A false promise for clean renewable energy in New Mexico
The New Mexico State Legislature enacted the “Renewable Energy Act” (REA) in 2004 to require that public utilities purchase no less than 10% of their energy from clean renewable energy sources by 2011 to promote energy self-sufficiency, preserve the state’s natural resources and pursue an improved environment in New Mexico.
Western Water and Power Production LLC (WWP) has proposed a 35 megawatt forest biomass energy power plant (enough power for 28,000 homes) near Estancia and the Public Service Company of New Mexico (PNM) has contracted to buy this energy as part of its required 5% under the REA.
WWP intends to acquire a large portion of the material for the energy produced by the biomass plant from cutting pinyon, juniper, and ponderosa pine from our public lands (state and federal).
Issues and Concerns
1. New Mexico forests are not a form of renewable energy.
Renewable energy is energy that is rapidly replenished naturally and cannot be used up.
WWP has obtained a state land lease to remove pinyon and juniper south of Estancia on Chupadero Mesa. It has taken many, many years for these trees to grow to their current size. For example, pinyon trees taller than 3 feet are generally 50-230 years old in New Mexico and the US Forest Service recommends 200-year-rotation management for juniper. In fact, the state-owned forests south of Estancia are not a renewable source of energy; once the trees from that forest are cut, the biomass company has indicated it will need to move onto nearby national forests. In doing so they move to an area where the smallest trees to be thinned are around 100 years old. In addition, in recent proposed and existing thinning projects the U.S. Forest Service has refused to put age and/or diameter limits on the trees harvested during thinning, so even much older trees will be ‘harvested.’ And again, when WWP is finished logging the National Forest, they will have to move on to another area since the rate of growth cannot keep up with the demand for biomass fuel and on from there.
On the other hand, the intent of the New Mexico Legislature and the public who supported the REA was to use genuine renewable energy sources such as wind and solar.
Under WWP’s definition, coal and gas could be considered renewable energy sources—like our forests, it just takes a longer time to renew them. However, coal and gas and New Mexico forests are not a source of renewable energy because the rate of use is faster than the rate of renewal.
The REA states that biomass is agriculture or animal waste, small diameter timber, salt cedar and other phreatophyte or woody vegetation removed from river basins or watersheds in New Mexico, landfill gas and anaerobically digested waste biomass; but … does not include electric energy generated by use of fossil fuel or nuclear energy.
WWP has yet to commit only to cutting “small diameter timber” trees under a prescribed age, or invasive (salt cedar, Russian olive etc.) trees along water courses.
2. Burning forest biomass is not a clean source of energy
· In passing the REA, the New Mexico Legislature required that the energy come from low- or zero-emissions generation technology. Actual clean and renewable energy sources like solar and wind do have zero emissions.
· The State of New Mexico’s Air Quality Bureau (AQB) considers any source that produces more than 100 tons of pollution per year to be a “major source” of pollution, which is not even a health based threshold. The plans for the initial operation of the WWP biomass energy plant will result in the release of 230 tons of nitrous oxides and 221 tons of carbon monoxide into our air per year. Hundreds of tons of pollution a year is not “low or zero” emissions.
· Nitrogen oxides (NOx) are the principle components of industrial and vehicular smog. When dissolved in atmospheric moisture the result can be acid rain which can damage trees and entire forest ecosystems. The biomass plant expects to release 230 tons per year of NOx. This is equal to 1.5 lbs of NOx per hour per megawatt of power. According to EPA statistics, an average coal fired plant in the US releases about 2.8 lbs of NOx per hour per megawatt of power. This means the biomass plant would emit over 50% of the NOx of a typical coal fired plant!
· The WWP facility will likely emit State Air Toxics (TAPs) like wood dust and ammonia which are both on the state air toxics list (188.8.131.522 NMAC Toxic Air Pollutants and Emissions).
3. The development and operation of the biomass energy plant in Estancia, NM may result in significant environmental harm.
The REA states that the use of renewable energy presents opportunities to promote energy self-sufficiency, preserve the state’s natural resources and pursue an improved environment in New Mexico. The REA also requires WWP’s procurement plan include a “demonstration that the plan is otherwise in the public interest”.
Nothing about the proposed biomass plant guarantees improvement of the environment in New Mexico nor is the currently proposed project in the general public interest. In addition, WWP has signed onto the recently finalized NM Forest Restoration Principles but a forest procurement plan from WWP has yet to be presented to the public for analysis.
In light of this fact, the following issues are of pressing concern:
· Significant soil damage may result from the mechanical removal of trees to feed the biomass plant.
· Large biomass extraction machinery may damage sensitive archaeological sites and the tree removal process will create access to hundreds of archeological sites that are currently inaccessible to vehicles.
· Cutting and burning trees will result in a significant increase in greenhouse gases. Live trees sequester carbon. Burning trees releases carbon monoxide which has an indirect radiative forcing effect by elevating concentrations of methane and tropospheric ozone through chemical reactions with other atmospheric constituents (e.g., the hydroxyl radical, OH) that would otherwise destroy them. In addition, carbon monoxide converts to carbon dioxide (a direct greenhouse gas) in the atmosphere.
· Removal of trees from the forest removes biomass that would otherwise contribute to soil development and renewed grass, plant, and tree growth.
· Transportation of the trees to the biomass plant will result in a dramatic increase of PM10 particulate emissions from vehicles working in the forests.
· The biomass plant will be a major source of nitrogen oxides and carbon monoxide (contributing to greenhouse gasses) and will release significant amounts of sulfur dioxide, volatile organic compounds, TSP and PM10 particulate emissions.
4. The use of a biomass energy plant to fulfill the requirements of the REA will divert resources from the development and use of solar and/or wind power.
· The REA mandates that public utilities get 5% of their energy supply from clean, renewable resources. Any energy provided by biomass will be at the expense of truly clean, renewable energy sources like solar and wind.
5. Water planning groups in the basin are looking for ways to reduce water use and the biomass energy plant will have a permanent and irreducible demand for precious water resources.
· The Estancia Basin water plan documents that the basin is rapidly running out of water. According to WWP, the biomass plant will use 200-400 acre-feet per year, enough water to supply 800 to 1600 homes. More important, this permanent requirement for water goes against every desire to reduce water consumption in the basin.
· WWP testified to the NM PRC that … One of the biggest benefits to the state of New Mexico from the Project may be an increase in water available for the health of the forest and rangeland and the conservation of water for other uses. The removal of water consuming overgrowth may substantially increase water availability for the remaining vegetation and for human and animal use with no supporting scientific evidence. In fact, scientific studies do not support this claim, but research shows that there is more recharge from pinyon-juniper forests than from grasslands (Phillips and Sanwig, 2005, Water Resources Research Volume 42).
6. WWP has not been open and candid with the NM Air Quality Bureau and the public and is far from “securing” the required forestlands to make its project viable.
In testimony to the NM Public Regulatory Commission and statements made to The Independent newspaper, WWP stated that they will use agricultural waste and ponderosa pine in the biomass plant. However, their application for an air quality permit is based solely on burning pinyon and juniper. Months before the state of New Mexico accepted bids for leasing public land for thinning;
WWP told the Mountain View Telegraph it already had a lease of 63,000 acres for 20 years. Unless the state land office was making deals behind close doors and then holding non-competitive bidding, this could not have been true at the time.
WWP has consistently implied that they have been guaranteed federal land for thinning. Any thinning on federal land must follow the National Environmental Policy Act (NEPA) which requires an evaluation of all options (including not thinning) and requires public involvement in the decision about thinning or not thinning.
For more information contact: Bryan Bird, Forest Guardians at 505.988.9126 or http://www.fguardians.org/, Bud Latven at 505.384.2208 or Paul Davis at 505.384.5376
also see http://www.na.fs.fed.us/pubs/silvics_manual/Volume_1/juniperus/scopulorum.htm