Mark Jenner
BioCycle April 2012, Vol. 53, No. 4, p. 61
Meaningful evaluation of biomass energy potential begins with the best available science and technology. Only after the science is understood does it make sense to look at potential policy impacts. The order of these steps is critical because things change. And our human-derived policies change much less predictably than does our increasing knowledge of science. When agricultural, forest and urban residual biomass policies are compared in the same economy-wide lens, carbon-based policies developed separately for each source collide.
Waste disposal technologies like landfills and anaerobic lagoons, for instance, were encouraged and supported through policies. Now several decades later, we are looking for policy alternatives. The technologies are still doing what they were designed to do. It is just that we have collectively decided that we want more from the biomass feedstocks than these earlier technologies provide.
I am a newcomer to forest residual biomass. As I learn more, I am fascinated by the complexities of managing biomass remaining after timber harvest as well as the need to manage the residuals that accumulate in a growing forest without harvest. Prevailing forest management policies over the past few decades have determined that public forests be left alone. In growing forests, this creates a buildup of dangerous wildfire fuel wood. The challenge is how to remove the amount of this residual biomass that is unhealthy for the forest without removing what is necessary for forest renewal and without disturbing the forest. Typically forest practitioners have the answers to achieve the necessary balance, but overarching public policies have restricted their options.
Increased interest in biomass energy provides a new demand for these surplus forest residuals. They are costly to remove whether for wildfire prevention, or for conversion to bioenergy. But when both work together, the removal costs are distributed across both activities. Easing the restrictions for removal of this understory forest biomass would complement both wildfire management and commercial development of local, renewable biomass.
Open Burning Policy Conflicts
In California, CAL FIRE, the state’s Department of Forestry and Fire Protection, has invested years in researching management of forest understory fuel wood accumulation. Even so, wildfires continue to increase. The state’s limited resources are not invested at levels that can implement strategies sufficient to prevent increasing wildfires. The decision to not remove increasing levels of understory fuel wood seems to be a human choice in the face of knowledge that this increases wildfire potential. Therefore man’s anthropogenic influence plays a role in emissions from wildfires. CAL FIRE has the technical solutions. The decision to under-implement wildfire prevention strategies is a policy determination rather than a lack of available technology.
In another context related to open burning, California determined in 1991 that the risks to air quality and human health from burning rice straw after harvest were too high and the open burning of rice straw was restricted. Curiously, the policy treatment technology choice also increased methane emissions from rotting the rice straw in the field. In this case increased methane emissions were determined to be a significant air quality improvement over open burning. Restricting open burning of one kind of biomass (rice straw), while not fully implementing fuel wood reduction management to restrict air emissions from wildfires on thousands of acres each year, seems a bit incongruent.
In the context of nitrous oxide emissions (NOx) the policy choices become even less congruent. For legally defensible and health-related reasons, California district air resource boards in nonattainment areas have set the NOx emissions at 9 ppm from stationary generators, which include biogas generators. This is a very low emission standard and has restricted adoption of anaerobic digesters in California. But it is difficult to argue for any NOx emissions in an air quality nonattainment area. However, in a 2002 emission inventory, the California Air Resources Board (CARB) found that 8 percent of the annual NOx emissions were generated from natural (wildfire) emissions. In this case it seems that wildfires are excluded as ‘natural’ rather than influenced by man.
Changing The Unchangeable
This month’s good news is that access to forestland fuel wood biomass is beginning to open up. Well at least on federal forestlands. Michael Theroux, a California biomass consultant, did an excellent job outlining the significant changes in federal policies that are opening up woody biomass on federal lands. Theroux traces existing forest fuel wood biomass access in federal forestlands back to the passage of the National Forest Management Act of 1976 and implementation of the 1982 Forest Planning Rule, which prescribed how to manage these lands and resources to provide sustained yields, maximum public benefit and minimal environmental impact. This has carried through successive laws including the Energy Independence Security Act of 2007 (EISA), which sets rules for renewable fuels standards and excluded biomass from federal lands for participation in these standards.
Theroux identifies four actions that are opening up this undervalued and underutilized federal forest biomass to wildfire reduction and biomass energy feedstock development. These have been developed across disciplines over time and have support. The first positive step is a proposed, highly collaborative revision of the Forest Planning Rule that is consistent with the National Environmental Policy Act (NEPA) and is being tested in several states. NEPA is the rulebook for setting environmental policy for the federal government. Second, adaptive forest management for restoration is being tested in over 20 Collaborative Forest Landscape Restoration projects covering more than 10 million acres. Third, President Obama and the USDA have initiated a jobs-based initiative to speed development of these management techniques. And fourth, the NEPA rule is being evaluated and modified to expedite forest resource based jobs through the White House Council on Environmental Quality. With implementation of these changes at the federal level, there is hope they may migrate down to state policies as well.
I enjoy watching significant policies that we know at one point to be ‘written in stone’ get changed eventually. Changing the unchangeable gives me great hope. So we must focus first on the science, and secondly on the policy influence. More details can be found in the March 2012, New Forest Planning Rule and Access to Woody Biomass document by Michael Theroux on his Teru Talks News website, www.terutalk.com.
Mark Jenner, PhD; World Agricultural Economic and Environmental Services (WAEES), California Biomass Collaborative, and Biomass Rules, LLC (www.biomassrules.com).