From: Mike Leonard <mike@northquabbinforestry.com>
Sent: Thursday, June 6, 2019 3:08 PM
To: RPS, DOER (ENE)
Subject: RPS Class I & II Rulemaking - North Quabbin Forestry
Comments
Attachments: Figure 1 Oil versus Wood Pellet Emissions.png; Figure 2
Heat Emissions from various sources.gif; Figure 3 - SO2 emissions - Wood
Pellets vs Oil.jpg; Figure 4 - PM Emissions for Residential Heating Systems.png
I’m Mike Leonard, Consulting Forester, North Quabbin Forestry. I
have a BS degree in Forestry from UMass and over 30 years’ experience
practicing forestry. My son and I help landowners protect and manage thousands
of acres across the state.
Recommendations:
1. Thanks to support from the
Working Forest Initiative, we now have over 500,000 acres of forest land with a
Forest Management Plan. But there is less than ¼ of all private forest land
enrolled so allowable biomass should be eligible from all private forest land as long as the Forest Cutting Plan calls
for Long Term Forest Management.
2. Lower
the efficiency standard to 40% for a full REC credit. The emerging cannabis
industry will need at least 200-300 MW of power. This power can come from new
combined heat and power biomass plants with attached greenhouses.
3. Chipwood
from landclearing should be counted as eligible biomass. A dual system for
chipwood does not make any sense. This will not increase the amount of land
cleared for development.
4. Reciprocity
with other New England States. We should have similar regulations as states
like Maine and New Hampshire since we are all part of the RGGI.
5. We
need more geographically diverse chip markets to reduce trucking costs and to
provide great forestry for landowners everywhere. In Massachusetts, our main
outlet is the Pinetree Power Biomass Plant in Fitchburg which has been great
for forestry in central MA. But western MA has nothing so landowners cannot get
the forestry services they need to manage their forest land effectively.
6. Establish
a $30/ton floor for chipwood. Right now it is only about $20/ton which is just
above break even. That’s not good enough. Increasing chip prices will spur
badly needed investment in our industry. The goal would be to create an awesome
forestry sector like they have in Sweden and Finland where great forestry is
practiced everywhere thanks to all their biomass markets.
7. Support
research and development into more biomass products such as organic water
resistant torrefied wood pellets, biochar, and wood bricks.
We’re proud of the forestry
work we do. We’re creating jobs, improving forest land, producing many
different forest products we all
use, and providing a source of clean locally produced real renewable energy. But forests in our state are in
serious trouble due to a variety of insect, disease, and other agents. Tree
mortality has greatly increased and millions of tons of timber are dying every
year. The only way we can help restore the health and productivity of our
forests is to support more markets for low grade timber and that means biomass!
North Quabbin Forestry –
2018 Forestry Work
Two
Main Services: Forest Management Plans and Forest Cutting Plans
The most important work we do is marking forest stands correctly
for an improvement cutting, commercial thinning, or a regeneration cutting.
Proper thinning can double the growth rate of the higher quality trees
increasing timber values as well as doubling CO2 sequestration rates by
creating healthier more productive forests. A lot of CO2 is also stored in long
lived forest products and by using carbon neutral forest biomass for heat and
power instead of fossil fuels. Diseased trees are also a significant
source of methane emissions according to a study by researchers at the Yale
School of Forestry. Estimated
methane emission rate from upland forests is equivalent to burning 16 gallons
of gas/acre/year. So by utilizing those diseased trees for biomass, we are also
greatly reducing those methane emissions.
We
did 920 acres of Mgt. Plans and 573 acres of Cutting Plans which is an average
year.
Timber
Harvest Volumes & Utilization:
On
the 573 acres:
1.5
MMBF – that is enough wood to build over 1,000 houses!
1,800
cords – that is enough firewood to heat or partially heat 354 homes reducing
the amount of heating oil used by 273,000 gallons!
5,800
tons of chipwood – that is enough to produce .5 MW of power at a biomass power
plant which is enough electricity to power 375 homes for an entire year!
All
forest products were harvested from sustainably managed woodlots which followed
a Forest Management Plan. The residual forest stands are now of higher quality
and will grow at a much higher rate. In 10-15 years, timber volumes on these
woodlots will be at least as high as before they were cut!
We
are not only improving woodlots but we are also providing landowners with a
source of income; encouraging them to keep their land in forest; improving
wildlife habitat; and maintaining many real green jobs right up the wood supply
chain. The multiplier effect is huge! But imagine if we could improve 50,000
acres/year! That should be the state’s minimum goal.
Our forests are not as productive as they could be because of
overcrowding, insect and disease agents, storm damage, non-native invasive
plants, and the legacy of destructive highgrade logging. The hemlock wooly
adelgid and emerald ash borer have put over 3 billion board feet of timber just
in Massachusetts at risk while the resurgent gypsy moth caterpillar has
defoliated over one million acres in southern New England causing widespread
tree mortality.
Innovative
Natural Resource Solutions did a biomass study for the 20 town area in NW MA
and calculated that 400,000 tons/year could easily be harvested for a wood
pellet plant in those towns alone. They also said that 60% of the standing
timber is low grade junk!
The
most recent US Forest Service Forest Inventory for MA said that forests in our
state are growing almost 5 times as fast as they are being cut. However tree
mortality is triple that of removals – over 2.5 million tons of timber is dying
in our forests every year releasing all those millions of tons of CO2.
So
there is a huge abundance of dead, dying, and junk timber. We need markets for
at least two million tons/year.
Increase
the incentives to 10 years, two years not enough. Work to improve chip prices –
if loggers could get $30/ton that would spur huge investments in new timber
harvesting machinery which are needed.
Forest
industry supports anything that will increase low grade biomass markets.
Forests
should be seen as infrastructure and managed to the highest degree possible.
Massachusetts
Forests are in Decline:
There are 3 million acres of forest land in Massachusetts which
cover 61% of the land area. Our forests are essential to protect wildlife
habitat, provide clean air and water, provide forest products that we all use,
and to help mitigate climate change.
The total amount of protected forest land in Massachusetts is over
1 million acres. But it is not enough to protect forest land, we must also
manage it. In the last decade, major threats to our forests have grown. The
most important are the hemlock wooly adelgid where 2.3 billion board feet of
hemlock timber is at risk and the emerald ash borer where almost 1 billion
board feet of timber is at risk. This is almost 15% of all the sawtimber in the
state. Other insect and disease agents, the spread of non-native invasive
plants which crowd out native vegetation, and the legacy of destructive
highgrade logging where the best timber is cut leaving a junk forest behind,
have also caused our forests to decline. More than 75% of our forests have been
degraded or are at risk for significant decline.
The Massachusetts Global Warming Solutions Act requires a 25%
reduction of greenhouse gas emissions by 2020 and an 80% reduction by 2050.
Deforestation as well as the urban heat island effect are responsible for up to
50% of the global warming in the last century. Thus protecting and managing our
forests are a major part of meeting the emission goals. However, our forests
ability to act as a carbon sink is declining. Forests store carbon as they grow
but as tree mortality increases, net growth slows and declines. Our forests are
releasing at least 2.5 million tons of CO2 every year. As insect pests (like the
HWA & EAB) and tree diseases spread, it is going to get much worse.
Our forests are in decline and dying. The only way we can help
restore the health and productivity of our forests is by practicing more
sustainable forestry. But in order to practice sustainable forestry and manage
our forests so they are more resilient to climate change, we need more low
grade timber markets so that low value and dying timber can be economically
removed. By supporting biomass markets, we will improve our forests and create
thousands of new job opportunities especially in our rural areas where they are
most needed.
Pollution Concerns for
Biomass Power:
I. Climate Impacts:
Biomass Power Plant’s
CO2 Emissions 115% lower than a Natural Gas Power Plant - https://www.bioenergy-news.com/display_news/12412/biomass_carbon_emissions_115_lower_than_natural_gas/?fbclid=IwAR0g2msLt73ic0Z8qdTkFzGod1DRSnmN8DcHiu0KhHmN51r5UTZ_h-bTxME
Biomass
Markets Support the Global Warming Solutions Act: https://www.facebook.com/MikeLeonardConsultingForester/posts/1101421256604713?__tn__=K-R
By
generating power with wood pellets instead of coal, electric utilities can
reduce lifetime carbon emissions by about 80 percent. - http://www.envivabiomass.com/lower-ghg-emissions-2/
Studies show a 90 - 97% reduction or more in CO2
reductions when switching to wood pellets from oil or natural gas: http://www.truenorthenergyservices.com/v/
See also Figures 1 and 2.
II. SO2 Emissions – Figure 3 –
Wood pellets produce no SO2 (sulfur dioxide) emissions. Oil produces a lot – 94
g/MJ. SO2 helps to produce acid rain which damages our forest and wetland
ecosystems. Thus wood pellets are much better for the environment than imported
heating oil.
III. Health Impacts from Particulates
Economics of Wood Pellets:
http://biomassmagazine.com/articles/16027/report-maine-can-benefit-by-encouraging-switch-to-pellet-heat - A study of 106 commercial, industrial, and
institutional buildings in Maine that switched to wood heat - $20.6 million in
total economic benefit.
If 15 percent of the homes and businesses in
Maine that currently use heating oil change to pellet heat over the next
decade, Strauss said it would keep an additional $133 million circulating in
the state’s economy and result in approximately 8,000 new jobs being created.
Additional economic benefits in the form of increase household disposable
income would also result due to the lower cost of wood pellets relative to
heating oil. Strauss estimates that a typical home in Maine would save $500 per
year in heating costs by switching from heating oil to pellets. Economic
benefits would also result from the construction and operation of new pellet
production plants, along with the establishment of pellet distribution
operations.
Overall, Strauss estimates that if 15 percent of
current heating oil users would switch to wood pellets, the state would see an
increase in income tax revenues of about $22.9 million per year. According to
the paper, the net annual estimated increase in state and local tax income
would be about $27.7 million. Not accounting for inflation, the paper
estimates an additional $280 million would be accrued by the Maine treasury
over a 10-year period.
http://economics.mit.edu/files/7337 - This study by MIT shows it costs up to
$600 to displace one ton of carbon using solar while it only cost $50 to
displace one ton of carbon when using wood pellets instead of fuel oil. Thus
wood pellets are more than 10X as cost effective as solar! Why are we subsidizing
made in China solar anyway?!
https://vermontbiz.com/news/2018/december/06/wood-vermont’s-locally-grown-renewable-fuel
"Low grade wood
becomes firewood, woodchips or, historically in our region, paper.
However," she said, "the paper industry has been collapsing in recent
years leaving a gap in the market for this low grade wood. It is absolutely
essential to have healthy markets for both high and low grade wood - without
the pair it is impossible to carry out a sustainable forest management plan.”
Thus an expanding market
for wood pellets is simply replacing some of the demand that has been lost with
the closing of numerous paper mills.
When you decrease local
wood production, we import more wood and export forest destruction:
https://harvardforest.fas.harvard.edu/sites/harvardforest.fas.harvard.edu/files/publications/pdfs/Berlik_JBiogeography_2002.pdf - In this paper by Harvard Forest entitled “The
Illusion of Preservation”, the authors argue correctly that when we lock up or
stop the management of our own forest lands, then we import more wood often
from areas that don’t have our high environmental standards. So forest
degradation and carbon emissions are simply exported. Hence, the
“illusion”.
Mike Leonard, Consulting
Forester
North Quabbin Forestry –
www.northquabbinforestry.com
33 Leighton Road
Petersham, MA 01366
978-724-8822