Sustainability Issues in Biomass Feedstock Production: A Policy Perspective - Engineering and Science of Biomass Feedstock Production and Provision - page 238

environmental questions: (1) the GHG implications of shifting energy production
from fossil fuel sources to forest biomass; (2) the amount of available forest wood
necessary to support the state's energy goals; and (3) the potential ecological
impacts of increased biomass harvests in state forests and the policies necessary to
ensure the continued sustainability of the harvests [ 55 ].
The new RPS rule defi nes eligible woody biomass as (1) forest-derived residues
(i.e., tops and other portions of trees produced as a byproduct of the normal harvest-
ing process, other woody vegetation that interferes with regeneration of natural
growth but limited to locally invasive native species and nonnative invasive woody
vegetation); (2) forest-derived thinnings (including whole trees that are weak or of
low vigor and trees removed during thinning operations for the purpose of reducing
stand density and enhancing growth and volume of the stand); (3) forest salvage
(i.e., damaged, dying, or dead trees due to weather events or disease and trees
removed to reduce fi re hazard, but not those trees removed due to competition
between plantings); and (4) non-forest-derived residues (including trees removed
for nonagricultural and agricultural land-use change) [ 56 ].
Each year, the unit using eligible biomass woody fuel must document total ton-
nage through “biomass fuel certifi cates.” The certifi cate also verifi es the source of
forest-derived residues and thinnings by citing either a Massachusetts Department
of Conservation and Recreation (DCR) “cutting plan” or other equivalent state plan
prepared by a licensed forester, or obtaining the signature of a professional forester
[ 56 ]. The DOER has created a set of certifi cate guidelines on an Excel spreadsheet
that place additional restrictions on biomass removal [ 57 ]. For forest-derived resi-
dues, the report must provide information detailing the residues' precise deriva-
tion—whether the residues are harvest by-products or the result of damage caused
by invasive species. This is required to prevent prohibited material or materials in
prohibited amounts from entering the supply chain, including material from old-
growth forest stands, naturally down woody material, forest litter, forest fl oor roots
and stumps, live cavity trees, den trees, and live but decaying trees and snags. In
addition, the amounts of biomass eligible to be taken away from a harvest site are
tied to the overall tonnage of biomass harvested and to the quality of the soil at the
harvest site.
For areas deemed to be of poor soil quality, 100 % of the tops and branches from
the forest material must remain on site in order to prevent erosion and to supplement
soil conditions and quality. In cases where soil quality is “good,” 25 % of the tops
and branches from the harvest must remain on site. A soil designation of “good” or
“poor” is determined by set criteria established by DOER and the NRCS. In all
cases, 30 % of material eligible for thinning must remain. Beyond regulation and
guidance specifi c to the RPS, any forest harvesting activity in the state above a cer-
tain volume must be conducted with an approved cutting plan pursuant to the Forest
Cutting Practices Act (FCPA), including compliance with the Best Management
Practices Manual [ 58 ]. Like most states, Massachusetts maintains its own
Endangered Species Act that also applies to any forestry activities, including those
conducted to qualify for the state's RPS.