The California Environmental Quality Act (CEQA) requires that an Environmental Impact Report address the project’s impacts on global warming and climate change. The EIR prepared for the Roseburg Biomass plant failed to do this adequately.
• It did not provide CO2 emissions data, analysis, and mitigations for the entire project, including from diesel emissions.
• It incorrectly states the project is "carbon neutral," using outdated IPPC (Intragovernmental Panel on Climate Change) guidelines (www.ipcc.ch).
The wood-fired power plant will:
• burn the equivalent of 250 cords of wood per day
• add new diesel truck traffic
• remove stored carbon from forests, now known to be an important global carbon sink.
Yet the EIR provides no data, calculation, or technical analysis to support its conclusion that the greenhouse gas (GHG) emission impact will be less than significant.
No estimates of greenhouse gas emissions
The California legislature has found that “global warming poses a serious threat to the economic well-being, public health, natural resources, and the environment of California.” (HSC 38501.a). Yet the project EIR makes no attempt to estimate the current levels of greenhouse gas emissions of the existing plant, much less the increases that the biomass plant will cause.
No mitigation measures
The project as approved offers no feasible mitigation measures, nor offers substantial evidence that such mitigation measures are infeasible – all in violation of CEQA. Instead the EIR claims that greenhouse gas (GHG) emission analysis and climate change is a field that is "too young" to study for this biomass project. This is no excuse; other agencies throughout California, including Shasta County, are evaluating and mitigating GHG impacts of their projects now.
Biomass not carbon-neutral
Biomass burning (usually of wood products and byproducts) is not carbon neutral. Energy generated through combustion of biomass may result in fewer carbon emissions than energy generated through combustion of fossil fuels—and that’s good—but that doesn’t mean that biomass is “zero emission” fuel. Growing trees absorb carbon dioxide, thereby slowing global warming through a process called carbon sequestration. Recent studies demonstrate that forests fifteen years and older are an important active carbon sink, and collectively act as a storehouse for up to 10 percent of the world's total net CO2 uptake. As noted in the EIR, Roseburg will obtain some of its biomass wood from logging live trees that otherwise would have held or sequestered carbon in the trunks, limbs and roots—banking some of the carbon in the soil too. When cut and burned, the trees' CO2 is released into the atmosphere immediately rather than gradually over hundreds of years. The EIR should assess the cumulative global warming impacts of RFP’s entire logging and veneer operation, not solely the emissions from the stack.
Logging Releases Significant Amounts of Carbon
Scientists estimate that a large fraction of all the carbon transferred to the atmosphere by humans has been released due to forest exploitation. In recent decades CO2 emissions resulting from human-induced changes to forests exceed CO2 emissions from all motor vehicle sources combined (although forest releases are less than total emissions from all uses of fossil fuels). Fewer trees means less carbon sequestration, which leads to more global warming.
Short-rotation clear cutting typically practiced by private industrial forest land-owners is probably the worst possible way to manage forests for carbon storage, because the young forests never develop large carbon stores; significant soil carbon is lost during and after clear cutting, slash disposal, and site preparation; and the resulting wood products produced have limited longevity.
Roseburg has claimed their wood-fired power plant will encourage land-owners to thin their forest land, thereby preventing catastrophic, carbon-releasing fires. This sounds great on the surface, but in fact forest thinning can never provide adequate fuel for the biomass plant.
Removing too much fuel makes forests hotter, dryer, and windier, thereby increasing fire hazard and decomposition rates, both of which counter carbon storage and other objectives. Thinning should be limited to undergrowth and small trees growing close together, neither of which provide much biomass. And much of that is best chipped and left on the forest floor to build up the soil.
California Attorney General’s statement
The California Attorney General’s office is taking a strong role in requiring counties to adequately address global warming. In fact, The Attorney General’s office has very recently reminded Siskiyou County planning officials that they are required to evaluate such GHG impacts (for the Nestle Water’s project), and offer effective mitigations. (Letter from Attorney General’s Office, to Siskiyou County Planning Department, July 28, 2008.)
To quote from the Attorney General letter:
"The DEIR fails to analyze the global warming impacts resulting from the Project. Global warming presents serious challenges to California and the Nation. All phases of a project must be considered when evaluating is impact on the environment. The diesel truck emissions from this project will result in releases of both carbon dioxide and diesel soot. Yet the DEIR entirely fails to address global warming resulting from either pollutant. Diesel soot – or black carbon – has been identified as a substantial contributor to global warming. Because the EIR omits any discussion of the emissions of carbon dioxide and diesel soot resulting from the project, it is impossible to determine the full extent of the impact of these emissions. Further, because they are not identified, they are also not mitigated where feasible, as required by CEQA. The DEIR fails to discuss emissions of ozone, carbon dioxide and PM2.5 that will result from hundreds of diesel truck trips every day."
These criticisms are similarly applicable to the deficient EIR prepared for the Roseburg biomass power plant project.
Mitigations possible
So much of today’s industry contributes to greenhouse gases; it may be impossible for most industries to function without releasing carbon. Obviously, the first place to look for mitigations is the central operation itself. Unfortunately, even if Roseburg were to install the very best air pollution control technology, the power plant would still produce carbon dioxide—just less than burning fossil fuels. There’s no way around that.
However, many businesses are making good faith mitigation efforts elsewhere in their operations or in the community. Here are some of the mitigations that could be adopted to help offset carbon emissions for this project:
1. Convert as many company vehicles as possible to hybrid or electric.
2. Plant hundreds of trees around the facility (which would also provide visual screening and some noise reduction).
3. Require all trucks delivering or picking up materials to turn off their engines when stopped or parked at the facility.
4. Stop clear-cutting and institute more sustainable logging practices for the veneer plant.
5. Use horse logging to cut and bring logs out to access roads, and/or use smaller logging machines that do less collateral damage to the soil and vegetation.
6. Green up the offices at the plant: Florescent light bulbs and LEDs throughout, electron ballasts for florescent tubes.
7. Turn down thermostats in winter, up in summer.
8. Install heat pumps for heating and cooling.
9. Make it a policy to turn off equipment, computers, lights, etc. overnight or when not in use for long periods of time.
10. Donate to expand public transportation systems
