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Published Dec. 18, 2010
The Center for Biological Diversity, an environmental organization, contends that the cap-and-trade program approved Thursday by the California Air Resources Board contains loopholes that would promote forest clear-cutting.
Regulations like the new one in California have the potential to significantly boost the use of solar electricity as a cost-competitive way to generate electricity while limiting emissions of greenhouse gases.
Like other proposed emissions trading programs, the California regulations call for the trading of carbon “offset” credits or allowances as one way companies can comply with regulated limits. The intent is to allow flexibility in promoting greenhouse gas reductions, the idea being that companies in some industries may have few or no options for cutting emissions while continuing to produce needed products at reasonable costs.
Under the regulations, companies will not face specific emissions limits but must supply enough allowances to cover their annual emissions. Each credit or allowance will represent a ton of carbon dioxide emissions. The total number of allowances to be issued in the state will drop annually. The board hopes that will prompt companies to seek the least costly and most efficient ways to cut emissions and reduce reliance on allowances.
The Air Resources Board will provide free allowances to industrial emitters between 2012 and 2014. Companies that need more than their initial free allotment will be able to buy them at quarterly auctions the board will conduct or on a tradable market.
Companies also will be able to cover 8 percent of emissions using credits from certain “offset” projects involving forestry management, urban forestry, methane digesters at dairy farms, or the destruction of existing sources of ozone-depleting substances in the United States, such as old refrigerators and air-conditioning equipment.
The Center for Biological Diversity, based in Tucson, Ariz., said in a news release after the board approved its emissions cap-and-trade plan that “among the options is buying offset credits from forest clear-cutting.”
“Clear-cutting forests is not the solution to global warming,” said Brian Nowicki, California climate policy director at the Center for Biological Diversity. “Including forest clear-cutting not only threatens forest ecosystems and important wildlife habitat, but the integrity of California’s cap-and-trade program as a whole.”
The board’s 105-page forestry offset program, called “Compliance Offset Protocol for Forest Projects,” as published Oct. 28, 2010, does not actually mention clear-cutting, but does acknowledge that trees are harvested commercially. The protocol has detailed procedures for receiving offset credits, specifically requiring, in effect, that more trees be planted than harvested, that native trees be preferred in forests, and that older trees be given greater weight, among many other specifications.
Exceptions to a requirement that the stocks of standing live trees be maintained or increased are allowed under certain circumstances.
The protocol says, “Exceptions are allowed where reductions in standing live carbon stocks are important for maintaining and enhancing forest health, environmental co-benefits, or the long-term security of all carbon stocks; where reductions are due to non-harvest disturbances; or where reductions are required by law. Note that these exceptions in no way change or affect the requirements related to compensating for reversals.”
The protocol spells out conditions under which reforestation projects qualify for offset credits in places where timber is harvested.
In its news release, the Center for Biological Diversity said that “Dozens of representatives of forest conservation organizations and residents of rural communities in California’s forested areas testified at the air board’s hearing Thursday in opposition to the inclusion of forest clear-cutting in the rule. Air Resources Board member Dorene D’Adamo proposed an amendment to protect against forests being converted to tree farms for the purpose of generating carbon credits, but the board ultimately voted to allow forest clear-cutting to remain in the rule.”
“At best, this will subsidize, at the expense of the people of California, the operations of some of the most damaging forest management going on today,” said Mr. Nowicki. “At worst, this will incentivize the clear-cutting of natural forests to be replaced by tree farms.”
The center says that “Other loopholes in the new regulation will allow big timber companies to claim offset credits for forest growth and other management actions that likely would have occurred anyway, even in the absence of a forest offset program. These so-called ‘non-additional’ credits do not represent actual emissions reductions, yet under the cap-and-trade rule can be sold to industrial polluters, who then can evade responsibility for reducing their own emissions. The result will be an overall increase in greenhouse gas pollution.”
The board’s view, as expressed in the protocol, is that the forest management credits do represent net greenhouse gas reductions because of the ability of trees to absorb and sequester carbon dioxide.
“The goal of this protocol is to ensure that the net GHG reductions and removals caused by a project are accounted for in a complete, consistent, transparent, accurate, and conservative manner and may therefore be reported as the basis for issuing Offset Credits,” the protocol says.
“Forests have the capacity to both emit and sequester carbon dioxide, a leading greenhouse gas that contributes to climate change. Trees, through the process of photosynthesis, naturally absorb CO2 from the atmosphere and store the gas as carbon in their biomass, i.e. trunk (bole), leaves, branches, and roots. Carbon is also stored in the soils that support the forest, as well as the understory plants and litter on the forest floor. Wood products that are harvested from forests can also provide long-term storage of carbon.
“Through sustainable management and protection, forests can also play a positive and significant role to help address global climate change. The Forest Offset Protocol is designed to address the forest sector’s unique capacity to sequester, store, and emit CO2 and to facilitate the positive role that forests can play to address climate change,” the document says.
The Center for Biological Diversity said, “the Air Resources Board had outsourced the development of the forest offset protocol to the Climate Action Reserve, a nongovernmental organization that registers carbon offset projects. The Climate Action Reserve developed rules that reflect the strong influence and preferences of the timber industry, particularly Sierra Pacific Industries, California’s largest private landowner and greatest practitioner of forest clear-cutting.”
In its action Thursday, “the board voted to make clear-cutting the face of California’s efforts to fight global warming,” said Mr. Nowicki. “Industrial polluters, instead of making positive changes to improve their operations and reduce their greenhouse gas emissions, will be able to simply buy dubious offset credits from industrial tree farms. This is a serious blow to the state’s forests as well as its efforts to reduce greenhouse gas emissions. We can and must do better, and that starts with closing these dangerous loopholes.”
The center also said that “the cap-and-trade regulations adopted Thursday also allow industrial polluters to avoid responsibility for greenhouse gas emissions caused by burning forest ‘biomass’ — including whole, live trees — for the generation of energy and other industrial uses. This not only would encourage the wholesale logging of California’s forests to provide fuel for industrial processes and electrical power generation, but also threatens to increase overall greenhouse gas emissions because the actual greenhouse gas emissions from burning wood can be higher than from burning fossil fuels.”
Sierra Pacific Industries operates eight co-generation plants that turn what it says is wood waste into electricity. The plants total 150 megawatts of power production capacity.
“Bark, sawdust, and other low-grade byproducts of the manufacturing process were burned or sent to landfills in the past. Today, SPI turns these materials into fuel for on-site co-generation facilities,” the company said on its website, adding, “Wood waste from the forest is also utilized in the co-generation process. Un-merchantable wood (small trees & branches) is selectively removed and processed to improve the remaining stand of timber in areas where trees are too dense and pose a fire danger.”
The company says that “the biomass power industry provides an environmentally responsible means of disposal of about 25 million tons of woody wastes annually, turning waste materials into valuable electricity. It prevents the open burning of a substantial amount of these tons, mostly agricultural and forest residues, with the attendant massive amounts of air pollution.”
When the Air Resources Board first began adopting the framework for the forest protocol in 2009, California Gov. Arnold Schwarzenegger praised Sierra Pacific Industries. In a letter that the company posted on its website, he said, “I’m extremely proud of the work Sierra Pacific is doing as a California company in leading the nation with the United States’ largest carbon sequestration project. This is exactly the way it’s supposed to work: the state sets rules that even the playing field and protect our economy and our environment, and a private company takes the ball and runs with it. I could not be more excited to think that this project will result in sequestering enough carbon dioxide that it will effectively take 300,000 cars off the road for a year. … The fight against global climate change is an important one to me, and this is exactly the kind of action we need to see if we’re going to be successful.”