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Comment 372 for 2022 Climate Change Scoping Plan (scopingplan2022) - Non-Reg.

First NameRobert
Last NameHambrecht
AffiliationAllotrope Partners
SubjectScoping Plan California Biomass Assumptions

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. 



Original File NameJoint Institute Forest Biofuels_final_2022.pdf
Date and Time Comment Was Submitted 2022-06-21 15:58:43

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