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HomeMy WebLinkAboutCOM 0571.004 2020-2022 Comm. N Ref. To: Q, Zo� Ref. Dote FEB 2012 2 LIU From: tawn UU U 1% 1 U, ir, a Sent: Monday, February 07, 2022 8:40 AM prn To: Council Testimony Y t Subject: Testimony: Regenerative Agriculture, Wate, Energy and Environmental Magement Committee 2/8/22 Testimony before the Regenerative Agriculture, Water, Energy and Environmental Management Committee 2/8/22 Subject: Renewable Energy Update by Hawaiian Electric Comments regarding 'Bioenergy' Let me encapsulate the concerns about 'bioenergy' in Hawaii by looking at the proposed wood burning power facility on the Big Island, Hu Honua. These comments are primarily in regard to greenhouse gas emissions. Hu Honua will emit 2.2x more Greenhouse Gas per KWh electricity produced than the Big Island's largest power plant, Hamakua Energy Partners, which burns kerosene. Solar Plus Storage facilities on the Big Island will charge Hawaiian Electric $0.08 per KWh of electricity produced. Hu Honua proposes charging initially$0.22 per KWh increasing above $.30 per KWh, approximately 3x the charges of the Solar Plus Storage projects. Hu Honua discloses in their 2019 GHG Analysis that it will emit approximately 2.1x more GHG per KWh electricity produced than the fossil fuel facilities which it replaces: https://drive.google.com/file/d/1 tLYoCgzly5y7e_TrYpxgtC6cAnrJ8Y80/view?usp=sharing The DCCA Consumer Advocate at the PUC has submitted testimony that 58% of the electricity generation which Hu Honua would replace would be other renewable sources (zero emitting wind, solar or geothermal)whereas 42% would be fossil fuels. The Consumer Advocate submitted testimony to the PUC on September 17, 2021 stating "... approval of the (Hu Honua)A&R PPA (Power Purchase Agreement)does not seem reasonable or in the public interest at this time." 'Without additional justification, there are GHG emissions, environmental, health, and customer impact concerns that do not support a favorable ruling by the Commission." Ililani Media Sept. 17 2021 Critique: Burning Trees as Fuel to Generate Electricity- Hu Honua and AES Critical examination suggests that burning chipped or pelletized trees as fuel for electricity generation at the Big Island's Hu Honua or, as proposed, at Oahu's AES Power Station will be worse for greenhouse gas emissions and global warming than burning coal. Allow me to begin with excerpts from a Letter signed by 500 Expert Scientists in Feb. 2021 to leaders of the US, EU, Japan and Korea regarding Bioenergy. (Please access the below link to see the impressive credentials of the signatories, which includes a former chair of the UN Intergovernmental Panel on Climate Change, a US National Medal of Science winner, President of the European Academies of Science, etc.) "The undersigned scientists and economists commend each of you for the ambitious goals you have announced for the United States, the European Union, Japan and South Korea to achieve carbon neutrality by 2050. Forest preservation and restoration should be key tools for achieving this goal and simultaneously helping to address our global biodiversity crisis. We urge you not to undermine both climate goals and the world's biodiversity by shifting from burning fossil fuels to burning trees to generate energy.,, "In recent years, there has been a misguided move to cut down whole trees or to divert large portions of stem wood for bioenergy, releasing carbon that would otherwise stay locked up in forests." "The result of this additional wood harvest is a large initial increase in carbon emissions .... As numerous studies have shown, this burning of wood will increase warming for decades to centuries. That is true even when the wood replaces coal, oil or natural gas." "Overall, for each kilowatt hour of heat or electricity produced, using wood initially is likely to add two to three times as much carbon to the air as using fossil fuels." Government subsidies for burning wood create a double climate problem because this false solution is replacing real carbon reductions. Companies are shifting fossil energy use to wood, which increases warming, as a substitute for shifting to solar and 1 wind, which would truly decrease warming." "To avoid these harms, governments must end subsidies and other incentives that today exist for the burning of wood whether from their forests or others. The European Union needs to stop treating the burning of biomass as carbon neutral in its renewable energy standards and in its emissions trading system. Japan needs to stop subsidizing power plants to burn wood. And the United States needs to avoid treating biomass as carbon neutral or low carbon as the new administration crafts climate rules and creates incentives to reduce global warming." Access the full text and list of the 500 signatories here: https://www.documentcloud.org/documents/20482842-scientist-leter-to-biden-van-der-leyden-michel-suga-moon-february-11- 2021 Let's look at the information which serves as background for the conclusions endorsed by the above scientists and experts. Two such 'Bioenergy' power stations have been proposed for Hawaii. First, Hu Honua Bioenergy, a partially built station on the Big Island, and Oahu's AES facility which must end coal use in 2022. 1. It is well known that burning pelletized or chipped whole green trees for power gives rise to 1.5x more greenhouse gas emissions (CO2e)than burning Coal, per KWh electricity produced. The IPCC Taskforce on Greenhouse Gas Inventories (2006) identifies that'in the smokestack' the burning of wood pellets or chips releases 1.25x more CO2(e) (GHG)than the burning of coal. Burning wood for electricity has an 'efficiency' of 26%while burning coal's efficiency is 33%. The diminished 'efficiency' of burning chipped green trees compared to burning coal brings emissions per KWh of electricity produced by burning wood to 1.5x more CO2(e)produced than by burning Coal. Though many references could be cited endorsing this finding, the IPCC Inventory and the below referenced Laganiere study are foundational. Range and Uncertainties in Estimating Delays in Greenhouse Gas Mitigation Potential of Forest Bioenergy Sourced From Canadian Forests Laganiere, et. al. (2017),5KG Global Change Biology: Bioenergy 2017 Volume 9 page 361 https://onIinelibrary.wiley.com/doi/pdf/l 0.1111/gcbb.12327 2. Again referencing the IPCC Task Force on Greenhouse Gas Inventories, the emissions produced by burning chipped or pelletized whole green trees produces 1.5x more GHG emissions than burning coal, 2.2x more CO2(e) (greenhouse gas)than burning oil, and 3x more CO2(e)than burning natural gas, per KWh of electricity produced. Big Island's largest power facility, Hamakua Energy Partners, burns jet fuel (Kerosene). Hu Honua will emit 2.2x more Greenhouse gas per KWh of electricity produced than that facility. Proposed and currently being built Solar plus Storage facilities on the Big Island will charge Hawaiian Electric$.08 per KWh of electricity produced. Hu Honua proposes charging initially$.22 per KWh increasing toward $.30 per KWh, approximately 3x the charges of the Solar plus storage projects. 3. Hu Honua will produce up to 21.5 MWh of electricity. Hu Honua's Clean Air Permit identifies GHG emissions as 293,000 tons CO2(e) per year. Hu Honua applied in 2019 to amend its permit by cancelling the GHG emissions from burning the wood fuel because of'carbon neutrality'of bioenergy. It let this application lapse (or withdrew it)after it was pointed out (by myself)in the Public testimony phase of the application that Kamehameha Schools was on record that they would not be regrowing the forest after initial harvest. See Attachment. Federal Statute and EPA directive require that the harvested forest be regrown in order that 'bioenergy' be considered carbon neutral or'renewable energy'. (The Clean Air Branch engineer reviewer expressed to me that mine was the only submitted Testimony to which he wrote a response, in that he had conversed with EPA(San Francisco) and Hawaii Attorney General's office several times in relation to this observation.) 4. The AES Coal power station on Oahu annually produces 200 Megawatts of electricity with 1,700,000 tons CO2(e) emissions. If we assume a linear relationship exists between energy production and GHG emissions in terms of CO2(e), and we take Hu Honua's electricity production at 21.5 MWh and its CO2(e) emissions at 293,000 tons, then extrapolation to AES conversion to wood fuel (generating the same 200 MWh energy)would be associated with an increase in CO2(e)from it's current 1.7million tons to 2.7 million tons CO2(e)yearly. This is 1.6x more CO2(e)than it now produces. Again, this assumes an approximately linear relationship between energy generation and CO2(e)emissions, given the same fuel source. 5. The scientific community's model of emissions for wood burning power stations arrives at a 1.5x greater GHG emissions than burning Coal. Extrapolation from Hu Honua's Clean Air Permit GHG emissions calculation to AES' conversion to burning wood (at 200 MWh production) calculates to 1.6x greater GHG emissions than burning coal. This convergence seems confirmatory. 6. Contention exists that the carbon released into the atmosphere by burning trees will be sequestered by the new growth of trees and thereby carbon neutrality will arise. This contention has been memorialized by Federal Statute and EPA directive. However, it must also be realized that twice, once in 2012 and again in 2019 the Science Advisory Board of the EPA has refused a requested endorsement of the EPA's policy of carbon neutrality of bioenergy because in the words of the SAB, "the feedstock and the time frame for carbon neutrality must be specified." Regarding 'feedstock', it is agreed that burning waste wood from industrial processes is carbon neutral because the wood waste would decompose releasing equivalent GHG. Hu Honua and AES will be using only minimal amounts of wood waste. Their fuel will be chipped or pelletized whole green trees. Burning 'green trees' could, over a time frame from several decades to a century or more, be carbon neutral, depending on 2 various factors, primarily the time to reach the equivalent mass of the harvested trees plus the harvesting and transport emissions. The conclusion therefore that is emphasized by the Science Advisory Board, leading to refusal of endorsement of the EPA policy of Carbon neutrality, is that the time frame must be specified. The EPA's time frame reference for carbon neutrality of bioenergy is 100 years, considered as one typical life cycle of forest trees. This time frame reference, in respect to our current Climate Crisis, is inappropriate. Reference: Science Advisory Board Review of Framework for Assessing Biogenic CO2 Emissions from Stationary Sources (March 5, 2019) https:HYosemite.epa.gov/sab/sabproduct.nsf/0/686C81 BACFAF9735852583B4005B3318/$File/EPA-SAB-1 9- 002+.pdf Science Advisory Board Review of EPA's Accounting Framework for Biogenic CO2 Emissions from Stationary Sources (September 28, 2012) https:fVosemite.epa.gov/sab/sabproduct.nsf/57B7A4F1987D7F7385257A87007977F6/$File/EPA- SAB-12-011-unsigned.pdf SAB Sends Letter to EPA regarding Review of Biogenic Framework- Biomass Magazine http://biomassmagazine.com/articles/16050/sab-sends-letter-to-epa-regarding-review-of-biogenic-framework 7. Contemporary research suggests that, following clear cut harvest of forested lands (the harvest method that would be employed by both Hu Honua and AES)those harvested lands will continue to be a net emitter of CO2 into the atmosphere, due to oxidation and release of stored soil carbon,for as long as 20 years, irrespective of regrowth of trees. Hu Honua proposes a 7 year harvest cycle. Please access this 7 minute presentation: https://www.youtube.com/watch?v=LDdKOmviKyg 8. How long does it take after harvest before re-sequestration reaches Carbon neutrality by regrowth of trees? How long to reach parity with burning Coal?A literature search finds only one source for these computations: the Government of Canada website, Bioenergy Greenhouse Gas Calculator(Exploration of this tool is strongly recommended). See < https:lLapps-scf-cfs.rncan..qc.ca/calc/en/bioenergy-calculator > This website calculates cumulative GHG emissions over time from burning trees for power compared to burning either natural gas or oil or coal. In addition to the comparison with coal, oil or natural gas, the site allows designation of speed of tree growth and distance and mode of transport to the generation facility. (I have seen no United States governmental or industrial resource which provides any similar comparison or computations.) 9. The above parameters are entered and calculated for the proposed bioenergy facility Hu Honua and presented in the Attachment. As the proposal for the AES power station becomes clarified as to where and what feedstock would be sourced, those data can be substituted. For Hu Honua with 'fast growth' trees and 50 kilometers average transport (Pahala,Waipio, etc., to Pepeekeo), the graph in the attachment shows a 'best case' and 'worst case' scenario (blue and red colored lines) in comparing the burning of chipped trees with burning Coal in Cumulative CO2(e)emissions. Where the lines cross '0' is the point of parity with burning Coal, NOT the point of'carbon neutrality'. This shows, for the example of Hu Honua, that the 'best case' for burning chipped green trees for power gives more accumulated Greenhouse Gasses than burning Coal for 70 years. As can be seen, it is more likely that the accumulated GHGs from burning wood chips will be worse than coal 'indefinitely'. For Hu Honua, the sequestration of CO2 by regrowth of trees is unlikely to ever reach carbon neutrality. 10. The State of Hawaii has recently announced a plan to plant or protect 100 million trees by 2030 for the purposes of carbon sequestration, addressing climate change. DLNR will not want to give up the much needed lands or trees for this purpose to any plantings that propose a seven year harvest cycle. Also, any announcement of planting more trees, such as the Hamakua Eucalyptus grandis, on the Big Island for the purpose of burning (especially on Oahu)would certainly be met with widespread hostility. Kamehameha Schools has announced that they will not regrow the 12,000 acres of trees on their Big Island Properties once they are initially harvested for Hu Honua (and therefore it is presumed that Hu Honua will be importing wood pellets from the Continental Americas or Oceania, as no other Hawaii source has been identified). Given that AES' need is for 200,000 to 300,000 acres of trees (as opposed to Hu Honua's 20,000 acres of trees)this will not be sourced in the islands. As some have argued for bioenergy in order to make Hawaii energy independent, the fact that fuel for these facilities will still end up coming from distant sources belies this argument. 11. It should be cautioned that the voices reflected in the 500 Scientists' letter are beginning to be heard by policymakers. The current drift in biomass policy and media discussions suggests, because of the reasons pointed out by those scientists, that within the next several years all subsidies and RPS considerations of biomass as carbon neutral will be withdrawn. See: https: lnews.mongabay.com/2021/03/dutch-to-limit-forest-biomass-subsidies-possibly-signaling-eu-sea- changel From National Geographic, November,2021, we find the following statement under the Tagline: "As world leaders pledge more action on climate change, one so-called solution—burning trees for electricity—could undermine progress." That statement: "In the European Union's "Fit for 55"framework for reducing emissions by 55 percent by 2030, biomass energy is still labeled as carbon neutral. But in a report published in 2018, the U.K.'s Committee on Climate Change said biomass energy should be limited. The country has contracts extending subsidies through 2027, but when they end, the committee discouraged further use." The unfolding realities of the climate crisis will overtake the convenient economic considerations of bioenergy as GHG neutral. This will lead to closure of most, if not all, bioenergy stations. 3 Mahalo for consideration of the above discussion. Tawn Keeney MD 4