This is why I think we shouldn't count carbon stored in harvested wood products

I am always taking the position that we should not include carbon stored in wood products as contributing to our Kyoto obligations or within forest carbon offsets and I am often challenged by others for this position. Their challenge is usually along the lines of, "But carbon in wood products is real, why not count what the atmosphere sees?" Here are some comments I made last week in D.C. to the Forest Carbon Standards Committee established by the AF&PA laying out my argument. It boils down to this: ask not just what the atmosphere sees, ask what outcome you wish to achieve!

The wood and paper industry is in the business of supplying society with products of great value to society. One of the environmental costs of this activity is that managed forests are maintained at a younger age and their carbon stocks at a lower level than would naturally occur.

Sufficient incentive already exists from the market place for the wood and paper industry to transform trees into products. What the industry needs is a financial incentive to reduce the impact of this activity on forest carbon stocks, while continuing to meet the societal product demand.

In developing carbon market incentives for forest management, we should therefore focus on increasing forest carbon stocks, not harvested wood product stocks. There is no inherent benefit of transferring carbon from the forest pool to the product pool. In fact, there are ecological costs to this transformation.

The main greenhouse gas benefit of supplying society with wood products is that they have lower embodied emissions than alternatives, especially in construction: the production of wood results in far fewer emissions than the production of steel or concrete. Placing a price on carbon will create an incentive to switch from concrete and steel to wood because of this lower emission profile. This incentive will exist without counting the carbon stored in the wood itself. This incentive should increase the demand for wood.

An increased demand for wood should create increased pressure on our forest that would exacerbate the lowering of forest carbon stocks. Let us use the forest carbon offset as a mechanism to reward forest managers and landowners that are able to meet this demand while also maintaining forest carbon stocks high or even increasing them.

These two forces pulling in different directions (price on carbon demanding more wood and an offset system rewarding more carbon in the forest) could help us find an environmentally optimal solution. Including carbon in harvested wood products in forest offset systems will reduce the impact of incentives to maintain or increase forest carbon stocks.

Implementing this approach is not a question of 'excluding' carbon in wood products from accounting; it is simply a question of making forest carbon stocks the focus of accounting and incentives.

Biomass and carbon neutrality

A little while ago CPAWS put out a couple of media releases and I wrote a couple of blog posts that commented on the issue of carbon neutrality and burning biomass as a source of energy. These communications have given rise to some questions about what exactly my position on this topic is, so I am writing this post to clarify.

1. The forest industry in Canada has made a lot of progress using wood processing waste as an alternative source of energy in their mills, and this is a good thing.
2. In accounting for emissions and setting energy policy, it is important to take account of the emissions that do result in the forest as a result of biomass harvest. For example, the harvesting of trees reduces forest carbon stocks and this reduced carbon stock should be recorded as an emission when it occurs. It is true that these forests and much of the carbon will grow back over time, but not accounting for the emissions when they occur could lead to inferior policy choices that fail to optimize emission reductions in the near-term. What I was responding to was the indication from policy initiatives that, rather than accounting for these emissions, they would *assume* carbon neutrality (simply because forest carbon grows back over the long-term).

To be clear: I have no problem with the approach of accounting for all emissions at the time of forest harvest.

I would like to thank the readers of my blog that have asked me for clarification on this point. I hope this helps!

If you are interested to read more about CPAWS' thoughts on biomass and woody bioenergy, you can check out a factsheet online.

Initiative Founded to Deliver "Bi-National" Forest Offset Standard

It's official: A Forest Carbon Standards Committee convened in Washington DC last week has agreed to take on the task of developing a "bi-national" forest carbon offset protocol that could be taken 'off-the-shelf' by any jurisdiction in the US or Canada that is going to include forest offsets in a regulated carbon market.

The protocol will be an ANSI (American National Standards Initiative) standard, and the secretariat is asking whether it could also be accredited as a CSA (Canadian Standards Association) standard. An important question is how Canadians and Canadian organizations will feel about this process setting a Canadian standard because it is membership on the committee is largely American.

The big question on my mind is: is this the right forum to develop the vision for Canadian forest carbon offsets?

The committee agreed to focus its work in four topic areas:

• Baselines and additionality
• Permanence and leakage
• Quantification, verification, measurement and monitoring
• Sustainability

The next step for a small sub-committee to develop a scoping paper for the committee's work.

Watch here for updates and comments on the process.

Time to Roll Up Your Sleeves, Time to Work on Forest Offsets

I'm in Wasthington D.C. for two days of meetings about forest carbon offsets. I was invited down by the American Forest and Paper Association to join its new Forest Carbon Standards Committee. What I didn't fully appreciate until getting here is that the AF&PA is proposing to kick off a process for developing a formal standard for forest carbon offsets that would be recognized by the American National Standards Institute (ANSI) and the Canadian Standards Association (CSA - CSA was here as an observer to consider participation).

Let me say that again with more gravitas: the American Forest and Paper Association is proposing that this committee should develop *the* standard for how forest offsets are treated across the US and Canada. It wants this standard to be of 'compliance quality' so that it could be picked up by regional/provincial/state and federal regulatory bodies in both countries. In other words: there's a new, big game in town.

How big and how important will depend on who participates, whether agreement can be reached and how good the standards are that result. Either way, it's time to roll up the sleeves because answers on how to do forest offsets (good or bad) are starting to flow: the Canadian federal system will soon be accepting proposals to develop forest offsets; the Western Climate Initiative has established a sub-committee that will review forest offset protocols; the Regional Greenhouse Gas Initiative and the California Climate Action Registry have proposed new rules for forest offsets, and this AF&PA process will try to develop a 'bin-national' standard that could influence or replace all these others.

I'll write more after the meeting tomorrow.

Green Carbon

I attended a phone call organized by Pew Envirionment Group on Friday to hear Brendan Mackey present the findings from Green Carbon: The role of natural forests in carbon storage. The report is a publication of the Australian National University that argues the importance of protecting primary forests to climate change mitigation and also demonstrates how conventional approaches to measuring carbon stocks in forests greatly underestimate the amount of carbon stored in primary forests.

He calls this carbon "green carbon," to contrast with the "brown carbon" stored in forests that are managed commercially by the forest industry for timber production. Dr. Mackay pointed out that much of the World's remaining primary forests are in industrialized countries like Canada and Russia, yet the current UN climate change negotiations' special discussion on preventing forest degradation only applies to the tropics and developing countries.

Actually, forest degradation in industrialized countries is also on the radar but in a more less visible way and is threatened to just be subsumed under a broader discussion of carbon stocks in managed forests. We could fail to see and appreciate the green carbon for all the brown.

Ensuring carbon offset systems protect biodiversity

In a recent submission to the federal government on Canada's Offset System for Greenhouse Gases, I proposed that all offset projects should be subject to a test for their effect on species listed under the federal Species At Risk Act.

I had been trying to come up with a test to ensure biodiversity benefits. We liked this idea because it was simple and consistent with an existing federal statute. I'm curious if anyone else has any thoughts on this idea or any information on other approaches being promoted elsewhere.

I know of a couple of other possible approaches:

1. The Forestry Protocol under the California Climate Change Action Registry only allows conservation, conservation-based forestry and restoration as eligible projects. This approach ensures biodiversity benefits by restricting project types.

2. The Climate, Community and Biodiversity Alliance also propose a species at risk test in their standard for assessing land-based carbon offset projects, but they also have a more general requirement of net positive biodiversity impacts. It seemed to me that the transaction costs of this approach might be too high.... would it be feasible to measure biodiversity benefits broadly?
...does anyone have any experience with this approach or knowledge of how this has been implemented?

3. In a draft forest management protocol developed for use (but not approved) within the Alberta Offset System, it was required that offset project activities not adversely affect biodiversity targets developed by forest managers. Certification to third-party forest management certification systems was also suggested.

4. The Clean Development Mechanism under the Kyoto Protocol require an evaluation of environmental impacts and an environmental assessment may be required.

What do you think? It would be great to hear your feedback. Thanks.

Some input on Canada's Offset System for Greenhouse Gases

The 60-day public comment period just passed
on the draft Guide for Protocol Developers under Canada's Offset System for Greenhouse Gases.

What's a protocol? An offset protocol is the document that tells someone interested in creating an offset project what he/she/it will have to measure the emission reduction and register it for sale within the offset system. A protocol developer could be an individual, institution, organization, business or government.

A 'guide' for protocol developers essentially tells us the level of rigor that will be expected of protocol developers and therefore gives us an indication of how rigorous and credible the whole system will be.

I wrote and submitted some comments from CPAWS and David Suzuki Foundation on the draft guide. You can check them out on the CPAWS website. Here are the major points we made in our submission:

• Emission reductions must be real and clearly additional to reductions that would have occurred without the purchase of offsets.
• Permanent credits must only be given for permanent emission reductions; for impermanent emission reductions, such as those associated with forestry and land use, credits should be temporary or deeply discounted.
• Limits must be placed on regulatory compliance through the use of offsets. The use of credits from forestry and land use activities could be further limited if there is less confidence about their performance or concern about the effect of forestry offsets on carbon price.
• All offsets should adhere to a principle of net environmental benefit. Protocols should require the measurement of impacts on species identified under the federal Species at Risk Act. This requirement should at least apply to forest protocols, which could be dealing with large ecosystems and could have significant biodiversity impacts.
• Forest projects should focus on conservation activities because these deliver the greatest short-term emission reductions and also the greatest environmental co-benefits. In fact, we encourage the Government of Canada to prioritize the development of a forest conservation offset, rather than a forestry offset.

A few details emerge from WCI...but not many

I called in to the conference call that the Western Climate Initiative was holding today to answer questions about the final recommendations released last month. There were about 300 people on the call - so many that there weren't enough lines at the start of the call and more had to be added!

I asked a couple of questions of the WCI partners:

1. The final recommendations say that each partner can decide whether or not biomass sources of energy are carbon neutral. I asked whether the WCI was going to do anything to ensure that these decisions took full account of actual emissions, warning that a carbon neutrality assumption for energy from burning forest biomass could mask actual emissions. The partners essentially answered that the jurisdictions have very different approaches to assessing carbon neutrality and WCI would not interfere. The answer indicated to me a lack of willingness to police this issue.

2. The final recommendations include a 49% limit on the extent to which a partner's emission reduction commitment can be met through offsets. Have the partners considered whether a separate (smaller) limit might be placed on the use of forest offsets to deal with concerns about permanence and emission allowance prices. The partners responded that they have not yet decided to place any additional limits on offset categories, leaving me with the impression that this discussion could still be had.

Many other questions were asked including a couple of more about offsets:

3. How would the 49% limit placed on partners be transferred to companies? The partners answered that they really hadn't figured this out yet.

4. What will be the process for developing offset protocols? The partners answered that a process in 2009 would be designed that would allow all partners to participate in the development of protocols. They said that they would make use of existing protocols as appropriate and perhaps adapt them for use in the WCI region.

The final WCI recommendations are online.

Quebec Calls for 125MW of energy from forests

This is a guest post from Nicolas Mainville, Director of Conservation, CPAWS Quebec:

Following the launch of its new program for woody bioenergy in July, the Quebec government just announced a call for 125 MW coming from forest biomass, to be purchased by Hydro-Quebec. This decision, approved by the Ministers’ Council (Conseil des ministres) last week, confirms the strong intention by Quebec to open large scale woody biomass energy projects across the province. Although no public hearings or debates have been put forward, this new strategy to “dynamise Quebec’s forest sector” has attracted a lot of attention lately. Here’s an overview of the new program to be included eventually in Quebec’s Forest Act, as described by the MNR:

Overview of the program

• The program was mainly put forward to accelerate conversion strategies of heavy fuel oil heating systems towards woody biomass (150 M$ is allocated over 3 years to the conversion strategy included in the Quebec Climate Change Mitigation Plan), but the new 125MW call shows that Quebec wants more than that and is ready to actively develop this sector.
• The program specifically allocates new volumes of woody biomass on Crown lands
• These volumes come from:
• not-harvested allocated wood,
• Not allocated left-overs (branches, leaves)… roots and stumps are not included in the program
• From naturally perturbed areas (wild fire, insects infestation, etc)
• “Back log” or temporary permits
• Anybody can apply to the program
• The best projects will be elected depending on:
• Profitability
• Environmental “gains”
• Support from local communities and regional authorities
• Investment proposed by the contractor
• It’s a 5 year program, that apparently will be included in the Forest Act once ongoing projects show their profitability

Goals of the Woody bioenergy Program:

• Create jobs and stimulate the regional economies
• Reduce Quebec’s dependence on foreign oil
• Promote new forest management strategies and improve the health of deciduous forests

Restrictions:

• The harvest must not interfere with soil productivity or biodiversity
• There is an “open door” for post-harvest fertilization

However, no guidelines, thresholds or monitoring is planned or described in this program. It is also ambiguous how it is going to cost the harvester and how much the government is planning to invest. The calls for submissions are ongoing but the industry is already complaining about the short amount of time dedicated to the program (5y). This program is shown as one of the best solutions to tackle climate change…many of the arguments are based on the false claim that the bioenergy sector is “carbon-neutral”.