350 Humboldt will be meeting in person at our Thursday May 25th meeting at 6 pm — that’s tomorrow at 6.
Where: The Gazebo in Larson Park. Directions are here (from the library at Cal Poly Humboldt). Quick version: Take Sunset from Highway 101 one block, past the skate park. Turn right at first street at the traffic circle (Jay St.). Turn right at end of street in one block (onto Eye St.). Turn right and park at end of street where the tennis courts and parking lot are. The Gazebo is past the tennis courts. There is a porta potty near the tennis courts and playground for kids.
What to bring: a folding chair. For some reason there is no seating in the Gazebo. Also, you may want to combine the in person meeting with a picnic. There are picnic tables nearby or you can munch while we talk.
What we will be discussing: After a poem is read by poet Kristy Hellum we will be discussing several initiatives to switch the combustion of biomass to cleaner alternatives. Below are a) A statement of the policy position the steering committee is recommending and b) two documents specific to the RCEA contract with Humboldt Sawmill. Please bring a copy of all three with you.
As a reminder, we make decisions by consensus if possible. If that is not possible, an 80% vote is required. Persons who have attended at least one general meeting between November and April are eligible to vote.
350 Humboldt Policy Statement on Burning Woody Biomass
350 Humboldt joins the growing scientific consensus that incinerating wood to produce heat and electricity is not carbon neutral but warms the planet. The biogenic, renewable nature of trees and other biomass does not counteract the high carbon intensity of combustion, which contributes to global warming for many years into the future. As 500 scientists said in a petition to world leaders in 2021: “Regrowing trees and displacement of fossil fuels may eventually pay off this carbon debt, but regrowth takes time the world does not have to solve climate change. As numerous studies have shown, this burning of wood will increase warming for decades to centuries.” [1] We must absolutely minimize all GHGs if civilization and other living things are to avoid the most catastrophic effects of climate change.
Making biomass electricity is a sensible option only when there is no less carbon-intensive way to dispose of wood waste or forest residues. Fortunately, modern technologies successfully use biomass as a feedstock for a variety of products. The list includes wood products such as oriented strand board, veneer lumber, plywood, etc.; new materials such as nano cellulose and bioplastics; soil amendments such as compost, mulch, and biochar; and fuels such as ethanol, renewable natural gas, and hydrogen. These fuels can be used to generate electricity or as low carbon alternatives to fossil fuels.
In addition to its warming effects, burning biomass for electricity produces significant air pollution, which––as in Humboldt––affects disadvantaged communities. This is particularly true when––as in Humboldt––the equipment is old and very far from state of the art.
In consequence of these facts, 350 Humboldt will pursue a variety of policies and actions through its Legislative Committee and through special campaigns as needed, including:
- Work to change policies. Biomass electricity obtained by incinerating wood should no longer receive special dispensations or incentives from the California state government. Biopower should be removed from the Renewable Portfolio Standard.[2] The CPUC should remove it from its emissions exemptions.[3] Biopower should be counted under Cap and Trade and must pay for each ton of GHG emissions over 25,000 a year as other power generators do.[4] All jurisdictions must include emissions from the combustion of biomass in their inventories of greenhouse gases.[5]
- Work to change RCEA. Biomass power currently being purchased by the Redwood Coast Energy Authority should be replaced by renewable sources in line with the RCEA Board’s 2018 pledge to use only “clean and renewable” power sources in 2025 and thereafter. This includes telling RCEA that the Integrated Resource Plan should not include biomass combustion.
- Work to block pellet plants. The Humboldt County Board of Supervisors should not support in any was the current development of two gigantic factories to produce wood pellets for burning for power in other countries.
We also note that wood stoves have the same issues of pollution (of selves and neighbors) and greenhouse gas emissions. For the climate we need electrification of all homes, but in rural Humboldt power outages are a significant risk in that case. The Climate Action Plan committee will work to promote alternatives for individual households that will provide backup during power outages but reduce pollution and global warming.[6]
[1] https://s3.documentcloud.org/documents/20482842/scientist-leter-to-biden-van-der-leyden-michel-suga-moon-february-11-2021.pdf
[2] The Renewable Portfolio Standard is a list of fuels for producing electricity. Biomass is legally “renewable” though it is not in actual Life Cycle Analyses.
[3] The California Public Utilities Commission currently is required by law to maintain Emission Performance Standard (EPS) for all electrical utilities. In a 2007 rulemaking, the Commission set the EPS for all Load Serving Entities (LSEs) at 1,100 pounds (lbs) of carbon dioxide (CO2) per megawatt hour (MWh). Biomass power, however, was exempted 15 years ago on a temporary basis.
[4] Other electric power generators are subject to cap and trade under which they must not exceed emissions over a set limit so they are forced to buy “credits” from those who have excess. The current price per credit is $26.34 per metric ton of CO2. Biomass power plants are exempted.
[5] For example, the CalEnviroScreen program tracks emissions near sensitive populations including those from power plants, but biomass power is exempt even though it is the dirtiest source of energy in California.
[6]Propane, for example, has about half the global warming effect as fuel oil and can be used in indoor space heaters, so may make a good backup. https://www.epa.gov/energy/greenhouse-gases-equivalencies-calculator-calculations-and-references ; https://www.propane101.com/lpgasspaceheaters.htm ; https://impactful.ninja/the-carbon-footprint-of-propane/
A RESOLUTION TO END BIOMASS CONTRACTS
WHEREAS, ________ is committed to ensuring and safeguarding the health, safety, and environment of the residents of our community; and
WHEREAS, the Humboldt Sawmill Company’s biomass plant is the largest stationary source of air pollution in Humboldt County, emitting fine particulates and air toxics which increase rates of heart disease, asthma attacks, strokes, cancer, adverse birth outcomes, learning disabilities, and premature death;
Whereas, the Humboldt Sawmill Company has been cited by the North Coast Unified Air Quality Management District for multiple violations of the Clean Air Act and by the Northern Coastal Regional Water Quality Control Board for multiple violations of the Clean Water Act during the time it has provided power to RCEA; and
Whereas the North Coast Unified Air Quality Management District was recently found to have longstanding failures to enforce the Clean Air Act and Air Toxic Hot Spots Act at the biomass plant leading to years of uncited violations; and
Whereas the Humboldt Del Norte Medical Society has called for an end to biomass contracts; and
Whereas RCEA’s biomass contract contains a provision allowing RCEA to exit prematurely if the biomass plant violates environmental laws; and
Whereas the climate emergency requires immediate and substantial reductions in carbon emissions while the biomass plant emits nearly three hundred thousand metric tons of carbon dioxide annually, a quantity equivalent to 80% of emissions from all Humboldt’s passenger vehicles, which warms the planet immediately and takes decades to be reabsorbed; and
Therefore be it resolved that _______ calls on the RCEA Board to end the contract with Humboldt Sawmill and permanently remove biomass incineration from its portfolio. Our RCEA Board representative is instructed to introduce this resolution and vote in favor of it.
If the RCEA Board fails to end the current biomass contract, then our RCEA Board representative will introduce and vote for an RCEA resolution to permanently remove biomass incineration from its portfolio when the current contract expires in 2031.
FACT SHEET: BIOMASS POWER: Not Clean, Not Climate Neutral
Humboldt County’s largest stationary source of air pollution
Humboldt County has 2 active federally designated Major Sources of pollution permitted under Title V of the Clean Air Act: PGE’s Humboldt Bay Generating Station and Humboldt Sawmill Company’s biomass plant. 1 Compared with the natural gas fired power plant, the biomass plant emits 10 times more fine particulates, 7 times more NOx, 15 times more benzene, and 5,800 times more formaldehyde, despite producing only one third as much electricity. 2
$2-5 million a year in health damage
The Humboldt Del Norte Medical Society has called for RCEA to stop contracting for biomass on health grounds. An EPA modeling tool shows 2-5 million dollars per year in health damages from the biomass plant’s particulate emissions shows due to increased heart and lung disease, hospitalizations, infant mortality, and premature deaths. 2,3 This figure does not include health harm from the plant’s toxic emissions of carcinogens, endocrine disruptors, and developmental neurotoxins.
Multiple violations of environmental and safety laws
When the biomass plant bid for its original contract with RCEA in 2016, it reported only 1 air quality violation. For 12 months prior to submitting the bid, the plant withheld monthly emissions monitor reports from the North Coast Unified Air Quality Management District which subsequently showed over 700 violations. While the plant has been under contract with RCEA, it has received 10 notices of violation of the Clean Air Act,4 one settlement order for multi-year violations of the Clean Water Act,5 3 serious OSHA violations resulting in worker injury 6 and has had multiple violations of sections of the Clean Air Act which NCUAQMD failed to cite.
Air district fails to enforce pollution laws
A recent review of public documents obtained from the North Coast Unified Air Quality Management District found that the air district has not been fully enforcing state and federal pollution laws at the biomass plant for years, eroding confidence that the agency will protect us from biomass pollution. The air district:
- Failed to respond when the plant didn’t submit monthly monitoring results for a year.
- Failed to enforce EPA regulations requiring testing of pollution monitoring systems
- Interpreted monitoring results according to outdated emissions standards
- Failed to follow state law requiring evaluation of the plant’s toxic risk to the community.7
Biomass emissions warm the planet
Limiting global warming to 2C requires deep emissions cuts this decade, starting immediately.8 HSC’s biomass plant emits 3 times as much climate pollution per kilowatt hour as electricity from natural gas, the greenhouse gas equivalent of 80% of Humboldt’s passenger vehicles. It takes 40-50 years from the time it enters the atmosphere for that carbon to be reabsorbed. 9 Meanwhile it warms the planet. Even if biomass is carbon neutral over the long term (which many scientists debate), it is not climate neutral in the critical period until 2050.
REFERENCES
1 North Coast Unified Air Quality Management District https://www.ncuaqmd.org/major-source-title-v-permits
2 California Air Resource Board Pollution Mapping Tool https://ww2.arb.ca.gov/capp-resource-center/data-portal/carb-pollution-mapping-tool
3 Co Benefits Risk Assessment Health Screening and Mapping Tool https://cobra.epa.gov/
4 NCUAQMD multiple Notices of Violation obtained via public record request
5 North Coast Regional Water Board Settlement Agreement with Humboldt Sawmill Company
https://www.waterboards.ca.gov/northcoast/board_decisions/tentative_orders/pdf/2022/220712%20Final%20Stipulated%20Agreement%20HSC.pdf November 2022
6 US Department of Labor https://www.osha.gov/ords/imis/establishment.inspection_detail?id=1520807.015
7 Multiple documents obtained by public record request and absence of requested documents (because they didn’t exist) from the NCUAQMD.
8 Synthsis Report of the IPCC Sixth Assessment Report (AR6) Summary for Policymakers https://report.ipcc.ch/ar6syr/pdf/IPCC_AR6_SYR_SPM.pdf
9 Law, BE et al Land use strategies to mitigate climate change in carbon dense temperate forestsPNAS April 3, 2018 115 (14) 3663-3668; first published March 19, 2018; https://doi.org/10.1073/pnas.1720064115 https://www.pnas.org/content/115/14/3663