On April 27, 2012, the Department of Energy Resources for the state of Massachusetts released proposed final regulations for the eligibility of biomass energy for credit under the state’s renewable portfolio standard (RPS). While the comment period is over and the agency is currently formulating a final rule, the rule may actually be the worst thing that could happen to future health of southern New England forests.
Under the proposed rule, biopower producers would only be eligible for credits under the Massachusetts renewable portfolio standard if they meet the following criteria:
The new rule, once finalized, will set off a flutter of paperwork, as the state will set up a Biomass Certificate Registry to issue and track the biomass certificates through the supply chain. The effect of biomass removals (at the 30% rate) will also be monitored to ensure forest health. ( A summary of the rule and a full list of paperwork requirements can be found here.)
The proposed regulation, the intent of which is “to reduce greenhouse gas emissions and to protect the broad range of human and ecological services of the forests,” may just have the opposite effect. According to a new paper by Eric Kingsley of Innovative Natural Resource Solutions, the 19 existing New England biomass power units provide landowners, foresters and loggers in the region with an important market for forest residue and low-grade wood,” and it is these markets for low-grade wood that incent landowners to continue to own and manage forests. (Read Kingsley’s full report at Importance of Biomass Energy Markets to Forestry: New England’s Two Decades of Biomass Energy Experience.)
How could low value forest products like forest residue or low-grade wood incent landowners to keep forests as forests?
Key Point #1
Biomass harvest is almost exclusively the product of a full forest harvest operation. Using 2010 data for timber harvests in the state of New Hampshire, Kingsley found that the volumes of three classes of timber products—sawlogs, pulpwood and biomass fuel—were relatively equal. The stumpage value of the products was not, however: “Sawlogs, which account for 26% of the volume, are responsible for 94 % of all landowner profits. Pulpwood (and firewood), 38% of statewide harvests, are 4% of the stumpage value to landowners. Biomass chips, 36% of the volume harvested statewide, reflect only 2% of the value to landowners.” Based on these statistics alone, Kingsley points out, the value of low-grade biomass “serves as the single greatest disincentive to clearing forests for biomass fuel.”
Key Point #2
Instead, Kingsley argues, a market for low-grade wood “encourages thinning and other forestry practices that support long-term value generation through the growth of high quality timber” as well as a “number of other long-term forestry benefits, . . . including the development of certain wildlife habitat types, improved forest productivity, and the potential for improved long-term forest economics that helps shield forestland from development pressure. Absent a low-grade market, forest landowners often resort to high-grading,” or the practice of removing only the best, most marketable trees in a stand, leaving only low-quality trees.
According to Climate Change, Carbon, and the Forests of the Northeast by the Forest Guild, high-grading affects the ability of a forest to provide a range of environmental benefits: “These harvests destroy much of the future value for wood production, reduce growth rates, damage forest aesthetics, and increase vulnerability to disturbances. These ecologically-degrading poor harvest practices reduce the ability of the forest to accumulate and store carbon for many years.”
Under the guise of protecting the state’s forests, Massachusetts' biomass power regulations will prevent landowners from extracting value from their forests, removing one of the few incentives they have to keep forests as forests. In addition, the private forests that do remain are more likely to be low quality, reducing their ability to sequester carbon.
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