Biomass regulatory changes no big deal

WE AT THE MASSACHUSETTS Forest Alliance read with interest Mary Booth’s recent CommonWealth op-ed, “Get Ready for Another Biomass Battle.” She addresses proposed regulatory changes to the Renewable Portfolio Standard (RPS), which offers incentives for renewable electricity generation. We noticed, however, that the article is very carefully worded to avoid revealing the major thrust of the proposed changes to the RPS as it relates to biomass.

That’s likely because opposition to the changes might wane if people understood what the Department of Energy Resources (DOER) was actually doing. Essentially, the changes to the biomass regulations are designed to make it easier to use non-forest-derived wood for power generation.

What is non-forest-derived wood? This is wood that didn’t come out of the forests, but instead comes from trees removed for safety reasons – and those removals aren’t controversial. We don’t complain when our neighbors have a tree service company take down a tree that is threatening to fall on their house. We don’t mind when cities or towns remove a tree that is at risk to fall on a playground, soccer field, or walking path in a municipal park, or take away dying street trees along sidewalks. We’re fine when utilities keep their rights-of-way clear of trees that could knock power out to our neighborhoods, or when trees are cut back along highways to keep motorists safe.

The problem is that that these efforts generate a lot of wood, most of which cannot be left behind and must be chipped and removed. In fact, there’s so much of this wood that disposal is a big problem – existing markets for these chips (such as converting it to mulch) can’t come close to absorbing the volume being created. Tree service companies are desperate to get rid of it, and sometimes truck it as far as Ohio, trying to find someone who might actually pay them for it, instead of charging them for disposal.

Cities and towns must pay to dispose of the wood they generate from street trees and parks – in some cases, tens of thousands of dollars a year. The chips are often dumped to decompose, where their carbon is released back to the atmosphere with no benefit.

DOER is attempting to solve this problem by letting this wood be used to displace fossil fuels in power generation. This chipped wood will then release its carbon in a productive way, rather than quickly decompose and emit its carbon anyway. This has the potential to save taxpayers money by reducing the need to pay for municipal wood disposal and also reduce the use of fossil fuels.

There are changes to the regulations which touch on forest-derived wood. These include streamlining the burdensome process of qualifying forest-derived wood (so time-consuming that foresters simply refused to do it), simplifying definitions of residues and thinnings, and so forth. But it’s very doubtful that these changes will result in much, if any, additional use of forest-derived wood for power generation.

That’s due to a minimum efficiency requirement of 50 percent for biomass power in the original regulations – put there to prevent any large biomass power plant from qualifying for renewable energy credits. This standard was impossible to meet, and didn’t apply to other renewable power generation systems, most of which couldn’t meet the standard themselves.

In the newly revised regulations, that efficiency standard has been waived for non-forest-derived wood (and forest salvage – removing stands of trees killed by weather events or invasive insects or diseases to speed up forest regeneration, which forest landowners typically need a grant to afford to do). It’s been left in place for forest-derived residues and thinnings. As long as that efficiency standard remains, little to no forest-derived wood will be used to qualify for renewable energy credits in larger biomass power plants – only in the few small combined heat and power biomass facilities in the state that are efficient enough to qualify. Only one new biomass power plant – in Springfield – has a chance of opening, and that plant is required in its permits to only use non-forest-derived wood.

While non-forest-derived wood isn’t a major focus of our organization, we support using that wood productively rather than letting it go to waste. We think it’s important for people evaluating these proposed regulatory changes to have the full picture of what the changes are designed to accomplish.

We believe there are good reasons to waive the efficiency requirement for forest-derived wood as well – it would create an important market for low-grade wood, helping make forest management more economically feasible, especially for landowners struggling to afford timber stand improvements. There is good science showing that forest management that creates age and species diversity results in a forest that is more resilient to the many challenges facing our forests today – from climate change to invasive insects and diseases to weather events.

As for climate change, the regulations require biomass plants to demonstrate a 50 percent lifecycle greenhouse gas savings compared to natural gas power plants, so a climate benefit is assured. Massachusetts has some of the densest concentrations of stored forest carbon in New England, and not only is the amount of carbon sequestered rising each year, but the rate at which we are sequestering is also increasing – all while we engage in active, sustainable forest management that generates the forest products we all use and rely on every day.

We would suggest DOER broaden the categories eligible for the efficiency waiver – such as material from wildlife habitat creation cuts or forest fire prevention efforts that we all support. Doing so will help our forest landowners, foresters, and timber harvesters in the rural economy as well as improve wildlife habitat and protect Massachusetts from fire risk.

Chris Egan is the executive director of the Massachusetts Forest Alliance.