Yosemite Clean Energy June 23
Comments to CARB regarding its 2022 draft climate scoping
plan
Yosemite Clean Energy is a California
company strategically positioned to convert forest and farm biomass
into carbon negative hydrogen and renewable natural gas, utilizing
CCS, and providing carbon negative transportation fuels to the
state. Yosemite is concerned by CARB’s assessment of forest
biomass utilization in its recent draft scoping plan. Specifically,
Yosemite disagrees with the assessment that 30% of waste biomass
should be left in the forest, that companies will leave more than
30% in the forest because of its lack of value, and that much of
the waste will be burned or left to rot due to lack of social cost.
A requirement to leave 30% of waste biomass in the forest is an
outdated number that does not consider amount of waste biomass per
acre in recent years. An estimation that companies would leave more
than 30% does not take into account the value of this waste biomass
and the value of efficiency when removing more waste from the same
area. Finally, the idea that much of the biomass in the state will
be left in the forest due to lack of social cost also fails to take
into consideration the value of waste biomass in a developed
biomeconomy, and the commercial efficiency of removing biomass for
utilization in biofuels production.
To meet the State’s forest management
goals, California has to develop a robust market for waste biomass,
and CARB has an ability to contribute to this market if it updates
its draft scoping plan with an eye for biofuels production as
opposed to the assumption that most waste biomass decay or burn.
Yosemite agrees with the article posted by Sam Uden, which provides
more information on each of Yosemite’s points. Link and text
as follows:
https://www.csgcalifornia.com/blog/missed-opportunity-draft-scoping-plan-fails-to-address-biomass-pile-burning-and-decay/
Missed opportunity: Draft Scoping Plan fails to address
biomass pile burning and decay
June 9,
2022Posted by Sam
Uden
California recently released a draft version of its
main climate plan, finding that it is preferable to open burn or
leave to decay in the forest a significant portion of biomass
residues resulting from wildfire prevention treatments. This is a
missed opportunity: as a robust strategy to collect and convert
forest waste into carbon-negative wood and energy products is
a promising path to enable the state’s goal
of treating one million
acres per year. This is essential to reduce the risk
of high-severity wildfire in California, where
a single runaway
season can emit volumes of
CO2 that rival what the state can
reduce in a decade.
In this
technical blog post, we analyze the role of forest biomass in
the Draft 2022 Scoping
Plan. We identify various modelling
assumptions that bias residues towards being left in the
forest. We provide recommendations to improve the treatment of
forest biomass in the Plan, feasibly driving a host of co-benefits
to watersheds and local communities. Finally, we highlight how
biomass utilization could support California’s need
for carbon dioxide
removal to achieve net-zero emissions and
below by 2045 or sooner.
***
The California Air Resources Board (CARB) recently released a
draft version of its Scoping
Plan, which describes how the state could achieve net-zero
emissions by 2045. The Plan covers all sectors of the economy. It
also incorporates a substantial new component that assesses the
carbon sequestration potential of the state’s Natural and
Working Lands (NWLs), including forests, croplands, wetlands, and
more. This is an important addition because of the increasing role
NWLs are likely to play both as a carbon sink but also source of
emissions, driven by impacts such as wildfire as well as the
management of farm and forest biomass residues.
One area
where the Plan falls short, is in relation to forest biomass.
Specifically, the proposed management of residues resulting from
wildfire prevention treatments. These volumes are expected to
increase substantially, as governments ramp up treatments
to one million
acres per year. CARB models an even more ambitious level of
treatments in the Plan, at 2.3 million acres per year.
The biomass utilization
imperative
It is generally estimated
that 10-15 dry tons of forest residues will accrue per acre
treated,[1]equal to 10-15 million new tons per year (at one
million acres treated) and 23-34.5 million new tons (at 2.3 million
acres treated). These huge volumes underscore the pressing need to
expand product markets and progressively build out an
infrastructure capable of managing them. A strategic focus on
residue utilization can support the
cost of forest treatments, provide economic
opportunities in rural communities, and avoid
the alternate
scenario where forest biomass is piled and burned or
left to decay, releasing CO2, PM2.5, and powerful short-lived
climate pollutants such as methane. A rough calculation shows that
this could result in an additional 63 Mt of CO2 emissions per
year.[2]
Contentious
assumptions adopted by CARB
Despite the utilization
imperative, CARB’s model is biased towards leaving biomass in
the forest – not only generating emissions, but also
maintaining a clear wildfire risk to communities. This follows
certain assumptions adopted in the underlying modeling. We describe
three of these below:
· 70%
assumption: As a baseline assumption, a maximum of
70% of gross residues resulting from a fire prevention treatment
can be collected, with at least 30% left in the forest. This is
based on a 2011 national
study that arguably does not reflect the
presently vulnerable
state of Western forests.
· Indifference
assumption: Relatedly, CARB assumes that regions
are indifferent to collecting the available 70% of residues, and
would (with equal probability) collect smaller portions, such as
50% or 30% of residues. CARB takes an average of possible
collection scenarios to develop a final estimate of
“mobilizable” residues (i.e., the volume of residues
that the model says could technically be collected). By taking an
average, this estimate is lower than if it was assumed that regions
prioritized collecting all available residues that posed a wildfire
risk to communities.
· Social cost
assumption: As a final screen, CARB assumes that
only a portion of the residues deemed “mobilizable”
would be collected, based on the “social cost” of open
burning or leaving the residues to decay. Social cost is measured
as the criteria pollutant and CO2 emissions damages associated with
open burning and decay. In a number of cases, including notably the
North Coast the model concludes it is preferable to open burn or
leave residues to decay because of the low value attributed to
reducing air pollution and wildfire in those regions.
The fallout of CARB’s modeling approach is that only a
small volume of forest biomass is recovered – on average, 2
tons per acre – into hydrogen with
carbon capture and storage. Relative to estimates of 10-15 tons
per acre, this suggests that 80-90% of what could be collected is
burned or left to decay (Fig. 1).
Fig. 1 stylistically
represents how model assumptions adopted by CARB limit the volume
of residues recovered in the Scoping Plan (on average, 2 tons per
acre) relative to the gross residue resource total. Note that this
is not an exhaustive assessment of the assumptions and approach
adopted by CARB.
Recommendations to improve the
model
The minimization of the role of forest
biomass in the draft Plan is significant, as it could justify
limited investments and policy support for climate-resilient
California forests and local communities. CARB should consider the
following strategies to improve the treatment of forest biomass in
the Plan:
· Review 70%
assumption: It is essential to retain some
residues in the forest to meet ecological and operational needs,
although 30% is arguably too high in water-scarce, fire-prone,
vulnerable Western forests. CARB should engage forestry experts
further to review this assumption.
· Revise
indifference assumption: It is reasonable to assume that,
when faced with a choice of recovering all available residues or
just a portion (the remainder of which would be burned or left in
the forest), regions would prioritize full residue recovery. This
reflects regional and state goals to reduce wildfire risk and CO2
emissions and support rural economic development.
· Abandon social
cost method: While we recognize CARB’s effort
to develop this screening method, it is limited in that it fails to
incorporate the benefits of collecting residues. These include
improvements to downstream water supply, wildfire risk reduction
for communities, and regional economic development associated with
the creation of new manufacturing facilities and carbon management
supply chains. Factoring-in these benefits would almost certainly
increase the volume of residues deemed “mobilizable” in
the model. However, to do so would be an extremely challenging (and
frankly, unreliable) analytical exercise. Instead, CARB should
abandon this method, recognizing that robust considerations
regarding air quality and public health will always be made at the
project level under CEQA and NEPA.
CARB should target the carbon dioxide removal
opportunity
A system that mobilizes forest waste into products will not
only reduce fire risk and CO2 emissions, but could also help
California achieve another objective: its need for carbon dioxide
removal (CDR).
CDR refers to actions that physically
remove CO2 from the atmosphere. The Plan estimates that 100 Mt of
CDR will be needed per year by 2045 to compensate for hard-to-abate
emissions in the economy, such as animal agriculture, aviation,
shipping, and some industrial processes, as well as to address
legacy emissions. As NWLs are expected to be a net source of
emissions, removals can only come in the form of direct air capture
with carbon storage (DACCS) and bioenergy with carbon capture and
storage (BECCS). As a relatively low-cost CDR option, CARB should target forest BECCS
for the CDR opportunity it provides.
BECCS is
routinely shown as the main CDR
option by the IPCC, and California is well-placed to advance this technology for
global benefit. Lawrence Livermore National Laboratory’s
award-winning Getting to
Neutral report provides a helpful starting point by
showing biomass waste availability on a county-by-county basis,
including forest, agricultural and urban residues. The Low Carbon
Fuel Standard is a policy
mechanism that can support sustainable forest BECCS (and
fire prevention) in California. BECCS projects also qualify for
$3.5 billion in forthcoming federal funding for Regional
Direct Air Capture hubs.
Conclusion
In 2020,
wildfires emitted over 100 Mt of CO2 in California. This
amount alone is greater than the total emissions reductions
achieved by the state since the passage of AB 32. Reducing the risk
of high-severity fires and improving forest resilience is one of
California’s most pressing climate problems.
A
robust forest biomass strategy that has the capacity to manage at,
or near to, the gross resource total from ecological land
management is essential to this. Moreover, a state biomass strategy
that prioritizes CDR can help assure the negative emissions needed
to achieve net-zero and below by 2045 or sooner.
For
more information on CSG’s research and policy initiatives in
support of California’s clean energy transition, please
contact Sam Uden (sam@csgcalifornia.com).
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