Biomass Energyand

Health in Humboldt County

Wendy Ring MD, MPH

December 2016

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EXECUTIVE SUMMARY

Humboldt County's biomass power plants were built in the 1980's for the dual purposes of generating electricity and disposing of mill waste. As knowledge has advanced in the ensuing decades, it has become clear that these benefits do not come without a cost. There is strong evidence-based consensus in the medical and public health community that burning biomass for energy is harmful to public health.

Humbolt's aging biomass plants emit more pollution than coal fired plants and are among the county's top stationary sources of air pollution. Over thirty percent of the county population is vulnerable to pollution-related health harm including increased emergency room visits, hospitalizations, and premature deaths. Regulatory agency monitoring is currently inadequate to protect public health.

BACKGROUND

Humboldt's biomass power plants in Scotia, Fairhaven, and Blue Lake were constructed in the 1980's to turn mill waste into electricity. The plants burn mill waste in boilers, producing steam to power turbines. The facilities are at the end of their life span, which on average is 20-30 years. As the costs of competing sources of electricity such as wind, solar, and natural gas have dropped, biomass energy has

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become commercially nonviable. Utilities which formerly purchased biomass power from local plants have cancelled contracts and/or failed to renew them.

The Community Choice Energy program has chosen to buy electricity from these aging plants because their energy is local and renewable and burning mill waste supports the local wood products industry.

A MAJOR SOURCE OF POLLUTION Humboldt County's biomass plants are among the county's top stationary sources of air pollution. In 2014, they collectively emitted 2,900 tons of carbon monoxide, 470 tons of nitrogen oxides, and over 100 tons of fine particulates. These amounts of criteria pollutants are seventy to seven hundred times more (varies by pollutant) than the Humboldt Bay Generating Station, which burns natural gas and produces more electricity than all 3 biomass plants combined. In 2013 (the most recent data available ) Blue Lake and Fairhaven each emitted nearly six tons of benzene and formaldehyde.

Table 1. REPORTED ANNUAL EMISSIONS 2014 (tons/year) 2013 (lb/year)

Facility MW CO NOx SO2 pm10 pm2.5 Benzene Formaldehyde Blue Lake 11 659 99 16 26 24 2006 2106Fair Haven 18 1466 171 30 34 31 9469 9923Eel River* 28 683 202 30 43 40 11947 17367

PG&E (gas) 163 8 15 0.1 1.2 1.2 770 2198

*now called Humboldt RedwoodSource: California Air Resource Board Emissions Inventory Facility Information

Since our local biomass plants generate different amounts of electricity, the best way to compare them is to look at emissions per megawatt hour generated. In 2014, Eel River produced the most pollutants per megawatt hour, followed by Blue Lake, and then Fairhaven. The difference between plants is as much as 50-60%.

Table 2. Emissions per MWh (in pounds)

Facility CO NOx SO2 pm2.5

Blue Lake 19.7 2.96 0.48 0.72Fairhaven 23.8 2.78 0.49 0.50Eel River 14.1 4.18 0.62 0.83

Sources: California Air Resource Board Emissions Inventory, Redwood Coast Energy Authority (Mwh compilation from California Energy Almanac)

HEALTH IMPACT OF BIOMASS ENERGYMany respected health organizations oppose burning biomass for electricity because it is harmful to

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public health. These groups include the American Academy of Pediatrics, American Lung Association, American Public Health Association, Asthma and Allergy Foundation of America, National Association of County & City Health Officials, National Environmental Health Association, Trust for America's Health, Children's Environmental Health Network and Physicians for Social Responsibility. Biomass pollutants increase emergency room visits, hospitalizations, and premature deaths. We don't notice these harms occurring in our community because they are hidden in plain sight. Pollution doesn't cause exotic diseases, it increases the frequency and severity of common ones, like lung disease, heart disease, and cancer.

Particulates Particulate matter, otherwise known as soot, is leftover carbon that didn't burn. Fine particulates, under 2.5 microns in size, are the most hazardous to health. Fine particulates make up more than 90% of the particle pollution from Humboldt biomass plants. They cause inflammation in the lungs leading to asthma attacks, exacerbations of chronic lung disease and lower respiratory infections. They enter the bloodstream, causing strokes and heart attacks. Chronic exposure causes narrowing of the arteries. Our county has non-attainment status for particulates, which means that levels violate EPA air quality standards.

Nitrogen Oxides Acute exposure irritates the eyes, nose, and throat; and increases emergency room visits and hospitalizations for asthma and chronic lung disease. Chronic exposure causes childhood asthma. Nitrogen oxides combine with carbon monoxide and other biomass pollutants to form ozone.

Carbon Monoxide (CO)Carbon monoxide decreases the body's ability to absorb and transport oxygen. Outdoor exposure to carbon monoxide is not harmful to healthy people, but can cause chest pain, or angina in people with heart disease.

OzoneOzone, commonly known as smog, is formed by the mixing of nitrogen oxides and carbon monoxide or volatile organic chemicals. Acute exposure decreases pulmonary function in healthy children and exacerbates asthma and chronic pulmonary disease, increasing emergency room visits, hospital admissions and premature deaths. Chronic exposure to ozone causes childhood asthma.

Air Toxics Naturally occurring chemicals released from burning wood can cause cancer, birth defects, miscarriages, brain damage, and other serious health impacts. Dioxin, benzene and formaldehyde are examples of toxic compounds emitted from biomass plants.

Sources: September 13 2016 letter to Congress from health organizations (attached)EPA. Integrated Science Assessment for Particulate Matter. 2009. WHO International Agency for Research on Cancer. IARC Monograph on the Evaluation of Carcinogenic Risks to Humans. 2016 Volume 109, Outdoor Air PollutionEPA. Integrated Science Assessment for Oxides of Nitrogen-Health Criteria. 2016.EPA. Integrated Science Assessment of Ozone and Related Photochemical Oxidants. 2013.EPA. Integrated Science Assessment for Carbon Monoxide, 2010. Beauchemin, P. Emissions from Wood-Fired Combustion Equipment. British Columbia Ministry of the Environment. 2008

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VULNERABLE POPULATIONS Not all people are equally sensitive to biomass pollution. Fetuses, infants, children, and teenagers are more vulnerable to permanent damage from air pollution because their lungs and brains are still developing. The elderly are more sensitive, as are people with diabetes, and chronic heart and lung disease because the inflammation caused by inhaling pollutants triggers constriction of airways and arteries already affected by age and disease. People of color and low income people are more vulnerable because they suffer disproportionate exposure and have worse health outcomes.

QUANTIFYING THE POPULATION AT RISK Vulnerable age groupsRoughly 30% of the Humboldt County population is in the vulnerable age ranges of under 18 or over 65. In some of the towns closest to biomass plants, the proportions are higher. 40% of Scotia residents and 75% of the population of Blue Lake Rancheria are in these vulnerable age groups.

Vulnerable conditionsAsthma is one of the fastest growing chronic diseases in California. Humbldt County has more asthmatics per capita and a 40% higher rate of emergency room visits for asthma than the state average. Roughly 1 in 10 children and 1 in 5 adults in Humboldt county have asthma. Due to having a higher percentage of smokers we also have a higher prevalence and death rate for chronic obstructive pulmonary disease. One in ten Humboldt adults have been diagnosed with heart disease.

Taken together, these high risk groups make up a large slice of Humboldt County's population. Forty four thousand county residents are vulnerable due to age, twenty four thousand are vulnerable due to asthma, and ten thousand are vulnerable due to heart disease. These numbers can't be added since there is probably some overlap but it is clear that a substantial portion of the population is at risk of harm.

Sources: US CensusHumboldt County Community Health Assessment California Health Information SurveyHumboldt County Asthma Profile http://www.californiabreathing.org/asthma-data/county-asthma-profiles/humboldt- county-asthma-profile

GEOGRAPHIC AREA AT RISK Residential proximity to fuel fired power plants is known to increase health impacts such as adverse birth outcomes, hospitalizations for asthma, COPD, and pneumonia and school days missed due to asthma. Increased incidence of adverse health effects has been found extending in a radius of 30-50 miles from power plants. Those who live closest have the most exposure and health consequences. Residents of Scotia and Blue Lake have additional exposure because the Mad River and Eel River valleys trap polluted air increasing the intensity and duration of exposure.

Biomass pollutants can persist for days and travel thousands of miles, putting communities downwind at risk. In the winter and fall prevailing winds from the southeast transport pollution from Scotia to Rio Dell and Fortuna, and from Blue Lake to Arcata. In the summer prevailing winds from the northwest carry pollution from Fairhaven to Cutten, Humboldt Hill, Loleta, and Fortuna. Sources:

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Estimated public health impacts of criteria pollutant air emissions from nine fossil-fueled power plants in Illinois. Levy, J. et al (2000) Harvard School of Public Health PaperCoal power plant emission exposure and its effect on education access JPublicHealth 22(4):313-321 · January 2014 Associations Between Residential Proximity to Power Plants and Adverse Birth Outcomes. Ha, S. et al  (2015) 182 (3):215-224.doi: 10.1093/aje/kwv042

ECONOMIC COSTThe medical costs of pollution induced or exacerbated illness are substantial. A typical emergency room visit for asthma costs $1,500 and an asthma hospitalization costs $6,000. An increase in asthma severity from mild to moderate requires the addition of maintenance medication costing $200-300 per month. A hospital admission for an exacerbation of chronic obstructive pulmonary disease costs $9,700 and an increase in COPD severity from mild to moderate adds $800 per month of medications. The lifetime cost of a heart attack, including care and lost productivity is $760,000. Some of these costs are paid out of pocket by individuals but most are shared by all of us in the form of taxes and insurance premiums.

The health impacts of air pollution exact an indirect cost on the economy due to lost productivity from missed days of work and school. Children who live near pollution emitting power plants have double the number of school absences due to asthma. Nationally, asthma causes 10.5 million missed school days and 14.2 million days of missed work at an estimated annual cost of 3.8 billion dollars.

Because Humboldt County has a chronic physician shortage, another cost we all pay is decreased access to health care. With practices closing, doctors not taking new patients, and appointment schedules full, and every office visit for care of a pollution related illness means someone else has to wait for medical attention.

Sources: Humboldt County Asthma Profile http://www.californiabreathing.org/asthma-data/county-asthma-profiles/humboldt-county-asthma-profileCDC. Asthma Facts— U.S. Department of Health and Human Services, Centers for Disease Control and Prevention, 2013.Barnett, S Costs of asthma in the United States: 2002-2007. Ann. Allergy Asthma Immon. 127:(1) 145-152. 2011

EQUITYThe economic benefits of biomass energy accrue to a relatively small number of people: the plant owners and the timber sector, which currently comprises 12% of the county's economy. The costs of biomass energy are more widely distributed, borne not only by the vulnerable groups previously enumerated, but by the entire community.

Source: Humboldt Economic Index, HSU Department of Economics 2016.http://www2.humboldt.edu/econindex/current.pdf

REGULATION DOES NOT EQUAL PROTECTIONWe don't know the true extent of biomass pollution's impact on air quality in Blue Lake, Fairhaven, and Scotia because it has never been measured. There are 3 air quality monitoring stations operating in Humboldt county and they are all in Eureka.

The North Coast Unified Air Quality Management District (NCUAQMD) regulates power plants as major sources under the Clean Air Act. NCUAQMD only requires biomass plants to monitor their particulate emissions once every one to two years. Hazardous spikes of particulates, sufficient to trigger asthma and cardiovascular events, occur during startup and shutdown and with increased fuel

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moisture. One measurement every 12-24 months will not detect these intermittent elevations and could leave a plant emitting daily dangerous levels of particulates for a year prior to detection.

Oversight of plant emissions also appears to be lacking at the state and local levels. Biomass facilities monitor their own emissions and report the results to NCUAQMD. The District forwards them to the California Air Resource Board which posts annual emissions inventories for each facility online. In the process of preparing this report, it was noted that NCUAQMD submitted completely identical emissions data to the state in 2012 and 2013 for all 4 power plants in its jurisdiction. I checked to make sure this was not simply a website error and Air Resource Board staff verified that these are the figures they received from the District. It is virtually impossible to have 2 years of identical emissions data for 7 criteria pollutants from 4 individual facilities.

Given the lack of air quality monitoring in communities where plants are located, the infrequency of monitoring particulate emissions, and less than rigorous oversight of emissions reporting, it would be a mistake to assume that regulatory agencies are protecting the public from the health harms of biomass pollution.

Sources: CARB Emissions Inventory, Title V plant operating permits issued by NCUAQMD.

LIMITED POTENTIAL FOR IMPROVEMENTHumboldt's biomass power plants were built over 30 years ago when air quality standards and pollution control technology were far worse than they are today. Plants are not required to upgrade pollution controls to current standards unless they modify their facilities. Blue Lake Power is the only plant which has had to do this in recent years, and it has taken multiple Clean Air Act violations and a lawsuit to force compliance. The cost of upgrading Blue Lake Power to meet EPA's requirement for Best Available Control Technology is estimated to be $700,000. EPA's mandated emissions limits AFTER new controls are installed are still two to four times higher than EPA limits for “middle-aged” coal fired power plants.

Table 3. EPA Allowable emission rates lb/ MMBtu

Blue Lake* Fairhaven Scotia Coal NOx 0.15 -.175 0.16 - 0.23 0.2 - 0.26 .088 CO 0.50 – 0.69 2.5 - 4.0 1.2 - 3.0 .144 PM10 0.02 - 0.03 0.04 0.04 .017

* after installing mandated new pollution controlsSources: Allowable emissions rates in 2016 EPA consent decree with Blue Lake Power http://www.ncuaqmd.org/files/permits/BLP/Exhibit%201%20-%209.pdfAverage EPA emission limits for COAL POWERED plants permitted 2002-2006 https://www.dep.state.fl.us/air/emission/construction/taylor/BACT.pdfNCUAQMD Title V Operating permits for Fairhaven Power and Humboldt Redwood

A SIGNIFICANT FRACTIONA lot of pollution in our county doesn't come from stationary facilities but from non-point sources like road dust and vehicle exhaust. On a countywide level, pollution from these sources dwarfs emissions from power plants, which raises the question: What difference does it make to eliminate a small

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fraction?

Aggregate data obscures local effects. Communities with biomass plants have a larger fraction of biomass pollution and will benefit the most if these plants close. Also the relation between air pollution and health is linear. There is no safety threshold below which no one gets sick. People with asthma and chronic lung disease are exquisitely sensitive to pollution and suffer adverse effects even at low levels when air quality meets EPA standards. These are very common diseases, with asthma alone affecting in in 10 children and 1 in 5 adults in Humboldt County. Lowering air pollution by even a few parts per billion will decrease ER visits and hospital admissions for these vulnerable individuals.

CONCLUSIONAir pollution from Humboldt's aging biomass power plants adversely affects the health of a large proportion of Humboldt County's population and imposes health costs on the entire community. Upgrading pollution controls is expensive, not required by law, and still leaves biomass plants emitting more pollution than coal. When present and future health impacts are taken into account, subsidizing the continued operation of these plants by buying their electricity at above market rates is not in the community's best interest.

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