Local Groups Oppose Biomass in Renewable Energy Resolution

May 26, 2017
Re: Request for Changes in Renewable Resolution

Dear Chair Kafoury and Commissioners Smith, Vega Pederson, Meieran, and Stegmann,

Thank you for the hard work done this far to shape a #100by50 Renewable Energy Resolution.

We, the undersigned, support the strong progress made so far but believe Multnomah County can do better. Specifically, we request that you amend the resolution prior to June 1 to incorporate our recommended changes to the County’s Renewable Energy Resolution.

The County should not assume that biomass is a clean, carbon neutral, and renewable source of energy. In 2014, the U.S. Environmental Protection Agency (EPA) found that “carbon neutrality cannot be assumed for all biomass energy a priori.” As data from EPA show,[1] even modern facilities burning wood and other biomass emit as much or more CO2, particulate matter,[2] and smog precursors per unit energy as modern fossil fueled plants, including coal plants. A number of studies[3] – some conducted here in Oregon – show that burning wood for energy results in persistent net CO2 emissions to the atmosphere and that re-sequestering the carbon emitted requires several decades to more than a century. In short, nothing that incentivizes putting carbon into the atmosphere should be considered renewable energy. We need to stop adding carbon to the atmosphere.

A renewable energy solution should not endanger forests by replacing carbon from fossil fuels with carbon from biomass. In 2010, a group of prominent scientists wrote to the U.S. Congress explaining that the notion that biomass results in a 100% reduction of carbon emissions is wrong. Biomass can reduce carbon dioxide if it is sourced from fast growing crops grown on otherwise unproductive land; in this specific case, the regrowth of the plants offsets the carbon produced by the combustion of the crops.

However, forests are presently the largest source of fuel for projects defined as biomass. While some assert that biomass is carbon neutral because trees will “grow back”, these proponents are quick to forget that a forest’s natural cycle of decomposition and regrowth takes many decades to over a century whereas combustion of biomass emits tremendous amounts of carbon instantaneously. Forests logged next year for biomass will be net emitters of CO2 for up to 50 years, and will need another 50 years at least before full ecological restoration is achieved. Carbon sequestered in 2117 does little to reduce atmospheric carbon today and the conversion of forests which generate clean drinking water and stabilize regional climates, into carbon dioxide and particulate air pollution does little good for local communities.

Please note that contrary to industry depictions, the high volume of feedstock needed to power an industrial biomass facility would only be available through industrial scale harvesting and burning of whole trees from large swaths of forest. In Paul Hawken’s recent book Drawdown[4], he states that in “Washington, Vermont, Massachusetts, Wisconsin, and New York, the amount of slash generated by logging operations falls far short of the amount needed to feed the proposed biomass burners. In Ohio and North Carolina, utilities have been more forthright and admit that biomass electricity generation means cutting and burning trees”. Timber harvesting in Oregon is already the number one source of greenhouse gas emissions in the state (figure below). Vast, short rotation timber plantations are the culprit – plantation management quickly releases any carbon stored into the atmosphere and leaves huge swaths of the landscape in open clearcut condition. On these recently clearcut lands, sequestration capacity is forgone, and for more than a decade after harvest the decay of slash and dead vegetation releases more carbon than is sequestered by new seedlings. Adding biomass to the mix will only exacerbate the situation by further reducing rotations and leaving more land in an open, carbon emitting condition.

1Talberth, John. 2017. Oregon Forest Carbon Policy Technical Brief. Lake Oswego, OR: Center for Sustainable Economy

Additionally, please acknowledge that any biomass facility located in Oregon would necessarily prioritize local industrial timber because crop sources (corn, sorghum, etc.) would need to be procured from distant parts of the country. Shipping of these crop based feedstocks would increase the overall cost and emissions associated with the operation of the facility.

Furthermore, because increasing the rate of forest carbon sequestration is essential for controlling, and decreasing, atmospheric CO2 levels, the County should actively safe-guard living, carbon-storing forest ecosystems in its Renewable Energy Resolution. Climate modeling conducted for the Intergovernmental Panel on Climate Change has determined that we need to not only reduce emissions, but actually take CO2 out of the air – that is, achieve negative emissions – to have a hope of controlling dangerous temperature rise.[5] The nation’s top carbon sequestering National Forests are located in the Pacific Northwest, an incredible asset in combating global climate change and stabilizing the regional environment. The carbon stored in these forests and their capacity to mitigate the local impacts of climate change should not be jeopardized by biomass projects.

The undersigned organizations accordingly request the following changes in reference to biomass.
Please change the current draft language from:

t.        “Renewable energy” specifically excludes energy derived from fossil fuels, nuclear, biomass that does not minimize impacts to human and ecological health, and incineration of municipal and medical waste;
To read: 
new line t.   “Renewable energy” specifically excludes energy derived from fossil fuels, nuclear, biomass, and incineration of municipal and medical waste;
The current draft language has enormous room for manipulation by profit-driven industries who may assert that they have “minimized” adverse impacts to human and ecological health. But without specific metrics by which to assess the ecological impact of the sourced feedstock, this clause is essentially unenforceable.  
If you believe that the County has compelling and scientifically evidenced reasons to include burning biomass in its suite of “renewable energies” and will not exclude it altogether, we recommend that the draft language include a provision that prohibits the use of biomass sourced from public lands (both state and federal) as they provide most of the healthy forest habitat, and important carbon stores, in the State of Oregon. In this case, such a resolution would read:   
t.     “Renewable energy” specifically excludes energy derived from fossil fuels, nuclear, biomass feedstocks sourced from public lands, and incineration of municipal and medical waste;   
To ensure that biomass sourced from private lands also is subject to some level of ecological scrutiny, we additionally request that you replace the original language of u. with:
u.      Forest biomass energy projects require special consideration6 to ensure that ecosystem health is not harmed, that the project does not result in increased life-cycle carbon emissions, and that air quality and fish habitat is not degraded;
 6 Please provide clarification of who will provide the ‘special consideration’ and what it entails as far as monitoring the source of the feedstock.

An additional request is as follows:  
The undersigned also petition to add the following clause to the County Renewable Resolution.
aa.  Energy conservation is critical to reducing fossil fuel demand and green infrastructure such as urban tree canopy, green streets, green roofs and other natural resource focused strategies are effective strategies to reduce energy consumption, urban heat island impacts and address disparities in the impacts of climate change on vulnerable communities.   And add this item under “The Multnomah County Board of Commissioners Resolves”:  That the County commits to expanding green infrastructure strategies to reduce energy demand, reduce urban heat island effects and limit the impacts of climate change in vulnerable communities.

Thank you for consideration of our request,

Bob Sallinger, Conservation Director, Portland Audubon Society
Dominick Dellasala, Chief Scientist, Geos Institute
Dr. John Talberth, President and Senior Ecologist, The Center for Sustainable Economy
Courtney Rae, Community Organizer, Bark
Regna Merritt, Healthy Climate Program Director, Oregon Physicians for Social Responsibility
Michael O’Leary, National Wildlife Federation
Bob Rees, Executive Director, Association of Northwest Steelheaders
Steve Pedery, Conservation Director, Oregon Wild
Mia Reback, Staff Organizer, 350PDX
Rhett Lawrence, Conservation Director, Oregon Sierra Club
Bonnie McKinlay, Representing the Climate Action Coalition






[1] See EPA’s “eGRID” database for information on air pollution and CO2 emissions from power plants in the United States. https://www.epa.gov/energy/emissions-generation-resource-integrated-data...

[3] See for example, Mitchell, S. R., M. E. Harmon and K. E. B. O'Connell (2012). "Carbon debt and carbon sequestration parity in forest bioenergy production." GCB Bioenergy 4(6): 818-827; Repo, A., J.-P. Tuovinen and J. Liski (2015). "Can we produce carbon and climate neutral forest bioenergy?" GCB Bioenergy 7(2): 253-262; Domke, G. M., D. R. Becker, A. W. D’Amato, A. R. Ek and C. W. Woodall (2012). "Carbon emissions associated with the procurement and utilization of forest harvest residues for energy, northern Minnesota, USA." Biomass and Bioenergy 36: 141-150; Clark, J., J. Sessions, O. Krankina and T. Maness (2011). Impacts of thinning on carbon stores in the PNW: a plot level analysis. Corvallis, OR, College of Forestry, Oregon State University.

[4] Hawken, Paul (ed), Drawdown, 2017, Penguin Publishing, New York. p 16

[5] See p. 10 of IPCC (2014). Climate Change 2014: Mitigation of Climate Change – Summary for Policymakers. Contribution of Working Group III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change. O. Edenhofer, et al. Cambridge, United Kingdom and New York, NY, USA.  At http://www.ipcc.ch/pdf/assessment-report/ar5/wg3/ipcc_wg3_ar5_summary-fo...

[6] Please provide clarification of who will provide the ‘special consideration’ and what it entails as far as monitoring the source of the feedstock.