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Railroad Ties: An Essential Biomass Power Fuel

Every year, millions of railroad ties in the U.S. are replaced. The
wood that keeps trains on track is subject to a significant amount of
wear and tear from constant train traffic and weather exposure. To keep
the train system safe and reliable, these ties must be replaced every so
often with new ones.

So what happens to the used railroad ties?
Sometimes they are sold for repurposing, providing a source of wood for
furniture building, landscaping and other small craft industries. The
volume of replaced railroad ties, however, requires a larger-scale
solution. Many biomass power facilities have discovered an ideal fuel
source in railroad ties, as their benefits are compelling. Railroad tie
fuel (RTF) allows biomass boilers to operate more efficiently by
complementing higher-moisture fuels like forestry residues. In turn,
this enhances healthy forests, promotes recycling for urban wood, allows
states to meet renewable energy goals, and reduces methane emissions
that would otherwise occur if the ties were left to decompose or be

As a result of a 2006 case, Natural Resources Defense Council vs.
the U.S. EPA, EPA was forced to develop regulations to define what
constitutes “fuel” and what is considered “waste.” Earlier this year,
the agency issued a draft rule clearly designed to encourage the
continued use of RTF. The agency noted the fuel value of railroad ties
as a “nonhazardous biomass alternative to fossil fuel.”Nevertheless, the
draft rule creates a convoluted test—called the “legitimacy
criteria”—that has the net effect of disqualifying potentially 80
percent of all RTF used by the biomass industry.

EPA’s proposal limits the use of RTF to boilers, where so-called
contaminant levels are similar to fuel oil. Only boilers that currently,
or at one time, have installed a fuel oil delivery system can use
railroad ties. This disregards the key facts that the emissions are the
same whether a boiler uses natural gas or fuel oil, and the agency has,
for years, encouraged the energy sector to replace fuel oil with
cleaner-burning natural gas. The net effect of the rule is to restrict
railroad ties to only boilers currently or formerly equipped with fuel
oil guns.

For boilers that do not fit into this category—and there are
many—the industry will be forced to spend millions of dollars to install
oil systems that will never be used and has a sole purpose of meeting
regulatory criteria. Regardless of whether the boiler uses natural gas
or fuel oil, the environmental performance is identical. So for
identical boilers using railroad ties, the one cofiring with natural gas
will be considered using a “waste” while the other cofiring with fuel
oil will be considered a “fuel.”

In fact, if EPA’s draft rule is adopted in its current form, the
environment is ultimately the loser. If railroad ties cannot be used for
energy, their fate is a landfill. According to industry estimates,
railroad tie fuel would fill an entire football field, 70 stories high,
every single year. That material would decompose, creating 1.65 million
tons of greenhouse gases annually.

Biomass Power Association, along with several of our members who
rely on railroad ties to keep their facilities running, submitted
comments to the EPA on its proposed rule. Our members alone use
approximately 815,000 tons of railroad ties per year, distributed among
13 facilities in seven states. In many cases, this material accounts for
25 percent or more of the facility’s fuel consumption. Under the
current drafting of the EPA’s rule, the fuel relied on to generate a
significant portion of their power would be disallowed.

We are confident that we can find a workable solution and are
working with the EPA and our members to ensure the continued use of RTF
by biomass facilities.


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