Virginia’s plan to cap its carbon pollution from power plants is an historic step, as the Commonwealth becomes the first southern state to meaningfully address climate change. Unfortunately, the new rule includes a pro-polluter giveaway: it exempts pollution from burning wood for electricity. The science shows what should be obvious: burning wood for electricity worsens climate change. This bad idea must be corrected for Virginia to become a true national leader on climate.
Giving forest biomass burners a free pass is inconsistent with the Regional Greenhouse Gas Initiative (RGGI)—the multi-state program that Virginia hopes to participate in by enacting this otherwise strong plan. Indeed, this polluter exemption establishes Virginia as the biomass laggard among the RGGI states. That is because the RGGI program regulates biomass that is “co-fired” (or mixed) with fossil fuels, covering units that burn “fossil fuel alone or in combination with any other fuel.”
Virginia had originally proposed an arrangement similar to that of RGGI: power plants co-firing biomass would rightly be required to pay for their pollution by securing “allowances” to emit carbon pollution into the atmosphere. In practice, this would mean Dominion’s Virginia City coal plant would need to account for the pollution it emits from burning wood. This approach would exempt entirely Dominion’s three power plants that exclusively burn wood for electricity (leaving those plants’ considerable climate pollution to be covered in a separate, future rulemaking).
Rather than adopt RGGI’s compromise approach, however, the administration of Gov. Ralph Northam instead bowed to industry pressure and retreated to a plan that ignores all carbon pollution from burning wood. This is a stunning backtrack. After all, a molecule of carbon dioxide from burning wood creates the same climate damage as a molecule of carbon dioxide from fossil fuel. In its retreat from the RGGI model, the Northam administration is instead pretending that there is a difference between the two.
In addition, Virginia’s loophole—in combination with other proposed subsidies and regulatory giveaways—may encourage a new Virginia market for an already exploding dirty and destructive wood pellet industry. Most U.S. wood pellet manufacturing already occurs in the Southeast. Twenty wood pellet facilities located in eight Southeastern states produce 7.5 million tons of carbon-intensive pellets a year, largely for export to international markets. (See facility map found here). Worst of all, approximately 180,000 acres of Southern forests are logged annually to supply these 20 pellet mills (based on estimates provided by Schlesinger and Christensen). These mills are a danger to our climate for a number of reasons:
- The degraded forest “carbon sink” from the industry’s harvests (even when accounting for regrowth) results in roughly 12 million tons of carbon dioxide emitted into the atmosphere annually. This represents about 75 percent of the annual emissions from coal-fired power plants in Virginia.
- Much of the logging done to source the pellet industry is in imperiled bottomland hardwood forests.
- The sourcing areas for these 20 pellet mills covers 15 million acres of these forests, more than eight times the size of the George Washington National Forest—including ecologically sensitive areas adjacent to the Great Dismal Swamp National Wildlife Refuge along the Virginia-North Carolina border.
In addition, the Northam administration’s policy of granting a free pollution pass for forest biomass burners is perversely aligned with the Trump administration’s policy, which falsely claims that forest biomass is “carbon neutral.” Last year, then-EPA Administrator Pruitt released a Statement of Agency Intent to treat forest biomass as “carbon neutral,” a demonstrably false premise that claims burning wood for electricity results in no net carbon pollution in the atmosphere.
Worse, Trump’s proposed Dirty Power Plan, released in August 2018, formalizes EPA’s “carbon neutral” policy, allowing coal-fired electricity generators to count co-fired biomass emissions as zero—just as Virginia’s rule unfortunately now does. That Trump policy is not supported by the conclusions of the EPA’s own scientific advisors rejecting carbon neutrality, and neither is the Northam administration’s similar biomass policy. More generally, carbon neutrality of biomass has been rebuffed by numerous scientific societies, refuted in the vast majority of peer-reviewed literature on the subject, and opposed by many hundreds of scientists around the world.
What a missed opportunity to fully align with RGGI and repudiate the Trump administration’s backwards policy—especially within an otherwise strong rule and the first southern state carbon policy on the books in the Trump era.
Make no mistake: burning wood to produce electricity pollutes our air, destroys our forests, and increases energy costs for consumers. It emits as much climate-damaging pollution as coal for every unit of energy produced. Biomass has no place in Virginia’s clean energy future and its pollution should be covered just like the other dirty fossil-fuel-fired plants in the Commonwealth.
As part of its role in guiding the state’s response to climate change and the pro-polluter excesses of President Trump, the Air Board and Virginia legislature should fix this surprising and misguided industry handout.