CMRA Comments on MassDEP Wood Fuel Assessment

The Construction Materials Recycling Association is a national 501c3 organization that promotes the recycling of construction and demolition (C&D) materials. As such, we have long supported and admired the state of Massachusetts and its Department of Environmental Protection because of its disposal ban for certain highly recyclable C&D materials. This has spurred the development of about a dozen major C&D recycling plants in the Commonwealth and surrounding border states, an astonishing number for a state so geographically small. Recent actions in the state, including this proposal for the assessment of C&D derived wood used for fuel, make us question the state’s support for C&D recycling wood, which is 40% of this waste stream. The reason for doubt is that biomass derived from C&D wood is a fundamental financial underpinning for any recycling operation, and the state should be supporting the clean use of this renewable power source, rather than set up barriers. There are few other markets for most of the wood generated under DEP’s disposal ban, and hurting this market is not demonstrating the support DEP should be showing. Question to the agency: if you take away this market, what do you intend the recyclers to do with this wood? It is our opinion that an out-of-state-out-of-mind mentality gives the wrong message and will likely jeopardize viable outlets that are currently available in Massachusetts. There are no other markets for the majority of this wood. That limited use extends to reuse of the wood, as again very little is qualified for reuse for a variety of issues.

The main concern of this document is over its intent, starting with its title. C&D wood used as a fuel is considered a biomass product. The concern is that there is a bias already built in to this process against C&D wood. It should be referred to as a biomass product.

Our current concern extends to which consultant will be chosen to do this work. Recently a think tank in Massachusetts put out a document that was critical of green waste being used as biomass. That study had several logical and scientific flaws and was basically incorrect, but did garner the headlines the group sought with the general public, who will not know the problems with the report. For this project, already those consultants with extensive knowledge of C&D recycling, C&D wood and it use in the incineration and gasification industry are expecting to be precluded from being able to win this contract. So that would only leave neophytes and those organizations already pre-disposed against C&D biomass, and as we have seen with the green waste study, the end result is pre-ordained and not scientifically valid. The C&D recycling industry is not afraid of a rigorous scientific examination of its biomass product. Indeed, this whole project is practically superfluous as the use of C&D wood as biomass has already been studied to death. But if the consulting or non-profit organization chosen already has its direction set and plans to come out with a negative (for C&D recycling) result no matter what the science says, then this would be patently unfair and would have to be examined for further action.

Besides the economic need for a readily available market for C&D wood, here are a couple of other facts that should be included in the final report of whomever does this work, if not even in this draft scope itself. First, it doesn’t matter what the fuel is going into the power-generating facility, it matters what comes out the stack for emissions. So the fuel is not the problem. And with the current stack controls available, which of course the agency should require on all new facilities, this should be a non-issue.

Second, a study performed by the University of New Hampshire showed C&D biomass seriously reduces greenhouse gas emissions. While the basis for this conclusion is covered extensively in the study, the reason can be put simply enough. One way or another, if the wood stays in a forest, dies and decomposes, or it is used as a biomass product, it is going to release its GHGs. But the fossil fuels that would be used if the C&D biomass is not would never release their GHGs if they stayed in the ground. Hence, anyone who opposes C&D biomass use is supportive of more greenhouse gas generation.  Also if C&D wood is not used for its bTu value, it too will decompose in a landfill and likely have long term emission of GHG through its decomposition process. We can provide a copy of this study to whatever organization performs this work for the state.

A couple of specific issues with the proposed assessment:
•    The creation of a state-sanctioned specification for C&D biomass. We question the need for this, as such a specification will be set by the requirements of the power-generating facility. Hence, it could change from operation to operation. Instead, we recommend that the state use its current successful beneficial use determination (BUD) process to review the required incoming material. One size does not fit all here.
•    Hypothetical facilities. Do not understand the need to look at a current combustion technology facility, only ones using the most advanced lowest-emitting combustion process. That is all the state is going to allow anyway.
•    Source and emissions information. The consultant is to look at the worst case scenario for emissions from facilities using C&D biomass. They are also to look at truck emissions for the vehicles supplying the facility. We understand the need for that, it was also done in the referenced New Hampshire study, but one must remember such data also applies to fossil-fuel-fired facilities, and should basically be a wash. In addition, it should be coupled with the transportation of the C&D biomass that would ultimately need to be hauled somewhere as well, which would likely double the perceived emissions.  Has the DEP done this study for other power-generating sources? The concern is this is an opportunity to hype how much emissions will be generated by a C&D facility when the other option has the same issues.

Finally, as the experts on C&D wood processing, the CMRA would be the ideal candidate to do a peer review on any document the consultant prepares, before it is made public, so we can correct any inaccuracies.

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