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:

  1. Climate impacts from CO2 emissions
  2. SO2 emissions – a precursor of acidic precipitation (acid rain)
  3. Health Impacts from Particulates

 

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.

 

  1. At a Mohawk Trail Woodlands Partnership meeting in October, UMass researcher Paul Catanzaro presented results of a study he did with Anthony Amato from UVM on the Impact of Forest Management on Carbon.  By reviewing Forest Cutting permits in Massachusetts, they found that most harvesting here is partial cutting, removing about 4Mbf/acre or about 13 metric tons of carbon/acre, cutting roughly 1/3 of the trees at a time.  A typical harvest reduces the net carbon storage/acre by about 17 percent, 10 metric tons/acre from the harvested timber, and another 3 tons from disturbing the duff.  Below surface carbon appears not to change much if BMPs are followed to protect soils from erosion.  By their calculations, the carbon removed in partial harvesting is replaced by new growth primarily of existing trees in about 9 years (at a rate of 1.5 metric/tons per acre per year).  A shelterwood harvest that cuts 2/3s of the net volume would reduce total stored carbon by about 30 percent and would take about 15 years to replace the stored carbon.
  2. This contrasts sharply with the 60 to 100 year carbon replacement scenario cited in the broadcast.  That scenario seemed to be based on the idea that if you cut down a sizable tree, it will take 60 to 100 years for an equal sized tree to grow to replace it.  While that might be true for an isolated tree in the open, it doesn’t reflect actual forest growth.  With the partial cutting common here, the trees uncut use the increased sunlight to grow faster and replace carbon much faster.  Added growth absorbs more carbon than new trees would initially.
  3. Another carbon study was done recently by Mass Wildlife on clearcuts they did to create early successional habitats for wildlife.  The study reportedly that net carbon on the clearcuts was within 2 percent of the total before harvesting after just 6 years regrowth.
  4. Thus my biomass improvement cuttings which typically remove 1/3 of the basal area re-sequester the carbon that was harvested or lost in just nine years. Further, by replacing imported fossil fuel with locally produced wood pellets, emissions are further reduced while it has tremendous economic benefits as well as forestry and wildlife benefits!

 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

  1. Figure 4 – PM Emissions from Residential Heating Systems - Wood pellets burn more cleanly compared to burning conventional cordwood used in fireplaces and wood stoves. Pellets create a minimal amount of smoke during operation. A modern pellet boiler is 140 times cleaner than that old wood stove.  There’s not much difference in particulate emissions between oil, propane, and a wood pellet boiler.
  2. The speculation that biomass energy increases asthma rates because of the tiny amount of additional particulate emissions is false. Modern biomass plants – both electric and thermal – are very efficient, clean burning, and well within strict EPA standards. In addition, a peer reviewed study by the prestigious John Hopkins Hospital concluded that it is indoor air pollution that is the main cause of higher asthma rates (and probably poor diet too).

 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.

http://biomassmagazine.com/articles/16027/report-maine-can-benefit-by-encouraging-switch-to-pellet-heat

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