Biomass Suitability & Sustainability
DOER is committed to ensuring both the suitability and sustainability of the woody biomass fuels involved in APS. To achieve this goal, the department has established a robust verification protocol involving the Massachusetts Biomass Registry, an online fuel registration portal designed to establish both origination and chain-of-custody for the involved biomass fuels. To ensure compliance with the registry DOER systematically confirms these data via both desk and field auditing procedures. These measures will also ensure that all woody biomass to meet the definition Clean Wood as listed within 310 CMR19.006 definitions. In essence, this regulation establishes that Clean Wood is silvically derived (from a tree) and is free of combustible contamination (e.g. paints, stains, adhesives, or preservatives).
To ensure compliance with the statutory requirement that APS generation units demonstrate a 50% reduction in lifecycle greenhouse gas emissions over a 30 year period (vs. locally available conventional fuels) it is necessary that woody biomass be categorized as either Residues or Thinnings. A further distinction involves the assessment of the fuel as either Forest-derived or Non-forest-derived. This second characterization is important as APS-eligible forest-derived materials may only be sourced from woodlands that are enrolled in a third-party certification program (SFI, FSC, PEFC or ATFS) or have been attested to by a licensed or state-certified forester. Such an attestation will support that applicable Best Management Practices and the operational guidelines for biomass retention (within the publication titled Biomass Harvesting and Retention Guidelines for the Northeast, Forest Guild, 2010) have been met by the harvesting activities.
All woody biomass involved in the APS must be ascribed to one of the following categories:
Forest-Derived Residues (Residues):
- Tops, crooks and other portions of trees produced as a byproduct, and trees collaterally damaged, during the normal course of harvesting material, such as timber, pulpwood or cordwood in the implementation of a silvicultural prescription as administered by a licensed or certified forester as prescribed in the Department’s Guideline on Biomass, Biogas, and Biofuels for Eligible Renewable Thermal Generation Units.
- Trees and portions of trees harvested for the purpose of the restoration and management of habitat for rare & endangered species as listed by the Massachusetts Division of Fisheries and Wildlife. Qualifying harvest areas must be approved by the Massachusetts Division of Fisheries and Wildlife Natural Heritage Program.
- Other woody vegetation that interferes with regeneration or the natural growth of the forest, limited to locally invasive native species and nonnative invasive woody vegetation.
- Unacceptable growing stock which is defined as trees considered structurally weak or have low vigor and do not have the potential to eventually yield an 8 foot saw log or survive for at least the next 10 years.
- Trees removed during thinning operations, the purpose of which is to reduce stand density and enhance diameter growth and volume of acceptable growing stock within the residual stand.
Forest Salvage (Residues):
- Damaged, dying, or dead trees removed due to injurious agents, such as wind or ice storms or the spread of invasive epidemic forest pathogens, insects and diseases or other epidemic biological risks to the forest, but not removed due to competition. Such eligible trees may be removed without limitation for biomass fuel, only if the injurious agent is a threat to forest health or risk to private or public resources, and if the United States Department of Agriculture Animal and Plant Health Inspection Service, the United States Department of Agriculture Forest Service, or appropriate federal or state governmental agency has issued a declaration, rule, or order declaring a major threat to forest health or risk to private or public resources.
- Trees removed to reduce fire hazard within fire-adapted forest ecosystems, as certified by a letter to the Department from the state agency responsible for forestry in consultation with the appropriate environmental state agencies.
- Forest products industry: Residues derived from wood products manufacturing consisting of Clean Wood.
- Land use change – agricultural: Trees cut or otherwise removed in the process of converting forest land to agricultural usage, either for new or restored farm land.
- Wood waste: Pruned branches, stumps, and whole trees removed during the normal course of maintenance of public or private roads, highways, driveways, utility lines, rights of way, and parks.
- Agricultural wood waste: Pruned branches, stumps, and whole trees resulting from maintenance activities directly related to the production of an agricultural product.