I appreciate the opportunity Monday night to have briefly shared my perspective on the environmental impacts of biomass incineration with the BOE. It was at the urging of the "core group" (whom Mr. Lofton seems to disparage, below) that VBOE invited me and my coleague Dr. Bielmyer to speak. As an ecologist and VSU professor for more than 24 years, I’ve long been interested in issues of conservation, forest resources and sustainable development in south Georgia. About a year-and-a-half ago, I met with Mr. Ricketts, who kindly gave me and Mr. Seth Gunning a thorough presentation on the proposed biomass plant. Ever since then, I’ve been educating myself on the general issue of biomass power generation and specifically on the Wiregrass plant. I attended the April 2010 public hearing (as did Mr. Ricketts and Mr. Lofton) conducted by EPD, and I asked several questions. I also submitted several written questions and comments to EPD for the public record, as did many others. All of those questions, and EPD’s answers, and the complete application, and permit, can be seen here:
(After you open this link, type "Wiregrass" into the search box, then click on "Narrative"; the last 13 pages contain all the public comments and responses.)
I’m sure Mr. Lofton is a well-meaning and certainly a tireless advocate for new industry. That is his job. It is the rest of our jobs to determine what really is "fact" and "opinion." No matter how loudly one proclaims it, unsubstantiated assertions are not facts, and inconvenient facts are not misinformation. I will point out some of these facts, along with links to document them,
in blue font, interspersed among Mr. Lofton’s comments, below.
Strange that in 45 minutes Mr. Lofton could not even address the concerns that Dr. Bielmyer and I raised in each of our 5 minutes. The relevant facts, which are not in dispute, are that: 1) this plant will combust 600 tons per day of organic waste including some sewage sludge; 2) it will send out of its smokestack more than 200 tons per year each of carbon monoxide, nitrogen oxides, and sulfur dioxide (all of which are harmful to human health, according to the American Lung Association); 3) it will spew more than 60 tons of volatile organic compounds and 13 tons of hazardous air pollutants (such as benzene and formaldehyde); 4) it will send more than 100 tons of larger particulates and an unknown quantity of micro-particulates into the air; the latter are particularly harmful to people, especially children, with respiratory conditions. Does this not concern you?From: Brad Lofton [firstname.lastname@example.org]The Wiregrass project, specifically, has only been vetted by one branch of one state agency, that being the Air Quality Branch of Georgia EPD. No other "government groups" have had any direct role in approving or even examining the Wiregrass proposal, and "environmental groups" do no "set policy." That said, there is a long and growing list of environmental NGOs that is beginning to critcally examine biomass incineration. As I said in my brief remarks Monday night, even those groups that jumped on the biomass bandwagon early—like Sierra Club—are having serious second thoughts. That’s because more and more scientific studies are being completed, which point to the conclusion that biomass incineration is more polluting than coal and may even have a worse effect on global warming than coal. Here is just one letter to Congress demanding an end to tax subsidies for biomass burning from 71 environmental groups:
Sent: Tuesday, September 28, 2010 12:51 PM
To: Karen R. Noll, [VBOE members]
Cc: Allan Ricketts; Gretchen K. Bielmyer; Bradley J. Bergstrom
Subject: Re: Thank you to the Valdosta Board of Education
Good afternoon ladies and gentlemen:
We were honored last night to provide you an update on a project that enjoys so much support from environmental groups all across America, and we are thankful for your invitation and partnership. Mrs. Noll won’t admit that no governmental group or environmental group in this country that is charged with setting environmental policy is opposed to our project. Not one. In fact, they collectively point to biomass as the way forward for our country, where nearly 45 percent of our existing renewable energy portfolio is biomass.
Such other prominent environmental groups as the Center for Biological Diversity, Natural Resource Defense Council, Georgia ForestWatch, Clean Air Task Force, and Southern Environmental Law Center have issued serious caveats about the downsides of overemphasizing biomass in a "renewable energy portfolio"; here are some links to their position statements:
A very important study on biomass that came out in the past year, called the "Manomet Study" can be found here (it is a big part of the basis for the now evolving views of a lot of the environmental groups):
As a result of this study, the state government of Massachusetts this year decided to rescind renewable energy tax credits from biomass combustion plants, because they now realize that it is invalid to assume that biomass plants are carbon-neutral or necessarily compatible with sustainable forestry:We were prepared last night to go into specific details regarding the air permit and provide the actual facts for you as opposed to the continued misinformation you are receiving from this core group. We ran out of time and apologize for the length. Please let us know when and where we can have that discussion.
What’s more, the plant will not even be required to do continuous monitoring of some of the most dangerous substances, including mercury and dioxins (the most carcinogenic chemicals known to science and considered toxic at minute levels), nor of the more dangerous micro-particulates. So, we won’t even know for certain how much of this stuff has escaped into the atmosphere or rained out onto the ground and into our rivers.
Our plant will be carbon neutral, with a mercury level that is so low it’s considered statistically insignificant by EPD. There is a dramatic difference between what the state and federal law allows under a statutory air permit and what our plant actually produces. This group is stating the "permitted" allowances despite the fact that the actual emissions are a very small fraction of that. Again, if Mrs. Noll and any of her "experts" would actually meet with us, we would explain that.(See point #3 below about the "carbon neutral" claim). It is true that the "permitted" mercury emission limit is absurdly high (based on an antiquted regulation that EPA will soon be updating). But Mr. Lofton in other written correspondence has made this claim: "…the projected Mercury that will be emitted from this plant will be less than 0.136 pounds per year and is statistically insignificant. There will be no Mercury emitted from the 99% wood fuel." However, if you read page 14 of the actual Wiregrass Plant Application Review by EPD (see link above), it says:
"But to remain conservative, the emission rate of mercury from the facility is calculated from sewage sludge (2.3E-03 lb/hour) plus biomass (2.19E-03 lb/hour). The total is 4.5E-03 lb/hour. The annual total is then 1.9E-02 tpy. This is equivalent to 7.2E-06 lb/MMBtu, as compared to the Wiregrass emission rate of 2.33E-08 lb/MMBtu. Wiregrass will be required to meet this limit by carrying out a test."First, note that EPD calculates a nearly identical total emission of Hg from biomass (not zero) as from sludge, and calculates a total Hg emission of 0.019 tons, which is 38 lbs of mercury per year. So, EPD’s estimate of 38 pounds is 279 times the amount that Mr. Lofton claims, and about half of it (not none of it) is projected to come from biomass. Thirty-eight pounds of mercury is not "insignificant," and it is a far cry from Mr. Lofton’s claim.
Rest assured that this is a safe, green, renewable energy plant that has been vetted by scores of environmentalists, all the major universities in Georgia (including Dr. Tom Manning, a biomass researcher at VSU), and approved by every level of government. If Mrs. Noll has further concerns, I would recommend her talking to President Obama, the U.S. Dept of Agriculture, the U.S. Department of Energy, the Federal Environmental Protection Agency, the state EPD, the Sierra Club, the World Wildlife Federation, the state of Georgia’s Center of Innovation for Renewable Energy, GA Tech, UGA, the Valdosta Daily Times (who support us), and scores of others who support us.Where do I begin?
1) Dr. Manning is a VSU chemistry professor. Dr. Manning did not attend the public hearing on the Wiregrass plant, nor did he submit any comments during the public review. His "research page" on his website does not indicate "biomass" as a topic he is researching, and a citation search of thousands of scientific journals (i.e. all the peer-reviewed ones) for "manning" and "biomass" turns up zero publications by Tom Manning on biomass. Dr. Manning’s opinion is as valid as mine, and I’ve no doubt that supports the Wiregrass plant; it should be a productive collaboration that provides hands-on opportunities for his chemistry majors. But that is hardly the point.
2) The Sierra Club’s policy on biomass includes an insistence that it be done sustainably from private lands, an opposition to biomass sources from public forests, and an absolute and unequivocal opposition to the incineration of biosolids (sewage sludge) as will happen at the Wiregrass plant. Unlike Mr. Lofton, I will give an attribution to this claim for you to check out if you wish: contact the Sierra Club Georgia Chapter Chair, Mark Woodall <email@example.com>
3) The federal EPA issued its "Tailoring Rule" this May, in which it ruled that a complete carbon accounting will be done for biomass plants, i.e., there will be no tacit assumption that biomass combustion for electricity is "carbon neutral" as Mr. Lofton asserts. I invite all, including Mr. Lofton, to read this important rule:
4) It’s interesting that Mr. Lofton cites GA Tech as specifically supporting his project (again, with citing any proof of this claim). I only point out (as I mentioned in my comments Monday night) that a recently published study out of GT indicates that all of Georgia’s electricity needs for the next decade can be met by improving energy efficiency, alone, without the need for any additional power plants of any kind:
We will not participate in a back and forth with this group. We’ll be happy to meet with any of you in person to provide additional information and facts. Everyone is entitled to an opinion, but not the facts. Thanks so much for what each of you do for our community, and it’s an honor to serve you.I understand that Mr. Lofton has already passed up several opportunities to cite actual evidence to support his many interesting claims. There is plentiful information in the links I’ve provided above. If he indeed has evidence that refutes any of the claims I’ve made, they should all be public sources, and nothing that would require a private meeting in order to convey.
Brad Bergstrom, Ph.D., Professor
Department of Biology
Valdosta State University
Valdosta, GA 31698-0015 USA
229-333-5770 FAX 229-245-6585