Calforests comments on CPUC biomass resolution

In response to the Governor’s proclamation on tree mortality, on February 5, 2016, the California Public Utilities Commission issued a draft resolution, E-4770, which seeks to authorize biomass procurement in high hazard zones.

Although Calforests agrees with the concept of a resolution to increase biomass energy capacity, the resolution does not go far enough to truly implement the Governor’s emergency proclamation, nor his 2012 Bioenergy Action Plan.  Below is a summary of our comments on the draft resolution.  To view the full text of the letter click here.

California Forest Conditions

California’s forests are overly dense and suffering from their 4th year of extreme drought. This makes them susceptible to natural disturbances such as wildfire and bark beetle infestation.

  • Bark beetle is most severe in the Southern Sierra Nevada Mountains, but has moved north to the Oregon Border, across the Klamath Mountains and down the east side of the Coast to the Mendocino National Forest.
  • Through aerial mapping, the Forest Service estimated in 2014 that 3.3 million trees had died. Mapping in 2015, has estimated more than 29 million dead trees.
  • Since 2001, on average 320,000 acres of National Forest land has burned every year. In 2015, the number of acres burned on National Forest land has jumped to 537,000 acres.
  • The Forest Service estimates 6.4 million tons) in high hazard zones and a total of 41.4 million tons) in the six counties of Madera, Mariposa, Fresno, Tulare, Kern, Tuolumne counties. Calforests estimates that by October 2016, the continuing expansion of insect and disease in the rest of the state will cause an additional 58 million tons of dead trees.
  • Calforests thinks it’s reasonable to assume that 75% of the mortality can be removed in the next 3 years, with the right infrastructure.
  • Removing the widespread tree mortality is a crucial first step toward safeguarding our communities, but a long-term comprehensive approach is needed to create healthier and more resilient forests.

Biomass Energy Infrastructure and Opportunities

  • Wood consumed in a biomass power plant boiler reduces pollutants by 98% when compared to open pile burning.
  • Biomass power costs more than other renewable energy sources, yet provides substantial environmental benefits that Calforests feels should be taken into account when establishing incentives and contracts.
  • Evidence suggest that there is a need for an additional 235 MW of additional operating capacity over and above current 563 MW operating capacity – totaling 798 MW of biomass energy capacity in order to deal with tree mortality. This would support the Governor’s 2012 Biomass Action Plan which calls for an increase to about 900 MW.
  • 7 biomass plants (210.8MW) have expiring contracts in the next 2-7 months and another 13 biomass powerplants (235.5 MW) are idle due to expired contracts.
  • All of the existing and idle biomass plants are needed to remove the large amount of tree mortality that is subject to the Emergency Proclamation.
  • Bilateral contracting procedures and RAM-type solicitations are critical to return the biomass power plant industry to a fully functioning capacity that can handle the current tree mortality.
  • The requirement that utilities use 80% of the fuel source from high hazard zones should be lowered to 29%, given that the additional capacity (235 MW) is 29% of total capacity (798 MW).
  • Any requirement of a percentage of the fuel source coming from high hazard zones will prove to be problematic because of the substantial cost of removal and transport.
  • According to the Governor’s Emergency Proclamation, the process to secure new contracts should begin by May 1, 2016, not July 1.
  • The minimum biomass energy target for utilities to procure totals 30 MW. Calforests believes that the IOU contracts should total the amount of existing biomass plants in need of new contracts, which would be 446 MW.
  • Each contract should be able to accommodate the largest 58 MW facility instead of the minimum 20 currently proposed.

State Policy is Needed

  • Without state policy, the biomass power industry will continue to shrink at a time when we need it most to implement the Governor’s Emergency Proclamation; RPS goals; AB 32; and his Bioenergy Action Plan.
  • State policy is needed to utilize some of the monetary part of the environmental benefit to incentivize biomass power and charge it back to the rate payer or utilize cap-and-trade revenue.
  • The resolution needs to provide incentives and set strict requirements for contract procurements