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