Petition to the Securities and Exchange Commission (SEC) to issue guidance underregulation S-K regarding how companies should disclose information about emissions ofgreenhouse gases from manufacturing and use of biomass-based fuels and products
Feb 27, 2019. Detailed, referenced document. “Re: Request for guidance to ensure that issuers manufacturing and using biomass-based fuels and products engage in comparable disclosures regarding greenhouse gas emissions that areinformative to investors and not materially misleading.” Cites issues with biochar amongst the financial scams that have occurred. Popular account: Accurate Reporting Of Biofuels’ Impact Needed, In the Financial Advisor, Feb 27, 2019. “The Partnership for Policy Integrity, an environmental group based in Pelham, Mass., which focuses on the impact of production and use of bio-fuels, filed a petition with the Securities and Exchange Commission Wednesday asking for guidelines on reporting on the environmental impact of substitutes for fossil fuels.”
Canada’s forests actually emit more carbon than they absorb — despite what you’ve heard on Facebook
Robson Fletcher · CBC News · Posted: Feb 12, 2019 “Our managed forest land hasn’t been a net carbon sink since 2001” Cleary written description of GHG deception at the highest levels. It fools everyone except the planet.
Better carbon accounting in European forests informed by Canadian model
http://theclimateexaminer.ca June 13, 2018. “The EU is implementing a new carbon accounting approach for its forests that improves the scientific rigour of previous methods.” The article references: Science-based approach for credible accounting of mitigation in managed forests, G. Grassi et al.,in Carbon Balance and Management 2018 13:8 “The credibility and effectiveness of country climate targets under the Paris Agreement requires that, in all greenhouse gas (GHG) sectors, the accounted mitigation outcomes reflect genuine deviations from the type and magnitude of activities generating emissions in the base year or baseline. This is challenging for the forestry sector, as the future net emissions can change irrespective of actual management activities, because of age-related stand dynamics resulting from past management and natural disturbances. The solution implemented under the Kyoto Protocol (2013–2020) was accounting mitigation as deviation from a projected (forward-looking) “forest reference level”, which considered the age-related dynamics but also allowed including the assumed future implementation of approved policies. This caused controversies, as unverifiable counterfactual scenarios with inflated future harvest could lead to credits where no change in management has actually occurred, or conversely, failing to reflect in the accounts a policy-driven increase in net emissions. Instead, here we describe an approach to set reference levels based on the projected continuation of documented historical forest.”
The European Union just made bioenergy worse for biodiversity
CJA Bradshaw et al. on Conservation Bytes Aug 21, 2018. Related scientific paper: Revised European Union renewable-energy policies erode nature protection. Klaus Josef Hennenberg et al., 2018 Nature Ecology & Evolution Volume 2, pages 1519–1520.
United Nations Climate Change Convention: The Paris Agreement
“The Paris Agreement’s aim is to strengthen the global response to the threat of climate change by keeping a global temperature rise this century well below 2 degrees Celsius above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5 degrees Celsius. Additionally, the agreement aims to strengthen the ability of countries to deal with the impacts of climate change. To reach these ambitious goals, appropriate financial flows, a new technology framework and an enhanced capacity building framework will be put in place, thus supporting action by developing countries and the most vulnerable countries, in line with their own national objectives. The Agreement also provides for enhanced transparency of action and support through a more robust transparency framework. There will be a global stocktake every 5 years to assess the collective progress towards achieving the purpose of the Agreement and to inform further individual actions by Parties.” View Summary of the Paris Agreement
Government of Canada: Greenhouse gas sources and sinks: executive summary
UN Climate Change: National Inventory Submissions 2018
Critical documments. 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.
A Blueprint for Forest Carbon Science in Canada 2012-2020
NRC, “Secured” PDF document, meaning you cannot copy the text.
Forest Carbon sequestration and Avoided Emissions
Chris Henschel and Tim Gray for Ivey Foundation 2007. A bit out of date, but a very clear description of a lot of the carbon science. “The overall carbon balance of Canada’s forests is equal to the Net Primary Productivity of all forests (NPP = carbon uptake due to photosynthesis – carbon loss due to plant and soil respiration) minus the loss of carbon due to disturbances such as fire and insects. In peatlands, the carbon balance results from emissions of methane balanced by removal of carbon from the atmosphere. Two major, independent modelling exercises of Canada’s forest carbon balance demonstrate that the source/sink balance of Canada’s managed forests and Canada’s entire forest landbase fluctuates over time. The CFS-CBM3 model used by the Canadian Forest Service estimates that Canada’s managed forest has been a sink for most of the past 70 years. However, the model estimates that it has been a source for at least four of the fifteen years between 1990 and 2005 and also estimates a 90% chance that Canada’s managed forest will be a net source during the first Kyoto commitment period (2008-2012). The source/sink balance of Canada’s forests is driven largely by forces beyond practical human control: natural disturbances and the current age class structure. The recent trend towards a more negative carbon balance is thought to be the result of a recent surge in fire and insect disturbance rates combined with increased temperatures….The scientific literature clearly demonstrates that managed forests [~65% of Canada’s forests in 2016] store less carbon than natural forests. One important reason for this difference is that managed forests contain less old forests. This fact results from the replacement of natural disturbance with harvest disturbance. Harvest rotation ages are generally shorter than the natural disturbance interval. This means that forest stands are not allowed to reach as old an age before they are disturbed, which represents an interruption in the process of forest stands accumulating carbon over time. The difference in carbon storage between managed and natural forests could be reduced if rotation ages were changed to match natural disturbance intervals but natural forests would still possess more old forest in systems where fire is the dominant natural disturbance because fires do not target mature stands as forest harvest does; fire is relatively age-independent, and burns stands of all ages, resulting in a proportion of the natural forest that ages well beyond the natural disturbance interval.18 The magnitude of the carbon loss due to conversion depends on the maximum storage capacity of the system (e.g. boreal vs. temperate) and the difference between the age of the old growth state in that system.19 Conversion of natural to managed forests in regions with shorter fire return intervalwill result in less carbon loss.”
View also Government of Canada> Natural Resources Forests >Forest Topics > Climate Change
Carbon accounting, Forest Carbon etc
Also view: Government of Canada> Natural Resources Forests >Forest Topics > State of Canada’s forests report > How does disturbance shape Canada’s forests? >Indicator: Carbon emissions and removals
Emissions/removals for Canada’s Managed Forests
European CommissionEnergy, Climate change, EnvironmentClimate Action: Land use and forestry regulation for 2021-2030
“Under EU legislation adopted in May 2018, EU Member States have to ensure that greenhouse gas emissions from land use, land use change or forestry are offset by at least an equivalent removal of CO₂ from the atmosphere in the period 2021 to 2030…Emissions of biomass used in energy will be recorded and accounted towards each Member State’s 2030 climate commitments, through the correct application of accounting in LULUCF…This breakthrough addresses the earlier broad criticism that emissions from biomass in energy production were not accounted for under previous EU law.”
What issues need to be addressed in the RED II draft to ensure environmental integrity and net climate benefit of bioenergy use?
German Environment Agency Scientific Opinion Paper 04 January 2018. “With this scientific opinion paper, we aim to raise awareness for some issues leading to insufficient GHG savings and potentially causing a gap between two climate and energy legislative frameworks of the European Union: the recast of the Renewable Energy Directive (RED II) and the Land Use, Land Use Change and Forestry Regulation (LULUCF Regulation). There is a risk that bioenergy, used to fulfill the renewable energy target may contribute to GHG savings only to a limited extent, but at the same time lead to intensification of forest management and therefore reduce the carbon sink potential of forests. Yet the impact on forest carbon sinks is currently not properly addressed in either draft legislation, meaning an increase in net-emissions caused by bioenergy will not necessarily require compensation through increased mitigation efforts in other sectors…In order to prevent incentivizing unsustainable bioenergy use and reduction of forest carbon sinks, which would be counterproductive to the overall goal of RED II and EU Climate Policy in general, we consider it necessary to address the issues raised here.”
Science-based approach for credible accounting of mitigation in managed forests
Giacomo Grassi et al.,2018. Carbon Balance and Management 2018 Dec; 13: 8.”The credibility and effectiveness of country climate targets under the Paris Agreement requires that, in all greenhouse gas (GHG) sectors, the accounted mitigation outcomes reflect genuine deviations from the type and magnitude of activities generating emissions in the base year or baseline. This is challenging for the forestry sector, as the future net emissions can change irrespective of actual management activities, because of age-related stand dynamics resulting from past management and natural disturbances.”
Carbon impacts of biomass consumed in the EU Supplementary analysis and interpretation for the European Climate Foundation
Robert Matthews et al,2018. Project report for ECF, May 2018. “Unless appropriate policy measures are taken to support sustainable bioenergy supply
(in terms of impacts on GHG emissions), particularly in the case of forest bioenergy supply, a significant increase in bioenergy use in the EU is likely to lead to a net increase, rather than decrease, in GHG emissions being contributed from bioenergy sources.
GHG mitigation scenarios for major emitting countries: 2017 update. Supporting information on emission projections
Takeshi Kuramochi et al., 2017.Project number 15032. NewClimate Institute, PBI Netherlands Environmental Assessment Agency, Science for Global Insight. Project funded by EU
Impact of the global forest industry on atmospheric greenhouse gases
Reid Miner FAO FORESTRY PAPER 159 (2010)
This book examines the influence of the forest products (roundwood, processed wood products and pulp and paper) value chain on atmospheric greenhouse gases.
Quantifying the biophysical climate change mitigation potential of Canada’s forest sector
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.”
Greenhouse Gas Protocol
GHG Protocol. Provides Calculation Tools/Worksheets, related info, e.g. view History of GHG Protocol, FAQs, more. “GHG Protocol establishes comprehensive global standardized frameworks to measure and manage greenhouse gas (GHG) emissions from private and public sector operations, value chains and mitigation actions. Building on a 20-year partnership between World Resources Institute (WRI) and the World Business Council for Sustainable Development (WBCSD), GHG Protocol works with governments, industry associations, NGOs, businesses and other organizations.”
Measuring climate impact of forests management — a groundbreaking approach
EUROPEAN COMMISSION JOINT RESEARCH CENTRE 2-AUG-2018 “A JRC-led group of forestry research experts has developed a rigorous new fact-based carbon accounting system that reflects how forest management practices can help mitigate greenhouse gas (GHG) emissions.” The article references this scientific paper:
Science-based approach for credible accounting of mitigation in managed forests
Giacomo Grassi et al., 2018. Carbon Balance and Management 2018 13:8
The Burning Question: Does Forest Bioenergy Reduce Carbon Emissions? A Review of Common Misconceptions about Forest Carbon Accounting
Michael T. Ter-Mikaelian et al., 2015 Journal of Forestry, Volume 113, Issue 1, 1 January 2015, Pages 57–68. “Critical errors exist in some methodologies applied to evaluate the effects of using forest biomass for bioenergy on atmospheric greenhouse gas emissions. The most common error is failing to consider the fate of forest carbon stocks in the absence of demand for bioenergy. Without this demand, forests will either continue to grow or will be harvested for other wood products. Our goal is to illustrate why correct accounting requires that the difference in stored forest carbon between harvest and no-harvest scenarios be accounted for when forest biomass is used for bioenergy. Among the flawed methodologies evaluated in this review, we address the rationale for accounting for the fate of forest carbon in the absence of demand for bioenergy for forests harvested on a sustained yield basis. We also discuss why the same accounting principles apply to individual stands and forest landscapes.” However, Ter-Mikaelian is still in favour of bioenergy even if it increases emissions in the short to intermediate term – see comments at https://forestpolicypub.com/2018/07/09/exploring-the-climate-science-policy-jungle-i-negative-emissions-and-forests/ and in the paper above, p 65.
Climate, economic, and environmental impacts of producing wood for bioenergy
Richard Birdsey et al 2018 Environ. Res. Lett. 13 050201 “Increasing combustion of woody biomass for electricity has raised concerns and produced conflicting statements about impacts on atmospheric greenhouse gas (GHG) concentrations, climate, and other forest values such as timber supply and biodiversity. The purposes of this concise review of current literature are to (1) examine impacts on net GHG emissions and climate from increasing bioenergy production from forests and exporting wood pellets to Europe from North America, (2) develop a set of science-based recommendations about the circumstances that would result in GHG reductions or increases in the atmosphere, and (3) identify economic and environmental impacts of increasing bioenergy use of forests. We find that increasing bioenergy production and pellet exports often increase net emissions of GHGs for decades or longer, depending on source of feedstock and its alternate fate, time horizon of analysis, energy emissions associated with the supply chain and fuel substitution, and impacts on carbon cycling of forest ecosystems. Alternative uses of roundwood often offer larger reductions in GHGs, in particular long-lived wood products that store carbon for longer periods of time and can achieve greater substitution benefits than bioenergy. Other effects of using wood for bioenergy may be considerable including induced land-use change, changes in supplies of wood and other materials for construction, albedo and non-radiative effects of land-cover change on climate, and long-term impacts on soil productivity. Changes in biodiversity and other ecosystem attributes may be strongly affected by increasing biofuel production, depending on source of material and the projected scale of biofuel production increases.”
Climate Action Tracker
“The Climate Action Tracker (CAT) is an independent scientific analysis produced by three research organisations tracking climate action since 2009. We track progress towards the globally agreed aim of holding warming well below 2°C, and pursuing efforts to limit warming to 1.5°C.”
Natural resources Canada: Indicator: Forest carbon emissions and removals
“In 2015, forest management activities in Canada’s managed forest, such as harvesting and regeneration, as well as the use and disposal of harvested wood products created a net sink of about 26 Mt CO2e. Natural disturbances in Canada’s managed forest resulted in emissions of about 247 Mt CO2e in 2015. This was mainly due to forest fires burning nearly 2 million hectares, the largest area burned in Canada’s managed forest since 1995. The total net emissions and removals from Canada’s managed forest sector, taking into account both human activities and natural disturbances, totalled about 221 Mt CO2e in 2015… In previous years, estimates of carbon emissions and removals from Canada’s managed forest displayed large year-over-year variability because natural disturbances, especially forest fires, masked the subtler impacts of human forest management activities.To this end, the Intergovernmental Panel on Climate Change (IPCC) recommended that countries develop new approaches to separate emissions and removals caused by human activities from emissions and removals caused by natural disturbances. This makes it possible to detect trends in emissions attributable to forest management.” Attached Notes provide more info on the accounting procedures.
Standards followed by Nova Scotia
From Mr. Jason Hollet in response on May 7, 2018 to a request to give me the references (names of documents etc) for “nationally and internationally accepted accounting standards for GHG emissions measurement as well as for the classification of biomass as a renewable energy source” (citing Mr. Hollet):
For reporting biomass emissions, we follow the approach described in Environment and Climate Change Canada’s Greenhouse Gas Reporting Program (GHGRP) and their National Inventory Report (NIR), which in turn follows guidance from the International Panel on Climate Change (IPCC).
For energy produced from biomass, this means N2O and CH4 emissions are required to be reported and included in the inventory. CO2 emissions must be reported, but is not considered part of the GHG emission inventory.
Below are links with the information as requested.
Nova Scotia’s provincial GHG inventory is prepared by Environment and Climate Change Canada. (reference to IPCC at the bottom, along with link):
ECCC also require facilities report their GHG emissions annually- Greenhouse Gas Reporting Program. Here is a recently released technical guidance document.
Nova Scotia also requires GHG reporting (new this year). Our QRV Standard is based on the Western Climate Initiative reporting methodologies.
IPCC Taskforce on GHG Inventories (see Chapter 2, section 2.33):
See also: Nova Scotia forests, forestry and GHGs 2: Who accounts for the EU’s emissions from bioenergy generated from imported chips? including the UPDATE Aug 10, 2018: Responses to questions posed to Climate Change NS about LULUCF Accounting: I had some questions about LULUCF accounting that I asked Jason Hollett, Executive Director of Climate Change at Nova Scotia Environment. View Questions and Answers
Renewable Electricity Plan A path to good jobs, stable prices, and a cleaner environment.
NS dept Energy, April 2010. 32 page doc with procurement requirement for biomass, cautions on biomass etc “Nova Scotia’s Renewable Electricity Plan is a program to move Nova Scotia away from carbon-based electricity towards greener, more local sources. The plan set renewable electricity generation targets of 25% by 2015 and 40% by 2020. In 2015, almost 27% of Nova Scotia’s electricity was supplied by renewable energy sources, like wind, tidal, biomass, and hydro, and we are on track to reach 40% by 2020.”- see https://climatechange.novascotia.ca/what-ns-is-doing
Climate Change Nova Scotia > Regulations
“New regulations are now in effect for reporting greenhouse gas (GHG) emissions. Collecting and publicly reporting GHG emissions supports the implementation of our cap and trade program which will help continue reducing emissions in Nova Scotia. Thresholds set in these regulations will ensure that most of the GHG emissions in the province are captured in the cap and trade program. The regulations took effect February 15, 2018. They apply to GHG emissions released from specified GHG activities that are carried out on or after January 1, 2017.” Links to regulations:
– Quantification, Reporting, and Verification of Greenhouse Gas Emissions Regulations Note: “Contents of all GHG reports…24 All GHG reports must contain all of the following information: …(g) the total carbon dioxide emissions from the combustion of biomass during the activities with respect to which the report is prepared;… (h) a description of the type of biomass used and the quantity;
– Standards for Quantification, Reporting, and Verification of Greenhouse Gas Emissions (2.8 MB PDF)
Note: ““Net emissions” means the total of GHG emissions from all sources for which calculation methods are documented in this Standard less the carbon dioxide emissions from the combustion of biomass. Net emissions are used to establish the threshold for calculating and reporting annual GHG emissions to the Government of Nova Scotia. ”
Biomass Sustainability Analysis An assessment of Ontario-sourced forest-based biomass for electricity generation
Mike Kennedy et al. 2011 Pembina Institute
“Harvesting of forest biomass for electricity production can be done in such a way as to not systematically decrease forest carbon stores over time (Figure 7). This outcome is consistent with the UNFCCC definition of renewable biomass.”