The Science that is being ignored by the “biomass” project

Previously logged areas burnt with such ferocity that residents barely had time to escape…. “At this point, anyone––who is still promoting logging as “fuel reduction”, and saying the problem is in our forests, or a lack of firefighting resources or denying the fact that weather and climate change are the dominant drivers of fire behavior – or not acknowledging the fact that logging is a substantial
additional contributor to increased fire spread and intensity, is really just putting people at greater risk.”


New threat to California’s forest and rivers

I am sending you due to your interest and experience in forestry, fish, and
wildlife values. Please consider the potential effects and outcomes related to
forest management projects (discussed –below in this document) that are
supported by California Resource Agencies. These projects will have long
term effects on forest health and productivity, water yield, hydrology, and
water storage and delivery. These projects are to encompass 7 million acres
(9 Counties) in the northeastern sector of California. These projects will be
templates for future management on all forestlands in California.
Please note that these closely related projects are being pushed by wildfire
concerns. However, there are business models associated with the wildfire
concerns that are questionable and beg for consideration and oversight.

There are a number of closely related programs:

Forest Thinning, for fuels management – related to a business model of
low value wood product to be removed from the forest and “utilized”
for biomass electrical generation and/or various value added wood
1. Use of Emergency Regulations allowed for under the Forest Practice
Rules – allowing for fuels and tree removal without environment review
or controls
2. The goal for targeted area water yield from increased runoff as a result
of forest thinning to ultimately fill a raised Lake Shasta and supply
SoCal via the Delta Tunnel(s).

3. Forest thinning with removal of ‘low value’ wood product to be
‘utilized’ for biomass burning for electrical generation and other wood
product. Wholesale removal of biomass can have negative effects on
forest function and values (productivity, ecological, hydrology, water
quality and fish and wildlife).
4. There is a new paradigm for Federal forest lands (19 million acres – see
forest stats at the bottom) – with a new State/Federal MOU supporting
thinning (and other operations) on Federal forest lands.
5.There is a new Bill – S 4431 Wildfire and Public Safety Act of 2020,
Feinstein, that will support forest thinning and subsidize biomass


Our forests are in trouble. They have been in trouble for a long time.
Currently the forest mass in California is about 25% of its original volume.
This condition is linked to loss of forest productivity, and to diminished fish,
wildlife, biotic, and carbon storage outcomes (stored carbon in forest biomass
and soil is a buffer to climate change).

Along with the diminished productive capacity there are prevailing conditions
of forested areas that are overstocked with small stems ( thick regeneration
after harvest, and brushy undergrowth – that are fuel ladder that can support
intense fire). These conditions are a result of historic forest mismanagement
– e.g. fire suppression, failure to thin after harvesting.

Their exists an argument for thinning (some scientists disagree and indicate
that if left alone the situation will resolve itself).

Thinning objectives can be accomplished by: controlled burning or by
mechanical operations. Mechanical operations may include removal of
material from the forest floor, chipping, chipping and leaving the material,
and knocking it down and leaving it on the ground to decompose.

Note: The science on effects of thinning and fire severity is not conclusive.
Will thinning prevent wildfire? (no), Will thinning reduce wildfire severity
(possibly – but not always), Will road construction for access to accomplish
thinning, and related disturbance from thinning activity have negative effects
on forest productivity, fish, wildflife, and water quality values? (very likely),
Will thinning provide increased water yield ?(unlikely). Please review links
for scientific articles.

These (above noted) activities, if accomplished properly, and within the rules
(Forest Practice Rules, Water Code, and Fish and Game Code) can be
effective in building, or rebuilding, and resilient and productive forest. The
rules must be followed and there must be regulatory supervision.

Note: The Forest Practice Rules have been determined to not be fully
protective of Water Quality and Wildlife values. [See: Independent Scientific
Review Panel Report, Dunne Report, and NOAA/EPA CZARA findings –
links below].
An outcome of thinning does not equate to ‘forest raking’ or ‘cleaning’ –
removal of all material (wood, wood product, trees, or forest debris) from the
forest floor, including larger trees. Wood on the forest floor, or masticated
brush, and larger trees are far less subject to fueling wildfire. (this material
decays rapidly when on the ground and does not really support catastrophic

SeeDisentangling Effects of Forest Harvest on Long-term Hydrologic and
Sediment Dynamics, Western Cascades, Oregon. Mohammad Safeeq, Gordon
E.Grant, Sarah L.Lewis, Shannon K.Hayes, and The High Costs and Low Benefits
of Attempting to Increase Water Yield by Forest Removal in the Sierra Nevada
– links included – below]
Roads will be needed to access areas for mechanical operations and removal
of woody material. Roads, with appurtenant road construction and road
maintenance issues are a significant factor in the alteration of natural
hydrologic regimes and are a major source of erosion.

Forest Health Concerns:
If you step back from it and look at it – the approach might be a business
model – rather than a forest health model. Use “utilizing” low value woody forest material as product as a way to support the business model to induce
thinning. Does the forest win or lose?
If it is determined that forest thinning needs to occur, in a specific area, for
forest health – there are questions as to how much, where, and why should the
material be removed and utilized.
Is there really justification (in terms of forest health, economics, and Green
House Gas consideration) for removal and burning as biomass for the
production of energy – electricity? Does the burning (mostly in plants that do
not capture GHGs), hauling, and mechanical work support negative outcomes
to the forest floor and environmental costs, while a small amount of energy is
produced? Please show me the science and calculations supporting all of this.
Part of the equation that must be considered is that once a biomass generation
plant is built and fired up, it must keep running and be continually fed by
‘low value’ woody material. This necessitates contracts for supply of
burnable product and induces a tendency to harvest wood product when it is
not necessary (there are numerous examples of this)
One outcome of forest thinning (as noted above in discussion on hydrology)
may be increased water yield.
Small stems are inefficient water users, where bigger trees are more efficient.
It is argued by some (there is no scientific proof yet) that thinning will
increase water yield. If true, there is no other conclusion that there will be
hydrologic effects and altered runoff regimes.
Where is the water thing going? There is evidence in the documents included
below, and the new State’s Water Portfolio, that this increased water yield
outcome is a central part of the (a) plan – to fill a raised Shasta Dam via
hydrological connections that would fill Lake Almanor, Trinity Lake, and
Lake Oroville – and then Shasta Lake – where the water would make its way
to the proposed Delta Tunnel(s) – and then southern California via the State’s
water conveyance system.
Thinning may provide additional water. This has not been fully determined.
As envisioned by the plan, increased water yield, with increased storage in
Lake Shasta and conveyance to southern California is part of the business model described in the documents included below – including the new State
Water Portfolio.
When discussing potential changes in hydrology, it can be scientifically argued
that leaving thinned material on the ground would have the effect of slowing
water movement and buffering and major changes in hydrology.
Is this all worth killing our forests and our rivers? Is a plan not backed up by
current science something to launch when it might likely impact true forest
health and recovery over millions of acres on public lands for decades to
Emergency Regulations
Emergency Regulations promulgated by the Board of Forestry have been
developed and are now in place supporting thinning operations. These
regulations – created to ease and provoke forest thinning and fire safe forest
management have actually turned out to be a regulatory subsidy for
harvesting forest product.
These Emergency Regulations are supported by industry (especially Sierra
Pacific Industries)as a business model supporting some necessary forest
thinning as well as streamlined timber harvest without the benefit of
environmental review. In fact, the creation of these Emergency Regulations
are not subject environmental review consideration (or challengeable in the
Rule Making Process).
Responsible agencies are not staffed and capable of review and inspect for
Rules compliance operations completed under these Emergency Rules.

The Emergency Rules are looked at and used by project proponents as way to
harvest larger trees without filing a Timber Harvest Plan and going through
environmental review.
This, in effect, is project streamlining and fast-tracking harvest operations.
Note: More importantly (TO BE AWARE)- a significant number of recent
thinning and harvest operations inspected by the Regional Water Quality
Control Board (Region 1 – this report is available)were found to be
problematic. When inspected, 40% were found to not be in compliance with the Forest Practice Rules and/or the Basin Plan (Water Quality Control
Plan)/Porter-Cologne. Again – the Forest Practice Rules have been found to
be not sufficient to protect the beneficial uses of water. And after the approval
of the Forest Practice Act (1973) to protect and restore our diminished forests
on 15 million acres of private forest lands – our forestlands are in worse shape
than ever.
Below – you will find a summary of how these issues were presented to me –
with links (below that summary) to the presentation of the “Business Model”
(by the presenters), and some science on forest thinning.
THE ISSUES – as they came before me.
I received a request for a proposal (RFP) for Spatial Analysis for 7 million
acres in the northeastern sector of the State. I called the Loretta Moreno
(Resources Agency) asking what this was about. Loretta was less than helpful
– not wanting to answer any questions. (BTW Loretta is running the AB 1492
pilot projects that Russ Henley had started – where the project failed to come
up with the ecological objectives or any legitimate findings – related to the
assessment of logging effects and sought after environmental/ecological
outcomes – all of which should be in place to assess implementation of the
Forest Practices Rules and any changes that might be needed to the Rules).
I did some research and discovered that the RFP was for forest management
(fuels management, with the objective of increasing water yield to fill Lake
Almanor, Trinity Lake, Lake Oroville, and finally Shasta Lake (with a
looming 18.5’ dam raise proposal in the works for Shasta dam). Findings of
this process are to be used throughout the State as a template for forest
management and water yield.
Then: I received an invitation to attend a biomass ZOOM meeting/Webinar
(links included-below) covering the subject of fuels management by forest
thinning, “utilizing” the “low value” wood product for biomass burning and
electrical production, and increasing water yield to flow into those same dams
with the increased water volume eventually making its way to the Bay delta
and finally to the Westlands Water District.
Note: ‘Utilization’ is a business model where woody material (‘low value’
wood product removed from the forest) can be used for a number of uses –
including, but not limited to: biomass energy production, oriented strand
board, other glued wood products (i.e. beams, board, landscape applications,
biochar, etc.).
The presentation (see the fist link below) – showed additional before and after
pictures of a ‘cleaned’ or ‘raked’ forest. Scary – tinned forest land remaining
with trees spaced far apart and with nothing left on the ground.
I do think there is a case for thinning overstocked areas. I also think that it is
not necessary to take away everything on the ground for burning or
economically utilized as wood product. Why does forest ‘wood product’ need
to be hauled away? Forests need dead material on the ground as part of the
ecological network. Forests have developed and functioned, over billions of
years – employing a process of decaying forest matter sustaining forest life. I
also have questions as to the efficacy and economics of hauling material and
burning it for power generation. What are the total GHG costs of mechanical
management for the removal of woody material, hauling, and burning –
without capturing the carbon in these power generation plants?
Additionally, the Biomass electrical generation plants, once established, need
to be continually fed. You cannot stop and start these facilities. This ends
with a need for a constant (uninterrupted) flow of material to be burned –
with actual supply contracts – to assure continued operations. This leads to aggressive (beyond what is needed for health) thinning and cleaning of the
There is a huge government and industry push to get this accomplished –
‘before the whole place burns down’. (Note: Donald Trump supports forest
raking for water yield and a dam raise for Shasta. And, the Governor wants
Federal funds to support these outcomes – including the Delta Tunnel) The
Forest Practice Rules, with the use of Emergency Rules, enable fast-tracking
these thinning operations. Thinning operations are not just limited to smaller
trees and fire ladder understory. Larger trees are being taken. The Regional
Board looked at some of the Exemption activity and found that 40% of these
operations did not comply with the Forest Practice Rules and/or the Basin
There is no public, interagency, or environmental review of these plans and/or
the Emergency Rule making.

There are a number of issues related to this that I would like your opinion on
(and maybe ideas on how to approach these issues).
 Forest Thinning for fuels management – in general
 Does the forest floor need to be cleaned
 Leaving thinned wood product on the ground
 Efficacy of hauling and burning
 Water yield outcomes – peak flow changes etc.
 Emergency Rules and fast tracking harvest
 Any other ideas or thinking on these subjects
See Links – below.
Feasibility of Biomass for Regional Energy Independence in Northern California
Presented by: Molly Dunton, Jon Lesser, Claire Desser Briefing for CA Forest
Biomass Working Group June 17th, 2020
Biomass “utilization” webinar related to the above document (1.5 hours – will
give you some idea)
Paper on Wildfire Management:
A New Direction for California Wildfire Policy—Working from the Home
Outward February 11, 2019

The Myth of “Catastrophic” Wildfire, John Muir Project
Technical Report
Disentangling effects of forest harvest on long-term hydrologic and sediment
dynamics,western Cascades,Oregon. Mohammad Safeeq, Gordon E.Grant,Sarah
L.Lewis,Shannon K.Hayes, Journal of Hydrology 580 (2020)
Reburn severity in managed and unmanaged vegetation in a large wildfire
Jonathan R. Thompson, Thomas A. Spies, and Lisa M. Ganio
Previous Fires Moderate BurnSeverity of Subsequent WildlandFires in Two Large
Western USWilderness AreasSean A. Parks,1,2* Carol Miller,1Cara R.
Nelson,2and Zachary A. Holden
Sierra Institute report: “Paying for Forest Health: Improving the Economics
of Forest Restoration and Biomass Power in California
Lawrence Livermore Lab’s report: Getting to Neutral: Options for
Negative Carbon Emissions in California
Biomass Energy Production in California: The Case for a Biomass Policy
Initiative Final Report
Article on Fire and Regeneration – To Thin or Not to Thin – California Sierra fires
science environment
Efforts To Reduce Wildfire Risk Fall Short, Buck Science
Forests and Water in the Sierra Nevada: Sierra Nevada Watershed Ecosystem
Enhancement Project Roger C. Bales, John J. Battles, Yihsu Chen, Martha H. Conklin,
Eric Holst, Kevin L. OHara, Philip Saksa, William StewartNovember 29, 2011
The High Costs and Low Benefits of Attempting to Increase Water Yield by Forest
Removal in the Sierra Nevada
Rhodes, J.J., and C.A. Frissell. 2015. The High Costs and Low Benefits of Attempting to Increase Water
Yield by Forest Removal in the Sierra Nevada. 108 pp. Report prepared for Environment Now
Report of the Scientific Review Panel on California Forest Practice Rules (1999)
WATERSHED EFFECTS (Dunne, University of California, 2001)
California Nonpoint Source Program Findings and Conditions – Coastal Zone
Management Act – Re-authorization (2004)

Forest Statistics
There are 33 million acres of forest(ed) lands in California.
Federal ownership is 19 million acres = 57%
State and local agencies (including land trusts) own 3%
Privately owned forest lands are 13.3 million acres = 40%
Industrial private owners are 4.7 million acres = 14%
Non-industrial privately owned forest lands are 9 million acres = 26%
Non-corporate private forest lands are 7.9 million acres
REITs and other investment devices are 344,000 acres
90+% of the non-corporate private ownerships are 500 acres or less
Four million acres are classified as very highly productive lands capable of producing 165 cu ft of wood product growth per year.

Redwood forests are the highest producing forests (and are a large part of the Four million acres of highly productive forest lands in the State.

Approx. 80% of wood product produced in California comes from private lands
This years fires burned over 1.5 million acres (to date – 9/5/20)
Bill Stewart, UC Forestry and Wildland fire expert – estimates this number of burned acres would be about average – prior to the era where we started suppressing fire. Recently 500,000 to 600,000 acres was average – where in 1936 close to a million acres burned.

Fire suppression hasenhanced fuel loading – leading to more intense burns. Most of the burned ground in recent fires was oak woodland, grass, chaparral habitat type. Fire in managed, high quality forestlands, is limited and less of a fire/ fuel loading management issue.

Ralph Bloemers Friends – for 20 years I have spent time in burned landscapes, with fire experts,biologists, foresters and ecologists. I have also visited with home safety experts,firefighters and first responders.
Last year I testified numerous times to the Oregon Wildfire Council about the need for Oregonians to harden their homes to fire.
I have also spent the last three years with Trip Jennings and Sara Quinn making films about fire in the West and the solutions. The feature length film is called Elemental and it is almost complete. The message from the experts is clear.
1) most big fires are driven by drought and wind (climate) not by the amount of fuels or forest conditions. While vegetation and topography are important factors, remember grasslands and shrublands burn too. In CA this year nearly 70 percent of landscapes that burned so far were not forestlands.

2) forest management – thinning, logging, clearing is a shot in the dark and often increases fire danger. Around homes it can help to reduce the immediate risk and provide for defensible space, but in the backcountry or further from homes it makes little to no difference in terms of home safety.

And the forest grows back. We do not have enough money to tend 350 million acres, and often the tending is logging that takes the most fire resistant material.
3) in extreme fire weather firefighters just try to help people escape. They don’t have enough wet stuff to put on the red stuff. We need to stop believing that firefighting will save us and put out fires. In Detroit Idanha, the firefighters fled. In Paradise the first responders told us they would have needed every fire truck from ALL of California in town within 1hour to be able to save SOME of the homes. The fire hit the town in about 2-3 hours after ignition as it moved very rapidly (3x normal rates) through previously logged and salvaged areas.

AND, most important
4) if we want to protect homes and communities from fire, then we have to harden our homes to fire, prevent ember penetration and ignition. And it is relatively easy and not high cost. Cover vents, clean gutters, hardscape perimeter, use non-flammable materials on the exterior…As to the long held belief, promoted by industry, that it is a problem in our forests, that logging-management-thinning can solve it well it does not hold up to scrutiny. Lets take a look at just one example.

Last night the Bear fire in the northern Sierra Nevada blew up. This area has been heavily logged over the past couple of decades–clearcuts, commercial thinning, “salvage” logging of snags, you name it, mostly on private lands but also quite a bit on National Forests too. The Bear fire just dramatically expanded today when it got to this massive area of heavy logging. The fire is now over 200,000 acres (mostly from last 24 hours), and at least three people have been killed as of now. There will likely be more.

This situation is very much like the Camp fire that hit Paradise in terms of the direct threat of recent logging to lives and homes, by contributing, along with the dominant force of extreme weather and climate change, to very rapid rate of fire spread, giving people little time to evacuate.

At this point, anyone–including you and any reporters, agency or university
scientists–who is still promoting logging as “fuel reduction”, and saying
the problem is in our forests, or a lack of firefighting resources or
denying the fact that weather and climate change are the dominant drivers of
fire behavior – or not acknowledging the fact that logging is a substantial
additional contributor to increased fire spread and intensity, is really just
putting people at greater risk.