Please accept our comments on the CARB Draft Scoping Plan as it
relates to forest biomass management. Allotrope
Partners has been engaged in the forest biomass sector in
California for over 10 years, working to build the infrastructure
and markets needed to assure a long term sustainable solution that
helps address the impacts of climate change and reduce the long
term risk of catastrophic forest fires. We have operated a
small diameter post-and-pole mill and a firewood packaging
operation in addition to managing the intake of waste biomass
generated from post-fire clean up and utility-led line management
activities. We have been consistently engaged in policy
discussions around this topic and participated in, among other
activities, the Working Group on the potential for Biofuels from
forest waste convened by the Joint Institute for Wood Products
Innovation.
CARB's modeling of forest biomass assumes only a maximum of 70%
of gross residues from fire prevention can be collected and, due to
its indifference assumption, even smaller amounts (two tons per
acre on average) are actually removed from the forest, with the
rest left in the woods. Such an assumption runs counter to
many models/studies, such as the Lawrence Livermore Lab
"Getting to Neutral" report, that suggest that a much larger amount
of material needs to be removed (in the range of 15 tons per acre)
in support of ecological forest mangagement that prevents forest
fires and the negative impact of such emissions would have on
climate change.
The State and Federal goals around forest management target one
million acres of forest treatment per year. This concerted
effort will require a substantial scale up of forest management
activity, again with an expectation of biomass removed per acre
being much higher than the CARB scoping plan models.
This enormous amount of biomass (Getting to Neutral report
suggests 35-45M tons per year including Agricultural and Urban
waste) presents a large challenge as well as an opportunity to be a
meaningful element of the State's efforts to address climate
change. There are numerous efforts underway to develop
biofuel projects that will use this material. At Allotrope,
we are pursuing the development a series of cellulosic ethanol
plants in partnership with technology partners and engineering
firms that will offer technology and price guarantees
respectively. Combined with carbon capture and sequestration
(a full BECCS solution), these facilities will produce fuels with a
Carbon Intensity of -100 and for every bone dry ton of biomass
utilized, these plants will capture and sequestre roughly a ton of
CO2.
Given the scale of the forest management need in California and
the potential for biomass to play a role in addressing climate
change, we urge CARB to revisit their assumptions around biomass
generation and generally support biomass utilization. We hope that,
moving forward, they can support efforts such as promoting
forest-based biofuels in the LCFS program and support changes in
federal regulations to assure that forest biomass can receive equal
treatment with other sources of biomass in the federal RIN
program.
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