Nova Scotia forests, forestry and GHGs 2: Who accounts for the EU’s emissions from bioenergy generated from imported chips?

For chips from Canada, we do. Sort of. By not specifically addressing Land Use Changes associated with forest bioenergy in GHG accounting, industry and government avoid admitting that many of these schemes are net emitters of GHGs over timeframes  meaningful for climate mitigation. There are signs, however,  that the Europeans are recognizing serious problems with forest bioenergy sourced from North America.

UPDATE Aug 10, 2018: Responses to questions posed to Climate Change NS about LULUCF Accounting:
As indicated below I had some questions about LULUCF accounting that I said I would ask of Jason Hollett, Executive Director of Climate Change at Nova Scotia Environment. View Questions and Answers
The responses confirm my conclusion that Land Use Changes associated with forest bioenergy are not specifically addressed in GHG accounting related to Paris Agreement etc.

Curved arrows represent biologically mediated flows of GHGs: the straight arrow, industrial emissions of GHGs; and the symbols at bottom right, long term sequestration of carbon in the oceans. Carbon dioxide is the most important GHG in relation to forestry.

I wrote about Peter Ritchie’s letter to Mr. Jason Hollett, Executive Director of Climate Change at Nova Scotia Environment and the response back on March 25 (view post), and envisaged that post as “the first in a series of posts in which I will try to get a handle on how forest management and the things we choose to produce from our forests affect our ability as a province to reduce the levels of GHGs (Greenhouse Gases) in our (global) atmosphere.”

As seems to happen whenever I get into this topic, I got bogged down with trying to comprehend the myriad of national and international regulations related to GHG emissions, and so it’s taken a while to get to #2 in the series.

Some of the materials I have been looking at in the meantime are posted at>Current Issues>Biomass Biofuels & GHGs and 6 subpages under the last (linked) heading:
– Literature
– Accounting Standards & Data
– Using The Feds’ Bioenergy GHG Calculator
– Wastes and Residues
– Business/Development
– GHGs In the News

Also in the meantime, PR again wrote JH and received a reply that merits attention, if for nothing else because the exchange illustrates how difficult it is to find out how Nova Scotia does its GHG accounting and whether it specifically includes accounting for emissions associated with forest biomass burning:

PR to JH, Energy Minister Mombourquette, others (Jul 17, 2018): …I have attached a recent briefing written by the European Acadamies Science Advisory Council.  It is concise and direct, so I will not attempt to summarize it here, only to point out that this is yet another significant and unequivocal statement of fact, made by a respected body of world-class scientists, that biomass-derived electricity, as produced by facilities like the Point Tupper biomass boiler, is NOT an improvement in mitigating carbon emissions when compared with coal-derived electricity.  How many such documents will have to be published and presented to you and your colleagues, for you to admit and act upon the facts of this matter?

JH to PR (Jul 20, 2018):  …Nova Scotia follows international and national standards for greenhouse gas accounting and we have no immediate plans to review those standards. Past actions have resulted in our provincial greenhouse gas emissions declining by 30% below 2005 levels, making us one of the national leaders in that respect. This is something all Nova Scotians can be proud of.

The European document PR refers to is this 2-page document:

Commentary by the European Academies’ Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality
EASAC Jun 15, 2018

It in turn references a 51 page document produced in 2017
Multi-functionality and sustainability in the European Union’s forests 
EASAC April, 2017

I found the latter, 51 page document very helpful in understanding how the Europeans – and in turn Canada, following more or less the same international reporting standards – do their forest carbon accounting and in particular how they account – and do not account – for emissions associated with forest biomass burning.

In simple terms, as I understand it, the carbon accounting relies on calculating the standing stocks (amounts) of carbon in trees and soil  on a unit of landscape and any reductions in those stocks over a time interval are assumed to represent carbon transferred to the atmosphere. Conversely increases in stocks  of carbon (trees, soil organic matter) on a unit of landscape are assumed to represent removal of carbon from the atmosphere. So they add up all of the losses and all of the gains for all of the units and the difference is the net change in carbon emissions for a region or whole country. If some of the losses relate to production of lumber, that represents continued storage of carbon and is subtracted from the losses – for a period, depending on the functional lifespan of the lumber.

Because it is assumed that a reduction in the carbon stocks corresponds to carbon emissions (minus carbon retained in harvested products), carbon emissions via bioenergy production are “accounted for” in these calculations; they do not have to be inserted as a separate item (although they may be reported).

There are many  issues related to these calculations, some of them highly problematical, but they make sense in broad terns except that it’s vague about if and how emissions associated with  burning of imported feedstocks in large bioenergy facilities are accounted for and who does it (italics is mine):

One effect of the 2009 RED and its resulting incentives has been that in some Member States substantial amounts of forest biomass have been imported (especially from USA and Canada) to produce electricity—either in dedicated biomass boilers or in cofiring with coal. This has allowed the importing country to report a reduced level of carbon dioxide emissions because emissions from biomass are not counted at the point of combustion. However, in reality such reported reductions do not equate with a contribution to climate change mitigation; rather, the importing country is taking advantage of the accounting rules and exporting responsibility for reporting emissions to the country that provided the feedstock and is thus responsible for LULUCF reporting. [RED = Renewable Energy Directive, LULUCF = Land use, land-use change and forestry] – p. 25 in Multi-functionality and sustainability in the European Union’s forests 

In other words, even if there is some “accounting” for carbon emissions,  that does NOT mean that the associated  bioenergy production  is carbon neutral as the Europeans assume; you simply can’t tell and in reality most could be far from carbon neutral without any impact on the Europeans’ assumptions.

So I guess a meaningful or helpful answer to PR’s question might have been something like “Emissions associated with bioenergy production in Europe are accounted for in their LULUCF  reporting, but as acknowledged in the EASAC report, there is no LULUCF  reporting on bioenergy generated from imported chips (or pellets). Our LULUCF accounting for Nova Scotia does include  land use changes associated with production of chips for both local consumption and export, and this feeds into the calculation of our net total GHG emissions.

I have absolutely no idea if the italicized part of my hypothetical response to PR has any validity or not. So that’s a question I am going to ask Mr. Hollet!

If NS does its own accounting, I suspect that the LULUCF documentation is too coarse to specifically identify or account for changes in carbon stocks related directly to production of chips for export to the EU. That seems to be the case for the national report – at least there is no reporting of land use changes associated specifically with production of bioenergy internally or for export. So while the emissions associated with burning Canadian chips in Europe are “accounted for” by LULUCF procedures, that does NOT mean that the accounting, even if were detailed would validate the carbon-neutral assumption – we simply don’t know!

To see how Canada does its GHG accounting and the latest numbers, view

UN Climate Change:
National Inventory Submissions 2018
Scroll down to get links to Canada NIR (13 April 2018_, and CRF (13 April 2018). Canada NIR (National Inventory Report) is a zip file, opens to give three PDF docs (pts 1,2,3) Part 1 is a very clear description of the whole accounting process for Canada. CRF=Common reporting Format; these are Excel files.

It’s not EZ reading, but it is comprehensible if you take the time…

In these and numerous other GHG reporting documents I have looked at, I have not found any reporting on land use changes associated specifically with production of forest biomass for bioenergy. Perhaps, the people who do it all could isolate that component, perhaps they could not.

Decisions about cutting or not cutting and about how to cut affect carbon storage on our forested landscape. View Protected Areas in Nova Scotia help to mitigate climate change, clearcuts do not , Post May 26, 2017

In the meantime, industry continues to extol the virtues of forest biomass as ‘green energy’ and to claim it contributes to reduction of GHG emissions.  Government, provincial and federal, and globally plays both sides, on the one hand supporting bioenergy schemes, on the other publishing research showing that many of these schemes are net emitters of GHGs1.

By not specifically addressing Land Use Changes associated with forest bioenergy in GHG accounting, industry and government avoid admitting that many of these schemes are net emitters of GHGs over timeframes  meaningful for climate mitigation.

That all suits industry because what really drives forest biomass, biofuels and the like, at least in Canada, is not concern about climate change but “Forest Sector Transformation”, the effort to find alternatives to markets for pulp and paper 2.

As the planet heats up, pressure will mount for more objectivity on what helps to reduce GHG emissions and what doesn’t; there are already signs that the Europeans are recognizing serious problems with forest bioenergy sourced from North America:

3.4 Biomass growth
The biomass boom [in Europe] is over. Biomass generation grew by only 3% in 2017, the same as in 2016. The growth of 5 Terawatt hours in 2017 is only half the growth observed from 2000-2015 (see figure 18). Half of this biomass growth was in Denmark and the UK; most other countries did not see any growth.

Given concerns over biomass sourcing – and, so often, the combustion of biomass in old, inefficient large coal plants – the slowdown is perhaps a relief. Co-firing in coal power plants is no longer rising, and the pipeline for planned conversion of coal power plants to run on biomass is quite small (Sandbag 2017).

As biomass growth slows, wind and solar alone will drive future renewable growth. This is another reason
to ensure wind and solar deployment accelerates.

SOURCE: Agora Energiewende and Sandbag (2018): The European Power Sector in 2017. State of Affairs and Review of Current Developments.


Drax power station aims to cut biomass gases in new pilot
BBC news May 21, 2018 “The UK’s biggest power station has announced a £400,000 pilot scheme to capture the carbon dioxide produced from burning wood pellets.”
Also: New chemistry enables UK negative carbon dioxide emissions pilot
Andy Extance for, May 24, 2018<

If our Land Use Changes (and those in the U.S.) associated with production of wood chips for export really resulted in significant net consumption of GHGs, why would the Drax station go to the added expense of CO2 removal?

Please take note, Nova Scotia’s new Department of Energy and Mines



1. Examples of research on Forestry/GHG balances by Canadian Government scientists:

Quantifying the biophysical climate change mitigation potential of Canada’s forest sector
by C. E. Smyth et al. 2014. Biogeosciences, 11, 3515–3529
Some bioenergy strategies were found to be effective, while others were not. Additional harvest for bioenergy was counterproductive from a climate change mitigation standpoint, while capturing more harvest residue in place of slash pile burning was highly effective. While some bioenergy options may not contribute to mitigation objectives when displacing emissions from the average energy profile within a region, we emphasize that our coarse-scale analysis could not capture the possibility of significant mitigation benefits through harvests for bioenergy in regions with specific fossil energy use characteristics. More opportunities may be identified if examined at finer spatial scales and if emissions displacement is not determined relative to the average energy profile within a region, for example in the case of remote communities that are not connected to the electricity grid.

The potential of forest biomass as an energy supply for Canada
David Paré et al. 2011. The forestry Chronicle 87: 71-76. “The main objectives of this paper are to give some figures and perspectives on Canadian forest biomass supply with respect to Canada’s energy demand and to examine the potential of using this feedstock for reducing our greenhouse gas (GHG) emissions…The range of estimates listed here indicates that this source of energy is important but that it is still a fraction of our energy demands. The potential of using this biomass to reduce our GHG emissions is strongly dependent, among other factors, on the technological pathways that are used, with direct heat production and combined heat and power (CHP) ranking amongst the best options available. The relative scarcity of the resource behooves us to use it efficiently.”

Range and uncertainties in estimating delays in greenhouse gas mitigation potential of forest bioenergy sourced from Canadian forests
Jérôme Laganière et al., Global Change Biology Bioenergy 2017 (9) 358–36 (published online in 2015)
Biomass feedstock and the type of fossil fuel replaced greatly affect the GHG mitigation potential and timing of forest bioenergy scenarios. The results indicate short to long ranking of parity times for residues < salvaged < green trees and for replacing the less efficient fossil fuels (coal < oil < natural gas). Not surprisingly, bioenergy sourced from harvest residues yielded the fastest atmospheric benefits.
By contrast, using medium and slow growing green trees showed little to no atmospheric benefits over the 100 year period. In northern forests, trees grow slowly and harvested lands usually take many decades to regenerate and regain C levels that are similar to preharvest levels (Seely et al., 2002; Kurz et al., 2013). Furthermore, when the reference forest is assumed to be unharvested in the counterfactual scenario, CO2 may still be taken up from the atmosphere while the land harvested for bioenergy slowly starts to regenerate. Accordingly, C parity time for procuring biomass from living trees takes many decades to be reached. Bernier & ParÈ (2013) obtained a time to C parity of over 90 years for a scenario that used wood chips from boreal tree species to replace oil in heat generation. Other studies also documented multidecadal parity times (or payback times) for bioenergy made from green trees in northern forests (McKechnie et al., 2011; Holtsmark, 2012; Mitchell et al., 2012; Ter Mikaelian et al., 2015). However, using silviculture to increase tree growth rate in the regenerating stand can improve the performance of this feedstock source and generate atmospheric benefits within a shorter time frame.
…Salvaged trees have the potential to generate relatively fast atmospheric benefits, but would require a good tracking system to reduce uncertainty and meet precise time frames. As shown in our analysis, favoring wood chips over pellets and local use over transoceanic export are good options to prioritize in order to reduce the uncertainty period.

2. From Natural resources Canada: Overview of Canada’s forest industry (italicized text mine):

Forest sector transformation
Forest product markets are cyclical, experiencing significant ups and downs over the economic cycle. This constant state of shifting circumstances creates both challenges and opportunities. In recent years, Canada’s forest industry has undergone an especially deep cyclical decline, coupled with structural changes in world markets. In particular, the rise of electronic media has resulted in deep decline for paper-based communications products—including several products (such as newsprint) that have traditionally been critical to the Canadian pulp and paper subsector.

In response to these challenges, the forest industry has begun to transform itself along four distinct lines: market development, operational efficiency, business process change and new product development. One of the most exciting elements of this transformation has been the new and innovative products, materials and services being produced in Canada’s forest sector. These include new building materials, biofuels that can substitute for fossil fuels, and biochemicals that can be used to produce bio-based pharmaceuticals, biodegradable plastics, personal care products and industrial chemicals. Chief among these are cellulosic fibrils and nano-crystalline cellulose—next-generation pulp-based products with the potential to revolutionize the pulp and paper sector.

These and other emerging technologies and business processes offer new ways of generating social, economic and environmental values for Canadians from our abundant forest resource. They generate value from a wider range of forest products and processes than traditional milling and pulping. Whether co-located with an existing establishment or a result of a greenfield investment, these new technologies and business processes increase overall industry productivity: additional revenue streams are available from each log harvested, diversifying product lines to stabilize economic performance and boosting the share of renewable products in the marketplace. These new technologies will also create opportunities for new entrants, enhancing competition and entrepreneurialism in the industry.

Responses to questions posed to Climate Change NS about LULUCF Accounting

As indicated above, I had some questions about LULUCF accounting that I said I would ask of Jason Hollett, Executive Director of Climate Change at Nova Scotia Environment.

The request, July 29, 2018:

Dear Mr. Hollet

Pursuant to your recent correspondence with Peter Ritcie on the topic of GHG emissions associated with forest biomass which I wrote about in a recent blog post at, I have several questions:

– Does your department or NSDNR (now NSLF) do its own LULUCF documentation, or is it all done by the feds?

– Does the LULUCF documentation that applies to this region specifically identify land use changes associated with production of feedstocks for bioenergy locally, and exported?

– What do the figures show? Can we be provided with those figures?

‘Greatly appreciate any comments, which I would share on

– David Patriquin

Response from Mr. Hollett, Aug. 9 at 1:55 p.m

Hi David,

Thanks for reaching out. My colleagues at Lands and Forestry and I have answered the questions you sent along to the best of our ability. I’ve included them below with your original questions for ease of organization. I hope it’s what you’re looking for.

– Does your department or NSDNR (now NSLF) do its own LULUCF documentation, or is it all done by the feds?

LULUCF for the purposes of GHG accounting is led by the federal government, not Nova Scotia Environment. From your blog post, I can see that you have found that source information through Canada’s submission to the UNFCCC.

You are likely familiar with the Department of Lands and Forestry’s Registry of Buyers and forest inventory program, both of which monitor forested land uses (i.e., forest conditions and harvest volumes). You can read about some of the forest conditions and trends in the 2016 State of the Forest Report and subsequent 2017 Update, both of which are available online at: and

Importantly, these latter provincial initiatives provide some of the same types of information that are used to estimate emissions in federal LULUCF accounting. However, ECCC/NRCan have their own methods and data sources for LULUCF accounting. NRCan (CFS) leads the accounting for forests and harvested wood products, ECCC leads for other land sectors. In addition to the ECCC National Inventory Report website referenced in the blog post, you can find more information here:

Additionally, Lands and Forestry created a new position in the Forestry Division this year that is dedicated to forest carbon and climate change modelling and will begin integating forest carbon accounting and forecasting into the forest management planning. The Department of Lands and Forestry also has a representative on the National Forest Sinks Committee, which is working collaboratively to integrate forest carbon accounting between the provincial/territorial and federal levels.

– Does the LULUCF documentation that applies to this region specifically identify land use changes associated with production of feedstocks for bioenergy locally, and exported?

LULUCF accounting has six emissions categories: forest land (a carbon sink), harvested wood products (a carbon source), cropland, grassland, wetlands, and settlements. Harvested wood products are not separated into different categories in the national inventory report. C02 emissions and removals from forests and harvested wood products are reported in the LULUCF sector. The Energy and Waste sectors report CH4 and N20 emissions from biomass combustion and decomposition at the landfill, respectively. For more information on methodologies, see here: https://www.ipccnggip.iges.or.ip/public/2006gl/

– What do the figures show? Can we be provided with those figures?

Currently, the National Inventory Report does not include LULUCF GHG inventory data at the provincial/territorial level. I recommend contacting NRCan if you would like more information. Contact there is Mark Hafer,

All the best,


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