menu-bgimg

What we can offer you

We provide detailed transactional data, cost benchmarks and in-depth analytics for participants in the wood raw materials supply chain.
  • Pricing Data
  • Benchmarks
  • Product Forecasting
  • Advisory Services
  • Analytics
Learn More

SilvaStat360 Platform

  • Price Benchmarks
  • Madison’s Lumber Reporter
  • The Beck Group’s Sawmill TQ
  • Timber Supply Analysis 
  • Global Economic Data

Explore Forest2Market's Interactive Business Intelligence Platform

Learn More

Industries

From biomass suppliers in the Baltics to pulp producers in Brazil and TIMOs in the United States, Forest2Market provides products and services for suppliers, producers and other stakeholders in the global forest products industry.

Learn More
x
 
Blog

How the Renewable Fuel Standards Limit Potential Wood Supply

August 19, 2014
Author: LeAndra Spicer

Although the RFS was intended to increase the use of renewable fuels, the legislation restricts qualified feedstock at the same time it mandates biofuels. To be considered RFS compliant, producers must use qualified materials from qualified sources according to four criteria:

  1. Ownership: Wood biomass that originates on land owned by the federal government is ineligible.
  2. Origin: Planted trees, tree residue, slash, and pre-commercial thinnings that comes from tree plantations is eligible. On non-plantation land, only slash and pre-commercial thinnings qualify.
  3. Conversion: Tree plantations must have been cleared prior to and actively managed no later than December 19, 2007.
  4. Non-ecologically sensitive: Biomass sourced from ecologically sensitive or old growth forests is excluded.

In this blog post, we take a look at what the EPA considers planted trees, tree residue, slash, and pre-commercial thinnings.

Planted Trees

The EPA defines planted trees as “trees harvested from a tree plantation.” A tree plantation consists primarily of hand-planted or machine-planted trees.  Trees originating from natural seeding by the mature trees growing on plantation land also qualify as renewable biomass. Therefore, “planted trees” is a misnomer in the sense naturally-regenerated trees on plantation land is allowable under the RFS program.

Tree Residue

The wood residue generated when planted trees that are harvested from actively managed tree plantations and processed for use in another application such as lumber, paper, or furniture is what the EPA considers tree residue. Qualified wood raw materials maintain their status as renewable fuel feedstock when processed for use in the manufacture of wood products.

Producers may generate RINs only for the biogenic portion of the tree residues. Tree residues mixed with chemicals or other materials during production are not eligible. Likewise, residues lose their qualified status if mixed with tree residues that did not originate on an eligible tree plantation.

Slash

The EPA considers slash as the material typically left on the forest floor following a logging operation or after a disturbance such as a storm or fire. Furthermore, materials traditionally left on the forest floor to replace nutrients in and improve the quality of soil qualify as slash. This includes tree tops, branches, bark, and unmerchantable trees.

Pre-Commercial Thinnings

Trees removed to promote the growth and improve the quality of the most desirable trees in a stand are considered pre-commercial thinnings. The EPA does not limit trees harvested as part of a pre-commercial thinning in terms of diameter, citing tree diameter varies according to the type and location of forest.

Trees that remain in a stand after a first pre-commercial thinning are restricted as qualified biomass. The EPA takes the position that trees that remain after the first thinning cannot generally be considered pre-commercial thinnings at a later date.

However, in the US South, it is common practice to thin stands twice between the time they are planted and the final harvest. Under the terms of the RFS, only those trees removed in the first thinning would qualify as renewable biomass.

This caveat could have implications in regards to the timing of thinnings, although it is most likely that timberland owners will continue to manage their timber assets to maximize sawtimber production as the economics are more favorable than they are for biomass. Any adjustments made in timing to accommodate biofuels markets will be made within the boundaries of this higher objective. 

This information and more is available in our latest whitepaper. Click the banner below to download.

Definitions from the Environmental Protection Agency 40 CFR Part 80 Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program; Final Rule. March 26, 2010.

Back to Blog

You May Also be Interested In

January 08, 2020
The Value of Carbon Emission Avoidance with Biopower Generation
Per a recent report published by the National Petroleum Council (NPC)—an advisory committee that represents the...
Continue Reading
October 08, 2019
Wood Bioenergy, Forest Management Key to Combatting Climate Change
Seth Ginther, Executive Director of the U.S. Industrial Pellet Association (USIPA), recently wrote an excellent piece
Continue Reading
August 22, 2019
WSJ’s Incomplete Reporting Perpetuates Misconceptions About Bioenergy
A recent article published in the Wall Street Journal notes that the increased consumption of wood pellets in the...
Continue Reading