1

I. Investigation of Slash Sources for the Port Townsend Biomass Power Plant When considering the slash sources that will be used to fuel the Port Townsend Cogeneration Plant, the amount, form, availability, and costs of the slash needs to be quantified. In Bill Wises presentation he introduces a table that illustrates the increasing amount of wood waste burned by the facility from the current 84,000 dry tons to 184,000 dry tons with the new biomass plant addition (Wise, 2012). He also indicates that this is the same wood materials they burn now, including sawdust, woodchips, recycled cardboard, hogwood, and urban wood. The primary benefit of increasing the amount of biomass used to power the production processes is that it reduces dependence on foreign reprocessed fuel oil, an estimated reduction of 1.8 million gallons of fuel oil annually (Wise, 2012). Furthermore, some sources note that an accumulation of woody debris, like slash piles, presents a fire hazard to a forest and nearby communities (JohnDeere). Because biomass needs to be removed for safety purposes it could also help increase local, renewable energy production. In fact the use of slash piles in biomass cogeneration plants is supported by the federal Energy Bill which includes biomass as a renewable energy (Deutscher, 2010). Forests are a renewable resource and many people believe that we should be utilizing forest byproducts to increase energy production and revitalize local economies (Deutscher, 2010). In comparing biomass to fossil fuels all economic, social, and environmental costs need to be considered in regards to resource extraction, transportation, refinement, energy efficiency, and harmful wastes including greenhouse gas emissions in order to compose an accurate picture of their benefits and disadvantages. Kees Kolff on the other hand educates that the removal of slash from forests harms the natural ecosystem (Kolff, 2012). Slash piles are an essential part of the forest and help replenish the soil with nutrients and through their decay help rebuild topsoil. This is especially important because slash piles are generally present in areas where lumber has been harvested leaving the soil exposed to the harshness of natural weathering processes. Slash piles also provide protection, cover, and habitat for wildlife, again very important because of the reduced amount of dense vegetation due to industrial harvesting (Dept. of Fish and Game, 2008). Studies have shown that brush and slash piles protect many vulnerable wildlife from predation and extreme climatic conditions (Dept. of Fish and Game, 2008). The coarse woody debris of the slash piles also creates favorable microclimates and nutrient sources for several forest species (Dept. of Fish and Game). Slash or woody debris for the cogeneration plant is also going to be collected from construction sites and other unconventional locations. Kolff worries that contamination of the slash is not being monitored and harmful lead paint or other toxins may be burned in the plant releasing noxious chemicals into the air (Kolff, 2012). An energy justice organization discovered that woody biomass may be contaminated with preservatives, binders, paints, glues, chlorine bleach, plastic laminating materials, chlorinated adhesives, or phenol and urea formaldehyde resins, which can emit toxic chemicals into the air when they are burned (Energy Justice Network). One specific point of contention between Port Townsend Cogeneration Plant supporters and those who are opposed is the CO2 emissions of slash piles left to decompose in the forest and the CO2 emissions produced by burning the biomass for energy. Those in favor of harvesting the

slash piles argue that the same amount of CO2 will be released into the atmosphere regardless if it is left in the forest or burned in a power plant. However, this does not expose the fact that the rate of natural decay takes hundreds of years to release the same amount of CO2 from a slash pile that a biomass power plant could release in a single afternoon. Some also argue that methane emissions, 21 times more potent as a greenhouse gas than CO2, from naturally decaying slash piles is greater than the methane released from the power plant. Kolff mentioned that methane is a potent byproduct of anaerobic decay, yet slash piles have a lot of air circulation and thus are not subject to this hypothesis (Kolff, 2012). The final explanation given by biomass supporters is the electrostatic precipitator, the scrubbers, and the advanced emissions reduction technology installed in the facility will reduce CO2 emissions as well as emissions of other harmful particulates. The emissions of naturally decaying organic matter are not filtered through the emissions control technology and thus are releasing more harmful gases than the plant would. There has not yet been the opportunity to fully analyze the effectiveness of some of the technology to prove or disprove these claims. However, I believe that the rate of natural decay vs. the rate of slash pile extraction and incineration is the focal point of this debate and should present a clear winner to this argument. Biomass may be a renewable resource, but not when it is being unsustainably managed. Slash piles may be a byproduct of lumber extraction, but they still provide primary services to the forest ecosystem. The use of slash and other biomass sources for the Port Townsend Cogeneration Plant has many hidden costs and complications that need to be reviewed and compared against alternatives before claims of renewable energy and carbon neutral are advertised.

II. Legal Factors Why no EIS? One of the recurring questions about the Port Townsend Cogeneration Plant is what specific impact it will have upon the environment. While this question is difficult to answer, it is one for which there are specific government procedures set in place for precisely that purpose. For this reason, groups like the East Jefferson Biomass Committee of the North Olympic Group of the Sierra Club and its spokesman Kees Kolff have repeatedly demanded that the proposed plants developers be required to complete an Environmental Impact Statement (EIS) report. While Kees Kolff and the groups opposing the cogeneration project argue that the plant is bad for the economy, bad for the environment, and bad for our health, the state Department of Ecology did not require an EIS statement in order for the project to be permitted (Arthur, 2012). Furthermore, when the issue was taken to the state courts, the appeal for an EIS was denied (CITATION). An EIS is not a binding legal statement; instead, the document is meant to serve as a tool for the permitting agency to make an informed decision as to the realistic impact that a potential project will have upon the surrounding environment. The reason that the Port Townsend plant was not required to undergo an EIS has to do with the way that it is being funded. Because the $55 million price tag for the project is being footed by private investors, the states regulations for the requirement of an EIS are different. The Nippon Project, in neighboring Clallum County, did have to present environmental study results, because it received funding in the form of a $600,000 grant and a $1.4 million loan from the Washington

Department of Commerce (Summerson, 2011). According to the Environmental Assessment (EA) for that project, [The] National Environmental Policy Act (NEPA) and the U.S. Department of Energy's (DOE's) NEPA implementing regulations require that DOE prepare a detailed Environmental Impact Statement (EIS) for all "major Federal actions significantly affecting the quality of the human environment." Federal regulations permit the DOE to conduct a less detailed Environmental Assessment (EA) to determine whether the proposed action will "significantly affect" the environment and thus whether an EIS is required. NEPA usually applies when, as here, a Federal agency provides Federal financial assistance for an activity or project to be carried out by a State or other non-Federal entity. (Summerson, 2011) Summersons referencing of why the Nippon plant had to undergo at least an EA explains a large part of the legal reasoning behind why the Port Townsend project is not required to conduct the same studies. However, Kees Kolff and the projects opponents are have still called for the report to be done arguing that the potential health hazards of the plant are significant enough to warrant it (Kolff, 2012). With the permitting process complete and the EIS posing a significant financial and time expense, there is no reason why the projects investors would be inclined to do an EIS, aside from the potential public support it could garner. The risk of not doing one, however, is that it looks as though the proponents of the project could be hiding risks that would only come out with an EIS. It is fairly certain that without any legal push, it is unlikely that a study will be done. Moreover, even if an EA or EIS was completed, it would have no real power at this point, since the plant is already permitted. More legal action would have to be taken in order to put a moratorium on the project. While these appeals might be more successful than the ones that have already happened, they would cost more time and money, and may not end up making a difference at all.

III. Competition for Biomass Another significant concern for the debaters of the Port Townsend Mill project lies with the issue of sourcing the biomass. A proposed radius of 50 miles around the plant will provide maximum cost efficiency, as well as limit the carbon emissions of transporting the biomass (to an extent) (Rhines, 2012). However, because of its proximity to both the Puget Sound and the Olympic National Forest, the Olympic Peninsula and surrounding areas have become prime locations for biomass and cogeneration plants. This poses an additional problem for the collection and use of biomass: competition. The map to the right shows several biomass plants (proposed or existing) in relation to population density calculated using the 2000 census ("Biomass incinerator locations," 2011). Circle nine (9) represents the Port Townsend Project, while circle eight (8) represents the Nippon plant (see table below for information on the other plants, as well as the Shelton groups assessment of harmful pollutants emitted by the plants). This information suggests that there will be significant competition for biomass in the region. While the projects have decried that there is plenty of slash wood to go around, as more

projects are proposed and current plants are expanded, this may be a changing issue (Summersen, 2011). Harmful Pollutants emitted in tons per year Company 1) Adage, NOC 1 2) Solomon, NOC 1 3) Simpson, 2003 3 4) Sierra Pacific, 2008 3 5) Grays Harbor Paper 4 6) Quileute Valley 2 7) Clallam County 2 8) Nippon, NOC 1 9) PT Paper, Boiler NOC 1 Megawatts Produced 65 31 14 18 18 0.75 5 20 15+25=40 Particulate Matter 195 66 109 8 105 2 21 36 178 Nitrogen Oxides 248 248 60 114 246 3 19 184 494 Sulfur Oxides 149 147 0 38 3 2 30 152 80 Carbon Monoxide 248 248 258 314 570 3 59 643 841

Red=proposed incinerators, Purple=existing Incinerators, Orange= expanding incinerators Sources 1 ORCAA or Ecology Notice of Construction 2 Modeled from ADAGE projections 3 ORCAA Actual emissions 4 NAAQS 1996 Boiler only ("Biomass incinerator locations," 2011)

Works Cited Arthur, A. (2012, March 21). Biomass: Educated disagree over health impact of project. Port Townsend Leader. Retrieved from

http://ptleader.com/main.asp?Search=1&ArticleID=31131&SectionID=36&SubSectionI D=55&S=1 Kolff, K. (April 21, 2012). The Burning of Biomass: Economy, Enviornment, Health. [PowerPoint slides]. Retrieved from http://www.ocean.washington.edu/research/gfd/has222-archive/kolff-25apr12.pdf Rhines, P. (2012, April). Lecture. Summerson, J. U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy Golden Field Office. (2011). Final Environmental Assessment for Nippon Paper Industries USA Company Biomass Cogeneration Project, Port Angeles, Washington (DOE/EA-1858). Retrieved from website: http://www.eere.energy.gov/golden/ReadingRoom/NEPA/1858/Environmental_Assessm ent.pdf [Web log message]. (2011, March 11). Retrieved from http://sheltonprogressive.blogspot.com/2011/03/biomass-incinerator-locationscompared_11.html

IV. The Math: Energy Output and Amount of Wood With the Port Townsend Paper Mill, the new cogeneration proposal would yield 25 MW of electricity. How many pounds of wood per day is this? Many conversions and rough estimates were taken into account, and the efficiency of burning wood is only 25%, but the total amount of dry wood needed is about 2 million pounds per day. Bill Wise stated that 184,000 dry tons per year of biomass will be used, while Kees Kolff stated that 400,000 wet tons per year will be used. To compare these numbers, the following information is necessary: Necessary information: 25 MW desired 10 MJ/kg dry wood Dry wood efficiency is 25% Average moisture content of wood in PNW is 50% Given this information, the calculations are as follows: 25 MJ 1s 1 kg 10 MJ 2.2 lbs 1 kg 3600 s 1 hr 24 hrs 1 day

= 475,200 lbs dry wood/day 475,200/.25 = 1,900,800 lbs dry wood/day due to a 25% efficiency rate of wood

Bill Wises Estimation 184,000 tons 1 yr 1000 kg 1 ton 2.2 lbs 1 kg 1 yr 365 days

= 1,109,041 lbs dry wood/day 1,109,041 lbs 1 day = 58.35 MJ/s 58.35 x .25 = 14.48 ~ 15 MW electricity Kees Kolffs Estimation 400,000 wet tons ~ 200,000 dry tons 200,000 tons 1 yr 1000 kg 1 ton 2.2 lbs 1 kg 1 yr 365 days 1 kg 2.2 lbs 10 MJ 1 kg 1 day 24 hrs 1 hr 3600 s

= 1,205,479 lbs/day 1,205,479 lbs 1 day = 63.42 MJ/s 63.42 x .25 = 15.85 ~ 16 MW of electricity V. Transportation of Biomass & Associated Costs In addition to local competition, the transportation of biomass resources from the site of origin to the cogeneration plant incurs additional environmental and economic costs. The use of trucks, fuel, and labor to harvest biomass resources has the potential to offset many of the savings that a cogeneration plant arguably produces. Indeed, logistics costs are generally prohibitive outside of a fifty-mile radius, and with the fluctuating price of fuel the costs of biomass production are dominated not by the resource supply but by the availability of transportation materials. 1 kg 2.2 lbs 10 MJ 1 kg 1 day 24 hrs 1 hr 3600 s

Kees Kolff cited a current biomass production of 82 trucks per day into the Port Townsend plant. Under the proposed cogeneration plant, an increased number of 15 trucks per day would be added. We can work through the economic costs utilizing data produced by a New Hampshire firm (Kingsley, 2011). Assuming a distance of 50 miles, the cost of diesel at $3.00 per gallon, and the capacity of one truckload to be 27 green tons, the average diesel amount used in transport is 2.09 gallons per green ton. With our current production level of 82 trucks per day, this equates to 2,214 tons of biomass transported at a cost of 4,600 gallons of diesel. With an additional 15 trucks per day, 2,619 tons of biomass would be transported as a cost of 5,500 gallons of diesel. The additional 850 gallons of diesel fuel needed per day accumulates into 310,250 gallons of fuel needed per year to accommodate 15 extra truckloads. Economics aside, the variability and uncertainty of transportation costs directly affects the projects environmental and social impact. The increased use of diesel in transport adds to the burning of fossil fuels and the release of particles into the atmosphere. Culturally, Port Townsend stands to change with an increase in transient traffic. Kees Kolff also noted that the proposed increase in trucking traffic through Port Townsend would be unsustainable as the Mill Road intersection in the heart of town is proposed to fail by 2020. Ultimately, the transportation of biomass should not act as the be-all, end-all factor in deciding the future of the PT plant, but further inquiry must be conducted to determine the various costs and sustainability models regarding this step in the production process. The curious nature of biomass in that it takes more energy to produce than it puts out draws questions on the viability of its utilization as an energy source, especially compared to more efficient fossil fuels. As one study aptly states: Transportation is a cost element in any energy project, and this is especially true for biomass because of its lower energy density, (Searcy, 2007). Working towards better solutions for transportation has become a central facet of the biomass dialogue; in the past few years, there has been new scholarship surrounding alternatives to current methods of trucking biomass transportation, supported by both producers and consumers alike (Short, 2009).

This is a graphic illustrating the cost of producing biomass in relation to the cost of diesel fuel.

Kingsley, E. (2011). Woody biomass risk management solutions. Retrieved from http://www.heatne.com/pdfpres11/Kingsley HeatNE Feedstock Risk Management - INRS.pdf. Searcy, E. (2007). The relative cost of biomass energy transport. Retrieved from http://wearemichigan.com/JobsAndEnergy/Biomass/Documents/The_relative_cost_of_biomass_ energy_transport.pdf. Short, H. (2009). How to move biomass cost effectively. Retrieved from ttp://snrecmitigation.wordpress.com/2009/04/24/pipes-trains-and-trucks-how-to-move-biomasscost-effectively/.