U.S. Densified Biomass (Wood Pellets) for UK and EU Export to Power Plants Stirring Pollution, Environmental Justice, and Life Cycle Greenhouse Gas Emission Concerns

 

     In past years environmentalists used to champion the use of woody biomass, especially for home wood burners and fireplaces as a natural, carbon neutral source of home heat. In more recent years the data clearly shows that woody biomass is not carbon neutral at all since a significant amount of the carbon from a decomposing tree will be taken up by nearby plants over the years and decades it decays. It can take decades for a decomposing tree to release much of its carbon into the atmosphere. When logs or pellets are burned that carbon is released instantaneously into the atmosphere along with a host of dangerous pollutants. In several cities around the world the biggest source of air pollution in the winter is home wood burning. Fortunately, environmentalists have reversed course on woody biomass with even hardcore environmentalists like Bill McKibben who once embraced biomass, turning away from it. Indeed, these days environmentalists are leading the charge against pollution, greenhouse gas emissions, and environmental justice concerns of biomass.

     This post is not about home wood burning but about the densified woody biomass industry where forest waste, wood product waste, and hardwood trees, are processed by being densified into chips and pellets, transported on ships to the U.K. and E.U. countries to be burned in power plants while getting credited and subsidized as a form of renewable energy. Now it is true that wood pellets produce less emissions than logs when burned so pellet stoves are indeed less polluting and less carbon intense than logs. However, the energy it takes to process the wood into pellets subtracts from the pollution and carbon intensity advantages of pellets over logs. A certain percentage of the densified woody biomass for export comes directly from cutting hardwood trees. This portion also increases carbon emissions through deforestation. The Energy Information Administration (EIA) began reporting more in depth on densified biomass in 2016. Now there is a monthly densified biomass report.

Source: Southeast U.S. Wood Pellet Plants Exporting to Europe. SELC_WoodPelletExportMap_2022_0908_maptable.pdf (southernenvironment.org)

 

   Source: Energy Information Administration  

          An environmental group, the Rachel Carson Council, published a scathing report in 2019 about the environmental and environmental justice concerns of the densified biomass industry, focused on the industry in North Carolina and the company Enviva. They noted that the Southeast and North Carolina have the largest concentration of clear-cutting logging for the wood pellet industry. The wood pellet for export industry began to take off in the mid-2000’s as EU countries and the UK were looking for alternatives to coal. Since coal plants can be relatively easy to adapt to burning wood pellets and pelletized wood does have less combustion emissions than coal it was considered to be a “green” solution. However, more recent changes to carbon accounting and life-cycle pollution emissions have shown that this is not a green solution at all. Citing a 2015 study by the NRDC they note that several new studies “have found that burning wood pellets for fuel releases as much as, or even more, carbon dioxide per unit of energy than coal.” Whether this is true depends on several factors such as wood sources for pellet production, time frame, and post-harvest forest management practices. Greater demand for wood pellets has resulted in higher percentages of clear-cut hardwood forests supplying the industry. That really hurts the carbon accounting. Clear-cutting is de facto deforestation. It has led to flooding and erosion issues in North Carolina. It can also reduce biodiversity if not done correctly.

Source: Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice. Rachel Carson Institute. 2019. Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice (sec.gov)

Source: Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice. Rachel Carson Institute. 2019. Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice (sec.gov)

     Wood chips are processed first by drying at very high temperatures, then ground into a fine powder, then compressed into pellets. Processing and burning of wood pellets produce volatile organic compounds (VOCs), nitrogen oxides, carbon monoxide (CO), and particulate matter (PM).  Up until 2018 these facilities were not required to have pollution controls in North Carolina. The Rachel Carson Council report notes that there have been many complaints about pollution from the industrial drying facilities and that several of the facilities are very near what are considered to be environmental justice communities. Other environmental issues include several reports of smoldering wood piles and the NRDC reported that “Between 2014 and 2018, local residents reported fires and explosions at eight of the country’s 15 largest wood pellet manufacturing facilities.” Apparently, local dust (ie. particulate matter) is also a major issue.

Source: Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice. Rachel Carson Institute. 2019. Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice (sec.gov)

     Drax Power Station in Northern England converted its generating units from coal to densified biomass in 2018, earning large government subsidies and tax incentives for converting to “renewable” power. While biomass can be considered to be renewable on a long time scale (it takes decades to replace a logged tree) it is not sustainable or green by any measure. The UK does not account for the deforestation, processing, and delivery of the pellets in its greenhouse gas inventory. The idea that burning the wood pellets produces 85% less greenhouse gases than burning coal is a really a joke. The NRDC calls it scientifically indefensible. This is of course because combustion emissions are only a small percentage of life cycle emissions for exported pelletized wood.  

     The vast majority of wood pellet production in the U.S. and Canada is for export. In 2016 82% of wood pellets were exported and 15% of total wood pellet production, or 405,900 tons, came from logging of hardwood trees. In 2021 the percentage of produced pellets exported was still at 82%. U.S. pellet production quadrupled between 2012 and 2016. From 2016 to 2021 it appears that U.S. pellet production increased more than another 30%, As total exports have increased significantly so has total amount of exports from logging of hardwoods. As in burning coal, burning wood creates ash. Pellets produce less ash than wood logs, having a higher rate of combustion. Home pellet stoves burn at 78% efficiency compared to wood stoves which burn at 54% efficiency. For comparison natural gas and propane unvented heaters for homes burn at over 99% efficiency and produce no ash.     

 

Source: Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice. Rachel Carson Institute. 2019. Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice (sec.gov)

Source: Energy Information Administration

Drax Wood Pellet Plant in Mississippi Routinely Exceeds Annual Air Pollution Limits

     More recently, a wood pellet production facility in Mississippi operated by the Drax Group, part of the UK company that owns Drax Power Station, has been the subject of environmental justice scrutiny. Local residents have been complaining about air pollution and noise pollution at night. They have demanded air quality monitors and less night-time operation. They have been battling the plant since it opened in 2016. Production has ticked up since the invasion of Ukraine and Europe and the UK’s rush to find energy cheaper than the costly oil and gas in 2022. NBC News reports:

“In 2020, the Mississippi Department of Environmental Quality fined Drax $2.5 million for violating its permit’s annual limits on the release of volatile organic compounds. Drax said the company has taken the appropriate steps to come into compliance with volatile organic compound limits.”

“Outside Mississippi, Drax agreed to $3.2 million in state penalties in Louisiana just last year for air pollution violations, though it did not admit any wrongdoing.”

     Around 7% of the U.K.’s electricity comes from the Drax Power Station. The company, which also produces hydroelectric power and power from pumped storage hydro, showed decent profits in 2022 like many energy companies. However, without government subsidies Drax would struggle to be profitable, according to their financial reports.

 

In Conclusion

     The bottom line for this post is that densified biomass, due to its life cycle carbon emissions, the time it takes to re-generate forests, and its significant air quality concerns, should not be considered a viable climate solution. If all pelletized wood, rather than 80-85%, came from wood waste, that would be an improvement for carbon accounting. If the pellet production plants were to get better air quality monitoring, pollution abatement equipment, and better siting, then that would be an improvement for pollution concerns, environmental justice concerns, and nuisance concerns. If the U.K. and the E.U. would lower subsidization of the industry and focus on other fuel sources including natural gas, then the industry would not continue to grow as it has over the past decade.

 

References:

A Mississippi Community takes on a U.K. energy giant over pollution concerns. NBC News. August 6, 2023. A Mississippi community takes on a U.K. energy giant over pollution concerns (nbcnews.com)

Southeast U.S. Wood Pellet Plants Exporting to Europe. SELC_WoodPelletExportMap_2022_0908_maptable.pdf (southernenvironment.org)

Drax: Subsidies for power giant questioned as annual profits soar. Sky News. February 23, 2023. Drax: Subsidies for power giant questioned as annual profits soar | Climate News | Sky News

No, Burning Wood Fuels Is Not Climate-Friendly. Natural Resources Defense Council. Jodi Helmer. March 8, 2022. No, Burning Wood Fuels Is Not Climate-Friendly (nrdc.org)

Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice. Rachel Carson Institute. 2019. Clear Cut: Wood Pellet Production, the Destruction of Forests, and the Case for Environmental Justice (sec.gov)

EIA: Densified biomass fuel production at 860,000 tons in April. Erin Voegele. Biomass Magazine. EIA: Densified biomass fuel production at 860,000 tons in April | Biomassmagazine.com

Densified Biomass Fuel (ie. Wood Pellets): Usage Distribution and Environmental/Climate Impacts. Kent C. Stewart. Blue Dragon Energy Blog, February 28, 2017. Blue Dragon Energy Blog: Densified Biomass Fuel (ie. Wood Pellets): Usage Distribution and Environmental/Climate Impacts

Densified Biomass Fuel Report. Connor Murphy, Operations Lead Specialist, EIA, for Pellet Fuels Institute Annual Conference. June 23rd, 2022. Densified Biomass Fuel Report (memberclicks.net)

 

The Value of Wetlands and Wetland Delineation

 

     In recent years the value of wetlands to local ecosystems has become established. Far into the past wetlands and “swampy” areas in some places in the U.S. were drained to remove unwanted effects such as mosquitoes, black flies, and other undesirable wildlife. Another major past benefit of draining swamps was that this resulted in big decreases in cases of malaria, which comes from a parasite spread by mosquitoes. After WWII when anti-malarial drugs and pesticides were developed and became more widely available, case of malaria dropped drastically. Swamps were also drained for agriculture and in a few cases to mine peat from bogs. Arguably, this resulted in some positive effects on nearby human habitation such as less mosquito-borne illness. However, it also degraded wetlands that provide environmental benefits.

 

 

The Value of Wetlands

 

     Wetlands preserve unique ecosystems and habitats. The species that inhabit wetlands perform ecosystem services. Wetlands are among the most biologically diverse ecosystems. The EPA notes that “wetlands are among the most productive ecosystems in the world, comparable to rain forests and coral reefs.” Wetlands can include large varieties of species of microbes, plants, insects, amphibians, reptiles, birds, fish and mammals. Dead plant material decomposes into small fragments of organic matter known as detritus that feeds many aquatic species. Wetlands are part of a geographic area known as a watershed where water drains from uplands to lowlands. The presence of shallow water, abundance of nutrients, and primary productivity lead to wetlands providing thriving food webs. Wetlands are involved in global water, nitrogen, and sulfur cycles and likely in atmospheric maintenance and carbon cycles as well. Wetlands are considered to be among the most threatened ecosystems.

     Not all functions and impacts of wetlands are benign. Wetlands preserve organic matter in low oxygen (hypoxic) or no oxygen (anoxic) conditions. This initiates anaerobic decomposition which results in release of methane into the atmosphere which has a high global warming potential. Methane contributes to global warming. Human-made wetlands such as rice paddies and reservoirs for dammed hydroelectric plants also release methane in significant amounts. Draining wetlands has the benefit of slowing methane release. However, in most cases the benefits of wetlands are seen to outweigh the detriments of wetlands. Even though they release methane they also sequester more CO2 than other environments, so the net greenhouse gas emissions of wetlands are more complicated to determine.

     Wetlands protect against floods by acting as buffer zones that can take in and store significant amounts of water. Coastal wetlands protect against storm surges from tropical storms and hurricanes. Wetlands support fishing economies. They provide critical habitat for migrating birds as rest areas and nesting sites. Wetlands can improve water quality and reduce contaminant concentrations.

 

Wetland Delineation

 

     The U.S. Army Corp. of Engineers and the U.S. Environmental Protection Agency define wetlands according to the Clean Water Act (CWA) as follows:

 

“Wetlands are areas that are inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas.”

 

     Wetland delineation involves detailed study of the soils, surface water, vegetation, and wildlife of a wetland. A key goal is to define the boundaries of the wetland. Another goal is to determine the function and value of the particular wetland and what kinds of impacts any development would have on that wetland. Another goal is to determine the jurisdiction of the wetland, whether it qualifies as part of the “Waters of the United States.” According to Section 404 a wetland has three characteristics: 1) presence of hydrophytes or plants that grow in or near water; 2) presence of hydric soils. Hydric soils are soils that are “saturated, flooded or ponded long enough during the growing season to develop anaerobic conditions in the upper part of the soil profile that favor the growth and regeneration of hydrophytic vegetation (USDA - SCS, 1991).”; and 3) a non-soil substrate such as sand or peat that is soaked or submerged for part of every year.

     Wetland boundaries need to be determined before jurisdiction can be established. Wetland delineations can be required before permitting building and development activities. Another function of wetland delineation is “identifying mitigation opportunities for mitigation banks – accounts of credits for restoring and protecting wetlands – as well as determining the boundaries of compensatory mitigation areas required by Section 404 permits. Compensatory mitigation areas help ensure that any project’s wetland impacts can be mitigated by reducing or removing the impact elsewhere in the watershed. For example, if a project causes significant wetland impacts, these areas help ensure that other projects within the watershed are not negatively impacted in the same way.” This seems to be a kind of impact trading – trading negative impacts in one area by assuring no impacts in another area by protecting that area or by restoring an impacted area. Wetland delineations can also help states and federal agencies to place certain wetlands off limits to any development or to certain kinds of development.

 

Source: Corps of Engineers Wetlands Delineation Manual. by Environmental Laboratory. Wetlands Research Program Technical Report Y-87-1 (on-line edition). U.S. Army Corps of Engineers. January 1987. Wetlands Delineation Manual (army.mil)

Source: Corps of Engineers Wetlands Delineation Manual. by Environmental Laboratory. Wetlands Research Program Technical Report Y-87-1 (on-line edition). U.S. Army Corps of Engineers. January 1987. Wetlands Delineation Manual (army.mil)

 

Types of Wetlands

 

     The U.S. Fish and Wildlife Service classifies wetlands according to the scheme developed by Cowardin as described in the publication Classification of Wetlands and Deepwater Habitats of the United States which divides wetlands into five types: marine, estuarine, lacustrine, palustrine and riverine. The U.S. Army Corps of Engineers classifies wetlands according to the scheme of Brinson in the publication A Hydrogeomorphic Classification for Wetlands which divides wetlands into the following types: marshes, swamps, bogs, and fens. According to the EPA marshes are defined as follows:

 

“Marshes are defined as wetlands frequently or continually inundated with water, characterized by emergent soft-stemmed vegetation adapted to saturated soil conditions. There are many different kinds of marshes, ranging from the prairie potholes to the Everglades, coastal to inland, freshwater to saltwater. All types receive most of their water from surface water, and many marshes are also fed by groundwater. Nutrients are plentiful and the pH is usually neutral leading to an abundance of plant and animal life. We have divided marshes into two primary categories: non-tidal and tidal.”

    

Non-tidal marshes are mostly freshwater marshes, but some may be brackish or salty. They are the most common wetlands type in North America. They often occur along existing streams. Due to their high level of nutrients freshwater marshes are among the most productive ecosystems on the planet with phenomenal biodiversity. They are also among the wetlands most impacted by humans. Tidal marshes occur mostly along the Atlantic Coast and the Gulf Coast. In tidal marshes the lower part of the marsh is typically covered daily by tides. Some are freshwater, some brackish, and some saline. These ecosystems are also impacted and threatened by human development. The Everglades in Florida are an example of a freshwater marsh.

     A swamp is a wetland dominated by woody plants. Swamps are of two types: forested swamps and shrub swamps. These swamps are typically bottomland forests along sluggish rivers with low gradients. They are common in the Southeast. Forested swamps occur throughout the U.S. The Great Dismal Swamp of coastal Virginia is one example that I have visited. One example of a shrub swamp is a mangrove swamp. Mangrove swamps cover vast distances along the Florida coast. Mangrove swamps are also noted for their ecosystem services of protecting against erosion and sequestering carbon. So-called blue carbon credits in carbon trading systems can involve the restoration and expansion of mangrove swamps.

     The EPA describes bogs this way:

 

“Bogs are one of North America's most distinctive kinds of wetlands. They are characterized by spongy peat deposits, acidic waters and a floor covered by a thick carpet of sphagnum moss. Bogs receive all or most of their water from precipitation rather than from runoff, groundwater or streams. As a result, bogs are low in the nutrients needed for plant growth, a condition that is enhanced by acid forming peat mosses.”

 

Thus, we can see that bogs are much different than swamps and marshes. Bogs are often inhabited by specifically adapted plants and animals due to the physically and chemically demanding conditions and low nutrient levels. Northern bogs occur in the Northern U.S., along the Great Lakes, and in Alaska. Most of the wetlands in Alaska are undisturbed by human encroachment. Pocosins are a type of bog that occurs in the U.S. Southeast. Many bogs and pocosins have been drained for agriculture and mined for peat. Pocosins often occur in broad flat uplands away from large streams and like northern bogs most of their moisture comes from precipitation. They may have significant charcoal layers due to past burning.

     Fens are peat-forming wetlands that receive moisture from sources other than precipitation, usually drainage from mineral soils and groundwater. They differ from bogs in being less acidic and having more nutrients. They develop a more diverse community of plants and animals. If they become separated from their water source, they can become bogs. Fens have also been impacted by human development.

  

 

Hydrophytic Plants

 

     Hydrophytic or aquatic plants, or hydrophyes, are plants that are adapted to growing in inundated and low-oxygen environments. These plants have evolved mechanisms for collecting oxygen including hypertrophied lenticels (Speckled Alder), hollow stems (rushes and grasses), and air-filled cells, or aerenchyma (cattail roots).  

     Other ways plants have adapted to oxygen-starved aquatic environments include developing long, hollow stems that reach the surface of the water; developing large, flat, waxy leaves that allow the top of the plant to float; floating on the surface of the water; developing air sacs or large spaces between cells, which provide buoyancy that allows the plant to float; and developing the ability to be completely submerged in water and rooted in the mud.

     Hydrophytes provide food and habitat for many species including algae, macroinvertebrates, amphibians, fish, birds, and more. Hydrophytes can also improve water quality by taking up nutrients, metals, and contaminants. Thus, they perform what is known as ecosystem services.  

     Wetland vegetation can also help with flood control and shoreline erosion. Wetlands are of different types that are inhabited by different hydrophytes. These different kinds of wetlands include salt marshes and sandy beaches, ponds, lakes, marshes, swamps, savannahs, bays, estuaries, bogs, fens, quiet streams, and tidal flats that are commonly flooded with at least a foot of water.

     Plants are given wetlands indicator statuses or categories. These are defined as follows:

 

-         Obligate wetland (OBL) - Almost always occurs in wetlands under natural conditions (estimated probability > 99%).

-         Facultative wetland (FACW) - Usually occurs in wetlands (estimated probability 67% – 99%), but occasionally found in non-wetlands (estimated probability 1% – 33%).

-         Facultative (FAC) - Equally likely to occur in wetlands and non-wetlands (estimated probability 34% – 66%).

-         Facultative upland (FACU) - Usually occurs in non-wetlands (estimated probability 67% – 99%), but occasionally found in wetlands (estimated probability 1% – 33%).

-         Obligate upland (UPL) - Almost always occurs in non-wetlands under natural conditions (estimated probability > 99%).

 

“A positive (+) or negative (−) sign is used for the facultative categories. The (+) sign indicates a frequency towards the wetter end of the category (more frequently found in wetlands) and the (−) sign indicates a frequency towards the drier end of the category (less frequently found in wetlands).”

 

 

Hydric Soils

 

     The National Technical Committee for Hydric Soils defines hydric soil as: “soils that formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part.”    

     A particular soil is inundated when the water table is at or above the soil surface. A water table may be steady throughout the year, or it may change seasonally. Thus, determining the position of the water table varies by area and sometimes by time of year. In a wetland the soil is submerged for at least part of every year. If the soil is submerged with no water movement as occurs in depressions, it is considered to be ponded. A soil is considered to be saturated if the water table is within six inches of the soil surface for sandy textured soils or within 12 inches for loamy or clayey textured soils. These depths differ for each grain size and texture since at those depths the textures will support a capillary rise to the surface. More capillary action occurs with smaller pore size.  If the water is saturated for at least several weeks during the growing season, then the oxygen in the soil will deplete and anaerobic conditions will develop. This will lead to an accumulation of organic matter and the reduction and movement of iron which in turn produces a soil structure that will be identifiable as a hydric soil. Hydric soil indicators are muck, mucky texture, gley colors and sulfidic odor. Gley color refers to a color from the Munsell soil color chart. It is a greenish-blue-gray color due to the anoxic conditions of wetland soils. Other hydric soil indicators include dark surface, organic accretions, oxidized rhizospheres, polychromatic matrix (matrix stripping), stratified layers, iron and manganese concretions, distinct and prominent mottles, and marl. The last three occur in loamy or clayey textured soils only. Basically, color and texture are the two main indicators of hydric soils.

     Many hydric soil indicators are based on biogeochemical processes. These include iron reduction, transformation, and differential accumulation; manganese reduction, translocation, and accumulation; carbon accumulation and differential decomposition; sulfur reduction; precipitation of calcium carbonate by algae; and various combinations of these processes. Hydric soils are classified according to a schema where A refers to all soils, S refers to sandy soils, and F refers to loamy or clayey soils. A number follows each letter and refers to other indicators.

     Hydric soils have been mapped all over the U.S., but these may not be in enough detail for specific properties. The main source of information and classification of hydric soils is the USDA Soil Conservation Services’ Field Indicators of Hydric Soils in the United States.

 

Source: Field Indicators of Hydric Soils in the United States: A Guide for Identifying and Delineating Hydric Soils, Version 8.2, 2018. USDA Soil Conservation Service. pdf.aspx (usda.gov)

 

Hydrology and Determination of the Water Table

 

     Water table determination can vary according to the reason the water table is being determined. The definition of a water table can be somewhat different for a soil scientist than for a hydrologist. For a hydrologist the water table can mean “… the level at which water stands in a well penetrating the aquifer.” The water table, or phreatic surface, is also defined as the surface that “forms the upper surface of the zone of saturation.” Typically, there is a single – zone of aeration – where the soil voids are occupied by both air and water and below that a single – zone of saturation – where the voids are occupied solely by water. The water table can be different for determining the suitability of a septic system than for design and construction of a storm water management system or for the suitability for the construction of an oil & gas well pad.

     A water table may be permanent or seasonal. In cases where standing water is less common one might want to find the seasonal water table. Although some soil scientists may refer to a high seasonal water table as a “perched water table,” a groundwater scientist will point out that a true perched water table is rare in nature, where an aquifer of limited extent is perched above the regional water table.     

     Saturated conditions show different features and characteristics in different soils and rocks including differences in hydraulic conductivity, groundwater flow rates, maybe different hydraulic gradients, and different degrees of anisotropy. Type of soil, in terms of composition and grain size distribution and degree of saturation are the two most important ground conditions that affect construction projects. They are also two of the most important factors in assessing contaminant transport. Heavy rains can also create temporary, or perched water tables that can lead to slips or landslides.

     Ideal determination of saturation conditions would require some degree of understanding saturation of the site throughout the year, type of soil, and the type of project. Detailed info could best be gathered by drilling test wells, but excavated soil profiles are typically the main approach. Soil scientists would correlate colors (a key indicator of saturated conditions) and look for mottling (often in gray vertical streaks) and other redoximorphic features, particularly those that indicate the reducing conditions brought about by newly saturated soil. “Redoximorphic features are formed by the reduction, translocation and oxidation of iron and manganese compounds in the soil after water saturation and desaturation, respectively.” Redoximorphic features are used to determine seasonal water tables and to identify anaerobic soils. The percentage of redoximorphic features in wetland soils are used to determine the frequency and duration of saturation in those soils. Since redoximorphic features are common in saturated soils they are extensively used in making land use decisions, particularly regarding on-site waste disposal and wetlands.

Example of the Redoximorphic Feature known as Mottling

     Reducing reactions take place in chemical order and so the degree of reduced chemicals can hint at how often and how long conditions are saturated. If there is sufficient organic matter present the sequence begins with aerobic decomposition by oxygen-consuming bacteria (aerobes). When saturated conditions and subsequent low oxygen conditions occur for long enough then anaerobic decomposition begins with reducing reactions in decomposition by anaerobes. The chemical sequence of reducing reactions begins with oxygen to nitrogen, to iron, to manganese, to sulfur, to carbon, and then to microbial gas. These constituents and their relative percentages can be clues to past saturation conditions. For instance, a sulfur smelling soil indicates enough saturation and saturation-time to have reduced significant amounts of sulfur, which is closer to generation of microbial gas, typically referred to as “swamp gas,” ie. methane. This indicates prolonged submergence.

     Saturated conditions close to surface, whether seasonal or permanent, can create problems for construction, drainage, landslide potential, and be more easily contaminated by spills. Structures built on or partially on saturated soil can be subject to hydrostatic uplift pressures which is buoyancy derived from saturated pore water pressures. In order for structures such as underground tanks to avoid hydrostatic uplift they must be built heavy enough to withstand those pressures – typically 1.5 times the pore water pressure. Spills are easier to clean up in unsaturated soils where they can be excavated, and the soil treated offsite. When contaminants enter groundwater, they can be more mobile and much more difficult to remediate. Saturated clay soils are the most problematic as they swell when wet and shrink when dry, but saturation can cause issues with other soils as well.

     The main redoximorphic feature that can indicate seasonal water tables is mottling which is more or less synonymous. They can form quickly in newly saturated conditions. Oxidized iron which is most often red and insoluble changing to a reduced gray form that is more soluble indicates saturation. Mottles can indicate soil water level, whether recent or in the past as in relict mottles. Another saturation indicator, as mentioned, is a gleyed (greenish gray) matrix. The Munsell color chart can be helpful in these determinations but is better for determining the A, S, or F soil number for hydric soils.

  

 Example of the Munsell Color Chart

Defining Wetlands According to the Clean Water Act

 

     The main source for defining wetlands used by the EPA and Army Corp. of Engineers for Section 404 of the CWA is the 1987 Corps of Engineers Wetlands Delineation Manual and Regional Supplements. It is organized into three categories: soils, vegetation, and hydrology. The regional supplements divide the U.S. into 10 regions with more specific regional delineation characteristics.

 

 

Jurisdictional Determination

 

     Since wetlands defined as Waters of the United States are protected and regulated under Section 404 of the CWA it is necessary to determine if a particular delineated wetland falls under that jurisdiction. Wetlands delineated by ecologists and environmental consultants must be submitted to the Army Corp. of Engineers for verification. They will then determine jurisdiction. First, there is a verified preliminary determination, which may be satisfactory for some projects and uses. A more detailed final approved delineation may be required for projects with more potential impacts.

     Anyone who buys land with the presence of hydric soils and other wetlands indicators should be aware of possible restrictions on building and development on those parts of the land. A wetland delineation will determine if there are any jurisdictional issues.

     The U.S. Fish and Wildlife Service has developed a National Wetlands Inventory. This may be used to determine preliminary suitability for a project, but more detailed analysis will likely be required to obtain permits. Environmental due diligence software can help to determine where a property is in relation wetlands inventories and previously mapped or delineated wetlands through GIS layers.

     Since wetlands can change due to changing saturation conditions, a wetland delineation is typically good for 5 years before a new delineation is required. This can perhaps be cumbersome for developers and landowners. This 5-year permit term is built into Section 404. Desired activities such as draining a wet area for agricultural use often require wetland delineation as well.

     It should also be determined whether a wetland is a human-made wetland such as results from damming or diverting water from one place to another. These may result from irrigation, impoundment, wetlands resulting from filling of formerly deepwater habitats, dredged material disposal areas, and wetlands resulting from stream channel realignment. Some of these human-made wetlands may be subject to Section 404. Of the three indicators of wetlands: hydrophytic plants, hydric soils, and hydrology, the presence of hydric soils is usually absent in human-made wetlands.

 

 

Wetland Restoration and Protection

 

     According to the EPA:

 

“Wetland restoration is the manipulation of a former or degraded wetland's physical, chemical, or biological characteristics to return its natural functions.”  

 

These include re-establishment which is rebuilding of a former wetland, and rehabilitation which refers to repairing a degraded wetland. Wetland protection refers to removing threats to wetlands and preventing the decline of a wetland. Wetland restoration can increase all the benefits of wetlands by adding to the total. Restoration and protection can be either voluntary or regulatory. Both can and do play a role in supporting the Clean Water Act and the Safe Drinking Water Act. Non-profits, local governments, and industry can collaborate in wetland protection and restoration. Partnerships with many federal agencies can aid in voluntary wetlands protection and restoration. Regarding restoration EPA notes that:

 

“… constructed treatment wetlands use natural processes involving wetland vegetation, soils, and their associated microbial life to improve water quality. They are often less expensive to build than traditional stormwater treatment options, have low operating and maintenance expenses, and can handle fluctuating water levels.”

 

References:

 

Wetland Delineation: What It Is And Why It Matters. By admincivil. February 14, 2022. Wetland Delineation: What It Is and Why It Matters - Civil Stuff

Wetland Delineation. Transect. A Guide to Wetland Delineation (2023) | Transect

How Wetlands are Defined and Identified under CWA Section 404. U.S. EPA. How Wetlands are Defined and Identified under CWA Section 404 | US EPA

Wetland Delineation - Hydric Soils. Florida Dept, of Environmental Protection. Wetland Delineation - Hydric Soils | Florida Department of Environmental Protection

Hydrophytic Vegetation: 13 Things (2023) You Ought to Know. by Erika. Hydrophytic Vegetation: 13 Things (2023) You Ought To Know (gokcecapital.com)

What is a Jurisdictional Delineation under CWA Section 404? U.S. EPA. What is a Jurisdictional Delineation under CWA Section 404? | US EPA

Water Table Training – Where’s the Water Table – sponsored by Pennsylvania Independent Oil & Gas Association (PIOGA), February 2016.

How do Wetlands Function and Why are they Valuable? U.S. EPA. How do Wetlands Function and Why are they Valuable? | US EPA

What is Hydric Soil? 10 Things (2023) You Should Know. by Erika. What is Hydric Soil? 10 Things (2023) You Should Know (gokcecapital.com)

Field Indicators of Hydric Soils in the United States: A Guide for Identifying and Delineating Hydric Soils, Version 8.2, 2018. USDA Soil Conservation Service. pdf.aspx (usda.gov)

Ambiguity of the Definition and Delineation of the Groundwater Table. Kent C. Stewart. Blue Dragon Energy Blog. May 28, 2016. Blue Dragon Energy Blog: Ambiguity of the Definition and Delineation of the Groundwater Table

Groundwater Hydrology (Second Edition) – by David Keith Todd (Wiley and Sons, 1959, 1980)

Interpretation of Micromorphological Features of Soils and Regoliths (Second Edition). 2018. Pages 425-445. Redoximorphic Features - ScienceDirect

Corps of Engineers Wetlands Delineation Manual. by Environmental Laboratory. Wetlands Research Program Technical Report Y-87-1 (on-line edition). U.S. Army Corps of Engineers. January 1987. Wetlands Delineation Manual (army.mil)

Classification and Types of Wetlands. U.S. EPA. Classification and Types of Wetlands | US EPA

National List of Plant Species That Occur in Wetlands -- North Central (Region 3). Reed P. 1988. National Wetland Inventory, U.S. Department of the Interior, Fish and Wildlife Service, St. Petersburg, FL. 90 pp.

The Concept of a Hydrophyte for Wetland Identification. Tiner R. (1991) Bioscience 41 (4) 236-246.

Wetland indicator status. Wikipedia. Wetland indicator status - Wikipedia

Overview of Clean Water Act Section 404. U.S. EPA. Overview of Clean Water Act Section 404 | US EPA

Basic Information about Wetland Restoration and Protection. U.S. EPA. Basic Information about Wetland Restoration and Protection | US EPA

Best Things First: The 12 Most Efficient Solutions for the World’s Poorest and Our Global SDG Promises. By Bjorn Lomborg. Copenhagen Consensus. 2023.

Comstock Resources’ and Aethon’s Screaming Monster Gas Wells in the Deep Western Haynesville/Bossier Play in the East Texas Basin

 

     As reported by Hart Energy, Comstock Resources is tapping some very high-volume wells in the deeper further west part of the Haynesville/Bossier Shale play. Unfortunately, I can’t get behind the paywall, but the Haynesville well recently completed and still cleaning up after six weeks is producing at an initial rate of 35MMCf/day and is expected to increase as it continues to clean up. Previous Bossier wells drilled by the company suggests EURs in the range of 3.5BCF per 1000ft of lateral. These are among the highest reserve gas wells in North America. The wells are very deep at over 17,000 ft vertical depth. The area being drilled so far is in the East Texas Basin in Leon and Robertson counties, far west of the presumed core of the Haynesville play centered near the Texas/Louisiana border three or four counties away. Comstock has also found success in the Woodbine play, stratigraphically below the Eagle Ford equivalent, further southeast in Polk County at just over 14,000ft. The Woodbine Organic Shale is being drilled in nearby Madison County at just over 8000ft.

     Another company, Aethon, has drilled a Bossier well in eastern Robertson County that IP’d at 36.9 MMCF/day from a 6561 ft lateral, yielding and IP rate of 5.6 MMCF/1000ft of lateral. These gas wells are very high pressure and literally scream, the pressure making an audible high-pitched sound. The Aethon well was completed in late September 2022 and kept confidential.

     In Robertson County Comstock’s Cazey Black A #1H’s IP’d at 42 MMcfe/day from 7,900 ft of lateral in the Lower Bossier and its Circle M Allocation #1H, IP’d at 37 MMcf/day, also from 7,900 ft of lateral in the Lower Bossier. More wells are being drilled and completed.

 

 

Source: Hart Energy

 

     The challenges to this deep Bossier and Haynesville play are the sheer vertical depths up to 19,000 ft and the very high well costs. Geology is also thought to have some challenges. Drill bits get used up and there is a need to run stronger casing with higher pressure ratings. One big snafu could be quite costly. Thus, even though the gas is there, the play is risky. One might draw some comparisons to the deep Utica/Point Pleasant Play in Pennsylvania. However, the high reserves could lead to overcoming these challenges as more wells are drilled.

Source: Hart Energy

     The extent of this deep play has yet to be fully delineated. The trapping, whether structural, stratigraphic, or a combo of the two, is not yet known. The size of the fairway is not yet known. With bottomhole temperatures as high as 425 deg F (Haynesville core area is about 300 deg F) and bottomhole pressures as high as 17,000 psi the challenges can be considerable. With well costs at $10 to 12 million, the play can be economic if high gas rates are consistently achieved, and operations problems are minimized.

     Stratigraphically the Late Jurassic Bossier is above the Haynesville Shale. I remember reading about early deep Bossier exploration in the area in the mid-2000’s where EURs up to 13BCF were made from vertical wells producing from a single zone. Geologist Peggy Williams reports that “the Bossier in the Robertson/Leon area has [a] porosity of 6% to 12% and permeability of 0.01 to 0.1 millidarcies.” The Bossier is a rock with interbedded shale and sandstones. The Bossier play is considered to be a basin-center gas accumulation. Some of these sandstones may be turbiditic which means they are deposited by sliding down slopes off of a continental shelf in the manner of avalanches. Turbidites move by density flow, which means that changes in fluid density due to a high density of suspended particles turn the fluid into a slurry that flows. The lack of continuity and variable nature of turbidites could limit the play and increase geologic risk but that remains to be seen.

 

“Turbidites are formed by underwater avalanches at the edge of continental shelves or deep lakes with steep slopes from the shelf along the shoreline. The material that settles at the bottom of the shelf (i.e. the turbidite deposit) tends to consist of sand and similar coarse material, grading upwards into siltstone which is formed by the fine grained mud that settles more slowly than the sand particles.” Source: Wikipedia

 

Bossier Sequence Stratigraphy Model. Source: AAPG. Figure 9 (searchanddiscovery.com)

     Pipeline capacity in the areas could be an issue in the future as these high volumes are delivered, However, with reasonable proximity to LNG export markets, that is likely resolvable.   

 

References:

North Houston Haynesville Wildcat Comes in at 35 MMcf/d. Nissa Darbonne. Hart Energy. August 2, 2023. North Houston Haynesville Wildcat Comes in at 35 MMcf/d | Hart Energy

Aethon’s Screamer Well Joins Comstock’s Deep-Bossier Wildcatting. Nissa Darbonne. Hart Energy. April 10, 2023. Aethon’s Screamer Well Joins Comstock’s Deep-Bossier Wildcatting | Hart Energy

Bossier Shale & Tight Gas Play Overview. Hart Energy. July 1, 2006. Bossier Shale & Tight Gas Play Overview | Hart Energy

Turbidite. Wikipedia. Turbidite - Wikipedia

Implementing the IRA: Aspiration vs. Reality: Summary, Analysis, and Review of a Breakthrough Institute Article

 

     Ted Nordhaus and Alex Trembath of the Breakthrough Institute published a fascinating article recently about the opportunities, challenges, and potential pitfalls of implementing the Inflation Reduction Act (IRA) enacted one year ago. They bring forth sound arguments based on past policies and a keen understanding of technological limitations and practical realities.

     The key point of the article is that the Biden administration could be making some significant and unnecessary mistakes in implementing the IRA by making mandates to speed up the decarbonization process at a pace faster than technology, supply chains, consumers, regulators, and property owners can keep up with. As the title suggests technological optimism is different than technocratic optimism. While we may be optimistic about promising new technologies, we had best not get ahead of ourselves and try to mandate emissions reductions before those technologies mature and become economical, which takes time and likely cost overruns on first-of-a-kind projects. The mandates are based on modeling. Modeling is based on assumptions. Some of those assumptions may well be wrong, especially ones about the time it takes to thoroughly vet, improve, mature, and deploy the technologies involved. I think it is likely that the culture of hype around renewable energy technologies and capabilities is a factor in these overly optimistic model assumptions. The authors see the proposed mandates as aspirational and akin to central planning.

     The authors note that clean energy subsidization has largely worked and has been widely popular. They also note that Democrats didn’t pay a price for the bipartisan infrastructure bill or the Inflation Reduction Act, even though there are calls to amend and repeal certain parts of it. They suggest that a carbon tax or stronger mandates would be risky enough to make the Dems pay a price. The following statement sums up the risk: “Progressive technocratic hubris, driven by overreliance on energy system models, an uncritical fetishization of industrial policy, and an unwillingness to fully account for the implications of political polarization and divided government, risks undermining much of what the IRA could accomplish.” Challenges to mandates from the Supreme Court and Congress could derail progress already made and future progress towards steady decarbonization. They suggest that we should embrace the bottom-up technological approach already immanent in the IRA without adding top-down approaches like mandates and executive action. The authors instead recommend focusing on cost reductions and technological performance improvements.

     The authors note that modeling has been predicated on expanding long-distance power transmission capacity at a rate more than double the historical rate. Another assumption is that wind and solar will continue to drop in price as it has in the past, except in the past few years when it has actually increased a bit. Other ways the models may prove overly optimistic include the effects of supply chains, siting, and value deflation. Solar is most susceptible to value deflation as has occurred in California where too much solar generation during the day has decreased the value of that generation.

     They also note challenges with EV rollouts: adoption has been slow despite tax credits, it has mostly benefited wealthy buyers buying luxury cars like Teslas, charging infrastructure is lagging, and battery costs have been rising rather than dropping as before (countering Elon Musk's predictions). EV’s made up 6% of new car sales in 2022. The expectation that they will make up 60% in 2030 seems quite ambitious. The authors argue that mandates based on this post-IRA modeling is simply not necessary. The best course of action is to just let the technologies mature with government assisted market-based approaches. Automakers are being coerced to quickly ramp up manufacture of more EVs and with new mandates for big increases on fuel economy that leaves them little choice. But consumers have thus far not been ‘gung-ho’ about EVs, and it doesn’t look like that is going to happen real soon. Automakers are already losing money on EV manufacture and becoming dependent on government subsidies.

     Development of the so-called hydrogen economy is another technology where aspirations are likely ahead of reality. Converting natural gas power plants to switch to hydrogen co-firing is certainly a possibility but not in a short time frame. Mandating it is not needed. Many issues need to be worked out before it can even happen on a significant scale. Even the EPA expects that only 1.5% of gas-fired plants will be hydrogen co-fired by 2040. The authors note as a caution that in the past the biomass and ethanol industries devolved into rent-seeking ventures so this is something to look out for with other new technologies.

     If a Republican administration comes back to power the whole decarbonization pace will very likely be scaled back, perhaps more than is prudent. Executive action and budget reconciliation work both ways, depending on who is in power. The most enduring type of decarbonization policies will be bipartisan, sensible, and reasonable. The challenges of decarbonization are significant and mandating beyond those challenges is not a prudent or pragmatic approach. The authors summarize these challenges as supply chain scale up, geopolitics, big changes in consumer behavior, siting issues, permit reform, technological improvements and cost reductions.

     The authors state five principles that they think should inform climate policy. The first one is:

1.      Regulatory reform will accelerate U.S. decarbonization to a far greater degree than new emissions regulations. The idea is that reform of existing regulations on permitting, siting, and transmission will do as much or more than mandated emissions reductions that will seems draconian to many. Biden administration proposed power plant and aggressive vehicle mpg regs threaten to become widely unpopular and potentially expensive for consumers and businesses. 

2. Technology innovation should lead emissions regulation. This is quite sensible since mandating beyond technological capabilities is simply not sensible. While the carrots of tax credits and subsidization have been popular and successful the sticks of mandates and limits have not and that is not likely to change. Furthermore: 

3. Subsidies are for innovation, not emissions reduction. The authors give the examples of early shale gas subsidization that helped to support its later development and maturation and early nuclear subsidization that got the industry going. They note that simple mandates and subsidies for more solar and wind do not address enabling technologies and policies like permit and siting reform, energy storage deployment, grid integration, and transmission buildout and upgrades. They risk overbuilding and potentially stranding wind and solar generation. They note that subsidies drive innovation and early-stage commercialization. 

4. Industrial policy and emissions policy are not the same thing. Here they point out as an example that pragmatic decarbonization policies will likely be more costly in the near-term which will necessarily slow implementation: “Foregoing Chinese supply chains and critical minerals will inevitably increase the cost of polysilicon solar panels, batteries, and electric vehicles in the short term. Requirements to use union labor and direct benefits to marginalized communities will increase the time and transaction cost associated with deploying critical low carbon infrastructure.” Aggressive mandates and timelines are simply not feasible and will result in problems that are not necessary and may jeopardize the very things they hope to accelerate. 

5. Quiet climate policy will trump climate ambition. This statement is basically a recap or a result of the previous ones. How much money will be spent over the next decade implementing the IRA is dependent on all the things mentioned above. How much is spent is “entirely dependent on whether the IRA tax credits survive subsequent administrations and Congresses, and whether the necessary technological developments, supply chains, infrastructure, and market demand actually materialize over the next decade such that firms are able to fully utilize the IRA tax credits.” Basically, they are saying that the quiet or less aggressive policies that are at a pace with technology maturation and have bipartisan support are simply more durable and likely to endure.

     

     This is a great article and should be widely read as it promotes a pragmatic approach to decarbonization that has the best chance of success and steady rollout. Kudos to the authors.

Addendum: Another recent Breakthrough Institute article addresses the downsides of the EPA’s proposed power plant rule, arguing sensibly for a less aggressive approach and one that favors reforms of existing regulations over new emissions reduction mandates. Below is a graph from that article showing much greater emissions reductions from expanding transmission lines at a pace that is actually feasible over emissions reduction that would come from the EPA’s rule alone.

 

Source: Deregulating Clean Energy Is More Important Than Regulating Carbon Emissions: An Analysis of the EPA’s Power Plant Regulation Proposal. Juzel Lloyd, Alex Trembath, and Seaver Wang. Breakthrough Institute. July 25, 2023. Deregulating Clean Energy Is More… | The Breakthrough Institute

References:

On the Difference Between Techno and Technocratic Optimism: The Inflation Reduction Act at One. Ted Nordhaus and Alex Trembath. The Breakthrough Institute. July 31, 2023.  On the Difference Between Techno and… | The Breakthrough Institute

Deregulating Clean Energy Is More Important Than Regulating Carbon Emissions: An Analysis of the EPA’s Power Plant Regulation Proposal. Juzel Lloyd, Alex Trembath, and Seaver Wang. Breakthrough Institute. July 25, 2023. Deregulating Clean Energy Is More… | The Breakthrough Institute

The Potential for More Powerful Solar Panels Made with Ferroelectric and Paraelectric Materials

     New research (August 2021) from Martin Luther University Halle-Wittenberg (MLU) in Germany is suggesting that vast improvements in solar panel efficiency are possible. The suggested improvement was up to 1000 times more efficiency. The new technique involves crystalline layers of barium titanate (BaTiO_3, aka BTO), strontium titanate (SrTiO₃) and calcium titanate (CaTiO₃), alternately placed on top of one another in a lattice structure known as a superlattice. These titanates are known as ferroelectric materials.

I should point out that nothing much has been announced about this particular research for the past few years, at least that is easy to find, so I have my doubts about its ultimate potential for making solar more efficient, especially in the near-term. There has been some 2022 research announcements about other types of ferroelectric materials being integrated with perovskite solar panels but that is all I could find with a quick search. Thus, there are obviously more barriers to the commercialization of these types of panels than the paper referenced suggests. 

“Current solar panels are silicon-based. Barium titanate, for instance, is a mixed oxide of barium and titanium. Ferroelectric materials have spatially separated positive and negative charges, which leads to an asymmetric structure that generates electricity from light. Unlike silicon, ferroelectric crystals do not require a pn junction to create the photovoltaic effect, making it easier to produce solar panels.”

The new structure alternates ferroelectric materials with paraelectric materials. The photovoltaic effect of barium titanate has been known for a while. The big discovery is that “the photovoltaic effect is greatly enhanced if the ferroelectric layer alternates not only with one but with two different paraelectric layers.” These ferroelectric-paraelectric superlattice structures (SLs) revealed that interaction between the alternating lattice layers appears to lead to a much higher permittivity, or easier electron flow due to the excitation by the light photons. Importantly, the research also showed that this increased flow was robust, remaining constant over a six-month time period. MLU physicist Dr Akash Bhatnagar noted: “The layer structure shows a higher yield in all temperature ranges than pure ferroelectrics. The crystals are also significantly more durable and do not require special packaging.”

     Silicon-based solar panels have efficiency limitations. Panels made from these ferroelectric materials have other advantages over silicon panels including lower cost, less space requirements, easier manufacturing, and of course, the potential increased efficiency. However, it is not thoroughly understood how this enhanced photoelectric effect emerges. Researchers are working on prototypes and venture capitalists are hoping for functional deployments over the next few years but that may well be a premature conclusion. As mentioned, the researchers noted: “The enhancement in photocurrent persists across a wide range of temperatures and over long periods of time, indicating the robustness and inherent character of the underlying origin.” This suggests that the observed effects are real, stable, and likely workable into functional devices.

    What the researchers are proposing as the reason for the enhanced effect is “the unison of these two rather discrete phenomena—higher permittivity and lowering of the bandgap owing to a modified electronic structure—culminates into an overall enhanced PV effect in SLs.”

    

Source: Strongly enhanced and tunable photovoltaic effect in ferroelectric-paraelectric superlattices. YESEUL YUN, LUTZ MÜHLENBEIN, DAVID S. KNOCHE, ANDRIY LOTNYK, AND AKASH BHATNAGAR. SCIENCE ADVANCES. 2 Jun 2021. Vol 7, Issue 23. Strongly enhanced and tunable photovoltaic effect in ferroelectric-paraelectric superlattices | Science Advances

 References:

Next-generation solar panels are 1000 times more powerful. JJ Shavit. The Brighter Side of News. April 15, 2023. Next-generation solar panels are 1000 times more powerful (thebrighterside.news)              

Strongly enhanced and tunable photovoltaic effect in ferroelectric-paraelectric superlattices. YESEUL YUN, LUTZ MÜHLENBEIN, DAVID S. KNOCHE, ANDRIY LOTNYK, AND AKASH BHATNAGAR. SCIENCE ADVANCES. 2 Jun 2021. Vol 7, Issue 23. Strongly enhanced and tunable photovoltaic effect in ferroelectric-paraelectric superlattices | Science Advances