April 21, 2009

Dear Drs. Volk, Bucholz and Luzadis:

We, the undersigned would like to comment on the NY Renewable Fuels Roadmap. We appreciate your efforts to reach out to the public on this important issue but feel compelled to offer additional comments here that have perhaps not been adequately captured by the survey that was distributed at the listening sessions.

These comments are an outgrowth of one such listening session that was held on 3/18/09 at the Cornell Cooperative Extension Learning Farm in Canton, NY. It was attended by nineteen people who are distinguished by their interest and commitment to the wise use of renewables, but these comments also reflect the broad consensus of the signatories, some of whom were not at the listening session.

St. Lawrence County, like other counties of the North Country has a large amount of renewable forest and grassland biomass resources that will inevitably play an increasing role in New York State’s energy mix. We cannot stress strongly enough that these precious, indigenous resources must be managed on a sustainable basis. The annual increment of growth minus the energy it takes to utilize the resource, defines the net available energy that is exploitable per year. This value (based on conservative assumptions) must be determined in order to have any coherent policy on renewable biomass fuels. In order to achieve sustainability, we believe that using the energy economics of nature as a model will provide the best guidance. That is to say, the principle (or goal) of minimizing energy loss when converting stored photosynthetic energy to useful work should be paramount. For the sake of simplicity, we will henceforth refer to this principle as “efficiency”.

Biomass fuels are by their very nature low-density energy sources, unless they are upgraded by drying or densification, thereby consuming more energy. This fact constrains the distance they can be economically transported and holds true regardless of whether one is talking about firewood, chips, wood pellets or grass pellets. (There is of course, also the restriction against moving firewood to prevent the spread of exotic invasive insects.) We would like to focus on two specific biomass examples in order to better describe a system that attempts to achieve biomass resource conservation and efficiency:

Wood Chips – These are best used as locally as possible in institutional and industrial applications to displace fossil fuel sources. The distance from source to use should be as short as feasible. They should be burned as efficiently as possible, ideally in a combined heat and electrical power system in order to minimize energy conversion losses. Gasification, coupled with advanced gas turbines or microturbines are some examples of high-efficiency technologies. Low-temperature heat that would normally be wasted should be used for low-temperature applications, such as greenhouses.

Following these principles of resource conservation and energy efficiency will result in maximum benefit to local economies.

Grass pellets – Producing grass pellets for local consumption using on-farm pelletizers or modular/mobile pelletizers would provide diversity to many agricultural operations by adding value to grass crops and displacing fossil fuels. There is a nascent community of grass pellet makers in the North Country who are trying to become proficient in the use of both production and combustion technologies. Grass pellets provide a good source of heat for farm or residential applications, but due to higher ash and chlorine content, they need to be burned in stoves and furnaces that are designed for them. The ash from both grass pellets and woody biomass should ideally be returned to the soils that supported the plants while they were growing. The State (NYSERDA) should assist by supporting the development of reliable, cost-effective hammermill-pelletizer systems in sizes appropriate to pellet production on-farm and/or by cooperatives. What is needed is a field-tested system that is capable of producing a significant hourly output with minimal labor requirements. Preferably such equipment would be manufactured in the State. The State should also consider providing technical assistance to cooperatives in order to develop local bioenergy economies.

New York State should provide incentives in proportion to the overall energy efficiency of a biomass-fueled system. The more useful BTUs of energy that can be extracted per unit of biomass, the higher the incentive should be. Much higher energy efficiencies and fossil fuel displacement can occur with the use of these same biomass resources for heating rather than biofuels.

Despite the fact that most of the petroleum fuel New York State imports goes to the transportation sector, we do not believe that the highest and best use of the biomass resources that predominate in St. Lawrence County is to make liquid fuels from them.

For the sake of sustaining the resources, practicing resource conservation and retaining dollars and employment in local economies, we prefer not to see primary biomass – biomass that has not yet had value added -- exported from our area to make liquid fuels. If, after satisfying as much local demand for heat, hot water, steam and electricity as we can with biomass, and there is enough biomass left to support a local bio-refinery within St. Lawrence County, then we could consider such a proposal.

In summary, in order to extract the maximum benefit from plant biomass resources, energy losses through harvesting, processing and transportation need to be minimized. This argues in favor of local use. Local use will tend to keep dollars local.

Thank you for the opportunity to comment.

Gregory M. Paquin, Chairman
St. Lawrence County Board of Legislators

David Katz, Chairman
St. Lawrence County Environmental Management Council

Douglas Welch, Chairman
St. Lawrence County Planning Board

Susan E. Powers, Ph.D.
Assoc. Dean and Professor, Clarkson University

CC:
Corrinne Rutzke, Riley-Robb Hall, Room 330, 88 East Miller Road, Ithaca, NY 14850

Zywia Wojnar, Pace Energy and Climate Center, E-House, Pace Law School, 78 North Broadway, White Plains, NY 10603

Judy Jarnefeld, NYSERDA, 17 Columbia Circle, Albany, NY 12203-6399