Vermont’s 2016 Comprehensive Energy Plan (CEP) aims for a statewide transition to ninety percent renewable energy by 2050 while “virtually eliminating reliance on oil.”

To help reach these goals, the state seeks to cut energy consumption by fifteen percent by 2015 and by over one-third by 2050 through efficiency and conservation measures.

Within ten years Vermont hopes to procure twenty-five percent of its energy from renewables, with forty percent by 2035. For 2025, the breakdown would include sixty-seven percent renewable electricity, thirty percent renewable heating, and ten percent renewable transportation fuels.

A significant component of renewable energy would come from bioenergy, mostly sourced from forests, with a small percentage of agricultural crops such as willow and grasses.

The CEP outlines eight principles to guide the further development of bioenergy in the state.

Principle #1:“Maintain forest health as a prerequisite to a sustainable wood energy fuel supply.”

Vermont’s forests contain 8,593 million cubic feet (107.4 million cords) of “standing timber.” Each year, the forests add 166.6 million cubic feet (2.1 million cords) of new growth, with 70.2 million cubic feet (0.9 million cords) cut for lumber, paper, fuel, and development.

This annual growth of 96.4 million cubic feet is belied by the fact that forest cover overall is actually decreasing in Vermont. The CEP documents how the state’s forests are becoming increasingly fragmented, with a “gradual loss of forestland that since 2007 has totaled about 75,000 acres.”

The plan notes that an increased demand for bioenergy will “likely begin to put more pressure on Vermont’s forests and farmland.”

Existing bioenergy demand for wood in Vermont includes two stand-alone biomass power facilities, the 50-megawatt McNeil Generating Station in Burlington and 25-megawatt Ryegate facility in Caledonia County in the Northeast Kingdom. McNeil burns 440,000 tons of wood per year with anywhere from one-half to two-thirds sourced from Vermont, the rest from neighboring states. Ryegate consumes about 200,000 tons annually.

Since 2014, McNeil hasn’t operated as a baseload facility as it has in the past, and is instead running at sixty-five percent capacity, a situation attributed to a “combination of wood-supply and bid-pricing issues.”

Since 2013, the 75 megawatt Laidlaw Berlin BioPower facility in Berlin, New Hampshire has also sourced at least five percent of its annual wood supply from Vermont’s forests, about 37,500 tons. The CEP takes into account such “increased regional competition for fuel-grade wood.”

Combined heat and power facilities in Vermont burn about 44,000 tons per year. Sixty schools, nineteen businesses, thirteen state buildings (including district heating), five college campuses, and twenty-four multi-family complexes heat with wood, along with 200 bulk pellet residential boilers.

Thirty-seven percent of the state’s households heat at least partially with firewood or wood pellets. 869,000 tons of cordwood is cut mostly in state, while 252,000 green tons of pellets is sourced mainly from Quebec and elsewhere in New England.

Whole trees, as well as treetops and branches left over from logging for lumber, comprise the vast majority of the state’s biomass energy, along with urban tree trimmings. While whole trees are part of the fuel mix, it’s difficult to determine the exact proportion in comparison to tops and branches.

Some forest advocates are concerned that an uptick in biomass energy will increase the amount of tree cutting to fuel facilities.

“The biomass industry includes trees that they call ‘low grade’ in their definition of ‘waste’ or ‘residues’ simply because they are a species, or have characteristics that do not provide high commercial market value,” said Chris Matera, founder of Massachusetts Forest Watch, who has researched biomass energy across Vermont and much of New England.

“To the rest of us, and to nature, these are important trees that filter the air and water, sequester carbon, maintain the soil, attract tourists, and provide wildlife habitat,” said Matera.

In 2009, the Vermont Legislature commissioned the Biomass Energy Development Working Group, comprised of representatives from the biomass and logging industries, foresters, environmental groups, and other interested parties to guide the utilization of biomass energy in the state. Its 2012 final report included several recommendations for forests.

One recommendation was for the Vermont Department of Forest Parks and Recreation to undertake a “harvesting impact study” comparable to one completed in 1990 to assess logging impacts statewide. The Working Group also encouraged monitoring of available biomass to “ensure confidence in assumptions about future forest growth and broader ecosystem and social impacts.”

Another suggestion was for a “uniform system for implementing wood procurement standards” for all scales of biomass energy. Additionally, the Working Group would like to see two positions created with Agency of Natural Resources to investigate logging for biomass in regards to ecological impacts, with the positions funded by a tax on wood consumption (for those using over 50 green tons per year).

Further, the Working Group advocated for a monitoring of a “representative sample of harvest operations” for biomass and possibly biomass site inspections as ANR used to conduct in the 1980’s when the McNeil Generating Station first came online.

Principle #2:“Improve the economic stability of forestland by expanding opportunities to market low-grade wood as an energy fuel source.”

2,500 to 3,500 workers are employed in the forestry and wood products industry in Vermont, which has historically made up less than 2% of statewide employment. According to the CEP, the expansion of bioenergy can “present far greater opportunities for employment, innovation, and profit in the harvesting, processing, and delivery of wood products.”

Currently, the majority of wood pellets consumed by Vermonters comes from Quebec and elsewhere in New England, as well as a significant portion of fuel for biomass electricity. Nearly all of Vermont’s cordwood is sourced in state.

According to the Montpelier-based Biomass Energy Resource Center, a program of the Vermont Energy Investment Corporation (VEIC), biomass energy has significant economic benefits due to the fact that it can be “locally produced, harvested, and processed.” Expanding biomass infrastructure creates more jobs, boosts the forest products industry, and generates local, state, and federal tax revenue.

Members of the biomass industry are generally pleased with the economic promise of the CEP.

“The Plan’s focus on feedstock development through sustainable forest management practices and a special focus on working with the academic community to develop short rotation energy crops offers promise that the state is seriously engaged in making biomass energy an important part of the state’s forest economy,” said Evan Dell’Olio, Director of External and Regulatory Affairs for Roberts Energy Renewables, a developer of New England bioenergy facilities.

Vermont’s forests also generate income through recreation and tourism, which brings in about $3.7 billion per year (indirect) and $2.2 billion directly, while generating twenty-three percent of state employment, according to a University of Vermont study.

Principle #3: “Increase the use of modern, advanced clean wood energy technology, especially in areas of at risk populations.”

The CEP acknowledges health risks from biomass energy, namely combustion-related air emissions that have “potentially negative implications for public health.” Therefore, the plan seeks to promote “best practices to reduce the emissions of pollutants and minimize adverse health effects.”

Biomass has lower sulfur dioxide emissions than fuel oil, yet it “emits substantially more of certain other pollutants—including fine particulate matter (PM2.5), carbon monoxide, and polycyclic aromatic hydrocarbons.”

Particulates can have “heart and lung impacts, and exacerbation of asthma and other respiratory conditions.” Any increase in particulates “will have a negative health impact.”

The CEP cites a 2015 World Health Organization report demonstrating that “residential heating by wood in North America was responsible for 8.3% of the total PM2.5 [particulate matter 2.5] and was associated with 9,200 premature deaths per year.”

The plan mentions other pollutants, including “nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOCs), and potential carcinogens including benzene and polycyclic aromatic hydrocarbons (PAH).”

Carbon monoxide (CO), a pollutant that results from incomplete combustion and “typically emitted by all combusting fuel sources,” is also of concern.

In order to “protect public health,” the CEP says that advanced pollution control technologies that can significantly reduce—though not completely eliminate—emissions “may be required.”

In its previous comments on the CEP, The American Lung Association (ALA) of the Northeast encourages public impact assessments for new and existing energy projects, including biomass energy, which could be funded through public and private partnerships.

The ALA applauds the review of health impacts mentioned in the CEP, however it reminds the state that action is also necessary, as “a review alone will not necessarily result in any decisions to protect the health of Vermonters.”

ALA wishes to see mandatory air pollution control technology in schools heating with wood, while encouraging air quality permits and emissions standards for future installations of biomass boilers in schools.

ALA wants ongoing financial incentives to replace older wood stoves with newer wood or pellet stoves meeting EPA certification. ALA also would like the state to require homeowners to dispose of older wood stoves and boilers upon selling their property.

Vermont has the highest per capita emission of fine particulates from residential wood stoves, twice the amount compared to the number two state of Wisconsin.

Siting can affect air pollution from wood heating due to “topography, meteorological conditions, and building design.” For instance, mountain valleys often have higher levels of particulates than monitoring stations located elsewhere.

The plan notes that during the winter of 2014-2015 in Rutland, PM 2.5 levels were higher than during the prior ten-year average. The plan notes that residential wood burning increased between 2008 and 2015.

Rutland is the #1 city in the US for incidence of asthma in adults 18 years and older, with fourteen and a half percent of those sampled in 2010 suffering from the disease, according to Centers for Disease Control.

John Wakefield, Section Chief for the Air Quality and Climate Division (AQCD) of Vermont Department of Environmental Conservation said, “we take any potential increase in woody biomass burning into account as far as associated public health and environmental effects.”

The AQCD played a large role in getting the CEP to encourage the phasing out of older stoves and outdoor wood boilers to “minimize health and environmental impacts associated with the emissions from wood burning,” said Wakefield.

Currently the AQCD is revising its regulations to reach beyond outdoor wood boilers to also include wood and pellet stoves.

The CEP points out that pellet stoves have lower emissions than cordwood because of surface area and lower moisture content, yet pellets “present several additional health concerns.”

According to an analysis of wood pellets, “toxic elements, including arsenic, copper, and chromium, were found in some samples at levels exceeding European standards” blamed on waste wood painted with preservatives or paint. Currently, no state or federal standards exist in the US for wood chip or pellets.

The CEP cites trials demonstrating that agricultural biomass emissions are “generally worse than emissions from woody biomass combustion.”

Principle #4: “Maintain in-forest carbon storage and uptake, and support efficient advanced wood energy technology to improve energy use per carbon emitted.”

The CEP mentions that the carbon aspects of bioenergy are “very complicated, due in part to the complexity and variability of forests, and are intertwined with the natural carbon cycles of forests.” Therefore, general policies for accounting the CO2 are “often unreliable.”

The effect on the carbon cycle “can vary substantially” depending on factors including the kind of fuel, growth rates, type of logging, transportation of wood, and how the wood is burned.

A 2009 study from the Rubenstein School of Environment and Natural Resources, University of Vermont, determined that northeastern forests left unlogged store more carbon than logged forests.

The Plan distinguishes between “biogenic carbon” from forests that cycles between trees and fossil fuel carbon that has been in the ground for millennia. While some scientists believe it is important to distinguish between forms of carbon, others maintain that the atmosphere makes no distinction as to the origin of the carbon molecule.

Principle #5: “Expand energy production from this renewable — but finite — source by using the most efficient wood energy technology available.”

“The state’s focus on recognizing impediments to the development of combined heat and power plants is encouraging,” said Evan Dell’Olio of Roberts Energy Renewables.

The plan highlights the efficiency of various biomass energy technologies. The Standard Offer Program incentivizes biomass systems that achieve fifty percent efficiency, which disqualifies stand-alone biomass power facilities. The 50 MW McNeil Generating Station in Burlington and 20 MW facility in Ryegate typically operate around twenty five percent efficiency.

The plan notes a “volume of public comments received by the DPS [Department of Public Service] in opposition to electric-only woody biomass power,” drawing the conclusion that the public wants to see more efficient uses for biomass.

Combined heat and power facilities can reach as high as seventy five to eighty percent efficiency according to Biomass Energy Resource Center. Vermont is home to several institutional and commercial CHP facilities, which burn 44,000 tons of wood per year for a few megawatts of electricity.

The plan advocates for lowering current standards to incentive facilities that initially are below the fifty percent threshold, yet will increase over time. “This suggestion works in tandem with Vermont’s other thermal heating initiatives,” said Dell’Olio.

The CEP recommends that pellet systems be eighty five percent efficient and wood chip and cordwood burning seventy five percent.

Principle #6: “Use newer, cleaner-burning wood heating systems, to reduce the overall emissions of particulate matter and other air pollutants.”

Heating buildings is thirty percent of Vermont’s total site energy consumption.

The CEP estimates that thirty seven percent of Vermont homes heat with wood, with fifteen percent using it as a primary source. Meanwhile, thirty three percent use heating oil, twenty one percent use propane, twelve percent use natural gas, and the remainder some combination of alternative sources.

More than 100 facilities in Vermont employ industrial or commercial biomass heating— including biomass district heating in Montpelier and the Waterbury state office—and these numbers are “rapidly growing.”

One third of Vermont children attend a school heated by wood.

Vermont is estimated to be the #6 state in the US for wood heating, according to the US Census. Home heating makes up sixty percent of Vermont biomass heating, with twenty-nine percent commercial and eleven percent industrial heating.

Over the winter of 2014-2015, the CEP calculates Vermonters burned around 347,500 cords or 869,000 tons of wood, an increase of 4% since 2007-2008, or about 33,000 cords.

Households using wood for the primary heating source burned about 4.8 cords per year while those using auxiliary stoves burned 2.1 cords. Over 2014-2015, 126,000 tons of pellets were consumed, with primary source burning at 4.4 tons and auxiliary source at 3.3 tons.

252,000 green tons for pellets plus 869,000 tons for cordwood added up to 1,121,000 tons of wood to heat the state.

The CEP supports a change out of older wood stoves to be replaced with newer, Environmental Protection Agency-certified stoves, and doubling wood heating by 2035.

Currently, thirty percent of Vermont households use stoves or fireplaces installed before 1990.

Under Act 47 passed in 2011, Efficiency Vermont provides incentives for installing biomass heating systems. Other incentives come from the Vermont Small Scale Renewable Energy Program for biomass equipment. Both are “helping to drive increased use of biomass in the state.”

In 2013, the entire state of Vermont burned 2.3 million tons for all energy uses.

“The Plan’s goal to increase the number of homes primarily heated with biomass sourced from Vermont’s forests to 25% would present an excellent growth opportunity for the forest and wood products sector,” said Dell’Olio.

“Such a move builds upon previous successes such as Montpelier’s $6 million district heating system and $900,000 in grants awarded earlier this year to support the installation of wood heating equipment and the supply of wood fuels.”

Principle # 7: Improve local infrastructure and technology, to support the expansion of clean and efficient advanced wood energy.

Siting is one of the main obstacles facing new biomass facilities.

One challenge is the limited amount of zoned spaces for industrial facilities. Another involves “infrastructure limitations,” which can be related to transporting wood chips and pellets, tying into public systems such as water and sewage, and the transmission of heat and power to the locations that would make use of it.

For instance, there have been discussions for years about making use of the excess heat from the McNeil Generating Station, a plan that has yet to come to fruition.

 Principle # 8: “Capture the unique and diverse ecosystem services that grass and willow offer.”

The CEP is primarily focused on wood sourced from forests, however grass, willow, and corn are also mentioned.

When it comes to liquid biofuels, the CEP says Vermont will continue to make use of ethanol—typically from corn and soy, but Vermont “should not use its limited biomass resources for the production of ethanol.”

The report references Middlebury College’s study of willow plantations to fuel its combined heat and power biomass facility. The first crop was “poorly stored and too wet to burn properly, with insufficient volume to obtain correct combustion settings on the boiler.”

University of Vermont Extension and Vermont Sustainable Jobs Funds’ Vermont Bioenergy Initiative (funded by US Department of Energy) conducted field trials to grow switchgrass and other grasses, yielding between three to five tons per acre.

A “polyculture” blend of grasses yielded more than four tons per acre, which is considered more adaptable to changing weather patterns and rainfall. Miscanthus can produce seven tons per acre and is considered suitable to Vermont’s wet, clay soil.

Crop-based biomass is “very feasible in Vermont, especially when pursued in a model of local-production for local use,” said Christopher Callahan, with UVM Extension.

Farms growing oilseed crops to fuel tractors and using grass and other agricultural residue for heating and for hot water is “quite viable,” said Callahan, who is also director of the Northeast Center to Advance Food Safety.

Callahan said grass biomass crops are also an opportunity, and are “aligned with the region’s historical production and use of hay and other grass forages.”

While promising, Callahan points out these developments are “very small scale” and “not comparable to larger bio-refinery systems more common in the rest of the country.”

Vermonter Josh Schlossberg writes for “The Biomass Monitor.”