The California Governor’s Office of Planning and Research on Aug. 27 filed comments with the California Air Resource Board expressing concern over the treatment of forest biomass waste and provisions governing where biomass can and cannot be sourced included the agency’s proposed changes to California’s Low Carbon Fuel Standard.&nbsp;“We believe that these amendments risk undermining the state’s ongoing efforts to meet its ambitious wildfire prevention, forest resilience and climate goals,” wrote Samuel Assefa, director of the Governor’s Office of Planning and Research, in the comments.&nbsp;In his comments, Assefa notes that CARB’s 2022 Scoping Plan for Achieving Carbon Neutrality identified the need for an expansion in wood biomass residue utilization, particularly from forest and agricultural residues, as necessary for achieving carbon neutrality by 2024. The letter also stresses that a robust and innovative wood products market is needed to increase forest management and restoration in California and drive biomass residue utilization as the scale necessary to meet the state’s wildlife prevention and climate goals.&nbsp;While California has developed several biomass utilization market and technology development programs, Assefa notes that biomass utilization projects have been difficult to get off the ground. &nbsp;“A key barrier to achieving this vision, that we have learned as part of implementing the pilot program at OPR, is a lack of a recurring revenue incentive for prospective project developers,” he wrote. “The Low Carbon Fuel Standard is a policy tool which has the potential to support the development of woody biomass residue utilization projects as this program can provide recurring incentives for these earlier stage projects.”Assefa specifically urges CARB to update its proposed definition of forest biomass waste. “CARB is proposing to define ‘forest biomass waste’ as small-diameter, non-merchantable residues, limited to forest understory vegetation, ladder fuels, limbs, branches, and logs that do not meet regional minimum marketable standards for processing into wood products,” he wrote. “This definition effectively excludes all forest biomass waste as eligible under the LCFS as all small diameter, non-merchantable residues can be converted into ‘wood products’ such as wood pellets.” Assefa encourages CARB to update the definition of forest biomass waste to mean “small-diameter, non-merchantable residues that are removed for wildfire mitigation, forest restoration projects, or the protection of public safety.”Assefa also addresses components of the proposed LCFS updates related to carbon capture and sequestration (CCS) eligibility. “OPR supports the use of CCS to reduce carbon intensities and generate carbon negative emissions where possible,” he wrote. “The proposed amendments, however, limit sequestration to geologic storage and limit the use of captured carbon to fuels production. These restrictions exclude the use of biochar, which can be a coproduct of hydrogen, electricity or biofuels production from waste biomass. The scientific literature supports the conclusion that biochar can be used for carbon sequestration in soil or to reduce emissions from enteric fermentation, livestock manure management and compost. &nbsp;Biochar can also be used in the production of concrete, pavement, and other products to sequester carbon. Excluding the use of biochar will harm the economic viability of forest waste projects and contradicts the recommendations in the 2022 Climate Change Scoping Plan to increase the use of bioenergy with CCS (BECCS).”In addition, Assefa asks that CARB update proposed LCFS provisions related to forest biomass waste as a specified source feedstock. “CARB is proposing to include forest biomass waste from non-industrial forestland removed for the purpose of wildfire fuel reduction or forest restoration as a specified source feedstock under the LCFS Program,” he wrote. “We find this troubling as this amendment would significantly restrict the amount of material available for biomass utilization projects. Industrial forestland owners are currently the only entities in the State capable of offering reliable, long-term forest feedstock supply agreements. At OPR, our staff has been working with state, federal and local government partners to enhance the biomass mobilization and processing capacity of rural economies throughout Northern California.”CARB originally issued proposed amendments to update its LCFS program in late 2023, with a public comment period that was open until Feb. 20, 2024. A public hearing on the proposed amendments was originally scheduled to be held in March 2024, but was later delayed and is now scheduled for Nov. 8, 2024. CARB released a new notice on Aug. 12 that includes a wide variety of updates to the originally proposed LCFS amendments. Those changes were subject to a 15-day public comment period, which closed Aug. 27. More than 250 additional comments were filed during the 15-day comment period. &nbsp;CARB could vote to implement the proposed amendments during the Nov. 8 hearing, with the proposed LCFS program changes in place as soon as early next year.&nbsp;Full copies of comments filed during the 15-day comment period are available on the CARB <a href="https://www.arb.ca.gov/lispub/comm/iframe_bccommlog.php?listname=lcfs2024&amp;_ga=2.72995152.213137543.1725048159-197957890.1723577824">website</a>.

2024-09-04 - California Governor’s Office urges CARB to update LCFS provisions focused on forest biomass waste (Biomass Magazine)

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The California Governor’s Office of Planning and Research on Aug. 27 filed comments with the California Air Resources Board expressing concern over the treatment of forest biomass in the agency’s proposed changes to LCFS.

California Governor’s Office urges CARB to update LCFS provisions focused on forest biomass waste

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