Comment on Permit No. SAC 12-01/Modification of Permit #94-VP-18b

Marily Woodhouse to: R9AirPermits 01/10/2014 09:39 AM

Please find attached a comment regarding the 

proposed modification of the permit for the biomass 

plant in Anderson, CA.

Marily Woodhouse

www.thebattlecreekalliance.org 

(530) 474-5803 EPA comment.docx
1

Jan. 7, 2014 

Deborah Jordan, Region 9, EPA Air Director 

Shaheerah Kelly 

EPA Region 9 

75 Hawthorne St. 

San Francisco, CA 94105-3901 

R9airpermits@epa.gov 

RE: Official comment on Permit No. SAC 12-01/Modification of Permit #94-VP-18b 

I am writing to submit comments on the expansion of the biomass plant owned by Sierra 

Pacific Industries (SPI) in Anderson, California. Battle Creek Alliance is a non-profit 501 

(c)(3) which works on forest and watershed issues mainly in Shasta and Tehama counties, 

although we also work in partnership with many other environmental groups throughout 

the state. I was not able to attend the public hearing due to the distance that would have to 

have been traveled on icy roads. 

I contacted Ross Bell, the Shasta Quality Air District Manager, in December 2013 to 

determine what the emissions are currently from the 4 megawatt plant. He didn’t know. 

When asked if there were any monitoring documents he said there might be some in the 

files somewhere. This lack of knowledge on the part of a regulating agency is troubling, 

particularly in light of the large increase in emissions and other effects that will occur if the 

biomass plant is enlarged to a 31 megawatt plant. If one of the main regulatory agencies is 

unable to monitor the effects of a 4 megawatt plant, how will they be able to monitor and 

analyze the additional direct and indirect effects of a plant that has increased its size, 

effects, and emissions by 87%? 

Due to the lack of information available from the regulatory agency, we found figures 

regarding biomass facility emissions from the Partnership for Policy Integrity. Using their 

figures for typical emissions from a 50 megawatt plant (based on rates from biomass facility 

permits issued) we compared a 4 megawatt plant to a 31 megawatt plant to determine its 

CO2 emissions, number of gallons of water used for cooling, number of tons of wood used, 

number of gallons of diesel fuel used to cut and transport the wood, and tons of waste ash 

produced per year: 1 

 
2

 4 MW 31 MW

CO2 emissions/tons per year 52,800 409,200

# gallons water/cooling/per day 72,000 558,000 

# gallons water/cooling/per year 26,280,000 203,670,000 

# of tons wood used/per year 52,000 403,000 

# of gallons of diesel fuel used 109,200 846,300 

# of pounds of ash/per year 525,600 16,293,600 

As can be seen above, there are huge increases in significant effects from a larger facility. 

Yet, your agency wants to modify the existing permit without any substantive analysis of 

these significant effects. 

Biomass energy emits huge amounts of CO2 

Cutting and burning forests for energy has been portrayed by the timber industry as 

“carbon neutral” by using different manipulative formulas. SPI released a white paper 

entitled “Carbon Sequestration in Californian Forests; Two Case Studies in Managed 

Watersheds” in 2007 that was reviewed by Peter Miller in 2008.2 From Miller’s review: 

As detailed below, the SPI study raises numerous methodological and policy issues that 

call into question both the quantitative conclusions and the value of those conclusions for 

the development of climate policy. A critical review of this study demonstrates that, 

contrary to the report’s conclusions, replacing existing diverse forests with uniform tree 

plantations is unlikely to produce significant carbon benefits and will instead increase the 

risk of catastrophic fire and threaten the extensive range of benefits provided by existing 

forest ecosystems. This memo provides an overview of methodological problems with 

the analysis, offers revised estimates of the carbon savings from each of the three 

scenarios, and concludes with a discussion of the key policy issues raised by the SPI 

study 

Methodological problems with the SPI study include the following: 

The SPI analysis is based on a non-peer-reviewed, unvalidated statistical model. 

While the authors acknowledge that their model violates normal statistical conditions, 

they reject alternative, unbiased approaches because they would be “tedious.” (p. 43- 

45) 

GHG emissions from logging, transport, and landfills are ignored or assumed to be 

zero even though the Intensive management approach is likely to have significantly increased 

emissions in all of these categories compared to less intensive management 

approaches. (p. 26-30) 

The SPI analysis assumes that soil carbon levels remain constant across management 

scenarios, despite the significant soil disturbance proposed under the Intensive 

scenario. In the Intensive scenario, forest soils would be mechanically ripped to three 

feet deep after existing stands were cleared, likely resulting in a significant loss of 

soil carbon. (p. 48)

The expansion of this plant would mean 356,400 more tons of CO2 would be added to the 

atmosphere each year, from just one point source at the biomass plant. As Miller points 
3

out, this does not include emissions from logging, transport, landfills, and soil carbon 

releases. Where is the EPA’s analysis regarding what impacts would occur to climate and 

air quality from an 87% increase at the point source, much less the other uncalculated 

tons of CO2 released from the associated activities? 

Biomass plants use huge amounts of water 

The expansion of this plant could require approximately 177,390,000 more gallons of water 

per year to be used for cooling than are currently being used. Is it not the EPA’s 

responsibility to safeguard the public trust resource of water? “The California Constitution 

stipulates that water is owned by the people and must not be wasted or put to an 

unreasonable use by those that have water rights” (Carle, 2004).3 

Excess water usage is an even greater concern than it has been in the past. Redding had 

the lowest amount of rainfall in 2013 in recorded history.4 The eastern part of Shasta 

County in which Battle Creek Alliance works shows an ongoing trend of less water and 

higher temperatures than in the past. The USDA Soil Conservation Service and Forest 

Service "Soil Survey of Shasta County Area, California" that is dated 1974, lists the area as 

having an average annual temperature of 50o and annual precipitation of 35 to 60 inches.5

The Shingletown weather station for the area shows these measurements since it was put 

into service in 2009:6 

Year Average temperature Hi temperature Precipitation

2009 56.4 105.8 29.00" 

2010 54.8 104.4 47.33" 

2011 54.6 99.6 28.93" 

2012 55.5 105.7 35.56" 

2013 56.6 106.5 15.38" 

In a scientific paper regarding carbon issues and drought between 2000 and 2004, 

Schwalm et al. (2012)7 wrote: 

“We further document a pronounced drying of the terrestrial biosphere during this period, 

together with a reduction in river discharge and a loss of cropland productivity... 

...the cumulative effect over five consecutive drought years led to a clear reduction in water 

availability as indicated by decreased runoff in all major water basins of the western United 

States... 

...This impending drydown of western North America is consistent with present trends in 

snowpack decline as well as expected increases in aridity and extreme climate events, 

including drought, and is driven by anthropogenically forced increases in temperature with 

coincident increases in evapotranspiration and decreases in soil moisture... 
4

...Decreases in crop productivity, primary production, latent heat flux, large basin runoff 

and CO2 uptake by the land surface associated with the turn of the century drought could 

become permanent conditions before the end of the century, consistent with a twenty-first 

century megadrought.” 

Does it fulfill the EPA’s mandate to protect the public, and the environment that sustains 

them, to modify a permit that allows over 177 million more gallons of water per year to be 

used for a privately owned, for-profit biomass plant? 

Biomass burning requires more forests to be cut for fuel 

Some sources refer to forests as “renewable energy”. While it is true that forests can regrow, even under the best temperature and rainfall conditions the time it takes for an 

individual tree or a forest or a complex ecosystem to develop is at least a century. These 

slow moving processes cannot be sped up, and we disregard the time factor at the risk of 

changing the near and far future irreparably. 

The AB 1492 Report which was issued in 2013 by the California Natural Resources Agency 

and Environmental Protection Agency includes an Appendix which lists the timber harvest 

plans approved in the 10 year period of 2003 to 2012.8 Shasta County is listed as having 

832,702 acres of non-federal timberland, or 33.8% of the county’s acres. Plans have been 

approved to cut 25% of the non-federal timberland (207,818.2 acres) in the past 10 years 

alone. The expansion of this plant will require 351,000 more tons of wood per year on an 

ongoing basis, year after year. The land has finite limits of what it can produce, even in 

more optimal conditions than are occurring presently. Where is all of the fuel for an 87% 

larger single biomass plant supposed to come from year after year? 

Diversity is one of the cornerstones of life. If the EPA approves a modification of this permit 

to enlarge the biomass plant, it will increase the amount of logging of grown forests to 

replace them with tree plantations that lack diversity. Replacing grown, existing forests 

with tree plantations simplifies plant and animal communities because it reduces habitat. 

A forest is made up of different kinds and sizes of trees that provide what is termed 

"structure" by ecologists, and has an "understory" of many kinds of shrubs and other 

plants. In turn, the structure and understory provide food, resting and denning habitat for 

all the other forms of wildlife, from microorganisms to bugs to birds to mammals. 

"Large-scale clear-cutting of forests should be avoided because it reduces biomass and 

biological diversity. Further, the loss of vegetation results in the rapid loss of nutrients from 

the soil, which eventually reduces the productivity of the entire ecosystem. Both biomass 

production and biological diversity decline as a result." (Pimentel et al. 1992)9 

The following images from Google Earth are from just a few of the mountain areas around 

Redding and Anderson. Each of the thousands of regularly spaced brown holes are 

clearcuts, with an average size of 20 acres, or 4 city blocks. 
5

←One clearcut up close 

Shingletown/Manton area, east of Redding ↑
6

Big Bend/ Burney area, northeast of Redding ↑

Mt. Shasta area, north of Redding ↑
7

Tehama County, southeast of Redding ↓

↑This is part of a replanted clearcut unit from a plan that was filed in 1998, as the unit was in 2009. A 

timber harvest plan consists of ~40 separate units within a thousand or so acres. The surrounding 

grown forest next to the plantation in this photo has since been cut as part of another plan. 
8

↑ This is a replanted plantation after 21 years. Note the lack of forest structure (i.e. 

different sizes of trees), the lack of different plant and brush species, and the lack of 

decomposing organic matter on top of the soil that acts to protect and enrich it. 

↑ Note the difference in an unlogged area. These areas will be gone if the pace of logging continues at 

the present speed, or moves even faster due to the higher demands from the biomass plant. 
9

Biomass burning creates tons of ash that requires disposal 

An increase in ash production from the amount of 525,600 pounds per year to 16,293,600 

pounds per year will require a great deal more transportation (increasing fuel usage and 

coincident air quality impacts) and more landfill space. The ash is mixed with water for 

disposal. Some ash may also have high concentrations of heavy metals, depending on what 

is being burned.10 

Biomass energy requires additional usage of diesel fuel for cutting and transportation 

Fueling this plant will cause an increase in fuel consumption for transportation that will 

use many more hundreds of thousands of gallons of diesel. This is another cumulative 

impact that is being ignored. 

This chart is from the Intergovernmental Panel on Climate Change: 

The American Lung Association "does not support biomass combustion for electricity 

production".10 Emissions from vehicles and wood burning are known to increase 

particulates in the air and cause respiratory problems. Biomass plants have been found to 

operate at ~ 24% efficiency.11 Enlarging this inefficient and polluting plant will combine 

with other increasing emissions to cause more cumulative effects to the health and well 

being of the greater Shasta County area, and its surrounding counties. 

Conclusion 

SPI, and their proponents, have made a point of talking about the handful of jobs that the 

expanded plant could provide. Shasta County has a population of 177,223 people; Tehama 

County has 63,463 people.12 The other surrounding counties number additional tens of 
10

thousands more people. All of these people will be impacted by reduced air quality, water 

loss, and loss of forest cover. The EPA is a public agency that should be acting in the best 

interests of the majority of the population. This permit must not be modified to allow huge 

increases in cumulative impacts. 

Barnosky et al. published a scientific paper in 2012 that examined the potential of 

biological systems to change suddenly at all scales, from local to global.13 They wrote: 

"Localized ecological systems are known to shift abruptly and irreversibly from one state to 

another when they are forced across critical thresholds... 

...It is now well documented that biological systems on many scales can shift rapidly from 

an existing state to a radically different state. Biological states are neither steady nor in 

equilibrium... The shift from one state to another can be caused by either a 'threshold' or a 

'sledgehammer' effect. State shifts resulting from threshold effects can be difficult to 

anticipate, because the critical threshold is reached as incremental changes accumulate 

and the threshold value generally is not known in advance. By contrast, a state shift 

caused by a sledgehammer effect--for example the clearing of a forest using a bulldozer--

comes as no surprise. In both cases, the state shift is relatively abrupt and leads to new 

mean conditions outside the range of fluctuation evident in the previous state... 

...Humans have already changed the biosphere substantially...the biological resources we 

take for granted at present may be subject to rapid and unpredictable transformations 

within a few human generations." 

We call upon the EPA to act with foresight and knowledge to protect the future. The 

corollary significant effects that enlarging this biomass plant would contribute to must be 

acknowledged, not ignored. 

Marily Woodhouse, Director 

Notes/Sources 

1 Partnership for Policy Integrity, www.pfpi.net, Biomass power cuts forests, pollutes the air, drains rivers, 

and worsens global warming--While costing taxpayers billions as "renewable" energy. 

Figures derived from: 50 MW plant produces 13,200 tons of CO2 per MW per year; uses 14,000-18,000 

gallons water per MW per day; uses 13,000 tons of wood per MW per year; produces 60 pounds of ash per 

MW per hour; logging and transportation of 1 ton of woodchips uses 2.1 gallons of diesel fuel= 27,300 gallons 

per MW per year

2 Miller, Peter. 2008. A Review of SPI’s study: “Carbon Sequestration in Californian Forests; Two Case 

Studies in Managed Watersheds”. 7 pp. 

3 Carle, David. 2004. Introduction to Water in California. University of California Press, Berkeley, CA. 261 pp. 
11

4 http://www.redding.com/news/2013/dec/31/california-marks-2013-historically-dry-year/

http://www.redding.com/news/2013/dec/31/dry-weather-wont-let-up-on-a-thirsty-north-state/ 

5 USDA Soil Conservation Service. 1974. Soil Survey of Shasta County Area, California. 176 pages. U.S. 

Government Printing Office, Washington, D.C.

6 http://www.wunderground.com/weatherstation/WXDailyHistory.asp?ID=KCASHING10 

7 Schwalm, Christopher R., Christopher A. Williams, Kevin Schaefer, Dennis Baldocchi, T. Andrew Black, 

Allen H. Goldstein, Beverly E. Law, Walter C. Oechel, Kyaw Tha Paw U, Russel L. Scott. 2012. Reduction in 

carbon uptake during turn of the century drought in western North America. Nature Geoscience, DOI: 

10.1038/NGEO1529

8 California Natural Resources Agency and California Environmental Protection Agency. 2013. AB 1492 

Report. 18 pp. 

9 Pimentel, D., U. Stachow, D.A. Takacs, H.W. Brubaker, A.R. Dumas, J.J. Meaney, J.A.S. O’Neil, D.E. Onsi, 

D.B. Corzilius. 1992. Conserving biological diversity in agricultural/forestry systems. Bioscience 42: 354-362. 

10 American Lung Association. Public Policy Position on Energy. Approved June 11, 2011. 

11 Partnership for Policy Integrity, www.pfpi.net, Carbon emissions from burning biomass for energy. 

12 http://en.wikipedia.org/wiki/Shasta_County,_California 

13 Barnosky, Anthony D., Elizabeth A. Hadly, Jordi Bascompte, Eric L. Berlow, James H. Brown, Mikael 

Fortelius, Wayne M. Getz, JohnHarte, Alan Hastings, Pablo A. Marquet, Neo D. Martinez, Arne Mooer, Peter 

Roopnarine, Geerat Vermeij, John W. William, Rosemary Gillespie, Justin Kitzes, Charles Marshall, Nicholas 

Matzke, David P. Mindell, Eloy Revilla & Adam B. Smith. 2012. Approaching a state shift in Earth’s biosphere. 

Nature, Vol 486, pp. 52-58. doi:10.1038/nature11018