Advocating for Forests in Oregon’s Climate Policy
Oregon has begun a new study on how a cap and trade program could help meet their climate targets. We support these efforts and suggest that forests play a more central role. View our public comments to Oregon’s Department of Environmental Quality:
June 23, 2016
Colin McConnaha
Oregon Department of Environmental Quality
811 SW 6th Ave. Portland Oregon 97204
Re: DEQ’s study of a Market Approach to Reducing Greenhouse Gas Emissions
Dear Mr. McConnaha,
Thank you for this opportunity to comment on the “Market Mechanism for Reducing Greenhouse Gas Emissions in Oregon” draft outline (outline). Our suggestions are drawn from both our deep experience in climate policy and markets as well as from our long-standing work in Oregon where we manage and hold working forest conservation easements and are forest landowners ourselves. We have been involved with the WCI since inception as well as with California’s AB 32, cap and trade program, and initial AB 32 forest offset protocols. We’ve also developed forest carbon offset projects in multiple states and been engaged in a number of voluntary and compliance offset transactions. Our comments will be largely focused on the forest sector, as forests are both a central part of the emissions problem and a key part of emissions reductions and sequestration solutions.
Overall, we encourage a market-based approach for Oregon as part of the WCI. We also urge you to more fully consider and integrate forests, and other natural and working lands as feasible, in Oregon’s climate policy. We also note the cost effectiveness of using forests within a cap and trade system, both for offsets and as a key focus of investments. In this latter case, Oregon’s forests are highly productive, core to sustaining a rural economy with economically disadvantaged communities, and enormously cost effective. (Experience in the investments of auction proceeds in California show forest-based investments are one of the most cost-effective tools to lower net emissions.)[1]
Natural lands, especially forests, are a significant source of emissions in Oregon as well as carbon sequestration. We recommend that the study includes a section on forests, and as feasible, other natural lands, in your greenhouse gas (GHG) inventory. We also urge that, from the outset, you take into account the carbon transfers from the forest sector to energy and manufacturing, as both forest products and energy from wood waste are an important part of the carbon flux. Particular care should be taken in using empirical data for the inventory, rather than basing it on assumptions when considering emissions from forests, forest fires, and woody biomass energy. (A number of the world’s top experts on these subjects are in Oregon, at OSU.) It is essential to have a CO2 inventory and accounting system in our records that match the actual atmospheric impacts of our actions.
Have a complete GHG inventory, including the forest sector
The outline could be improved by including an assessment of a GHG inventory under section VII: Program design consideration for linking and meeting Oregon’s GHG goals. A complete inventory of GHG emissions is a cornerstone to measuring the success of a market system. Regardless of which elements of the inventory are ultimately included under the cap and trade system, it is critical to have the data to understand the state’s total effect on the atmosphere. This will also aid in the evaluation of related programs that affect the uncapped sectors.
It is only by knowing the baseline of forest sector emissions that the state can really evaluate the impact of offset projects in the uncapped sectors. Without that, there is simply an assumption of net gains in these sectors. A further aspect to include from the inception of a forest sector inventory is the background emissions from normal forest function, which contains periodic fire. As we see in the outbreak of multiple fires over the past years, fire suppression and past management regimes have led to major fuel overloads that lead to catastrophic fires. However, the total emissions from such uncharacteristic fires are still well within the natural range of fire emissions[2]; in fact, the west as a whole has yet to make up for the “fire deficit” caused by fire suppression and past management.[3] Applying an averaged 100-year fire cycle baseline attributed in decadal increments within the inventory will ensure the forest sector emissions are not distorted.
Oregon’s GHG monitoring currently does not account for land use changes and other carbon fluxes from natural lands. Including a complete inventory is necessary as forest conversion presents a significant source of emissions. Between 1974 and 2014, Oregon lost 704,000 acres to human development.[4] Ninety-five percent of this land loss occurred on private lands.[5]
In recent years (2001-2011), Oregon lost 263,000 acres to human development[6] –that’s equivalent to losing an area the size of Eugene each year. If we estimate that 93 tons of carbon (341 tons of CO2) are stored in each acre of forest land,[7],[8] then this would amount to direct emissions of about 9 MMTCO2 for each year between 2001 and 2010 from land conversion. For comparison, Oregon’s total inventoried GHG emissions amounted to 102.9 MMTCO2 in 2010.[9]
Further, many acres of forest had already been converted or heavily logged by the 1970’s. Since 1850, 8% of the forest land in the state has been lost[10], amounting to over 2.5 million acres. Between 1953 and 1977 alone, over a million acres of forest land were lost in the pacific northwest.[11] The emissions from logging in Oregon and Washington between 1900-1992 amounted to over 6,000 MMTCO2.[12],[13] Yet, only 10% of land in Oregon is permanently prevented from conversion. [14]
The opportunity to reabsorb those emissions is also a key attribute of forests. Oregon has the most carbon stored in forests of any of the contiguous states, with 2,555 million metric tons of carbon.[15]
Ensuring that Oregon’s forest land and other natural resources are harnessed to provide a net climate benefit relies on the establishment of a natural resources carbon inventory. There are well-established protocols for accounting for GHG inventories on natural lands. For instance, the IPCC has developed guidelines[16] and California recently released an updated methodology for their natural lands accounting.[17]
Reinvesting auction revenues from a cap and trade system can help disadvantaged populations and rural communities
As of the 2010 census, 19% of Oregon’s population lived in rural areas.[18] While unemployment statewide is down to 4.5% as of May 2016,[19] in some rural areas, the unemployment rate is as high as 8.2%.[20] Employment in the forest industry can be significant in rural areas – in 2013, Oregon’s forest sector employed more than 58,000 people and paid a higher wage than the statewide average.[21] The forest sector is the second largest employer, responsible for 11% of Oregon’s economic output.[22] However, employment in the forest sector has generally declined over the past 20 years.[23]
Reinvestment of auction revenues in restoring and conserving managed forestland could have economic benefits for rural communities. A nation-wide study found that investment in forests created more jobs per dollar invested than many other industries, including road building and fossil fuels.[24] Research on investments made by the Oregon Watershed Enhancement Board found that for every million dollars invested in forestry and watershed restoration, between 15 and 24 jobs were created.[25]
These investments in forests are not only good for rural communities – they are also quite effective in reducing GHG emissions. A recent California Legislative Analysis Office report showed that investments in forestry topped the list of cost-effective GGRF investments – costing only $4/ ton CO2 reduced.[26]
The reinvestment in natural lands with auction revenues supports rural economies and helps reduce GHG emissions. It also provides countless other co-benefits from restoring habitats that help wildlife adapt to climate change to improving water security.
Carbon offsets create incentives for forest conservation
Like reinvesting auction revenue in restoring and sustaining working forests, using carbon offsets has many of the same benefits – for rural communities, wildlife, and carbon storage. Carbon offsets reduce the cost of program implementation, while creating incentives for forest conservation. Assigning a monetary value to the carbon benefits of forests prompts landowners to let their forest stands grow older, reforest former forest lands, and protect lands from conversion to development.
The forest offset protocols and system that California established is now in use on over 2 million acres in 30 states[27], and may also be used internationally under the REDD program. It is worth your consideration as part of the market study.
Thoughtful accounting of emissions related to woody biomass energy
Woody-based biomass energy can be an important source of renewable energy and utilize materials derived from thinning and restoration activities in forests. This could be a very helpful tool in restoring forest health, especially for Oregon’s eastside forests. That said, this should be accompanied by investments in improving biomass energy generation efficiency and clean technology, and, perhaps most importantly, a good accounting system that tracks emissions from harvest through combustion. Assumptions that thinning automatically reduces a specific amount of potential emissions from avoided fire have not to date been supported by empirical evidence. An accurate account of the emissions from biomass facilities – with a scientific basis for the amount actually offset by forests – will help incentivize greener technology and be more accurate from the atmosphere’s perspective.
We appreciate this opportunity to provide thoughts about a market mechanism for reducing Oregon’s GHG emissions. We hope that more thoroughly incorporating natural lands at this early stage of the study will help ensure that they can be an asset for Oregon’s fight against climate change instead of a liability. Please feel free to reach out if we can elaborate on these comments or help with other aspects of the study as it relates to forests and natural lands.
Sincerely,
Laurie Wayburn
President of Pacific Forest Trust
References:
[1] http://www.lao.ca.gov/Publications/Report/3445
[2] Hanson, C. 2010. The Myth of “Catastrophic” Wildfire: A New Ecological Paradigm of Forest Health. John Muir Project Technical Report 1. John Muir Project of Earth Island Institute, Cedar Ridge, California.
[3] Marlon, J.R., Bartlein, P.J., Gavin, D.G., Long, C.J., Anderson, R.S., Briles, C.E., Brown, K.J., Colombaroli, D., Hallett, D.J., Power, M.J., Scharf, E.A., Walsh, M.K., 2012. Long-term perspective on wildfires in the western USA. PNAS 109, E535–E543. doi:10.1073/pnas.1112839109
[4] Gary, A., Hubner, D., Lettman, G., McKay, N., and Thompson, J. 2016. Forests, Farms & People: Land Use Change on Non-Federal Land in Oregon, 1974-2014. Oregon Department of Forestry. Salem, Oregon. Available at: http://hdl.handle.net/1957/58941
[5] Gary, A., Hubner, D., Lettman, G., McKay, N., and Thompson, J. 2016. Forests, Farms & People: Land Use Change on Non-Federal Land in Oregon, 1974-2014. Oregon Department of Forestry. Salem, Oregon. Available at: http://hdl.handle.net/1957/58941
[6] https://www.disappearingwest.org/
[7] Wayburn, L.A., Franklin, J.F., Gordon, J.C., Binkley, C.S., Mladenoff, D.J., and Christensen, N.L. 2000. Forest Carbon in the United States: Opportunities & Options for Private Lands. The Pacific Forest Trust, San Francisco, CA. Available at: https://www.pacificforest.org/forest-carbon-in-the-united-states/
[8] USDA. New Data Highlights Role of Forests in Fight Against Climate Change. Available at: http://www.usda.gov/wps/portal/usda/usdamediafb?contentid=2010/10/0532.xml
[9] http://www.oregon.gov/deq/AQ/Documents/OregonGHGinventory07_17_13FINAL.pdf
[10] Oregon Forest Resource Institute. 2009. Oregon Forest Facts and Figures: 2009. Available at: http://library.state.or.us/repository/2013/201305161432344/2009.pdf
[11] Alig, R.J., Plantinga, A.J., Ahn, S.E. & Kline, J.D. 2003, “Land use changes involving forestry in the United States: 1952 to 1997, with projections to 2050”, General Technical Reports of the US Department of Agriculture, Forest Service, no. 587, pp. 1-77.
[12] Harmon, M.E., Harmon, J.M., Ferrell, W.K., and Brooks, D. 1996. Modeling carbon stores in Oregon and Washington forest products: 1900-1992. Climatic Change 33: 521-550.
[13] Wayburn, L.A., Franklin, J.F., Gordon, J.C., Binkley, C.S., Mladenoff, D.J., and Christensen, N.L. 2000. Forest Carbon in the United States: Opportunities & Options for Private Lands. The Pacific Forest Trust, San Francisco, CA. Available at: https://www.pacificforest.org/forest-carbon-in-the-united-states/
[14] https://www.disappearingwest.org/
[15] USDA Forest Service, Forest Inventory and Analysis Program. 2014. Available at: http://www.fia.fs.fed.us/Forest%20Carbon/methods/docs/2014/Total%20forest%20carbon20140721.xlsx
[16] http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol4.html
[17] http://arb.ca.gov/cc/inventory/sectors/forest/forest.htm
[18] https://www.census.gov/geo/reference/ua/urban-rural-2010.html
[19] http://www.bls.gov/lau/#cntyaa
[20] http://www.opb.org/news/article/oregons-rural-unemployment-rates-are-higher-than-in-cities-/
[21] https://www.qualityinfo.org/-/a-comprehensive-estimate-of-oregon-s-forest-sector-employment
[22] https://www.oregon.gov/LCD/pages/forlandprot.aspx
[23] https://oregoneconomicanalysis.com/2013/05/28/timber-counties/
[24] Garrett-Peltier, Heidi and Pollin, Robert. 2010. University of Massachusetts Political Economy and Research Institute. As cited in (http://grist.org/article/2010-02-01-the-jobs-are-in-the-trees/). Infrastructure multipliers and assumptions are presented in “How Infrastructure Investments Support the U.S. Economy: Employment, Productivity and Growth,” Political Economy Research Institute, January 2009. (http://www.peri.umass.edu/236/hash/efc9f7456a/publication/333/).
[25] Nielsen-Pincus, Max and Moseley, Cassandra. 2010. Economic and Employment Impacts of Forest and Watershed Restoration in Oregon. Ecosystem Workforce Program, Working Paper Number 24. University of Oregon.
[26] http://www.lao.ca.gov/Publications/Report/3445
[27] Data on ARB registered projects available at: http://database.v-c-s.org/VCS_OPR, http://www.arb.ca.gov/cc/capandtrade/offsets/offsets.htm, and https://acr2.apx.com/myModule/rpt/myrpt.asp?r=111