From: Mike Leonard <mike@northquabbinforestry.com>
Sent: Saturday, July 20, 2019 7:07 PM
To: RPS, DOER (ENE)
Subject: RPS Class I & II Rulemaking - Comments
The MA Global Warming Solutions Act mandates steady reductions of
greenhouse gas emissions. Forests are the major landscape feature in MA
covering 60% of our land area and are a significant sink for CO2 emissions.
Thus our forests can play a major role in achieving the mandated goals as long
as foresters have the ability to practice superior silviculture.
Massachusetts Climate
Policy for our forests:
http://resilientma.org/sectors/forestry
- “Climate Change
Clearinghouse for the Commonwealth”
Under Management Practices:
• Increase forest diversity (species, structure,
age classes and habitats) and vigor via professional forest management
• Encourage active forest management for
renewable wood products and wildlife benefits and promote local wood products
to keep working forest landscapes economically viable
• Permanently conserve the most intact,
productive and resilient forest ecosystems
• Expand invasive species management with
programs to reach private and public landowners
So what is the state’s
plan to implement the “Climate Policy for our Forests”? It is impossible to carry out the state’s
policy without substantial markets for low grade timber.
A great help would be if
DOER includes forest derived wood from forest improvement/forest regeneration
cuttings as long as the Forest Cutting Plan called for Long Term Forest Management
in their proposed waiver from the efficiency standards for biomass power
plants. Why would you include non-forest-derived wood - from utility and
highway right-of-way clearings, tree service work, municipal tree trimmings and
tree removals in parks and on streets but not from forestry work?! It makes no
sense.
https://www.nrs.fs.fed.us/pubs/2575
Carbon Consequences of Thinning Practices
Thinning a forest stand to concentrate growth
on selected stems is a long-standing forest management practice. Can the choice
of thinning methods be a tool used to increase carbon sequestration? Our
results indicate that the choice of thinning method has the potential to alter
the stand’s ability to sequester carbon. Plots
thinned from below had the highest carbon sequestration rate.
What
is “thinning from below”? The
improvement cuttings I prescribe and mark are designed to upgrade the overall
quality of forest stands. These thinnings are primarily from below which means
that most of the trees removed are from the lower crown classes. This type of
thinning accelerates the natural mortality of a forest stand as it develops
over a long period of time by removing those undesirable trees that are of
lower quality and/or are losing the race for survival due to natural
competition. So the Forest Cutting Plans I develop have the highest carbon
sequestration rates. But in order to practice this superior silviculture and
improve sequestration rates, we need more low grade biomass markets.
In contrast, the thin from above treatment (destructive highgrade logging -http://northquabbinforestry.com/liquidation-cutting/
) displayed negative carbon sequestration rates, storing significantly
less carbon than thinning from below. The smaller suppressed trees left after a
highgrade were generally unable to respond to release, slowing stand growth.
A thin from below would sequester 295 tons of carbon, while highgrading would
release 22 tons of carbon.
https://tinyurl.com/y4t4v7jr
- Destructive Logging versus Great Forestry – Photo Album by North
Quabbin Forestry
Conclusion:
Plots that were thinned from below had much
greater volume production and much higher carbon sequestration rates than plots
that were highgraded.
Forest Regeneration Cuttings
Improve Carbon Sequestration Rates in Degraded Forest Stands
Many
of our forests gave been degraded because of destructive highgrade logging as
well as insect, disease, and other agents. These degraded forest stands are
nowhere near as productive as they could be in terms of timber production and
carbon sequestration rates. So that’s when foresters often recommend a
regeneration cutting to begin the process of regenerating a new forest stand.
http://www.ctforestry.uconn.edu/documents/3347NEForestRegenerationHandbookRevisionFinal.pdf-
Northeast Forest Regeneration Handbook
https://extension.tennessee.edu/publications/Documents/SP680.pdf
- Treatments for Improving Degraded Hardwood Stands
Young forest
stands will have much higher carbon sequestration rates than degraded forest
stands. However proper forest regeneration cuttings cannot be carried out
unless we have low grade biomass markets so that regeneration cuttings will be
economically feasible.
Final Thoughts:
Managed
forests sequester more CO2 annually than unmanaged forests. This is
accomplished by: utilizing materials from thinnings for energy to offset fossil
fuel consumption; long term storage of carbon in durable wood products from
harvested wood; increasing growth rates of the higher value trees; and
successfully regenerating the harvested forest to meet or exceed previous
sequestration rates. Therefore, increasing the acreage under actual forest
management will enhance CO2 storage for our forests. Managed forests are also
less apt to be developed rather than unmanaged forests so CO2 continues to be
sequestered in those managed forests rather than being lost when the forest is
developed. If you want to see great forestry, then you must support more
biomass markets because without low grade markets, great forestry is
impossible.
This is why DOER must
include forest derived wood from forest improvement/forest regeneration
cuttings as long as the Forest Cutting Plan called for Long Term Forest
Management in your proposed waiver from the efficiency standards for biomass
power plants.
Mike Leonard, Consulting
Forester
North Quabbin Forestry –
www.northquabbinforestry.com
33 Leighton Road
Petersham, MA 01366
978-724-8822