Tag Archives: Clean Power Plan

Hey, EU!! Wood may be a Renewable Energy Source, but it isn’t a Clean Energy Source

EU policy background

The United Nations Framework Convention on Climate Change (The Paris Agreement) entered into force on 4 November 2016. To date, the Paris Agreement has been ratified by 122 of the 197 parties to the convention. This Agreement does not define renewable energy sources, and does not even use the words “renewable,” “biomass,” or “wood”. You can download this Agreement at the following link:


The Renewable Energy Policy Network for the 21st Century (REN21), based in Paris, France, is described as, “a global renewable energy multi-stakeholder policy network that provides international leadership for the rapid transition to renewable energy.” Their recent report, “Renewables 2016 Global Status Report,” provides an up-to-date summary of the status of the renewable energy industry, including the biomass industry, which accounts for the use of wood as a renewable biomass fuel. The REN21 report notes:

“Ongoing debate about the sustainability of bioenergy, including indirect land-use change and carbon balance, also affected development of this sector. Given these challenges, national policy frameworks continue to have a large influence on deployment.”

You can download the 2016 REN21 report at the following link:


For a revealing look at the European Union’s (EU) position on the use of biomass as an energy source, see the September 2015 European Parliament briefing, “Biomass for electricity and heating opportunities and challenges,” at the following link:


Here you’ll see that burning biomass as an energy source in the EU is accorded similar carbon-neutral status to generating energy from wind, solar and hydro. The EU’s rationale is stated as follows:

“Under EU legislation, biomass is carbon neutral, based on the assumption that the carbon released when solid biomass is burned will be re-absorbed during tree growth. Current EU policies provide incentives to use biomass for power generation.”

This policy framework, which treats biomass as a carbon neutral energy source, is set by the EU’s 2009 Renewable Energy Directive (Directive 2009/28/EC), which requires that renewable energy sources account for 20% of the EU energy mix by 2020. You can download this directive at the following link:


The EU’s equation seems pretty simple: renewable = carbon neutral

EU policy assessment

In 2015, the organization Climate Central produced an assessment of this EU policy in a three-part document entitled, “Pulp Fiction – The European Accounting Error That’s Warming the Planet.” Their key points are summarized in the following quotes extracted from “Pulp Fiction”:

“Wood has quietly become the largest source of what counts as ‘renewable’ energy in the EU. Wood burning in Europe produced as much energy as burning 620 million barrels of oil last year (both in power plants and for home heating). That accounted for nearly half of all Europe’s renewable energy. That’s helping nations meet the requirements of EU climate laws on paper, if not in spirit.”

Pulp Fiction chart

“The wood pellet mills are paying for trees to be cut down — trees that could be used by other industries, or left to grow and absorb carbon dioxide. And the mills are being bankrolled by climate subsidies in Europe, where wood pellets are replacing coal at a growing number of power plants.”

”That loophole treats electricity generated by burning wood as a ‘carbon neutral’ or ‘zero emissions’ energy source — the same as solar panels or wind turbines. When power plants in major European countries burn wood, the only carbon dioxide pollution they report is from the burning of fossil fuels needed to manufacture and transport the woody fuel. European law assumes climate pollution released directly by burning fuel made from trees doesn’t matter, because it will be re-absorbed by trees that grow to replace them.”

“Burning wood pellets to produce a megawatt-hour of electricity produces 15 to 20 percent more climate-changing carbon dioxide pollution than burning coal, analysis of Drax (a UK power plant) data shows. And that’s just the CO2 pouring out of the smokestack. Add in pollution from the fuel needed to grind, heat and dry the wood, plus transportation of the pellets, and the climate impacts are even worse. According to Enviva (a fuel pellet manufacturer), that adds another 20 percent worth of climate pollution for that one megawatt-hour.”

“No other country or U.S. region produces more wood and pulp every year than the Southeast, where loggers are cutting down roughly twice as many trees as they were in the 1950s.”

“But as this five-month Climate Central investigation reveals, renewable energy doesn’t necessarily mean clean energy. Burning trees as fuel in power plants is heating the atmosphere more quickly than coal.”

You can access the first part of “Pulp Fiction” at the following link and then easily navigate to the other two parts.


In the U.S., the Natural Resources Defense Council (NRDC) has made a similar finding. Check out the NRDC’s May 2015 Issue Brief, “Think Wood Pellets are Green? Think Again,” at the following link:


NRDC examined three cases of cumulative emissions from fuel pellets made from 70%, 40% and 20% whole trees. The NRDC chart for the 70% whole tree case is shown below.

NRDC cumulative emissions from wood pellets

You can see that the NRDC analysis indicates that cumulative emissions from burning wood pellets exceeds the cumulative emissions from coal and natural gas for many decades. After about 50 years, forest regrowth can recapture enough carbon to offset the cumulative emissions from wood pellets to below the levels for of fossil fuels. It takes about 15 – 20 more years to reach “carbon neutral” (zero net CO2 emissions) in the early 2080s.

The NRDC report concludes

“In sum, our modeling shows that wood pellets made of whole trees from bottomland hardwoods in the Atlantic plain of the U.S. Southeast—even in relatively small proportions— will emit carbon pollution comparable to or in excess of fossil fuels for approximately five decades. This 5-decade time period is significant: climate policy imperatives require dramatic short-term reductions in greenhouse gas emissions, and emissions from these pellets will persist in the atmosphere well past the time when significant reductions are needed.“

The situation in the U.S.

The U.S. Clean Power Plan, Section V.A, “The Best System of Emission Reduction,” (BSER) defines EPA’s determination of the BESR for reducing CO2 emissions from existing electric generating units. In Section V.A.6, EPA identifies areas of compliance flexibility not included in the BESR. Here’s what EPA offers regarding the use of biomass as a substitute for fossil fuels.


This sounds a lot like what is happening at the Drax power plant in the UK, where three of the six Drax units are co-firing wood pellets along with the other three units that still are operating with coal.

Fortunately, this co-firing option is a less attractive option under the Clean Power Plan than it is under the EU’s Renewable Energy Directive.

You can download the EPA’s Clean Power Plan at the following link:


On 9 February 2016, the U.S. Supreme Court stayed implementation of the Clean Power Plan pending judicial review.

In conclusion

The character J. Wellington Wimpy in the Popeye cartoon by Hy Eisman is well known for his penchant for asking for a hamburger today in exchange for a commitment to pay for it in the future.


It seems to me that the EU’s Renewable Energy Directive is based on a similar philosophy. The “renewable” biomass carbon debt being accumulated now by the EU will not be repaid for 50 – 80 years.

The EU’s Renewable Energy Directive is little more than a time-shifted carbon trading scheme in which the cumulative CO2 emissions from burning a particular carbon-based fuel (wood pellets) are mitigated by future carbon sequestration in new-growth forests. This assumes that the new-growth forests are re-planted as aggressively as the old-growth forests are harvested for their biomass fuel content. By accepting this time-shifted carbon trading scheme, the EU has accepted a 50 – 80 year delay in tangible reductions in the cumulative emissions from burning carbon-based fuels (fossil or biomass).

So, if the EU’s Renewable Energy Directive is acceptable for biomass, why couldn’t a similar directive be developed for fossil fuels, which, pound-for-pound, have lower emissions than biomass? The same type of time-shifted carbon trading scheme could be achieved by aggressively planting new-growth forests all around the world to deliver the level of carbon sequestration needed to enable any fossil fuel to meet the same “carbon neutral” criteria that the EU Parliament, in all their wisdom, has applied to biomass.

If the EU Parliament truly accepts what they have done in their Renewable Energy Directive, then I challenge them to extend that “Wimpy” Directive to treat all carbon-based fuels on a common time-shifted carbon trading basis.

I think a better approach would be for the EU to eliminate the “carbon neutral” status of biomass and treat it the same as fossil fuels. Then the economic incentives for burning the more-polluting wood pellets would be eliminated, large-scale deforestation would be avoided, and utilities would refocus their portfolios of renewable energy sources on generators that really are “carbon neutral”.

U.S. Energy Information Administration’s (EIA) Early Release of a Summary of its Annual Energy Outlook (AEO) Provides a Disturbing View of Our Nation’s Energy Future

Each year, the EIA issues an Annual Energy Outlook that provides energy industry recent year data and projections for future years. The 2016 AEO includes actual data of 2014 and 2015, and projections to 2040. These data include:

  • Total energy supply and disposition demand
  • Energy consumption by sector and source
  • Energy prices by sector and source
  • Key indicators and consumption by sector (Residential, Commercial, Industrial, Transportation)
  • Electricity supply, disposition, prices and emissions
  • Electricity generating capacity
  • Electricity trade

On 17 May, EIA released a PowerPoint summary of AEO2016 along with the data tables used in this Outlook.   The full version of AEO2016 is scheduled for release on 7 July 2016.

You can download EIA’s Early Release PowerPoint summary and any of the data tables at the following link:


EIA explains that this Summary features two cases: the Reference case and a case excluding implementation of the Clean Power Plan (CPP).

  • Reference case: A business-as-usual trend estimate, given known technology and technological and demographic trends. The Reference case assumes Clean Power Plan (CPP) compliance through mass-based standards (emissions reduction in metric tones of carbon dioxide) modeled using allowances with cooperation across states at the regional level, with all allowance revenues rebated to ratepayers.
  • No CPP case: A business-as-usual trend estimate, but assumes that CPP is not implemented.

You can find a good industry assessment of the AEO2016 Summary on the Global Energy World website at the following link:


A related EIA document that is worth reviewing is, Assumptions to the Annual Energy Outlook 2015, which you will find at the following link:


This report presents the major assumptions of the National Energy Modeling System (NEMS) used to generate the projections in AE02015. A 2016 edition of Assumptions is not yet available. The functional organization of NEMS is shown below.


The renewable fuels module in NEMS addresses solar (thermal and photovoltaic), wind (on-shore and off-shore), geothermal, biomass, landfill gas, and conventional hydroelectric.

The predominant renewable sources are solar and wind, both of which are intermittent sources of electric power generation. Except for the following statements, the EIA assumptions are silent on the matter of energy storage systems that will be needed to manage electric power quality and grid stability as the projected use of intermittent renewable generators grows.

  • All technologies except for storage, intermittents and distributed generation can be used to meet spinning reserves
  • The representative solar thermal technology assumed for cost estimation is a 100-megawatt central-receiver tower without integrated energy storage
  • Pumped storage hydroelectric, considered a nonrenewable storage medium for fossil and nuclear power, is not included in the supply

In my 4 March 2016 post, “Dispatchable Power from Energy Storage Systems Help Maintain Grid Stability,” I addressed the growing importance of such storage systems as intermittent power generators are added to the grid. In the context of the AEO, the EIA fails to address the need for these costly energy storage systems and they fail to allocate the cost of energy storage systems to the intermittent generators that are the source of the growing demand for the energy storage systems. As a result, the projected price of energy from intermittent renewable generators is unrealistically low in the AEO.

Oddly, NEMS does not include a “Nuclear Fuel Module.” Nuclear power is represented in the Electric Market Module, but receives no credit as a non-carbon producing source of electric power. As I reported in my posts on the Clean Power Plan, the CPP gives utilities no incentives to continue operating nuclear power plants or to build new nuclear power plants (see my 27 November 2015 post, “Is EPA Fudging the Numbers for its Carbon Regulation,” and my 2 July 2015 post, “EPA Clean Power Plan Proposed Rule Does Not Adequately Recognize the Role of Nuclear Power in Greenhouse Gas Reduction.”). With the current and expected future low price of natural gas, nuclear power operators are at a financial disadvantage relative to operators of large central station fossil power plants. This is the driving factor in the industry trend of early retirement of existing nuclear power plants.

The following 6 May 2016 announcement by Exelon highlights the current predicament of a high-performing nuclear power operator:

“Exelon deferred decisions on the future of its Clinton and Quad Cities plants last fall to give policymakers more time to consider energy market and legislative reforms. Since then, energy prices have continued to decline. Despite being two of Exelon’s highest-performing plants, Clinton and Quad Cities have been experiencing significant losses. In the past six years, Clinton and Quad Cities have lost more than $800 million, combined.“

“Exelon announced today that it will need to move forward with the early retirements of its Clinton and Quad Cities nuclear facilities if adequate legislation is not passed during the spring Illinois legislative session, scheduled to end on May 31 and if, for Quad Cities, adequate legislation is not passed and the plant does not clear the upcoming PJM capacity auction later this month.”

“Without these results, Exelon would plan to retire Clinton Power Station in Clinton, Ill., on June 1, 2017, and Quad Cities Generating Station in Cordova, Ill., on June 1, 2018.”

You can read Exelon’s entire announcement at the following link:


Together the Clinton and Quad Cities nuclear power plants have a combined Design Electrical Rating of 2,983 MWe from a non-carbon producing source. For the period 2013 – 2015, the U.S. nuclear power industry as a whole had a net capacity factor of 90.41. That means that the nuclear power industry delivered 90.41% of the DER of the aggregate of all U.S. nuclear power plants. The three Exelon plants being considered for early retirement exceeded this industry average performance with the following net capacity factors: Quad Cities 1 @ 101.27; Quad Cities 2 @ 92.68, and Clinton @ 91.26.

For the same 2013 – 2015 period, EIA reported the following net capacity factors for wind (32.96), solar photovoltaic (27.25), and solar thermal (21.25).  Using the EIA capacity factor for wind generators, the largest Siemens D7 wind turbine, which is rated at 7.0 MWe, delivers an average output of about 2.3 MWe. We would need more than 1,200 of these large wind turbines just to make up for the electric power delivered by the Clinton and Quad Cities nuclear power plants. Imagine the stability of that regional grid.

CPP continues subsidies to renewable power generators. In time, the intermittent generators will reduce power quality and destabilize the electric power grid unless industrial-scale energy storage systems are deployed to enable the grid operators to match electricity supply and demand with reliable, dispatchable power.

As a nation, I believe we’re trending toward more costly electricity with lower power quality and reliability.

I hope you share my concerns about this trend.

Is EPA Fudging the Numbers for its Carbon Regulation?

In my 2 July 2015 post, I commented on significant deficiencies in the U.S. Environmental Protection Agency (EPA) Clean Power Plan proposed rule. On 3 August 2015, the EPA announced the final rule. You can read the final rule for existing power plants, the EPA’s regulatory impact analysis, and associated fact sheets at the following link:


The Institute for Energy Research (IER) is a not-for-profit organization that conducts research and analysis on the functions, operations, and government regulation of global energy markets. The IER home page is at the following link:


On 24 November 2015, the IER published an insightful article entitled, Is EPA Fudging the Numbers for its Carbon Regulation?, which I believe is worth your attention. The IER’s main points are:

  1. U.S. Energy Information Agency’s (EIA) Annual Energy Outlook (AEO) is the data source usually used by federal government agencies in their analysis of energy issues.
  2. EPA stands out as an exception. It frequently chooses not to use EIA data, and instead develops it’s own duplicative, different data.
  3. In the case of the Clean Power Plan, the EPA’s own data significantly underestimates the number of coal plants that need to be retired to comply with the Plan. The result is a much lower estimate of the economic impact of the Plan than if EIA data had been used.

It appears to me that the EPA created and used data skewed to produce a more favorable, but likely unrealistic, estimate of the economic impact that will borne by the U.S. power industry and power customers as the Clean Power Plan is implemented. Form your own opinion after reading the full IER article at the following link:


Update 19 Feb 2016

On 8 February 2016, the American Nuclear Society (ANS) released their, “Nuclear in the States Toolkit Version 1.0 – Policy Options for States Considering the Role of Nuclear Power in Their Energy Mix.” The toolkit catalogs policies related to new and existing nuclear reactors for state policymakers to consider as they draft their Clean Power Plan compliance strategies.   The Toolkit identifies a range of policy options that individually or in aggregate can make nuclear generation a more attractive generation alternative for states and utilities.

You can download this document at the following link:


On 9 February 2016, the U.S. Supreme Court issues a stay on implementation of the EPA’s Clean Power Plan (CPP) pending the resolution of legal challenges to the program in court.

The ANS noted that, “….the stay provides them (the states) an opportunity to take a new look at the carbon offsets that existing nuclear plants provide, which they weren’t encouraged to do under the CPP rules.”


EPA Clean Power Plan Proposed Rule Does Not Adequately Recognize the Role of Nuclear Power in Greenhouse Gas Reduction

On June 2, 2014, the U.S. Environmental Protection Agency (EPA) proposed what they called, “a common sense plan to cut carbon pollution from power plants.”  You can access the Clean Power Plan Proposed Rule and many related documents at the following EPA link:


This Plan proposes to limit carbon emissions from existing fossil fuel fired electric generating units, including steam generating, integrated gasification combined cycle, or stationary combustion turbines (in either simple-cycle or combined-cycle configuration) operating or under construction by January 8, 2014. Main points of the Clean Power Plan include:

  • Wind and solar power are the preferred EPA options.
  • Natural gas is an interim solution.
  • New nuclear capacity is not a compliance option.
  • The EPA allows compliance credit for:
    • New nuclear plants currently under construction, and
    • Preservation of existing nuclear plants that might otherwise be retired

I’ve already formed my opinion on the Clean Power Plan. To help you form your opinion, I recommend that you refer to the following recent analyses by four respected government and industry organizations that have reviewed the Clean Power Plan.

Institute for Energy Research (IER)

On 15 June 2015, the IER issued the results of their analysis entitled, EPA’s Clean Power Plan Ignores New Nuclear as a Compliance Option. IER concluded that the compliance formulae in the Clean Power Plan are biased toward new wind and solar power development. Deployment of these technologies, which currently are not capable of delivering reliable capacity, will decrease the reliability of the electric grid. IER also concluded that the Clean Power Plan will result in much higher electricity prices for all American consumers, while having only a marginal impact on global temperature based on EPA’s computer models.

You can read the IER analysis at the following link:


National Association of Clean Air Agencies (NACAA)

On 21 May 2015, the NACAA issued a report entitled, Implementing EPA’s Clean Power Plan: A Menu of Options, containing 25 chapters, each of which explores a particular approach to greenhouse gas (GHG) reduction in the electric power sector.  NACAA is a nonpartisan, nonprofit association of air pollution control agencies in 41 states, the District of Columbia, four territories and 116 metropolitan areas.  Each chapter of their Menu of Options includes a brief descriptions of: (1) the option and it’s pros and cons; (2) the regulatory backdrop, policy underpinnings, implementation experience, and GHG reduction potential associated with the option; and (3) benefits of the option to society and the utility system, including costs and cost-effectiveness. In the last chapter, a variety of emerging technologies and other policy options for reducing GHG emissions are addressed.

An interesting table and two figures included in Chapter 6 of the Menu of Options are reproduced below.

NACAA Table 6-1 Source: NACAA

In 2012, electric power generation technologies with zero or low GHG emissions accounted for 31.4% of the USA’s total generating capacity. The data in Table 6-1 shows that 82.2% of the zero or low GHG emission generating capacity came from nuclear and hydroelectric power plants. The remaining low-emission generation capacity came from biomass, wind, geothermal, and solar power plants.

NACAA Figure 6-3Source: NACAA

In Figure 6-3, “life cycle GHG emissions” include those associated with operation as well as construction, fabrication, and fuel processing.  While nuclear power is not included among the “technologies powered by renewable resources”, it’s clear in Figure 6-3 that nuclear power meets the GHG reduction performance of the other technologies using renewable resources.

NACAA Figure 6-7  Source: NACAA

In Figure 6-7, note the relative cost-of-energy differential between nuclear power and fossil power. This difference makes it difficult for nuclear power plants to compete head-to-head with coal and natural gas merchant power plants and encourages the early retirement of some nuclear power plants on economic grounds.  While most renewable power sources have even higher costs-of-energy, various financial schemes subsidize their power generation.

You can download individual chapters or the entire NACAA Menu of Options at the following link:


U.S. Energy Information Administration (EIA)

On 22 May 2015, the EIA released their analysis of the Clean Power Plan. The EIA analysis supports the IER finding that the Clean Power Plan will result in much higher electricity prices for all American consumers, even in a scenario that allows GHG reduction credit for new nuclear generation.

You can read the EIA press release at the following link:


You also can download a PDFs copy of the May 2015 EIA report, Analysis of the Impacts of the Clean Power Plan, at the following link:


Nuclear Energy Institute’s (NEI)

To address the “clean power” attributes of nuclear power, I refer you to an NEI Knowledge Center webpage: Environment: Emissions Prevented, which you will find at the following link:


Here you’ll find a link to data on the amount of sulfur dioxide, nitrogen oxides, and carbon dioxide emissions avoided in the U.S. during the years 1995 to 2014 by virtue of having about 20% of U.S. electric power generated by nuclear power plants instead of fossil power plants. NEI reports the total avoided emissions for this period as follows:

  • Sulfur dioxide: 57.75 million short tons (52.4 million metric tons)
  • Nitrogen oxides: 22.92 million short tons (20.8 million metric tons)
  • Carbon dioxide: 13,063.6 million short tons (11,851 million metric tons)

On this website, NEI states:

“Nuclear energy facilities avoided 595 million metric tons of carbon dioxide in 2014 across the U.S. This is nearly as much carbon dioxide as is released from nearly 135 million cars, which is more than all U.S. passenger cars. The U.S. produces more than five billion metric tons of carbon dioxide each year.

Without the emission avoidances from nuclear generation, required reductions in the U.S. would increase by more than 50 percent to achieve targets under the Kyoto Protocol.”

2013 paper, “Prevented Mortality and Greenhouse Gas Emissions from Historical and Projected Nuclear Power”.

Supporting the above NEI position on the GHG reduction merits of nuclear power, there is a related 2013 article by NASA scientists from Goddard Institute for Space Studies and Columbia University entitled, “Prevented Mortality and Greenhouse Gas Emissions from Historical and Projected Nuclear Power”.  You can read a short article on this paper on the Scientific American website at the following link:


You also can read the complete paper at the following link:


In their study, authors Pushker A. Kharecha and James E. Hansen used historical production data from 1971 to 2009 and calculated that global nuclear power has prevented an average of 1.84 million air pollution-related deaths and 64 gigatonnes of CO2-equivalent (GtCO2-eq) greenhouse gas (GHG) emissions that would have resulted from fossil fuel burning. From their analysis, the authors drew the following conclusion:

“In conclusion, it is clear that nuclear power has provided a large contribution to the reduction of global mortality and GHG emissions due to fossil fuel use. If the role of nuclear power significantly declines in the next few decades, the International Energy Agency asserts that achieving a target atmospheric GHG level of 450 ppm CO2-eq would require “heroic achievements in the deployment of emerging low- carbon technologies, which have yet to be proven. Countries that rely heavily on nuclear power would find it particularly challenging and significantly more costly to meet their targeted levels of emissions.”

So, what do you think about the EPA’s proposed Clean Power Plan? Is this the “common sense plan to cut carbon pollution from power plants” promised by EPA; a politically motivated piece of crap designed to kill the nuclear and coal power industries; or something in between?