Director, Partnership for Policy Integrity Mark Harmon, PhD - - PDF document

Input to CEQ on bioenergy and forest carbon accounting Mary S. Booth, PhD Director, Partnership for Policy Integrity Mark Harmon, PhD Professor and Richardson Chair in Forest Science Oregon State University March 19, 2014

Federal Greenhouse Gas Accounting and Reporting Guidance Revision 1: June 4, 2012 Guidance recognizes that cutting and burning forests emits CO2: “Within a parcel of land, carbon stocks may decrease (such as when carbon is released into the atmosphere through combustion and decay) or increase (such as when carbon is stored during tree growth or through soil absorption). Biological sequestration is the net increase of carbon stored within a parcel of land over time, while the net decrease is considered an emission. In other words, a standing forest that exists today is not, in and of itself, considered sequestration, but any additional carbon that is stored within that forest as it grows over time would be considered sequestration.“ “Additionality” is even more important when it comes to bioenergy:

• Bioenergy carbon benefits assume offsetting.
• To be legitimately counted as having no net impact on atmospheric carbon,

emissions from woody biomass must be rapidly recovered by sequestration that is additional to background levels

• Rules of additionality for offsets should therefore also apply to thinning/bioenergy

when carbon benefit claims are made (offsets should be “real, measureable, verifiable, and additional”).

A minor point: Section 3.1, re biogenic C: “Part or all of the carbon in these fuels is derived from material that was fixed by biological sources on a relatively short timescale. Depending

• n the full emissions impact of biomass production and use, these emissions may or may not

represent a net change in atmospheric carbon dioxide concentrations. This contrasts with carbon from fossil fuels, which was removed from the atmosphere millions of years ago.” Carbon is carbon! Unless fuel supplies were deliberately planted (ie, closed-loop biomass), how recently the carbon was sequestered is irrelevant – what matter is how quickly it (that is, an equivalent amount) is re-sequestered.

Why we’re here Concerns: USFS request that agency be able to set its own rules

• n what constitutes GHG emissions from thinning/bioenergy
• projects. USFS appears to want all forest management

activities to be considered carbon neutral. Our perspective - GHG accounting must have Consistency Rigor Site-level accountability

White Mountain National Forest, New Hampshire

A need for site-level accountability

~25 acres

Gifford Pinchot National Forest, Washington

After more than 18 years, carbon stocks recovering 1994: Global average CO2 = 358.82 ppm* 2012: Global average CO2 = 393.82 ppm 46.264868° , -121.941855°

* ftp://aftp.cmdl.noaa.gov/products/trends/co2/co2_annmean_mlo.txt

Gifford Pinchot National Forest, Washington

Sometimes carbon stocks never recover 1994 2012 46.264791° , -122.002895°

USFS wants discretion to decide what level of project would trigger GHG accountability But the numbers mount up quickly, and multiple small projects sum to same impacts as large projects. There is a need for accountability. Rule of thumb: one ton of “green” wood @45% moisture content  ~1 ton of CO2 Example: 20 MW biomass project at Nippon Paper, Port Angeles, WA (NEPA filing)

• Not enough “waste” wood for fuel  whole tree harvesting

~367,000 tons of CO2 per year

• NEPA filing treated it as zero emissions

Example: 2012 California “Bioenergy Action Plan” Goal of 2,000 to 5,000 MW of new bioenergy.

– Midpoint (3,500 MW) would require about 2.4 million acres of thinning per year at typical thinning rates of 15 – 20 tons per acre.

• Facility lifetime – 30 to 40 years?

– Would emit about 46 million tons of CO2/yr

• A 75% increase over the ~61 million tons of CO2 from CA

power sector in 2010.

Links fuels reduction thinning to bioenergy

Carbon benefit from thinning? Assumptions don’t hold up

• Winrock International thinning study 1(initiated by CA

Energy Commission):

– Regrowth takes decades – Probability of any area burning is low – Thinning for fuels reduction and generating biopower increases carbon emissions over the fossil fuel/no-thinning scenario

• Oregon State Study (Joshua Clark et al2):

– Reduction in carbon stocks from thinning lasts decades. – Taking long-lived wood products and displaced fossil fuel emissions into account doesn’t help

1 Goslee, K., et al. 2010. Draft Final report on WESTCARB Fuels Management Pilot

Activities in Shasta County, California. California Energy Commission, PIER.

2 Clark, J., et al. 2011. Impacts of thinning on carbon stores in the PNW: a plot level

• analysis. College of Forestry, Oregon State University, May 25, 2011.

Carbon accounting for thinning/bioenergy is straightforward:

Project-level data already being collected - USFS tracks how much timber they’re removing. Simple conversion to CO2 equivalents. Should occur by project. For purposes of bioenergy carbon accounting at site level, FIA data not great on characterizing carbon stocks… But ok for generating regrowth estimates Possible to estimate net CO2 emissions from forest thinning/bioenergy projects (acknowledging offsets through time) using FIA-derived regrowth estimates for forest carbon

Input from Mark Harmon, Oregon State University (member of EPA’s Science Advisory Panel on biogenic carbon accounting)

• 1. Bioenergy is not a priori carbon neutral:

The EPA assembled a cross-section leading scientists to determine if biogenic carbon was always carbon neutral. The panel concluded that there was no scientific justification for this view. None.

• 2. Carbon costs of projects must be estimated, FIA inadequate:

The USFS needs to make some estimate of the carbon impacts of large- scale projects. They cannot rely on FIA to provide a post-implementation

• assessment. First, it is after the fact so anticipated problems will not be
• quantified. At best impacts would be learned 5-10 years after

implementation delaying any mitigating actions. Second, The FIA inventory is not adequate in terms of the density of plots, temporal resolution (5-10 year lags), or in terms of the carbon pools it assesses (strong on live trees, weak on dead trees, soils, forest floors). Thus FIA as currently run would not provide timely, spatially useful, or adequate effects data (because it is missing several key pools).

• 3. FIA data is not consistent regionally:

The FIA data on National Forests lands, especially in the west, has been

• problematic. If FIA is to be used at any level (district, forest, region, and

nationally) this problem has to be fixed.

• 4. USFS credibility at stake:

By not providing carbon assessments, the USFS risks undermining its credibility and its capability. It will be hard to maintain USFS credibility if no credible attempt was made to assess carbon impacts and there will be no investment in building a credible staff that can undertake these

• assessments. Currently the USFS does not have any local, forest-wide or

regional capability in terms of carbon assessments. The staff have not been trained, they have few credible tools, and they do not understand the key concepts. This is not a way forward in terms of building credibility and capability.