I mentioned that I was working on a project to find areas of agreement between environmental groups of various kinds (ENGOs) and others on a variety of topics related to restoration, fuels management and wildfires. I looked at the Climate Smart Agriculture and Forestry public comment letters that USDA requested earlier this year.
Previously we’ve discussed the question of “fuel treatment vs. restoration” because sometimes they are lumped (in reality, and in discussion and writing) and sometimes they are split; and there are enough disagreements around this set of questions (IMHO) without different definitions clouding the picture. And some ENGO’s are against fuel treatments (“excuse for logging”) but not restoration. I also agree with Susan Jane Brown who gave some examples in this comment of what we can accomplish without being in agreement:
And I personally think that we can disagree about it and still move forward with treatments on the land: many collaboratives do this regularly. For example, there may not be agreement on anthropogenic climate change, but there is agreement that losing structures in a wildfire is an undesirable outcome and that community preparedness and landscape RESILIENCE are things we can take steps to accomplish.
So for now, I’ll just be on the lookout to see how each group defines “restoration.” To cut to the chase, I found that a surprising number of ENGOs support commercial use of restoration residuals, which I’ll cite in this and later posts. But there is a main underlying political question.. who decides what counts as restoration? We can imagine an international FSC-like certification system, a USDA organic labelling kind of thing, something at the state level, all the way to what a local collaborative agrees on. Each choice invests different actors, at different spatial levels, with power to wield the lever of what’s in and what’s out, with associated concerns of diversity, equity and inclusion.
But let’s start with the Statement on Removal and Use of Forest Biomass, which is actually not from the Climate Smart Letters at all. It was signed by the ENGO’s in the image at the top of the post. The whole statement is well thought out and comprehensive IMHO and worth a read. Below are a few excerpts.
Statement on Removal and Use of Forest Biomass
● Bioenergy facilities utilizing forest biomass waste include a range of different technologies and energy production scales, ranging from small scale bioenergy for heat (e.g., thermal-only installations), to cogenerating community scale biomass (1-5MW), to medium scale facilities (5-20MW), to larger scale facilities (> 20MW) co-located with wood processing and other light industrial facilities that can make use of waste heat and generated energy.
● The removal of forest biomass for bioenergy purposes should follow the guidelines below to ensure environmental standards are being met:
o The demand for power generation or value-added wood products at any facility should never drive removal of biomass from the forest.
o Biomass facilities should be sized according to the availability of fuel in the surrounding landscape and an ecologically appropriate removal rate, in accordance with restoration plans. To mitigate trucking and transportation costs and greenhouse gas emissions, it is desirable that supply areas be in relatively close proximity to the facility.
o The availability of fuel should be determined by landscape-level ecological restoration plans that provide for the ecological integrity and biodiversity of the target landscape.
o Any biomass facility should utilize woody biomass at an annual rate and for a period of time that is ecologically appropriate for the surrounding forested landscape. In order to attract private investment and encourage public private partnerships, supply agreements should be guaranteed across all lands and among all land restoration partners for a minimum of 10-20 years. These two conditions should be harmonized when developing commercial uses for forest
● Our groups are dedicated to ensuring clean air and clean water for all. With this goal central to our organizations, we believe that siting biomass facilities in California Clean Air Act non-compliant air basins should be avoided to reduce pollution burdens on disadvantaged communities, unless those facilities can be shown to reduce emissions from other sources of burning. Facilities should generally be located in air quality basins in compliance with federal and state standards and should incorporate emissions control technologies to ensure they remain within state, federal, or tribal standards. This precludes the siting and building of additional biomass facilities in noncompliant air basins, like the Central Valley, unless a net reduction in emissions can be achieved.
I also liked how they touched upon marketing and keeping productions within forested communities where possible or practicable..
● Marketing and branding approaches for restoration byproducts such as energy, pellets, bio briquettes, biochar, fire resistant building materials, etc., that include triple bottom
line impact statements and reinvest a portion of proceeds for charitable purposes aligning with long term restoration and maintenance of fire resilient landscapes is an additional value-added economic stacking tool that will help to reduce the taxpayer burden in the long run.
● Facilities and uses should be sited either within or as close as possible or practicable to forested communities to capture economic and social benefits in the communities of origin of the biomass materials. Previously used mill sites may be ideal in many locations and can leverage federal funding for clean-up.
The landscape level planning idea still makes me wonder.. would it be possible to do one giant NEPA document, perhaps at the 4FRI scale?
Which parts do you agree and disagree with?