This post was provided by Jim Sullivan, Assistant Executive Director, Bennington County Regional Commission, VT. This report was prepared by an advisory committee to the Bennington County Regional Commission regarding the Beaver Wood Energy Biomass Project proposal and does not represent an official position of the BCRC.
The Regional Energy Committee has reviewed information submitted by Beaver Wood Energy concerning their proposed 29.5 MW biomass generating facility and wood pellet fuel manufacturing facility in Pownal. The Committee also has listened to a presentation on the project by Beaver Wood principals and consultants, asked a series of questions of the developers, and read letters submitted by residents, municipal governments, and other local organizations. The Committee’s specific interest and expertise is in the area of energy; the comments in this memo, therefore, focus on the types of issues that are covered in the Bennington Regional Energy Plan, and less specifically on issues that may be part of the Section 248 review that are peripherally related to the use and conversion of energy resources.
It also should be noted that Scott Printz, chair of the Committee, disclosed the fact that he is an employee of Col-East, a company based in North Adams, Massachusetts, and that Col-East has been retained to provide some aerial photography for the owners of the property where the facility is to be located. The Committee felt that Mr. Printz could, and did, fairly and objectively participate in discussions related to the project.
The 2009 Bennington Regional Energy Plan provides information, policy guidance, and recommended actions that direct the work of the Energy Committee. That Plan provides comprehensive information about our region’s utilization of various energy resources and includes an extensive discussion related to the development of renewable energy resources. Perhaps the most important concept contained in the Energy Plan is the assertion that, because of the decreasing availability and escalating cost of obtaining fossil fuels, in the near future we – as a society – will have available to us considerably less total energy than we have had at any time in the past several decades. The Energy Plan addresses the role of alternative energy in our future by stating that “Alternative energy in the form of renewable resources such as solar, wind, hydroelectric, and biomass…can provide significant amounts of clean energy well into the future,” but that “the total amount of energy that can be extracted from such resources is markedly less than what we currently obtain from fossil fuels.” Consequently, the Energy Plan’s primary thrust is to encourage energy conservation in all aspects of our lives and economic systems.
At the same time, the Energy Plan recognizes that availability of a considerable amount of energy will be necessary to maintain an acceptable quality of life for our residents and to support future economic progress. Several basic goals and objectives are spelled out that relate directly to our future energy supplies:
- Increase opportunities to make energy choices at the local level.
- Assure diversity in the mix of energy sources to minimize the impacts of a supply restriction in any particular fuel.
- Decrease our reliance on non-local energy sources through conservation and development and use of local renewable energy resources.
- Make energy choices that minimize adverse impacts to the environment.
- Assure both an adequate supply of electricity and a secure distribution network to meet the region’s needs.
The chapter of the Energy Plan that covers renewable energy resources includes a section dedicated specifically to biomass (wood) energy. That section observes that wood, together with direct solar energy, “is the most obvious and ubiquitous source of locally available energy.” And while the Plan agrees with Beaver Wood’s contention that sufficient biomass is available for both existing uses and the new facility within the region and surrounding area, it also points out a number of concerns (that will be discussed in more detail below); for example:
- Heavy and continual removal of woody biomass to maximize energy yield will deplete soil nutrients and reduce future productivity.
- Net energy yield of biomass production is relatively low because of the energy inputs required to cut, transport, and process the wood, and most of those energy inputs are derived from petroleum fuels (with all of the uncertainties related to supply and cost noted above).
- Considerable potential for adverse local environmental and community impacts.
Despite those concerns, the local abundance of the resource, its relative environmental benefits (compared to utilization of coal, oil, or natural gas), potential benefit to the regional economy, and ability to contribute to the smaller-scale distributed energy production facilities that will be required in the future “suggest that planning for greater utilization of the resource should be pursued.”
The Energy Plan does contemplate use of biomass for both electricity generation and production of wood pellet fuel. According to the Plan, because electricity will become an increasingly important way to “provide energy for everything from manufacturing to transportation and communication, the feasibility of using wood from the region’s forests to generate electricity should be considered.” The Plan goes on to say, however, that any such a facility must be located to minimize negative impacts on the environment, residential neighborhoods, and public infrastructure. Concerning pellet fuel, the Plan observes that although cord wood used for space heating provides the most effective use of biomass – in terms of net energy yield and displacement of the maximum amount of fossil fuel use – the convenience and efficient burn characteristics of wood pellet fuel are attractive. Because pellet fuel currently must be transported into the region from a considerable distance, the Plan suggests that there may well be sufficient demand for a pellet manufacturing plant in the area.
Although the Energy Plan clearly supports the development of local renewable energy resources such as biomass, the actual benefits and effectiveness of any particular project must be closely scrutinized. The Energy Committee discussed numerous aspects of the Beaver Wood Energy project; the issues and concerns identified are covered in the following categories: Use of Biomass Resource, Sustainability of the Project, Transport Options and Truck Traffic, Environmental Concerns (air quality, water supply and quality), and “Other Concerns” (aesthetics, property values, economic impacts, and jurisdictional issues).
Does the proposed project represent a wise use of our biomass energy resource?
The Regional Energy Plan reports that there is enough wood biomass in the region to supply a significant portion of the area’s energy demand. The most efficient and effective use of this resource is to maximize its use in modern space heating systems (furnaces and wood stoves) in area residences. The significant investment in biomass heating systems at local schools and colleges has shown that heating of large buildings and institutions can be cost-effectively accomplished with biomass as well. Electricity generation is inherently less efficient than space heating biomass applications, but produces a very useful and versatile energy carrier.
Because burning cord word from area forests in residential applications is the most efficient and cost-effective use of our biomass resource, in terms of net energy yield and reduced consumption of imported fossil fuels, transitioning to such applications should be a high priority for the region. Initially, it may appear that a less-efficient biomass-based electricity generating facility might conflict with such applications by diverting wood from residential space heating applications. The type of biomass product used in a biomass energy facility, however, is not cord wood, but the residual material (branches, tops, and other woody debris) remaining after the harvest of trees for firewood, saw logs, and other applications. Expanded use of forest resources for efficient residential space heating applications, therefore, actually produces additional product that can be used for the generation of electricity. The wood pellet fuel manufacturing facility that is a component of this project uses whole logs for pellet production, and thus is another source of the residual biomass that can be made available for the generating facility. Although the wood chip based heating systems at large institutional uses (schools, colleges, hospitals) demand the same residual biomass product, there remains adequate forest growth to supply both markets.
Two major concerns related to the proposed intensive use of the regional biomass resource need to be carefully considered. The first issue involves the effects on forest soils and productivity of removing large quantities of biomass. Whenever material is removed from the forest, a portion of the energy and nutrient base needed to maintain productive growth of all forest biota is removed as well. Moreover, most of this productive-potential is tied up in the very products being removed for the biomass facility: the branches and tops of the trees. If forest productivity significantly declines, our future ability to economically and sustainably obtain wood products – for biomass energy or any other purpose – will be compromised. A related concern is the potential decline in the ability of the land to support healthy and diverse ecosystems and to maintain surface and ground water quality. For these reasons, we feel it is critical that qualified soil scientists and forest ecologists review the harvesting methods proposed to ensure that sufficient material is left in the woods to replenish the natural systems. Once operating, effective monitoring of harvesting should be required to ensure that adverse impacts are minimized.
The Energy Committee also notes that because of the intensive energy inputs required for the production of wood pellet fuel (grinding whole logs, drying and compressing the product into pellets, packaging, and transport to markets largely outside the region), pellets are a very low net energy fuel and generally not the preferred use of our biomass resource. The advantages of pellet fuel include convenience and the clean-burning nature of the fuel (and consequent reduced particulate emissions). The Committee recognizes that the biomass generating facility will be producing a large amount of heat and it is appropriate and efficient to make use of that heat energy in some way. Ideally, that “waste” energy could be used for some type of district heating, but the location of the facility is not conducive to such use. (If the biomass energy facility were in a suitable location and scaled to match the heating needs of an identified user, the overall efficiency and net energy yield of the project would be greatly increased.) Given the subject proposal, however, the pellet manufacturing facility derives one of its major energy inputs from a resource (heat from the biomass facility) that would be lost if the biomass generating facility were built with no secondary use of the waste heat. If the pellet facility is built, it is hoped that the local market for the product will expand to limit the export of the pellets (and energy) from our region.
Is the project sustainable; will it be producing electricity to meet regional needs will into the future?
The energy density of biomass is low relative to fossil fuels, but it has the advantage of being available locally. The relatively low energy density of biomass means that large volumes of this feedstock need to be procured and transported to the facility every day (further details provided in discussion of environmental issues). Our analysis indicates that the net energy (amount of energy output relative to energy inputs required to obtain the electricity for the end-user) produced by the proposed electricity generating facility appears to be less than 3:1, a relatively inefficient and costly energy source. Considering the large initial capital expenditure and the energy-intensive (and expensive) nature of the operation, it appears that the business will require significant federal financial support. If operating subsidies are required in addition to the initial ARRA funding, future loss of the subsidies would jeopardize the viability of the plant. Higher operating costs – in the form of reduced subsidies or higher feedstock prices – will require additional revenues in the form of higher prices for electricity and pellet fuel. Increasing petroleum prices are likely to be a significant factor driving up operating costs, but it is likely that pellet and electricity prices will, in fact, rise along with them.
A significant concern is that biomass energy facilities rely heavily on petroleum (largely diesel) for the harvesting, processing, and transport of wood, and future interruptions in the supply of diesel fuel would render the project inoperable, eliminating revenue flow and making the project unsustainable. The fact that oil reserves are becoming more difficult and costly to access is evident. It is inevitable that at some point in the future (when the energy required to obtain, process, and deliver the petroleum product approaches the energy derived from it) those liquid fuels will not be available at all. Although there is disagreement as to when that point will be reached, there is widespread agreement that world oil production has peaked and that as production declines in coming years, there will be supply disruptions. The further that feedstock fuel must travel to get to a biomass energy facility, the more damaging are these disruptions in diesel fuel availability, thus prompting the Energy Committee to speculate whether a smaller-scale facility that would derive its fuel from a more local area, would be more sustainable. We are, however, evaluating the project proposed by the developer, and thus note only that this potential is real and poses a threat to the sustainability of the project that the developer should consider seriously.
What are the best transportation options for the facility and what are the likely impacts of truck traffic?
The trucks delivering wood chips to the biomass energy plant and logs to the pellet manufacturing facility, as well as trucks shipping finished pellets and waste ash from the site, represent a significant impact on roadways in the vicinity of the project and to adjacent residential neighborhoods. Beaver Wood Energy points out that the increase in overall traffic volume on US 7 attributable to the vehicles accessing the facility will not reduce the level of service on the highway, at any intersection, or require turning lanes, but it is important to recognize that 97 of the vehicles arriving at the facility every day (194 round trips) will be large trucks. Although truck traffic may not affect level of service, heavy trucks certainly do affect the roadway and the neighborhoods they pass through to a much greater extent than do cars.
According to projections provided by Beaver Wood Energy, approximately two-thirds of the trucks will arrive from (and supposedly depart to) the south on US 7 and the balance from the north on US 7 (Route 346 apparently is unavailable due to a restricted bridge). Further breakdowns in routing (e.g., trucks using Routes 2 E/W versus US 7 to Williamstown and Routes 9 and 67 versus US 7 to Bennington) were not available. The potential noise, safety, and roadway infrastructure impacts in all of these areas, particularly to residents living along US 7 and to businesses in Bennington and Williamstown (and to Williams College in Williamstown) could be considerable. Currently, there is very little through truck traffic on US 7 – most of the trucks on this route are making deliveries to local destinations – so the increase certainly will be noticeable. An eventual bypass highway around Bennington could alleviate some of the truck traffic impacts in the center of that town, but impacts in other areas would occur for as long at the biomass facility operates.
An active rail line passes by the project site, but use of rail in this case would be inefficient compared to direct truck deliveries. With most of the wood being sourced locally, trucks would have to drive to a rail terminal, probably using many of the same roads they would use to deliver directly to the Beaver Wood Energy facility, and load the wood onto the rail cars. The rail cars would then have to be unloaded at the facility. Use of rail for deliveries would only make sense if the feedstock were harvested at a distant location, but that would involve additional transport costs (thus reducing already marginal net energy yields) and fail to achieve the objective of using local renewable energy resources.
The towns most affected by the truck traffic: Pownal, Bennington, and Williamstown, Massachusetts, should be consulted to determine how they would prefer deliveries be staged. For example, if trucks are not allowed to make deliveries during evening hours, higher volumes of truck traffic would occur during the day (because a minimum amount of biomass must be delivered to the site every day).
Noise and dust generated by trucks operating on the site also must be considered. Truck maneuvering areas should be designed and located to avoid excessive impacts to off-site locations. Trucking and other site operations should conform to the performance standards contained in the Pownal Zoning Bylaw.
Will the project adversely impact air quality, water quality, or water supplies?
Most of the written comments submitted to the BCRC by residents of the area express grave concerns over the project’s affect on air quality and the quality and quantity of both ground water (wells that serve existing homes and businesses) and surface water (the Hoosic River). The Energy Committee feels that these concerns must be given great weight and that the project must not go forward unless and until a rigorous examination of the evidence by state regulators determines that all safety and other standards are clearly satisfied. One reason that renewable energy projects are often viewed favorably is because they are perceived as being environmentally advantageous compared to other sources of energy; if public health and the availability of clean drinking water is compromised in any way, support for the projects becomes untenable.
The Energy Committee does not feel it has the expertise to evaluate air and water quality data and models, but enumerates below several issues that are of critical concern.
- Air quality: Any air quality modeling must reflect a full understanding of the unique narrow valley where the project site is located. Particulate emissions and any contaminants in water (whether found in source surface or ground water or added as part of any industrial process on site) that may be released in steam must be identified, controlled within regulatory standards, and continuously monitored to prevent releases that could affect public health.
- Carbon Emissions: A great deal of controversy has been generated recently around the issue of C02 emissions/carbon footprint/climate change impacts of biomass facilities. It is clear that burning biomass releases large amounts of carbon (a larger amount than coal by volume of material burned since wood is less energy dense), but it is carbon that is circulating in our contemporary ecosystem. If the forest soil remains productive (see concerns with removal of excessive material noted above), new growth rapidly takes up comparable amounts of carbon. Fossil fuels such as coal, oil, and natural gas, on the other hand, release carbon that has been sequestered for tens of millions of years and is, essentially, adding new carbon to the contemporary ecosystem. To minimize the carbon footprint of a biomass energy operation, it is critical to ensure that areas of harvested forest be maintained in a condition where they can continue to support strong new forest growth. Conversion of harvested areas to non-forest uses would adversely affect net carbon flow attributable to biomass energy operations.
Even if emitted carbon were replaced one for one by carbon take up by new vegetative growth, a biomass energy operation cannot be “carbon neutral,” because of the large quantity of fossil fuels used to harvest and transport the wood. If the 97 trucks accessing the Beaver Wood Energy site each drove an average of 75 miles per day, based on mileage data from the Bureau of Transportation Statistics, the total daily fuel consumption would be over 1,000 gallons of diesel. If trucks accessed the site 300 days per year, trucking operations alone (not considering other fossil fuel based energy use in plant operations), the facility would account for the consumption of close to 400,000 gallons of diesel fuel per year. Notwithstanding these rather large numbers, the electricity we use must be generated somewhere and biomass-fueled systems may produce less net carbon than facilities that rely on direct combustion of fossil fuels to run their turbines.
- Water Quality: Waste water from the biomass facility will be discharged into the ground. Any contaminants in the water – whether originating from pollution in the Hoosic River, from the plant’s well, or from any industrial additives – may be concentrated in the waste water. The waste water must be monitored, treated, and discharged in a manner that ensures that hazardous materials do no migrate to any off-site potable water supply or to any surface water feature, including the Hoosic River.
- Water Supply: Water withdrawals from the well at the site must not impact the recharge rates or long-term viability of any existing well. If the project is permitted and constructed, and an adverse impact on a well is found to have occurred in the future, a system must be in place that requires Beaver Wood Energy to fully remediate the situation.
The amount of water drawn from the Hoosic River also must be strictly limited to ensure that lower flow levels do not result in changes in water temperature, substrate, or other features that would degrade aquatic habitat or impair traditional river uses. The Town of Pownal owns a dam downstream from the Beaver Wood Energy site and has been in active discussions with a development company seeking to re-start the hydroelectric generating activity at the site. Hydroelectricity generated at an existing dam site has a high net energy yield and is a preferred source of local electricity. The viability of the hydro site in Pownal is heavily dependent upon adequate flows in the river; the amount of water withdrawn at the Beaver Wood Energy facility must be shown to have no adverse impact on generating capacity at this downstream dam.
Other issues related to development of the project.
- Aesthetics: The project will impact the visual landscape in two principal ways: (1) the buildings on the site and (2) the steam plume that will be emitted and most evident on cold days. The site is in an extremely scenic natural location, on the banks of the Hoosic River and surrounded by mountains. At the same time, a large decrepit grandstand, a relic of a former racetrack, dominates the site and detracts from the visual quality of the landscape. The new buildings on the site will be prominent, but properly sited and maintained, would not further degrade the visual character of the area as viewed from US 7. The steam plume would be visible over a much larger distance. Currently, two public schools and a college in Bennington that use biomass heating systems emit steam plumes which are noticeable from many locations around that town. The appearance of the plume at the Beaver Wood Energy site would be similar, but would be discharged higher into the atmosphere from a stack approximately 200 feet in height. On days with significant wind, the steam would dissipate relatively quickly, but on calm days it would rise to a considerable altitude and remain very much in evidence. The significance of this impact to the visual landscape of the valley should be given due consideration.
- Property Values: With real estate prices having fallen dramatically over the past two to three years, residents in the vicinity of the proposed facility are understandably concerned over further losses in the value of their properties. Studies have shown that proximity to an industrial facility reduces property values, but that the effect falls off fairly quickly with distance. The number of properties likely to be affected and the magnitude of the impact should be given full and careful consideration.
- Economy: The potential positive economic impacts of a biomass energy project in the region are considerable, including creation of jobs at the facility, support jobs in logging and transportation, and reducing the outflow of dollars to purchase energy from distant locations. The payroll generated by the facility will lead to secondary impacts (multiplier effects) as that money is spent in local businesses. Property tax revenues would reduce residential tax bills locally and provide some funding for education statewide. Although the general trend is that increased levels of development in a community lead to an increased demand for services and thus an increase in public expenditures, utilities tend to have a relatively modest impact on the demand for services.
- Jurisdictional Issues: The Town of Pownal maintains that the wood pellet manufacturing facility is separate from the electricity generating utility portion of the project and should be subject to local zoning review (and assumedly Act 250 review as well). The Energy Committee does not offer an opinion on this issue, noting only that although key aspects of the facilities’ operations are integrated, they could be constructed and operated individually.
The Bennington Regional Energy Plan supports the use of locally available resources to develop renewable energy projects in the region. The Energy Plan seeks first and foremost to encourage energy conservation, but recognizing that our basic energy needs must be met, identifies local resources (such as woody biomass) that hold promise as sources of renewable energy. Even though electricity generation does not represent the most efficient uses of biomass, it does have considerable value and can be complementary to other uses of the regional biomass resource. An electricity generating facility would ideally be sited and scaled so that its waste heat could be most efficiently used for space heating, although the proposed pellet manufacturing operation would benefit from the heat energy that would otherwise be lost.
Pellet fuel, despite its low net energy yield, has certain advantages and would be most beneficial if local markets were developed so that the energy does not have to be exported from the region.
Great care must be taken to ensure that the extensive logging needed to fuel this project does not damage natural resources and reduce the productive capacity of the forest.
Because large-scale biomass energy projects such as the Beaver Wood Energy facility are marginal in terms of net energy yield, there are concerns over the sustainability of the project. Procurement and transport of the large quantities of biomass fuel necessary for this project require large amounts of fossil (diesel) fuel that will be increasingly expensive and probably periodically unavailable. A smaller-scaled project would use less fuel for transportation, result in reduced environmental impacts, and would likely be more sustainable. If the Beaver Wood Energy project cannot be sustained in the future because of cost, disruptions in the supply of diesel fuel, or other reasons, plans should be in place to allow it to be decommissioned and the site returned to productive use. As long as the plant does operate, it will have a beneficial effect on the regional economy.
The location of the proposed facility presents difficult challenges in terms of truck traffic and potential impacts to air quality, water quality, and water supply. State regulators must rigorously examine the project to ensure that public health and safety and important natural systems are not compromised.