­ment of Envi­ron­men­tal Pro­tec­tion web­site for details: http://www.dep.state.pa.us/dep/deputate/airwaste/wm/MRW/Tires/Tires.htm
35. Har­ri­son, Vic­ki, “Super­vi­sors: Burn­ing issue may require expert opin­ion,” The Dai­ly Item, A1, August 20, 1998.

36. Note 22 supra.
37. Ibid.
38. House Bill 1180, “The Tick­et to Work and Work Incen­tives Improve­ment Act of 1999” became Pub­lic Law No. 106–170 when passed on 12/17/1999.
39. Howe, Patrick, “Chick­en Manure Pow­er Tax Break Has Sen­a­tors Cluck­ing,” Chat­tanooga Times/Chattanooga Free Press, July 31, 1999.
    
40. Elliott, Bri­an, Ener­gy Pro­gram Orga­niz­er, Clean Water Action Alliance, “Pow­er Plant Air Emis­sions Com­par­i­son,” Feb­ru­ary 23, 2000. This is a com­par­i­son of Fibrowatts’ FibroTh­et­ford facil­i­ty in the UK to the Ser­burne Coun­ty, Min­neso­ta coal-fired pow­er plant (Sher­co) oper­at­ed by North­ern States Pow­er. In this com­par­i­son, NOx and mer­cury emis­sions are about the same as coal, SO2 is near­ly as high as coal, par­tic­u­late mat­ter is much low­er than coal, hydrochlo­ric acid, man­ganese and anti­mo­ny are much high­er than coal.
    
41. Alter­na­tive Resources Incor­po­rat­ed, A Review of the Air Emis­sions from a Fibrowatt 50-MW Pow­er Plant Fueled with Poul­try Lit­ter, Pre­pared for Fibrowatt, LLC, Feb, 2000. This report shows that NOx and car­bon monox­ide emis­sions from Fibrowat­t’s pro­posed turkey lit­ter incin­er­a­tor in Min­neso­ta would be a lit­tle high­er than coal plant emis­sions. It also shows that acid gas­es (sulfer diox­ide and hydro­gen chlo­ride) and par­tic­u­late mat­ter (PM10) would be about the same as coal plant emis­sions.
    
42. Ibid. Fibrowatt makes these argu­ments for the glob­al warm­ing gas­es as well as for the tox­ic met­als which they say would be “recy­cled” back into the envi­ron­ment.
    
43. Kel­lam, Aaron, “Delaware res­i­dents raise stink over plant,” Newszap, 9/12/1999. http://www.newszap.com/stories/091299c.html

44. Muller, Alan, Green Delaware, Let­ter to Liz Robin­son, Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee “Regard­ing: Use of ‘Green‑e’ to pro­mote incin­er­a­tion in Delaware and else­where,” Feb­ru­ary 24, 2000.
    
45. Mills, Robin, Mary­land Safe Ener­gy Coali­tion, state­ments at Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee meet­ing Feb­ru­ary 24, 2000.
    
46. Nel­son, Jes­si­ca, Insti­tute of Local Self Reliance, “Poul­try manure leg­is­la­tion is putting ener­gy needs eggs in wrong bas­ket,” Pio­neer Plan­et, 3/10/2000. http://www.pioneerplanet.com/opinion/ocl_docs/027009.htm
    
47. Nel­son, Jes­si­ca, “Should Min­nesotans Sub­si­dize the Burn­ing of Poul­try Manure? — A Fact Sheet,” Insti­tute for Local Self-Reliance.
    
48. Nation­al Renew­able Ener­gy Lab­o­ra­to­ry, “Bio­mass — Nature’s Renew­able Store­house of Solar Ener­gy and Chem­i­cal Resources.” http://www.nrel.gov/research/industrial_tech/biomass.html
    
49. House Bill 2827 / Sen­ate Bill 935, the Nation­al Sus­tain­able Fuels and Chem­i­cals Act of 1999, would autho­rize $49 million/year in research mon­ey from 2000–2005 for a wide range of bio­mass and biobased indus­tri­al products.
    
50. Tick­ell. Oliv­er, and Charles Clover, “Trees that nev­er flower her­ald a silent spring,” Dai­ly Tele­graph, Lon­don, July 17, 1999. http://www.purefood.org/Monsanto/frankentrees.cfm

51. Reins­bor­ough, Patrick, Rain­for­est Action Net­work, “An After­word On The Link Between Genet­i­cal­ly Engi­neered Forestry And The Great Kyoto Cli­mate Scam” com­ments on Dai­ly Tele­graph arti­cle “Trees that nev­er flower her­ald a silent spring” in com­mu­ni­ca­tion titled “Why are oil com­pa­nies genet­i­cal­ly engi­neer­ing trees?” http://www.earthsystems.org/list/seac-announce/1999/1507.html
    
52. “Genet­ic Engi­neer­ing Of Poplars In The Pacif­ic North­west,” Nation­al Bio­log­i­cal Impact Assess­ment Newslet­ter, Novem­ber 1995. http://www.fsl.orst.edu/tgerc/overvw.htm
    
53. Mid-Atlantic Bio­mass sub­com­mit­tee meet­ing on 2/24/2000 passed a rec­om­men­da­tion to require organ­ic cer­ti­fi­ca­tion. This rec­om­men­da­tion was dis­missed by the Mid-Atlantic Green‑e Advi­so­ry Com­mit­tee on 2/25/2000 and envi­ron­men­tal­ists only man­aged to obtain an exclu­sion on GMOs as fuel crops.
    
54. These issues were raised by Arthur Clark in his com­ments titled “Rec­om­men­da­tions to the Green‑e Mid-Atlantic Advi­so­ry Com­mit­tee on Bio­mass Ener­gy Sources,” sub­mit­ted Decem­ber 8, 1999.
    
55. Fiel­er, Jeff, Cli­mate Pol­i­cy Spe­cial­ist, Nat­ur­al Resources Defense Coun­cil (NRDC), Tes­ti­mo­ny before U.S. Sen­ate Com­mit­tee on Agri­cul­ture, Nutri­tion, and Forestry Hear­ing on The Nation­al Sus­tain­able Fuels and Chem­i­cals Act of 1999. http://www.senate.gov/~agriculture/Hearings/Hearings_1999/fie99527.htm
    
56. Com­mu­ni­ca­tions with Den­ny Halde­man, Dog­wood Alliance.
    
57. Note 54 supra.

58. J.W. Konig, Jr. and K.E. Skog. 1987. Use of Wood Ener­gy in the Unit­ed States–an Oppor­tu­ni­ty. Bio­mass 12:27–36.
    
59. Note 54 supra.
    
60. Phil Lusk, Resource Devel­op­ment Asso­ciates, Pre­sen­ta­tion on Anaer­o­bic Diges­tion at Green‑e Bio­mass Work­shop, 12/1/1999. Clar­i­fied in con­ver­sa­tion with Mr. Lusk on 3/17/2000.
    
61. “Growth of the Land­fill Gas Indus­try,” Chap­ter 10 of the “Renew­able Ener­gy Annu­al 1996” report by the U.S. Depart­ment of Ener­gy’s Ener­gy Infor­ma­tion Admin­is­tra­tion. Avail­able online at http://www.eia.doe.gov/cneaf/solar.renewables/renewable.energy.annual/chap10.html
    
62. “Air Emis­sions from Munic­i­pal Sol­id Waste Land­fills — Back­ground Infor­ma­tion for Pro­posed Stan­dards and Guide­lines” Doc­u­ment # is EPA/450/3–90/011A. March 1991, 544 pages.
    
63. These sug­ges­tions were made by pan­elists at the Envi­ron­men­tal Pro­tec­tion Agency Land­fill Methane Out­reach Pro­gram (LMOP) Con­fer­ence Jan­u­ary 10–11th, 2000. Pro­ceed­ings avail­able online at: http://www.epa.gov/lmop/confer2000.htm
    
64. Ibid. At the Jan­u­ary 2000 EPA LMOP con­fer­ence in Wash­ing­ton, D.C., the con­fer­ence atten­dees were encour­aged to join the Sol­id Waste Asso­ci­a­tion of North Amer­i­ca’s lob­by­ing day for the land­fill gas tax cred­it legislation.