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A couple of weeks ago my Dad sent me an interesting article via e-mail about a law that we will apparently get to vote on in Massachusetts. It caused me to do a lot of thinking about if the law is good or not, and who would be in favor of such a law. Here’s the article, I can not find it on the net to attribute it:

Massachusetts Evaluates Carbon Neutrality of Biomass

WASHINGTON – The carbon-neutrality of biomass is up for debate in Massachusetts at both the regulatory and legislative level, with a study, ballot initiative and legislation in the spotlight. For [company] and the forest products industry, it is critical for biomass to be considered carbon-neutral because our facilities use an average of 60 percent biomass to power our operations. [company] is a leader by using 73 percent biomass to run our U.S. mills, and we support the science that when biomass, such as wood, is combusted for energy, it releases back into the atmosphere carbon dioxide that it absorbed from the atmosphere during growth. When harvested biomass is replanted, the cycle repeats. In contrast, fossil fuel is not carbon neutral. The combustion of natural gas, coal and petroleum fuels results in a net increase of carbon dioxide in the atmosphere since this carbon dioxide was never originally absorbed from the atmosphere and there is no balancing cycle to remove it. Failure to recognize the carbon neutrality of biomass could lead to unintended negative consequences such as increasing fossil fuel use and greenhouse gas emissions, reducing forest land, creating substantial uncertainty and deterring growth of renewable energy, as well as driving jobs away from the U.S. and toward jurisdictions that recognize biomass carbon neutrality.

Biomass Study
The Massachusetts Division of Energy Resources (DOER) has begun a six-month study to examine the carbon neutrality of biomass and biomass sustainability. The Commonwealth has suspended consideration of all applications for biomass facilities under the state’s Renewable Portfolio Standard pending the outcome of the study. It is expected that the study results will be used to inform new regulations addressing biomass facilities and may be precedent-setting elsewhere. The American Forest & Paper Association (AF&PA) attended the public meeting on the study last month and submitted written comments. [company] and AF&PA will continue to be engaged moving forward.

Ballot Initiative
The “Stop Spewing Carbon Campaign” has gathered the required amount of signatures necessary to move forward with a proposed ballot law that would require biomass energy sources to emit no more than 250 pounds of carbon dioxide per megawatt hour to be considered renewable. The proposal would not take offsets into account and would rely solely on smokestack emissions. The initiative, which must be approved by the legislature by the first Wednesday in May, is expected to appear on the November 2010 ballot. AF&PA is working with other organizations that are also opposed to the initiative to discuss formation of a formal opposition campaign.

Related Legislation
Legislation that would prohibit the burning of construction and demolition waste and treated wood in biomass facilities has been pending in the Massachusetts legislature for approximately one year and had previously received minimal attention. After the political and media attention given to the study and ballot initiative, interest in the legislation grew. At a December hearing, a number of environmental groups testified and expanded the conversation to biomass facilities in general. AF&PA is closely monitoring the bill to ensure it is not expanded to an outright ban

These are my Dad’s comments that accompanied the article:

It is an interesting political debate, but I would think the science is well known. I would think that if you burn it, you make CO2. Of course, the paper itself ties up carbon, as long as it is not eventually burned. Fossil fuels are just as carbon neutral as wood – They just took a lot
longer to “repeat” the cycle.

In any event, in Massachusetts, they will actually ask the voters to decide…. Weird !!

Here is my analytical response about the nature of the law and possible laws in this area:

Certainly, in the long run, the amount of carbon and oxygen on the planet remains the same with the exception of fusion, fission, meteors, and material carried by the solar wind. In this sense, we are always carbon neutral. This is the same sense by which it is easy to say fossil fuels are as carbon neutral as wood because they are produced via a cycle.

Now, the carbon neutral everyone else is talking about has to do with where the carbon is stored and in what molecules. Specifically the ratio of C02 (and CH4) in the atmosphere to the carbon stored in biomass, fossil fuels, and other stored resources. In this arena carbon neutrality is all about rates. The rate at which we release carbon from stored resources into the air, and the rate at which stored resources take up carbon from the air.

Fossil fuels take carbon from the air at an incredibly slow rate. First requiring that animals or plants bleed it from the air and then requiring they decompose for a long time. It is because of this slow rate that almost any fossil fuel burning is considered non-neutral. Trees, of course, take up carbon from the air at some, much larger rate, and so stand a much easier chance of being carbon neutral. It appears that ballot initiatives is targeting this exact sort of definition of carbon neutral. Specifically it requires “biomass energy sources to emit no more than 250 pounds of carbon dioxide per megawatt hour to be considered renewable.” This defines a rate at which carbon may be burned for it to be considered renewable. It is a convoluted rate calculation, one that is not expressed in units comparable to carbon intake by trees per unit, but one that fundamentally can be converted and compared.

There does exist a scientific question, the answer to which is also the answer to whether or not this is a good law. That question is, at what rate does biomass pull carbon from the atmosphere, and is that higher or lower than the purposed rate in the law? The law should stipulate a burning limit rate that is exactly equal to the rate at which biomass removes carbon from the atmosphere. To set a rate too high or too low would injure some party without cause. This rate may very based on the type or source of the biomass, perhaps widely, perhaps not. If it varies wildly by type then the law should take different sources and their rates into account, breaking out burning limits by source type. Such a law would correctly include the fundamental scientific nature of atmospheric carbon neutrality, which seems like a reasonable thing to do. Its already a scientific law anyways.

Of course, if the burn limit lower than what [company] burns, then [company] will have to substitute another energy source to make up the difference or it can pay the fines that I’m sure will be the penalty in the law. This is an economic choice, but not one that should be avoided. It would be up to [company] and its competitors to individually choose alternatives that minimized cost. Now, if the proper carbon externality cost is not applied to all sources of carbon, this can create perverse incentives that actually increase pollution. That is why all non-neutral carbon should be taxed at the same rate. Externality taxes (and their functional equivalents) to counteract pollution must treat all sources of pollution in the same way in order to avoid costly perverse incentives.

The fines this law would impose on non-neutral biomass combustion constitute a tax and would need to be set at the same levels as equivalent carbon taxes on other carbon sources. Therefore, this is also a requirement that must be satisfied for this to be a good law. Given that fossil fuels are not carbon taxed in Massachusetts it seems unlikely that this law will meet this standard, unless they also pass fossil fuel carbon tax equivalents at the same time.

As to the paper containing carbon, it is the person who choses to burn it that should pay the tax on the carbon produced by doing so. As stated, the only neutrality we care about is in the atmosphere vs. not. [company] putting carbon in paper should not result in a tax payment. It should result in a carbon tax credit if that carbon (the whole process in general) were to, in some way, result in a net drop of carbon from the atmosphere.

If fact, if one were to credit trees owned by a person for reducing carbon, and tax all carbon put into the atmosphere it should be equivalent to the properly calibrated law that induces taxes only above
the limit at which burning becomes non-neutral. That is, it is equivalent to the government in terms of net tax collected. It may change who pays the tax and who gets the credit. But [company], owning lots of trees, would surly fair the similarly under both systems.

However, I failed to understand until my father responded that his company would be in favor of the law. I had clearly assumed above that they were opposed due to the taxes they may incur if they burned too much. Here is his response:

I would go with your definition, but suspect that is not the one that will be used.

I’m not sure what it takes for “biomass energy sources to emit no more than 250 pounds of carbon dioxide per megawatt hour to be considered renewable” but it takes at least 15 years to grow a tree, and only a few minutes to burn it, so I cannot see how that can be carbon-neutral.

Certainly [company] would benefit greatly from defining biomass as carbon-neutral. We currently generate over 75% of our energy from biomass. I’m sure we could easily move that to 100%. If the price were right, we could exceed 100% [& sell power to the grid]. The problem I have with this is the definition of biomass as carbon-neutral. Burning wood &/or other biomass &/or ethanol or other petro-like products created from biomass actually contribute to exactly the same problem. We need to find cleaner solutions.

I had failed to understand the scope of the badness of the law. I had assumed above that the units did actually work out properly. This time I set out to discover if that was indeed the case:

Lets look at the “biomass energy sources to emit no more than 250 pounds of carbon dioxide per megawatt hour to be considered renewable” part. Lets consider only one adult tree of mass 850kg (when burned) that will be burned under this regime, and we want the burning to result in zero net co2 creation after considering the absorbed co2 during the life of the tree.

250 lb co2/megawatt hour = 0.315×10-7 kg co2/Joule

( http://bioenergy.ornl.gov/papers/misc/energy_conv.html) wood provides 15 GJ/1000kg = 15×10^6J/kg wood (ignoring energy spent in drying, lets say solar does this for us)

Combining we get: .4724920521 kg co2/kg wood

therefore any wood that we burn will have to produce co2 at a rate equal to or less than that per kg to be renewable. Now, how long will it take a tree to absorb that much co2 per kilogram.

a tree absorbs co2 at a rate of 48lb co2/year (http://www.coloradotrees.org/benefits.htm) which is 6.899×10-7 kg/s

it will therefore take a tree 684870 seconds (190.2 hours, 7.9 days) to absorb the co2 that is released by burning 1 kg of it. Therefore out 850kg tree would need to live for 6737.7 days (or about 18.459 years) before it was burned in order for burning it to be renewable.

A more complex calculation can clearly be done involving a varying rate of co2 absorption based on growth, and more exact figures for specific kinds of trees. This type of calculation could produce a graph showing when it would be renewable to burn the tree.

Anyways, that is how the rate comparison pans out I think. I expected that [company] would be opposed to this law. Since they use so much biomass to generate so much power it would be quite bad for them if it turned out that they burned at a non-renewable rate, as defined by the 250 lb co2/megawatt hour.

But yes, I think I see your point. As shown by that rate calculation above this 250 number implies a certain amount of time that our tree needed to be alive, in order for it to be neutral. The law as described imposes no such restrictions on the age of the tree burned, and therefore it has zero bearing on if the burning that takes place is actually neutral or not.

I now understand why [company] would favor this law. When I first responded I assumed [company] would not favor the law, because as we both agree, the burning that they do could easily be non-neural in reality, and clearly I fixated on encoding reality in to law. This law, as described, since it does not include a time factor, violates an assumption I made in my 4th paragraph above. I had assumed that the rates were comparable, equivalent in units, but they are not.

So, fundamentally flawed law has no basis in reality really. Except that as my dad says ~15 years is about how long they usually let the trees grow for other reasons and so as he says:

That is actually a lot closer to carbon-neutral than I had imagined it would be. I wonder who figured out the 250 lb co2 / megawatt hour limit? Maybe they knew something.