This document discusses the health risks of biomass combustion and argues that current regulations do not adequately protect human health. It presents data showing biomass combustion emits more particulate matter and other pollutants per unit of energy than coal. These pollutants are linked to various diseases, especially in children. While biomass plants may obtain necessary permits, the document argues permits do not guarantee safety as regulations allow harmful pollution. It also notes the biomass industry receives substantial government subsidies.

1. Biomass combustionDue DiligenceWilliam A. H. Sammons, M.D.drsammons@aol.com781-799-0014

2. AssurancesI am not paid by a power producer or other energy entity. This is an imperative issue to address. The material is not my beliefs or my opinionsEvery statement is referencedI have been to DC in talks with EPA and Congressional staff and elected officials in CongressI have played a part in stopping more than a dozen plants

3. What are we going to talk about?HEALTHDioxin and particulate matter [PM <2.5 microns]Risk to everyone, but especially childrenREALITYCurrent regulations are NOT PROTECTIVE OF HUMAN HEALTHRequires difficult decisions by county/city leadersMONEY240+ plants across the country> $20,000,000,000 in federal tax credits, grants, subsidies$6-8,000,000,000/yr in renewable energy creditsMillions more in state grants, subsidies, and tax breaksCLIMATE EFFECTS

4. Data shows the following is trueBiomass combustion is “dirtier” than burning coalHealth care effects and secondary increase in costs are significantPower from biomass combustion is expensiveBiomass combustion is unequivocally not carbon neutral or climate neutral within any useful time frameForest management science is controversial at minimum

5. Emissions from biomass combustionTHE TRUTHNot carbon neutral in a useful timeframe – multiple decades to a centuryNot climate neutralNot human health benignNot affordable

6. Biomass is NOT “clean”Biomass combustion, per unit of power produced, whether direct combustion or in a multiple stage gasification process, produces more harmful pollutants than burning coalTHIS IS THE PRIMARY REASON IT IS A HEALTH RISK FOR ALL PEOPLE LIVING NEAR A PLANT

7. EMISSIONS COMPARISON DATA– Numbers Confirmed by EPA BURNING WOOD IS “DIRTIER” THAN BURNING COAL

8. Gainesville, FLIn 2010, Florida issued an air pollution permit for the 100 MW Gainesville Renewable Energy Center (GREC) biomass burning electricity project. In 2007, the adjacent coal plant installed new pollution controls. Acomparison of relevant emissions between the two plants shows the biomass combustion plant will emit, per megawatt hour of power produced:67% more carbon dioxide367% more particulate matter 62% more NOxhttp://www.pfpi.net/carbon-emissions

9. Multiple Pollutants with known Negative Health EffectsNOxOzoneHeavy MetalsVOCHAPSDioxinFuransCO

10. Effects of air pollution--childrenAir pollution affects the growth of lung function during the period of rapid lung development between the ages of 10 and 18 years. Gauderman et al. (2007)Children’s Health study (CHS), which began in Southern California in 1993, included more than 6000 public school children. Many research papers emerging from this study have produced findings showing that exposure to air pollution in the region has resulted in increased school absences, asthma exacerbation, and new-onset asthma. (Künzli et al. 2003). Data from theAmerican Cancer Society (ACS) cohort5 estimated that for each10-µg/m3 increase in annual average exposure to PM2.5,long-term all-cause, cardiopulmonary, and lung cancer mortalitywere increased by approximately 4%, 6%, and 8%, respectively.Therelationship between PM2.5 and adverse health effects was linearand without a discernible lower "safe" threshold.http://circ.ahajournals.org/cgi/content/full/109/21/2655

11. 2009 SOTA from the American Lung AssociationThe researchers concluded that air pollution may increase the risk of babies being born with low birth weight, even though almost all the air pollutants were at levels that were officially listed as safe by the U.S. Environmental Protection Agency.58Researchers tracking 3,500 students in Southern California found an increased onset of asthma [3x] in children who were taking part in three or more outdoor activities in communities with high levels of particle pollution.61Air Pollution Increases Risk of Underdeveloped Lungs Another finding from the Southern California Children’s Health study looked at the long-term effects of particle pollution on teenagers. Tracking 1,759 children between ages 10 and 18, researchers found that those who grew up in more polluted areas face the increased risk of having underdeveloped lungs, which may never recover to their full capacity. The average drop in lung function was 20 percent below what was expected for the child’s age, similar to the impact of growing up in a home with parents who smoked.62

12. Permit process provides inadequate protectionAmerican Heart AssociationAmerican Lung AssociationAmerican Cancer SocietyMore than 70,000 physicians

13. Florida –American Lung AssociationApril 11, 2011“Burning biomass could lead to significant increases in emissions of nitrogen oxides, particulate matter and sulfur dioxide and have severe impacts on the health of children, older adults, and people with lung diseases. “Furthermore, we have noticed a pattern nationwide of biomass plants being proposed for rural areas away from cities; where less protective pollution control restrictions and weaker permitting requirements apply. Plant proponents will say that they “meet the air pollution requirements” but the requirements themselves tend to be more lax.

14. DANGERSTATEMENTS FROM MEDICAL ORGANIZATIONS“[1] Not grant renewable energy credits to biomass, as well as [2] to not grant any other preferential treatment of biomass in any of the energy or climate change legislation. American Lung Association to Senator Kerry Nov 16, 2009.The Massachusetts Medical Society stated its opposition to the three currently proposed largescale biomass power plants in Massachusetts on the grounds that each facility poses an unacceptable public health risk. Testimony to the Massachusetts Legislature Feb 2010 by Massachusetts Medical SocietyThe Hampden County Medical Society has expanded its opposition to construction and operation of this [Russell] and all other biomass power plants in Western Massachusetts, again citing unacceptable health risks to the population. Open letter from HCMS November 19, 2009

15. EMISSIONS COMPARISON DATA– Numbers Confirmed by EPA BURNING WOOD IS “DIRTIER” THAN BURNING COAL

16. ParticulatesParticulates are produced by combustion– at very high levels by diesel truck engines and biomass combustion.More than burning coal per unit of power producedStack emissions [filterable] and those which form in the atmosphere [condensable]Particulates come in multiple types:PM 10 – a relatively minor health hazardPM 2.5 & PM ultrafine & PM nano– major health hazards, especially for children, as reported in literally thousands of medical articles in the last four yearsOther smaller particles

17. Particulates Inhale at Your Own RiskStudies demonstrate larger cardiovascular risksposed by more prolonged exposures to higher PM levels than observedover only a few days. p. 71 Women may be atgreater risk for cardiovascular mortality related to PM [p. 76], as are people who are overweight [p 35].Long-term exposure to elevatedconcentrations of ambient PM2.5at levels encountered in thepresent-day environment (i.e., anyincrease by 10 µg/m3)reduces life expectancy within apopulation probably by severalmonths to a few years. p 113PM elicits numerousadverse biological responses (e.g., systemic inflammation) that may further augment future cardiovascular risk overthe long term after months to years of exposure. p 9Although the dangersto 1 individual at any single time point may be small, the publichealth burden derived from this ubiquitous risk is enormous.Short-term increases in PM2.5 levels lead to the early mortalityof tens of thousands of individuals per year in the United Statesalone. p 116.

18. Recent studiesAlzheimers disease and Parkinson’s disease related to prolonged PM exposurehttp://www.niehs.nih.gov/news/newsletter/index.cfmAutism related to PM exposurehttp://www.ncbi.nlm.nih.gov/sites/entrez?db=pubmed&cmd=link&linkname=pubmed_pubmed&uid=20361442Bronchiolitis -- There was a clear link between total charges and costs for infant bronchiolitis hospitalizations and levels of fine particulate matter pollutant surrounding those hospitals.aje.oxfordjournals.org/cgi/content/full/kwn252ADHD and executive cognitive function impaired by prolonged exposure to PMEur J Pediatr. 2010 Dec 30

19. DANGERThe latest draft of the US EPA Air Quality Criteria for ParticulateMatter has confirmed the presence of an apparent linear dose-responserelationship between PM and adverse events.http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=58003

20. Data from allNorth American studies demonstrate that this curve is withouta discernible threshold below which PM concentrations pose nohealth risk to the general population.http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=58003, http://circ.ahajournals.org/cgi/content/full/109/21/2655

21. DANGERThe most dangerous particulates are not regulated or accounted for in the permitting process– so permits are not “protective of human health”.“Although the dangersto 1 individual at any single time point may be small, the publichealth burden derived from this ubiquitous risk is enormous.Short-term increases in PM2.5 levels lead to the early mortalityof tens of thousands of individuals per year in the United Statesalone.” http://circ.ahajournals.org/cgi/content/full/109/21/2655 p 116.

22. DANGERIt is the opinion of the writing group that the overall evidenceis consistent with a causal relationship between PM2.5 exposureand cardiovascular morbidity and mortality. This body of evidencehas grown and has been strengthened substantially since publicationof the first AHA scientific statement.1http://circ.ahajournals.org/cgi/content/full/121/21/2331(Circulation. 2010;121:2331-2378.)© 2010 American Heart Association, IncBecause the evidence reviewed supports that there is no safethreshold, it appears that public health benefits would accruefrom lowering PM2.5 concentrations even below present-day annual(15 µg/m3) and 24-hour (35 µg/m3) NAAQS p 116

23. Dioxin“But the amounts will be very small”There has been ongoing discussion at EPA for more than a decade trying to decide if the agency can risk declaring a “safe threshold”Of the approximately 100 scientists many say say there is no safe threshold of exposure.The current number is 0.7 picograms/kg/dayFor a 100 kg man that is 70 picograms/dayIn pounds that is: 0.000000000000154 lbs/day

24. DioxinFindings of Institute of Medicine at National Academy of SciencesThe U.S. Institute of Medicine, part of the National Academy of Sciences, now links dioxin to various cancers, insulin dependent diabetes, nerve and heart disease among people exposed directly or indirectly, and to spina bifida in their children. http://www.nap.edu/catalog/12662.htmlhttp://iom.edu/Activities/Nutrition/DioxinFoodSupply.aspx [2008]

25. Dioxin“The provisional cancer potency factor is the highest of any chemical EPA has evaluated. Dioxin has been shown to produce cancer at far lower concentrations than any of the more than 600 other chemicals EPA has studied and for which EPA has developed cancer potency values. DeGrandchamp, p 30 www.epa.gov/region8/superfund/ut/magnesium/HHRA06Feb07.pdfSystemic effects: The primary targets appear to be the skin, liver, thyroid, and cardiovascular, endocrine, and immune systems. [P 316 USPHS]. Median half life of the chemical in the body is estimated to be 7.1 years [Pirke, 1989]Nursing increases exposure of infants: Consumption of breast milk by nursing infants leads to higher levels of exposure and higher body burdens of dioxins during early years of life as compared with non- nursing infants. Lipid concentrations peaked at around 4 months at about 46 ppt TEQDFP-WHO98. The formula-fed infants peaked at less than 10 ppt after the first year. P 1-18 EPA/600/P-00/001Cb

26. Regulation hang-up The principle assumption, and the basis for the conclusion, is that if air quality standards are not exceeded by the combination of existing ambient concentrations and the marginal increase from the boiler then no harm is assumed to occur. This approach is, of course, fundamentally flawed for those emissions, like particulates for which no safe level can be demonstrated.

27. Protection or Sham?The permitting process is meant to protect people from harm, especially children and the most vulnerable So if SRE gets all the permits isn’t everything going to be safe– or at least OK?PEOPLE ASSUME THEY GET PROTECTION

28. Permit≠Protection??SREMAY BE DOING WHAT IS LEGAL BUT THAT DOES NOT MEAN YOU ARE SAFE AND GETTING ALL THE REQUIRED PERMITS DOES NOT MEAN YOUR CHILDREN ARE SAFE

29. Underestimated RiskIt is the opinion of the writing group that the overall evidenceis consistent with a causal relationship between PM2.5 exposureand cardiovascular morbidity and mortality. This body of evidencehas grown and has been strengthened substantially since publicationof the first AHA scientific statement.1 At present, no crediblealternative explanation exists. These conclusions of our independentreview are broadly similar to those found in the EPA’sIntegrated Science Assessment for Particulate Matter final report(http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546). P 117

30. NAAQS is NOT Sufficiently ProtectiveThe Clean Air Scientific Advisory Committee of the EPA, which is mandated by the Clean Air Act to provide scientific advice on setting air quality standards, argued “there is clear and convincing scientific evidence that significant adverse human-health effects occur in response to short-term and chronic particulate matter exposures at and below 15 µg/m3, the level of the current annual PM2.5 standard” (CASAC 2006). http://www.epa.gov/sab/pdf/casac-ltr-06-003.pdf

31. DANGERA reasonableargument can now be made that the "real" effects [of particulates] are likelyto be even stronger than previously estimated. http://circ.ahajournals.org/cgi/content/full/109/21/2655

32. DANGERMoreover,because a number of studies have demonstrated associations betweenparticulate air pollution and adverse cardiovascular effectseven when levels of ambient PM2.5 were within current standards,even more stringent standards for PM2.5 should be strongly consideredby the EPA. http://circ.ahajournals.org/cgi/content/full/109/21/2655

33. Industry statementsEpidemiologic studies reported a correlation between adverse health effects and increases in ambient particulate concentration, even when the mass concentration was below the then-current air quality standards.

34. Particle surface area, number of ultrafine particles, bioavailable transition metals, polycyclic aromatic hydrocarbons (PAH), and other particle-bound organic compounds are suspected to be more important than particle mass in determining the effects of air pollution.

35. Accumulating evidence suggests that mass concentration is not the most appropriate measure of potential health effects,1 and that health studies need to consider other characteristics, such as particle number, particle morphology, and detailed chemical speciation.2–4

36. The result is that the removal efficiency of particles from air is least efficient in an intermediate size range from 0.1 to 1 µm. This minimum PM removal efficiency is observed in post-combustion cleanup equipment at the source, in the atmosphere, and in the respiratory system.

37. Particles in the 0.1–0.3 µm range have the highest penetration through APCD compared with both larger and smaller particles,63,78,179,180 so the 0.1–1 µm particles form a larger fraction of the mass distribution leaving the APCD than they do in the uncontrolled combustion emissions.63

38. Air & Waste Manage. Assoc. 50:1565-1618Best controlsPermits aren’t protective in part because the POLLUTION CONTROLS REQUIRED ARE NOT THE BEST AVAILABLE.

39. RISK from biomass combustionHealth risk to everyone, especially childrenIncrease the release of harmful pollutants especially particulates and dioxinExpensive power which requires taxpayer subsidies when the country is in a financial crisis

41. What’s Driving the System$$$$$$$

42. MoneyLots of it– you pay & SRE profitsFederal dollarsSection 1603 -- $12-14 billion on biomass combustion alone without accounting for pellet plants and conversion of coal to co-firing biomassProduction Tax CreditDOE loan guaranteesSection 48c -- Manufacturing tax creditBCAP– underwrites the fuel supply costs

43. MoneyLots of it– you pay & SRE profitsSouth Carolina

44. MoneyLots of it– you pay SRE profitsRenewable Energy CreditsThe EIA projects that at minimum under current policies the country will add 50 GW of biomass combustion this decade.The current market for REC’s is > $20/REC and expected to rise as high a $35-$40/REC1 REC per MWh of power produced$ 2.63 million/yr for Allendale$ 7. 45 billion/yr50,000 X 24 X 365 X 20 X 0.85

45. MoneyDoes SRE deserve a tax abatementRenewable Energy Credits – $2.63 million/yrFederal taxpayer obligation– will be 30% of development costsSC fundsOngoing power purchase agreementIf selling power at $0.04/KWh then SRE will have a guaranteed income of at least $5.26 million/yr

46. The Assumption“Combustion of biomass emits greenhouse gases….[but] the CO2 emissions from these activities are not included in the national emissions totals. It is assumed that the C released during the consumption of biomass …causes no net addition of CO2 to the atmosphere.” http://epa.gov/climatechange/emissions/downloads09/Energy.pdfThis was the opinion of experts that has now been discredited

47. The FOIA– The discovery!EcoLaw asked EPA for data to support the assumption of carbon neutrality1.6 GB of material receivedMore than 80 repetitions of the word “assumed” or “assumption”The data, the papers, the meeting notes, the substantive e-mails: THE RESULTS >>>>>

49. The Paradox—VOODOO REPORTINGEPA HAS UNTIL NOW EXEMPTED POWER PLANTS WHICH USE BIOMASS AS A FUEL SOURCE TO GENERATE ELECTRICAL ENERGY FROM ACCOUNTING FOR THEIR CARBON EMISSIONS AND ALLOWED REPORTING THOSE EMISSIONS AS A ZERO. THAT’S RIGHT– ZEROTailoring rule: Goes was going into effect January 2, 2011. Now new ruling is July1, 2011 so they need the permit quickly.

50. CLIMATE NEUTRALCARBON NEUTRAL IS NOT THE SAME AS CLIMATE NEUTRAL

51. Biomass Burning is not Carbon NeutralBurning [regardless of the type of combustion process] releases CO2in minutes but the CO2won’t be re-sequestered for centuries so burning biomass will accelerate climate change not help.