R E P O R T

Biomass Sustainability 

and Carbon Policy Study 

Prepared for:

Commonwealth of Massachusetts 

Department of Energy Resources

100 Cambridge Street

Boston, Massachusetts 02114

Prepared by:

Manomet Center for Conservation Sciences

81 Stage Point Road 

P.O. Box 1770 

Manomet, Massachusetts 02345

Phone: (508) 224-6521

Contributors:

Thomas Walker, Resource Economist (Study Team Leader)

Dr. Peter Cardellichio, Forest Economist

Andrea Colnes, Biomass Energy Resource Center

Dr. John Gunn, Manomet Center for Conservation Sciences

Brian Kittler, Pinchot Institute for Conservation

Bob Perschel, Forest Guild

Christopher Recchia, Biomass Energy Resource Center

Dr. David Saah, Spatial Informatics Group

Manomet Center for Conservation Sciences June 2010 NCI-2010-03

N at u r a l Capita l Init iat i v e at M anome t

Manomet Center for Conservation Sciences 

14 Maine Street, Suite 305 

Brunswick, ME 04011 

Contact: 207-721-9040, jgunn@manomet.org

Contact Information for Report:

Manomet Center for Conservation Sciences

Natural Capital Initiative

14 Maine Street, Suite 305

Brunswick, Maine 04011

Phone: 207-721-9040

jgunn@manomet.org
Manomet Center for Conservation Sciences 2 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Acknowledgements

This report was prepared for the Commonwealth of Massachusetts Department of Energy Resources in response to RFP ENE 

2010-001.

Manomet Center for Conservation Sciences would like to acknowledge the thoughtful contributions to this study by our Advisory 

Panel: Dr. Clark Binkley (International Forestry Investment 

Advisors), Dr. David Foster (Harvard Forest), Mr. Paul Lemar, 

Jr. (Resource Dynamics Corporation), and Dr. Alaric Sample 

(Pinchot Institute for Conservation). 

Also, additional staff at team members’ organizations provided 

valuable input and technical support: John Hagan and Andrew 

Whitman (Manomet Center for Conservation Sciences); Adam 

Sherman and Kamalesh Doshi (Biomass Energy Resource Center); 

Zander Evans (Forest Guild); and Will Price (Pinchot Institute 

for Conservation).

Finally, we would like to thank Dr. Anne Perschel of Germane 

Consulting for skillfully organizing and leading the public meeting 

on December 17, 2009. 

Suggested Citation: 

Manomet Center for Conservation Sciences. 2010. Massachusetts Biomass Sustainability and Carbon Policy Study: Report 

to the Commonwealth of Massachusetts Department of Energy 

Resources. Walker, T. (Ed.). Contributors: Cardellichio, P., 

Colnes, A., Gunn, J., Kittler, B., Perschel, R., Recchia, C., Saah, 

D., and Walker, T. Natural Capital Initiative Report NCI-2010-

03. Brunswick, Maine. 
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Biomass Sustainability and Carbon Policy Study

Contents

Executive Summary: Biomass Sustainability and Carbon Policy .....................................................................................6

Introduction ...........................................................................................................................................................................................................6

Summary of Key Findings..................................................................................................................................................................................6

Chapter 1: International and U.S. Forest Biomass Energy Policies .................................................................................9

1.1 Overview.........................................................................................................................................................................................................9

1.2 International Forest Biomass Energy Policies .......................................................................................................................................9

1.2.1 Historical Context................................................................................................................................................................................9

1.2.2 Policy Instruments..............................................................................................................................................................................10

1.2.3 Sustainability Concerns....................................................................................................................................................................11

1.3 U.S. Federal Forest Biomass Energy Policies.......................................................................................................................................13

1.3.1 Most Significant Federal Programs & Incentives for Biomass Energy..................................................................................13

1.3.2 Environmental Protection Agency Position on Biomass Energy and Carbon Accounting ...........................................14

1.3.3 Pending Federal Climate and Energy Legislation ......................................................................................................................15

1.4 Massachusetts Forest Biomass Energy Policies ...................................................................................................................................15

1.4.1 Massachusetts Renewable Portfolio Standard.............................................................................................................................16

1.4.2 Massachusetts RGGI Implementation..........................................................................................................................................16

1.5 Biomass Energy Policies in Other States ..............................................................................................................................................17

1.6 Overall State and Federal Policy Drivers for Biomass Power in Massachusetts.........................................................................17

References..........................................................................................................................................................................................................18

Chapter 2: Technology Pathways....................................................................................................................................20

2.1 Introduction to Technology Options........................................................................................................................................................... 20

2.2 Electricity Generation....................................................................................................................................................................................... 20

2.2.1 Current Sources of Electrical Supply ............................................................................................................................................... 20

2.2.2 Electrical Generation Pathways ......................................................................................................................................................... 20

2.3 Thermal Production ..........................................................................................................................................................................................21

2.3.1 Current Sources of Thermal Supply ..................................................................................................................................................21

2.3.2 Thermal Production Pathways...........................................................................................................................................................21

2.4 Combined Heat and Power Options............................................................................................................................................................ 22

2.4.1 CHP Pathways........................................................................................................................................................................................ 22

2.5 Emerging Technologies .................................................................................................................................................................................... 23

2.5.1 Emerging Technology Pathways ........................................................................................................................................................ 23

2.6 General Discussion and Summary ................................................................................................................................................................ 23

2.6.1 The Future Role of Biomass Under Present Policies..................................................................................................................... 23

2.6.2 Efficiency...................................................................................................................................................................................................25

2.6.3 Carbon Impacts...................................................................................................................................................................................... 27

2.6.4 Affordable Cost for Biomass Source Material................................................................................................................................ 28

References......................................................................................................................................................................................................................29

Chapter 3: Forest Biomass Supply .................................................................................................................................. 31

3.1 Introduction and Major Findings.....................................................................................................................................................................31

3.1.1 Conceptual Framework for Forest Biomass Supply Analysis.......................................................................................................31

3.1.2 Major Findings and Conclusions....................................................................................................................................................... 34

3.1.3 Potential Wood Biomass Supplies from Other Sources................................................................................................................35

3.1.4 Report Organization ............................................................................................................................................................................. 36

3.2 Biomass Supply from Private Lands in Massachusetts............................................................................................................................. 36

3.2.1 Historical Estimates of Timber Harvests on Private Timberland............................................................................................ 36

3.2.2 Logging Residues................................................................................................................................................................................... 38

3.2.3 Low-Price Biomass from Private Timberlands................................................................................................................................39

3.2.4 High-Price Biomass from Private Timberlands..............................................................................................................................45

3.2.5 Potential Biomass Supply Based on Forest Growth.......................................................................................................................51

3.3 Biomass Supply from Public Lands in Massachusetts...............................................................................................................................51

3.3.1 Historical Harvest Estimates...............................................................................................................................................................51

3.3.2 Timber Harvest Projections for 2010—2025..................................................................................................................................52

3.3.3 Low-Price Biomass Scenario.................................................................................................................................................................53
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3.3.4 High-Price Biomass Scenario...............................................................................................................................................................53

3.4 Summary of Forest Biomass Supplies in Massachusetts...........................................................................................................................53

3.5 Biomass Supply from Non-Forest Sources in Massachusetts.................................................................................................................. 54

3.5.1 Land Clearing and Conversion........................................................................................................................................................... 54

3.5.2 Tree Care and Landscaping Sources...................................................................................................................................................55

3.6 Biomass Supply from Nearby States...............................................................................................................................................................55

3.6.1 Timberland Area and Timber Inventory......................................................................................................................................... 56

3.6.2 Timber Growth ..................................................................................................................................................................................... 56

3.6.3 The Forest Products Industry and Regional Harvesting..............................................................................................................57

3.6.4 Landowner Characteristics in the Region....................................................................................................................................... 58

3.6.5 Summary of Forest Biomass Supply Potential in Border Counties............................................................................................59

3.6.6 Inter-regional Trade and Implications for Biomass Supplies for Future Bioenergy Plants in Massachusetts................ 60

References......................................................................................................................................................................................................................61

Chapter 4: Forest Sustainability and Biomass Harvesting in Massachusetts.................................................................. 63

4.1 Introduction .........................................................................................................................................................................................................63

4.2 Stand-level Impacts to Forest Health Resulting from Increased Biomass Demand..........................................................................63

4.2.1. Introduction............................................................................................................................................................................................63

4.2.2. Impacts on soils and productivity...................................................................................................................................................... 64

4.2.3 Impacts on Habitat and Biodiversity.................................................................................................................................................67

4.3 Lessons from Other Initiatives: Protecting Stand Level Ecological Values through Biomass Harvest Guidelines................. 68

4.3.1 Overview of Regulatory Frameworks .............................................................................................................................................. 68

4.3.2 Key Findings from An Assessment of Biomass Harvesting Guidelines (revised)..................................................................69

4.3.3 Adequacy of Massachusetts BMPs for Increased Biomass Harvests.........................................................................................70

4.4 Forest Sustainability Indicators and Landscape Level Effects of Biomass Harvesting.....................................................................71

4.4.1 Introduction .............................................................................................................................................................................................71

4.4.2 Potential Ecological Impacts of Biomass Harvests ........................................................................................................................71

4.4.3 Potential Impacts of Biomass Harvests on Landscape Aesthetics ............................................................................................ 72

4.4.4 Potential Impacts of Biomass Harvesting on Economic Productivity of Forests.................................................................. 73

4.4.5 Existing Approaches to Managing Landscape Level Impacts in Massachusetts................................................................... 73

4.5 Recommendations for Addressing Stand and Landscape Level Impacts of Increased Biomass Harvesting ..............................74

4.5.1 Stand Level Recommendations ...........................................................................................................................................................74

4.5.2 Landscape Level Recommendations..................................................................................................................................................76

References......................................................................................................................................................................................................................78

Chapter 5: Forest Carbon Modeling...............................................................................................................................82

5.1 Forest Management and Carbon Sequestration ........................................................................................................................................ 82

5.2 Inventory Data and Forest Carbon Models................................................................................................................................................ 82

5.3 Model Scenarios ..................................................................................................................................................................................................83

5.4 General Results and Model Evaluation........................................................................................................................................................ 84

5.4.1 General Results....................................................................................................................................................................................... 84

5.4.2 Cover Type and Ownership Differences in Carbon Accumulation ........................................................................................ 88

5.4.3 Regeneration Contribution to Carbon Accumulation................................................................................................................ 89

5.4.4 Role of Tops and Limbs in Carbon Budget..................................................................................................................................... 89

5.5 Conclusion .......................................................................................................................................................................................................... 93

References..................................................................................................................................................................................................................... 93

Chapter 6: Carbon Accounting for Forest Biomass Combustion...................................................................................95

6.1 Introduction ........................................................................................................................................................................................................ 95

6.1.1 Brief Review of Previous Studies........................................................................................................................................................ 95

6.1.2 Carbon Accounting Framework ........................................................................................................................................................ 96

6.1.3 Other Considerations: Landscape or Stand-Level Modeling ..................................................................................................... 99

6.2 Technology Scenarios and Modeling Assumptions................................................................................................................................100

6.2.1 Overview of Technologies and Approach......................................................................................................................................100

6.2.2 Forest Harvest Scenarios.................................................................................................................................................................... 101

6.2.3 Biomass and Fossil Fuel GHG Emissions .....................................................................................................................................105

6.3 Forest Biomass Carbon Accounting Results.............................................................................................................................................105
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6.3.1 Introduction ..........................................................................................................................................................................................105

6.3.2 Energy Technology and Carbon Debt Recovery.........................................................................................................................105

6.3.3 Forest Management and Carbon Recovery...................................................................................................................................107

6.3.4 Discussion of Results........................................................................................................................................................................... 112

6.4 Final Considerations....................................................................................................................................................................................... 113

References........................................................................................................................................................................................................... 114

Appendix 1-A: Federal, State and Regional Biomass Energy Policies..........................................................................................................115

Appendix 2-A: 18 Selected Technology Pathways...........................................................................................................................................126

Appendix 2-B: Technology Pathways Summary..............................................................................................................................................129

Appendix 2-C: Affordable Price of Biomass—Calculation Assumptions................................................................................................ 131

Appendix 3-A: Review of Previous Studies of Massachusetts Biomass Availability...............................................................................132

Appendix 3-B: Logging Residue Data and Estimation..................................................................................................................................134

Appendix 3-C: Firewood Data.............................................................................................................................................................................136

Appendix 3-D: A Closer Look at Biomass Potential in Southern New Hampshire..............................................................................137

Appendix 4-A: Ecology of Dead Wood in the Northeast.............................................................................................................................139

Appendix 4-B: Revised Assessment of Biomass Harvesting and Retention Guidelines ....................................................................... 150

Appendix 4-C: Forest Biomass Retention and Harvesting Guidelines for the Northeast................................................................... 169

Appendix 5.................................................................................................................................................................................................................177
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Biomass Sustainability and Carbon Policy Study

Executive Summary

Biomass Sustainability and 

Carbon Policy

Introduction

This study addresses a wide array of scientific, economic and 

technological issues related to the use of forest biomass for generating energy in Massachusetts. The study team, assembled and 

directed by the Manomet Center for Conservation Sciences, 

was composed of experts in forest ecosystems management and 

policy; natural resource economics; and energy technology and 

policy. The Commonwealth of Massachusetts Department of 

Energy Resources (DOER) commissioned and funded the study.

The study provides analysis of three key energy and environmental 

policy questions that are being asked as the state develops its 

policies on the use of forest biomass.

1. What are the atmospheric greenhouse gas implications of 

shifting energy production from fossil fuel sources to forest 

biomass?

2. How much wood is available from forests to support biomass 

energy development in Massachusetts?

3. What are the potential ecological impacts of increased biomass 

harvests on forests in the Commonwealth, and what if any 

policies are needed to ensure these harvests are sustainable?

The goal of the report is to inform the development of DOER’s 

biomass policies by providing up-to-date information and analysis 

on the scientific and economic issues raised by these questions. 

We have not been asked to propose specific policies except in 

the case where new approaches may be needed to protect the 

ecological functioning of forests. We do not consider non-forest 

sources of wood biomass (e.g., tree care and landscaping, mill 

residues, construction debris), which are potentially available in 

significant quantities but which have very different greenhouse 

gas (GHG) implications. 

This Executive Summary highlights key results from our research 

and the implications for the development of biomass energy 

policies in Massachusetts. While certain of the study’s insights 

are broadly applicable across the region (e.g., estimates of excess 

lifecycle emissions from combustion of biomass compared to fossil 

fuels), it is also important to recognize that many other conclusions are specific to the situation in Massachusetts—particularly 

greenhouse gas accounting outcomes that depend on the forest 

management practices of the state’s landowners, which likely differ 

considerably from those in neighboring states. Nonetheless, the 

framework and approach that we have developed for assessing 

the impacts of wood biomass energy have wide applicability for 

other regions and countries.

Summary of Key Findings

Greenhouse Gases and Forest Biomass: At the state, national, 

and international level, policies encouraging the development of 

forest biomass energy have generally adopted a view of biomass 

as a carbon neutral energy source because the carbon emissions 

were considered part of a natural cycle in which growing forests 

over time would re-capture the carbon emitted by wood-burning 

energy facilities. Beginning in the 1990s, however, researchers began 

conducting studies that reflect a more complex understanding 

of carbon cycle implications of biomass combustion. Our study, 

which is based on a comprehensive lifecycle carbon accounting 

framework, explores this more complex picture in the context of 

biomass energy development in Massachusetts. 

The atmospheric greenhouse gas implications of burning forest 

biomass for energy vary depending on the characteristics of the 

bioenergy combustion technology, the fossil fuel technology it 

replaces, and the biophysical and forest management characteristics 

of the forests from which the biomass is harvested. Forest biomass 

generally emits more greenhouse gases than fossil fuels per unit of 

energy produced. We define these excess emissions as the biomass 

carbon debt. Over time, however, re-growth of the harvested forest 

removes this carbon from the atmosphere, reducing the carbon 

debt. After the point at which the debt is paid off, biomass begins 

yielding carbon dividends in the form of atmospheric greenhouse 

gas levels that are lower than would have occurred from the use of 

fossil fuels to produce the same amount of energy (Figure 1). The 

full recovery of the biomass carbon debt and the magnitude of the 

carbon dividend benefits also depend on future forest management 

actions and natural disturbance events allowing that recovery to occur. 

Figure 1 (tonnes of carbon). The schematic above represents the incremental 

carbon storage over time of a stand harvested for biomass energy wood relative 

to a typically harvested stand (BAU). The initial carbon debt (9 tonnes) is shown 

as the difference between the total carbon harvested for biomass (20 tonnes) 

and the carbon released by fossil fuel burning (11 tonnes) that produces an 

equivalent amount of energy. The carbon dividend is defined in the graph as the 

portion of the fossil fuel emissions (11 tonnes) that are offset by forest growth 

at a particular point in time. In the example, after the 9 tonnes biomass carbon 

debt is recovered by forest growth (year 32), atmospheric GHG levels fall below 

what they would have been had an equivalent amount of energy been generated 

from fossil fuels. This is the point at which the benefits of burning biomass begin 

to accrue, rising over time as the forest sequesters greater amounts of carbon 

relative to the typical harvest. 

The initial level of the carbon debt is an important determinant of 

the desirability of producing energy from forest biomass. Figure 2 

provides a summary of carbon debts, expressed as the percentage 
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Biomass Sustainability and Carbon Policy Study

compared to what would have been the case if fossil fuels had been 

used over the same period—approximately 25% lower over the 

period under a rapid recovery scenario. For biomass replacement 

of coal-fired power plants, the net cumulative emissions in 2050 

are approximately equal to what they would have been burning 

coal; and for replacement of natural gas cumulative total emissions are substantially higher with biomass electricity generation.

Figure 4: Cumulative Carbon Dividends from Biomass 

Replacement of Fossil Fuel

Biomass Cumulative % Reduction in Carbon Emissions

 (Net of Forest Carbon Sequestration) 

Year

Oil (#6) 

Thermal/

CHP

Coal, 

Electric

Gas, 

Thermal

Gas, 

Electric

2050 25% -3% -13% -110%

2100 42% 19% 12% -63%

 

Forest Biomass Supply: Future new supplies of forest biomass 

available for energy generation in Massachusetts depend heavily 

on the prices that bioenergy facilities are able to pay for wood. 

At present, landowners in the region typically receive between $1 

and $2 per green ton of biomass, resulting in delivered prices at 

large-scale electricity facilities of around $30 per green ton. Under 

current policies that are influenced by the competitive dynamics of 

the electricity sector, we do not expect that utility-scale purchasers 

of biomass will be able to significantly increase the prices paid to 

landowners for biomass. Consequently, if future forest biomass 

demand comes primarily from large-scale electric facilities, we 

estimate the total “new” biomass that could be harvested annually 

from forest lands in Massachusetts would be between 150,000 

and 250,000 green tons—an amount sufficient to support 20 

MW of electric power capacity—with these estimates potentially 

increasing by 50%−100% when out-of-state forest biomass sources 

are taken into account (these estimates do not include biomass 

from land clearing or other non-forest sources such as tree work 

and landscaping). This is the amount of incremental biomass 

that would be economically available and reflects the costs of 

harvesting, processing and transporting this material as well as 

our expectations about the area of land where harvest intensity 

is likely to increase. Thermal, CHP, and other bioenergy plants 

can also compete for this same wood—which could support 16 

typically sized thermal facilities or 4 typical CHP plants—and 

have the ability to pay much higher prices on a delivered basis; 

thus, they have more options for harvesting and processing forest 

biomass and can outbid electric power if necessary.

Paying higher prices to landowners for forest biomass could 

potentially increase forest biomass supplies significantly. For this 

to occur, electricity prices would need to rise, due to substantially 

higher fossil fuel prices or significant policy shifts. Thermal, CHP, 

and pellet facilities can already pay much higher prices for biomass 

at current energy prices, and would remain competitive if prices 

paid to landowners were to rise significantly. If these prices were 

of total biomass emissions that are in excess of what would have 

been emitted from fossil fuel energy generation. Replacement of 

fossil fuels in thermal or combined heat and power (CHP) applications typically has lower initial carbon debts than is the case 

for utility-scale biomass electric plants because the thermal and 

CHP technologies achieve greater relative efficiency in converting 

biomass to useable energy. As a result, the time needed to pay off 

the carbon debt and begin accruing the benefits of biomass energy 

will be shorter for thermal and CHP technologies when the same 

forest management approaches are used in harvesting wood.

Figure 2: Carbon Debt Summary Table

Excess Biomass Emissions as % of Total Biomass Emissions

Scenarios Coal Oil (#6) Oil (#2) Natural 

Gas

Electric 31% 66%

Thermal/ 

CHP 2%-8% 9%-15% 33%-37%

The absolute magnitude and timing of the carbon debts and 

dividends, however, is sensitive to how landowners decide to 

manage their forests. Since future landowner responses to increased 

demand for forest biomass are highly uncertain, we modeled the 

recovery of carbon in growing forests under a number of alternative management scenarios. 

For a scenario that results in relatively rapid realization of greenhouse gas benefits, the switch to biomass yields benefits within 

the first decade when oil-fired thermal and CHP capacity is 

replaced, and between 20 and 30 years when natural gas thermal 

is replaced (Figure 3). Under comparable forest management 

assumptions, dividends from biomass replacement of coal-fired 

electric capacity begin at approximately 20 years. When biomass 

is assumed to replace natural gas electric capacity, carbon debts 

are still not paid off after 90 years. 

Figure 3: Carbon Debt Payoff

Fossil Fuel Technology Carbon Debt Payoff (yr)

Oil (#6), Thermal/CHP 5

Coal, Electric 21

Gas, Thermal 24

Gas, Electric >90

Another way to consider greenhouse gas impacts of biomass energy 

is to evaluate at some future point in time the cumulative carbon 

emissions of biomass (net of forest recapture of carbon) relative 

to continued burning of fossil fuels. The Massachusetts Global 

Warming Solutions Act establishes 2050 as an important reference year for demonstrating progress in reducing greenhouse gas 

emissions. Figure 4, comparing 40 years of biomass emissions with 

40 years of continued fossil fuel burning, shows that replacement 

of oil-fired thermal/CHP capacity with biomass thermal/CHP 

fully offsets the carbon debt and lowers greenhouse gas levels 
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Biomass Sustainability and Carbon Policy Study

anticipate that harvested acreage will not increase from current 

levels—biomass will come from removal of logging residues and 

poor quality trees at sites that would be harvested for timber 

under a business-as-usual scenario. Furthermore, in this scenario 

the combined volume of timber and biomass harvests represents 

less than half of the annual net forest growth across the state’s 

operable private forest land base. Under our high-price biomass 

supply scenario, although harvests still represent annual cutting 

on only about 1% of the forested lands in the state, the total 

harvest levels approach the total amount of wood grown each 

year on the operable private forest land base.

Under either price scenario, however, harvests for bioenergy facilities could have more significant local or regional impacts on the 

landscape. These might include aesthetic impacts of locally heavy 

harvesting as well as potential impacts on recreation and tourism 

and the longer-term health of the wood products sector of the 

economy. We have outlined four general options encompassing a 

wide range of non-regulatory and regulatory approaches that the 

state may wish to consider if it determines that further actions are 

needed to protect public values at the landscape scale.

• Option 1: Establish a transparent self-monitoring, selfreporting process for bioenergy facilities designed to foster 

sustainable wood procurement practices.

• Option 2: Require bioenergy facilities to purchase wood from 

forests with approved forest management plans.

• Option 3: Require bioenergy facilities to submit wood supply 

impact assessments.

• Option 4: Establish formal criteria for approval of wood 

supply impact assessments—possible criteria might include 

limits on the amount of harvests relative to anticipated forest 

growth in the wood basket zone.

At the stand level, the most significant sustainability concerns 

associated with increased biomass harvests are maintenance of soil 

productivity and biodiversity. Current Chapter 132 Massachusetts forest cutting practices regulations provide generally strong 

protection for Massachusetts forests, especially water quality; 

however, they are not currently adequate to ensure that biomass 

harvesting is protective of ecological values across the full range of 

site conditions in Massachusetts. Other states and countries have 

recently adopted biomass harvesting guidelines to address these 

types of concerns, typically through new standards that ensure 

(1) enough coarse woody debris is left on the ground, particularly 

at nutrient poor sites, to ensure continued soil productivity and 

(2) enough standing dead wildlife trees remain to promote biodiversity. While the scientific literature does not provide definitive 

advice on the appropriate practices for Massachusetts’ forests, 

recent guidance from the Forest Guild and other states provides 

the State Forestry Committee with a useful starting point for 

developing additional stand level standards that ensure continued 

protection of ecological values in Massachusetts forests. 

to increase to $20 per green ton, we estimate that supplies of forest 

biomass from combined in-state and out-of-state sources could 

be as high as 1.2 to 1.5 million green tons per year. However, this 

high-price scenario is unlikely given current expectations of fossil 

fuel prices and existing renewable energy incentives. 

Figure 5 shows the potential bioenergy capacity that could be 

supported from these estimated volumes of “new” forest biomass 

in Massachusetts. The upper end of the range for Massachusetts 

forest biomass supplies under our high-price scenario is approximately 885,000 green tons per year—this is close to the annual 

quantity of biomass that can be harvested without exceeding the 

annual net growth of the forest on the operable private land base. 

If additional forest biomass supplies that would be potentially 

available from out-of-state sources are taken into account, the 

biomass quantity and number of bioenergy facilities that could be 

furnished would be 50%–100% higher than shown in this table.

Figure 5: Potential Bioenergy Capacity from “New” Forest 

Biomass Sources in Massachusetts

Green Tons per Year

Current Massachusetts Harvest * 325,000

Potential Forest Biomass Supply 

(Massachusetts only) **

 Current Biomass Prices 200,000

 High-Price Scenario 800,000

Number of Facilities

Electric Power Capacity: 

Number of 50 MW Plants

 Current Biomass Prices 0.4

 High-Price Scenario 1.6

Thermal Capacity: 

Number of 50 MMBtu/hr Plants ***

 Current Biomass Prices 16

 High-Price Scenario 62

CHP Capacity: Number of 5 

MW/34 MMBtu/hr Plants ***

 Current Biomass Prices 4

 High-Price Scenario 15

Notes: * Average of industrial roundwood for 2001−2009.

** Based on mid-point of the range of volumes estimated for new biomass 

in Massachusetts.

*** Thermal plants are assumed to operate 1800 hours per year, while 

CHP plants operate 7200 hours per year.

Forest Sustainability and Biomass Harvests: In Massachusetts, 

the possibility of increased harvesting of biomass for energy has 

raised a number of sustainability issues at both the landscape 

and stand levels. At the landscape scale, potential impacts to 

a broad range of societal values arise with increases in biomass 

harvesting. However, in our low-price scenario for biomass, we 
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Biomass Sustainability and Carbon Policy Study

Chapter 1

International and U.S. 

Forest Biomass Energy Policies 

1.1 Overview

International and U.S. domestic forest biomass energy policies 

form a critical backdrop to the analyses presented in this report. 

The purpose of this introductory chapter is to provide a general 

understanding of (1) the development of policies that have driven 

the growth of the biomass energy sector; (2) the key policy instruments that have been relied upon to promote this development; 

and (3) a summary of recent discussions about the greenhouse 

gas (GHG) implications of forest biomass energy.

The chapter is organized into two major sections. The first reviews 

international biomass energy policies—focusing on the historical 

development of these policies, discussing the policy instruments 

in place that promote biomass development, and summarizing 

recent concerns about the impact on GHG of emissions from 

biomass energy facilities. The second section provides a more 

detailed review of U.S. energy policies affecting forest biomass 

both at the federal and state levels, with a particular focus on 

policies in Massachusetts. 

1.2 International Forest Biomass Energy 

Policies

1.2.1 Historical Context

The late 20th century development of forest biomass energy 

facilities originated from energy security concerns triggered by 

the 1973–1974 oil crisis. The International Energy Agency (IEA) 

was founded at this time primarily to address the security issue. 

Energy Security can be described as “the uninterrupted 

physical availability at a price which is affordable, while 

respecting environment concerns.” The need to increase 

“energy security” was the main objective underpinning 

the establishment of the IEA. With particular emphasis 

on oil security, the Agency was created in order to establish 

effective mechanisms for the implementation of policies on 

a broad spectrum of energy issues: mechanisms that were 

workable and reliable, and could be implemented on a 

co-operative basis (International Energy Agency, 2010).

Although IEA’s original founding agreements did not explicitly 

address forest biomass, the agency created IEA Bioenergy in 

1978 with:

...the aim of improving cooperation and information 

exchange between countries that have national programmes 

in bioenergy research, development and deployment (IEA 

Bioenergy, 2010).

Our review of available documents suggests that prior to IEA 

Bioenergy’s 1998–2002 Strategic Plan (IEA Bioenergy, NA), 

the greenhouse gas implications of forest biomass combustion 

were not a primary area of research for the organization (IEA 

Bioenergy, 1995). Moreover, recent IEA policies have continued 

to reflect the view that biomass combustion is “close to carbon 

neutral in most instances” (International Energy Agency, 2007).

In fact, from a climate change perspective, the desirability of biomass 

energy appears to have been the prevailing wisdom of international 

bioenergy policies over most of the past ten or fifteen years. These 

policies have generally equated burning of biomass from renewable 

sources with “climate friendly” outcomes. The presumption has 

been that as long as the harvested areas grow back as forests, the 

emitted CO2 emissions will be recaptured in the growing trees, 

resulting in lower net CO2 emissions over time across the entire 

energy generation sector. For example, in a 2000 study of forestry 

and land use, the Intergovernmental Panel on Climate Change 

(IPCC), the lead international organization charged with assessing 

impacts of greenhouse gas emissions, stated that:

Biomass energy can be used to avoid greenhouse gas emissions from fossil fuels by providing equivalent energy 

services: electricity, transportation fuels, and heat. The 

avoided fossil fuel CO2 emissions of a biomass energy 

system are equal to the fossil fuels substituted by biomass 

energy services minus the fossil fuels used in the biomass 

energy system. These quantities can be estimated with a 

full fuel-cycle analysis of the system. The net effect on fossil 

fuel CO2 emissions is evident as a reduction in fossil fuel 

consumption (IPCC, 2000).

In its most recent 2007 assessment, IPCC noted that:

In the long term, a sustainable forest management strategy 

aimed at maintaining or increasing forest carbon stocks, 

while producing an annual sustained yield of timber, fibre 

or energy from the forest, will generate the largest sustained 

mitigation benefit.

For the purpose of this discussion, the options available to 

reduce emissions by sources and/or to increase removals 

by sinks in the forest sector are grouped into four general 

categories (1)...(4) increasing the use of biomass-derived 

energy to substitute fossil fuels (IPCC, 2007).

European Union policies also promote the use of forest biomass energy, 

as embodied in the EU’s 2006 Forest Action Plan: 

The EU has adopted an ambitious energy and climate 

policy which aims by 2020 to reduce energy consumption 

by 20%, with a similar cut in CO2 emissions, while raising 

the share of renewables in the EU’s energy mix to 20%.

More than half of the EU’s renewable energy already 

comes from biomass, 80% of which is wood biomass. 

Wood can play an important role as a provider of biomass 

energy to offset fossil fuel emissions, and as an environmentally friendly material. There has recently been higher 

demand for wood from the energy sector in addition to 
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rising demand from the established wood-processing 

industries. Many experts consider that significantly 

more wood could be mobilised from EU forests than is 

currently the case. However, the cost at which this can 

be done is the key factor (EU, 2006).

In approving the Forest Action Plan, the Commission of 

European Communities identified a variety of key actions, 

including: 

Key action 4: Promote the use of forest biomass for energy 

generation

Using wood as an energy source can help to mitigate 

climate change by substituting fossil fuel, improving 

energy self-sufficiency, enhancing security of supply and 

providing job opportunities in rural areas.

The Standing Forestry Committee will support the implementation of the Biomass Action Plan (Commission of 

European Communities, 2005) in particular concerning 

the development of markets for pellets and chips and 

information to forest owners about the opportunities of 

energy feedstock production.

The Commission will facilitate investigation and dissemination of experience on mobilisation of low-value timber, 

small-sized wood and wood residues for energy production. The Member States will assess the availability of 

wood and wood residues and the feasibility of using 

them for energy production at national and regional 

levels, in order to consider further actions in support of 

the use of wood for energy generation. The 7th Research 

Framework Programme and the IEE-CIP provide the 

necessary possibilities to facilitate such activities.

The Commission will continue to support research and development 

of technologies for the production of heat, cooling, electricity and 

fuels from forest resources in the energy theme of the 7th Research 

Framework Programme’s cooperation specific programme, and 

to encourage the development of the biofuel technology platform 

and support the implementation of its research agenda through the 

7th Research Framework Programme (Commission of European 

Communities, 2006).

1.2.2 Policy Instruments

Energy policies for forest biomass are embedded in a broader 

system of policies promoting the development of renewable 

energy sources. These policies are typically implemented through 

incentive schemes such as feed-in tariffs that guarantee favorable 

purchase prices for renewables and through Renewable Portfolio 

Standards (RPS) requiring that renewable sources constitute a 

certain minimum percentage of energy generation. A 2009 

status report from the Renewable Energy Policy Network for 

the 21st Century (REN21) provides summary data characterizing the renewable energy policies of countries around the globe. 

According to REN21:

By early 2009, policy targets existed in at least 73 countries, and at least 64 countries had policies to promote 

renewable power generation, including 45 countries and 

18 states/provinces/territories with feed-in tariffs (many 

of these recently updated). The number of countries/states/ 

provinces with renewable portfolio standards increased 

to 49. Policy targets for renewable energy were added, 

supplemented, revised, or clarified in a large number of 

countries in 2008 (Renewable Energy Policy Network for 

the 21st Century, 2009).1

By allowing projects to qualify for feed-in tariffs and be counted 

towards RPS goals, designation of forest biomass as a renewable 

energy source has been an important driver of biomass energy 

project development. The REN21 status report indicates that 

by the end of 2008, 52 GW of biomass power capacity existed 

worldwide, about evenly split between developed and developing 

countries. The European Union and United States accounted for 

15 GW and 8 GW of this capacity, respectively. About 2 GW 

of this total were added in 2008, an annual increase of approximately 4 percent.

Within the broad context of biomass energy policies, individual 

countries have emphasized different policy instruments. A variety of 

researchers have conducted assessments of country-specific impacts 

of biomass policies—for an excellent summary see (Junginger, 2007). 

Faaij (2006) points out that:

All EU-15 countries implemented policies for supporting 

bioenergy. These include the deployment of compensation 

schemes, tax deduction (in some cases specifically aimed at 

biofuels), feed-in tariffs, tax incentives, energy tax exemption, bidding schemes, CO2-tax and quota. Precise targets 

on the national level differ strongly however and are hard 

to compare because of differences in definitions and fuels 

in or excluded (such as MSW and peat).The same is true 

for the level of (financial) support provided through the 

various programs and instruments. The different countries 

clearly have chosen very different approaches in developing 

and deploying various bio-energy options. Partly this is 

caused by the natural conditions (type of resources and crops, 

climate) and the structure of the energy system, and also 

by the specific political priorities linked to the agricultural 

and forestry sectors in those countries.

A general conclusion of these studies is that higher rates of biomass 

energy development are typically a function not of any single 

factor but instead result from the combined effects of a variety 

of policy instruments, in the context of a country’s existing mix 

of energy sources and the degree of development of its forestry 

sector (Kautto, 2007; Junginger, 2007). For example, Sweden is 

one of the European countries that have most rapidly adopted 

biomass energy systems. Two key factors have been identified as 

1 For an extensive list of countries and their policies, see Table 2, pages 

23–24, www.ren21.net/pdf/RE2007_Global_Status_Report.pdf, and 

pages 17–18 of www.ren21.net/pdf/RE_GSR_2009_Update.pdf
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1.2.3 Sustainability Concerns

Although mainstream policies continue to promote biomass 

as a renewable and carbon friendly fuel, the international 

policy framework is beginning to require more detailed assessments of the carbon implications of bioenergy development. 

This more sophisticated approach to understanding the greenhouse gas implications of climate policy dates from the 1990s 

when researchers began building formal models to explore 

the impacts of biomass combustion on greenhouse gas levels, 

for example studies by Marland and Schlamadinger (1995).2

Work along these lines became a prominent feature of research 

conducted IEA Bioenergy Task 38, which is focused directly 

on the climate change implications of biomass combustion for 

energy. Researchers contributing to Task 38 have pointed out 

the difficulty of generalizing about the climate benefits of 

biomass combustion. This view was expressed in a December 

2009 status report from IEA Bioenergy issued to coincide with 

the Copenhagen conference on climate change. This report 

provided a clearly articulated summary of the current, and in 

our view state-of-the-art, thinking on the impacts of forest 

biomass combustion on greenhouse gases.

Ranking of land use options based on their contribution 

to climate change mitigation is also complicated by the fact 

that the performance of the different options is site-specific 

and is determined by many parameters. Among the more 

critical parameters are: 

• Biomass productivity and the efficiency with which 

the harvested material is used—high productivity 

and efficiency in use favour the bioenergy option. Low 

productivity land may be better used for carbon sinks, 

given that this can be accomplished without displacing 

land users to other areas where their activities lead 

to indirect CO2 emissions. Local acceptance is also a 

prerequisite for the long-term integrity of sink projects.

• The fossil fuel system to be displaced—the GHG emissions 

reduction is for instance higher when bioenergy replaces 

coal that is used with low efficiency and lower when it 

replaces efficient natural gas-based electricity or gasoline/ 

diesel for transport.

• The initial state of the land converted to carbon sinks or 

bioenergy plantations (and of land elsewhere possibly 

impacted indirectly)—conversion of land with large 

carbon stocks in soils and vegetation can completely 

negate the climate benefit of the sink/bioenergy 

establishment.

• The relative attractiveness of the bioenergy and carbon 

sink options is also dependent on the timescale that 

is used for the evaluation. A short timeframe (a few 

2 For a more complete list of Task 38 background papers from the 1990s, 

see www.ieabioenergy-task38.org/publications/backgroundpapers/

backgroundpapers.htm#marland1

the basis for this growth. First is the presence of a large and welldeveloped forest products sector. Second, the design of Sweden’s 

tax system has strongly encouraged biomass development through 

a range of mutually reinforcing policies.

Overall it appears that taxation has been a very effective policy instrument in increasing biomass utilisation 

in Sweden throughout the 1990’s. This has particularly 

been the case in the heat sector, but, following market 

liberalisation, significant increases in the electricity sector 

have also been noted. It should be noted in this respect that 

the Swedish tax regime is long established and comprises 

multiple layers of VAT, energy and CO2 taxes, increasing 

the effectiveness of tax increases. There is also a complex and 

frequently modified system of allocating rebates to certain 

industries that has enabled the tax to be augmented as 

required to encourage biomass use at the expense of fossil 

fuels, while maintaining competitive industrial advantage 

(Cooper & Thornley, 2007).

On the other hand, Faaij (2006) points out that France’s focus on 

biofuels and heat is primarily a function of excess capacity in its 

nuclear electricity production sector, making electrical generation 

from biomass unattractive. 

The government policies of non-European countries also could 

dramatically increase biomass energy generation. For example, 

China has established a variety of policy goals that will promote 

biomass energy development (Roberts, 2010). By 2020, China 

is proposing to build 24 GW of biomass power capacity, equivalent to more than eight 25 MW plants per month over the next 

decade, although Roberts notes this is overly ambitious and 

likely to be downgraded to 10 GW. Although most of China’s 

biomass appears to be based on agricultural wastes, plans do 

include increasing wood pellet production from two million 

tons per year in 2010 to 50 million tons per year by 2020 and 

developing 13.3 million hectares of forests to produce biomass 

feedstock. According to Roberts (2010), China has accounted 

for 23 percent of recent worldwide investment in biomass energy 

(compared with Europe’s 44 percent share). Policies in large 

forested countries like Canada are also aimed at promoting 

biomass energy development, although Roberts notes that 

Canada has been slow in developing its bioenergy resources 

and that most “meaningful” biomass policies are being put 

in place at the provincial level, for example Ontario’s feed-in 

tariffs and British Columbia’s carbon tax. 

Overall, growth of the biomass sector internationally could 

have important implications for the U.S. and Massachusetts. 

In Britain, two 300 MW biomass power plants are currently 

in the planning stages. These plants are projected to consume 

six million green tons of wood chips annually, purchased from 

around the globe, with New England identified as a possible 

source of woodchips (MGT Power, 2010). Given the potential 

for such increased international trade in biomass, Massachusetts 

forests could become suppliers of biomass regardless of whether 

any biomass plants are actually built in the state. 
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In on-line supporting material for the Science article, Searchinger 

et al. note that:

Use of forests for electricity on additional carbon: 

Roughly a quarter of anthropogenic emissions of carbon 

dioxide are removed from the atmosphere by the terrestrial 

carbon sink, of which the re-growth of forests cut in previous 

decades plays a major role. Any gain in carbon stored in 

regenerating forests contributes to the sink, so activities 

that keep otherwise regenerating forests to constant levels 

of carbon reduces that sink relative to what would have 

occurred without those activities.

The net effect of harvesting wood for bioenergy is complicated and requires more analysis. Each ton of wood 

consumed in a boiler instead of coal does not significantly 

alter combustion emissions. However, some of the wood 

in standing timber is typically not utilized and is left to 

decay in the forest or nearby, causing additional emissions. Much of the carbon in roots will also decompose. 

Replanting may accelerate release of carbon from forest 

soils. As the forest regenerates following cutting, it may 

sequester carbon faster or slower than would have occurred 

in the absence of the harvesting, depending on the previous 

forest’s age, site quality and forest type. Over long periods, 

the carbon stocks of the forests with and without the harvest 

for biofuels may be equal. For this reason, how different 

emissions are valued over time plays an important role 

in estimating the net carbon effects of harvesting wood 

for use as a bioenergy. 

In Europe, policies towards biomass may be beginning to 

reflect this more complex view of potential greenhouse gas 

impacts. A 2009 EU policy directive recognizes the need to 

demonstrate the sustainability of biomass energy, and specifies that the European Commission complete such a study. 

Section 75: The requirements for a sustainability scheme for 

energy uses of biomass, other than bioliquids and biofuels, 

should be analysed by the Commission in 2009, taking 

into account the need for biomass resources to be managed 

in a sustainable manner (European Parliament and 

Council, 2009).

However, the results of this recently completed study of biomass 

sustainability take as a starting point the presumption of biomass 

carbon neutrality—adopting the long-term view that CO2 emissions 

from combusted biomass eventually will be recaptured as long as 

the forests are regenerated. In this context, the report goes on to 

discuss a variety of recommended policy options including ones 

to ensure that all biomass is sourced from certified sustainable 

supplies. To the extent that this new report becomes the basis for 

future EU policies, such policies would appear to adopt a very 

long-term view of the relevant timeframe for biomass policies, one 

that does not place great emphasis on the potential for shorter 

term increases in CO2 flux that likely result from forest biomass 

energy generation.

decades) tends to favour the sink option, while a 

longer timeframe favours the bioenergy option. The 

reason is that the accumulation of carbon in forests and 

soils cannot continue endlessly—the forest eventually 

matures and reaches a steady state condition. This is 

also the case for soils. In contrast, bioenergy can be 

produced repeatedly and continue to deliver greenhouse 

gas emissions reduction by substituting fossil fuels.

The bioenergy and carbon sink options obviously differ in 

their influence on the energy and transport systems. Bioenergy promotion induces system changes as the use of biofuels 

for heat, power, and transport increases. In contrast, the 

carbon sink option reduces the need for system change in 

relation to a given climate target since it has the same 

effect as shifting to a less ambitious climate target. The 

lock-in character of the sink option is one disadvantage: 

mature forests that have ceased to serve as carbon sinks 

can in principle be managed in a conventional manner 

to produce timber and other forest products, offering a 

relatively low GHG reduction per hectare. Alternatively, 

they could be converted to higher yielding energy plantations (or to food production) but this would involve the 

release of at least part of the carbon store created. On the 

other hand, carbon sinks can be viewed as a way to buy 

time for the advancement of climate-friendly energy technologies other than bioenergy. Thus, from an energy and 

transport systems transformation perspective, the merits 

of the two options are highly dependent on expectations 

about other energy technologies (IEA Bioenergy, 2009). 

Growing concerns about greenhouse gas impacts of forest biomass 

policies also surfaced recently in journal articles by Johnson (2008) 

and by Searchinger, et al. (2009). The Searchinger article, appearing 

in Science and titled “Fixing a Critical Climate Accounting Error,” 

points out that rules for applying the Kyoto Protocol and national 

cap-and-trade laws contain a major flaw in that the CO2 emissions from biomass energy are not properly taken into account 

because they embody the implicit assumption that all biomass 

energy is carbon neutral. Consistent with the recent IEA report 

discussed above, Searchinger’s critique states:

The potential of bioenergy to reduce greenhouse gas emissions inherently depends on the source of the biomass and 

its net land-use effects. Replacing fossil fuels with bioenergy 

does not by itself reduce carbon emissions, because CO2

released by tailpipes and smokestacks is roughly the same per 

unit of energy regardless of the source. Bioenergy therefore 

reduces greenhouse gases only if the growth and harvesting 

of the biomass for energy capture carbon above and beyond 

what would be sequestered anyway and thereby offset 

emissions from energy use. This additional carbon may 

result from land management changes that increase plant 

uptake or from the use of biomass that would otherwise 

decompose rapidly.
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incentives (the Production Tax Credit, Investment Tax Credit, 

Modified Accelerated Cost Recovery System, and Clean Renewable 

Energy Bond program); however they have received a relatively small 

share of the total funding. The U.S. Energy Information Administration (EIA) estimates that in fiscal year 2007, open-loop biomass 

facilities received approximately $4 million in tax credits under the 

production tax credit program, compared to approximately $600 

million for wind facilities. Funding for combined heat and power 

or purely thermal facilities is also negligible compared to expenditures on other renewable resources (EIA, 2008). And many of the 

biomass-specific grant programs have total annual allocations in 

the $1 to $5 million range, with individual projects often capped 

in the $50,000 to $500,000 range. 

The primary federal subsidy or incentive to biomass electric 

power production is the Renewable Electricity Production Tax 

Credit which provides $0.011 per kWh or approximately $10 per 

MWh.3

 As discussed more fully below, while smaller in value 

than state Renewable Energy Credits (REC’s), which currently 

average between $20–$35 per MWh, the PTC does provide a 

significant and stable incentive for the development of biomass 

power over time. The American Recovery and Reinvestment 

Act of 2009 allows taxpayers eligible for the federal renewable 

electricity production tax credit (PTC) to take the federal business energy investment tax credit (ITC) or to receive a grant 

from the U.S. Treasury Department instead of taking the PTC 

for new installations for up to 30% of capital costs following the 

beginning of commercial production. The new law also allows 

taxpayers eligible for the business ITC to receive a grant from 

the U.S. Treasury instead of taking the business ITC for new 

installations. Grants are available to eligible properties placed in 

service in 2009 or 2010, or if completed by 2013. 

Within federal subsidies specific to biomass energy, there is an 

even greater emphasis on transportation fuels, a very limited 

focus on biomass power, and no historic public policy support 

for biomass thermal applications.

In addition to the federal Production Tax Credit, the Biomass 

Crop Assistance Program (BCAP) has provided significant 

subsidies over the past year to the biomass supply sector. However, 

it is considered unlikely that the current high level of subsidies 

will continue. Created in the 2008 Farm Bill, BCAP (sec. 9011) 

is an innovative program intended to support establishment and 

production of eligible crops for conversion to bio-energy, and to 

assist agricultural and forest landowners with collection, harvest, 

storage, and transportation (CHST) of these eligible materials 

to approved biomass conversion facilities (BCF). 

3 The federal renewable electricity production tax credit (PTC) is 

a per-kilowatt-hour tax credit for electricity generated by qualified 

energy resources and sold by the taxpayer to an unrelated person 

during the taxable year. Originally enacted in 1992, the PTC has 

been renewed and expanded numerous times, most recently by H.R. 

1424 (Div. B, Sec. 101 & 102) in October 2008 and again by H.R. 

1 (Div. B, Section 1101 & 1102) in February 2009. Efforts to again 

renew the PTC are currently underway in the US Congress.

At the broader international level, the IPCC is also in the 

processing of preparing a new report on renewable energy that 

is expected to be published in 2011. Initial indications are that 

this report will provide more detailed considerations of the carbon 

issue for forest biomass. 

1.3 U.S. Federal Forest Biomass Energy 

Policies

1.3.1 Most Significant Federal Programs & 

Incentives for Biomass Energy

Federal incentives for renewable energy (including forest biomass) 

have taken many forms over the past four decades. The focus 

of most of these programs has been on encouraging renewable 

electricity generation and, more recently, production of renewable 

transportation fuels, such as ethanol. The third area of energy 

use—thermal applications for heat, cooling and industrial process 

heat—has not been a focus of federal energy programs until very 

recently. A summary of the full scope of existing federal programs 

and incentives related to the development of biomass energy 

facilities is included as Appendix 1-A to this report.

Federal policy initially encouraged renewable electricity generation 

by requiring utilities to purchase electricity from renewable energy 

generators at a fixed cost through the Public Utility Regulatory 

Policy Act (PURPA). More recently, federal policy has shifted 

towards encouraging renewable energy through tax incentives and 

direct grants—with the primary focus on renewable transportation fuels and renewable electricity generation. 

The thrust of current federal investment in renewable energy is 

summarized in a recent report by the Environmental Law Institute 

(Environmental Law Institute, 2009). From 2002 through 2008 

the U.S. Government spent approximately $29 billion on renewable 

energy subsidies (compared to $72 billion spent on fossil fuels). 

Of this $29 billion, most was dedicated to transportation fuels 

or electricity generation through a combination of tax programs 

and direct grants and loans. 

• Transportation fuels via corn-based ethanol production 

received more than half of the total subsidies ($16 billion), 

primarily through the Volumetric Ethanol Excise Tax Credit 

Program (VEETC) ($11 billion) and the corn-based ethanol 

grant program ($5 billion). 

• Renewable electricity generation projects received 

approximately $6 billion in subsidies during this 

seven-year period, principally through the Production 

Tax Credit ($5 billion), the Investment Tax Credit 

($250 million), the Modified Accelerated Cost Recovery 

System ($200 million), and the Clean Renewable Energy 

Bond program ($85 million). 

• Thermal energy as a sector received no significant 

subsidies.

Within the electric power sector biomass facilities are eligible for 

funding under these four primary renewable electricity generation 
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The Commodity Credit Corporation (CCC) has issued a draft 

rule to implement BCAP specifying the requirements for eligible 

participants, biomass conversion facilities, and biomass crops and 

materials. Public comment on the draft rule closed on April 9, 2010. 

Comments on the rule address a diversity of issues ranging from 

overall support for the continuation of the program to concern that 

the initial focus on CHST payments has resulted in a substantial 

new subsidy for the existing woody-biomass market, creating market 

distortions and instability in the supply sector, cutting costs for 

some users (e.g., biomass power plants) and increasing costs for 

other competing industries (OSB manufacturers and other users 

of bark and chips). In addition, some comments have raised the 

issue of the absence of forest management requirements in BCAP 

could encourage overcutting in response to the short term subsidy 

to suppliers. Others have spoken to the need to focus BCAP on 

directing more resources towards the establishment and production of new energy crops, so the program can fulfill its purpose of 

expanding the amount of biomass available for alternative energy.

1.3.2 Environmental Protection Agency 

Position on Biomass Energy and Carbon 

Accounting5

As determined by the Environmental Protection Agency in their 

final rule on Mandatory Reporting of Greenhouse Gases, electric 

generation and thermal facilities are not required to count emissions associated with biomass combustion when determining 

whether they meet or exceed the threshold for reporting (emission of 25,000 metric tons per year for all aggregated sources at a 

facility). But if the threshold is exceeded, facilities are required to 

separately report emissions associated with the biomass combustion. Thus, facilities that rely primarily on biomass fuels are not 

be required to report under the rule (EPA, 2009).

This approach is consistent with IPCC Guidelines for National 

Greenhouse Gas Inventories, which require the separate reporting 

of CO2 emissions from biomass combustion, and the approach 

taken in the U.S. Inventory of Greenhouse Gas Emissions and 

Sinks. Separate reporting of emissions from biomass combustion 

is also consistent with some State and regional GHG programs, 

such as California’s mandatory GHG reporting program, the 

Western Climate Initiative, and The Climate Registry, all of 

which require reporting of biogenic emissions from stationary 

fuel combustion sources. While this reporting requirement does 

not imply whether emissions from combustion of biomass will or 

will not be regulated in the future, the data collected will improve 

EPA’s understanding of the extent of biomass combustion and 

the sectors of the economy where biomass fuels are used. It will 

also allow EPA to improve methods for quantifying emissions 

through testing of biomass fuels.

5 Much of this section is drawn directly and/or quoted verbatim 

from the EPA’s Response to Public Comments Volume No.: 1 

Selection of Source Categories to Report and Level of Reporting, 

September 2009

The program pays for up to 75% of establishment costs of new 

energy crops. In addition, farmers participating in a selected 

BCAP project area surrounding a qualifying BCF can collect 

five years of payments (15 years for woody biomass) for the 

establishment of new energy crops. An additional matching 

payment of up to $45/ton (on a $1 to $1 basis) to assist with 

collection, harvest, storage and transportation (CHST) of an 

eligible material to a BCF will also be available for a period of 

two years. 

The launch of this new program has resulted in a substantial new 

subsidy for the existing wood market with significant market 

impact. Large numbers of existing biomass conversion facilities (led by lumber, pellet and paper mills currently burning wood 

for their own energy use without a federal subsidy) submitted 

applications to USDA to be approved as qualifying facilities. 

Consequently, funds obligated (though not yet spent) for BCAP 

through the end of March 2010 soared to over $500 million, 

more than seven times BCAP’s estimated budget of $70 million 

in the 2008 Farm Bill. The USDA now estimates BCAP costs 

at $2.1 billion on CHST from 2010 through 2013.

USDA has allocated $2.1 million to Massachusetts for BCAP 

payments and $500,000 has been dispersed to date. Despite 

broad outreach (11 public meetings and other efforts), BCAP 

enrollment has been limited in the state, probably due to the 

limited array of biomass facilities. In Massachusetts, there are two 

qualifying biomass conversion facilities (BCF): Pinetree Power 

(17 MW electric generation facility) and LaSalle Florists, a very 

small greenhouse operation (USDA, 2010). Pinetree Power has 

about 20–25 suppliers that are approved eligible material owners 

(EMO). Based on interviews with procurement personnel at the 

Pinetree facility, the long-term impact of BCAP is unknown at 

this point. Overall, it is perceived to have created instability in 

the supply sector, potentially cutting costs for the electric power 

industry, but increasing costs for other competing industries that 

are not enrolled in the program. In Pinetree’s view, it also might 

encourage overcutting in response to the short-term subsidy to 

suppliers. The lack of forest management requirements for the 

program was also noted. 4

Based on interviews with Cousineau Forest Products, a leader in 

the wood brokerage industry for pulp, chips and biomass supplies 

across New England and the east, approximately 50% of the BCAP 

subsidy is being passed onto qualifying facilities from suppliers in 

the form of lower prices paid for fuel. Consequently, as currently 

structured, the BCAP program is significantly lowering fuel costs 

for the biomass power sector. Where landholdings are small, such 

as in Massachusetts, these savings generally accrue to loggers and 

the biomass consumers. In areas with larger landholdings, more 

of these savings go to landowners.

4 Pinetree Power information based on interviews with Tim 

Haley who prepared their BCAP application and Jamie Damman 

(M.S.) forester and wood buyer for North Country Procurement, 

consultant to Pinetree Power.
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Biomass Sustainability and Carbon Policy Study

of thermal energy. In all of the various versions of these bills, 

energy produced from biomass is considered to be renewable 

and carbon neutral and generally excluded from proposed caps 

on carbon emissions and related proposals for carbon emission 

allowances. There is continuing debate about the definition of 

biomass from qualifying sources and various proposals to provide 

safeguards for natural resources on public and/or private lands. 

This debate also includes consideration of sustainability requirements or guidelines for biomass to qualify as a renewable fuel. 

There is concern that aggressive targets for increasing the use of 

biomass for production of renewable electricity and transportation fuels from the current Renewable Fuels Standard, a proposed 

Renewable Electricity Standard and a limit on carbon emissions 

would outstrip the capacity of our nation’s forests to provide 

an economically and ecologically sustainable supply. To ensure 

sustainable harvesting levels and accurate accounting of carbon 

emissions and re-sequestration, there is discussion and debate 

about including emissions from renewable biomass energy under 

proposed carbon caps based on full lifecycle accounting. At this 

point, however, it is unclear what direction will emerge in this 

developing legislation. 

1.4 Massachusetts Forest Biomass Energy 

Policies

Massachusetts has implemented policies to increase the use 

of biomass to meet energy needs in the electricity sector, the 

transportation sector, and the building heating sector, although 

as is the case at the federal level, state policies have been focused 

primarily on using biomass to replace fossil fuels in the electricity 

and transportation sectors. Combined with the state’s regulatory 

structure for implementing the Regional Greenhouse Gas Initiative (RGGI) (which sets an emissions cap on fossil fuel electrical 

generation systems of 25 megawatts or greater), this has created 

significant incentives driving the state towards greater reliance 

on biomass electric generation capacity. A recent exception to 

this trend is the Massachusetts Green Communities Act of 

2008, which established new Renewable and Alternative Energy 

Portfolio Standards (RPS and APS) that allow eligible CHP 

units to receive credits for useful thermal energy. This program 

promotes the installation and effective operation of new CHP 

units for residential, commercial, industrial, and institutional 

applications. Overall, the bill significantly reforms the state’s 

energy policy, and makes large new commitments to electric 

and natural gas energy efficiency programs, renewables, and 

clean fossil fuels like combined heat and power (Environment 

Northeast, 2008).

Massachusetts has two regulatory programs that directly impact 

the incentives for developing biomass-fueled electricity in the 

state. The first is the Massachusetts Renewable Portfolio Standard (RPS), which is administered by the Department of Energy 

Resources (DOER), and the second is the implementation of the 

state’s membership in the Regional Greenhouse Gas Initiative 

(RGGI), which is administered by the Department of Environmental Protection (DEP). 

This rule is based on the EPA’s basic premise that burning biomass 

for energy is considered to be carbon-neutral when considered in 

the context of natural carbon cycling: 

Although the burning of biomass also produces carbon dioxide, 

the primary greenhouse gas, it is considered to be part of the 

natural carbon cycle of the earth. The plants take up carbon 

dioxide from the air while they are growing and then return 

it to the air when they are burned, thereby causing no net 

increase. Biomass contains much less sulfur and nitrogen 

than coal; therefore, when biomass is co-fired with coal, sulfur 

dioxide and nitrogen oxides emissions are lower than when coal 

is burned alone. When the role of renewable biomass in the 

carbon cycle is considered, the carbon dioxide emissions that 

result from co-firing biomass with coal are lower than those 

from burning coal alone (EPA, 2010).

Regarding consideration of life-cycle emissions, the EPA has 

stated that preparation of a complete life cycle analysis is beyond 

the scope of this rule:

With respect to emissions and sequestration from 

agricultural sources and other land uses, the rule 

does not require reporting of emissions or sequestration associated with deforestation, carbon storage in 

living biomass or harvested wood products. These categories were excluded because currently available, practical 

reporting methods to calculate facility-level emissions for 

these sources can be difficult to implement and can yield 

uncertain results. Currently, there are no direct 

GHG emission measurement methods available 

except for research methods that are very expensive and 

require sophisticated equipment (EPA, 2009).

Regarding biomass-derived transportation fuels, the Energy 

Independence and Security Act of 2007 (EISA) (P.L. 110–140) 

required EPA to establish a rule for mandatory lifecycle GHG 

reduction thresholds for various renewable liquid transportation fuel production pathways, including those using wood as a 

feedstock. Each qualifying renewable fuel must demonstrate that 

net GHG emissions are less than the lifecycle GHG emissions of 

the 2005 baseline average for the fossil fuel that it replaces. For 

non-agricultural feedstocks, renewable fuel producers can comply 

with the regulation by: (1) collecting and maintaining appropriate 

records from their feedstock suppliers in order to demonstrate 

that feedstocks are produced in a manner that is consistent with 

the renewable biomass requirements outlined in the ruling, or 

(2) fund an independent third party to conduct annual renewable biomass quality-assurance audits based on an a framework 

approved by EPA.

1.3.3 Pending Federal Climate and Energy 

Legislation

Pending federal climate and energy legislation continues to be in 

flux, with an uncertain future and significantly evolving content. 

Overall, these bills focus primarily on the production of renewable electricity and transportation fuels rather than production 
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Biomass Sustainability and Carbon Policy Study

significant factor in the economics of biomass power generation 

and a significant factor in negotiating Power Purchase Agreements. The current market price for REC’s is between $20–$40 

per MWh and the average monthly price for electricity in the 

ISO New England region from March 2003—February 2010 

is $62/MWh (ISO New England, 2010). At these rates (which 

have been even higher in past years with REC’s bringing up to 

$50/MWh) REC’s are clearly a major, though variable, factor in 

a biomass power plant’s return on investment. 

1.4.2 Massachusetts RGGI Implementation

As a member of the Regional Greenhouse Gas Initiative (RGGI), 

Massachusetts has agreed with ten other states to cap carbon 

dioxide emissions from large (i.e. > 25 MWe) fossil fuel-fired 

electric power plants in the ten-state region, and to lower this 

cap over time. Each individual state has adopted regulations to 

create allowances corresponding to their share of the cap, and 

to implement accounting, trading, and monitoring regulations 

necessary to control emissions. Any allowance can be used for 

compliance with any state’s RGGI regulation. The RGGI Model 

Rule provides a template on which all state regulations are based.

The RGGI Model Rule includes three provisions related to the 

combustion of biomass fuels. The first exempts facilities whose 

fuel composition is 95% or greater biomass from the program. 

The second allows projects that achieve emissions reductions by 

switching to certain biomass-derived fuels for heating to apply to 

create offset allowances. The third applies to regulated facilities 

that co-fire biomass fuels with fossil fuels, or switch completely 

from fossil to biomass fuel. In such cases, emissions that result 

from the combustion of “eligible biomass” fuels are not counted 

toward compliance obligations. Massachusetts’ RGGI regulation includes all three of these provisions, but no power plant 

or offset project in the state has yet applied to take advantage of 

the co-firing or offset provisions. The definition of below is from 

Massachusetts’ RGGI regulation:

El ig ibl e biom a ss . Elig ible bioma ss includes 

sustainably harvested woody and herbaceous fuel sources 

that are available on a renewable or recurring basis 

(excluding old-growth timber), including dedicated 

energy crops and trees, agricultural food and feed crop 

residues, aquatic plants, unadulterated wood and wood 

residues, animal wastes, other clean organic wastes not 

mixed with other solid wastes, and biogas derived from 

such fuel sources. Liquid biofuels do not qualify as eligible 

biomass. Sustainably harvested shall be determined by the 

Department [of Environmental Protection].

In addition to the complete exemption from the RGGI system 

for generators whose fuel composition is 95 percent or greater 

biomass, the RGGI Model Rule and all participating states 

except for Maine and Vermont provide partial exemptions for 

facilities that co-fire with smaller percentages of biomass. This 

partial exemption provides that any carbon dioxide emissions 

attributable to “eligible biomass” may be deducted from a facil1.4.1 Massachusetts Renewable Portfolio 

Standard

The Massachusetts RPS program currently mandates that all 

retail electricity suppliers must include minimum percentages 

of RPS Class I Renewable Generation, RPS Class II Renewable 

Generation, and RPS Class II Waste Energy in the retail electricity 

they sell to consumers. For 2010, the Class I requirement is 5%, 

the Class II Renewable requirement is 3.6%, and the Class II 

Waste requirement is 3.5%. The definition of “eligible biomass 

fuel” under the RPS program is:

Fuel sources including brush, stumps, lumber ends and 

trimmings, wood pallets, bark, wood chips, shavings, 

slash and other clean wood that are not mixed with other 

unsorted solid wastes; by-products or waste from animals 

or agricultural crops; food or vegetative material; energy 

crops; algae; organic refuse-derived fuel; anaerobic digester 

gas and other biogases that are derived from such resources; 

and neat Eligible Liquid Biofuel that is derived from such 

fuel sources.

It is notable that this definition contains no “sustainability” 

requirement. The RGGI definition, by contrast, does contain 

such a requirement, though the criteria for sustainability in that 

definition are not fleshed out at this time. This definition also 

includes liquid biofuels, which are expressly excluded from the 

definition of “eligible biomass” for purposes of the Massachusetts 

RGGI program. 

Biomass facilities may qualify as RPS Class I or Class II generation units as long as they are classified as “low-emission, advanced 

biomass Power Conversion Technologies using an Eligible Biomass 

Fuel.” Both the Class I and Class II RPS regulations also allow 

generators that co-fire to qualify as RPS Renewable Generation 

as long as certain requirements are met. This provision in the RPS 

program is analogous to the biomass exemption from carbon 

dioxide emissions accounting in the RGGI program.

In 2008, the Massachusetts Green Communities Act established 

new Renewable and Alternative Energy Portfolio Standards (RPS 

and APS) allowing Combined Heat and Power facilities to be 

included as an eligible technology, provided the thermal output 

of a CHP unit is used in Massachusetts. APS eligible CHP units 

receive credits for the useful thermal energy of a CHP unit delivered to Massachusetts end-uses, subject to the formula included 

in the regulations. The DOER rules issued for this program will, 

for the first time in the Commonwealth, promote the installation 

of new CHP units for residential, commercial, industrial, and 

institutional applications. 

A central component of the Massachusetts RPS program is the 

issuance of Renewable Energy Credits (REC’s) for biomass-fueled 

electric power generation, providing a significant incentive and 

market driver for large-scale biomass electric power generation. 

While the market price for REC’s varies significantly based on 

state RPS requirements, the available pool of qualifying renewable 

energy sources, and overall demand for electricity, they are a very 
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programs; public benefits funds; other grant and/or loan programs; 

power purchasing programs at the state and/or local level; and a 

variety of tax incentives. 6

States with large sources of biomass supply—Minnesota, Missouri, 

Oregon, Washington and Wisconsin—also tend to have biomassspecific policies or programs in addition to general programs such 

as renewable portfolio standards. These states are also likely to 

have biomass working groups or a biomass program (Connecticut, 

Minnesota, Oregon, Pennsylvania, and Vermont). Some have 

produced biomass reports, including woody biomass supply assessments. (Arizona, California, Minnesota, Oregon, Vermont, 

Washington, and Wisconsin). These reports typically focus more 

on biomass promotion and less on sustainability, and some discuss 

the linkage between biomass utilization and climate change. 

Finally, some states have produced woody biomass harvesting 

guidelines that focus on best management practices for harvesting 

woody biomass in an ecologically sensitive and sustainable manner 

(Minnesota, Missouri, Pennsylvania, and Wisconsin). All such 

harvesting guidelines are voluntary guidance only.

1.6 Overall State and Federal Policy Drivers 

for Biomass Power in Massachusetts

While conclusive data on the cumulative amounts and impacts 

of the suite of state and federal policies relevant to biomass power 

are not available, interviews with plant managers and experts 

in the field of electric power regulation and development7 and 

analyses of federal subsidies indicate that, generally, the most 

important federal subsidy is the Production Tax credit ($10 

per MWh) and most important state incentives are Renewable 

Portfolio Standards and the related sale of Renewable Energy 

Credits (currently $25–$35 per MWh). While the value of a 

REC is higher, the price varies significantly in the marketplace 

with the cycling of RPS requirements, emergence of new technologies, construction of new renewable energy facilities, the 

state of the economy and demand for electric power. While less 

valuable at only $10/MWh, the federal PTC is a more stable 

source of income for biomass plants over time.

Overall, the economics of individual biomass power plants are 

determined by the Power Purchase Agreement (PPA), which 

defines a long-term contract for the purchase of power from a 

generating facility to utilities or other buyers in the electric power 

market. PPA’s include some or all of the power produced by the 

generating facility and can also include some or all of the REC’s 

held by a facility in long term contracts. Overall, banks and other 

investors need confidence in a credible investment stream stemming from a contract including an adequate price (for power and 

6 For a description of the range of tax incentive programs, see the 

public policy program appendix to this report

7 Synapse Energ y Economics, Cambridge, Massachusetts; 

Innovative Natural Resource Solutions, Portland, ME; Mc Neill 

Generating Station, Burlington VT; Schiller Station, Portsmouth, 

NH; Ryegate Power Station, East Ryegate, VT.

ity’s total carbon dioxide emissions when calculating whether 

the facility’s emissions are within its carbon-allowance budget. 

Regarding the impact of the Regional Greenhouse Gas Initiative 

(RGGI) as an incentive for biomass electric power generation, since 

RGGI defines biomass power as carbon neutral and exempt from 

participation in the carbon allowance program and categorically 

excludes biomass power from allowable offsets qualifying for 

carbon allowances, biomass energy receives no direct incentives 

through the carbon allowance auction program central to RGGI 

implementation. It might be incentivized, however, through state 

investments in clean energy from auction revenues allocated to 

consumer benefit and renewable energy and efficiency programs. 

In Massachusetts, these revenues are allocated to five uses, as 

follows, based on the recently passed 2008 Green Communities Act: promotion of energy efficiency and demand response 

(minimum of 80% of revenue); reimbursement of municipalities in which tax receipts decrease due to RGGI (limited to 3 

years); green communities (not to exceed $10 million per year); 

zero-interest loans to some municipalities for efficiency projects; 

and, state administration of the cap and trade program (Green 

Communities Act, 2008).

In terms of the impact of the RGGI program on the development 

of biomass generating facilities, should auction prices rise sufficiently, they could provide an incentive for generating facilities 

to switch to biomass as a power source, or for the construction of 

new biomass-fired power plants. However, at current allowance 

prices of approximately $2 per ton of carbon dioxide, there is 

insufficient price pressure to incentivize such a shift at this time 

(RGGI, Inc, 2010). 

A summary of the range of statutory and regulatory provisions 

that directly address biomass in Massachusetts, with an emphasis 

on biomass policy within the electricity sector, is included in 

Appendix 1-A to this report.

1.5 Biomass Energy Policies in Other States 

Based on a review of eleven states’ policies regarding biomass 

(Arizona, California, Connecticut, Maryland, Minnesota, 

Missouri, Oregon, Pennsylvania, Vermont, Washington, and 

Wisconsin), the thrust of state policies promoting biomass and/or 

biofuels is focused on electric generation and less so on transportation and thermal. All surveyed states have numerous policies, 

programs and/or incentives to promote electric generation from 

renewable sources of energy, including biomass. A few states have 

policies to support the use of biomass/biofuels for transportation 

(California, Minnesota, Oregon, Pennsylvania, Washington, and 

Wisconsin) and/or for thermal production (Arizona, Connecticut, 

Missouri, Oregon, Pennsylvania, Vermont, Washington, and 

Wisconsin).

Typically, states include biomass as one of a number of sources 

of renewable energy in a variety of policies and programs aimed 

at increasing electric generation from renewable energy such 

as renewable portfolio standards. Other common state policies supportive of biomass electric generation are net metering 
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Biomass Sustainability and Carbon Policy Study

References

Commission of European Communities. (2005). Biomass Action Plan 

Communication from the Commission . Retrieved from http://eur-lex.

europa.eu/smartapi/cgi/sga_doc?smartapi!celexplus!prod!DocNumbe

r&lg=en&type_doc=COMfinal&an_doc=2005&nu_doc=628

Commission of European Communities. (2006). Communication 

from the Commission to the Council and the European Parliament 

on an EU Forest Action Plan. Brussels.

EU. (2006). The EU Forest Action Plan. European Commission on 

Agriculture and Rural Development 2007–2011.

Energy Information Administration. (2008). Federal Financial 

Interventions and Subsidies in Energy Markets 2007.

Environmental Law Institute. (2009). Estimating US Government 

Subsidies to Energy Sources: 2002–2008

Environment Northeast. (2008). Summary of Massachusetts 2008 

Energy Bill, An Act Relative to Green Communities, Senate Bill No. 

2768, June 25, 2008

European Parliament and Council. (2009). Directive 2009/28/EC of 

the European Parliament and of the Council of 23 April 2009 on the 

promotion of the use of energy from renewable sources and amending 

and subsequently repealing Directives 2001/77/EC and 2003/30/EC.

Retrieved from http://eur-ex.europa.eu/smartapi/cgi/sga_doc?smartapi

!celexplus!prod!CELEXnumdoc&lg=EN&numdoc=32009L0028

EPA. 2009. 40 CFR 86, 87, 89 et. al. October 30, 2009.

EPA. 2009. Federal Register / Vol. 74, No. 209 / Friday, October 30, 

2009 / Rules and Regulations

EPA. 2010. Air Emissions. Retrieved 2010 from EPA: http://www.

epa.gov/cleanenergy/energy-and-you/affect/air-emissions.html

Green Communities Act. (2008). Chapter 169 of the Acts of 2008, 

An Act Relative to Green Communities.

IEA Bioenergy. (2009). Bioenergy—a Sustainable and Reliable 

Energy Source. Energy Research Centre of the Netherlands, E4Tech, 

Chalmers University of Technology, and the Copernicus Institute of 

the University of Utrecht.

IEA Bioenergy. (NA). IEA Bioenergy Strategic Plan 1998–2002.

IEA Bioenergy. (1995). Progress and Achievements 1992–1994. 

Retrieved from IEA Bioenergy: www.ieabioenergy.com/DownLoad.

aspx?DocId=1027

IEA Bioenergy. (2010). What is IEA Bioenergy? Retrieved 2010, from 

IEA Bioenergy: www.ieabioenergy.com/IEABionergy.aspx

International Energy Agency. (2010). Energy Security. Retrieved 2010, 

from IEA: www.iea.org/subjectqueries/keyresult.asp?KEYWORD_

ID=4103

International Energy Agency. (2007). Good Practice Guidelines: 

Bioenergy Project Development & Biomass Supply. Paris: International 

Energy Agency.

IPCC. (2007). Contribution of Working Group III to the Fourth 

Assessment Report. Intergovernmental Panel on Climate Change.

IPCC. (2000). Land Use, Land Use Change and Forestry. 

Intergovernmental Panel on Climate Change.

ISO New England, Inc. (2010). SMD Monthly, Daily LMP

possibly REC’s) over a sufficiently long period of time to satisfy 

the debt service for the facility. It is worth noting that only one 

new biomass power plant has been built in the region since the 

advent of REC’s (Schiller) and that RECs are considered to be 

an important feature in its financial picture. 

After the Power Purchase Agreement, the second largest cost 

variable involved in the finances of a biomass power plant is fuel 

supply and pricing. For example, the Ryegate plant in Vermont 

and Schiller plant in New Hampshire spend between 60% and 

70% of their operating costs on fuel purchases and generally, 

costs in excess of $30–$35 per ton are considered the maximums 

if biomass power is to remain competitive with other fossil fuel 

capacity.8

 Given the relative importance of fuel purchases on 

operating costs, BCAP payments could play a significant role in 

incentivizing power plants over other non-energy biomass uses 

in Massachusetts if a continued high level of subsidy to suppliers 

of biomass to qualifying electric generation facilities lowers 

fuel supply costs for the power sector. However, given current 

Congressional review of the BCAP program and the USDA 

rulemaking process, it is considered unlikely that current levels 

of subsidies will continue.

Regarding relative incentives for the construction and location of 

biomass power plants in Massachusetts versus other New England 

states, it does not appear that there are significant subsidies or 

incentives in existing public policy that make Massachusetts more 

or less likely to attract new biomass power plant proposals. While 

Massachusetts does have a strong market for REC’s due to their 

well-established and aggressive RPS program, this does not provide 

any particular incentive for building qualifying plants in Massachusetts versus surrounding states. Furthermore, Massachusetts 

is not unique in having a number of current biomass power plant 

proposals. Vermont currently has 5 to 8 proposals in varying stages 

of discussion; New Hampshire has two major projects that have 

come and gone over the past few years; etc.9

 To further illustrate 

the scale and scope of biomass power plant proposals across the 

region, over the past ten years, there have been 243 biomass power 

plant proposals in the ISO New England region, with only one 

new plant constructed Schiller Power Plant, NH). 

Overall, federal and state policies and incentives are responsible for 

the trend within the biomass industry to propose large-scale 

electric generation facilities in Massachusetts and elsewhere 

in the country.

8 $30–$35 per ton for wood purchase is the breaking point as reported 

in interviews with the Ryegate and Schiller power plants and is also 

consistent with independent research conducted by the Biomass Energy 

Resource Center.

9 Recent Vermont biomass power plant proposals include: 20–25 

MW plant in Ludlow, 20–30 MW plant in Rutland, two 20–30MW 

combined pellet mill/biomass plants in Pownal and Fair Haven, 20–

30MW plant in North Springfield. Recent New Hampshire biomass 

power plant proposals include: 70MW power plant in Berlin, 50–70 

MW power plant (in combination with a celluslosic ethanol plant) in 

Groveton.
Manomet Center for Conservation Sciences 19 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Johnson, E. (2008). Goodbye to carbon neutral: Getting biomass 

footprints right. Environmental Impact Assessment Review 

Marland, G., & Schlamadinger, B. (1995). Biomass Fuels and 

Forest-Management Strategies: How do We Calculate the 

Greenhouse Gas Emission Benefits? Energy—The international 

Journal , 20 (11), 1131–1140.

MGT Power. (2010). MGT Projects. Retrieved 2010, from MGT 

Power: http://www.mgtpower.com/projects.php

Renewable Energy Policy Network for the 21st Century. (2009). 

Renewables Global Status Report 2009 Update. Paris.

RGGI, Inc. (2010). March 12, 2010 Press Release “RGGI CO2 

Auctions Yield Millions for Investment in Clean Energy, Job Creation”

Searchinger, T., Hamburg, S., Mellilo, J., Chameides, W., Havlik, 

P., Kammen, D., et al. (2009). Fixing a Critical Climate Accounting 

Error. Science , 326, 527–528.

USDA. (2010). Farm Service Agency Biomass Crop Assistance Program

Retrieved 2010, from USDA http://www.fsa.usda.gov/FSA/webapp?

area=home&subject=ener&topic=bcap
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Biomass Sustainability and Carbon Policy Study

Chapter 2

Technology Pathways

2.1 Introduction to Technology Options

Biomass in various forms can be used for a range of energy options, 

through a variety of technologies, to achieve various end purposes. 

In this chapter, we are looking at several pathways to give the reader 

an understanding of this range, but also to inform and model 

potential demand for fuel supply in the future (Chapter 3), and to 

understand the carbon implications for these choices (Chapter 6). 

This assessment looks exclusively at the use of existing low-grade 

forest resources in Massachusetts and surrounding counties in 

neighboring states, as opposed to agricultural crops or residues 

or plantation trees and crops which can also provide biomass for 

energy. Sources of non-forest based biomass, such as wood waste 

from construction debris, or other sources sometimes considered 

as biomass, such as municipal waste, were not considered. 

With respect to the forest’s low-grade wood resource potentially 

used for energy, the end products can be solid—such as cordwood, wood chips, or wood pellets—liquid, such as pyrolysis 

oil or cellulosic ethanol, or gas—synthetic or producer gas made 

through “gasification” and “bio-char” technologies. Finally, the 

end uses can range from residential to industrial applications, 

and fall into three general categories: electricity power production, thermal applications for heating (and cooling), or emerging 

technologies such as cellulosic ethanol or gasification. Between 

the first two categories, is combined heat and power (CHP), 

which in turn can be thermally led (optimizing heat production 

with some electricity produced) or electricity-led (sizing the plant 

for optimal electricity production and using some of the heat). 

Some of these technologies and applications are well established 

and have been in place for years and others are pre-commercial or 

still under development. In the sections that follow, we describe two 

main currently available applications for electricity and thermal 

production, with CHP discussed in a subsequent section. This 

discussion focuses on those technologies and applications that 

are already well established, or are technologically available in the 

immediate future should policies wish to guide additional biomass 

in these directions. These are the applications most likely to place 

demands on Massachusetts’ forest resources in the short term. 

Still, because of the amount of federal investment for research 

and development in some of the emerging technologies, which, 

if realized, have the potential to significantly affect demand for 

forest resources (such as cellulosic ethanol), a third category 

of applications is discussed in Section 2.5, entitled “Emerging 

Technologies.” All of the liquid biofuels options for producing 

transportation fuels fall into this category, as does gasification 

and bio-char production. 

Among these application areas, we selected 12 technology pathways 

to describe how biomass might be used, and compared them to 

their six fossil fuel equivalent applications. These are described 

in Appendix 2-A, and summarized in Appendix 2-B. 

2.2 Electricity Generation

2.2.1 Current Sources of Electrical Supply 

Massachusetts uses about 55.8 million Megawatt hours (MWH) 

of electricity (Energy Information Administration—EIA, 2010) 

and produces about 47.1 million MWH (EIA, 2007). Massachusetts is a member of ISO New England, which is responsible for 

wheeling power throughout the region and bringing in power 

from other regions as needed. Of the power the state produces, 

renewables account for about two million MWH (4.3 percent), 

with biomass power generation accounting for 119,000 MWH, 

or six percent of the renewable portfolio and 0.3 percent of total 

production (EIA, 2007). Ten natural gas-fired power plants are 

now the state’s leading power producers, accounting for over 

half of net generation. Coal, primarily from Colorado and West 

Virginia, is the state’s second leading generation fuel; it is used in 

four plants and accounts for about 25 percent of net electricity 

production. Massachusetts also uses oil-fired systems (seven 

existing plants—although oil has been increasingly replaced by 

natural gas over the past decade) and nuclear from the Pilgrim 

plant to round out the remaining percentages of its profile. Of 

the renewables, landfill gas is the largest contributor, accounting 

for about 1.1 million MW followed by hydroelectric generation 

at 797,000 MWH (EIA, 2010). 

The nuclear facility, all of the fossil fuel based power, and solid-fuel 

biomass power plants all use steam turbine technology, which has 

the common attribute of being approximately 25 to 32 percent 

efficient at converting the energy value of the fuel to electricity. 

Unused heat in these systems is released through cooling towers, 

or through heat exchanged in Cape Cod Bay in the case of the 

Pilgrim Nuclear facility (Entergy, 2008). The four coal facilities 

use 382,000 tons of coal each year (EIA, 2007), and the wood 

facilities1, at full operation, would use approximately 215,000 

green tons annually (INRS, 2007). 

2.2.2 Electrical Generation Pathways

Pathways 1–4 describe the range of power facilities used now, 

and for the foreseeable future, to produce electricity. Pathway 

#1 assumes a 50 MW biomass powered facility, and enables 

comparison to two fossil fuel options for coal (Pathway #3) 

and natural gas (Pathway #4) as well as a co-firing option where 

wood is substituted for 20 percent of the coal at a coal-fired 

unit (Pathway #2).

All pathways assume advanced pollution controls as needed 

to ensure the units are performing to meet expected pollution 

control objectives, but the efficiency is an average based on 

present performance of units in use today. Generally, this is 

32 percent for coal, 20–25 percent for woody biomass, and 33 

percent for natural gas (Appendix 2-B). 

1 There are two wood-fired electrical facilities in Massachusetts: 

Pinetree-Fitchburg (14 MW) which is operating and Ware Co-Gen 

(8.6 MW) which is idle (INRS at 40).
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Exhibit 2-2 presents efficiency, particulate, and CO2 emissions 

associated with these residential applications.

2.3.1.2 Institutional Biomass Forms and Uses

Use of biomass for heat and hot water in community buildings, 

institutions, etc. has had limited application in Massachusetts. 

Two examples are: Quabbin Reservoir Administrative Building 

in Belchertown, and Mount Wachusett Community College 

in Gardner. The Quabbin system was installed in 2008 and 

uses 350 tons of wood per year to displace 22,000 gallons of #2 

heating oil (Biomass Energy Resource Center-BERC, 2010). It 

is 2.0 MMBtu/hr in size. The Mount Wachusett system is 8.0 

MMBtu/hr in size, was installed in 2002 and uses between 

1,200 and 1,400 tons of wood each year (BERC, 2010). This 

system replaced electric heating, and the college estimates it 

has saved 30 million kWh of electricity in the eight years of 

operation (BERC, 2010). The technology for these systems uses 

centralized hot water-based boilers and underground insulated 

pipe distribution systems. 

Other applications of this scale of system are used in several schools. 

Several colleges are considering conversion to biomass, including 

UMASS Amherst, and the VA hospital in Northampton.

2.3.2  Thermal Production Pathways

Pathways 5–10 describe the range of applications that may be used 

for thermal production, beginning with cordwood systems that 

would serve a typical home (Pathways #5 and #6). These boilers 

represent small systems that, at 100,000 Btu/hr, would be used to 

serve a small business or residence. The difference between these 

two pathways is that Pathway #6 represents an EPA-certified boiler 

that is more efficient and therefore has fewer carbon emissions 

per energy output than Pathway #5. 

Pathway #7 describes a pellet system, separated into two parts 

in order to compare effectively with other sources of thermal 

energy presented—pellet manufacturing is Pathway 7A and 

covers the process of using green wood chips to produce pellets, 

and Pathway 7B describes the use of these pellets in a typical 

commercial or institutional setting, sized at 5.0 MMBtu/hr. 

When considering pellets and comparing to other fuels with 

respect to harvesting needs and carbon impacts, it is important 

to consider both pathways.

The following chart (Exhibit 2-1) presents the CO2 emissions for 

the four electrical generation pathways.

These pathways are used to evaluate and compare different scenarios 

for forest management and carbon impacts if policies are directing 

biomass use toward stand-alone electrical generation, and to enable 

comparison to the most likely fossil fuel alternatives. Of all the 

fuels considered, natural gas is the cleanest and the lowest carbon 

emitting due to its ability to generate power using a direct combustion turbine at higher efficiency than traditional steam turbine 

technologies, and the fact that it has less carbon per unit of energy. 

2.3 Thermal Production

Roughly one-third of the nation’s energy demands are thermal 

demands for heat, hot water, cooling, and industrial process heat 

(EIA,2008),. In the Northeast, this percentage is even higher, 

with the region using 82 percent of the nation’s home heating oil 

(EIA, 2009). In Massachusetts, 42 percent of the households and 

businesses use #2 heating oil or propane as their primary source 

of heat (EIA, 2007). 

At the residential and community scale, biomass can be an effective means of using local wood resources and displacing fossil 

fuels efficiently. Generally, these thermal systems are between 75 

percent and 85 percent efficient (See Appendix 2-B). 

2.3.1 Current Sources of Thermal Supply 

2.3.1.1 Residential Biomass Forms and Uses

Biomass has been used to heat homes for millennia. The amount 

of biomass used to heat Massachusetts’ homes is not known, but 

is estimated at between one and two million green tons annually (Personal Communications, MADOER, 2010). Residential 

applications use biomass in fireplaces; wood stoves, furnaces, and 

boilers2; pellet stoves furnaces and boilers; and outdoor wood 

boilers. These applications decrease in efficiency (California Air 

Resources Board-CARB, 2005) and increase in emissions as one 

moves from pellet stoves and boilers to wood stoves and boilers 

to outdoor wood boilers to fireplaces. 

2 A stove is considered to be a stand-alone space-heating device, a 

furnace is a central hot air system, and a boiler is a central hydronic 

(hot water pipe and radiator) system.
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Thermally led CHP maximizes the demand for heat, but produces relatively little electricity. At the community scale, a typical CHP facility 

might produce 1–5 MW of electricity while heating a college campus 

or small community district of 200–500 homes and businesses. 

An important point to note is that the efficient scale of producing 

electricity alone leads to plants in the 20–50 MW size range. At 

this scale, it is more cost-effective to produce the power, and any 

CHP component is a complicating factor that tends to reduce 

the overall cost-effectiveness of the project under current policies. At smaller scale thermal-led CHP systems, the opposite 

is true—production of heat alone maximizes cost-effectiveness 

of the project, and adding an electrical component reduced the 

overall economics of the project, i.e. the savings in heat help 

subsidize the electrical generation components.

Conventional technology requires the production of steam to 

produce electricity, but European commercial technologies include 

gasification where the produced gas is combusted directly in a 

combustion turbine, or Organic Rankine Cycle (ORC) thermal 

oil technology which uses a thermal oil to gain temperature 

gradients necessary to produce electricity without steam, so that 

the thermal system can be designed around hot water, and at low 

pressure. The ORC system, while more easily incorporated into 

a hot-water based thermal application and therefore of greater 

potential in smaller CHP systems (see below), the ORC process 

is still only approximately 20% efficient on its own in the production of electricity, but would be expected to be between 75% and 

85% efficient in heat-led applications. Heat-led gasification can 

be expected to be approximately 75% efficient. (See Appendix 

2-B for sources of efficiency information). 

2.4.1 CHP Pathways

Pathways #11 and #12 describe moderate-sized CHP systems capable 

of producing 5.0 MW of electricity. The first uses conventional 

technology, producing steam to run a turbine, and fully utilizes the 

34 MMBtu/hr of heat generated to heat facilities on the order of 

magnitude of a college campus, a hospital, or small community. As 

such, the overall efficiency is rated at 75 percent. The second pathway 

uses gasification technology, which is just an emerging technology 

here in the United States. Still, there is an example of a commercial 

system operating since 2000 in the Town of Harboøre, Jutland, 

Denmark that produces 1.6 MW of electricity and heats 900 homes 

(BERC, 2010). The efficiency rating for this system is also 75 percent. 

Pathways #13 and #14 are the fossil fueled equivalent of the 

biomass CHP systems for oil and natural gas.

Exhibit 2-4 below presents CO2 emissions for the four CHP 

pathways considered.

Pathway #8 is a wood chip system sized at 50 MMBtu/hr, which 

would serve a community in a district energy system of the 

kind commonly used in Europe. Pathways #9 and #10 provide 

information about the fossil fuel equivalent versions of this system, 

using #6 heating oil and natural gas, respectively.

Exhibit 2-3 presents the CO2 emissions from these thermal pathways3: 

2.4 Combined Heat and Power Options

All electrical production from combustion of fuels creates excess 

heat that is often wasted. In the case of power plants, excess 

heat is often released through cooling towers, as steam from the 

turbine is condensed and returns to the boiler. Combined heat 

and power systems (CHP) seek to utilize some or all of this excess 

heat. As this excess heat is made into useful energy, the efficiency 

of the generating system increases with the proportion of heat it 

uses. Generally, using conventional technology, for each unit of 

electricity produced, three units of thermal energy are released. 

Electricity-led CHP is an option where power production is near 

a thermal demand. A 20 MW power plant produces enough 

heat to heat approximately 1,100 homes4. However, to date, the 

economics, incentives and siting preferences have not resulted in 

power plants choosing this route. As a result, regardless of the 

fuel source producing the electricity, approximately 75 percent of 

the energy value of the fuel has been wasted as lost heat. Taking 

advantage of this energy value requires planning, intentional 

siting, and either financial or regulatory incentives that promote 

power producers deciding to increase the complexity of their 

systems by the addition of steam or hot water as a salable output. 

This is not the business model that has been pursued to date. 

Recently, with the increased understanding of efficiency and 

concern about efficient use of resources, biomass power facilities are beginning to incorporate some CHP in their proposals, 

though because of the large amount of heat available relative to 

potential nearby uses, these projects often make use of only a 

small percentage of the available heat (10–15 percent).

3 As with the other exhibits which follow, the source of data for 

these charts is presented in Appendix 2-B

4 20 MW electric produces approximately 136 MMBtu/hr of heat. 

Residential heating typically uses 40 Btu’s/sq ft. Based on a 3,000 

square foot house, heating requirement is 120,000 Btu’s/hr, or 

1,137 homes.
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2.6 General Discussion and Summary

2.6.1 The Future Role of Biomass Under

Present Policies

Electricity demand is expected to increase by approximately 1.2 

percent annually, with a peak demand increase of 1.3 percent due 

to increased cooling demand in the summer (ISO New England 

Inc., 2009). Air pollution goals, as well as cost and projected 

supplies, will continue to drive new power production toward 

natural gas, but for the state’s RPS. In an attempt to reach 15 

percent by 2020, Massachusetts is looking to alternatives to 

fossil fuels to reach its goals. There are several significant wind 

projects in place and in planning, as well as solar projects, but 

as biomass power is “base load,” the trend has been to look 

to it to supply an increased share of the electricity portfolio. 

Over the next five to 10 years, barring a change in policy or incentives, or a dramatic change in the price of fossil fuel or electricity, 

we would expect the current pattern of incremental proposal 

and construction of stand-alone biomass power plants between 

20 MW and 50 MW to continue to be the major focus of the 

use of biomass. As described elsewhere, the pattern has been for 

many to be proposed (214 throughout New England over the 

past decade, with one constructed), and there are currently four 

proposals in Massachusetts. In part, the low ratio of “proposed” 

to “constructed” reflects the marginal economics of constructing 

plants based on the present cost of electricity, and the desire for 

investors to recoup costs of capital investment within a relatively 

short period of time—most private investors look for a return 

on investment of 20 percent within two to five years5. 

Events that can speed this up are if the wholesale rates of electricity 

increase substantially while the policy direction for renewables 

is maintained. In 2008, Massachusetts paid an average of 16.27 

cents/kWh retail for electricity, the fourth highest in the nation 

and highest in New England. It is doubtful that electricity prices 

will increase dramatically in the face of the downward regional and 

nationwide pressure on prices. If Renewable Electricity Credits 

(REC’s) rise in value and are stabile over a period of several years, 

this too would encourage construction of more power plants. 

5 It also reflects the tendency for proposers to announce projects at 

a very early stage of project development as a relatively easy means 

of assessing public acceptance of a given project, so the public 

announcements are not a good gauge of projects that are truly in 

advanced development and are likely to be built.

2.5 Emerging Technologies

There are several emerging technologies for using biomass that 

have the potential to change the demand for low-grade wood 

over time. Most of these are transportation sector related. The 

US Department of Energy has invested hundreds of millions of 

dollars over the last decade to augment the ethanol production 

of agricultural crops (corn primarily) with ethanol derived from 

woody-biomass sources (cellulosic ethanol). To date, they have 

sponsored both research and development, funding six pilot scale 

plants throughout the country. While not yet commercially viable, 

our transportation fuel demands are so high and this is another 

area, like heating oil, directly related to our importation of fossil 

fuels, that the issue is an important one to consider in the context 

of making policies to support the sustainable use of the low-grade 

wood resource. To put it in context, the Range Fuels plant near 

Soperton, Georgia will begin at pilot scale producing 20 million 

gallons of cellulosic ethanol a year, using 250,000 tons of wood. 

At its commercial scale of 100 million gallons per year, the wood 

demand will be over 1.2 million tons of green wood per year for 

this one plant (Range Fuels, 2010). 

Smaller scale work in bio-oil (pyrolysis oil) and bio-char (torrefaction) are emerging technologies that can help with both transportation fuel alternatives to gasoline and diesel, as well as, in 

the case of bio-char, potentially sequester portions of the wood 

carbon for long periods of time (Laird, 2008). These systems are 

operational at very small scales at the moment, but have a potential 

to contribute positively to the biofuel equation.

There are other technologies of similar scale to the bio-oil that 

use biomass to produce a range of products, including fertilizers, 

plastics, and glues. All of these products are relatively limited in 

demand, so source material from forests will not be significant 

relative to energy demands or other forest product uses. 

2.5.1 Emerging Technology Pathways 

The emerging technologies represented here all use some of the 

heat for other aspects of their processes, so their efficiencies are 

generally in the 40–45 percent range. Pathway #15 provides an 

example of a commercial-scale cellulosic ethanol plant, making 

100 million gallons of cellulosic ethanol per year. In this process, 

the cellulose in the wood is converted to sugars that are fermented 

into alcohol. The lignin part of the wood is combusted directly 

to produce steam and electricity. Pathway #18 is a variation on 

this whereby the by-product of pyrolysis is used to produce other 

products, such as plastics, glues, organic fertilizers, and fuel additives instead of electricity. Pathway #16 represents a bio-oil and 

bio-char system, producing 15 million gallons/year of bio-oil, 

and approximately 21,575 tons of bio-char (charcoal), having 

heating value of 11,000 btu/lb (dry basis), that can be used as a 

soil amendment for carbon storage. Pathway #17 is of similar size, 

producing a syngas that is used to make liquid fuels, with lignin 

used to produce steam-based electricity. The following chart 

summarizes the CO2 implications of these pathways:
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Biomass options in the home most closely able to substitute for 

oil are pellet boiler and furnace systems, and these systems are 

very popular in Europe and increasingly so here. The obstacles 

preventing large conversion of homes are primarily related to price. 

A conventional central heating system costs between $2,500 and 

$4,000 for a typical home. A comparable pellet system would 

be between $5,000 and $8,500. Even though the fuel is cheaper 

than oil, its availability in bulk is presently limited, and the cost 

disparity in systems cannot be made up for by the present 30 

percent tax credit that has a cap of $1,500 per home. 

If one wishes to promote advanced biomass technologies for the 

home, incentives such as tax credits, change-out programs, and 

programs that allow homeowners to offset the additional costs 

of choosing a biomass system either through credits or ability to 

finance costs through low or no cost options all work to overcome 

the cost implications. Proposals are pending in Congress to 

raise or eliminate the tax credit cap, and to develop a Homestar 

program that among other things supports pellet system installations. Similarly, New Hampshire and Maine each have programs 

to encourage an expanded residential market. A reliable bulk 

delivery option and convenient storage and automated delivery 

to the boiler or furnace are also necessary for the residential use 

of pellets to increase significantly and displace oil and propane. 

Cordwood use is limited in growth to those capable of handling 

and tolerating the storage, handling, and messiness of cordwood. Outdoor wood boilers avoid some of the indoor mess of 

handling cordwood, but the low efficiency and high emissions 

from them are of increasing concern to states in the Northeast, 

even when compared to conventional wood stoves. Though they 

are improving, some of the cost-attractiveness of these systems 

will be lost as their technology improves.

One hears periodically about home-based CHP systems, but with 

regard to biomass systems these are not commercially available, 

and developing products are very expensive relative to either 

conventional fossil fuel or biomass thermal systems. There are 

some demonstration projects using a Stirling Engine design, but 

these are still experimental or unique applications (Obernberger, 

et. al, 2003). We conclude from this that electrical generation 

from wood at the residential scale is not commercially available. 

With respect to residential heating, it is important to recognize 

the individual residential component and fuel price sensitivity of 

the cordwood market when considering net available low-grade 

wood for sustainable biomass use. Although each homeowner’s 

use is relatively small—perhaps five to 10 tons per season (2-5 

cords)—cumulatively, it can be significant, and often the hardest 

sector to quantify. In Vermont for example, cordwood is estimated 

to account for between 30 and 40 percent of all biomass use in the 

state (BERC, 2007). It increased by 20–30 percent in the single 

season of 2008 when oil approached $150/barrel.

There will also likely be small, incremental increase in thermal 

applications of biomass at colleges, institutions, and other facilities 

that have the capital to invest in longer-term payback projects, as 

Factors that can make power plant investment slow down are 

low value of REC’s coupled with only an inflationary increase 

in the price of electricity. Also, if the availability of fuel supply is 

restricted, or if it is only available at a cost higher than what plants 

can afford to pay, biomass power will be discouraged. We consider 

this scenario to be possible, but unlikely in the immediate future. 

While incentives and policies may promote biomass electric 

plant construction, the pace and penetration of biomass power 

plants are controlled most significantly by the fuel supply; it is 

such a large portion of the cost of operations that it is looked at 

very carefully by investors. This is why multiple proposals may be 

vetted at a given time, but if one is built, the others in the woodbasket are significantly adversely affected and are less likely to 

go forward. If there are reasonable harvesting and procurement 

standards in place regarding overall sustainability, this factor is 

likely to increase the due diligence on available fuel supply and 

prevent over-development of biomass power facilities.

If policies are changed to require CHP or a minimum annual net 

efficiency standard, as some states have done in certain circumstances and as DOE encouraged in recent procurements, more 

CHP can be expected. But under current conditions, siting 

constraints, the required scale for economically viable power 

production and lack of large centralized demand for thermal at 

the scale produced by a 20–50 MW power plant will all limit 

the desirability of power developers to include heat, as well as the 

amount of heat that can be effectively used by an electricity-led 

CHP system. We do not see electricity-led CHP as growing in 

the absence of policies or incentives to encourage that direction. 

Residential conversions are very dependent on oil and propane 

prices. In the absence of policies that would encourage large-scale 

switchover to biomass in residences, such as a substantial increase 

in the residential tax credit, or a change in building codes or insurance standards (to not require a conventional fossil fuel-based 

system in the home), the trend is expected to remain about the 

same. Although the use of biomass for home heating is significant, 

and currently not well-quantified, dramatic changes in the trend 

are not expected, though as explained below, residences can react 

quickly to rapid oil and propane price increases. 

At this scale, residential use will not be a significant driver in 

determining Massachusetts’ forest resource capacity for increased 

biomass use or the overall sustainability of the resource. Accordingly, the analyses in subsequent sections of this report assume 

residential use (and all existing uses for that matter) remains 

about the same as they are. That said, things which weigh in on 

people’s decisions to burn wood in the home primarily relate to 

cost of the fossil fuel alternative, and while this consideration 

may be at the forefront individual preferences regarding energy 

security and price stability, ease of operation and maintenance, 

degree of automation and convenience, cleanliness, availability 

of the wood fuel, heating effectiveness and comfort all play a 

role. Other factors such as emissions, environmental benefit, 

energy independence, space, and cumulative impacts are of lesser 

importance to the individual decision.
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efficiency for extracting the energy value of that biomass resource. 

Exhibits 2-6 and 2-7 on the following pages show the range of 

efficiencies for the different applications and pathways selected 

from most efficient to least efficient.

It is important to recognize that what is presented is just the efficiency of the process to produce energy or fuel or product from 

the biomass. This does not include up-front processes to get the 

biomass to the facility, or additional losses incurred through the 

use of the end product. For example, for electricity, these efficiencies do not include line losses or the efficiency of a given appliance 

to turn remaining electricity into useful work. Similarly, for the 

transportation fuels, this does not include the relative inefficient 

(18 percent) ability of your car to take the energy value of the fuel 

and convert it into the work of moving you down the road. Finally, 

for the thermal applications, it does not include the loss of heat 

exchange from the thermal system to a home, or the efficiency of 

a home to retain heat. These examples show that further down 

the process more losses of the energy value of the original biomass 

will be incurred. They may be smaller or they may be quite large, 

depending on the end use. 

the economics are compelling at current or slightly higher than 

current heating oil prices. These are not going to be common or 

numerous, as few institutions have the capital to make the changeover, and the payback period of generally between seven and 12 

years is too long for private investment interest. To increase thermal 

applications dramatically, if that is a policy direction Massachusetts 

wishes to pursue, state and federal incentive programs to provide 

capital, such as through a revolving loan fund, would be needed . 

Finally, cellulosic ethanol production has the potential to 

completely usurp power production at a comparable scale if 

electricity prices remain low, and oil (gasoline) prices increase 

markedly. However, the pilot projects under way and supported 

by the US DOE must prove out, and as such, we consider this 

scenario to be worthy of watching, but unlikely—especially in 

the near five to 10 year timeframe.

2.6.2 Efficiency

As has been discussed throughout, converting biomass into 

different energy pathways and products yields varying ranges of 

Exhibit 2-6: Graph of Efficiency of 18 Technology Pathway 

Options6

6 Graph information is derived from Appendix 2-B. See that 

Appendix for data and sources.
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Exhibit 2-7: Chart of Efficiency of 18 Technology Pathway 

Options7

 

7 Chart information is derived from Appendix 2-B. See that 

Appendix for sources.
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2.6.3 Carbon Impacts

The CO2 emissions from each of the pathways vary depending 

on the fuel and the efficiency of the product made. Generally, the 

CO2 emissions expressed as “input” energy reflect the fuel the 

process is based on, and the CO2 emissions based on “output” 

energy reflect the efficiency of the biomass-product conversion, 

be that electricity, thermal, or fuel. Exhibits 2-8 and 2-9 on the 

following pages reflect the different pathways from least CO2

emissions based on energy output to the most emitting pathways.

As with the efficiency discussion, it is very important to note 

this is not a life-cycle analysis of these technology pathways. The 

carbon aspects of mining coal, harvesting biomass, or drilling and 

transporting natural gas or oil are not shown here. Nor, except 

for the electricity and thermal applications, are the emissions 

of the ultimate use accounted for—that is, the fuels combusted 

will further release CO2 associated with that product. While 

full carbon life-cycle accounting for all pathways is beyond the 

scope of this work, lifecycle estimates of carbon emissions for the 

technological options considered in Chapter 6 are provided there. 

Exhibit 2-8: (above) Graph of CO2 Emissions of 18 Technology 

Pathways8

Exhibit 2-9: (next page) Chart of CO2 Emissions of 18 Technology Pathways9

8 Graph information is derived from Appendix 2-B. See that 

Appendix for data and sources.

9 Chart information is derived from Appendix 2-B. See that 

Appendix for sources.

Exhibit 2-8: Graph of CO2 Emissions of 18 Technology Pathways11

Exhibit 2-9: Chart of CO2 Emissions of 18 Technology 

Pathways12
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Biomass Sustainability and Carbon Policy Study

2.6.4 Affordable Cost for Biomass Source 

Material

Finally, for the purposes of conducting sensitivity analyses of the 

demand for forest products and how demand might affect cost 

paid for biomass, and how, in turn, that affects harvesting methods, 

intensity and options, we have looked at what the maximum affordable price is for each pathway to pay for biomass from the forests. 

The following Exhibits 2-10 and 2-11 illustrate these prices.

The maximum affordable price for power generation has been 

calculated based on the wholesale price of 12.5 cents per kWh 

including REC benefits, the cost of biomass fuel as 33 percent of 

sale price, higher heating value of wood chips as 17 MMBtu/ton, 

and moisture content of wood chips as 40 percent. The maximum 

affordable price for thermal applications has been calculated based 

on the price of #2 oil as $3 per gallon, higher heating value of 

138,000 Btu/gallon, combustion efficiency of 80 percent for oil 

boiler, affordable price of wood chips as percent of price of oil on $/

MMBtu basis as 50 percent and the combustion efficiency of wood 

chips boiler as 75 percent. The maximum affordable price of wood 

pellets for thermal energy has been calculated based on e f wood 

pellets with six percent moisture content as percent of price of oil 

on $/MMBtu basis as 75 percent and the combustion efficiency of 

wood pellet boiler at 80 percent. The maximum affordable price of 

wood chips for manufacturing wood pellets have been calculated 

based on maximum affordable price of wood pellets for thermal 

energy at $261 per ton, efficiency of conversion of wood chips to 

wood pellets as 85 percent, requirements of wood chips per ton of 

wood pellets as 1.575 tons, and the affordable price of wood chips 

as 60 percent of the price of wood pellets. The maximum affordable price for other technology pathways has been estimated in 

proportion of the net efficiencies for the products. 

The maximum affordable price is important as the price one is 

willing and able to pay for biomass determines the type of equipment and treatments that can be applied to the forest, and which 

uses may get preference over others with respect to biomass product. 

Higher affordable prices may enable better management, landowner 

commitment to sustainable forestry, and enhancement of logging 

infrastructure and methods. The pathways constraining the electricity related biomass prices are based on an electricity wholesale 

price of 12.5 cents/ kWh, which assumes a wholesale price to the 

grid plus any value of REC’s. Thermal applications are based on 

a $3.00 per gallon oil equivalent. Obviously, if the price of either 

goes up, then the ability to pay more for biomass (and still have the 

project “break even”) goes up as well. All of the assumptions for 

this and the other analyses are shown in the attached Appendix 2-C. 

Exhibit 2-10: (below) Maximum Price at which Biomass is 

Affordable for Each Biomass-Related Technology Pathway10

10 Graph information is derived from Appendix 2-B. See that 

appendix for data and sources. Methodology for calculations is 

presented in Section 2.6.4.

Exhibit 2-10: (below) Maximum Price at which Biomass is 

Affordable for Each Biomass-Related Technology Pathway13
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Biomass Sustainability and Carbon Policy Study

References

Biomass Energy Resource Center, 2007. Vermont Wood Fuel Supply 

Study: An Examination of the Availability and Reliability of Wood 

Fuel for Biomass Energy in Vermont, 

url: http://www.biomasscenter.org/resources/publications.html 

Biomass Energy Resource Center. 2010. College Chip System 

Smoothly Generates Cost Savings. 

url: http://www.biomasscenter.org/resources/case-studies/

campuses/200-mt-wachusett.html

Biomass Energy Resource Center. 2010. On the Coast of Denmark, 

a Quietly High-Performing Woodchip Gasifier Is Producing District 

Heat and Power. 

url: http://www.biomasscenter.org/resources/case-studies/

communityde/214-harboore.html

Biomass Energy Resource Center. 2010. Woodchip System at Quabbin 

Ignites Interest in Massachusetts.

 url: http://www.biomasscenter.org/resources/case-studies/govtfacilities/165-quabbin.html

Bituminous Coal. 2010. 

url: http://en.wikipedia.org/wiki/Bituminous_coal

California Air Resources Board. 2005. Wood Burning Handbook –

Protecting the Environment and Saving Money, (14 pp) 

url: http://www.cabq.gov/airquality/pdf/arbwoodburninghandbook.pdf 

Department of Energy (DOE). 2000. Carbon Dioxide Emissions 

from the Generation of Electric Power in the United States. 

url: http://www.eia.doe.gov/electricity/page/co2_report/co2report.

html

Energy Efficiency & Renewable Energy (ERRE), US Department of 

Energy. 2009. ABC’s of Biofuels. 

url: http://www1.eere.energy.gov/biomass/abcs_biofuels.html

Energy Information Administration (EIA), US Department of 

Energy. Energy Kids: Energy Units Basics. 

url: http://tonto.eia.doe.gov/kids/energy.cfm?page=about_energy_

units-basics

Energy Information Administration (EIA), US Department of 

Energy. 2008. Annual Energy Review

http://tonto.eia.doe.gov/energy_in_brief/major_energy_sources_

and_users.cfm 

Energy Information Administration (EIA). US Department of 

Energy, 2009. Fuel and Kerosene Sales, 2008

http://www.eia.doe.gov/energyexplained/index.cfm?page=heating_

oil_use 

Energy Information Administration (EIA), US Department of 

Energy. 2007. Massachusetts Renewable Electricity Profile. 

url: http://www.eia.doe.gov/cneaf/solar.renewables/page/state_

profiles/massachusetts.html

Energy Information Administration (EIA), US Department of 

Energy. 2010. Massachusetts State Energy Profile. 

url: http://tonto.eia.doe.gov/state/state_energy_profiles.

cfm?sid=MA

Engineering Toolbox. 2005. Fuel Oil and Combustion Values. 

url: http://www.engineeringtoolbox.com/fuel-oil-combustionvalues-d_509.html

Exhibit 2-11: Maximum Price at which Biomass is Affordable 

for Each Biomass-Related Technology Pathway11

11 Chart information is derived from Appendix 2-B. See that 

appendix for sources. 
Manomet Center for Conservation Sciences 30 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Entergy. 2008. Pilgrim Station & the Local Environment. 

url: http://www.pilgrimpower.com/local-environment.html

Innovative Natural Resource Solutions. 2004. New Hampshire Biooil Opportunity Analysis. 

url: http://www.inrsllc.com/download/NH_bio_oil_analysis.pdf

Innovative Natural Resource Solutions (INRS) LLC. Biomass 

Availability Analysis—Five Counties of western Massachusetts. 

Prepared for DOER, January, 2007. (55 pp.)

ISO New England Inc. 2009. 2009 Regional System Plan. 

url: http://www.iso-ne.com/trans/rsp/2009/rsp09_final.pdf

Kerr, Dawn R., Mann, Margaret K., Spath, Pamela L. 1999. Life 

Cycle Assessment of Coal-fired Power Plants. National Renewable 

Energy Lab (NREL). 

url: http://www.nrel.gov/docs/fy99osti/25119.pdf

Laird, David A. 2008. The Charcoal Vision: A Win–Win–Win 

Scenario for Simultaneously Producing Bioenergy, Permanently 

Sequestering Carbon, while Improving Soil and Water Quality 

Agronomy Journal 100: 178-181.

Obernberger, I. et al. 2003. State of the Art and Future Developments 

regarding Small Scale Biomass CHP Systems with a special focus 

on ORC and Stirling Engine Technologies. International Nordic 

Bioenergy Conference (2003). 

Range Fuels. 2010. Biomass to Energy: Renewable, Sustainable, Low 

Carbon Biofuels and Clean Energy. url: http://www.rangefuels.com/
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Biomass Sustainability and Carbon Policy Study

Chapter 3

Forest Biomass Supply

3.1 Introduction and Major Findings

Massachusetts has attracted the attention of bioenergy proponents 

and investors, in part due to a substantial rise in timber inventories over the last several decades. Recent studies on the availability of biomass to support new bioenergy plants have focused 

on incremental forest growth—implicitly treating inventory 

accumulation as potential supply—and confirmed expectations 

that inventories will continue to rise significantly. These studies 

thus concluded that available biomass is more than adequate to 

furnish several large-scale electric power plants without reducing 

timber inventories below current levels.

At this juncture, state policymakers require a better understanding 

of biomass supply, looking at factors beyond forest growth. Policymakers need to know whether the objectives of different energy 

policies are consistent with available wood supply, and how forest 

biomass harvests might respond to different economic realities 

that may be driven policy choices. With this perspective, we have 

crafted this analysis of forest biomass supplies in 2010−2025 

around two central questions:

• How much forest biomass would be supplied at current 

biomass stumpage prices if there is an increase in demand 

from bioenergy plants?

• How much would forest biomass supplies increase if bioenergy 

plants pay higher prices for wood?

Another goal of this supply analysis is to better understand the 

implications of potential biomass harvest levels for forest health 

and forest harvesting guidelines.

3.1.1 Conceptual Framework for Forest 

Biomass Supply Analysis

Key Study Features

Our approach focuses on economic issues and landowner behavior 

and has been developed with an eye toward the availability and 

quality of relevant data. Unlike previous forest-growth-based 

studies,1 this study of forest biomass supply in Massachusetts 

has several features that are different: 1) it is explicitly linked to 

energy prices; 2) it incorporates data on biomass harvesting and 

1 Recent studies using the forest-growth approach to assess biomass 

availability in Massachusetts are reviewed in Appendix 3-A. While 

these studies provide useful information on how much wood could 

be harvested on an ongoing basis without reducing inventories below 

current levels, they do not address the complex economic and social 

factors that will determine how much of this biomass would actually 

be available to furnish new biomass facilities. We have developed 

estimates of biomass availability using a forest-growth approach in 

Section 3.2.5 so that they may be compared with the results of the 

approach that we have developed.

production costs; 3) it provides a detailed analysis of historical 

harvesting patterns on private lands, thus recognizing landowner 

willingness to harvest along with harvest intensity; 4) it considers 

the effect of stumpage prices and per-acre income on landowner 

behavior; 5) it is closely linked to available timber inventory in 

terms of accessible areas, mature volumes on private lands, and 

stocks of low-value trees; 6) it treats public lands separately and 

utilizes information on historical harvest levels, new Forest 

Resource Management Plans, and the Forest Futures Visioning 

Process; and 7) it incorporates sustainability criteria that have 

been developed and presented in Chapter 4.

We define forest biomass as wood supplied from forest management 

activities on private lands and public lands. These two ownership 

categories are considered separately in our analysis because they 

differ in several important ways: 1) the factors that determine 

the decision to harvest; 2) forest management objectives on 

private and public lands, and thus silvicultural prescriptions and 

harvesting techniques; and 3) harvest intensity and timber yields. 

In terms of area harvested in Massachusetts each year, private 

lands dominate with an average of about 22,000 acres harvested 

annually in 2000−2009.2 In contrast, only about 4,000 acres of 

public land were harvested annually in the same time period. 

Note that we do not include land clearing as a source of forest 

biomass, because it is not a forest management activity and there 

are issues related to definitions of renewability. Nevertheless, it 

is the source of a substantial volume of wood (the average area of 

land cleared for development in 1999−2005 was estimated to be 

almost 5,000 acres per year) and so we have provided a separate 

section on potential biomass volumes from this source.

Incremental Biomass Production

The purpose of this supply study is to evaluate how much forest 

biomass would be available to furnish the potential expansion 

of bioenergy capacity and production in Massachusetts. For this 

reason, our analysis and projections are focused on incremental 

biomass production, not total production. The volume of biomass 

chips that has been produced from forest sources historically 

is considered to be “utilized” and, since this wood is already 

accounted for, it is not available to meet the demand from new 

bioenergy plants. We sometimes refer to this incremental production as “new” biomass.

Two Biomass Price Scenarios Linked to Energy Prices

We have developed two biomass price scenarios—linked to energy 

prices—that are intended to provide DOER with guidance as 

to how much wood may be available to furnish new bioenergy 

plants. These scenarios recognize the importance of stumpage 

prices and income in influencing landowner behavior, and the 

important relationship between delivered biomass prices and 

harvesting systems/logging costs. This section discusses these 

scenarios with respect to electricity prices; thermal and CHP 

2 The data and information provided in this section are summarized 

from the main body of this chapter. Sources and references are 

contained in the relevant sections.
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be triggered by either macroeconomic or policy shifts.6 Also, policy 

initiatives (such as REC’s) that provide higher income for utilities 

could be compatible with this level of biomass stumpage prices.7

We should note that we think that the high level of electricity 

prices that would drive this scenario is unlikely on the basis of 

macroeconomic trends and projections of future escalation in 

coal and natural gas prices. Significant changes in government 

policies would probably be necessary for this scenario to unfold 

and could take the form of greater incentives for electric power, 

or policies that spur substantial investment in thermal, CHP 

plants, and pellet plants.

How much forest biomass would landowners be willing to supply 

in response to higher prices? As demand and prices increase, more 

wood can be supplied from private lands by increasing removals 

of low-value wood from sites that are already under harvest, 

diverting wood from other end-use markets (such as pulpwood) 

to biomass, and increasing the number of acres being harvested. 

The standard and most direct approach to answering this question would be to estimate the effect of price changes on harvest 

volumes directly (that is, the timber supply elasticity). We have 

presented some results from our analysis of this relationship in 

Massachusetts, but they are merely suggestive due to the poor 

quality of the data on both harvest volumes and prices.

A second approach would be to rely on the literature for estimates 

of timber supply elasticities that have been developed in other 

regions. Available studies generally show that timber supply is very 

inelastic (that is, price changes have little or no influence harvest 

volumes).8 However, these results are not necessarily relevant in 

evaluating the biomass supply situation in Massachusetts because 

the characteristics of the landowners, timber inventory, and 

forest products industry are very different. Importantly, there 

are two issues not addressed in previous research that are likely 

to have a significant effect on forest biomass supply behavior in 

Massachusetts and call for an alternative approach.

The first issue relates to biomass prices and per-acre incomes. 

Studies which examine the relationship between harvests and prices 

generally focus on sawtimber prices (and sometimes pulpwood) 

because these dominate the value of a harvest in most regions. 

6 There are numerous policies under consideration that could lead 

to such changes (see U.S. Environmental Protection Agency, 2009: 

EPA Analysis of the American Clean Energy and Security Act of 

2009).

7 If electric power plant demand for wood increases but there are 

no increases in electricity prices that would allow power producers 

to pay the higher prices needed to generate more wood supply, then 

direct payments to landowners would be another policy that could 

lead to more biomass production.

8 There are many issues with these studies that raise concerns, 

perhaps the most serious being data limitations and errors in 

measuring price and harvest variables. In addition, many studies 

estimate binary choice models and only address the question of 

whether or not price has an effect, not the magnitude of that effect.

are addressed in the following section. Note that this assessment 

is intended to provide estimates of forest biomass potential over 

the medium term; in the near term, logging and infrastructure 

constraints (not addressed in this study) could be significant 

obstacles to harvest increases.

Our starting point is to estimate the potential of forest biomass 

to supply electric power plants in Massachusetts. This is an area of 

immediate concern for DOER given that they are now considering 

proposals for several facilities and the adequacy of wood supplies 

to furnish these plants is a central issue. In this scenario, our 

assumptions have been developed to reflect the current pricing 

environment for electricity and biomass: real electricity prices are 

assumed to remain near recent levels as are the price of renewable 

energy credits.3, 4 Consistent with this assumption, real biomass 

prices are also assumed to remain near recent levels: delivered 

wood prices at power plants would be about $30 per green ton, 

and biomass stumpage prices would average $1−$2 per green ton. 

We refer to this scenario as the “Low-Price Biomass” scenario.

Our second scenario is intended to provide perspective on the 

upper bound for forest biomass production if bioenergy demand 

and prices increase beyond the level established in the Low-Price 

Biomass scenario. It is not reasonable to specify an absolute 

maximum for biomass supply since supply is an economic concept 

which depends on timber prices (and a host of other factors). Thus, 

we need to specify a “high” biomass stumpage price, and then 

consider how private landowner harvests might respond to this 

price level. Forest biomass volumes could still increase beyond this 

level, but it would be increasingly difficult to due to biophysical, 

economic, and social constraints and increasingly unlikely due to 

macroeconomic and energy constraints. We refer to this future 

outlook as the “High-Price Biomass” scenario.

How high should the biomass stumpage price be in this 

“limiting”case? For increased demand from new wood-fired electric 

power capacity, we have developed an upper-range electric price 

scenario that leads to real biomass stumpage prices of about $20 

per green ton.5 The significant increase in real electricity prices 

needed for power plants to purchase wood in this scenario could 

3 Reference case (or base case) forecasts of electricity prices 

suggest that real prices will remain relatively flat over the next 15 

years, as they play off a projected declining trend in real natural 

gas prices and a slightly increasing trend in real coal prices (see for 

example, Annual Energy Outlook 2010: U.S. Energy Information 

Administration, 2009). 

4 The assumption about REC’s is important since they provide a 

significant share of revenue for wood-fired power plants and they 

can be modified by state policy.

5 The delivered wood and electricity prices consistent with this 

scenario are discussed later in this report.
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an electric power plants.11 Importantly, in the same woodshed, 

thermal and CHP plants can pay this difference—and much 

more if necessary—and remain profitable.

At the high end of the supply curve, if the market price of delivered 

wood for electric power plants is $50−$60 per green ton, thermal 

and CHP plants would face wood prices in the range of $65−$75 

per green ton. This price level is still below the range that these 

plants could afford to pay today and cover their full costs. Of 

course, if electric power prices increase due to macroeconomic 

factors and fuel costs, it is a safe bet that oil prices would be much 

higher as well; in fact, most forecasts indicate that oil prices will 

increase faster than electricity prices (which are tied more closely 

to the cost of coal and natural gas).

In sum, higher-quality chip specifications for thermal and CHP 

plants shift the supply curve for delivered wood chips upward 

relative to that of electric power plants. Under reasonable energy 

price scenarios, when these plants compete for the same wood 

supply, thermal and CHP plants will be able to outbid electric 

power plants due to their production economics and the competitive environment of the energy markets in which they operate.

Harvesting Systems and Logging Costs

We have conducted our assessment of wood biomass supply in 

Massachusetts with and without the harvesting restrictions—

particularly with respect to the removal of tops and limbs—that 

are provided by the guidelines in Chapter 4 of this report.

Our assessment of biomass supply in Massachusetts suggests that 

if demand increases due to the expansion of electric power plants, 

it will almost certainly be accompanied by increases in whole-tree 

harvesting due to the limited supply of other forest biomass and 

the cost advantages of whole-tree methods. Generally, we assume 

that whole-tree harvesting can be used on private lands as long as 

it meets the forest practices standards required by the state. Given 

the uncertainty regarding the acceptance of whole-tree harvesting 

(particularly mechanical systems) in Massachusetts, our supply 

projections allow for the fact that many landowners, foresters, 

and loggers will still favor alternative harvesting methods.

Thermal and CHP plants are not constrained to use whole-tree 

harvesting methods because of their ability to pay higher prices 

for delivered wood chips. These facilities could buy wood procured 

with log-length methods, in which trees are delimbed and bucked 

at the stump and the logs are forwarded or skidded to the landing. 

Log-length methods may be selected over whole-tree methods if 

management plans call for leaving tops and limbs scattered on 

the site and/or there is concern about damage to soils or to the 

11 While thermal and CHP plants will compete for bole chips, 

electric power plants can use whole-tree chips from tops and limbs. 

However, given the wood supply situation in Massachusetts, it 

appears that electric power plants would need to obtain most of 

their wood from whole trees and thus could face the prospect of 

competing directly with thermal and CHP plants for bolewood 

when operating in the same woodshed.

However, if biomass prices rise significantly, they can make an 

important contribution to income and influence landowner 

decisions.9 The second issue is the age structure of the inventory 

in Massachusetts. Many empirical studies consider inventory 

levels in a broad sense, but none directly consider the age structure of the inventory. A large percentage of the private forests in 

Massachusetts are now over 60 years old and are ready—if not 

overdue—to be thinned for landowners interested in commercial 

timber production10; financial incentives could have an important 

effect on the decisions of these landowners.

These concerns have led us to an approach for the High-Price 

Biomass scenario that recognizes landowner characteristics, the 

age structure of the inventory, and the importance of per-acre 

income levels. While we believe this method provides a better 

estimate of forest biomass supply than traditional economic 

approaches, a good deal of uncertainty concerning landowner 

responses cannot be eliminated since we are considering behavior 

that is well beyond our historical experience. As demand and prices 

increase, the confidence intervals grow wider and it is important 

to recognize and acknowledge this uncertainty.

Biomass Supplies for Thermal and CHP Plants

It is relatively straightforward to extend the above scenarios to 

evaluate the availability of forest biomass supplies for wood-fired 

thermal and CHP plants. The cost structure of thermal and 

CHP plants and their competition with facilities that use oil and 

natural gas allow them to pay much higher prices for wood than 

electric power plants. For example, in current markets (assuming 

oil prices of $3 per gallon), thermal and CHP plants could pay 

up to $85−$95 per green ton of wood (45% moisture content) 

and still cover their full cost of capital (based on the analysis in 

Chapter 2).

In terms of wood supply, one important difference between 

electric power and thermal/CHP plants is that the latter prefer 

higher-quality chips that are uniform in size and shape and have 

low ash content (Maker, 2004; P Squared Group and Biomass 

Energy Resource Center, 2008). Clean chips and chip specifications in general may add about $10−$15 per green ton to the cost 

of chip production. Thus, thermal and CHP plants would need 

to pay $40−$45 per delivered green ton compared to $30 for 

9 Landowners may also respond differently to an equivalent 

amount of income from harvesting biomass and sawtimber because 

the removal of low-value biomass may have a different impact on the 

value of non-timber amenities than the removal of large trees.

10 Kelty et al. (2008) reference silvicultural research that indicates 

that 50 years is the recommended age for first thinning (cited 

from Hibbs and Bentley, 1983), but indicate that first thinnings 

in Massachusetts are commonly delayed until stands reach 70 years 

of age.
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bring more private land into timber production, increase the 

harvest intensity on all lands that are harvested, and divert 

wood from pulpwood and other end-use markets to biomass. 

With our scenario of biomass stumpage prices at $20 per green 

ton, per-acre income from wood sales could double and we 

estimate that about 685,000−885,000 green tons of “new” 

forest biomass could be produced annually in Massachusetts.

• Increased prices would not be expected to lead to higher harvest 

levels on public lands. However, at these higher stumpage 

prices, biomass supplies would increase as wood from public 

lands would likely be diverted from pulpwood to bioenergy 

plants. The volumes would be small, however, and would 

account for only about 5% of “new” statewide forest biomass 

production.

• We have estimated a “sustainable” level of biomass supply 

using the criteria that harvests do not exceed net growth and 

that biomass harvests can be maintained at the same level for 

the foreseeable future. Based on our estimates of operable 

private land area and our growth estimates in Chapter 5, we 

have calculated that average annual biomass supply could 

be 900,000 green tons per year. Thus, the high end of the 

range that we derived using our approach (885,000 green 

tons) would be considered “sustainable” by this definition. 

In addition, our analysis suggests that the “supply” estimates 

developed using forest-growth approaches would only be 

consistent with very high biomass stumpage prices.

Forest Biomass Supply Available from the Border Counties

• We evaluated supplies in the border counties (NH, VT, 

NY, CT, and RI) by considering timberland area, timber 

inventory, growth rates, ownership characteristics, and forest 

products production. There is no simple scheme to weight 

these factors, but our best estimate is that incremental 

forest biomass production in the border counties would be 

about 50% greater than that of Massachusetts. The logic 

of our two scenarios still applies: at low biomass stumpage 

prices, “new” volumes would be limited because they come 

primarily from the additional harvest of low-value wood 

on sites already being logged for other commercial timber; 

at high biomass stumpage prices, the harvested land base 

would increase considerably, as would the harvest intensity 

on these sites.

• Biomass produced in the border region could be consumed in 

the “local” market, shipped to Massachusetts, or shipped to 

the next ring of bordering counties and beyond. The eventual 

destination for this wood will depend on the location and 

timing of new capacity investment throughout the region 

and a variety of other factors such as transportation costs, 

infrastructure, and supply logistics. While this is a complex 

problem with a high degree of uncertainty, we think that as 

a general planning guide it would be prudent to assume that 

Massachusetts could successfully purchase only half of the 

available wood. Thus, in the Low-Price Biomass scenario, 

“new” forest biomass available from the border counties to 

residual stand (Fight et al., 2006). As noted earlier, our estimates 

indicate that log-length harvesting methods would add about 

$10−$15 to the cost of a green ton of chips.

3.1.2 Major Findings and Conclusions

Here we summarize the major findings of our wood supply 

assessment:

Forest Biomass Supply Available in Massachusetts with LowPrice Stumpage

• At current prices for biomass stumpage, we estimate that 

about 150,000−250,000 green tons of “new” biomass could 

be harvested annually from forest lands in Massachusetts.12

Most of this material would be sourced from standing trees 

due to the small size of the forest industry in Massachusetts, 

and hence the limited supply of logging residues and limited 

opportunities for log merchandizing. This wood would be 

available to electric power, thermal, CHP or other bioenergy plants; however, if the wood is harvested as feedstock 

for electric power plants, whole-tree harvesting would be 

necessary to produce chips at $30 per delivered green ton.

• We estimate that virtually all of the “new” forest biomass 

supply would be harvested from private lands. Given the low 

price of stumpage in this scenario, biomass producers would 

have economic access only to low-value wood and it would be 

harvested almost exclusively on sites that are already being 

harvested for sawtimber. If whole-tree harvesting operations 

are established for biomass production, it would also become 

economical to remove sawtimber logging residues from those 

same sites. Applying the ecological guidelines provided in 

Chapter 4 of this report, our projection shows that tops and 

limbs from industrial roundwood would account for about 

15%−20% of the “new” biomass harvest from private lands.

• We find that there would likely be little or no increase in 

biomass production from public lands. Our review of Forest 

Resource Management Plans and anticipated forest policies 

leads us to conclude that the total volume of wood harvested 

on public lands in 2010−2025 will be about the same level that 

we have observed during the past decade. We have assumed 

that biomass fuel will not be diverted from other end uses 

(such as pulpwood) in this scenario. Logging residues are 

not projected to contribute to supply because of ecological 

restrictions and poor economics.

Forest Biomass Supply Available in Massachusetts with HighPrice Stumpage

• Higher biomass stumpage prices could dramatically affect 

the supply of biomass by providing economic incentives that 

12 The major uncertainty that accounts for this range is the average 

volume of biomass material removed from an acre. It is also possible 

that some pulpwood could be diverted to biomass fuel at relatively 

low biomass stumpage prices, but we have not introduced this 

potential shift in the Low-Price Biomass scenario.
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may not be difficult to procure wood at affordable prices in the 

early stages of expansion, but it could become more problematic 

as prices rise nearer to the levels assumed in the High-Price 

Biomass scenario.

3.1.3 Potential Wood Biomass Supplies 

from Other Sources

This assessment has focused on the core issue of biomass production from forest sources. It is important to recognize that there are 

other biomass sources that could potentially make a substantial 

contribution to the supply of wood available for new bioenergy 

facilities in Massachusetts. These can be classified into three 

major categories: 1) wood from land clearing; 2) wood from mill 

residues and tree care/landscaping sources; and, 3) wood grown 

in short-rotation plantations.

Wood From Land Clearing

There is a high degree of uncertainty in estimating the area of 

land that is cleared each year in Massachusetts, the amount of 

wood removed from that land, and the current disposition of 

that wood. As a result, it is difficult to estimate the volume of 

incremental biomass supplies that could be generated from land 

clearing over the next 15 years. Holding the area of land cleared 

annually constant, we have calculated that a 10% increase in the 

recovery rate13 would yield an additional 30,000 green tons per 

year of biomass that could furnish an expansion in bioenergy 

plants. Given current disposal costs for cleared wood and current 

potential uses for that wood, it would seem that an increase in 

recovery rates from 30% to 70% (at high biomass stumpage prices) 

would provide reasonable bounds for the potential supply from 

this source. This translates to a maximum volume of 120,000 

green tons of “new” biomass given our assumptions on the area 

of land cleared and the expected diversion of high-quality wood 

to other end-use markets.

Wood Biomass From Mill Residues and Tree Care/

Landscaping Sources

Among these other sources, the most significant is wood from 

tree care/landscaping sources. This wood is often referred to as 

“urban wood” which is somewhat of a misnomer because it includes 

wood not only from tree care in urban areas, but also wood from 

tree care from sources such as county parks and recreation areas 

and maintenance of electric power lines. The term can also be 

confusing because it is not always clear whether it includes “urban 

waste” such as construction debris. 

A literature review conducted in 2002 indicated that tree care/

landscaping sources accounted for 1.0 million tons (42%) out the 

total available supply of 2.5 million tons of non-forest wood biomass 

in Massachusetts (Fallon and Breger, 2002). However, given the 

difficulties in estimating this volume (noted in the report), this 

estimate is perhaps best used to suggest that the potential from 

13 We define the recovery rate as the percentage of wood cleared 

that is used for industrial roundwood products or industrial and 

residential fuelwood.

furnish bioenergy plants in Massachusetts would be about 

110,000−190,000 green tons per year. With the assumption 

of high biomass stumpage prices, forest biomass supplies from 

adjacent counties would increase to about 515,000−665,000 

green tons annually.

Our projections for incremental forest biomass production 

in Massachusetts and the border counties are summarized in 

Exhibit 3-1. Although we have provided a range of estimates in 

this table, there are, of course, a wider set of possible outcomes 

for these scenarios. This uncertainty is largely due to our limited 

historical experience with biomass harvesting in Massachusetts, 

and this becomes a greater concern when we analyze the impact 

of much higher biomass prices. We have conducted sensitivity 

analysis of some of our key assumptions within this chapter. 

Perhaps the most significant source of uncertainty is how private 

landowners will respond to the prospect of earning higher income 

from biomass harvests. Another general issue is the acceptance 

and adoption of whole-tree harvesting by landowners, foresters, 

and loggers in Massachusetts—this is particularly important in 

scenarios involving electric power expansion since whole-tree 

harvesting would likely be necessary due to cost considerations. 

For the border counties, it is more difficult to address the issue 

of confidence intervals because our estimates were established 

relative to Massachusetts, and then scaled down to recognize 

that facilities outside of Massachusetts would compete in this 

same woodshed.

Exhibit 3-1: Summary of Forest Biomass Fuel Supplies for 

2010−2025

Low- and High-Price Biomass Scenarios

000 Green Tons per Year

Low-Price High-Price

Massachusetts

Private Lands 150−250 650−850

Public Lands 0 35

Total 150−250 685−885

Border Counties 110−190 515−665

Combined Total 260−440 1,200−1,550

Note: Estimates have been rounded for this table.

We have focused on two price scenarios for forest biomass supply, 

with the high-price scenario intending to provide an approximate 

upper bound for incremental biomass harvests. Clearly, these 

two price levels represent only two points on a supply curve that 

embodies many price-harvest combinations. A few comments 

on the shape of this curve are appropriate. At current/low price 

levels, the supply curve for private owners is presumed to be flat 

suggesting that any volume of forest biomass up to the range of 

150,000−250,000 green tons per year could be procured at these 

prices. At high-end prices, we would expect that the slope of the 

curve would be relatively steep reflecting landowner resistance to 

harvesting additional acres due to the greater value that owners at 

the margin may place on non-timber amenities. This nonlinearity 

suggests that if bioenergy capacity increases in Massachusetts, it 
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3.5 reviews potential biomass production from other sources, 

including land clearing and conversion.

In Section 3.6, we present our assessment of biomass supply from 

nearby states by evaluating their potential relative to Massachusetts. 

Key topics covered include timberland area, timber inventory, 

timber growth, forest products industry status and associated 

harvesting levels, and landowner characteristics. After developing estimates of potential additional biomass production in 

the border region, we conclude by discussing some of the factors 

that determine where this wood might eventually be consumed.

Some of our work and analysis has been presented in several 

Appendices, which include the following topics: 1) a review of 

results of previous studies on forest biomass availability in Massachusetts (Appendix 3-A); 2) logging residue data and methods 

for estimation (Appendix 3-B); 3) firewood production and 

consumption in Massachusetts (Appendix 3-C); 4) an analysis of 

biomass potential in southern New Hampshire (Appendix 3-D).

3.2 Biomass Supply from Private 

Lands in Massachusetts

Private timberlands in Massachusetts are by far the most important source of “new” or incremental forest biomass production 

because of their size and the ability of landowners to adjust their 

harvest decisions in response to changes in market conditions. 

The analysis in this section is organized as follows: 1) historical 

estimates of timber harvests; 2) review of potential supplies from 

logging residues; 3) projection of biomass supplies in the Low-Price 

Biomass scenario; and 4) projection of biomass supplies in the 

High-Price Biomass scenario. Our projections include a review 

of harvesting costs, and examine the important role of stumpage 

prices in influencing production volumes.

3.2.1 Historical Estimates of Timber

Harvests on Private Timberland

The economics of forest biomass production are generally most 

favorable when biomass harvests are integrated with sawtimber 

harvests. In this section, we provide a detailed analysis of historical 

patterns of timber harvests in Massachusetts to lay the groundwork 

for our projections of sawtimber and other industrial roundwood 

harvests. Unless income incentives increase substantially under 

some scenarios that are described under our High-Price Biomass 

scenario, the harvesting footprint with biomass is likely to be 

very similar to that for industrial roundwood alone. Biomass 

production will then come from increasing the harvest intensity 

on these lands, by taking tops, limbs, and low-value standing trees.

Unlike several states in the Northeast region, Massachusetts does 

not track and collect data on annual harvest levels. Thus, this 

analysis relies on forest cutting plans (FCPs) that are required by the 

state under the Forest Practices Act. Although FCPs have several 

these sources may be substantial and worthy of further investigation (importantly, the carbon profile of this material is generally 

similar to logging residues and thus very favorable compared to 

that of harvesting standing trees).

Two other important sources of wood biomass that should be 

noted are mill residues and urban waste (municipal solid waste, 

and construction and demolition debris). Although mill residues can be a valuable source because they are clean, dry and 

easily accessed, they are generally fully utilized. Moreover, mill 

residue supplies in Massachusetts have been declining in parallel 

with the contraction in lumber production. On the other hand, 

solid waste and C&D debris may be considered under-utilized, 

but are expensive to sort and can be difficult to recover due to 

contamination issues.

Short-Rotation Wood Plantations

DOER and DCR commissioned a study that included an evaluation of the potential of growing short-rotation willow crops 

in Massachusetts for bioenergy use (Timmons et al., 2008). In 

light of our forest biomass supply assessment, there are three 

reasons that the potential of this supply source on marginal 

agricultural lands may deserve more attention if DOER wishes 

to promote bioenergy development. First, our economic analysis 

has shown that the potential to produce forest biomass chips 

in the current pricing environment and with current policy 

incentives is significantly less than suggested by previous studies 

that were focused on forest growth. Second, although BCAP 

policies are now undergoing revision, the proposed rules offer 

significant subsidies for the establishment and development of 

wood energy crops (see policy review in Chapter 1). Third, if 

carbon emissions are an important consideration in state energy 

policies, closed-loop short-rotation crops have some obvious 

advantages when compared to natural forest biomass sources.

3.1.4 Report Organization

This report is organized as follows. Section 3.2 provides an in-depth 

analysis of biomass supplies from private lands in Massachusetts. 

We begin with a review of historical levels of timber harvesting 

since we believe this is fundamental to understanding future 

biomass supplies—biomass production often makes economic 

sense only when integrated with sawtimber harvests. The forecast for low-price biomass supply requires the review of three 

important topics: 1) costs of whole-tree harvesting; 2) low-value 

wood supply in sawtimber stands; 3) landowner willingness to 

increase harvest intensity. In order to generate a forecast of highprice biomass supplies, the discussion is extended to include: 1) 

the size of the operable land base after adjusting for biophysical 

factors and landowner characteristics; 2) landowner response to 

higher wood prices and higher per-acre income levels.

Section 3.3 discusses the potential for harvesting “new” biomass 

supply from public lands, and covers both historical harvest 

levels and projections of wood harvests. Our forecasts for forest 

biomass supplies in Massachusetts are summarized by source for 

our two biomass stumpage price scenarios in Section 3.4. Section 
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acres in 2008 according to FIA data16 (these data suggest that this 

shift was primarily due to a transfer of timberlands from private 

to public ownerships, with land conversion playing a much less 

important role17). While the stability in area harvested is open 

to various interpretations, the most probable explanation would 

relate to the small share of land that is harvested. Thus, in spite 

of the increasing fragmentation of the land base and the small 

average parcel size of ownership, the data suggest that much of the 

harvesting in Massachusetts may take place on an operable land 

base that may not have changed much over this period of time.

Exhibit 3-2: Acres Harvested on All Private Lands, 1985−2009

Note: Derived from Forest Cutting Plans assuming 95% of plans are 

completed.

As noted above, sawtimber demand is the key driver of harvesting 

activity on Massachusetts timberland and thus critical to the 

analysis of potential biomass supply. Over the historical time 

period, the sawtimber harvest on a per-acre basis has ranged from 

a low of about 1,600 board feet (International 1⁄4" log rule) in 1991 

to a high of 2,200 board feet in 2006 (Exhibit 3-3). The average 

in 1994−2009 was 2,000 board feet per acre.18

The stability in the volume of sawtimber harvested on private 

lands in 1994−2009 contrasts markedly with the large decline 

in lumber production during this period. Lumber production in 

Massachusetts was just over 100 million board feet in 1993 and 

16 Reference to FIA data is made frequently throughout this report. 

FIA refers to the Forest Inventory and Analysis National Program 

which provides detailed data on forests and forestland based on 

surveys by the U.S. Forest Service.

17 It should be noted that it is difficult to quantify accurately the 

magnitude of these land shifts and different data sources can lead to 

different conclusions. For example, using the same FIA database and 

considering forestland in Massachusetts (forestland area is about 5% 

greater than timberland area) suggests larger losses in the private land 

base, smaller gains in the public land base, and a much higher share of 

land lost to conversion. Data that provide direct measurements of land 

conversion in Massachusetts are discussed later, but these data also have 

numerous problems and are not consistent with the FIA trends.

18 It is interesting to note that Kelty et al., 2008 report that a 50% 

overstory thinning on average private lands in Massachusetts would 

yield 2 MBF (International 1⁄4" log rule) per acre.

important limitations with regard to coverage and timing14, they 

are the best data source available to identify important long-term 

trends in harvesting activity in Massachusetts. We have obtained 

these data for 2001−2009 from the Massachusetts Department of 

Conservation and Recreation, and for 1984−2000 from research 

at the Harvard Forest (Kittredge et al., 2009). 

The FCP data indicate that the average annual volume of wood 

“harvested” from private lands in 2001−2009 was 323,000 green 

tons.15 Average volumes by end-use market according to these 

plans were 224,000 green tons of sawtimber, 84,000 green tons 

of “pulpwood,” and 16,000 green tons of fuelwood. However, 

one must be cautious in interpreting these data because wood 

that is classified as pulpwood may actually be consumed for fuel, 

either in residential or industrial uses—wood classifications and 

conversions to green tons are discussed in more detail later in 

this section.

In order to analyze these data, we first consider acres harvested 

on all private lands, which are shown in Exhibit 3-2. Harvested 

acres dropped sharply in the late 1980s, but rebounded by the 

mid-1990s and have been relatively flat since that time. In fact, 

the stability of the private land area harvested over the past 15 

years is remarkable given the number of factors that influence 

this trend, including overall demand levels for wood products, 

and harvest volumes supplied from public lands and land clearing 

activity. We should note that forest industry lands are only a small 

portion of the private land base in Massachusetts (harvests on 

industrial lands account for only about 5% of acreage as well as 5% 

of volume removed); thus, we have not disaggregated private lands 

into industrial and non-industrial components as is commonly 

done in timber supply analysis.

This “stable” trend is more interesting in light of the fact that the 

area of private timberland in Massachusetts has declined by 20% 

during this period, from 2.5 million acres in 1985 to 2.0 million 

14 Important limitations include: 1) they are pre-harvest plans and thus 

the volume to be harvested is only an estimate of what was actually cut; 

2) once filed, the plans can be implemented over the following two years 

and there may be extensions (for two additional years); in addition, 

those who file may choose not to harvest at all; 3) they are only required 

for wood harvests greater than 50 cords or 25,000 board feet; 4) they are 

only required if the land remains in forest use and thus do not include 

land clearing. These issues are discussed in Ch. 132 of the Massachusetts 

Forest Cutting Practices Act and by Kittredge et al., 2009.

15 Although these data are pre-harvest levels as stated in the Forest 

Cutting Plans, we refer to them as though they are “actuals,” partly 

for convenience, but also because we have adjusted them, reducing the 

levels by 5% (based on information reported by Kittredge et al., 2009) 

and using a distributed lag function to allocate harvests over multiple 

years to account for the fact that those who file plans have up to two 

years to harvest with the possibility of extensions.
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early 1990s to only about 2 green tons per acre in 2000. Since that 

time, other industrial roundwood harvests have climbed sharply, 

reaching 7 green tons per acre in 2009 (according to plan data, this 

consists of 5 green tons of pulpwood and 2 green tons of fuelwood).

We should also note that our analysis of historical timber harvests 

includes only a small percentage of the total volume of firewood 

that is cut and consumed in Massachusetts. FCPs are required 

only for harvests that exceed 50 cords and it appears that most 

firewood is produced in much smaller operations. This is consistent 

with Massachusetts landowner surveys that suggest that many 

owners of small parcels are interested in firewood harvests, but 

not harvests of industrial roundwood.

Exhibit 3-4: Average Harvest Intensity on All Private Lands, 

1985−2009

Sawtimber compared with Other Industrial Roundwood 

(green tons per acre)

Note: Derived from Forest Cutting Plans assuming 95% of plans are 

completed.

For this study, we have assumed that residential fuelwood harvests 

do not have a significant impact on the potential for forest biomass 

supply since most of the biomass for industrial use is likely to come 

from larger harvesting operations. However, there is an interface 

between the two sectors as some residential fuelwood does get cut 

during industrial roundwood harvests, and sometimes in followup harvests if crews move in to remove smaller wood or standing 

dead wood. This area may deserve additional study because of the 

large volume of firewood production in Massachusetts, which 

we estimate may be two-to-three times the volume of industrial 

roundwood harvested (see Appendix 3-C). 

3.2.2 Logging Residues

Most studies of potential forest biomass availability start with 

logging residues because: 1) they represent a substantial volume of 

wood (4.5 billion cubic feet in the U.S. in 2006, which compares 

with 15.0 billion cubic feet of roundwood harvested for all products (Smith et al., 2009); 2) their removal has been considered 

integral to forest and ecological health in many situations due to 

potential fire hazard and insect damage; 3) they are perceived to 

be underutilized and have additional value as product output; 

edged higher to 104 million board feet in 1996; however, production was estimated to have been only 69 million board feet in 

2001 and 49 million board feet 2005 (Damery et al., 2006). On 

public lands, sawtimber harvests were also flat over the past 15 

years according to FCP data. One interpretation of these trends 

would be that the contraction in lumber production was less a 

function of final demand than of the competitive position of 

sawmills in Massachusetts, and high-quality sawlogs continued 

to be cut and shipped out of state to be processed elsewhere. 

Another factor that needs to be considered is that it appears 

that land clearing dropped sharply over this time frame; thus, a 

potentially important source of sawlogs declined substantially and 

may have increased the demand for sawlogs from private lands.

Most importantly for this study, in spite of major changes in 

local processing capacity and demand and some significant price 

swings, acres harvested and sawtimber harvests have remained 

relatively stable. These trends provide the basis for our projections of future harvest levels in Massachusetts. 

Exhibit 3-3: Average Sawtimber Harvest Intensity on All 

Private Lands, 1985−2009 (000 board feet, International 

1⁄4" log rule per acre)

Note: Derived from Forest Cutting Plans assuming 95% of plans are completed.

In order to project forest biomass supply, it is also important to consider 

the volume of timber that is being harvested for other end uses. These 

calculations provide insight into other demands on the resource base, 

harvest intensities on timberland, and the potential for additional 

harvests of biomass. In order to compare the harvest volumes reported 

on the FCPs, we converted sawtimber (MBF, International 1⁄4" log 

rule), pulpwood (reported as 128 cubic-foot cords), and fuelwood 

(reported as green tons) to common units (green tons in this case). 

Harvest intensity for sawtimber in green tons per acre is contrasted 

with the other industrial roundwood uses in Exhibit 3-4.19 Other 

industrial roundwood fell from about 4 green tons per acre in the 

19 We have combined pulpwood and fuelwood into “other industrial 

roundwood” because the two classifications are not reliable indicators 

of their end-use markets. Some pulpwood—perhaps more appropriately 

referred to as cordwood—can be cut and split for firewood, and may 

be chipped for biomass. Fuelwood is comprised of roundwood that is 

processed for residential firewood, and also wood that is chipped for 

industrial biomass use.
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collection and delivery to a central location would generally be 

prohibitively expensive.

In order to produce biomass competitively from tops and limbs, 

whole-tree harvesting operations would likely be necessary to 

reduce the costs of landed residue material. Rather than topping 

and limbing felled trees at the stump, trees could be skidded to 

a landing with some portion of the top and limbs remaining 

intact. Tops and limbs could then be removed at the landing 

and chipped there. If biomass is produced in this manner, the 

primary costs would be chipping (about $6−$7 per green ton 

for slash) and transport from the landing to a bioenergy plant 

(directly dependent on distance, but averaging about $8−$12 

per green ton).21 Thus, total delivered costs would be $14−$19 

per green ton.22

3.2.2.3 Forecast of Forest Biomass Supply 

from Logging Residues on Private Lands

In order to project biomass supplies that can be used to meet 

potential demand from new bioenergy plants, we have assumed that 

65% of the tops and limbs from harvested trees can be recovered on 

acres where silvicultural prescriptions include whole-tree biomass 

harvests. This percentage was selected for two reasons: 1) it leaves 

behind more than enough material to conform to the ecological 

guidelines that have been spelled out in Chapter 4; 2) it recognizes 

that a significant share of tops and limbs remain uneconomic 

due to timber breakage, small pieces, and small branches. Some 

issues, such as difficulties in handling large hardwood crowns, 

encompass both ecological and economic concerns.

Harvests of logging residues have been considered in conjunction 

with harvests of standing forest biomass in the following sections. 

We did not consider it useful to develop a separate biomass supply 

scenario for only logging residues. Biomass production from 

logging residues would be widely dispersed and given historical 

harvest levels, it would amount to only about 2−3 green tons on 

an average acre. It may be feasible to economically recover this 

material in some locations with small chippers and chip vans. 

However, in the broader context of biomass markets, the economic 

case for producing forest biomass makes more sense when more 

volume is produced on a per-acre basis. Thus, our projections 

of biomass supplies from logging residues are combined with 

harvests of other low-value standing trees and these projections 

are discussed below.

3.2.3 Low-Price Biomass from Private 

Timberlands

21 These data are based on the combination of a literature review 

and informal survey of industry professionals.

22 Although we have assumed that tops and limbs are free at the 

landing in this case, increased competition for this material in 

response to higher biomass demand would likely cause the value of 

the wood to be bid higher, thus raising the cost of delivered wood. 

There are also some additional logging costs associated with piling 

or “putting up’ the material at the landing.

4) they are assumed to be the most easily procured—and thus 

the least costly—source of biomass supply from forests. Logging 

residues have been a central focus of many studies (for example, 

the “Billion-Ton-Study,” Perlak et al., 2005) and are considered 

a key source of forest biomass fuel.

3.2.2.1 Logging Residue Generation

Here we consider the potential volume of forest biomass supplies 

from logging residues in Massachusetts. The primary source 

of logging residue data in most studies is the Timber Products 

Output (TPO) reports from the U.S. Forest Service. These data 

could not be used directly for Massachusetts due to problems in 

the underlying database (see Appendix 3-B for a full discussion of 

the logging residue data). In addition, the TPO methodology tends 

to overstate the volume of logging residues available for biomass 

fuel because the data include a significant volume attributable to 

breakage and residual stand damage.

For these reasons, we have devised an alternative approach in 

which we estimate the volume of tops and limbs associated with 

harvesting trees of varying diameter classes (the derivation of these 

estimates is provided in 3-B). When these percentages of top and 

limb material are applied to recent industrial roundwood harvest 

levels, they suggest that the total volume of “logging residues” 

generated on private lands in Massachusetts is on the order of 

100,000 green tons per year.20

3.2.2.2 Logging Residue Recovery

Most studies that evaluate the availability of logging residues make 

the assumption (sometimes implicitly) that the bulk of logging 

residues are delivered to a landing as part of normal harvesting 

operations. In these logging operations, a tree is assumed to be 

delivered to the landing for the value of the sawlog and pulpwood, 

while the “wastewood” is assumed to be a by-product of the 

operation with zero costs for “delivery” to a landing. With these 

assumptions, the portion of the tree that could be considered 

biomass fuel is inexpensive and available for the cost of chipping 

and transport to a bioenergy facility. While this may be true 

in many regions, it is generally not the case in Massachusetts 

where logging operations commonly consist of manual felling, 

bucking into logs in the field at the stump, and cable skidding 

or forwarding; thus, most tops and limbs remain on the ground 

where the trees are felled.

While it may be feasible to recover scattered logging residues 

in some circumstances, it seems fair to conclude that biomass 

supply from logging residues in Massachusetts would be minimal 

without some modifications to existing harvesting operations. 

Although these logging residues do have the advantage of having 

been felled at no cost to the biomass producer, the high cost of 

20 One shortcoming of this approach is that it is not possible to 

estimate how much of this topwood and limbwood may already 

be utilized for products (due to differing utilization standards), or 

harvested for firewood.
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3.2.3.1 Costs of Whole-Tree Harvesting

In whole-tree harvesting systems, trees are felled by either mechanical or manual means and moved to a landing with most or all of 

their tops and branches. For our analysis, the costs of whole-tree 

harvesting in Massachusetts are important because low-value trees 

that are cut only for biomass chips have to bear the full variable 

costs of the harvest. If a logging operation is arranged to include 

biomass chip production, some portion of the cost of getting 

equipment to the site and setting up operations should also be 

covered by biomass. These fixed costs are one reason that production volume is an important economic variable in determining 

the profitability of biomass harvests.

In order to estimate the costs of whole-tree harvesting in 

Massachusetts, we have conducted a large number of simulations with the Fuel Reduction Cost Simulator.24 Our main 

interest in this analysis is to understand the relationship 

between tree size and the chip production costs because it 

commonly stated that pre-commercial thinnings and small 

trees can make a significant contribution to forest biomass 

supply. This model can also be used to analyze the relationship 

between chip production costs and a host of other factors such 

as block size and skidding distance. 25

We designed this analysis to determine the cost of producing 25

green tons of wood chips on one acre (this volume is based on 

our analysis of availability in the next section) using different 

combinations of the size and number of trees.26, 27 The results 

are presented in Exhibit 3-6. Although these parameters will 

24 The Fuel Reduction Cost Simulator (FRCS) was developed by the 

U.S. Forest Service (Fight et al., 2006) to estimate the costs associated 

with fuel reduction treatments in harvests of whole trees, logs, and chips 

with a variety of harvesting systems. Although originally developed for 

forests in the Northwest, the model has been subsequently expanded 

to other regions (including the Northeast) by Dennis Dykstra and is 

available on the U.S. Forest Service website at: www.fs.fed.us/pnw/

data/frcs/frcs.shtml

25 Our analysis in Task 5 has also utilized this model as a key source 

in developing estimates of diesel consumption as a component of 

the life-cycle analysis.

26 Assumptions made so that conditions would be representative 

of average conditions of Massachusetts include: a) harvest block 

size of 50 acres, and thus an average skidding distance of 600 feet; 

b) terrain sloped 5%; c) species mix evenly distributed between 

softwood and hardwood. 

27 We also assumed no move-in costs simply to avoid the issue of 

how these costs should be shared with sawtimber operations. Movein costs depend directly on the total tons produced from a given 

logging operation. In our simulations, producing 25 green tons 

on 50 acres (1250 tons total) results in move-in costs of $1-$2 per 

green ton (assuming a 15-mile move) if there is no complementary 

sawtimber/pulpwood harvest to share the expense. If 25 green tons 

are produced on 25 acres, then move-in costs per green ton remain 

about the same because the doubling in fixed costs is approximately 

offset by the reduction in skidding costs due to shorter hauls.

At this stage of the analysis, we remain focused on biomass supplies 

from acres that are already under harvest for sawtimber and other 

industrial roundwood products. We restrict the potential for 

forest biomass to this footprint because of our assumption that 

biomass stumpage prices remain near recent levels. As shown in 

Exhibit 3-5, stumpage prices for forest biomass chips averaged 

only $1−$2 per green ton in southern New Hampshire in 2008 

and 2009. Prices were lower than this in western Massachusetts, 

but higher in Maine. At these price levels, there will be little 

incentive for landowners to bring additional acres into production. Historically (at least for the past several decades), timber 

harvests in Massachusetts have been driven by the demand for 

sawtimber23 and in this scenario, this continues to be the case.

Exhibit 3-5: Average Cost of Fuel Grade Chips in Southern 

New Hampshire

Dollars per Green Ton

Delivered Stumpage Difference

2005 $18 $0.8 $17

2006 $23 $0.8 $22

2007 $22 $0.9 $21

2008 $32 $1.2 $31

2009 $30 $1.6 $28

Source: Compiled from average quarterly prices as reported by the New 

Hampshire Timberland Owners Association’s Market Pulse and reported 

in the Timber Crier magazine.

If the demand for biomass fuel increases in response to an expansion 

in bioenergy plants, how much “new” biomass could be harvested 

economically from areas already under harvest for sawtimber in 

Massachusetts? There are three analytical tasks involved in this 

projection. First, we address the issue of harvesting costs in Massachusetts: if new biomass demand originates from electric power 

plants, it would almost certainly be accompanied by an increase in 

whole-tree harvesting; thus, we start with an analysis of these costs. 

As shown in Exhibit 3-5, delivered prices for fuel grade chips were 

about $30 per green ton in 2008−2009 and we are assuming that 

biomass producers must be close to that target for electric power 

plants. If new biomass demand originates from thermal and CHP 

plants, they can pay higher prices for wood chips and thus have 

the option of using alternative logging methods; in addition, they 

will be competing for bolewood because of their need for higherquality chips. Second, we consider the issue of how much low-value 

timber (that is, timber with low stumpage prices) is available on 

typical stands that are being harvested for sawtimber? Once we 

have established how much low-value wood is available and the cost 

of harvesting it, we then consider whether landowners would be 

amenable to these higher harvest levels. Using this information, we 

conclude this section with a projection of how much forest biomass 

supply would be available at current energy prices.

23 According to Forest Cutting Plan reports for 1984−2003, 95% 

of harvests included sawtimber.
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We also tried to estimate the costs of such logging operations 

on the basis of a literature review. Available studies show wide 

variation in costs due to factors such as species, size, quality, 

terrain, and harvesting equipment: the range extends from about 

$20-to-$50 per green ton. However, without information that 

links harvesting costs to timber size, it is not possible to put these 

estimates in our context. It seems that pre-commercial thinnings 

and small trees should be excluded as part of the biomass resource 

in Massachusetts—as one logger in Maine told us anecdotally, 

“the fastest way to go broke in the biomass business is to harvest 

2-to-6 inch trees.”

These model results clearly demonstrate the critical importance 

of tree size and handling costs in the economics of whole-tree 

harvesting: whole-tree harvesting appears to be cost prohibitive 

for sapling-size trees. In addition, manual harvesting is much more 

expensive than mechanical in the small-diameter classes primarily 

due to the high costs of gathering and skidding unbunched trees. 

However, the cost curves for these two whole-tree systems converge 

(and eventually cross) as tree diameter increases. This may be 

important for management plans on some forests because the 

two systems will have different impacts on soils and harvest sites.

There are a variety of other harvesting systems that could be 

employed in removing forest biomass. Thermal and CHP plants 

often demand higher-quality chips than electric power plants and 

can pay more for delivered wood; thus, more harvesting options 

are available for procuring their wood supply. Log-length methods 

may be selected instead of whole-tree methods if the manager or 

operator wishes to leave tops and limbs scattered on the site and/

or is concerned about residual stand damage (to both soils and 

standing trees). Two common log-length methods that could be 

used are cut-to-length (in which mechanized harvesters are used 

to fell, delimb, and buck trees at the stump) and manual systems 

(in which chainsaws are used to fell, delimb, and buck trees at 

the stump) (Fight et al., 2006). Logs can then be debarked and 

chipped at the landing, or transported to a plant and processed 

there. Using the FRCS model, we have estimated that these 

harvesting systems will add about $10−$15 per green ton to the 

cost of delivered chips.

In future decisions regarding the choice between mechanical and 

manual harvesting systems, labor issues also are an important 

consideration. As labor costs rise and the labor force ages, there 

will be a preference for mechanized harvesting to reduce overall 

labor costs (including improving safety and reducing insurance 

premiums for health, liability, and worker’s compensation). Labor 

costs have been identified as having an important role in increasing 

mechanized harvesting—both whole-tree and cut-to-length—in 

some regions. 

3.2.3.2 The Availability of Low-Value Wood in 

Massachusetts Forests

The Low-Price Biomass scenario assumes that biomass stumpage 

will be available for $1−$2 per green ton, which is generally the 

price we see throughout markets in New England. Here we provide 

differ by individual site, logging equipment, harvest layout 

and many other factors, we believe our general conclusions 

are robust.

Exhibit 3-6: The Influence of Tree Size on the Cost of Chips 

($/GT, FOB Truck, at Landing) Using Mechanical and 

Manual Whole-Tree Harvesting

DBH, in Height, ft # Trees* GT/Tree Mech WT Man WT

3.0 25 980 0.03 $92 $160

5.0 35 287 0.09 $51 $63

7.0 45 92 0.27 $26 $28

9.0 55 46 0.54 $19 $21

11.0 60 30 0.85 $16 $17

13.0 65 21 1.22 $14 $13

15.0 70 15 1.63 $13 $11

Notes: * “# Trees”denotes the number of trees at each diameter and height 

that are required to yield 25 green tons of chips.

In these calculations, mechanical harvesting uses a drive-to-tree fellerbuncher and grapple skidder. Manual harvesting uses chainsaw felling in 

combination with chokers and cables to skid unbunched trees.

The model suggests that the minimum size threshold for wholetree harvesting in Massachusetts is in the range of 7.0−9.0 inches 

DBH if the economic objective is to deliver chips to a bioenergy 

plant at a cost of about $30 (or less) per green ton. In addition to 

harvesting costs, this estimate allows for: 1) $1−$2 per green ton 

for biomass stumpage; 2) $8−$12 per green ton for truck transport 

to the bioenergy plant; 3) recognition of the potential range in 

model estimates due to site-specific factors and modeling errors.28

It is important to note that these estimates include machinery and 

equipment costs. While lower delivered prices may not attract 

new investment in machinery and equipment, those who already 

have equipment may choose to operate if they are able to cover 

only their variable costs of production.

Costs rise exponentially when tree sizes decrease below this level 

because of the exponential relationship between tree diameter and 

weight. For example, it would take about 40 trees that are 3-inches 

DBH to produce one ton of green chips, and thus it would take 

almost 1000 trees to generate 25 tons of green chips. The number 

of trees required for 25 green tons could be reduced to about 100 

at 7-inches DBH and to only 10 trees if tree DBH was 18 inches.

28 Modeling errors can arise from many sources. For example, 

on the fixed cost side, key areas of concern would be the choice of 

equipment and the calculation of ownership costs for situations in 

Massachusetts. On the variable cost side, wage costs and diesel costs 

are important parameters that may vary significantly over time and 

for different operations.
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These data provide only a starting point and need several adjustments before they can serve as a useful upper bound for potential 

biomass supply. About 30% of grade 4 & 5 trees are greater 

than 25" DBH; it is not practical to harvest these trees with 

standard equipment. On the opposite end of the spectrum, 

about 20% of the pulpwood trees are less than 7" DBH and 

we exclude half of these (those that may be in the 5"−6" range) 

because of their higher harvesting costs. Finally, as discussed 

earlier, some poletimber-size trees are already being harvested 

for pulpwood/fuelwood end uses; these total about 10 green 

tons per acre (when adjusted to a comparable basis with the 

inclusion of tops and limbs).

With these adjustments, the availability of grade 4 & 5 trees is 

reduced from 21 to 15 green tons per acre; pulpwood is reduced 

from 27 to 12 tons per acre; and rough cull remains at 11 tons 

per acre; hence, the revised total of available biomass is 37 green 

tons per acre. At the risk of appearing overly precise, we should 

recognize that this timber will continue to grow: if we assume the 

volume increases by an average net annual growth rate of 2% per 

year for 71⁄2 years to reflect the average availability in 2010−2025, 

timber availability rises to 43 green tons per acre.31

This review characterizes the potential availability of biomass in 

broad terms of value and economic accessibility, but there is still 

a good deal of uncertainty in defining what share of this volume 

would be available at very low stumpage prices. At this level of 

aggregation, there is no straightforward way to address this, but 

it would be reasonable to assume that not more than half of 

low-grade sawtimber and poletimber could be purchased and 

harvested at low stumpage prices. This would reduce available 

supply to the range of 20−25 green tons per acre. On the basis of 

the information and assumptions presented above, we think that 

15 green tons per acre is a good “ballpark” estimate of incremental 

whole-tree biomass potential—we also consider 20 green tons per 

acre as a potential upper bound.

3.2.3.3 Landowner Willingness to Harvest

We have identified a significant volume of low-value wood in 

Massachusetts that could be harvested at low cost, at least with 

whole-tree harvesting systems. The question that remains is: 

if the demand for forest biomass from private timberlands in 

Massachusetts increases (from bioenergy plants established in 

Massachusetts, nearby states, or overseas), what is the likelihood 

that we would see increased biomass harvests in conjunction with 

sawtimber operations? Would landowners be receptive to these 

changes? In many cases, there could be strong economic incentives, 

even though they would not be the result of direct, immediate 

income in the Low-Price Biomass scenario.

While there is a tendency to use landowner surveys to highlight 

the lack of interest in timber production in Massachusetts, 

there is a flip side to this viewpoint. Every year, an average of 

22,300 acres of private timberland in Massachusetts is harvested, 

31 Increasing the available volume for growth has the same effect as 

the inventory variable in standard economic models of timber supply.

a broad overview of the volume of wood in Massachusetts forests 

that might be available at such low prices.

Approximately 65% of the standing trees on Massachusetts timberland are 1"−5" DBH; however, in spite of their large numbers, 

these sapling-size trees represent only 5% of the timber volume 

on a tonnage basis (FIA Statistics for 2008). It would be cost 

prohibitive to harvest trees in this size class based on our analysis. 

In order to be competitive in current markets, biomass producers 

would need to harvest trees with low stumpage value that are 

greater than 5" DBH.

As discussed earlier, sawtimber harvests are crucial in opening 

timber stands to biomass production. In Massachusetts, sawtimber 

harvests will typically take place in stands that are 60-to-100 years 

old, and FIA data for 2008 indicate that these stands account 

for 80% of total growing stock volume. Thus, these age classes 

are by far the most important in identifying the availability of 

low-cost wood.

Exhibit 3-7 presents the total volume and volume per acre for 

timber stands classified in the 61−100 year age class in Massachusetts.29 The key groups that are potential sources of biomass 

potential are: 1) rough cull trees, with 8% of the average stand 

volume; 2) grade 4 & 5 trees, with 16% of the volume; and 3) 

pulpwood trees,30 with 21% of the volume. As reported in this 

table, the combination of these three groups totals 59 green 

tons per acre.

Exhibit 3-7: Timber Volume by Tree Grade, Age Classes 

61−100 Years in Massachusetts (All Timberland) 

000 Acres and Million Green Tons, 2008

Quantities Share GT / Acre

Acres (000’s) 2,120

Total Volume 

(millions)

273.2 100% 129

 Grades 1 & 2 76.4 28% 36

 Grade 3 67.9 25% 32

 Grades 4 & 5 44.7 16% 21

 Pulpwood 57.8 21% 27

 Rough Cull 23.0 8% 11

 Rotten Cull 3.5 1% 2

Note: FIA data; include all live volume (merchantable volume, tops, limbs, 

and stumps) in trees ≥ 5 inches DBH.

29 These volumes represent total tree biomass, not just bole volumes. 

Since we are not interested in total volumes for individual ownerships, 

we have combined the data for private and public lands to obtain 

more accurate estimates of grade shares and per-acre volumes.

30 Pulpwood is defined as 5"−9" DBH for softwood trees, and 

5"−11" DBH for hardwoods.
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This projection is predicated on several key assumptions:

• The total land area harvested remains at the historical average.

• One half of this area is managed as it has been in recent 

years. The same volume of sawtimber and other industrial 

roundwood will be harvested and no logging residues are 

harvested for biomass because such operations are not justified by the economics (due to scattered material which is 

costly to harvest and low volumes per acre). Due to the low 

level of pulpwood stumpage prices, it is possible that some of 

this material could be diverted to biomass fuel, but we have 

not included this potential shift as part of the Low-Price 

Biomass scenario.

• The other half of the land area harvested receives silvicultural 

treatments that include whole-tree biomass harvesting.35

While many landowners will find this management option 

suitable for their objectives, many others will not look favorably upon heavier logging of their woodlots.

• On the acres that are harvested more intensively with wholetree methods, 65% of tops and limbs removed for industrial 

roundwood production are harvested for biomass. (As noted 

above, pulpwood is assumed not to be diverted to biomass 

in this scenario.)

• For whole-tree biomass harvests, 15 green tons are cut per acre. 

Of this volume, 10% is left on the harvest site for ecological 

reasons (this is equivalent to 1/3 of tops and limbs).

Projections for this biomass harvest scenario are shown in Exhibit 

3-8. Land is classified as “1⁄2 Current” (land harvested as in recent 

years) and “1⁄2 WT” (land harvested with whole-tree harvesting). 

Removals per acre average 21.8 green tons in “1⁄2 Current,” compared 

to 36.8 green tons in “1⁄2 WT,” so the removals per acre average 29.3 

green tons statewide (compared to 21.8 tons with no additional 

biomass harvesting). Total forest biomass fuel harvested averages 

16.5 green tons per acre in “1⁄2 WT,” and 8.3 green tons per acre 

for all private lands in Massachusetts. On the acres where biomass 

is harvested, 13.5 green tons come from whole trees, while 3.0 

green tons consist of residues from sawtimber/pulpwood harvests.

As shown in Exhibit 3-8, this scenario results in 184,000 green 

tons of additional biomass produced for bioenergy on private 

lands in Massachusetts. If we increase the biomass removal rate to 

20 green tons per acre, the biomass harvest increases to 235,000 

green tons. The availability of low-value stumpage (timber that 

will be sold for only $1−$2 per green ton) and the implications 

35 This assumption is consistent with an electric power demand 

scenario. It can be easily modified for thermal or CHP demand. 

We would assume that stumpage prices remain at the same level—

thermal and CHP could pay more for stumpage but there is no 

reason to do so unless competing for higher-value timber. The main 

difference would be that if loggers do not use whole-tree methods, 

then tops and limbs would be excluded from the harvest volumes.

primarily for sawtimber. More than half of the private acreage 

in Massachusetts (1.2 million acres) is held in parcels that are 50 

acres or larger (Butler, 2008).32, 33 Owners of 40% of the family 

forest land (about 650,000 acres) reported that a commercial 

harvest—sawlogs, veneer logs, or pulpwood—occurred since 

they acquired the land.34 The large majority of these owners 

stated that they harvested trees because the trees were mature 

and/or they wished to improve the quality of the remaining 

trees. Suffice to say, while timber production is certainly not 

the number one priority on most private forest land in Massachusetts, there is a significant component of the forest land base 

in Massachusetts that is used to generate timber income and 

would likely be available for more aggressive forest management 

under the right circumstances.

There are landowners who would like to pursue forest management 

practices that will enhance the growth of their forest for future 

commercial timber production. With no market for biomass, 

these owners need to pay loggers for the cost of harvesting and 

collecting low-value wood and then may have an additional cash 

outlay for slash disposal. This could be a substantial investment 

with a return not seen for many years. However, with a “new” 

market for biomass fuel, the prices for delivered biomass may be 

sufficient to cover logging costs and may go beyond break-even 

to generate positive stumpage values for this material. Thus, 

harvesting of forest biomass could open the door for alternative 

forest management practices that are focused on improving 

sawtimber growth and value.

3.2.3.4 A Forecast of Forest Biomass Supply 

in Massachusetts with Low-Price Biomass 

Stumpage

Here we combine the information above to forecast how much 

“new” forest biomass could be supplied if demand from bioenergy 

facilities increases while real biomass stumpage prices remain at 

recent levels. The forecast is intended as an upper limit in the 

sense that any volume less than this could be produced to meet 

the demand from bioenergy plants at similar prices.

32 Landowner survey results show that only 43% of the 1.7 million 

acres that are family owned are 50 acres or larger; however, 88% of 

the remaining 0.4 million acres held by private owners belong to this 

size class.

33 The National Woodland Owner Survey provides a substantial of 

information intended to characterize the behavior of private forest 

owners in the United States. The main report summarizing these 

data is Family Forest Owners of the United States, 2006 (Butler, 

2008). An on-line version—NWOS Table Maker Ver 1.01—

provides users with the ability to create their own customized tables 

for individual states.

34 Among survey respondents, 25–30 years seems like a reasonable 

approximation of the average ownership tenure for family-owned 

land (measured by area, not number of owners): the ownership 

tenure was 25–49 years for about 40% of the family-owned acreage 

and 10–24 years for about 30% of the acreage.
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Biomass Sustainability and Carbon Policy Study

3.2.3.5 The Experience in Nearby States

It is useful to consider this outlook for whole-tree harvesting with 

respect to other states in New England where whole-tree harvesting 

is now more extensive than in Massachusetts and has a much longer 

history, and thus might be considered to be in a mature phase. Maine 

and New Hampshire, with relatively large forest products industries 

and well-developed wood-fired power plant sectors, may represent 

the potential for whole-tree harvesting when the industry pursues 

more aggressive harvest yields with mechanization. State harvest 

reports indicate the following: in Maine (Maine Forest Service, 

2009), forest biomass chips comprised 23% of the total harvest 

of roundwood products in 2008 (3 million green tons out of a 

total harvest of 13 million green tons); in New Hampshire (New 

Hampshire Report of Cut, 2008), the comparable share was 24% in 

2000−2006 (790,000 green tons out of a total harvest of 3.2 million 

green tons, on average). Whole-tree harvesting is not practiced to 

the same extent in Vermont (Vermont Forest Resource Harvest 

Summary, various years), where forest biomass chips represented 

an average of 13% in 2000−2006 (200,000 green tons out of a 

total harvest of 1.5 million green tons, on average).

for removal rates is one of the key assumptions in this scenario. 

Further analysis of these removal rates is provided below. 

The share of land assumed to be harvested using whole-tree methods 

is also a critical assumption in this scenario. The relationship between 

biomass production and this share is linear in our formulation since 

we are working with “average” acres. Thus, if whole-tree harvesting 

and increased harvesting intensity were used on only one-quarter of 

all private lands being harvested commercially, production of biomass 

for bioenergy would be reduced to 92,000 green tons; similarly, if 

these practices were extended to all commercial harvests on private 

lands, biomass production would increase to 368,000 green tons.

In the next section, we review related data from nearby states to 

provide some perspective on these estimates of forest biomass production for Massachusetts. The data from nearby states give us some 

confidence that our forecasts are in the appropriate range; however, 

it is difficult to say for sure without more detailed analysis of timber 

sales and more experience with biomass harvesting in Massachusetts.

Exhibit 3-8: Biomass Supplies Available from Massachusetts 

Private Lands under the Low-Price Biomass Scenario

Annual Rates, 2010−2025 (Green Tons and Acres)

Current Low Biomass Price

Harvest 1⁄2 Current 1⁄2 WT Total

Area Harvested (acres) 22,300 11,150 11,150 22,300

Wood Removals Green Tons per Acre

 Industrial Removals 21.8 21.8 21.8 21.8

 Roundwood Harvest 17.1 17.1 17.1 17.1

 Logging Residues Generated 4.7 4.7 4.7 4.7

 Left on Site 4.7 4.7 1.6 3.2

 Harvested for Biomass Fuel 0.0 0.0 3.0 1.5

 Whole-Tree Biomass Removals 0.0 0.0 15.0 7.5

 Whole-Tree Harvest 0.0 0.0 13.5 6.8

 Logging Residues Left on Site 0.0 0.0 1.5 0.7

 Total Removals 21.8 21.8 36.8 29.3

 Total Biomass Harvest 0.0 0.0 16.5 8.3

Wood Removals 000’s of Green Tons

 Industrial Removals 485 243 243 485

 Roundwood Harvest 381 191 191 381

 Logging Residues Generated 104 52 52 104

 Left on Site 104 52 18 70

 Harvested for Biomass Fuel 0 0 34 34

 Whole-Tree Biomass Removals 0 0 167 167

 Whole-Tree Harvest 0 0 151 151

 Logging Residues Left on Site 0 0 17 17

 Total Removals 485 243 410 652

 Total Biomass Harvest 0 0 184 184

Notes: “Current Harvest” is a projection assuming that commercial harvests continue at average levels of the past several years and there is no additional 

harvesting for biomass. With the increased harvest in the Low-Price Biomass scenario, one half of acres are assumed to be managed in the same way as in the 

Current Harvest Projection (“1⁄2 Current”), and one half of acres are assumed to be managed more intensively using whole-tree harvesting techniques (“1⁄2 WT”).
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Biomass Sustainability and Carbon Policy Study

not modeled the dynamics of the harvesting and transport sector, it 

would be reasonable to assume that these costs would also increase 

in the near term due to the limited supply of loggers, foresters, 

machinery, and equipment; thus, delivered wood prices would likely 

rise well above $50 per green ton. However, we would anticipate 

that harvesting and transport costs would subsequently retreat 

with increasing competition and new investment in harvesting 

machinery and equipment. If these increases in wood costs were 

fully incorporated into the price of electricity, the impact would 

be as follows: a $20 per green ton increase in delivered wood prices 

(from $30 currently to $50) would equate to an increase of 3.2 

cents per Kwh; delivered wood prices of $60 per green ton would 

translate to an increase of 4.8 cents per Kwh; and $70 per green 

ton would equate to an extra 6.4 cents per Kwh.

There are a variety of other scenarios that could lead to the production of much higher volumes of forest biomass fuel supplies. A 

key factor distinguishing these scenarios are those in which exogenous factors affect biomass demand directly (examples would be 

increasing energy production or high export demand for biomass 

fuel) and those that stimulate other commercial timber production 

(examples would be housing policy or local product promotion) 

and increase biomass production as by-product. Generally, biomass 

prices will rise in cases where there is direct demand stimulus; 

however, if biomass production rises as a by-product of expanded 

sawtimber production, biomass prices will remain low. We have 

assumed that higher biomass demand drives this scenario for 

two reasons: 1) we are primarily interested in energy policy, and 

whether forest biomass supplies would be adequate to support 

an expansion of bioenergy capacity; and 2) the probability of a 

substantial increase in sawtimber production seems fairly remote.36

There are several issues that need to be considered in gaining an 

appreciation for how much biomass could be harvested from 

private lands in Massachusetts if biomass stumpage prices were 

to rise substantially. These include:

• How large is the operable land base, or in other words, how 

much land should be excluded from potential harvesting due 

to biophysical constraints or lack of landowner interest in 

timber production?

36 Although lumber production is likely to recover from the recent 

downturn, we are aware of no studies that project the lumber industry 

in this region (or in the U.S. North in general) to move above the trend 

levels of the past decade. Although the sawtimber inventory is rising in 

Massachusetts, there appear to be few other competitive advantages that 

would promote an expansion of the sawmilling industry: 1) maturing 

timber has not resulted in increasing sawtimber harvests in the past two 

decades; 2) sawmills are closing in Massachusetts, not expanding, and 

lumber capacity has contracted sharply over the past decade; 3) there 

are questions about sawtimber quality due to age and years of partial 

cutting for sawtimber production; 4) there is plenty of “cheap” timber in 

competing areas of North America and the world and this is especially 

true over the coming decade due to delays in timber harvesting that 

have occurred as the result of the housing debacle of 2007−2010.

For Massachusetts, our Low-Price Biomass scenario (assuming 

removal of 15 green tons in silvicultural treatments with biomass) 

yields a harvest share for forest biomass chips of about 33% (this 

figure includes whole-tree chips from tops and limbs produced in 

harvesting industrial roundwood). Thus, relative to the northern 

New England experience, it appears that our scenario would 

represent a reasonable upper bound for expected outcomes. With 

assumed biomass removal rates of 20 green tons per acre, the forest 

biomass harvest share in Massachusetts would increase to 38%, 

which would seem high, particularly when considered in the 

context of differences in parcel size, attitudes, and social factors 

among the states. However, this share will depend on other factors 

that could favor a higher share in Massachusetts including: the 

availability of low-value timber on forest stands that are being 

harvested; and, the extent of alternative outlets for pulpwood 

along with the relative strength of demand and prices for pulpwood 

and biomass fuel. Given these uncertainties, we have reported the 

likely biomass harvest as a range from 150,000 to 250,000 green 

tons per year, thus spanning the estimates (184,000 and 235,000 

tons) provided above. 

3.2.4 High-Price Biomass from Private 

Timberlands

How much would forest biomass supplies increase if bioenergy 

plants could pay higher prices for stumpage? As demand and 

prices increase, more wood can be supplied from private lands 

by increasing the volume of wood removed from sites that are 

already under harvest for industrial roundwood, diverting wood 

from other end-use markets (such as pulpwood) to biomass, and 

increasing the number of acres being harvested. This scenario is 

intended to provide perspective on the upper bound for forest 

biomass production if bioenergy demand and prices increase 

beyond the level established in the Low-Price Biomass scenario. 

It is not reasonable to specify an absolute maximum for biomass 

supply since supply is an economic concept that depends on 

timber prices (and a host of other factors). Thus, we need to 

specify a “high” biomass stumpage price, and then consider 

how private landowner harvests might respond to this price 

level. Forest biomass volumes could still increase beyond this 

level, but it would be increasingly difficult to due to biophysical, 

economic, and social constraints and increasingly unlikely due 

to macroeconomic and energy constraints.

The amount that bioenergy plants can afford to pay for wood is 

a function of the prices they receive for their output. In order 

to determine a biomass stumpage price in this limiting case, we 

have assumed that the increase in demand for biomass comes 

from an expansion in electric power capacity (this assumption 

does not, however, restrict the usefulness of these results for 

other types of bioenergy). We have considered several electric 

price scenarios and selected $20 per green ton as the real biomass 

stumpage price that would reflect the high end of projections 

for electricity prices.

A biomass stumpage price of $20 per green ton would be consistent 

with a significant increase in the price of electricity. Although we have 
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Biomass Sustainability and Carbon Policy Study

In order to estimate the size of the operable land base on private 

lands, we rely on a variety of studies and a growing body of research 

on landowner behavior and factors that affect willingness to 

harvest. Our general approach, which has become fairly standard, 

is to reduce the total land area to account for: 1) physical land 

attributes that limit logging access; 2) small parcels that have a 

low probability of being harvested due to economic and social 

factors; and 3) lack of landowner interest in producing timber 

due to the higher value of nontimber benefits.38

Physical factors appear to be relatively unimportant in limiting 

harvesting activity in Massachusetts. A study by Butler et al. 

(2010) indicated that 6% of the land in family-forest ownership 

should be considered unavailable due to biophysical restrictions 

(primarily slope and hydric physiographic class). Kelty et al. 

(2008) assumed 7% of forest land was off limits to logging based 

on a review of forest plans for the Quabbin state forest. For our 

scenarios, we have reduced the private land area by 5% to account 

for these factors, and have done so assuming that the restrictions 

are distributed equally across all groups and size classes.

Our next step is to eliminate parcels of small size. The rationale for 

their removal is twofold: 1) the attitudes of owners holding small 

parcels, who tend to be focused on forest benefits other than timber 

income; and 2) the relatively high costs of wood production on small 

parcels, which becomes much more important when whole-tree 

harvesting of biomass fuel is considered. The distribution of acres 

across ownership size classes is presented in Exhibit 3-10.

Exhibit 3-10: Number of Acres Held by Size of Holdings, 

Private Land Owners, 000’s (2002−2006)

Acre Class Family Other Total Percent # Owners

1−9 562 0 562 26% 261

10−19 208 0 208 10% 17

20−49 187 61 248 11% 8

50−99 250 62 312 14% 4

100+ 479 370 849 39% 3

TOTAL 1,686 493 2,179 100% 293

Notes: Data are from Family Forest Owners of the United States, 2006 

(Butler, 2008). Family owners are defined as “ families, individuals, 

trusts, estates, family partnerships, and other unincorporated groups of 

individuals that own forest land.” Other private owners are industry, 

corporations, clubs, and associations. 

38 We should note that we have not adjusted the total land area for 

land clearing and conversion. If forest land clearing continues at recent 

historical rates (which we discuss in more detail in Section 3.5.1), this 

would mean a reduction of about 70,000 acres of private forest land 

(only 3% of the total) over the next 15 years. However, as noted earlier, 

this number could be much larger historically (and going forward), 

but it is difficult to measure the magnitude of the shift accurately and 

to document the exact causes of land use changes. However, this shift 

clearly becomes of greater consequence over a longer time horizon. 

In addition, land clearing is linked to trends in land fragmentation 

which has important implications for wood supply.

• What is an appropriate harvest schedule for these lands, or 

over what period might we expect initial harvests to begin 

and for these lands to be brought under management?

• What share of this land is likely to be drawn into production 

at different price levels? Harvesting these lands is not an all 

or nothing proposition, so here we consider how landowners 

may respond to higher biomass prices and the higher income 

they may receive from such harvests.

After discussing each of these factors, we provide a forecast of 

biomass supplies at much higher demand and price levels. We 

then review some key areas of uncertainty and provide some 

sensitivity analysis for important assumptions.

3.2.4.1 Estimation of the Size of the Operable 

Private Forest Land Base in Massachusetts

As shown earlier, the area of private land harvested in Massachusetts has been very stable over the past 15 years, and has not 

exceeded 25,000 acres during the 25 years for which we have data. 

This sort of stability would be consistent with a regulated forest 

where each age class has the same number of acres. However, 

this is far from the case in Massachusetts, which would be better 

described as an even-aged forest due to the high concentration of 

timber in a few age classes: Exhibit 3-9 indicates that about 50% 

of the acreage on private lands in Massachusetts is in the 61−80 

year stand-age grouping (according to Kelty et al., 2008, this is 

about the age that the first partial thinning is done by most owners 

interested in harvesting timber). Much of the standing timber 

inventory in Massachusetts can be considered already mature or 

approaching maturity; in fact, natural mortality exceeds removals 

according to the FIA data for 2008.37 These age-class data suggest 

that with higher demand and higher prices, harvesting activity 

could increase and break out of the stable pattern seen historically. 

Exhibit 3-9: Number of Timberland Acres by Age Class, 

Private Land Owners, 000’s (2004−2008)

Age Class Acres Percent

0−20 24 1%

21−40 69 3%

41−50 142 7%

51−60 202 10%

61−70 529 26%

71−80 507 25%

81−90 373 18%

91−100 101 5%

100−120 60 3%

120+ 18 1%

TOTAL 2,026 100%

Source: FIA data.

37 Although these differences are not statistically significant 

given the large sampling errors associated with both removals 

and mortality.
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Biomass Sustainability and Carbon Policy Study

in minimal activity as compared to 43% who planned to harvest 

sawlogs. In response to their reason for owning their land, 71% 

(again, based on acreage) said for beauty and scenery, 51% said for 

privacy, and only 34% said to produce sawlogs or pulpwood. At 

the same time, although timber income is not a primary motivation for owning land, it is still important as owners of 66% of the 

land reported having a commercial harvest on some portion of 

their land during their tenure. (All data are from the National 

Woodland Ownership Survey, on-line data, Butler et al., 2008.)

Based on these survey data, we have reduced the available area 

of family-owned forest parcels that are greater (or equal to) 20 

acres by 20%, which believe is conservative. We have assumed 

the same adjustment is appropriate for landowners in the “other 

private” category.

A summary of the results from our process of netting down the 

private land area to obtain the operable land base is shown in 

Exhibit 3-11. Our methodology and assumptions reduce the total 

private land base by 51%, thus leaving 1,071,000 acres of private 

land available for harvesting in Massachusetts. It is interesting to 

compare these results with two other studies for Massachusetts 

that use similar methods, but different assumptions. Kelty et al. 

(2008) provides two scenarios of private land availability: the 

higher has 1,072,000 operable acres when 10 acres is used as a 

parcel size threshold (and other constraints are introduced) 40; a 

second scenario with a 100-acre threshold shows only 379,000 

acres available (which seems somewhat extreme compared to our 

calculations). Butler et al. (2010) estimate that biophysical and social 

constraints on private lands might reduce the wood available from 

family-owned forests by 68% (we show a 59% reduction for the 

family-forest category). That study also uses a 20-acre threshold, 

but assumes a much larger reduction due to social constraints.

Exhibit 3-11: Private Land Area Available for Timber 

Harvesting in Massachusetts, After Deductions for 

Biophysical and Social Constraints 000 Acres

Family 

Owners

Other 

Private Total

Total Timberland Area 1,686 493 2,179

Reduce for Physical 

Constraints (5%) 1,602 468 2,070

Reduce for Small Parcels (< 

20 Acres) 870 468 1,339

Reduce for Other Social 

Factors (20%) 696 375 1,071

Percentage Available 41% 76% 49%

3.2.4.2 Harvest Schedule for the Operable Land 

Base

The above analysis provides an estimate the total size of the operable land base. The 22,300 acres that are already being harvested 

40 It is tempting to consider the nearly identical results as confirmation 

of the validity of one or both approaches. The two approaches are 

different, and the fact that the results are almost identical is coincidental.

Analysis of landowner attitudes leads to the conclusion that interest 

in timber production is highly correlated with size of forest holdings, and most owners of small parcels choose to own forest land 

for reasons other than wood harvesting (although they are often 

interested in obtaining fuelwood for their own use). For example, 

for the land held in parcels less than 10 acres, a large majority of the 

land would not be logged or there would be “minimal activity to 

maintain forest land” during the next five years, while all respondents 

said they would not harvest sawlogs or pulpwood.39

Butler et al. (2010) suggest that the minimum operable size for timber 

harvesting may now be about 15 acres, and might be increasing 

into the range of 30 acres, based on studies that have evaluated the 

economies of scale associated with modern harvesting equipment. 

Surveys of minimum economical scale for whole-tree harvesting in 

Vermont among different stakeholder groups provided responses 

that were concentrated around 800 green tons per logging operation (Sherman, 2007). Average responses by group were: foresters, 

27 acres at 12 cords per acres (810 green tons); logging contractors, 

23 acres at 14 cords per acre (805 green tons); chipping contractors, 

15 acres at 21 cords per acre (788 green tons). These data suggest 

that removing an average of 25 green tons of the wood on an acre 

would require a logging site of at least 30 acres.

Using the information on both landowner attitudes and economies of scale, we have excluded parcels less than 20 acres from 

the operable land base. While there seems to be evidence that 

the harvest threshold may now be above this level, we have tried 

to be conservative in an effort to establish an upper bound to the 

operable harvest base. In addition, this lower level allows for the 

use of current equipment and harvesting methods that may be 

suitable for smaller-scale production for thermal and CHP plants.

Another reason that this threshold is likely to be “conservative” 

and tend to overstate the amount of land available for harvesting 

and biomass production is that we have not attempted to project 

changes in the distribution of land ownership by parcel size in the 

future. There have been significant reductions in average parcel 

size historically (Kittredge, 2009). Perhaps more importantly 

for our analysis, projections suggest that there are likely to be 

significant increases in private forest land development in central 

and southeastern Massachusetts from 2000 to 2030 (Harvard 

Forest, 2010). However, as noted with land clearing, it is difficult 

to quantify these developments and they are more critical for 

long-term projections than over the next 15 years.

The final adjustment to the land base relates to landowner attitudes 

of those who hold parcels that are greater than our threshold of 

20 acres. Surveys of family forest owners indicate that those who 

hold parcels greater than 50 acres also place high value on benefits 

other than commercial timber production. For example, when 

asked about their management intentions for the next five years, 

owners of 56% of the land said they would do nothing or engage 

39 The rationale for eliminating these parcels from biomass harvesting 

becomes more obvious when one considers that the average parcel size 

in the 1−9 acre size class is only 2 acres.
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wisdom that short-run timber supply is inelastic. Of course, 

this calculation is merely suggestive of ownership behavior 

because of the quality of the data and the limited sample size.41

Furthermore, there is no possibility to consider asymmetric 

behavior and to evaluate whether landowners would respond 

in a similar fashion if prices rose sharply.

While this result is interesting, one must also be cautious in 

extrapolating the conclusions much beyond the historical 

range: in this scenario, we are considering prices and potential landowner income that is far above historical levels. Over 

the 2000−2006 period, an average harvest on private lands 

generated about $400 per acre.42 If we assume that 20 tons of 

biomass are harvested on an acre with stumpage prices of $1 per 

green ton, then per-acre income would rise by $20, or by only 

about 5%. However, if biomass prices jump to $20 per green 

ton, landowners could now earn an additional $400 per acre, 

thus doubling their income on a per-acre basis.

As biomass stumpage prices increase, we would expect that many 

of the owners in the operable land base would move to take 

advantage of the opportunity to earn more income. However, 

landowners possess a complex set of objectives and it is difficult to 

say how high prices would need to rise to induce all landowners 

in the operable land base to harvest biomass. It seems likely that 

the response would be mixed at $20 per green ton: the financial 

incentives would likely be too compelling for many to ignore; on 

the other hand, they are probably not adequate to attract many 

landowners who place high value on the nontimber benefits of 

owning forests and are not focused on timber revenue.

A final consideration in making a realistic assessment of the response 

in biomass harvests to higher prices, particularly in the near term, is 

the limitations of the labor and logging infrastructure. These would 

need to expand dramatically to achieve much higher harvest levels 

and this is another development that would be at odds with recent 

trends. In assessing the ramifications of this from the perspective 

of biomass supply, the concern is that harvesting costs may need 

to rise sharply to attract investment in this sector: this could mean 

reduced stumpage prices that would mitigate the supply response, or 

an increase in delivered wood prices that would choke off demand. 

We would anticipate that harvesting and transport costs would 

subsequently retreat with increasing competition and new investment in harvesting machinery and equipment.

3.2.4.4 A Forecast of Forest Biomass Supply 

with Higher Biomass Stumpage Prices

This outlook assumes that biomass stumpage prices rise to $20 per 

green ton as a result of higher demand from bioenergy plants. A 

41 We should underscore this point by recalling that the FCP data 

report only planned harvests, not actual harvest volumes.

42 We calculated this value by assuming a harvest of 2 MBF and 

using a weighted average of median red oak and white pine stumpage 

prices for western Massachusetts from 2000−2006 (University of 

Massachusetts Amherst, 2008).

each year in Massachusetts (and in our Low-Price Biomass 

scenario) are assumed to be part of this land area. In this new 

scenario, higher biomass stumpage prices encourage more of the 

landowners in the operable land base to harvest timber in any 

given year. How many more acres would be harvested annually? 

Or, put another way, what would be a reasonable time frame 

over which to enter these stands and initiate forest management?

We have assumed that 25 years would be a reasonable period over 

which bring these stands into production. The most important 

factor is the age structure of these stands. As shown earlier 

(Exhibit 3-9), the majority of the timber on private lands in 

Massachusetts has reached the age where it is appropriate to begin 

thinning based on silvicultural and economic considerations. 

Another important factor is that the harvest is “scheduled” to 

accommodate the life expectancy of electric power and other 

bioenergy plants—the facilities will need some assurance that 

wood supplies will be adequate on an ongoing basis in order to 

attract capital for large-scale investments.

If we assume that 1,071,000 acres are available among the private 

land base in Massachusetts, and that partial harvests will occur 

on these lands over a 25-year period, then 42,800 acres would 

be potentially available for harvest each year.

3.2.4.3 The Supply Curve for Landowner’s Who 

Harvest Timber

Our analysis so far has attempted to determine the maximum 

operable land base, which we have defined as the land that would 

be harvested at much higher prices. In order to provide more 

perspective on how much of this land might be accessed, we 

need to incorporate the assumptions of our High-Price Biomass 

scenario (biomass stumpage prices averaging $20 per green ton). 

How do these owners value their nontimber amenities and at 

what prices would they be willing to become active players in 

the timber market? Would these price levels be sufficiently 

compelling to bring all of these lands into production?

The prices required to increase harvests significantly on private 

lands in Massachusetts are outside the range of recent historical 

experience. This is obvious from the remarkable stability in 

harvest levels that we have seen in Massachusetts over the past 

two decades. In order to assess whether this harvest stability 

is simply the result of limited price variation or the fact that 

landowners are insensitive to price swings, we have examined 

the relationship between timber prices (a weighted index of 

real red oak and white pine sawtimber stumpage prices) and 

harvest volumes (sawtimber harvests according to FCPs).

From 1994 to 2005, observations on prices and volumes are 

tightly clustered and somewhat random: the average absolute 

deviation from the mean is only 5% for prices and 6% for 

volumes. However, a much different story emerges over the last 

few years. From the average of 2003−2005 to 2009, planned 

sawtimber “harvests” fell about 30%, while real prices dropped 

60%. This would suggest a price elasticity of timber supply 

of about 0.5, a result that is consistent with the conventional 
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Biomass Sustainability and Carbon Policy Study

biomass fuel harvested averages 32.4 green tons per acre in Bal 

WT, resulting in an average of 21.3 green tons per acre for all 

private lands in Massachusetts. On the acres where biomass is 

harvested, 31.0 green tons come from whole trees, while only 

1.4 green tons consist of residues from sawtimber harvests. 

As shown in Exhibit 3-12, this scenario results in 694,000 green 

tons of additional biomass produced for bioenergy from private 

lands in Massachusetts. This represents an increase of about 510,000 

green tons from our Low-Price Biomass scenario: approximately 

1/3 of the additional material comes from increased harvesting of 

“low-value” timber and the diversion of wood formerly harvested 

for non-sawtimber industrial uses to biomass; the remaining 2/3’s 

comes from new land that is brought into production. This estimate 

is intended to represent an upper limit for biomass fuel production 

in Massachusetts, given the biophysical availability of wood and 

our assessment of how landowners might respond in a situation 

with much higher biomass prices. We think this scenario provides a 

reasonable representation of biomass supply over the medium term 

with biomass stumpage prices near $20 per green ton (as noted 

earlier, this analysis does not account for logging and infrastructure 

constraints that may restrict harvesting in the near term).

There are, of course, many uncertainties in this scenario and thus 

some sensitivity analysis to key assumptions is important. One crucial 

assumption is the harvest intensity with higher stumpage prices. Our 

scenario shows total timber removals averaging 47 green tons an acre 

for harvested acres that include biomass production. This is more 

than twice the current average harvest of about 22 green tons per 

acre. Nevertheless, with biomass stumpage prices of $20 per green 

ton, bioenergy plants could compete for most timber on a typical 

stand and could probably consistently outbid lumber producers for 

Grade 3 sawtimber. If we raise per-acre biomass removals from 35 

green tons to 50 green tons (total removals increase to 62 green tons 

per acre), then the biomass harvest would increase from 0.7 million 

tons to 1.0 million tons. A further biomass increase to 60 green tons 

per acre would increase the forest biomass harvest to 1.2 million tons.

Another important assumption is the percentage of operable area 

that is harvested at higher prices. If we increase the additional 

area that is brought into production from one-half to two-thirds 

(from 10,250 acres to 13,667 acres), then the total biomass harvest 

would increase to about 800,000 green tons. On the other hand, 

if all acres were brought into production (20,500 additional acres), 

then the total biomass harvest from private lands would increase 

to 1.0 million green tons.

Relaxing some of our assumptions increases harvest estimates 

to 800,000 tons and above. In order to acknowledge these key 

uncertainties, we have summarized our results as a range from 

650,000 to 850,000 green tons. Estimation of the upper end of 

this range is not scientific, but simply reflects our judgment of the 

uncertainty in these estimates and the likelihood that harvests 

could be higher. Importantly, it is a reminder to use caution in 

using these harvest levels as point estimates.

substantial increase in landowner income brings more land into 

production. Forest biomass fuel becomes a primary timber product, 

much as pulpwood is today, and we assume that bioenergy plants 

can outbid their competitors for pulpwood and low-grade sawlogs 

and that this material is harvested more intensively as well. It is 

worth noting that $20 per green ton is equivalent to prices of 

about $50 per cord and $100 per MBF (International 1⁄4" log rule).

While is a good deal of uncertainty associated with many of 

the assumptions in this analysis, we believe that developing this 

forecast provides useful guidance while demonstrating many of 

the important factors at work. Following the presentation of the 

results, we provide some sensitivity analysis to key assumptions 

along with some discussion of the conclusions.

This projection is predicated on the following key assumptions:

• One half of the original harvest footprint of 22,300 acres 

continues to be managed as it has been in recent years. The 

same volume of sawtimber and other industrial roundwood 

will be harvested and no logging residues are harvested for 

biomass because the economics do not justify such lowvolume operations. (As in the previous scenario, the pulpwood 

produced in this “original” share of the harvest is still assumed 

to be consumed in this end-use market, although it could 

easily be diverted to biomass fuel at the assumed price levels.)

• One half of the “original” 22,300 acres receive silvicultural 

treatments that include whole-tree biomass harvesting.43

With the introduction of whole-tree harvesting on these 

acres, trees formerly harvested for other industrial markets 

are now chipped for biomass. Sixty-five percent of sawtimber 

tops and limbs are harvested for biomass.

• Of the remaining acreage available annually (20,500 acres, 

or 42,800 minus 22,300), one half is assumed to be drawn 

into production for whole-tree biomass harvests. The same 

amount of sawtimber is removed as on other lands, but all 

other roundwood harvested is used for biomass.

• For whole-tree biomass harvests, 25 green tons are cut per acre 

as higher prices increase the harvest intensity of “lower-value” 

wood. Of this volume, 10% of all material is left on the site 

for ecological reasons (equivalent to 1/3 of tops and limbs).

Projections for this High-Price Biomass scenario are shown 

in Exhibit 3-12, with the land classified as “1⁄2 Current” (land 

harvested as in recent years) and “Bal WT” (the balance of land 

harvested with whole-tree harvesting). Removals per acre average 

21.8 green tons in 1⁄2 Current, compared to 46.8 green tons in 

Bal WT; removals per acre average 38.2 green tons statewide, 

as more acres are brought into production and harvested more 

intensively than in the Low-Price Biomass scenario. Total forest 

43 As noted in our previous scenario, this assumption is consistent 

with an electric power demand scenario and can be easily modified 

for thermal or CHP demand. The main difference would be that if 

loggers do not use whole-tree methods, then tops and limbs would 

be excluded from the harvest volumes.
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Exhibit 3-12: Biomass Supplies Available from Massachusetts 

Private Lands under the High-Price Biomass Scenario

default value for the supply elasticity that frequently appears 

for non-industrial private landowners is 0.3, which seems to 

date from Adams and Haynes (1996).

In our scenario, we have assumed that biomass stumpage prices 

increase to $20 per green ton. With our price and harvest 

assumptions, per-acre incomes about double. The High-Price 

Biomass scenario also shows a 50% increase in acres harvested. 

If we consider the landowner decision variable to be how many 

acres to harvest, then our results suggest that a 1% increase in 

income results in a 0.5% increase in harvest activity. As we 

have said, this “elasticity” cannot be directly compared with 

the timber supply elasticity; however, in terms of first-order 

approximations, both are inelastic suggesting that the behavior 

assumed for Massachusetts landowners is not inconsistent with 

previous research.

Annual Rates, 2010−2025 (Green Tons and Acres)

Current High Biomass Prices

Harvest 1⁄2 Current Bal WT Total

Area Harvested (acres) 22,300 11,150 21,400 32,550

Wood Removals Green Tons per Acre

 Industrial Removals 21.8 21.8 12.3 15.5

 Roundwood Harvest 17.1 17.1 10.1 12.5

 Logging Residues Generated 4.7 4.7 2.2 3.1

 Left on Site 4.7 4.7 0.8 2.1

 Harvested for Biomass Fuel 0.0 0.0 1.4 0.9

 Whole-Tree Biomass Removals 0.0 0.0 34.5 22.6

 Whole-Tree Harvest 0.0 0.0 31.0 20.4

 Logging Residues Left on Site 0.0 0.0 3.4 2.3

 Total Removals 21.8 21.8 46.8 38.2

 Total Biomass Harvest 0.0 0.0 32.4 21.3

Wood Removals 000’s of Green Tons

 Industrial Removals 485 243 263 506

 Roundwood Harvest 381 191 216 406

 Logging Residues Generated 104 52 48 100

 Left on Site 104 52 17 69

 Harvested for Biomass Fuel 0 0 31 31

 Whole-Tree Biomass Removals 0 0 737 737

 Whole-Tree Harvest 0 0 664 664

 Logging Residues Left on Site 0 0 74 74

 Total Removals 485 243 1,001 1,243

 Total Biomass Harvest 0 0 694 694

Notes: “Current Harvest’”is a projection assuming that commercial harvests continue at average levels of the past several years and there is no additional 

harvesting for biomass. With the High-Price Biomass scenario, one half of acres of the “original” footprint are assumed to be managed in the same way 

as in the Current Harvest Projection (“1⁄2 Current”), and balance of the acres are assumed to be managed more intensively using whole-tree harvesting 

techniques (“Bal WT”).

To put these results in perspective, we have looked to the literature for estimates that may provide useful comparisons of the 

timber supply response. The response of harvest levels to prices 

is commonly measured as the timber supply elasticity. For statistical reasons, harvest response to income is not comparable to 

harvest response to prices. Nevertheless, a few comments on 

timber supply elasticities are useful. Most econometric studies 

have found timber supply to be very inelastic for non-industrial 

private ownerships. In fact, a meta-analysis indicated that of 

the 19 relevant studies that were reviewed, seven did not find 

a significant relationship between harvests and prices, that is, 

prices do not affect harvest decisions (Beach et al., 2003). The 

study also concluded that there often was not enough information in this research to compute supply elasticities (some were 

binary choice models). In spite of all the work and research 

that has been done over the past two decades on this topic, the 
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rate. We have selected 50 years in parallel with the analysis by 

Kelty et al. (2008). However, the simple fact that our starting 

year is 2010—compared to the base year 2000 used by Kelty et 

al. (2008)—changes the growth trajectory enough to reduce our 

“sustainable” growth levels compared to their results.

The second theoretical issue concerns scale: there is no simple answer 

to the question of how to define the appropriate land base. If all forest 

land in Massachusetts were included, the total land area would jump 

to about 3.0 million acres and average timber growth would be about 

4.0 million green tons per year. Using this theoretical approach, it 

would be feasible to harvest wood much more aggressively on operable private lands due to the ongoing increase in timber inventories 

on public lands and private lands that are not being harvested.

3.3 Biomass Supply from Public Lands 

in Massachusetts

This section considers the availability of forest biomass supply 

from harvesting on public lands in Massachusetts. We first 

review estimates of historical harvest levels on all public lands 

and then explore these in more detail by major agency. These 

trends are then used to develop projections of commercial timber 

harvests for public lands for 2010−2025.

Using this background and perspective, we provide two forecasts 

of biomass supply from public lands that are consistent with 

our Low-Price Biomass and High-Price Biomass scenarios. As 

discussed previously, these are projections of incremental biomass 

production and do not include biomass chips that may already 

be counted in historical wood production totals.

3.3.1 Historical Harvest Estimates

As noted earlier, we have obtained data on Forest Cutting 

Plans (FCPs) for public sector lands for the period from 1984 

to 2009. Exhibit 3-13 shows the number of acres targeted for 

harvest on public lands according to these plans. There is a 

general downward trend in these data: the annual average for 

2005−2009 was 4,300 acres, significantly less than the average 

of 5,600 acres in 1984−1988.

Exhibit 3-13: Acres Planned for Harvest on All Public Lands, 

1984−2009

3.2.5 Potential Biomass Supply Based on

Forest Growth

Previous studies of potential biomass supply in Massachusetts (reviewed 

in Appendix 3-A) have considered supply to be the maximum volume 

of low-value wood that could be harvested without reducing timber 

inventories below current levels. It is useful to compute this estimate 

to see how it compares with our estimate of biomass supply in the 

High-Price Biomass scenario. This also provides information as to 

whether our estimate is “sustainable” when using the criteria that 

harvests do not exceed net growth and that biomass harvests can be 

maintained at the same level for the foreseeable future.

The calculation of the total “sustainable” volume of biomass that 

can be harvested in Massachusetts depends critically on how the 

land area is defined and how net growth is estimated. While there 

are a variety of ways to make these calculations, here we follow the 

methodology used by Kelty et al. (2008). We define the land area 

as the size of the operable land base on private lands, which we 

have derived to be 1,071,000 acres in the previous section. For the 

growth rate, we use data from Chapter 5 on the average annual 

growth of unmanaged “mature” stands in all cover types. The average 

annual increase in the volume of above-ground live trees over the 

next 50 years is 1.3 green tons per acre. Thus, the long-term average 

annual growth (net of mortality) in Massachusetts would be 1.4 

million green tons per year. Finally, if we reduce this estimate by 

36% to account for timber that would be expected to be consumed 

as sawtimber (again following Kelty et al., 2008), average annual 

biomass availability would be 900,000 green tons per year.44

The upper end of our estimate of biomass supply of 850,000 green 

tons per year in the High-Price Biomass scenario is within the 

range of what would be considered “sustainable” based on the 

rule of harvest not exceeding growth, and thus would not result 

in a reduction of timber inventories across the operable land base. 

However, our sensitivity analysis of biomass supplies showed some 

projections as high as 1.2 million green tons per year which would 

exceed “sustainable” annual volumes as we have defined them here.

The discussion of sustainability in this context raises two important 

theoretical issues. One issue concerns the approach of calculating 

“sustainable” growth rates using initial inventory levels and fixing 

the time horizon in the future.45 The majority of the timber 

inventory in Massachusetts is over 60 years old, and given the 

shape of the timber yield curves, average timber growth rates 

are decelerating over time. As a result, the longer the future time 

span that is selected, the lower the average “sustainable” growth 

44 Note that this approach provides a “ballpark” estimate and does not 

attempt to adjust for logging residues and similar details. Estimates of 

biomass availability from previous studies using the “forest-growth” 

approach are discussed in Appendix 3-A.

45 Another approach that is commonly used but beyond the scope of 

this study is to evaluate the volume of wood that could be produced 

if the forests of Massachusetts were brought into fully regulated 

management under optimal rotation ages. Such an approach would 

likely lead to a higher estimate of long-term timber and biomass supply.
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Per-acre harvest rates have all been converted to a green ton basis 

in Exhibit 3-16. Excluding the “Other” group, sawtimber harvests 

average 17 green tons per acre, while the total harvest per acre 

ranges from 25-to-30 green tons. Thus, sawtimber has accounted 

for 56% to 67% of the wood harvested from public lands.

Exhibit 3-16: Summary of Forest Cutting Plans for Public 

Lands in Massachusetts

Harvest in Green Tons per Acre, Annual Averages, 

2001−2009

Sawtimber Pulpwood Fuelwood Total

DCR, State Parks 

& Recreation 16 7 2 25

DCR, Water 

Supply Protection 17 9 5 30

Fisheries & 

Wildlife 16 9 3 27

Cities & Towns 17 6 2 26

Other 23 6 13 42

Average, All 

Public Lands 17 7 3 27

3.3.2 Timber Harvest Projections for 2010—

2025

As with timber harvest projections for private lands, historical 

trends provide the starting point for this assessment. Our next step 

was to review the 15-year Forest Resource Management Plans for 

state forests, several of which have already been approved. Finally, 

we contacted representatives from each of the three main state 

divisions—State Parks & Recreation, Water Supply Protection, 

and Fisheries and Wildlife—to review historical cutting levels and 

discuss their expectations for harvests in the future.

On the basis of our review and discussions, it appears that historical 

averages for 2001−2009 probably provide the best estimate of acres 

to be treated and timber harvest volumes over the next 15 years. 

Information from some of the individual Forest Plans suggest that 

acres and harvests could be higher than we have observed historically, but it seems more likely that there will be some downward 

adjustments to reflect the recommendations of the Forest Futures 

Visioning Process (2010). There will, no doubt, be other adjustments to harvest areas and to harvest intensity and silvicultural 

treatments, but we do not anticipate that these will be significant 

enough to alter our assessment of future biomass potential.

With regard to the issue of biomass harvesting, there are at least 

two key factors that distinguish our analysis of potential supplies 

from private versus public lands. First, private landowners have 

the flexibility to be much more responsive to market forces and 

can adjust the acreages they choose to harvest as well as their 

silvicultural treatments. In contrast, public lands are subject to a 

wider array of objectives and planning issues and it is more difficult 

for these plans to be modified in response to changes in market 

demand and prices. Second, the harvest of tops and limbs will not 

We have assembled planned harvest data by public agency for 

2001−2009 in several tables that follow. Exhibit 3-14 provides 

annual averages of the number of acres to be harvested, along 

with timber harvests of sawtimber (MBF, International 1⁄4" rule), 

pulpwood (cords), and fuelwood (tons).46 During this nine-year 

period, state lands accounted for an annual average of 3,092 

acres, or 79% of the public area to be harvested. City and town 

lands accounted for 811 acres per year, or 21% of the total. The 

“Other” category was less than 1% of the total and consists of 

occasional harvests by the University of Massachusetts and the 

Army Corps of Engineers.

Exhibit 3-14: Summary of Forest Cutting Plans for Public 

Lands in Massachusetts

Area and Volumes, Annual Averages, 2001−2009

Acres MBF Cords Tons

DCR, State Parks & 

Recreation

1,490 4,884 4,030 2,470

DCR, Water Supply 

Protection

1,454 4,873 5,069 6,766

Fisheries & Wildlife 148 465 502 450

Cities & Towns 811 2,789 2,033 1,804

Other 30 137 75 388

Total Public Lands 3,933 13,148 11,709 11,877

Harvest rates on a per-acre basis are presented in Exhibit 3-15. 

Among the major groups, the harvest intensity for sawtimber 

was very consistent, ranging from 3.2-to-3.4 MBF per acre; these 

compare with harvest rates of 2.0 MBF per acre on private lands. 

“Pulpwood” harvests averaged 3.0 cords per acre and “fuelwood” 

harvests averaged 2.9 green tons per acre.

Exhibit 3-15: Summary of Forest Cutting Plans for Public 

Lands in Massachusetts

Harvest per Acre, Annual Averages, 2001−2009

MBF Cords Tons

DCR, State Parks & 

Recreation

3.3 2.7 1.7

DCR, Water Supply 

Protection

3.4 3.5 4.7

Fisheries & Wildlife 3.2 3.4 3.0

Cities & Towns 3.4 2.5 2.2

Other 4.5 2.5 12.8

Average, All Public 

Lands

3.3 3.0 3.0

46 As noted earlier, “pulpwood” is sometimes referred to as “cordwood” 

and likely contains a combination of wood that will be shipped to pulp 

mills and processed for fuelwood. Fuelwood includes both residential 

fuelwood that will be cut and split and wood that will be processed into 

biomass chips.
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The main vehicle for achieving the increased biomass production on public lands will be the diversion of wood from other 

end uses: at the projected price levels for biomass stumpage, 

bioenergy plants will be able to outbid their competitors for 

low-grade sawtimber, pulpwood, and residential fuelwood. We 

do not expect that forest management plans on public lands 

would be modified to increase the total volume of material that 

could be harvested on designated logging sites.

In this scenario, incremental biomass production from public lands 

is estimated as follows: 1) about 4,000 acres will be harvested each 

year; 2) all of the pulpwood harvested—7 green tons per acre—will 

now be chipped for biomass; 3) half of the fuelwood harvested—1.5 

green tons per acre—will also be chipped for biomass (it is known 

that much of the reported fuelwood volume is already consumed 

for biomass fuel so we have assumed half simply to recognize this 

phenomenon). Thus, “new” biomass supplies from public lands 

would total 34,000 green tons per year (4,000 acres x 8.5 tons/acre).

We have assumed that the removal of tops and limbs will not be 

acceptable under new silvicultural guidelines for state lands. We 

should note that if the removal of logging residues were permissible, 

this would further increase biomass supplies by about 17,000 green 

tons, thus bringing the total from public lands to approximately 

50,000 green tons per year.

We should point out that our scenarios reflect relatively light harvests 

on state lands relative to the volume of timber grown each year. In 

these scenarios, timber inventories on state lands continue to rise, 

resulting in rising levels of carbon storage. If the political winds 

on harvesting shift, these policies could be modified so that much 

more biomass is harvested from state lands. However, we think that 

such a scenario would have low probability because of the state’s 

mandate to balance a wide array of timber and nontimber objectives.

3.4 Summary of Forest Biomass 

Supplies in Massachusetts

The volumes of biomass available from private lands and public 

lands for our two scenarios are summarized in Exhibit 3-17. 

Importantly, we should re-emphasize that these data represent the 

incremental volumes of biomass that we project could be supplied 

in response to expanded demand from new bioenergy plants, and 

thus would be available to furnish these facilities.

Our Low-Price Biomass scenario was designed to evaluate the 

potential supplies of forest biomass that might be produced if 

there was an expansion in demand from bioenergy plants. This 

analysis was motivated by the assumption that if the increase for 

demand originates from wood-fired electric power plants, they 

will not likely be able to pay much more than the current price of 

$30 per green ton without significant increases in real electricity 

prices; thus, given the harvesting and transport costs, there is 

little value left for stumpage. This same volume of wood could be 

utilized by thermal and CHP plants—they could pay more for 

stumpage than the $1−$2 per green ton that we have assumed, but 

be permitted from public lands if new management guidelines 

suggested by the Forest Futures Visioning Process are adopted.

Thus, once management plans have been established on public 

lands, undergone public scrutiny, and been officially approved 

by the responsible agency, it is more difficult to increase harvests 

in response to potential new demand from bioenergy plants. 

However, while the volume of wood to be harvested may be 

pre-determined, the ultimate disposition of the wood is not—

planned harvests of pulpwood and residential fuelwood might 

be diverted to biomass fuel depending on demand conditions 

and relative prices.

3.3.3 Low-Price Biomass Scenario

The economics of biomass production on private lands in Massachusetts suggest that in order to obtain sufficient volumes to 

furnish bioenergy plants and make logging operations profitable, 

it is necessary to harvest some combination of cull material, 

small trees, and low-grade sawtimber: the harvest of whole trees 

generates the volume that makes it economic to enter the stand 

for biomass production. Once that process is underway, then 

tops and limbs from industrial roundwood harvests can also be 

harvested for biomass.

Given the various constraints associated with harvests on public 

lands, we find that there is not likely to be any increase in 

biomass production above the levels that are already being 

produced for the market. (There are no estimates of the volume 

of biomass chips produced from public lands historically, but 

it is known that whole-tree biomass chips account for much of 

the “fuelwood” volume that is reported in tons on the FCPs.) 

There are several key reasons for our assessment: 1) we are not 

anticipating an increase in the total volume of wood harvested 

on public lands; on average, future annual harvest levels are 

projected to be about the same as during 2001−2009; 2) we are 

not anticipating any diversion from previous end-use markets 

(pulpwood, for example) because of the assumed low-price levels 

for biomass stumpage; 3) restrictions on the removal of tops and 

limbs mean that logging residues from industrial roundwood 

harvesting will not be available.

Thus, while there is already some production of chips on public 

lands, we do not project any significant increase in biomass supplies 

beyond recent levels.

3.3.4 High-Price Biomass Scenario

It is likely that biomass supplies from public lands would become 

significant in response to a large increase in biomass stumpage 

prices. In this scenario, biomass stumpage prices are assumed 

to increase to $20 per green ton in response to higher demand 

from bioenergy plants. As we have noted, if the higher demand 

originates from electric power plants, higher electricity prices 

will be needed for wood-fired utilities to remain in operation. 

For thermal and CHP plants, it is likely they could afford wood 

at these prices and remain profitable.
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or lumber (manufacturing residues, from furniture, pallets, etc.). 

It appears that most secondary-source material is already being 

fully utilized in Massachusetts, and this is consistent with recent 

trends that show significant inflation in their prices. Tertiary 

sources (often referred to as “urban wood”) include all other 

wood material and consists mainly of municipal solid waste, 

construction and demolition debris, and wood from landscaping 

and tree care. Tertiary material may potentially be a source of 

substantial volumes of biomass that could provide feedstock for 

new bioenergy plants and this source is briefly discussed below.

3.5.1 Land Clearing and Conversion

According to a report by Mass Audubon (2009), forest land clearing 

and conversion averaged 4,700 acres per year from 1999 to 2005. 

Forest land clearing and conversion was reported at much higher 

levels in the previous three decades, but there are numerous inconsistencies between these data and independent data on building 

and construction. In addition, the new techniques and methods 

used in the 2005 survey (involving computer imaging and digitization) provide much finer resolution and greater accuracy in 

measuring land areas cleared. Given that average building permits 

in 1999−2005 were similar to the average levels of the past 20 years, 

we have assumed that recent levels of land clearing and conversion 

represent a reasonable estimate of land clearing for 2010−2025.

We have not been able to identify any information that would 

allow us to track the volume and disposition of the wood removed 

from these lands. It is probably safe to assume that higher-value 

sawtimber material is cut and sold, whereas the fate of the lowvalue material is much harder to predict.

Given the lack of information on these land clearing and conversion operations, it is not feasible to provide a rigorous quantitative projection of biomass supply from these sources. However, 

we can provide a framework for understanding the important 

parameters in evaluating this supply—this framework can then 

be used to demonstrate the biomass potential from land clearing. 

The potential increase in biomass supply from this source over 

the next 15 years will depend on: 1) the relative size of the land 

area cleared (future versus history); and 2) the relative rates of 

biomass recovery between the two periods. As noted above, we 

have assumed that land clearing will remain at the recent historical 

level of 4,700 acres per year. Thus, any increase in biomass production will require an increase in biomass recovery rates.

In order to demonstrate the potential biomass supply from land 

clearing, two important assumptions are necessary. The first 

concerns removals of sawtimber and other high-value timber for 

industrial products: we assume that the economics always justify 

harvesting this material first and for this example we assume that 

it accounts for an average of 36% of standing timber volume. The 

second assumption is the initial stocking levels of lands to be cleared 

and we assume that an average acre has 100 green tons of wood 

(this is less than the average shown in Exhibit 3-7 which applies 

only to stands of mature timber). Thus, the maximum volume of 

wood that could have been harvested for biomass in each year of 

would not need to until demand increases to higher levels.47 On 

private lands, income from biomass production is not adequate to 

justify bringing more land into production and biomass volumes 

will be limited to increasing the harvest intensity on sites already 

being logged for sawtimber. On public lands, we do not anticipate 

an increase in the incremental volume of biomass production: 

planned harvest volumes are not likely to be modified in response 

to increased biomass demand, and low biomass stumpage prices 

will not provide the economic incentives to divert timber from 

current uses to biomass chips.

Exhibit 3-17: Summary of Forest Biomass Fuel Supplies for 

2010−2025

Low- and High-Price Biomass Scenarios

000 Green Tons per Year

Low-Price High-Price

Private Lands 150−250 650−850

Public Lands 0 35

TOTAL 150−250 685−885

Note: Some estimates are rounded for this table.

In our High-Price Biomass scenario, total “new” forest biomass 

supply increases from 150,000−250,000 green tons per year to 

about 650,000−850,000 green tons per year. We have postulated 

that increases in demand from bioenergy plants drive biomass 

stumpage prices up to $20 per green ton, and prices in energy 

markets are high enough so that electric power, thermal, and CHP 

plants can compete for this wood. The large volume increase from 

private lands occurs primarily because much higher income levels 

provide incentives to bring more timberland into production. Public 

lands are also assumed to yield more biomass as relative prices cause 

timber to be diverted from pulpwood markets to biomass markets.

3.5 Biomass Supply from Non-Forest 

Sources in Massachusetts

Our study has focused on biomass supplies from forest biomass 

sources, which include the harvesting of whole trees (including 

thinnings, cull, pulpwood, and low-grade sawtimber) and logging 

residues. These are sometimes classified as primary sources (see, for 

example, the Billion-Ton Study, Perlak et al., 2005). Wood from 

land clearing from development is also considered to be a primary 

source of wood biomass fuel in the taxonomy of the Billion-Ton 

Study. The potential volume from this source is evaluated below.

There are two other important general sources of non-forest 

biomass material that should be mentioned. Secondary sources 

(“mill residues”) include any wood residues generated in the 

processing of logs (mill residues from sawmills, veneer mills, etc.) 

47 There are several reasons (including administrative, logistical, and 

transport costs) that may lead some facilities to pay higher prices for 

biomass stumpage in their own timbershed, rather than purchase biomass 

from other locations where stumpage may be available at lower cost.
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and recreation areas and maintenance of electric power lines. The 

term can also be confusing because it is not always clear whether 

it includes “urban waste” such as construction debris. 

A literature review conducted in 2002 indicated that tree care/

landscaping sources accounted for 1.0 million tons (42%) out the 

total available supply of 2.5 million tons of non-forest wood biomass 

in Massachusetts (Fallon and Breger, 2002). However, given the 

difficulties in estimating this volume (noted in the report), this 

estimate is perhaps best used to suggest that the potential from 

these sources may be substantial and worthy of further investigation (importantly, the carbon profile of this material is generally 

similar to logging residues and thus very favorable compared to 

that of harvesting standing trees). Problems in measuring supplies 

from these sources may be attributed to: 1) the actual generation 

of this material is difficult to estimate; 2) it appears that wood 

from land clearing may be included in this estimate; 3) little is 

known about the current disposition of these materials, although 

some broad generalizations are possible such as more than half 

of the material in the Northeast is “managed on-site”; and 4) the 

economics of recovering this material are quite variable due to 

the wide variety of sources from which it is generated.

3.6 Biomass Supply from Nearby States

The outlook for how much wood is available to furnish an 

expansion of bioenergy capacity in Massachusetts is certainly 

not complete without considering potential wood supply and 

demand from the surrounding region. State boundaries mean 

little in the wood biomass market, as demand, supply, and prices 

are determined on a regional basis. New bioenergy facilities in 

Massachusetts would have access to wood from nearby states, 

while, at the same time, new bioenergy facilities in nearby states 

would have access to wood supplies in Massachusetts.

There are a number of ways to gain some insights into this issue. 

Our strategy is as follows. Given the objectives of this study, we 

have focused most of our effort on a detailed analysis of forest 

biomass fuel supplies within Massachusetts. It is not possible to 

use the same approach for the Massachusetts timbershed, so we 

assess the potential of this region by putting it in perspective relative to Massachusetts. Among the key features that we compare 

are: timberland areas, timberland inventory, timber growth 

rates, landowner characteristics, and forest products output. 

We have defined the timbershed as the counties which border 

Massachusetts: the distance across these counties is similar to 

the maximum that biomass could be economically transported 

to bioenergy plants located in Massachusetts.

Once estimates of “new” biomass supply potential are developed 

for the border counties, the question remains as to where this wood 

will be consumed. This will depend on many factors including 

local demand, permitting requirements for new energy facilities, 

who builds first, transportation costs and infrastructure. In the 

last section, we discuss the implications of these factors for future 

wood flows to—and from—Massachusetts.

the historical period—as well as in the forecast period—would 

be about 300,000 green tons (4,700 acres x 64 tons/acre).

At this stage, it is easy to see the importance of the recovery rate. 

If biomass demand increases due to the expansion of bioenergy 

plants, then we would expect that there would be an increase 

in the percentage of material from land clearing that would be 

chipped and used for biomass fuel. Although it is not possible to 

quantify historical recovery rates, we can demonstrate the potential 

magnitude of this biomass source by considering the impact of 

different recovery rates. A recovery rate of 30% would imply that 

90,000 green tons of material was collected and utilized. Each 

increase of 10% in the recovery rate would add an additional 

30,000 green tons to the supply base, so at 70%, the total volume 

of supply available would be 210,000 green tons.

While the disposition of wood from land clearing sources is not 

known in 2000−200548, it is highly probable that if demand 

increases significantly for bioenergy uses, a greater share of 

this wood would be recovered and shipped to these markets. 

Logistics and economics will govern how much biomass can 

be recovered from land clearing. The kinds of machinery used, 

the harvesting methods, and the end-use markets for this wood 

will vary depending on the size of the parcel being cleared and 

other site-specific factors. The price of biomass delivered to a 

bioenergy plant will also be a critical factor in determining how 

much biomass is actually recovered, as will transport costs and 

tipping fees when the option is sending the material to a landfill.

The potential volume of wood that could be generated from 

land clearing in 2010−2025 will depend critically on the current 

disposition of this wood. If current recovery and utilization are 

low, the incremental volumes available in the future could be 

substantial. At the extreme, one might consider the increase in 

volume to be as much as 120,000 green tons if recovery rates were 

to increase from 30% to 70%. Conversely, if current recovery 

rates are higher due to tipping fees and competing uses, “new” 

biomass from these sources in the future would be reduced 

accordingly. A final consideration is the possibility that this 

material in being “underutilized” in current markets. That is, if 

wood is chipped and used in landscaping primarily because it is 

a good economic option compared to disposal, it is possible that 

some of this wood could be diverted to bioenergy in situations 

where that might become a higher value use.

3.5.2 Tree Care and Landscaping Sources

Among the tertiary sources mentioned above, the most significant 

is wood from tree care and landscaping sources. This wood is often 

referred to as “urban wood” which is somewhat of a misnomer 

because it includes wood not only from tree care in urban areas, 

but also wood from tree care from sources such as county parks 

48 The startup of the Schiller plant in Portsmouth, New Hampshire 

in 2006 makes the comparisons going forward more problematic. 

The plant consumes about 500,000 green tons of wood per year and 

has ready access to wood from land clearing in eastern Massachusetts 

(where most land clearing in the state occurs).
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Biomass Sustainability and Carbon Policy Study

and thus reflect an average of data collected over the period 2004−2008. 

County List: New Hampshire: Cheshire, Hillsborough, Rockingham;

Vermont: Bennington, Windham; New York: Rensselaer, Columbia, 

Dutchess; Connecticut: Litchfield, Hartford, Tolland, Windham; 

Rhode Island: Providence

3.6.2 Timber Growth 

When interpreted strictly from a biophysical standpoint, there is 

a large volume of “excess” wood available in both Massachusetts 

and the border region in the sense that forests are growing more 

wood than is being removed through harvesting and mortality. 

Here we compare the potential of the border counties to Massachusetts on the basis of relative rates of timber growth. We should 

emphasize that relationship between net growth and removals is 

not a measure of supply; it only speaks to how much timber could 

be harvested without reducing inventory levels.50

There are a number of ways of measuring and evaluating timber 

growth. Ultimately, the key variable of interest is how much 

additional wood will become available in different regions. As 

noted above, we are primarily interested in private inventories 

because biomass harvesting is subject to fewer restrictions and 

owners tend to be more responsive to market forces.

Most often, this growth has been evaluated by comparing net 

growth (gross growth less mortality) and removals. This relationship would be an excellent metric (it essentially defines inventory 

accumulation at any point in time) were it not for the poor quality 

of the data on removals. Furthermore, issues of data accuracy 

have become more of a concern in recent years due to the new 

annualized survey procedures that have been adopted by the 

Forest Service. For example, the sampling error for removals in 

2008 is 45% in Massachusetts and 31% in New Hampshire. At 

the county level, the sampling error for removals is so large as to 

make these data effectively meaningless.51

Although any approach will encounter problems with accuracy 

due to sample size and sample frequency issues, we believe that 

comparing inventory levels over time is a better method for 

50 Even if a forest is not adding new wood each year, it still has the 

potential to contribute to biomass production; biomass supplies can 

come out of existing stocks, not growth. From a carbon standpoint, 

a forest that has matured to the point that the yield curve has leveled 

off (net growth = mortality) may be a preferred source of material.

51 Data for 2008 for timber removals in 12 Massachusetts counties 

show: no removals recorded in 7 counties, sampling errors of 100% or 

greater for 3 counties. For the 13 selected counties that are adjacent 

to Massachusetts, there were no removals recorded in 2 counties, 

sampling errors of 100% or greater for 4 counties, and the minimum 

sampling error for the remaining 7 counties was 53%. The reason for 

the poor accuracy is that removals are a rare event given the sampling 

methodology; for example, in Massachusetts, about 120 plots were 

re-measured in 2008 (20% of the 600 plots in the sample) and with 

about one percent of timberlands harvested in Massachusetts each 

year, that means that one would expect to find, on average, only about 

six plots with harvest activity every five years.

This section thus addresses two central questions:

• How much incremental biomass supply is available in the 

border counties?

• How much of this supply is likely to be shipped to new 

bioenergy plants in Massachusetts?

3.6.1 Timberland Area and Timber Inventory

Timber inventory is an obvious place to start in considering the 

border counties’ potential contribution in meeting future demand 

from Massachusetts bioenergy plants. In Exhibit 3-18, we show 

the timberland areas and timber growing stock inventories in 

Massachusetts and in the major counties that border Massachusetts.49 These FIA data indicate that timberland areas in the border 

counties are nearly 30% greater than those of Massachusetts. The 

conclusion is the same using the growing stock data.

Also noteworthy is that Massachusetts has a much higher share 

of public land (30%) than the border counties (an average of 19%, 

ranging from 28% in the Vermont and Connecticut sub-regions to 

only 5% in New York’s three counties). Thus, when private lands 

only are considered, timberland areas and timber volumes in the 

border counties are about 50% greater than those in Massachusetts. 

This distinction is important because harvesting regulations for 

biomass fuel are generally more restrictive on public lands than on 

private; for example, in New Hampshire, whole-tree harvesting 

is prohibited on National Forest lands.

Exhibit 3-18: Timberland Area and Growing Stock Inventory in Massachusetts Timbershed, 000 Acres and Million 

Green Tons; 2008

Area Inventory

Total Private Public Total Private Public

Massachusetts 2,895 2,026 869 207 146 62

Border County 

Total 3,712 3,018 694 262 212 50

New Hampshire (3 

counties) 1,075 938 137 81 70 11

Vermont 

(2 counties) 755 543 212 57 43 15

New York 

(3 counties) 747 708 38 46 43 3

Connecticut 

(4 counties) 983 709 274 69 49 19

Rhode Island 

(1 county) 152 120 33 10 8 2

Combined Total 6,607 5,044 1,563 470 358 112

Border Counties ÷ 

Mass. 1.28 1.49 0.80 1.27 1.46 0.81

Source: FIA On-line; volumes converted from original units assuming 

30 green tons per 1000 cubic feet. Note that 2008 is the nominal date 

for the survey data, but the data were compiled from annualized surveys 

49 Data on growing stock volumes significantly understate the 

volume of biomass available because of the availability of wood 

from non-growing stock sources, notably cull trees, tops and limbs. 

However, our analysis is focused on relative levels—not absolute 

volumes—and this omission has little effect on our conclusions.
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Notes: See Exhibit 3-18 for county definitions. Net G is net growth per acre: 

the net growth volumes are taken directly from FIA data for 2008 and 

divided by area for 2004−2008 (Exhibit 3-18). Inv Δ is a more inclusive 

measure of volume change on an average acre and accounts for net growth, 

removals and mortality; it is calculated as the change in stocking levels over 

the last 10-to-15 years (depending on the date of the previous inventory).

3.6.2.2 Total Volume Growth

Does the conclusion change when we adjust overall inventory 

growth for historical land use changes? There are two aspects 

of land-use change to consider: 1) shifts in total timberland area 

over time; 2) shifts from private to public ownership. For the 

border counties as a whole, the change in total timberland area 

has been negligible (a decrease of less than 1% from the earlier 

inventory years). However, over this same time frame, there has 

been a large shift from public to private ownership: approximately 

20,000-to-25,000 acres per year have shifted into public ownership 

according to FIA data (as noted earlier, there are inconsistencies 

in these data due to measurement errors and sampling errors and 

their accuracy has been disputed). Thus, while the total increase 

in timber inventory was about 2.6 million green tons per year in 

the border zone, the increase in private timber inventories was 

only 0.9 million green tons per year, while inventories on public

lands increased by 1.7 million green tons per year.

When measured on a comparable basis, private timber inventory volume in Massachusetts has increased at a rate of about 

1.1 million green tons per year. Thus, in the important area of 

private timber inventory growth, the data suggest that inventories 

in Massachusetts are increasing at rates similar to those in the 

surrounding counties. From this perspective, the border countries lose the 50% advantage that we observed when considering 

growth rates on a per-acre basis. 

Of course, there is no a priori reason to assume that land use 

changes will continue at the same rates as in the recent past. 

Good arguments can be made that future shifts from private 

to public lands could accelerate or proceed more slowly. In any 

case, it does seem clear that a serious assessment of biomass fuel 

availability in the border counties should consider an in-depth 

analysis of land-use changes in the region. To the extent that 

significant reductions in private timberland will continue, this 

would likely have an important influence on potential supplies 

from the surrounding region.

3.6.3 The Forest Products Industry and 

Regional Harvesting

Another possibility for assessing the relative importance of 

the border counties is to consider harvesting levels given that 

the greatest potential for biomass (at least in the near term) 

comes from integrated harvesting with higher-value industrial 

roundwood. Logging residues—generally considered to be a 

prime source of biomass fuel—will be directly proportional 

to the amount of industrial roundwood harvested. Perhaps 

more importantly, areas that already have a significant forest 

industry may be good candidates for biomass fuel harvests 

through additional cutting of low-value timber, or possibly 

evaluating growth trends. The primary reason is statistical in 

that standing inventory can be measured on each plot that is 

surveyed each year. Likewise, with regard to components of 

change in the FIA data, net growth is much more reliable than 

data on removals. Since we are interested in small areas, we have 

also combined private and public inventories for this comparison 

because sampling errors for areas and inventories increase significantly for separate ownerships.

3.6.2.1 Growth per Acre

When all lands (private and public) are considered together, timber 

growth rates in Massachusetts are similar to the border region on 

per-acre basis. In Exhibit 3-19, average stocking levels are shown 

along with two sets of growth rates. The data on net growth per acre 

(gross growth less mortality) are derived by dividing net growth (as 

reported directly by FIA data) by the area in each region. The data 

indicate that growing stock timber inventories in Massachusetts are 

increasing at an average rate of 1.6 green tons per acre. The average 

growth rate in the border counties is essentially the same (1.5 green 

tons per acre), spanning a range of 1.2−1.8 green tons per acre.

The second set of growth data is derived by calculating the annual 

rate of change in per-acre stocking levels using FIA data between 

the 2004−2008 inventory/area surveys and the surveys from 

10-to-15 years ago. This is a more inclusive measure of timber 

accumulation on an average acre by accounting for not only net 

growth and mortality, but also removals. These data also show 

very little difference between Massachusetts and the border counties—timber inventory volume is increasing at an average of about 

0.8−0.9 green tons per acre, and with the exception of Rhode 

Island, the border counties are clustered around this number.

According to the above data, timber volume per acre is increasing 

at very similar rates throughout the area we have defined as the 

Massachusetts timbershed. These similarities reinforce the idea of 

using relative land areas as a measure of potential supply. Thus, if 

timberland use and ownership were to remain the same over the 

next 15 years, the potential contribution of the border counties 

areas—from a growth perspective—would be about 50% greater 

than Massachusetts (based on the private timberland area).

Exhibit 3-19 Stocking Levels and Inventory Growth for 

Growing Stock

All Timberlands (Private + Public), Green Tons per Acre

Stocking Net G Inv Δ

Massachusetts 71.7 1.6 0.8

Border County Total 70.7 1.5 0.9

 New Hampshire 

(3 counties) 74.9 1.3 0.7

 Vermont (2 counties) 76.1 1.2 0.7

 New York (3 counties) 61.1 1.8 1.0

 Connecticut

 (4 counties) 70.0 1.8 1.0

 Rhode Island 

(1 county) 65.9 1.2 2.4
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Biomass Sustainability and Carbon Policy Study

family-owned forest land is 6 acres, while Rhode Island is also 6 

acres and Connecticut averages 9 acres per owner. Forest holdings are much larger in New Hampshire and Vermont, where the 

average owner has 19 acres and 36 acres, respectively (although it 

is likely to be the case that parcel sizes in the border counties are 

more similar to those in Massachusetts than the state averages 

would imply). Notably, a significant area of New Hampshire’s 

private forest land (1.3 million acres) is held by non-family owners 

(average forest holdings of owners in this group are substantially 

larger). According to these survey data, only 43% of the family 

forest land area in Massachusetts is held in parcels that are 50 

acres or larger. New Hampshire and Vermont are much higher 

at 64% and 75%, while Connecticut is 48% and Rhode Island 

is 33%. Importantly, New Hampshire has twice as much familyowned land as Massachusetts in 50+ acre parcels, while Vermont 

has three times as much land; however, we do not have data on 

the relative areas for the border county region.

Exhibit 3-21: Attributes of Family Forest Landowners

MA NH VT CT RI

Private Lands (000 

acres)

2,179 3,646 3,864 1,383 303

Family Forest Owners 

(000 acres)

1,686 2,358 3,109 898 204

Family Forests, 50 acres 

or more

729 1,514 2,343 434 68

% of Family Forests, 50 

acres or more

43% 64% 75% 48% 33%

Average Size, Family 

(acres per parcel)

5.8 19.0 35.7 8.9 5.5

Timber production is 

important*

20% 21% 29% 12% 11%

Commercial harvest in 

past 5 years

40% 59% 68% 39% 26%

Commercial harvest in 

next 5 years

20% 29% 39% 9% 11%

% of family forests available given constraints*32% 43% 57% 20% 21%

Source: National Woodland Ownership Survey, Butler et al., 2008; 

on-line data.

Notes: 1) Data are state level, not for county sub-regions. 

2) The survey asks landowners to rank the importance of producing commercial timber on a 7-point scale from “very important” to “not important.” These 

data show the percentage that ranked production as ‘1’ or ‘2’ on this scale.

3) “% of family forest available given constraints”is taken from Butler et 

al. (2010) and reflects reductions for biophysical and social constraints, 

including parcel size and landowner attitudes and preferences.

With respect to timber production, probably the three most 

important questions asked in the National Woodland Ownership Survey are: 1) how important is timber production?; 2) did 

you conduct a commercial harvest in the past five years?; and, 

3) do you plan to conduct a commercial harvest in the next five 

years? The results shown in Exhibit 3-21 are much as one might 

expect: Vermont and New Hampshire owners gave answers that 

because forest industry intensity is a good indicator of timber 

availability and underlying landowner attitudes.

For this overview, we have used TPO data because they have the 

appropriate concepts at the county level (Exhibit 3-20). These 

data indicate that production in the border counties is about 

three times that in Massachusetts; thus, from the vantage point 

of current harvesting activity, the border counties show a lot more 

promise as a source of biomass than Massachusetts. The table also 

shows an index which compares the intensity of harvests in the 

different areas—this is calculated as roundwood harvests divided 

by total timberland acres, and is indexed to Massachusetts = 1.0.

Exhibit 3-20: Industrial Roundwood Harvests in Massachusetts Timbershed, 000 Green Tons and Index; 2006

Sawlogs Pulpwood All Ind. Cut/Acre

Massachusetts 217 33 254 1.0

Border County 

Total 605 174 819 2.5

New Hampshire 

(3 counties) 252 111 387 4.1

Vermont 

(2 counties) 142 28 170 2.6

 New York 

(3 counties) 92 30 137 2.1

 Connecticut 

(4 counties) 101 6 107 1.2

 Rhode Island 

(1 county) 17 0 17 1.3

Source: Harvest data from TPO. All Ind. is “All Industrial” and, in addition to sawlogs and pulpwood, includes veneer logs, composite products, posts, 

poles, piling, and miscellaneous. Cut/Acre is an index (Massachusetts = 1.0), 

measured as All Ind./ Timberland Acres. See Exhibit 3-18 for county definitions.

3.6.4 Landowner Characteristics in the Region

Ownership characteristics provide another perspective on future 

wood biomass fuel availability in the border counties for at least 

three reasons: 1) the size of forest holdings is generally considered 

to be highly correlated with the landowner’s propensity to harvest 

timber; 2) the size of forest holdings is of particular importance for 

biomass fuel because of economies of scale in whole-tree harvesting; 

and 3) landowner attitudes are important in the decision of whether 

or not to use their land for commercial timber production.

In Exhibit 3-21, data that address the above issues are presented 

at the state level.52 In Massachusetts, the average parcel size for 

52 We evaluated these data at the survey unit level in New 

Hampshire and Vermont to focus more directly on the sub-regions 

of concern. However, there were no obvious differences within the 

states, particularly given the large sampling errors associated with 

this survey. We did not consider the data for New York because the 

three-county area accounts for such a small share of the state’s total 

forest land.
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Biomass Sustainability and Carbon Policy Study

more difficult to evaluate. It is certainly the case that New 

Hampshire, Vermont, and New York would be much more 

conducive to increased harvesting than Massachusetts based 

on landowner attitudes and the distribution of ownership by 

parcel size. This already manifests itself in a much larger forest 

industry and much higher roundwood production. Thus we are 

faced we this analytical dilemma: these regions may be more 

attractive for timber harvesting, but given that more harvesting 

is now taking place, how much further expansion is likely? 

Has investment to date put the production in these regions 

in equilibrium relative to Massachusetts? Are there still more 

promising opportunities in the border counties? Or are they 

already approaching production levels that make it more difficult 

to expand further? Whole-tree harvesting already has a long 

history in southern New Hampshire for example, suggesting 

that future increases might be more difficult to achieve and 

come only at higher cost.

While this issue will not be settled in this analysis, we have made 

an effort to better understand the situation in southern New 

Hampshire: it has been suggested that New Hampshire has the 

most potential for increasing supplies of forest biomass because 

of its inventory, harvest rates, and favorable stance toward timber 

production. Our evaluation of recent harvest relationships and 

price trends is provided in Appendix 3-D. We did not find any 

obvious pockets of opportunity or expansion possibilities in 

the southern counties, nor any evidence to support claims that 

southern New Hampshire may be in an advantageous position 

to produce more biomass compared to neighboring areas.

Since we have considered the availability of biomass from border 

counties in relation to supplies from Massachusetts, it is important 

that we consider these supplies in the context of our two scenarios 

for Massachusetts. In our Low-Price Biomass scenario, we expect 

that biomass supplies in Massachusetts will increase as a result of 

more intensive harvesting using whole-tree harvesting. Given the 

development that has already taken place in some of the border 

areas, we would not expect that increased biomass demand at 

current biomass prices would spur additional harvesting to the 

same extent that we might see in Massachusetts. However, in our 

High-Price Biomass scenario, more land is harvested and more 

timber is harvested from that land. We would expect that this 

will cause a substantial response in the border counties, just as 

we expect in Massachusetts. Given landowner characteristics in 

the region, one might argue that the response in border counties 

might be greater than in Massachusetts.

Mindful of the numerous uncertainties involved in projecting 

the potential supply of biomass in the counties bordering Massachusetts, we consider a reasonable “guesstimate” to be 50% 

more than can be produced within this state. In our Low-Price 

Biomass scenario, this would suggest the border counties could 

produce an additional 225,000−375,000 green tons of forest 

biomass annually. If the High-Price Biomass scenario unfolds, 

border county supply would jump to an annual average of 

1.0−1.3 million green tons.

most favored timber production, Massachusetts was ranked in 

the middle of this group, and Connecticut and Rhode Island 

owners were least oriented toward timber production.

There appears to be a fairly high degree of correlation between 

parcel size and landowner interest and willingness to pursue 

commercial timber harvests. A recent study by Butler et al. 

(2010) developed a methodology to combine these factors in a 

manner to eliminate double counting in the presence of multiple 

constraints. Harvest “participation rates” from this study are 

shown on the last line of Exhibit 3-21: Vermont had 57% of 

family forest land available for harvest (ranking the highest 

of all 20 northern states); New Hampshire was second of this 

group with 43% available; Massachusetts had only 32% of land 

available; Connecticut and Rhode Island were the lowest with 

only about 20% of land available (and ranked among the lowest 

of the 20 northern states).

Some question the validity and usefulness of landowner surveys, 

so it is useful to have additional information from other sources. 

Participation rates in current use programs provide further 

insights into the level of interest in forest management and 

related income incentives. The Chapter 61-61A-61B program 

in Massachusetts has had limited success relative to its counterparts in New Hampshire and Vermont. In Massachusetts, 

about 15% of private forest lands were enrolled in this program 

in 2009 (Massachusetts Department of Conservation, 2009). 

This is in stark contrast to New Hampshire where about 27,000 

landowners participate in the current use program, covering 

nearly 3 million acres (New Hampshire Timberland Owners 

Association, 2010). In Vermont, more than 1.6 million acres of 

forest land were enrolled in their current use program in 2009 

(Vermont Department of Taxes, 2010).

Ownership attributes clearly reinforce the patterns shown earlier 

on the basis of area, inventory and harvesting. The potential for 

forest biomass fuel from border counties in Connecticut and 

Rhode Island appears limited. On the other hand, the border 

counties of New Hampshire, Vermont, and New York are similar 

in size to Massachusetts (on the basis of timberland area, inventory, 

and growth) and their forest products industry and industrial 

roundwood harvests are significantly higher. Furthermore, landowner surveys for New Hampshire and Vermont show family 

owners in these states to be more supportive of timber harvesting.

3.6.5 Summary of Forest Biomass Supply 

Potential in Border Counties

In order to assess potential forest biomass supplies from the counties surrounding Massachusetts, we have looked at several key 

measures relative to Massachusetts. The general conclusion from 

our analysis of timberland area, timber inventory, and timber 

growth is that private lands in the border counties have the 

ability to supply about 50% more biomass than Massachusetts.

When the analysis is expanded to account for landowner characteristics and the development of the forest products industry, 

the potential biomass contribution of border counties becomes 
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Biomass Sustainability and Carbon Policy Study

3.6.6.2 Potential Future Trade in Forest 

Biomass Fuel

One of the advantages of Massachusetts size and shape is that it 

has access to a large horseshoe of wood as part of its timbershed. 

However, it is important to recognize that an even larger horseshoe 

envelops this timbershed, which means that wood available from 

that area may provide incentives to build bioenergy facilities in 

the border region, or that wood could flow from Massachusetts 

to feed plants in that area. Exhibit 3-23 provides a list of facilities 

that—if built—might potentially compete for the same wood 

that could provide feedstock to proposed plants in Massachusetts. 

Plans and proposals change frequently and this list is intended 

only to be suggestive of some of the facilities—and their size—

that are now under consideration in this region. This list does not 

include facilities that are located overseas, but there is always the 

possibility that biomass produced in this region could be directed 

to export markets.

Exhibit 3-23: Proposed Bioenergy Plants that Could Influence Biomass Availability for Massachusetts (Wood Use in 

Green Tons per Year)

State Company Location Size Wood Use

MA Russell Biomass Russell 50 MW 550,000

Greenfield Biomass Greenfield 50 MW 550,000

Tamarack Energy Pittsfield 30 MW 350,000

Palmer Renewable Springfield 30 MW *235,000

NH Clean Power 

Development

Berlin 29 MW, 

CHP

340,000

Clean Power 

Development

Winchester 15 MW 150,000

Alexandria Power Alexandria 16 MW 

(re-start)

200,000

Greenova Wood 

Pellets

Berlin pellets 400,000

Laidlaw Energy Berlin 40 MW 400,000

VT Vermont Biomass 

Energy

Island Pond pellets 200,000

Brattleboro District 

Heat

Brattleboro

CT Decker International Plainfield 30 MW 400,000

Tamarack Energy Watertown 30 MW 400,000

Notes: * plan calls for construction and demolition debris as feedstock.

Two important strategic issues in siting large-scale bioenergy 

facilities are relevant to this discussion. One is that transportation costs are a significant component of delivered biomass costs 

and so the location of new facilities should be optimized so that 

they have access to the most wood within short distances. Thus, 

plants should be built where there are ample supplies of wood 

in the “home” area. This could be analyzed with mathematical 

optimization models, but the results would probably be of little use 

due to the large number of other factors that affect plant location, 

many of which are specific to individual locations and facilities.

3.6.6 Inter-regional Trade and Implications 

for Biomass Supplies for Future Bioenergy 

Plants in Massachusetts

Understanding potential wood biomass supplies in the counties 

that surround Massachusetts is critically important in estimating 

biomass availability for bioenergy plants that may get built in 

Massachusetts. But where will this wood be consumed? It is 

crucial to consider future demand outside of Massachusetts and 

possibilities for biomass trade. Biomass produced in the border 

counties could stay within its home zone for local use, it could 

flow between sub-regions (from New Hampshire to Vermont, 

for example), it could flow to the northern areas, or it could 

flow to Massachusetts. Likewise, wood in Massachusetts is not 

limited to home use; in fact, with few outlets for wood biomass 

in Massachusetts currently, biomass chips are now being shipped 

to bioenergy facilities in New Hampshire.

3.6.6.1 Historical Wood Products Trade

Recent patterns in wood products trade in this region provide 

some perspective on trade possibilities. Data available on wood 

trade for New Hampshire, Vermont, Maine, and New York show 

that the four-state region is a net importer of wood, purchasing 

195,000 green tons in 2005. (We caution that the data are for only 

one year and they do not indicate specifically what is happening 

with Massachusetts.)

Data for Vermont (Northeast State Foresters Association, 2007b) 

indicate that Vermont consumed about 400,000 green tons of 

biomass chips in 2005. Of this total, about 300,000 green tons 

were imported from other states, while at the same time, Vermont 

exported 75,000 green tons; thus, net imports were just over half 

of wood chip consumption.

Based on the limited data that we have on Massachusetts wood 

trade, it appears that trade between Massachusetts and Vermont 

has been one-directional, with Massachusetts exporting a small 

volume of sawlogs to mills in Vermont.

Exhibit 3-22: Wood Trade Among Northeast States, 2005

(000 green tons; does not include international trade)

Import Export Net Imports

New 

Hampshire 353 820 -468

Vermont 508 630 -123

Maine 1,115 363 753

New York 838 805 33

TOTAL 2,813 2,618 195

Source: Northeast State Foresters Association, 2007a. Original data in 

cords; converted to green tons assuming 2.5 green tons per cord.
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Biomass Sustainability and Carbon Policy Study

Suffice to say, there is no simple answer to the question of how 

much biomass might be available from the border counties to 

furnish new bioenergy facilities in Massachusetts. However, it 

would seem prudent that each new facility (particularly those 

with large annual wood consumption) conduct its own feasibility 

study and carefully establish that the supplies it needs are available 

and not destined for other bioenergy plants.

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Maine Forest Service, Department of Conservation, Forest Policy 

and Management Division. 2009. 2008 Wood Processor Report, 

Including Import and Export Information.

A second strategic issue is what has been termed “first-mover 

advantage,” which suggests that the facility that starts up first 

will have a competitive advantage in establishing its network 

and logistics for wood supply. In addition, the first mover may 

discourage future investments that would need to access the 

same timbershed. However, being first does not rule out the 

possibility that other new facilities that may start later: they 

may be willing to compete for the same wood due to proximity 

or the belief that they will be more efficient and thus able to pay 

more for their fiber.

3.6.6.3 Wood Supplies Available for 

Massachusetts

How much in the border counties would be available for new 

bioenergy facilities in Massachusetts? This will depend on how 

the bioenergy industry in the region evolves and depends on the 

following:

• How many new facilities will be built and how large will 

they be?

• Where will they be built?

• When will they be built? 

In order to provide some general guidelines, such an analysis 

might proceed as follows. For economic reasons, it would seem 

most likely that the majority of wood produced would remain 

in its home market: it might be reasonable to assign that a 50% 

probability. The remaining 50% could be shipped to Massachusetts or shipped “outside” to the facilities in the next ring 

of border counties. Thus, in this example, the supply of biomass 

being shipped to Massachusetts from the border region would 

be 25% of the total available. If the amount of wood available 

in Massachusetts is X, and the amount available from outside is 

1.5X, then Massachusetts could plan on increasing its supplies 

by 0.375X (or 0.25 * 1.5X).

These numbers can be adjusted to develop some insights into what 

might represent a reasonable upper bound. Suppose we make the 

assumption that the amount of “new” biomass available in the 

border counties is actually twice that available in Massachusetts 

(call this 2X). Furthermore, suppose that Massachusetts is able 

to purchase half of that wood by virtue of location or the timing 

of establishing new plants and their supply infrastructure. In 

this case, Massachusetts could increase its supply by X (or 0.5 * 

2X), thus doubling the amount available only within the state.

In order to provide some general guidance and indication of 

the volumes of biomass that could be available from the border 

counties to supply new bioenergy facilities in Massachusetts, we 

have assumed that Massachusetts could successfully purchase 

50% of the potential incremental production. In our Low-Price 

Biomass scenario, this would suggest that 110,000−190,000 green 

tons of forest biomass from border counties could augment the 

supplies available within Massachusetts. Supplies available from 

border counties increase to 515,000−665,000 green tons in the 

High-Price Biomass scenario.
Manomet Center for Conservation Sciences 62 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Vermont Department of Taxes. 2010. Annual Report. Division of 

Property Valuation and Review.

Vermont Forest Resource Harvest Summary. Various years. Vermont 

Department of Forests, Parks & Recreation.

Maker, T.M. 2004. Wood-Chip Heating Systems: A Guide for 

Institutional and Biomass Heating Systems. Original 1994, revised in 

2004 by Biomass Energy Resource Center, Montpelier, Vermont.

Mass Audubon. 2009. Losing Ground: Beyond the Footprint.

Massachusetts Department of Conservation and Recreation, 

Bureau of Forest Fire Control and Forestry, 2008 Annual Forestry 

Stakeholder Report: Promoting Stewardship of Our Forest for a Safe 

and Healthy Environment, Economy, and Society. 2009.

New Hampshire Report of Cut. 2008. Summary data generated by 

Matt Tansey, New Hampshire Division of Forest & Lands.

New Hampshire Timberland Owner’s Association. Timber Crier. 

Various issues.

New Hampshire Timberland Owner’s Association. 2010. Website: 

www.nhtoa.org.

Northeast State Foresters Association. 2007a. The Economic 

Importance and Wood Flows from the Forests of Maine, New 

Hampshire, Vermont and New York, 2007.

Northeast State Foresters Association. 2007b. The Economic 

Importance and Wood Flows from Vermont’s Forests, 2007.

P Squared Group, LLC and Biomass Energy Resource Center. 2008 

(February). Heating with Biomass: A Feasibility Study of Wisconsin 

Schools Heated with Wood. 

Perlak R.D., Wright L.L., Turhollow A.F., Graham R.L., Stokes B.J., 

and Erbach D.C. 2005 (April). Biomass as Feedstock for a Bioenergy 

and Bioproducts Industry: The Technical Feasibility of a Billion-Ton 

Annual Supply.

Sherman, A.R. 2007. Vermont Wood Fuel Supply Study: An 

Examination of the Availability and Reliability of Wood Fuel for 

Biomass Energy in Vermont. BERC (Biomass Energy Resource Center).

Timmons D, Allen G, Damery D. 2008. Biomass Energy Crops: 

Massachusetts’ Potential. University of Massachusetts, Department 

of Resource Economics. 

University of Massachusetts Amherst. 2008. Southern New England 

Stumpage Price Report. MassWoods, maintained by Paul Catanzaro. 

www.masswoods.net/sne_stumpage/

U.S. Department of Agriculture, Forest Service. Forest Inventory and 

Analysis National Program. Forest Inventory Data Online: www.fia.

fs.fed.us/tools-data.

U.S. Department of Agriculture, Forest Service. Forest Resources 

of the United States, 2007. A Technical Document Supporting the 

Forest Service 2010 RPA Assessment. Smith W.B., Miles P.D., Perry 

C.H., and Pugh S.A. 2009. Gen. Tech. Rep. WO-78.

U.S. Department of Agriculture, Forest Service. Forest Resources 

of the United States, 2002. A Technical Document Supporting the 

USDA Forest Service 2005 Update of the RPA Assessment. Smith 

W.B., Miles P.D., Vissage J.S., and Pugh S.A.

U.S. Department of Agriculture, Forest Service. Timber Product 

Output Mapmaker Version 1.0. On-line software for the Timber 

Product Output Database Retrieval System (TPO). www.fia.fs.fed.

us/tools-data/other/

U.S. Energy Information Administration. 2009. Annual Energy 

Outlook 2010 Early Release Overview. Report #:DOE/EIA-0383(2010).

U.S. Environmental Protection Agency, Office of Atmospheric 

Programs. 2009. EPA Analysis of the American Clean Energy and 

Security Act of 2009, H.R. 2454 in the 111th Congress (6/23/09). 
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Chapter 4

Forest Sustainability and Biomass 

Harvesting in Massachusetts

4.1 Introduction

The objective of this task of the Biomass Sustainability and 

Carbon Policy study is to evaluate the potential impacts posed 

by increased biomass harvesting in the forests of Massachusetts and offer recommendations for mitigating any negative 

outcomes that are identified. Although biomass harvesting offers 

opportunities to enhance silvicultural treatments and produce 

greater quantities and quality of traditional forest products 

such as sawlogs these economic impacts are not the focus of this 

chapter. This chapter reviews indicators of forest sustainability 

for Massachusetts forests and gauges the impact of increased 

biomass harvesting on forest ecosystem sustainability. It also 

suggests options for policies, guidelines, or regulations that 

might be needed to protect ecological values while producing a 

forest based energy supply and realizing the economic benefits 

from increased silvicultural productivity.

The concept of forest sustainability requires consideration of 

what is being sustained, over what time period, and at what 

landscape scale. Section 2 addresses these issues at the standlevel, focusing on the localized ecological impacts of biomass 

harvesting. These stand-level considerations are most readily 

observed and quantifiable. The stand-level analysis discusses 

the potential impacts to ecological systems and processes 

and then reviews the biomass harvesting guidelines used by 

other states and political entities to minimize any impacts at 

the stand level. Then the adequacy of Massachusetts’ current 

forest management regulations and guidelines are evaluated. 

Section 3 considers a broader set of sustainability factors at 

the landscape rather than the stand level. This discussion 

includes socio-economic indicators that go beyond stand-level 

ecological effects and have the potential to alter the provision 

of forest ecosystem services at a regional scale. The chapter 

concludes with a discussion of policy options that the state 

may want to consider for addressing these potential stand- and 

landscape-scale impacts. 

To help answer questions about the potential impact of increased 

biomass harvests on forest sustainability at both stand and landscape scales, this report draws heavily on information from three 

separate but related reports that were developed or updated for 

this study by the Forest Guild. These documents are included as 

appendices to this report. Ecology of Dead Wood in the Northeast 

consists of a literature review of important topics relevant to 

biomass harvesting in forest types common to Massachusetts. 

Excerpts from this report and implications for Massachusetts 

policies are included in Section 2. An Assessment of Biomass 

Harvesting Guidelines (2009) was revised for this study, and 

the unpublished revised version is included. Finally, Forest 

Biomass Retention and Harvesting Guidelines for the Northeast 

is a complete set of recommendations to protect Massachusetts 

forest types that was developed in a parallel process by Forest 

Guild members and staff.1 These guidelines provide a useful 

starting point for the development of state-specific guidelines 

for Massachusetts.

These reports provide more detailed background information 

and a richer exploration of the underlying science and issues. 

Overviews of each of these reports and their implications for 

policies addressing increased biomass harvests in Massachusetts 

are included in Section 2 with the stand-level discussion. 

4.2 Stand-level Impacts to Forest 

Health Resulting from Increased 

Biomass Demand

As we learned from the analysis in Chapter 3, woody biomass 

generated solely from logging debris (tops and branches) will 

contribute minimally to commercial-scale biomass facilities. 

This implies that the only way to meet higher demand would 

be to increase the annual forest harvest, i.e., cut more trees per 

acre or harvest additional acreage. Increasing harvest levels does 

not automatically mean an unsustainable forest ecosystem. As 

noted in Chapter 3, timber inventories have been increasing in 

Massachusetts for many decades and harvests can potentially 

be increased without reducing future wood supplies. The challenge with increased harvests is to provide assurances that forest 

ecosystem health would be preserved. There are three main areas 

where forest ecosystem sustainability might be affected. These 

issues are relevant to any harvesting operation, but become of 

greater concern if additional wood is removed for biomass:

• Impact on hydrology and water quality

• Impact on soils and site productivity

• Impact on habitat and biodiversity

4.2.1. Introduction

Hydrology and water quality are already covered with existing 

Best Management Practices (BMPs) in Massachusetts (reference 

to BMPs). Increasing the harvest levels to meet biomass demands 

should therefore not compromise water resources because of the 

protections already in place. It is not clear that protections are in 

place for soils and productivity, or biodiversity, and therefore we 

focus on these issues in this Task. 

Many of the possible impacts related to biomass harvesting relate 

to the removal and retention of woody material. This is true for 

soil protection as well as wildlife and biodiversity. Although dead 

wood and declining trees have traditionally had little commercial 

value, they do have substantial ecological value. For this reason, 

we focus our analysis on the ecology and benchmarks for retention of this material. 

1 The three Forest Guild reports mentioned here are included in 

the Appendices.
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the trees grow larger, more snags of larger sizes begin to appear. 

From age 40 to 100 years, DWM increases as small snags fall. Then 

larger snags begin to contribute to DWM. Very few large pieces 

of DWM are produced. Large DWM often results from wind 

or other disturbances that topple large trees in the old-growth 

stage. Thus, large dead wood tends to accumulate periodically 

from these disturbance pulses, whereas small pieces of DWM 

accumulate in a more predictable pattern throughout all stages 

of stand development. 

Implications for Massachusetts Policies: The patterns of DWM 

development indicate the importance of retaining large live trees 

and large snags at the time of harvest. As the stand moves through 

the younger stages of development, it creates minor amounts of 

DWM of larger sizes. Retaining larger-diameter trees in all stages 

can provide larger size classes of DWM. 

The concern at the stand level is that increased biomass harvests in 

Massachusetts might alter natural patterns of DWM accumulation and cause ecological damage. This can occur in stands that 

have not previously been harvested or by adding the additional 

removal of biomass to any kind of previous harvest. With new 

biomass markets becoming available, all sizes of woody material 

might be removed. Harvests that include taking material for 

biomass energy could lead to the removal of most or all of the 

dead or dying standing material, as well as low-quality trees that 

would eventually enter this class. Regeneration harvests, cuttings 

that are intended to establish new seedlings, might be helped by 

the ability to remove cull material that hinders new regeneration, 

but if the biomass removals are too heavy and too consistent, the 

amount of DWM could be reduced to insufficient levels. In some 

cases, increased prices for biomass, coupled with under-utilized 

equipment and logging contractors looking for work, might 

persuade a landowner to do a more intensive harvest than under 

a pre-biomass market scenario. Without guidelines for DWM 

retention, these heavier harvests might, in some cases, pose a 

greater risk for soils by depleting the structures—FWM, and to 

a lesser extent CWM and large woody material—that store and 

release nutrients back into the mineral soil. 

4.2.2.3 DWM: Soil Productivity

DWM plays an important physical role in forests and riparian 

systems. DWM adds to erosion protection by reducing overland 

flow (McIver and Starr 2001, Jia-bing et al. 2005). DWM also has 

substantial water-holding capacity (Fraver et al. 2002).

In many ecosystems, DWM decomposes much more slowly than 

foliage and fine twigs, making it a long-term source of nutrients 

(Harmon et al. 1986, Greenberg 2002) (Johnson and Curtis 2001, 

Mahendrappa et al. 2006). While there is great variation across 

ecosystems and individual pieces of DWM, log fragmentation 

generally appears to occur over 25 to 85 years in the U.S. (Harmon 

et al. 1986, Ganjegunte et al. 2004, Campbell and Laroque 2007). 

In some ecosystems, CWM represents a large pool of nutrients 

and is an important contributor to soil organic material (Graham 

and Cromack Jr. 1982, Harvey et al. 1987). However, a review 

Ecology of Dead Wood in the Northeast was prepared to provide 

background information for this study as well as to policymakers 

and foresters involved in biomass harvest issues elsewhere. 

The paper reviews the scientific literature to provide information 

about the amount of dead wood retention necessary for forest 

health in the forest types of the northeastern U.S. Establishing 

the ecological requirements for dead wood and other previously 

low-value material is important because expanded biomass markets 

may cause more of this material to be removed, potentially reducing 

the forest’s ability to support wildlife, provide clean water, and 

regenerate a diverse suite of vegetation. The paper covers the topics 

of dead wood, soil compaction, nutrient conservation, and wildlife 

habitat in temperate forests generally as well as in specific forest 

types of the Northeast. The sections that follow include excerpts 

from the report that cover the relevant major research findings and 

then summarize the implications for policies in Massachusetts.

4.2.2. Impacts on soils and productivity

Biomass harvesting can affect chemical, physical, and biological 

attributes of soils. The silvicultural choices of what to harvest, 

the amount of material harvested, and the way the material is 

harvested are all factors that need to be considered, and sometimes 

mitigated, to protect soils. This section covers issues related to soil 

nutrients and productivity.

4.2.2.1 Definition of Downed Woody Material 

Woody material is sometimes divided into coarse woody material 

(CWM), fine woody material (FWM), and large woody material. 

The U.S. Forest Service defines CWM as down dead wood with 

a small-end diameter of at least 3 inches and a length of at least 3 

feet and FWM as having a diameter of less than 3 inches (Woodall 

and Monleon 2008). FWM tends to have a higher concentration 

of nutrients than CWM. Large downed woody material, such as 

logs greater than 12 inches in diameter, are particularly important 

for wildlife. Fine woody material is critical to nutrient cycles. In 

this report, we use the term downed woody material (DWM)

to encompass all three of these size classes, but in some circumstances we discuss a specific size of material where the piece size 

is particularly important.

Implications for Massachusetts Policies: In order to avoid 

confusion, it will be important for Massachusetts to settle on 

definitions and terminology that are most helpful to discussions 

of native forest types and associated concerns.

4.2.2.2 DWM: Stand Development and 

Harvesting 

The process of dead wood accumulation in a forest stand consists 

of the shift from live tree to snag to DWM, unless a disturbance 

has felled live trees, shifting them directly to DWM. During 

stand development following a clear cut, there is a large amount 

of DWM. The DWM remaining from the initial harvest decomposes rapidly in the first 25 years and continues to decline to age 

40. The young stand produces large numbers of trees, and the 

intense competition produces an increasing number of snags. As 
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thinning that removes all small trees for biomass and generates 

from 9 to 25 dry t/ac or 20 to 56 Mg/ha) stocks of Ca, the nutrient 

of greatest concern, could be replenished in 71 years (Kelty et al. 

2008). The Massachusetts study was based on previous research 

with similar results from Connecticut (Tritton et al. 1987, Hornbeck et al. 1990).

During the Forest Guild’s working group discussions of soil 

productivity, the Kelty study was investigated thoroughly as it 

raised serious questions of long-term sustainability. As general 

cautionary context for soil productivity, it should be noted that 

leaching, particularly of Ca due to acidic precipitation, can reduce 

the nutrients available to forests even without harvests (Pierce et 

al. 1993). In the case of Ca and the Connecticut research there are 

important questions as to whether the input rates from natural 

weathering were accurate. Other researchers believe the weathering 

rates are much higher and the Ca-phosphorus mineral apatite 

may provide more sustainable supplies of Ca to forests growing 

in young soils formed in granitoid parent materials (Yanai et al. 

2005). For example, a recent study using long-term data from 

Hubbard Brook Ecosystem Study indicated that “the whole-tree 

harvest had little effect on the total pool of exchangeable calcium” 

after 15 years (Campbell et al. 2007). 

Consequently, the analysis provided in the Kelty study does not 

provide sufficient scientific justification to generalize about Ca 

depletion. The bottom line is that even while some available studies 

suggest that soil capital should be protected by avoiding sensitive 

sites and prohibiting clearcutting with whole-tree removals, there 

is no scientific basis for concluding that avoiding clearcutting or 

whole-tree harvesting are necessary at all sites to maintain productivity. Sensitive soil types should be determined and appropriate 

guidelines applied. We recommend a conservative approach that 

includes the retention of some DWM in all harvests. The Forest 

Guild Biomass Retention and Harvesting Guidelines deal directly 

with these issues and are summarized in this report. 

4.2.2.4 Quantities of Dead Wood

Site productivity and the rate of decomposition help determine 

the amount of dead wood in a given stand (Campbell and Laroque 

2007, Brin et al. 2008). As mentioned above, DWM decomposition varies greatly but generally occurs over 25–85 years in the 

U.S. (Harmon et al. 1986, Ganjegunte et al. 2004, Campbell 

and Laroque 2007). All mortality agents including wind, ice, 

fire, drought, disease, insects, competition, and senescence create 

dead wood (Jia-bing et al. 2005). These mortality agents often 

act synergistically.

A review of 21 reports of quantitative measures of DWM in 

Eastern forest types shows great variability across forest types and 

stand-development stages (Roskoski 1980, Gore and Patterson 

1986, Mattson et al. 1987, McCarthy and Bailey 1994, Duvall 

and Grigal 1999, Idol et al. 2001, Currie and Nadelhoffer 2002). 

The reports ranged from 3 to 61 t/ac (7 to 137 Mg/ha) with a 

median of 11 t/ac (24 Mg/ha) and a mean of 15 t/ac (33 Mg/ha). 

Measurements of old forests (>80 years old), had a median of 11 

t/ac (24 Mg/ha) and a mean of 13 t/ac (29 Mg/ha) in DWM.

of CWM in Northern coniferous forests suggested that it may 

play a small role in nutrient cycling in those forests (Laiho and 

Prescott 2004). 

A review of scientific data suggests that nutrient capital can be 

protected when both sensitive sites (including low-nutrient) 

and clearcutting with whole-tree removal are avoided (see also 

Hacker 2005). However, there is no scientific consensus on this 

point because of the range of treatments and experimental sites 

(Grigal 2000). A study of an aspen/mixed-hardwood forest 

showed that even with a clear-cut system, calcium (Ca) stocks 

would be replenished in 54 years (Boyle et al. 1973). Minnesota’s 

biomass guidelines present data that showed soil nutrient capital 

to be replenished in less than 50 years even under a whole-tree 

harvesting scenario (Grigal 2004, MFRC 2007). Whole-tree 

clearcutting and whole-tree thinning (Nord-Larsen 2002) did 

not greatly reduce amounts of soil carbon or nitrogen (N) in 

some studies (Hendrickson 1988, Huntington and Ryan 1990, 

Olsson et al. 1996, Johnson and Todd 1998). Lack of significant 

reduction in carbon and N may be due to soil mixing by harvesting 

equipment (Huntington and Ryan 1990). However, intensive 

cutting, such as clear-cutting with whole-tree removal, can result 

in significant nutrient losses (Hendrickson 1988, Federer et al. 

1989, Hornbeck et al. 1990, Martin et al. 2000, Watmough and 

Dillon 2003)—in one case, an initial 13% loss of Ca site capital 

(Tritton et al. 1987). 

Overall, the impact of biomass harvesting on soil nutrients is 

site dependent. Low-nutrient sites are much more likely to be 

damaged by intensive biomass removal than sites with greater 

nutrient capital or more rapid nutrient inputs, which is one reason 

scientific studies on the nutrient effects of whole-tree harvesting 

may yield different results.

Low-impact logging techniques that reduce soil disturbance 

can help protect nutrient capital (Hallett and Hornbeck 2000). 

Harvesting during the winter after leaf fall can reduce nutrient 

loss from 10 to 20% (Boyle et al. 1973, Hallett and Hornbeck 

2000). Alternatively, if logging occurs during spring or summer, 

leaving tree tops on site would aid in nutrient conservation. 

Nordic countries have demonstrated that leaving cut trees on 

the ground in the harvest area until their needles have dropped 

(one growing season) can also reduce nutrient loss (Nord-Larsen 

2002, Richardson et al. 2002).

Implications for Massachusetts Policies: The scientific literature 

makes clear that DWM plays a critical role in ensuring continued 

soil health and productivity. Modeling indicates that biomass 

harvests have the potential to reduce soil nutrient capital and 

cause long-term productivity declines (Janowiak 2010) at some 

sites; but other studies identify cases where soil nutrient capital 

is replaced in reasonable time periods even under whole-tree 

harvesting scenarios.

A recent report, Silvicultural and Ecological Considerations of 

Forest Biomass Harvesting In Massachusetts, suggested that with 

partial removals (i.e., a combination of crown thinning and low 
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or P concentration, soil bulk density, or soil N because of the 

whole-tree harvest (Johnson and Todd 1998).’

White Pine and Red Pine Forests: Estimates of the volume of down 

dead wood in Maine’s pine forests are 255 ft3/ac (18 m3/ha) or 

1.6 t/ac (3.5 Mg/ha) (Heath and Chojnacky 2001). A review 

of research on DWM in the red pine forests of the Great Lakes 

area showed that there were 50 t/ac (113 Mg/ha) of DWM in an 

unmanaged forest at stand initiation and 4.5 t/ac (10 Mg/ha) in a 

90-year-old stand (Duvall and Grigal 1999). In comparison, the 

managed stand Duvall and Grigal (1999) studied had less DWM 

at both initiation 8.9 t/ac (20 Mg/ha) and at 90 years 2.9 t/ac (6.6 

Mg/ha). The same review showed the unmanaged stand had 30 

snags per ac (74 per ha) while the managed forest had 6.9 per ac 

(17 per ha) (Duvall and Grigal 1999). Red and white pine that fall 

to the ground at time of death will become substantially decayed 

(decay class IV of V) within 60 years (Vanderwel et al. 2006).

While not a recognized forest type, stands with a mix of oak, 

other hardwoods, white pine, and hemlock are common. Many 

of the red oak and white pine stands on sandy outwash sites 

are susceptible to nutrient losses because of a combination of 

low-nutrient capital and past nutrient depletion (Hallett and 

Hornbeck 2000).

Implications for Massachusetts Policies: The amount of DWM 

and natural patterns of decay and soil replenishment vary by 

forest type in unmanaged stands. Ideally, DWM retention targets 

would also vary by forest type; but presently there are not enough 

data across forest types and ages to set specific targets. The Forest 

Guild Retention and Harvesting Guidelines for the Northeast 

include examples of DWM ranges by forest types.

Exhibit 4.1: DWM Ranges by Forest Type

Northern 

HW Spruce-Fir OakHickory

White and 

Red Pine

Tons of 

DWM 

per acre*

8–16 5–20 6–18 2–50

* Includes existing DWM and additional material left during harvesting 

to meet this target measured in dry tons per acre.

The Forest Guild’s guidelines also include general targets for 

retaining logging residues to protect soil nutrient capital. Over 

time, Massachusetts and other state guidelines may be able to 

hone in on specific targets by forest type.

4.2.2.6 Impacts from Changing Harvesting 

Technology Caused by Increased Biomass 

Harvesting

All harvesting practices disturb forest sites, but the overall impact 

on soil structure and nutrients depends on the site, operator skill, 

and conditions of operation. A comprehensive study of site impacts 

in Maine (Benjamin 2010) reviewed the literature regarding soil 

compaction and erosion from logging. A comparison of nine related 

In contrast, a study of U.S. Forest Service inventory plots found 

a mean of 3.7 t/ac (8.3 Mg/ha) and a median of 2.9 t/ac (6.5 Mg/

ha) of DWM across 229 plots in the Northeast (Chojnacky et al. 

2004 see Figure 2). This low level of DWM across the landscape 

may be due to widespread clearcutting in the 1880-1930 periods.

Implications for Massachusetts Policies: The amount of dead 

wood varies across forest types and stand ages. In order to determine appropriate benchmarks that correlate with forest health, 

more data by stand and age is required than current research 

provides. However, we find there is sufficient data to construct 

some initial, but likely conservative, guidelines. These are detailed 

in the Forest Guild’s Biomass Retention and Harvesting Guidelines and summarized in Section 4.5.2 of this report. 

4.2.2.5 Soils and Productivity Issues by 

Forest Type

Northern Hardwood Forests: In general, the amount of DWM in 

Northern hardwood forests follows the ‘U’ pattern mentioned 

above. Young stands have large quantities of DWM (usually due 

to a harvest); mature stands have less; older or uncut stands have 

more. For example, a study in New Hampshire measured 38 t/

ac (86 Mg/ha) of DWM in a young stand, 14 t/ac (32 Mg/ha) in 

mature stands, 20 t/ac (54 Mg/ha) in old stand, and 19 t/ac (42 

Mg/ha) in an uncut stand (Gore and Patterson 1986). Gore and 

Patterson (1986) also note that stands under a selection system 

had lower quantities of DWM, i.e., 16 t/ac (35 Mg/ha). A review 

of other studies identified similar temporal patterns and quantities 

of DWM (Roskoski 1977, Gore and Patterson 1986, McCarthy 

and Bailey 1994, McGee et al. 1999, Bradford et al. 2009).

Estimates of the volume of down dead wood in Maine’s northern 

hardwood forests are 598 ft3/ac (42 m3/ha) or 9 t/ac (20.5 Mg/

ha) (Heath and Chojnacky 2001). Keeton (2006) estimates 

a volume of 600 ft3/ac (42 m3/ha) of DWM in a multi-aged 

northern hardwood forest.

Transitional Hardwoods: As with the other forest types discussed, 

DWM density tends to follow a ‘U’ shape in oak-hickory forests. 

For example, Idol and colleagues (2001) found 61 t/ac (137 Mg/

ha) in a one-year post-harvest stand, 18 t/ac (40 Mg/ha) in a 31–

year-old stand, and 26 t/ac (59 Mg/ha) in a 100-year-old stand. 

Tritton and colleagues (1987) measured 5.8 t/ac (13 Mg/ha) in 

an 80-year-old stand in Connecticut.

Estimates of the volume of down dead wood in Maine’s oak-hickory 

forests are 244 ft3/ac (17 m3/ha) or 0.7 (1.5 Mg/ha) (Heath and 

Chojnacky 2001). Wilson and McComb (2005) estimated the 

volume of downed logs in a western Massachusetts forest at 143 

ft3/ac (10 m3/ha).

A study in Appalachian oak-hickory forests showed that the 

decomposing residues left after a saw log harvest increased concentration of Ca, potassium (K), and magnesium in foliage and soils 

after 15 years in comparison to a whole-tree harvest (Johnson 

and Todd 1998). However, the study found no impacts on soil 

carbon, vegetation biomass, species composition, vegetation N 
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to meet the biomass demand. This will initially result in a more 

open residual stand than would have occurred otherwise and 

can range from stands with slightly lower residual stocking all 

the way to clearcuts. Habitat will change on individual parcels 

providing opportunities for new species and eliminating them 

for others. The other potential impact is on dead wood. Both 

standing snags and fallen logs (DWM) are important habitat 

features for many forest species. Dead wood is a part of a healthy 

forest. Forests that are intensively managed for forest products 

may eliminate important dead and dying structural components 

which could result in a lack of habitat and species on those managed 

landscapes. To ensure forest health for biodiversity, safeguards 

will be needed to ensure that dead wood remains a component 

of the forest ecosystem.

4.2.3.1 DWM: Wildlife and Biodiversity 

Dead wood is a central element of wildlife habitat in forests 

(Freedman et al. 1996). Many forest floor vertebrates have benefited 

or depended on DWM (Butts and McComb 2000). In New 

England, De Graaf and colleagues (1992) catalogued at least 40 

species that rely on DWM.

Some examples from the Northeast of relationships between 

animals and DWM include a study showing that low densities 

of highly decayed logs (less than one highly decayed log/ha ) 

had a negative impact on red-back voles (Clethrionomys gapperi) 

in a northern hardwoods forest in New Brunswick, Canada 

(Bowman et al. 2000). DWM retention increased spotted salamander (Ambystoma maculatum) populations in a Maine study 

(Patrick et al. 2006). 

In aquatic environments, DWM provides a crucial refuge 

from predation (Angermeier and Karr 1984, Everett and Ruiz 

1993). Logs that fall in the water formed a critical component 

of aquatic habitat by ponding water, aerating streams, and 

storing sediments (Gurnell et al. 1995, Sass 2009). In fact, 

removal of large woody material from streams and rivers had 

an overwhelming and detrimental effect on salmonids (Mellina 

and Hinch 2009).

DWM is a key element in maintaining habitat for saproxylic (live 

and feed on dead wood) insects (Grove 2002). For example, some 

specialist litter-dwelling fauna that depend on DWM appear to 

have been extirpated from some managed forests (Kappes et al. 

2009). Extensive removal of DWM could reduce species richness 

of ground-active beetles at a local scale (Gunnarsson et al. 2004). 

More generally, a minimum of 286 ft3/ac (20 m3/ha) of DWM 

has been suggested to protect litter-dwelling fauna in Europe 

(Kappes et al. 2009).

Dead logs serve as a seedbed for tree and plant species (McGee 

2001, Weaver et al. 2009). Slash could be beneficial to seedling 

regeneration after harvest (Grisez, McInnis and Roberts 1994). 

Fungi, mosses, and liverworts depend on dead wood for nutrients 

and moisture, and in turn, many trees are reliant on mutualistic 

relationships with ectomycorrhizal fungi (Hagan and Grove 

1999, Åström et al. 2005). In general, small trees and branches 

studies (Martin, 1988) concluded “the percentage of disturbance 

per area has increased over time with changes in equipment 

(tracked to wheeled machines, chain saws to harvesters) and 

harvest methods (partial cuts to clearcuts to whole-tree clearcuts).” 

However, the research also suggests that biomass harvesting will 

not contribute to or create additional physical impacts on the soil 

productivity as compared to conventional harvesting as long as 

BMPs are followed (Shepard 2006) 

The supply scenarios developed in the Chapter 3 Forest Biomass 

Supply analysis indicate that “if biomass demand increases due 

to the expansion of electric power plants, it will almost certainly 

be accompanied by increases in whole-tree harvesting due to the 

limited supply of other forest biomass and the cost advantages of 

whole-tree methods.” The concerns for physical soil structure and 

erosion revolve around the equipment that will likely be introduced on harvesting operations. Whole-tree harvesting systems 

come in a variety of designs that rely on different pieces of equipment. In Massachusetts, the most common whole-tree logging 

systems employ a feller/buncher, one or more grapple skidders, and 

some kind of loader at the landing. This equipment can be larger 

and heavier than traditional harvesting equipment and has the 

potential to magnify adverse effects on soil. Also, many biomass 

harvests use a two-pass system in which one piece of equipment 

cuts trees and stacks them and another piece eventually picks 

them up for transportation to the landing. Repeated equipment 

passes can cause greater degrees of soil compaction, resulting in 

increased soil strength, which can (1) slow root penetration and 

reduce the regeneration and tree growth (Greacen and Sands, 

1980; Miller et al., 1996); and (2) reduce soil infiltration rates, 

thereby increasing the potential for erosion through changes in 

landscape hydrology (Harr et al.1979). 

The extent of impacts on soil properties and site productivity 

will depend on the degree current best management practices 

(BMPs) and new guidelines are followed. Current BMPs include 

fundamental approaches that apply to biomass harvests as well 

as traditional harvests. They include anticipating site conditions, 

controlling water flow and minimizing and stabilizing exposed 

mineral soil. These guidelines should be re-emphasized and 

implemented in biomass harvests. Additional guidelines related 

to the retention and use of woody biomass will be helpful especially on skid trails and stream approaches. For example, research 

shows that spreading tops and limbs along skid trails and other 

operating areas and driving the equipment on this buffer can 

reduce soil impacts. In order to have this material available for 

these purposes it must be retained in place or brought back to 

the operating area. There are competing values of biomass that 

pit the desire to remove the material as a renewable fuel and to 

mitigate the global effects of climate change on forest ecology 

versus its onsite ecological benefits. 

4.2.3 Impacts on Habitat and Biodiversity

Increasing harvests to include greater biomass removal will have 

two primary effects on habitat and biodiversity. First, a greater 

volume of wood will be removed from many harvest operations 
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4.3 Lessons from Other Initiatives: 

Protecting Stand Level Ecological 

Values through Biomass Harvest 

Guidelines

States from Maine to Missouri, Canada, and some European 

countries have addressed or are addressing stand-level ecological 

concerns by developing guidelines for harvesting woody biomass 

from forests. To inform the Massachusetts process, we have 

expanded on the Forest Guild’s report An Assessment of Biomass 

Harvesting Guidelines to provide updates, include additional states 

in New England, and give a thorough assessment of northern 

European initiatives. This section begins with an overview of the 

Guild report highlighting key points relevant to Massachusetts. 

It concludes with a brief review of the harvesting regulations 

and BMPs in Massachusetts and the gaps in those directives that 

indicate that a new set of guidelines is needed. 

4.3.1 Overview of Regulatory Frameworks 

In the U.S., forestry on private and state lands is regulated primarily 

at the state level. At least 276 state agencies across the country have 

some oversight of forestry activities, including agencies focused 

on forestry and others concerned with wildlife or environment 

protection policies (Ellefson et al. 2006). All 50 states have BMPs. 

In general, BMPs originally focused on water quality and did 

not anticipate the increased removal of biomass. Consequently, 

BMPs historically have offered little or no specific guidance on 

the amount of removal that is healthy for ecosystems or how much 

biomass should be retained. However, this situation is changing. 

Pennsylvania’s old BMPs encouraged operators “to use as much of 

the harvested wood as possible to minimize debris,” while more 

recent guidelines recommend leaving “15 to 30% of harvestable 

biomass as coarse woody debris.”

Woody biomass is usually considered to be logging slash, smalldiameter trees, tops, limbs, or trees that cannot be sold as highervalue products. Depending upon prevailing market conditions, 

however, material meeting pulp or pallet specifications may also be 

used in biomass energy facilities. Reasons for biomass harvesting 

guidelines are likely to mirror the reasons forestry is regulated in 

general, which include (Ellefson and Cheng 1994):

• general public anxiety over environmental protection,

• the obligation to correct misapplied forestry practices,

• the need for greater accountability,

• growth of local ordinances,

• landscape-level concerns, and

• following the lead of others.

Biomass harvesting guidelines are designed to fill the gaps where 

existing BMPs may not be sufficient to protect forest resources 

under new biomass harvesting regimes. In other words, BMPs were 

host more species of fungus-per-volume unit than larger trees 

and logs; however, larger dead logs may be necessary to ensure 

the survival of specialized fungus species such as heart-rot agents 

(Kruys and Jonsson 1999, Bate et al. 2004).

Implications for Massachusetts Policies: It is clear that dead 

wood is a central contributor to biodiversity in our forests and 

that many species are dependent on sufficient quantities and 

sizes. This requires retention of DWM, standing cull trees and 

live trees that will eventually create these structures. 

4.2.3.2 Habitat and Biodiversity Issues by 

Forest Type

Northern Hardwood Forests: The number of dead trees in five 

hemlock-yellow birch forests range from 16 to 45 per ac (40 

to 112 per ha) or from 3 to14% of the basal area (Tritton and 

Siccama 1990). The 14 sugar maple-beech-yellow birch stands 

survey ranged from 14 to 99 dead trees per ac (35 to 245 per ha) 

or 5 to 34% of basal area (Tritton and Siccama 1990). Other 

estimates of snag densities in northern hardwood forests include 

5 per ac (11 per ha) (Kenefic and Nyland 2007), 15 per ac (38 

per ha) (Goodburn and Lorimer 1998), and 17 per ac (43 per 

ha) (McGee et al. 1999).

The number of cavity trees is another important habitat element 

in northern hardwood forests that is reduced by harvest. For 

example, studies in northern hardwood forests have shown a 

reduction from 25 cavity tree per acre (62 per ha) before harvest 

and to 11 (27 per ha) afterward (Kenefic and Nyland 2007). 

Another study measured 7 cavity trees per ac (18 per ha) in 

old growth, 4 per ac (11 per ha) in even-aged stand, and 5 per 

ac (13 per ha) in a stand in selection system (Goodburn and 

Lorimer 1998).

Transitional Hardwoods: Out of seven oak stands in Connecticut, 

the number of dead trees ranged from 19 to 44 per ac (46 to 109 

per ha) or 5 to 15% of basal area (Tritton and Siccama 1990). The 

decadal fall rates of snags in a Massachusetts study varied from 

52 to 82% (Wilson and McComb 2005). Snags, particularly 

large-diameter snags, provide important nesting and foraging 

sites for birds (Brawn et al. 1982, Gunn and Hagan 2000). In 

general, wildlife habitat requirements for dead wood are poorly 

documented, but it is clear that some wildlife species rely on 

dead wood in oak-hickory forests (Kluyver 1961, DeGraaf et 

al. 1992).

Implications for Massachusetts Policies: The number of 

standing dead trees varies by forest type in unmanaged stands. 

Ideally, biomass retention targets would also vary by forest type; 

but presently there are not enough data across forest types and 

ages to set specific targets for standing dead trees by forest type. 

The Forest Guild Retention and Harvesting Guidelines for the 

Northeast include guidelines with targets for retaining standing 

live and dead trees that are general for all forest types in Massachusetts. Over time Massachusetts and other state guidelines 

may be able to hone in on specific targets by forest type. 
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Wisconsin, and California are also covered because of their forest 

practices guidance on biomass harvest and retention. 

Entities interested in addressing concerns about biomass removal 

have taken at least three different approaches. One is to verify 

that existing forest practice regulations cover the issues raised by 

biomass harvests, obviating the need for new guidelines. Second, 

in instances where existing rules or recommendations are found 

to be insufficient, some entities—including Minnesota, Missouri, 

Pennsylvania, Wisconsin, and Maine—have taken a different 

approach and chosen to craft separate biomass guidelines that 

augment existing forest practice guidance. In the third case, 

standards-setting entities, such as the Forest Stewardship Council 

(FSC), have chosen to address concerns particular to biomass 

harvests in a revision of existing rules or recommendations. The 

examples in this report detail the status of rules and recommendations for removing biomass from forests.

The existing guidelines cover topics such as dead wood, wildlife 

and biodiversity, water quality and riparian zones, soil productivity, 

silviculture, and disturbance. An Assessment of Biomass Harvesting 

Guidelines lists the commonly used subtopics for each and identifies which are covered in a given set of guidelines. In some cases, 

a subtopic is noted as covered because it appears in another set 

of forestry practice rules or recommendations instead of that 

state’s biomass guidelines. The list of subtopics was developed 

from section headings of the existing guidelines and is similar 

to other criteria for sustainable production and harvest of forest 

biomass for energy (Lattimore et al. 2009). 

4.3.2 Key Findings from An Assessment of 

Biomass Harvesting Guidelines (revised)

An Assessment of Biomass Harvesting Guidelines reveals a number 

of approaches to the development of biomass guidelines that 

provide useful insights for Massachusetts. While not necessarily 

directly applicable to the ecological conditions in Massachusetts, 

these approaches illustrate the general types of measures that 

have been adopted by other states and government entities. Three 

important questions are addressed:

Do other guidelines offer specific targets backed by scientific research, or are they more general and open to further 

interpretation?

The ability to assure the public that sustainable forestry is being 

practiced is often confounded by vagueness and generalities in 

forestry BMPs or guidelines. Foresters are leery of prescribing 

targets that are expected to be carried out on every acre of forestland. Each forest stand is subject to different ecological factors, 

historical trends, disturbance patterns, landscape context, and 

management intent and should be treated as unique. Despite these 

difficulties, it is important for the profession to define targets and 

a system of monitoring to win public confidence and retain what 

has been called a “social contract” to practice forestry. The struggle 

between the need to set specific measurable targets and the realities of on-the-ground forestry is now being played out as states 

and others entities attempt to set biomass harvesting guidelines.

developed to address forest management issues at a particular point 

in time; as new issues emerge, new guidelines may be necessary. 

State BMP manuals usually include sections on timber harvesting, 

site preparation, reforestation, stream crossings, riparian management zones, prescribed burning and fire lines, road construction 

and maintenance, pesticides and fertilizers, and wetlands. These 

programs are routinely monitored, and literature suggests that 

when these BMPs are properly implemented they do protect 

water quality (Shepard, 2006). 

U.S. federal law requires states to address non-point source 

pollution of waterways. State programs vary with some states 

prescribing mandatory practices while others rely on voluntary 

BMPs and education and outreach programs. These programs can 

be categorized in three ways: non-regulatory with enforcement, 

regulatory, and combination of regulatory and non-regulatory. 

In the Northeast, Massachusetts and Connecticut are considered 

regulated; Vermont and New Hampshire are non-regulated with 

enforcement; and Rhode Island, New York, and Maine use a 

combination of approaches. 

Over time BMPs for water quality have expanded to include 

aesthetics, wildlife, and other resources. A survey in 2000 noted 

that nine states had extended their BMPs in such fashion, three 

of those from the Northeast (NASF Edwards and Stuart). This 

indicates a precedent for expanding BMPs to include issues 

such as increased biomass harvesting. In fact, some of the BMPs 

developed for water quality and conventional forestry already 

contain guidelines that would serve to protect water quality 

during increased biomass harvests. When these guidelines were 

developed, however, they were designed to specifically and solely 

address the issue of water pollution. Full implementation of these 

guidelines is necessary for protection of water quality. As harvests 

become more intense, other ecological issues, such as soil nutrient 

protection and wildlife habitat, come into play; previous BMPs 

likely do not account for them.

Although in many cases BMPs are voluntary, water pollution 

control requirements are not, and therefore landowners are 

compelled by law to adopt water quality BMPs to avoid legal 

penalties. This may explain the relatively high rates reported for 

national compliance (86%) and in the Northeast (82%) (Edwards 

2002). Biomass harvesting standards must address several management criteria such as protection and maintenance of forest structure for wildlife habitat, soil nutrient protection, and forest-stand 

productivity. These criteria, unlike those for water quality, typically 

have no legal foundation to compel compliance. 

The recently updated Forest Guild report, An Assessment of 

Biomass Harvesting Guidelines, reviews the biomass harvesting 

or retention guidelines from New York and New England, other 

states with specific biomass guidance, parts of Canada, northern 

European counties, and other organizations including the U.S. 

federal government and certification groups. We have grouped 

New York and the New England states together to offer a snapshot 

of the current situation in states geographically near Massachusetts. Maryland, Minnesota, Missouri, Michigan, Pennsylvania, 
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• New Hampshire: Under uneven-aged management, retain a 

minimum of 6 secure cavity and/or cavity trees per acre with 

one exceeding 18 inches diameter at breast height (DBH) 

and 3 exceeding 12 inches DBH.

• California: retain all snags except where specific safety, fire 

hazard, or disease conditions require they be felled.

• Minnesota: on non-clear cut sites, leave a minimum of 6 

cavity trees, potential cavity trees, and/or snags per acre. 

Create at least 2-5 bark-on down logs greater than 12 inches 

in diameter per acre.

4.3.3 Adequacy of Massachusetts BMPs for

Increased Biomass Harvests

The situation in Massachusetts is very similar to that in other 

states: current regulations and guidelines were developed for 

protection of water quality and did not anticipate the intensification of biomass harvesting. In Massachusetts, current regulations require a cutting plan that describes the harvest and the 

approaches to mitigate water-quality problems such as erosion 

and sedimentation.

Current regulations and BMPs, however, do not direct silvicultural or harvesting activities to sustain all the ecological values 

that might be negatively affected by increased biomass harvesting. 

There are no retention rules or guidelines that would prevent the 

harvest of every cull tree or den tree on a property, a situation that 

could take place with or without an expanded biomass market. 

Similarly, there are no harvesting guidelines that would prevent the 

scouring of DWM. Our literature review reveals these activities 

have the potential to degrade wildlife habitat, biodiversity, and 

soil nutrient levels. In addition, the current cutting plan process 

does not require sound silvicultural practice and the ecological 

safeguards that these proven practices offer in comparison to 

undisciplined harvesting. Finally, the introduction of larger, heavier 

whole-tree harvesting equipment presents new challenges and 

opportunities. Larger equipment can damage forest soils through 

soil compaction and increase residual stem damage because of 

their size. However, in some cases, new forest equipment can 

reduce soil impacts because they can provide less pressure per 

inch and reduce stand damage because of their longer harvesting 

reach. In practice, some of these impacts are and will be mitigated 

through good decisions by landowners, foresters and loggers, and 

the influence of supervising foresters through the cutting plan 

process. In most situations, however, there are no regulatory or 

voluntary guidelines in place that compel compliance. 

The assessment of guidelines in other states and countries reveals 

a number of additional approaches that can be tailored to state 

forest types and conditions to prevent ecological damage from 

biomass harvesting. We recommend that a similar set of guidelines be developed in Massachusetts and integrated into the 

cutting plan process. The newly developed Forest Guild Biomass 

Retention and Harvesting Guidelines for the Northeast utilize 

the best thinking and approaches from other states to develop a 

set of guidelines for northeastern forest types. These should be 

In Maine, the earlier drafts of voluntary guidelines provided specific 

numeric targets, but the final version is more general (Benjamin 

2010). Although background materials refer to specific targets 

recommended in an important multi-stakeholder report on 

biodiversity in Maine, targets were not incorporated in the final 

draft. The final guidelines call for leaving “some wildlife trees” 

without incorporating the numbers of trees per acre suggested 

in the report. Also, these guidelines call for leaving “as much fine 

woody material as possible” without specific requirements for top 

retention found in other states. Similarly, the Forest Stewardship 

Council’s standards for the U.S. require the maintenance of habitat 

structure and well-distributed DWM, but are not specific about 

the amount that should be left on site. 

How do other guidelines address the concern over the depletion of soil nutrients?

As noted above, some biomass harvest guidelines call for sufficient 

material to be retained to protect ecological functions such as soil 

nutrient cycles but offer no targets. A number of guideline documents, however, do offer targets in this category. The following 

is a sampling of the various ways retention of DWM has been 

approached.

• Alabama: Enough logging slash should be left and scattered 

across the area to maintain site productivity.

• Maine: Where possible and practical retain and scatter tops 

and branches across the harvest area.

• Michigan: retention of 17% to 33% of the residue less than 

four inches in diameter.

• Minnesota: tops and limbs from 20% of trees harvested.

• Missouri: 33% of harvest residue.

• New Hampshire: “Use bole-only harvesting (leaving branches 

and limbs in the woods) on low-fertility soils, or where fertility 

is unknown.”

• Pennsylvania: 15 to 30% of “harvestable biomass.”

• Wisconsin: tops and limbs from 10% of the trees in the 

general harvest area with a goal of at least 5 tons of FWM 

per acre.

• Sweden: 20% of all slash must be left on site.

• Finland: 30% of residues should remain and be distributed 

evenly over the site.

How do other guidelines address the concern over retention 

of forest structure and wildlife habitat?

The literature confirms that forest structure is important for 

wildlife habitat. Existing BMPs and new biomass harvesting 

guidelines use both general and specific approaches to address 

this issue. The following samples provide a snapshot of the range 

of approaches. 

• Maine: leave some wildlife trees; retain live cavity trees on 

site; vary the amount of snags, down logs and wildlife trees; 

and leave as much FWM as possible.
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Such localized, wood basket effects could take the form of rapid 

reduction or change in the quality of forest cover if many landowners respond to the demand from a new biomass facility by 

cutting more heavily on acres they would have harvested for 

timber anyway or by increasing the acreage they decide to harvest. 

From the ecosystem services perspective, such an increase in 

cutting could have a variety of effects. First, if enough landowners 

decide to conduct relatively heavy biomass harvests, we might 

see a reduction in older forest habitat and a shift to plant and 

animal species that prefer younger forests. Second, heavier or 

geographically concentrated cutting by private landowners could 

have broad aesthetic impacts that might be unacceptable to the 

public, potentially having negative impacts on other ecosystem 

services like forest-based recreation or tourism. Third, at a regional 

scale, increased harvest area or intensity may have long-term 

implications for the local timber and wood products economy 

if stands are harvested in a manner that results in a reduction in 

long-term supplies of high-quality timber. These various effects 

are discussed below in greater detail.

4.4.2 Potential Ecological Impacts of 

Biomass Harvests 

The ecological impacts from differing harvest scenarios can be 

considered at different scales. At the broadest scale—the forested 

land base of Massachusetts—a total harvest of 32,500 acres 

per year is approximately 1% of the total land base. This rate of 

harvest is unlikely to cause statewide ecological changes. The 

state’s forestland is on a trajectory to be comprised of older age 

classes, and harvests on 32,500 acres will not alter that trajectory 

significantly other than to provide the opportunity to make small 

shifts toward younger successional forests. The harvest intensities predicted at the stand level are close to historical ranges, and 

the total volume of removal is far below growth rates. Other 

factors such as climate change, rapid land conversion, large-scale 

disturbance from insect, disease, or hurricanes could all play a 

cumulative role to cause landscape-wide ecological disturbance, 

but the harvest scenarios are not widespread enough to have this 

broad effect alone.

However, landowner response to increased demand from bioenergy facilities could create more significant changes at smaller 

landscape scales. It is possible that several adjacent landowners or 

a significant number of landowners in a watershed or viewshed 

independent of each other could all respond to biomass markets 

with regeneration cuts over a short time period. Although this 

cannot be ruled out, the historical trends and landowner attitudes 

predict otherwise. Historically, rising prices at local sawmills do 

not appear to have stimulated widespread harvests of sawtimber 

for parcels nearby. Varying landowner attitudes and goals for their 

properties apparently work at even the smaller scale to mitigate a 

mass movement in any one direction of harvest or management, 

and we expect this to hold for biomass markets as well.

The public’s major landscape ecological concern focuses on wildlife 

habitat and the potential risks to individual or groups of species. 

The fact is, the abundance of any given species will wax and wane 

directly applicable to Massachusetts and provide a starting point 

for developing guidelines tailored to the regional ecology and 

forest types of the Commonwealth. 

4.4 Forest Sustainability Indicators 

and Landscape Level Effects of 

Biomass Harvesting

4.4.1 Introduction

Beyond stand-level impacts, biomass harvesting has the potential to 

affect the provision of a broad suite of ecosystem services at larger 

regional or statewide scales. In this context, we are adopting the 

ecosystem services definitions used in the recent Forest Futures 

Visioning Process conducted by the Massachusetts Department 

of Conservation and Recreation (DCR). These include ecological, 

socio-economic and cultural values provided by forests—essentially 

the term ecosystem services refers to all the public and private values 

provided by our forests. The sustainability of this broad suite of 

ecosystem services across the landscape is not primarily a scientific 

problem; instead it involves balancing a complex set of public values 

that go far beyond simply ensuring that biomass harvests leave a 

well-functioning ecosystem in place on harvested sites. 

Landscape ecological processes operate at varying spatial scales (e.g., 

across multiple stands, within a watershed, or an entire ecoregion). 

In the case of forests, the spatial arrangement and relative amounts 

of cover types and age classes become the ecological drivers on 

the landscape. The two most relevant ecological processes of 

interest in Massachusetts’ forests include facilitating or blocking 

movement of organisms and loss of “interior” habitat because of 

smaller patch sizes. Pure habitat loss is not necessarily a landscape 

ecological issue until it reaches a threshold where it influences the 

spatial pattern of habitats. At that time, which will vary by species, 

the spatial pattern can drive impacts beyond the effects of pure 

habitat loss. For most species (including plants, invertebrates, and 

vertebrates), we do not know where this threshold exists (Andren 

1994, Fahrig 2003, Lindenmeyer & Fischer 2006). In the discussion below, effects at the “landscape scale” generally refer to loss 

of habitat at different scales (e.g., watershed, statewide) and we 

do not attempt to address ecological processes that are influenced 

by the spatial arrangement of habitats. 

The wood supply analysis in Chapter 3 suggests that absent very 

significant changes in energy prices, we do not expect dramatic 

increases over the next 15 years in harvest acreage across the state. 

But that analysis is really focused on overall supplies, and has 

not attempted to define more localized spatial impacts of these 

harvests. Moreover, although we do not foresee major changes 

in electricity pricing that would provide incentives for much 

heavier harvests, we cannot rule out such an occurrence in the 

event of a major energy price shock or a change in energy policies 

that significantly raises long-term prices. Consequently, for any 

specific bioenergy facility, we cannot rule out that forest impacts 

are potentially more dramatic within the “wood basket” of the 

facility than would occur on average across forests in the state. 
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forest to a more natural state. Jenkins notes that the pragmatists 

point to the literature which suggests “there have been almost no 

losses of vertebrates or higher plants from the working forests 

and that overall levels of biodiversity in clearcuts and managed 

forests often exceed those of old, undisturbed forests.” The idealists “see the working forest as a conservation failure, and while 

they grudgingly accept it has considerable biodiversity, they argue 

that it is the wrong kind.” They draw on the general literature of 

biodiversity and landscape ecology to suggest that our current 

forests are fragile and impoverished or will become so when the 

“extinction debt” induced by dissection and fragmentation is 

finally “paid.” These proponents however, have not able to come 

up with good lists of the species that have actually been lost from 

managed forests. 

The history of the intensively managed industrial landscape 

of northern New England and New York is far different than 

Massachusetts. The low harvest rates of the last century have 

allowed the Massachusetts forests to mature. The current forest 

landscape of the state offers management possibilities for the 

pragmatist and the creation of old growth for the idealists. The 

lessons from the Northern Forest indicate that even in regions with 

much heavier harvesting the debate over the impacts of changing 

habitat patterns across the landscape continues unresolved. We 

can certainly expect this debate to continue in Massachusetts as 

we try to understand a dynamic and shifting land cover that is 

resilient but faces a number of pressures. While the number of 

landowners and their attitudes and behaviors seem to ameliorate 

the possibility of widespread harvests, there still remains the 

possibility of localized habitat loss within a watershed as well as 

stand-level effects. For this reason, in a concluding section we 

suggest a number of policy options that Massachusetts officials 

could consider if they wish to assure a greater degree of protection 

for these ecological values. 

4.4.3 Potential Impacts of Biomass 

Harvests on Landscape Aesthetics 

The forests of Massachusetts play a number of supporting roles 

in the socio-economic framework. They are the predominant 

natural land type and form the backdrop for most communities 

and many economic enterprises, including tourism and recreation. 

The forest landscape is integral to the way of life of Massachusetts 

residents and shapes the image of Massachusetts for visitors and 

employers locating businesses there. Although historically these 

forests have been heavily cut, and at one time reduced to 20% of 

the landscape, the current perception is one of dense unmanaged 

forests covering most of the landscape. At the more localized or 

regional scale, biomass harvesting could potentially alter this forest 

landscape. The heavily harvested forest landscape of northern 

Maine is one extreme example of what a forested landscape can 

look like when subject to available markets for low-grade material 

and landowners willing to harvest using clearcutting and short 

rotations. From the level of public reaction and media attention 

paid to clearcutting on public lands in the past, it is expected that 

broad scale clearcutting on private lands would likely have severe 

socio-economic impacts for Massachusetts. 

as forest age classes change and as those age classes shift across the 

landscape. The challenge, whether biomass harvesting becomes 

prevalent or not, is to make sure that no species declines to a level 

where it is at risk of being extirpated from the landscape as a result 

of forest harvesting. Once again, the number of different private 

landowners and varying nature of private landowner attitudes 

and behaviors serves to insulate forest landscapes from trends 

in harvesting strong enough to cause anything other than slight 

landscape scale changes in habitat or species composition. 

Wildlife habitat could potentially be affected at smaller landscape 

scales (such as a watershed) if many landowners in the wood 

basket of a power plant suddenly change their historical cutting 

patterns. If clearcutting or acceleration of regeneration harvests 

in even-aged stands are used, this could create a loss of mature, 

interior habitat (depending on the spatial level of harvesting) 

and species associated with that habitat. Although these species 

would likely shift elsewhere and still maintain viable populations 

across broader landscape scales, they might not exist in certain 

sub-regions for periods of time. Our scenarios do not predict 

broad-scale clear cutting, and it is more likely that habitat could be 

affected by practices that are more acceptable to landowners such 

as more intensive thinnings. One possible scenario for landowners 

would be to use the new markets for biomass to combine a partial 

thinning of the dominant trees with a low thinning to remove 

understory vegetation. If poorly managed, these practices could 

eliminate certain structural layers from the forest or deplete the 

forest of the dead and dying material necessary for certain species. 

The importance of dead wood has been covered elsewhere in the 

report. The lower forest structure provides important habitat as 

well. For example birds, particularly long-distance migrants prefer 

stands with an understory component (Nemi and Hanowski 

1984, DeGraaf et al 1998).

In order to gauge the effect that increased biomass harvesting 

could have on the amount of habitat at the landscape scale, it 

is instructive to consider neighboring regions. Maine and New 

Hampshire have a longer history with markets for low-grade material and the introduction of whole tree harvesting and clearcutting 

for pulp and biomass. How well these landscapes have fared in an 

ecological sense depends on perspective. If one compares these 

landscapes to an old growth ideal, they fall resoundingly short. 

However, a recent review of the ecological literature (Jenkins 

2008) for the Northern Forest region indicates the difficulty in 

quantifying landscape-wide ecological damage. 

Jerry Jenkins, a scientist with the Wildlife Conservation Society, 

reviewed the scientific literature on ecological factors in the 

intensively managed Northern Forest region for the Open Space 

Institute. The subsequent report, Conservation Easements and 

Biodiversity in the Northern Forest Region, includes sections 

on Northern Forest biodiversity and the effects of logging on 

biodiversity. Although the conclusions of this review are debated 

in the Northern Forest region, his introduction is helpful in 

understanding the different perspectives in evaluating landscape 

ecology. The “pragmatic” approach is to maintain the biodiversity 

that exists at present. The “idealistic” approach is to restore the 
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Whether these negative scenarios play out depends on whether 

the stand is managed with a silvicultural prescription, and that 

in turn depends on landowner intentions and state regulations 

for forest management.

4.4.5 Existing Approaches to Managing 

Landscape Level Impacts in Massachusetts

Historically, Massachusetts has not had programs to manage silviculture and forest harvesting at the landscape (i.e., multi-owner) 

level. This may be a function of the historical fact that over the last 

century Massachusetts forests have been recovering from heavy 

harvesting and deforestation from a prior period when much of 

the landscape was in agricultural use. In addition, the statewide 

harvest has been limited in number of acres and intensity. The 

advent of increased biomass harvesting, the continued loss of 

forestland to development and the effects of climate change may 

change the perception of an expanding healthy forest and need 

for greater oversight of harvesting at the landscape level. While 

the state does limit the size of individual clearcuts and requires 

adequate regeneration from harvests and in some cases regulates 

harvesting in concern for endangered species, nothing in current 

regulations or guidance limits the ability of private landowners 

to independently decide to harvest their forests, even if this 

results in very heavy and rapid cutting in a relatively small area. 

Furthermore, under the existing regulations, it is theoretically 

possible for an individual landowner to legally harvest an entire 

standing forest within a relatively short timeframe (5–10 years) 

by using a combination of clearcutting and shelterwood harvests.2

There are many historical reasons why forest regulatory policy has 

been implemented at the stand level rather than the landscape 

level. The focus of existing regulations has generally been aimed 

at protecting public rather than private ecosystem services values. 

For example, BMPs came into existence to protect water quality, 

which is clearly an ecosystem service that affects the public good—

either through off-site contamination of drinking water supplies 

or damage to public recreational resources. Proposed policies that 

assert control over ecosystem services that are viewed as purely 

private in nature have been much more controversial. The recent 

proposed changes to introduce better silviculture into the Forest 

Cutting Practices regulations are a case in point where the State 

Forestry Committee wrestled with these issues and ultimately 

agreed on an approach that would require sound silviculture 

practices across all harvests. The practice of silviculture was 

determined to be a public value and worthy of addressing in the 

cutting plans. But again, the only controls on forest harvesting 

now are at the stand level and focused on protecting values that 

are traditionally considered in the greater public’s interest, such 

as clean water, rare species, adequate forest regeneration, and fire 

protection. Landscape aesthetics, for example, are not captured 

by any existing regulation. Voluntary programs, such as land 

2 Shelterwood harvest are heavier cuttings that are intended to 

regenerate the forest with seedlings but leave a sheltering mix 

of larger trees that are removed shortly after the regeneration is 

established.

While the harvest scenarios do not anticipate broad scale clearcutting, reactions to aesthetic landscape changes are difficult to 

quantify. The view-shed of most forested areas of Massachusetts 

now consists of rolling acres of consistent overstory. Even a small 

amount of clearcutting, consistently repeated across the landscape 

would dramatically alter these views and probably create a different 

and negative reaction from tourists or residents. Therefore, any 

significant increase in clearcutting methods as a form of forest 

management could have potentially dramatic impacts on recreation and tourism and face significant challenges from residents 

accustomed to a maturing forest. The quantification of these 

effects is beyond the scope of this study. 

Fortunately, alternative forms of forest management are available 

including uneven-aged management that maintains a continuous 

overstory, and forms of even-aged management that delay final 

harvests until sizable regeneration has occurred. These alternative 

methods would mitigate the landscape-scale aesthetic effects on 

tourism and recreation and likely be more acceptable to residents. 

4.4.4 Potential Impacts of Biomass 

Harvesting on Economic Productivity of 

Forests

Massachusetts forests have historically supported a vibrant forest 

products industry that has declined dramatically in the last two 

decades. Although harvest rates of sawtimber remain steady, 

the number of Massachusetts sawmills and wood product businesses has declined. More of the current harvest leaves the state 

for processing. The future of this industry is directly connected 

to a continuing availability of high-quality forest products. The 

growth and harvest of these higher-quality forest products could 

be either enhanced or diminished by increased biomass harvesting. 

As demand and price for biomass rises, the number and choice 

of trees removed in harvests change. Trees that previously had 

no value and were left behind can now be removed profitably or 

at no cost. We expect that increased demand for biomass will 

lead to the introduction of whole-tree harvesting equipment 

on a wider scale, which will enable smaller trees to be harvested 

more economically. One positive effect of these new markets is 

to make it possible for foresters to remove portions of the stand 

that have little future economic value and thus provide growing 

space for trees with better potential. Without a biomass market, 

such improvement operations cost money and are typically not 

possible to perform. 

However, new biomass markets may cause the harvest of trees 

that would eventually develop into valuable crop trees if left to 

grow. A straight, healthy 10" oak tree that would someday grow 

to be an 18" high-value veneer log might be removed too early in 

order to capture its much lower biomass value today. The misuse 

of low thinnings to remove biomass could also remove the future 

sawtimber crop as well as the forest structure referred to earlier. 

Whole tree harvesting equipment may make such removals 

more profitable, but these trees can also be added to the harvest 

in conventional operations that use skidders and chain saws. 
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Fundamentally, in the face of imperfect scientific information, 

the choice of policies for protecting ecosystem functions at the 

stand level must factor in public values regarding how conservative biomass retention policies should be. In addition, it may 

be important to understand the public’s views on the extent to 

which biomass standards should rely on voluntary or mandatory standards. This likely will depend on the extent to which 

the public believes the proposed harvest practices are needed to 

protect public versus private values.

In light of these considerations, Massachusetts may find it useful 

to utilize the State Forestry Committee to convene an appropriate 

public process to establish biomass harvesting retention and 

harvesting guidelines for Massachusetts. The scientific data we 

reviewed in Section 3 provide a starting point for these public 

discussions. One approach other states have used is to create a 

panel of experts from across the spectrum of forestry interests 

to come up with recommendations which are then reviewed 

and commented on by stakeholders. The revision of Chapter 132 

regulations could easily fit this format by using the State Forestry 

Committee as the expert panel.

Embedded within our process recommendation is a second broad 

recommendation that the State Forestry Committee use the 

Forest Guild’s Forest Biomass Retention and Harvesting Guidelines

for the Northeast as a starting point for the substantive discussion of the options for ensuring biomass harvesting does not 

result in diminished ecosystem function at the stand level. The 

Forest Guild’s proposed guidelines are readily adaptable to the 

Commonwealth and cover the major Massachusetts forest types. 

The Forest Guild Biomass working group consisted of 23 Forest 

Guild members representing field foresters, academic researchers, 

and members of the region’s and country’s major environmental 

organizations. The process was led by Forest Guild staff and was 

supported by the previously referenced reports Ecology of Dead 

Wood in the Northeast (Evans and Kelty 2010) and An Assessment 

of Biomass Harvesting Guidelines (Evans and Perschel 2009a).

Wherever possible the Forest Guild based its recommendations 

on peer-reviewed science. As noted above, however, in many cases 

available research was inadequate to connect practices, stand 

level outcomes, and ecological goals. Where this was the case, 

the Forest Guild relied on field observation and professional 

experience. The guidelines are meant to provide general guidance and where possible offer specific targets that are indicators 

of forest health and can be measured and monitored. They are 

not intended to be applied on every acre. Forests vary across the 

landscape due to site differences, natural disturbances, forest 

management, and landowner’s goals. All of these elements need to 

be taken into consideration when applying the guidelines. These 

guidelines should be revisited frequently, perhaps on a three-year 

cycle, and altered as new scientific information and results of field 

implementation of the guidelines becomes available.

In the following section, the Forest Guild’s stand-level recommendations for ensuring biomass harvests do not damage ecosystems 

are examined in. six major categories.

purchases for conservation through land trusts and the state, have 

been the mechanism to achieve landscape objectives.

A second hypothesis for the lack of landscape-level forest management policies is a purely practical one. How such controls might 

be implemented is a difficult question. For example, what type of 

system would be put in place to decide who can harvest their land 

and when? Suppose a landowner needs short-term income for a 

medical emergency or college tuition. It will be difficult for the 

state to assume too much control over an individual’s rights when 

a widely held public value is not being obviously compromised.

Finally, in the past 50 to 75 years, we generally have not had a 

forest landscape “problem” caused by over-cutting that the public 

believed needed to be addressed. Forests have been increasing 

in both area and wood volume for many years as abandoned 

farmland has returned to woodland. However, that trend may 

be changing as urbanization and other land-use changes begin 

to reduce the amount of forestland in the Eastern U.S. (Drummond and Loveland 2010).

From this discussion, it should be clear that the sustainability 

of ecosystem services at the landscape level raises a wide array of 

complex issues involving public values. Forest ecology and science 

can help inform decisions about the need for an approach to 

ensuring biomass harvests do not compromise ecosystem services 

at a landscape scale. But ultimately, public policy on this issue will 

be a value-based exercise. As a result, our recommendations on 

this issue, included in the final section of this chapter, focus on 

options that could be considered as part of a broader process of 

assessing public perceptions about what would be unacceptable 

impacts at the landscape level.

4.5 Recommendations for

Addressing Stand and Landscape 

Level Impacts of Increased Biomass 

Harvesting

4.5.1 Stand Level Recommendations

The science underlying our understanding of the potential impacts 

posed by increased biomass harvests and the efficacy of policies to minimize these impacts is currently far from providing 

definitive guidance. While it is clear that DWM is fundamental 

to nutrient cycling and soil properties, there appears to be little 

or no consensus on the amount of woody debris that should be 

maintained. In fact, the literature generally suggests that minimum 

retention levels will differ based both on underlying site productivity as well as with the volume of material harvested and the 

anticipated amount of time the stand will have to recover before 

the next harvest. DWM is also essential for maintaining habitat 

and biodiversity; but again the scientific studies do not provide 

a definitive answer to the question of how much DWM should 

be left after a harvest. The impacts of logging equipment on soils 

are also likely to depend on site-specific conditions. 
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greater than 10 inches should be left. In areas under even-aged 

management, we suggest leaving an uncut patch for every 10 acres 

of regeneration harvest, with patches totaling 5% to 15% of the 

area. These guidelines also call for maintaining vegetation layers 

(from the over-story canopy to the mid-story), shrub, and ground 

vegetation layers to benefit wildlife and plant species diversity. 

There are targets for retention of downed woody material by 

weight and forest type. In addition, there are specific targets by 

forest types for snags, cavity trees, and large downed logs. 

In Massachusetts, there has been an awareness of the importance of 

forest structure for wildlife but no specific guidelines that broadly 

influence the retention of this material. The targets recommended 

here can be readily integrated into forest inventories, tree selection, and forest cutting plans. 

Water Quality and Riparian Zones

In general, water quality and riparian concerns do not change 

with the addition of biomass removals. Massachusetts State BMPs 

currently cover these issues, and habitat management guidelines 

are available for additional protections for streams, vernal, pools, 

and other water bodies. These can be integrated into a set of 

guidelines tailored to Massachusetts.

Silviculture and Harvesting Operations

Most concerns about the operational aspects of biomass harvesting 

are very similar to all forestry operations. However, some key 

points are worth mentioning for Massachusetts forestlands:

• Integrate biomass harvesting with other forest operations 

to avoid re-entering a site and increasing site impacts such 

as soil compaction.

• Use low-impact logging techniques such as piling slash to 

protect soil from rutting and compaction.

• Use appropriate equipment matched to the silvicultural 

intention and the site. 

Forest Types

Different forest types naturally develop different densities of 

snags, DWM, and large downed logs. Currently, available science 

leaves uncertainty around the exact retention targets for specific 

forest type and does not provide enough data to provide detailed 

guidance on each structure for every forest type. The Forest 

Guild guidelines, however, do discuss the relevant science that 

is available by forest type. Massachusetts can take that information and augment it with more localized research or prompt 

new research on specific topics. This information can be used to 

establish minimum retention targets for Massachusetts forest 

types. Wherever possible, targets should be exceeded as a buffer 

against the limitations of current research.

4.5.1.2 Improved Silvicultural Requirements 

for Forest Ecosystem Management

Finally, we would like to note that Massachusetts has for a number 

of years been considering changes to the forest cutting plan 

4.5.1.1 Forest Guild Biomass Harvest 

Guidelines

Site Considerations to Protect Rare Forests and Species

Biomass harvests should be avoided in critically imperiled or 

imperiled forest types that can be determined through the State 

National Heritage Program. Biomass harvesting on sensitive sites 

may be appropriate to control invasive species, but they should 

only be done for restorative purposes and not to provide a longterm wood supply. Old-growth forest should be protected from 

harvesting. In Massachusetts, old growth exists exclusively on 

public lands.

Retention of Coarse Woody Material

A review of scientific literature reveals a limited number of studies 

that address the biomass and nutrient retention issue. Some studies 

suggest that biomass harvesting is unlikely to cause nutrient 

problems when both sensitive sites (including low-nutrient sites) 

and clearcutting and whole-tree harvesting are avoided. However, 

there is no scientific consensus on this point because of the wide 

array of treatments and types of sites that have not yet been 

studied. Given this lack of consensus, the Guild’s recommendations adopt a conservative approach on this issue. They direct 

harvesting away from nutrient-limited sites. On sites with operable soils, we recommend that between 25% and 33% of tops and 

limbs be retained in harvests where 1/3 of the basal area is being 

removed on 15 to 20 year cycles. When harvests remove more 

trees or harvests are more frequent, greater retention of tops and 

limbs may be necessary. Similarly, where the nutrient capital is 

less rich or the nutrient status is unknown, greater retention of 

tops, branches, needles, and leaves is recommended. Conversely, if 

the harvest removes a lower percentage of basal area, if entries are 

less frequent, or if the site is known to have high nutrient levels, 

then fewer tops and limbs need to be left on site.

In Massachusetts it will be important to identify the soils where 

there are concerns regarding current nutrient status as well as those 

soils that could be degraded with repeated biomass harvests. Much 

of the current harvesting activity falls into the low-frequency 

and low-removal categories and will require lower levels of retention. It is difficult in most operations to remove all the tops and 

limbs even if the operator is attempting to do so. In these cases, 

the retention guidelines may not call for a significant change in 

operations. If whole-tree harvesting becomes more commonplace, 

the guidelines would become more important and the balance of 

acceptable retention and the frequency of harvests and removal 

intensities a greater issue. Whole-tree operations in some jurisdictions have dealt with retention targets for tops and limbs by 

cutting and leaving some whole trees that would otherwise have 

been designated for removal or transporting and scattering a 

certain percentage of the material back to the woodlot from the 

landing during return trips to remove additional material.

Retention of Forest Structures for Wildlife and Biodiversity

The Forest Guild recommends a number of approaches for retaining 

forest structure. All live decaying trees and dead standing trees 
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certainty in Massachusetts forest conditions. The current system 

is not designed to assure protection and oversight of a number 

of ecological and socio-economic sustainability indicators that 

could be affected by increased biomass harvesting.

Proposed Changes to the Cutting Plan Process

In 2006 the Massachusetts Forestry Committee ended a threeyear process where regular public committee meetings were held 

to completely revise the Chapter 132 Forest Cutting Regulations. 

By statute, the Committee involves representatives from the key 

stakeholder interests, and each meeting included a number of 

public members from various stakeholder groups. The process 

also involved work in several sub-committees and data analysis 

from the DCR. The process ended in the spring of 2006 with 

the Committee completing its voting on a complete package of 

revisions to the Regulations. The result, supported by the majority 

of members, was forwarded to DCR in anticipation of public 

hearings on the Regulations.

Two of the proposed changes are directly related to ensuring that 

biomass harvesting protects ecological and socio economic values. 

• A requirement that all forest cutting be based in silviculture, 

regardless of the owner’s intent, and allowing state foresters 

to require that trees of high-timber quality be left distributed 

across the stand after thinning or intermediate cuttings.

• A requirement for marking all trees either to be cut or to be 

left, regardless of value or cost.

The committee was considering using the silvicultural requirement as a way of getting around opposition to a third suggestion 

that would mandate that only licensed foresters could fill out a 

harvesting plan. We recommend that when the Chapter 132 

review process begins again, these proposed changes be resurrected in light of the interest in increasing the biomass harvest. 

The requirement that all cutting plans be based on silviculture 

would help assure that biomass harvesting would be ecologically 

sound and aligned with the long-term economic productivity of 

the stand. In our view, the requirement for marking trees will also 

promote good silviculture and ecological practices. However, it 

may not be necessary in every case, and some flexibility should 

be considered. These changes would ensure the engagement of 

professional foresters, require that the harvest be silviculturally 

sound, and refine the decision making process for selecting trees 

for harvest by requiring the marking of trees in most cases. 

4.5.2 Landscape Level Recommendations

To determine the need for and nature of approaches to minimizing ecosystem service losses at the landscape-scale as a result 

of forest biomass harvests, we recommend a public process-based 

approach. A broad-based and legitimate public process is necessary 

for addressing landscape-scale impacts of biomass harvesting, 

particularly because the scientific literature has much less to offer 

at the landscape scale than it does at the stand level. A key driver 

of public concerns about diminished ecosystem services at the 

regulations. In our view, putting these improved silvicultural 

guidelines in place, while not directly aimed at biomass harvests, 

will provide greater assurance that Massachusetts forests are 

managed to maintain ecosystem functions at the stand level. The 

remainder of this section discusses the current regulatory context 

and the changes that have been proposed.

Existing Regulatory Framework

Regulations for harvesting forest growth in Massachusetts are 

guided by intent to promote sound forestry practices and the 

maintenance of the health and productivity of the forest base. 

The licensing of foresters in Massachusetts is a recognition of 

their unique professional education, skills, and experience to 

practice forestry. One of the keystones of forestry is the practice 

of silviculture, the art and science of controlling the establishment, growth, composition, health, and quality of forests and 

woodlands to meet the diverse needs and values of landowners 

and society on a sustainable basis. Therefore, the argument has 

been made that all harvesting in the state should adhere to an 

acceptable form of silviculture and be performed by a licensed 

professional forester.

The state requires an approved harvesting plan for any harvest 

over 25,000 board feet. Any harvest is subject to oversight by 

Natural Heritage and Endangered Speices Program which imposes 

“life zones” around vernal pools and limits harvesting to certain 

months of the year in turtle habitat. But most harvested acres 

are ultimately subject only to requirements indicated in the 

state approved cutting plan for the property. Unfortunately, 

the current harvesting plan does not need to be filled out by a 

licensed forester, nor does it need to follow any accepted form 

of silvicultural practice. 

On the cutting plan, landowners are offered a choice of long-term 

management and short-term management. A long-term management choice “employs the science and art of forestry.” However, 

the short-term option does not and is characterized as follows:

Harvest of trees with the main intention of producing 

short-term income with minimum consideration given to 

improving the future forest condition ... [and] the selection 

of trees for cutting based on the economic value of individual 

trees which commonly results in a residual forest stand 

dominated by poor-quality trees and low-value species. 

While this strategy produces immediate income and meets 

the minimum standards of the act, it does little to improve 

the future condition of the forest.

DCR takes the position that long-term management is the 

preferred option and warns that the short-term harvests retain 

slower-growing and poor-quality trees which can limit management options. Still, the short-term option is acceptable and used 

by 20% of current harvests. This means that aside from restrictions on some harvest areas through the Natural Heritage and 

Endangered Species Program the door remains open for virtually any kind of harvest as long as it protects water quality and 

assures adequate regeneration of some kind of tree species- a near 
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that biomass energy supplies would be harvested in a manner that 

would not result in damage, at least at the stand level. Vermont 

and New York require their biomass power producers to obtain 

their supply from forests with approved forest management plans. 

Such a requirement would be a start for Massachusetts facilities, 

but the harvests should also be certified as having been conducted 

under an acceptable set of biomass harvesting and retention 

guidelines. The Forest Guild guidelines or other state guidelines 

could be used where deemed sufficient, or enrollment in one of 

the existing forest certification programs that incorporate biomass 

retention guidelines could work as well.

One wood pellet manufacturer in New York State is supplied by 

100% FSC-certified lands. Historically, certification has not been 

a practical option for a diverse, small forest-ownership land base 

such as Massachusetts. To the extent that aggregation of land 

ownerships into certification systems becomes more common, this 

may become feasible. In addition, the state has recently developed 

a new program that will allow small owners who seek Chapter 61 

property tax exemption for their forest land to prepare “stewardship plans” that will automatically confer third-party certification 

status on their lands. The biomass facility would periodically 

report and be evaluated on the ecological and socioeconomic 

sustainability of the supply. This kind of transparent reporting 

has proven effective in the toxic waste sector and is applicable to 

biomass supply.

Another level of assurance is to require the biomass facilities that 

receive subsidies or incentives to monitor, verify, and report on 

the sustainability of their supply, including an annual geographic 

analysis of the facility’s geographic wood basket. Some of the supply 

may come from other states; so the biomass facilities will need 

to account for supply not produced under the various safeguards 

that may be instituted in Massachusetts. 

Overall, while these approaches improve the likelihood that 

bioenergy facilities are supporting good forestry practices, they 

may not be sufficient to fully protect against over harvesting at 

the local or regional scales.

Option 3: Require bioenergy facilities to submit wood supply 

impact assessments

This option would require that a facility submit information on its 

anticipated wood supply impacts as part of the facility siting and 

permitting process. The facility would identify the area from which 

it anticipates sourcing most of its forest biomass and would present 

information on the level of the cut across this region over the life 

of the facility. As conceived here, this is purely an informational 

requirement and would not be used as the basis for a positive or 

negative determination on a permit. But requiring information 

from a developer on the long-term impacts of their operation 

on wood supplies within the wood basket of the facility, may 

result in greater public accountability for the facility and a better 

understanding of the likely impact on forests. Similar informational programs, such as requiring manufacturing companies to 

landscape level is uncertainty about the local and regional impacts 

of specific bioenergy facilities. Resolving these uncertainties 

requires gaining a better understanding of the spatial dimensions 

of harvests for specific proposed facilities. These uncertainties 

depend on facility size, wood demand, and the extent to which 

the facility relies on forest versus other biomass. Another uncertainty relates to future energy prices. While landowner reaction to 

price trends is difficult to predict with accuracy, the likelihood of 

increased harvests and the concern over landscape-scale impacts 

increases if policies result in greater use of bioenergy technologies that can afford to pay more for wood (e.g., thermal, CHP, 

cellulosic ethanol). 

Uncertainty, however, will not be the only driver of public preferences. Equally important is how the public perceives and values 

possible impacts to competing ecosystem services (e.g., renewable 

energy production versus biodiversity across the landscape), and 

how risk averse the public is to potential negative impacts of 

biomass harvesting. Only through a legitimate public process will 

it be possible to gauge the public’s desire for some landscape-level 

controls on biomass.

With these issues in mind, we have developed some options 

that could form the basis for a public dialogue on the need for 

and desirability of policies addressing landscape-scale impacts 

of biomass harvesting. These range from non-regulatory, information-based approaches to more stringent and enforceable 

regulatory processes. In general, it may be easier for an individual bioenergy facility to implement voluntary sustainable 

guidelines for the procurement of their biomass than for a state 

to implement the same sort of policies. Four possible options 

are discussed briefly below.

Option 1: Establish a transparent self-monitoring, selfreporting process for bioenergy facilities that includes a 

commitment towards continual improvement.

Bioenergy facilities could report their procurement status on a 

year-to-year basis. The report could include a report card that 

indicated where the supply came from according to a number 

of assurance criteria. Examples of these criteria can be found in 

the Forest Guild’s Assurance of Sustainability in Working Forest 

Conservation Easements and the Biomass Energy Resource Center’s 

Wood Fuel Procurement Strategies for the Harwood Union High 

School report. Using a licensed forester or a management plan 

would be at one end of the assurance of sustainability spectrum. 

Compliance with the Forest Guild’s biomass harvesting and 

retention guidelines might be in the middle of the spectrum and 

receiving supply from forest certified by FSC could be one of the 

highest assurances. Each year the facility would be expected to 

show improvement. 

Option 2: Require bioenergy facilities to purchase wood 

from forests with approved management plans 

If bioenergy facilities were allowed to purchase wood only from 

landowners with approved forest management plans approved 

by licensed foresters, there would exist a base level of assurance 
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submit information on toxic chemical use, have created positive 

incentives for improved environmental outcomes. 

Option 4: Establish formal criteria for approval of wood 

supply impact assessments

This option differs from Option 3 in that the state would establish 

criteria that would have to be met in order for a facility to receive 

approval for its wood supply impact assessment. For example, 

possible approval criteria might be based on limits on the amount 

of harvests relative to anticipated forest growth in the wood basket 

zone. These could take a variety of forms. For example, the state could 

require a demonstration that biomass harvests could be conducted 

without reducing future harvest levels in the wood basket zone (i.e., 

a non-declining even flow) or other types of limits on how much 

forest inventories in the wood basket could be reduced over the life 

of the facility. Once approved, the facility might also be required 

to submit annual comparisons of actual wood supplies with those 

included in the approved wood supply impact assessment. Measures 

could also be put in place requiring corrective actions to be taken 

by a facility if impacts exceed those anticipated in the impact assessment. Such an approach is more regulatory in nature and likely will 

be more expensive for facilities but it would give added assurance 

to the public that local and regional harvests would not diminish 

broader forest-based ecosystem services.

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Chapter 5

Forest Carbon Modeling: Stand-Level 

Carbon Dynamics and Implications of 

Harvesting for Carbon Accumulation

We evaluated the carbon dynamics of five common forest cover 

types throughout Massachusetts (Mixed Oak, White Pine, 

Northern Hardwoods, Hemlock, Mixed Hardwood). We had two 

primary objectives with this task: (1) to achieve an understanding 

of Massachusetts forest carbon dynamics and implications of 

different harvest intensities at the stand level; and (2) to support 

the forest carbon life cycle accounting analysis (Chapter 6) by 

providing data on the total carbon recovery rates of forest stands 

following harvests of varying intensity. Below we summarize the 

methods used to evaluate forest carbon dynamics and discuss the 

implications of varying harvest intensities on the carbon volume 

response by forest stands in Massachusetts. 

5.1 Forest Management and Carbon

Sequestration

Practices that increase the amount of biomass retained on a given 

acre over time can be seen as having a carbon benefit. This is 

particularly true when the removal of the retained biomass (e.g., 

for pulp wood for paper making) would have generated carbon 

emissions in a relatively short period of time or emit methane 

when ultimately disposed. Increased stand-level retention practices 

consistent with an ecological forestry approach are considered 

an appropriate mitigation strategy as well. Also appropriate are 

reduced impact logging practices that minimize soil disturbance 

and residual damage to stands, thereby reducing mortality and 

maintaining stand vigor. Under such approaches, late-successional 

forest structures are seen as beneficial to forest health and resiliency, as well as achieving the biomass levels needed to yield 

carbon benefits (NCSSF 2008). The relative value of extending 

rotations is being debated, but there is evidence accumulating 

that older forests continue to sequester carbon well beyond stand 

ages we are likely to see in the northeastern forests any time soon 

(Massachusetts: Urbanski et al., 2007; Globally: Luyssaert et al., 

2008). Extending rotation lengths serves to enhance structural 

complexity, thereby accumulating more biomass on a given acre 

(Foley et al., 2009). This strategy could also serve to sequester more 

carbon offsite in long-lived wood products through the production of larger diameter trees suitable for use in these products. 

However, Nunery and Keeton (2010) showed that even when 

offsite storage was considered in Northern Hardwood stands, 

the unmanaged stands still accumulated more carbon over a 160 

year time frame. Perez-Garcia et al. (2005) also concluded that 

offsite storage could not surpass onsite storage unless product 

substitution was considered. The assumptions made around 

product conversion efficiencies, decay rates, and the certainty 

around substitution effects will drive the conclusions about the 

significance of offsite carbon as a long-term sink associated with 

forest harvesting (e.g., Van Deusen, in press). 

Our modeling of forest carbon dynamics only includes estimates 

of onsite storage. Chapter 6 incorporates a more complete carbon 

life cycle accounting of the substitution implications associated 

with using wood for energy. The role of offsite storage in products 

is minimal when you consider that only 3.5% of hardwood sawlogs 

are estimated to be still in use after 100 years in the Northeast 

(Smith et al., 2006). A significant amount of hardwood sawlogs 

(28%) is estimated to remain in landfills after 100 years (Smith 

et al., 2006), but without methane capture technologies in place 

emissions associated with landfill storage would far exceed the 

benefits of other offsite storage. Landfill emissions are especially 

problematic since methane has a Global Warming Potential 

25 times worse than carbon dioxide (IPCC, 2007). Without a 

comprehensive life cycle assessment for products derived from 

Massachusetts forests we felt it was not productive to speculate on 

the role of offsite storage, particularly for the time periods we are 

considering below. More importantly for our analyses however, 

Chapter 6 assumes that the increase harvest intensity for biomass 

energy wood doesn’t change the disposition of materials that 

would be harvested absent biomass extraction. 

Below we describe the widely-accepted models and inventory data 

we used to understand the role of forest management in standlevel forest carbon dynamics. Where appropriate, we describe 

the limitations of the models and data and how they were used 

to inform the analyses in Chapter 6. Models are a representation 

of a complex ecological reality and are best used to investigate 

trends and likely outcomes, not predetermined certainty. Data 

are generally presented in aggregate to show broad trends, but 

specific examples are also given to illustrate points.

5.2 Inventory Data and Forest 

Carbon Models

Data used in the analyses were based upon Forest Inventory and 

Analysis (FIA) data from the U.S. Forest Service. We obtained 

inventory data from the FIA DB version 4.0 Data Mart from 

1998–2008.1 FIA plot data (including tree lists) were imported 

into the Northeast (NE) Variant of the US Forest Service Forest 

Vegetation Simulator (FVS)2 and are accepted as compatible with 

the model (Ray et al., 2009). FVS is a widely-accepted growth 

model within current forest carbon offset standards (e.g., Climate 

Action Reserve Forest Project Protocol 3.13 and the Chicago 

Climate Exchange Forest Offset Project Protocol 4) and as a 

tool to understand carbon implications of forest management 

within the scientific community (e.g., Keeton 2006; Ray et al., 

2009; Nunery and Keeton, 2010). The modeling package relies 

1 http://fia.fs.fed.us/tools-data/default.asp

2 http://www.fs.fed.us/fmsc/fvs/

3 http://www.climateactionreserve.org/wp-content/

uploads/2009/03/Forest-Project-Protocol-Version-3.1.pdf

4 http://www.chicagoclimatex.com/docs/offsets/CCX_Forestry_

Sequestration_Protocol_Final.pdf
Manomet Center for Conservation Sciences 83 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

on NE-TWIGS (Hilt and Teck, 1989) as the growth and yield 

model to derive carbon biomass estimates in the Northeast. 

These growth and yield models are based on data collected by 

the USFS’s Forest Inventory and Analysis unit from the 1950s 

through the 1980s. Developed by the US Forest Service and 

widely used for more than 30 years, the FVS is an individual 

tree, distance independent growth and yield model with linkable modules called extensions, which simulate various insect 

and pathogen impacts, fire effects, fuel loading, snag dynamics, 

and development of understory tree vegetation (Crookston and 

Dixon 2005). FVS can simulate a wide variety of forest types, 

stand structures, pure or mixed species stands, and allows for 

the modeling of density dependent factors. 

The FVS model modifies individual tree growth and mortality 

rates based upon density-dependent factors. As would be expected 

to be observed in nature, the model uses maximum stand density 

index and stand basal area as important variables in determining 

density related mortality. The NE Variant uses a crown competition 

factor CCF as a predictor variable in some growth relationships. 

Potential annual basal area growth is computed using a speciesspecific coefficient applied to DBH (diameter at breast height) and 

a competition modifier value based on basal area in larger trees is 

computed. In the NE Variant there are two types of mortality. The 

first is background mortality which accounts for occasional tree 

deaths in stands when the stand density is below a specified level. 

The second is density related mortality which determines mortality 

rates for individual trees based on their relationship with the stand’s 

maximum density. Regeneration in the NE Variant is user-defined 

(stump sprouting is built in) and we describe the regeneration inputs 

in more detail below.

The FVS Fire and Fuels Extension includes a carbon submodel 

that tracks carbon biomass volume based upon recognized allometric equations compiled by Jenkins et al. (2003). The carbon 

submodel allows the user to track carbon as it is allocated to 

different “pools.” Calculated carbon pools include: total aboveground live (trees); merchantable aboveground live; standing dead; 

forest shrub and herbs; forest floor (litter, duff); forest dead and 

down; belowground live (roots); belowground dead (roots). Soil 

carbon was not included explicitly in this analysis. Our FVS model 

simulations captured the carbon dynamics associated with the 

forest floor and belowground live and belowground dead root 

systems. Mineral soils were not included in our analyses, but 

appear generally not to be a long-term issue. A meta-analysis 

published in 2001 by Johnson and Curtis found that forest 

harvesting, on average, had little or no effect on soil carbon and 

nitrogen. However, a more recent review (Nave et al., 2010) found 

consistent losses of forest floor carbon in temperate forest, but 

mineral soils showed no significant, overall change in carbon 

storage due to harvest, and variation among mineral soils was 

best explained by soil taxonomy. It is important to recognize the 

current scientific uncertainty around the role of timber harvesting 

in carbon dynamics but the evidence presented to date does not 

modify our conclusions derived from the modeling. 

5.3 Model Scenarios

FIA data for both private and public lands from inventories 

between 1998–2008 were imported into a database for manipulation into the FVS model. The most current inventory year from 

each plot was used in the analysis and grown to the year 2010 

using the model described below. Plots were categorized by forest 

cover type based on tree species list from each plot (Exhibit 5-1).

We selected a subset of the FIA plots that met a condition of having 

≥ 25 Metric Tons of Carbon (MTC) per acre of aboveground 

living biomass (“aboveground live carbon”) prior to any harvest 

in 2010 to represent stands that are typically harvested across the 

state. This was important to match the assumptions made in the 

Chapter 3 supply analysis and is consistent with the approach of 

Kelty et al. (2008). These plots represented a mean aboveground 

live carbon stocking of 31 MTC/acre (or approximately 124 

green tons per acre). We refer to these plots as “operable” stands 

as they represent the majority of 70-100 year old stands with a 

likelihood of being harvested in the near term. A total of 88 

FIA plots were used for the analyses of operable stands (Mixed 

Oak n=4; Northern Hardwood n=31; Mixed Hardwood n= 29; 

Hemlock n=3; White Pine n= 21).

The model scenarios we tested were designed to understand the 

carbon implications of varying intensity of harvest (i.e., removal 

rates) including an evaluation of “no management” or “let it grow” 

scenarios. In particular, we were interested in the implications of 

harvests that were defined as “biomass” harvests that removed 

the majority of tops and limbs (65%) and represented higher 

rates of total removal than that defined as “Business as Usual” 

(BAU) in supply analysis (Chapter 3). FVS allows the user to 

Cover Type Cover Type Code Dominant Species Parameter

Mixed Oak MO Quercus spp. (hickories secondary) > 50% trees > 5” dbh are Quercus spp.

White Pine WP Eastern White Pine > 50% trees > 5” dbh are Pinus strobus

Northern 

Hardwoods NH Red and Sugar Maple, Beech, Yellow Birch, Black Birch > 50% trees > 5” dbh are northern hardwood spp.

Hemlock HE Eastern Hemlock > 50% trees > 5” dbh are Tsuga canadensis

Mixed Hardwood MH Northern Hardwoods/Mixed Oak default classification (can contain pine and 

hemlock)

Exhibit 5-1: Cover Type Classification for FIA Plots
Manomet Center for Conservation Sciences 84 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

the dynamics of conducting harvests with silvicultural objectives 

that included promoting crop tree development and moving 

towards uneven-aged silvicultural systems. 

We chose to model carbon accumulation within a period between 

2010 and 2100. Modeling on such a time frame comes with a 

degree of uncertainty and we acknowledge the limitations of this 

approach. In particular, projections do not include the impacts 

on carbon accumulation from stochastic natural disturbances, 

climate change, or the influence of exotic species. However, using 

these data to understand the potential long-term trajectories is 

appropriate and can tell us a great deal about response trends. 

select and customize forest management scenarios based on input 

criteria such as target residual basal area (BA), target percent 

removal, specification of diameter and species preferences, and 

tops and limbs retention preferences. Twenty scenarios were run 

using data from all FIA plots representing a range of intensity 

from no management to a silvicultural clearcut that removed 

all trees > 2" DBH (Exhibit 5-2). Scenarios are categorized as 

follows: (1) Unmanaged Accumulation; (2) Business as Usual 

Harvest (BAU); (3) Biomass Harvests; and (4) Sensitivity 

Analysis Harvests. The sensitivity analyses were designed to 

elucidate the carbon dynamics associated with retaining versus 

removing tops and limbs in biomass harvests and to understand 

Scenario Name Harvest Scenarios Category

Tops and Limbs 

Removed From 

Site (%)

Regeneration 

Scenario (see 

Exhibit 5-3)

MS1 Unmanaged Unmanaged Unmanaged 0 1

MS2 BAU 32% Common Partial Harvest (Business As Usual), Thin 

25% of stand BA from Above BAU 0 2

MS3 BAU 32% Light Biomass BAU with 65% Tops and Limbs Removed Biomass 65 2

MS4 BAU 32% Heavy 

Biomass BAU with 100% of Tops and Limbs Removed Biomass 100 2

MS5 Heavy Harvest BA 40 Heavy Harvest, Thin from Above to 40 ft2/acre BA Sensitivity 0 3

MS6 Heavy Harvest BA 40 

Light Biomass Heavy Harvest w/ Light Biomass Biomass 65 3

MS7 Commercial Clearcut 

(Tops and Limbs left) Commercial Clear Cut Sensitivity 0 4

MS8 Commercial Clearcut Commercial Clearcut with 65% Tops and Limbs 

Removed Biomass 65 4

MS9 Selection Cut “Quality” Individual Tree Selection (75 ft2/acre BA 

retained) Sensitivity 0 2

MS10 Selection Cut Light 

Biomass

“Quality” Individual Tree Selection (75 ft2/acre BA 

retained), 65% Tops and Limbs removed Sensitivity 65 2

MS11 Silvicultural Clearcut Silvicultural Clearcut No Legacy (>2” DBH trees 

removed) Sensitivity 0 4

MS12 Silvicultural Clearcut 

No Regen

Commercial Clearcut, No Legacy Trees Left, No 

Regen Sensitivity 0 x

MS13 DBH BA60 Thinning through diameter classes to BA 60 ft2/acre 

of trees > 8” DBH Sensitivity 65 3

MS14 DBH All BA60 Thinning through diameter classes to BA 60 ft2/acre Sensitivity 65 3

MS15 Biomass BA60 Thin from Above to BA 60 ft2/acre Biomass 65 3

MS16 BAU 20% Common Partial Harvest, Thin from Above (15% BA 

removed = 20% volume) BAU 0 2

MS17 BAU 20% Light Biomass

Common Partial Harvest, Thin from Above (15 % 

BA removed = 20% Volume), 65% Tops and Limbs 

Removed

Sensitivity 65 2

MS18 BAU 35% Light Biomass

Common Partial Harvest, Thin from Above (20% 

BA removed = 35% volume removed), 65% Tops and 

Limbs removed.

Sensitivity 65 2

MS19 BAU 40% Light 

Biomass

Common Partial Harvest, Thin from Above (30% 

BA removed = 40% volume removed), 65% Tops and 

Limbs removed.

Biomass 65 2

MS20 BAU 15% Common Partial Harvest, Thin from Above (10% BA 

removed = 15% volume) Sensitivity 0 2

Exhibit 5-2: Summary of FVS Treatment Scenarios Analyzed
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Note: Species were allocated based on proportional representation within 

each cover type and weighted to reflect a higher proportion of intolerant 

and intermediate shade tolerant species in the Heavy Partial Harvest 

and Commercial Clearcut scenarios. 

5.4 General Results and Model 

Evaluation

5.4.1 General Results

All values below are expressed in terms of Metric Tons of 

Carbon per Acre (MTC/acre). Approximately 50% of dry 

wood weight is considered to be made up of carbon (or 25% 

of green wood weight). We also present values either in terms 

of Total Stand Carbon (TSC) or Aboveground Live Carbon 

(AGL). AGL is simply the carbon biomass associated with 

the aboveground elements of a live tree. TSC is comprised 

of aboveground live and dead trees, belowground live and 

dead roots, lying dead wood, forest floor, and shrub and herb 

carbon pools. AGL dynamics reflect behavior foresters would 

be more accustomed to and are analogous to stand basal 

area and merchantable volume response. Basal area to AGL 

Shorter-term projections (ca. 30 to 50 years) have been verified 

to have a higher degree of confidence since the impacts of these 

uncertainties are minimized by low probability of occurrence 

(Yaussy, 2000). We also focused on the stand-level response 

following a single harvest event at Time = 0 (i.e., 2010) rather 

than conduct a more complicated series of repeated harvest entries. 

We can infer a “sawtooth” response from repeated entries to a 

target basal area or residual condition, but single entry scenarios 

provided us the best information to evaluate the short-term 

impacts and response of stands following “biomass” harvests 

needed to inform Chapter 6.

The FVS NE Variant does not add regeneration elements by default 

(except for stump sprouting for appropriate species following 

harvest). Regeneration inputs were required to more appropriately 

reflect the behavior of forest stands following harvest. We followed 

the methods of Nunery and Keeton (2010) and adapted conservative regeneration inputs that were designed to be appropriate to 

the cover type and disturbance intensity but still within a range 

of natural variability (Exhibit 5-3). Conceptually, seedling inputs 

were periodically entered into the simulation throughout the time 

period to mimic baseline regeneration rates in an unmanaged 

stand. In harvested stands, larger numbers of seedlings were input 

immediately post harvest to mimic the pulse of regeneration that 

would be expected to follow a disturbance. Exhibit 5-3 shows 

the number of seedling inputs relative to the harvest scenario. 

Greater removal of overstory trees promotes the opportunity for 

larger numbers of seedlings to become established. The mix of 

species in heavier harvests was weighted more heavily to shade 

intolerant and intermediate shade tolerant species as would be 

expected following an actual harvest (after Leak et al. 1987 and 

Leak 2005). Regeneration inputs in harvested stands were then 

gradually reduced over time to mimic a stand initiation period 

followed by baseline regeneration. Site indices were inconsistently 

available for the FIA dataset so we used the default FVS value 

set to sugar maple with a site index of 56. 

Note: Regeneration is expressed in trees (seedlings) per acre. Inputs based on methods described in Nunery and Keeton (2010) and regeneration 

response to harvests described in Leak et al. (1987), Hornbeck and Leak (1992), and Leak (2005) (5-3a).

Regeneration 

Group Harvest Scenarios 

Year

2015 2025 2035 2045 2055 2065 2075 2085 2095 2105 2115

1 Unmanaged Baseline 

Regeneration 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 

2 Light Partial Harvest 

Response 2,500 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 

3 Heavy Partial Harvest 

Response 5,000 2,500 2,500 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 

4 Commercial Clearcut 

Response 20,000 5,000 2,500 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000

Shade Tolerance

Cover 

Type Intolerant Intermediate Tolerant Total

HE 16% 21% 63% 100%

MH 33% 40% 27% 100%

MO 23% 43% 34% 100%

NH 18% 54% 28% 100%

WP 32% 31% 37% 100%

Mean 24% 43% 33% 100%

Exhibit 5-3: Regeneration Inputs Used in FVS Model Scenarios
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the volume that could have been achieved in an unmanaged 

scenario. So, over a long period of time, biomass harvests 

have an opportunity to recover a large portion of the carbon 

volume removed during the harvest. However, this assumes 

no future harvests in the stand as well as an absence of any 

significant disturbance event. Both are unlikely. This return 

interval, or cutting cycle, in a silvicultural system will clearly 

play a role in the recovery of onsite carbon storage over time. 

If stands are consistently entered prior to achieving complete 

recovery, the result will be a declining “sawtooth” pattern of 

growth and recovery of carbon volume stored onsite. With 

planning and monitoring, uneven-aged silvicultural systems 

can be implemented that allow adequate time for recovery 

while maintaining a basal area that promotes quality sawlog 

production (Hornbeck and Leak, 1992). 

Canopy and sub-canopy density plays an important role when 

the harvest is not heavy enough to reduce the crown completion 

factors. Heavy harvests create light and space for fast growing 

intolerant hardwood species to succeed, which can create a pulse 

of fast growing AGL. The heavy harvest also generates more 

lying dead wood from the tops and limbs. This may keep the 

initial post-harvest TSC value high, until this material decays 

and is lost from subsequent carbon pools. However, this loss is 

very rapidly recovered by the fast growing species. The curves 

in Exhibits 5-4a and 5-4b show the general pattern of a faster 

growth rate in the periods immediately following a harvest 

event, followed by a gradual slowing at the end of the modeling 

period. This is not surprising particularly for the unmanaged 

scenario which would represent plots that are reaching ages 

around 200 years old by the end of the modeling period. The 

FIA data that forms the basis of the NE Variant modeling 

would have had few plots that represented stands of this age, 

so accumulation behavior this far out in time is uncertain and 

requires further research (e.g., Keeton et al., In Press).

The Heavy Harvest (BA40) and Commercial Clearcut harvest 

scenarios behave very similarly to each other. This is largely 

because the Commercial Clearcut retained trees greater than 

5" DBH which effectively brought the stand to 40 ft2/acre of 

basal area. Depending upon the density of trees > 5" DBH 

in the plot, the Heavy Harvest could actually be a heavier 

harvest than the Commercial Clearcut—which may explain 

the greater carbon accumulation after 2020. Note that Total 

Stand Carbon is actually higher for a time in the Commercial Clearcut plots, possibly a product of mortality from the 

regeneration inputs that are lost through density competition 

within the smaller stems in that scenario. When we look at the 

impacts of a Silvicultural Clearcut that removes trees down to 

2" DBH, it becomes obvious that there are immediate carbon 

benefits (AGL) to leaving behind advance regeneration when 

it is available (Exhibit 5-5). Even though 20,000 seedlings 

per acre are being input into the stand following harvest, it 

takes some time before those stems contribute significantly 

to the AGL, eventually the curve approaches the Commercial 

Clearcut, but not before 100 years. 

relationships are typically more linearly related than AGL and 

merchantable volume (Ducey and Gunn, unpublished data). 

Not surprisingly, unmanaged stands result in greater onsite 

carbon storage than any of the management scenarios we 

simulated when both TSC and AGL are considered over the 

90 year horizon (Exhibits 5-4a and 5-4b). Here, a range of 

management scenarios (including unmanaged) are shown to 

illustrate the response of a light diameter-limit partial harvest, 

a heavy harvest that removes 65% of the tops and limbs, and a 

commercial clearcut that removes all trees greater than 5" DBH. 

The mean values include both public and private landowners, 

and all cover types are aggregated. These patterns were also 

observed by Nunery and Keeton (2010) in Northern Hardwood 

stands and even held true when offsite storage of carbon was 

considered. There were a few plots where managed stands met 

or exceeded the unmanaged scenario by 2100. These plots were 

typically understocked at the time of harvest and a heavy harvest 

was able to “release” the advanced regeneration and promote 

the growth of the intolerant and intermediate shade tolerant 

species that were input following the harvest. These fast growing 

species begin to decline after 40 to 50 years and it is likely that 

a decline would be observed beyond our modeling period as a 

result of mortality in these short-lived species. If longer-living 

shade tolerant species were present in the pre-harvest canopy 

or mid-story, it is likely that these species would persist longer 

than the intolerants in the managed scenario.

Exhibit 5-4a: Total Stand Carbon Accumulation over Time

(see next page)

5-4b: Aboveground Live Carbon Accumulation over Time 

(see next page)

Light partial harvests in stands that remove larger diameter 

trees recover slowly and roughly parallel to unmanaged stands, 

but gradually approach unmanaged volumes over a 90-year 

period. This is likely because residual mean diameter is still 

relatively high following the harvest and the associated growth 

response is slow. These light diameter-limit partial harvests 

(e.g., BAU 20% and BAU 32%) represent the mean harvest 

intensity across Massachusetts. The light harvest in the canopy 

increases the growth rate in the initial ten year period, but very 

quickly returns to approximately the same as the unmanaged 

growth rate. Over time these BAU stands approach unmanaged 

stocking but don’t quite catch up after 90 years. This finding 

is consistent with work in the Harvard Forest by O’Donnell 

(2007) who found that carbon uptake in live biomass following 

a light partial harvest recovered quickly after an initial decline 

to equal the un-harvested control site’s carbon uptake rates. 

If this relationship holds into the future, the onsite stocks 

would not catch up to the unmanaged site. In contrast, the 

scenarios we defined as “biomass” harvests (Biomass 40%, 

Biomass BA40, Biomass BA60) maintain high growth rates 

for several decades. Because of this increased growth rate, 

even the heavier harvested stands can reach almost 90% of 
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Biomass Sustainability and Carbon Policy Study

Exhibit 5-4a: Total Stand Carbon Accumulation over Time

Note: Plots included are from FIA plots with >25 MTC/acre of Aboveground Live Carbon (pre-harvest) in 2010. Private and public owners and all 

cover types are aggregated (see Exhibit 5-2 for harvest scenario descriptions).

Exhibit 5-4b: Aboveground Live Carbon Accumulation over Time

Note: Plots included are from FIA plots with >25 MTC/acre of Aboveground Live Carbon (pre-harvest) in 2010. Private and public owners and all 

cover types are aggregated (see Exhibit 5-2 for harvest scenario descriptions).
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Biomass Sustainability and Carbon Policy Study

Note: Comparison is between a Commercial Clearcut (removing trees >5" 

DBH) vs. Silvicultural Clearcut (removing trees > 2" DBH).

Aboveground Live Carbon typically follows a pattern of faster 

growth when mean diameters are small and densities are not 

limiting; then slows down as basal area maximums are reached 

and the lifespan maximums are approached. This is typical of what 

would be expected based on principles outlined in Oliver and 

Larson’s classic Forest Stand Dynamics text (1996). Total Stand 

Carbon provides interesting insight primarily in the short term 

responses of stands as carbon pools are influenced by material left 

on the site. Later in the trajectory, the TSC becomes interesting 

again as mortality occurs and contributions of material to the 

dead standing and lying dead pools can vary. 

5.4.2 Cover Type and Ownership Differences 

in Carbon Accumulation

Species response rates can vary depending upon silvical characteristics and this can be illustrated in some variation among cover 

type responses. Below are some examples of variation among cover 

types (Exhibits 5-6a through 5-6c). In general, the patterns are 

Exhibit 5-5: Aboveground Live Carbon Accumulation

Following Clearcut Harvests

similar. The differences occur in terms of starting carbon volume 

and then become more pronounced near the end of the modeling 

period. For example, the Hemlock cover type accumulates the 

greatest amount of carbon over the long term as would be expected 

from a shade tolerant and long-lived species. However, these 

curves are based on only 3 plots, so a larger sample might bring 

it in line with other types. In addition, the future of Hemlock in 

Massachusetts is highly uncertain given the current status of the 

Hemlock Woolly Adelgid. For the other cover types, response 

to harvests (Exhibits 5-6b and 5-6c) generally follows the same 

trends with the real differences being accentuated late in the 

model period as with the Hemlock. Though there are minor 

differences among the cover types, we generally will report the 

results in Chapter 6 in aggregate. 

Likewise, for the purposes of this analysis, we aggregated plots 

regardless of ownership type (Public and Private). Ownership 

does not result in major differences in terms of carbon trajectories 

and response to harvests (e.g., Exhibit 5-7). Minor differences do 

occur in starting carbon volume, but the plots behave similarly 

over time. Kelty et al. (2008) documented differences in growth 

between ownership types but were using two different data sets 
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Biomass Sustainability and Carbon Policy Study

between 1.23 MTC/acre and 4.22 MTC/acre depending on the 

intensity of the overall harvest. This carbon volume decays very 

rapidly if left on the forest floor, but is compensated for by new 

growth generally within 10 years following the harvest (Exhibit 

5-8). The tops and limbs left in the forest can be observed as a 

pulse of carbon in the “lying dead” carbon pool, but it moves 

relatively quickly into the forest floor and ultimately is mostly 

lost to the atmosphere within a short time period (e.g., Exhibit 

5-9). Thus, if tops and limbs are harvested in one scenario, and 

left in another, Total Stand Carbon in both scenarios will nearly 

converge within one decade. This recovery of carbon lost from 

tops and limbs could theoretically be faster if there is significant 

material left onsite suppressing regeneration. Overall, the model 

results indicate that the removal of tops and limbs is generally a 

minor stand level carbon issue; however, as shown in Chapter 6, 

they can have a significant impact on carbon recovery profiles if 

they represent a significant proportion of the total harvest.

Exhibit 5-8: Tops and Limbs Contribution to Total Stand 

Carbon (see page 93)

Exhibit 5-9: Carbon Pool Comparison (see page 93)

to make those comparisons (FIA for private lands and MA DCR 

Continuous Forest Inventory for public lands). Utilizing the 

Continuous Forest Inventory Plots from the MA DCR proved 

to be logistically challenging to integrate into FVS with the FIA 

plots data. Since data were available for both Public and Private 

lands within FIA, we decided to maintain consistency by only 

using FIA data. 

Exhibit 5-6a: Unmanaged TSC Accumulation by Cover 

Type (see page 91)

Exhibit 5-6b: BAU 32% Removal TSC Accumulation by 

Cover Type (see page 91)

Exhibit 5-6c: Heavy Harvest BA40 TSC Accumulation by 

Cover Type (see page92)

Exhibit 5-7: Ownership Similarities in Carbon Accumulation 

Over Time by Cover Type (TSC) (see page 92)

5.4.3 Regeneration Contribution to Carbon

Accumulation

Appropriately reflecting a realistic regeneration scenario is an 

important component of extending the time frame in which the 

FVS model results can be meaningful. Simply put, regeneration 

fills space made available by disturbances or natural mortality. In 

our simulations, we have followed the basic principle that heavier 

disturbances create more space and light, and therefore allow 

increasing larger numbers of seedlings to become established. 

Lighter harvests create less space and light in which regeneration 

will be successfully established. The successful seedlings will be 

appropriate to the amount of shade they can tolerate. Regeneration species composition is generally related to species already 

present within a stand and adjacent stands. But heavy harvests in 

the NE would typically result in 2/3 of the regenerating species 

being either shade intolerant or intermediate tolerance. Biologically relevant amounts and species composition were integrated 

into our approach. 

The silvical characteristics of the regeneration are the primary 

factor contributing to forest carbon dynamics over time. Shade 

intolerants are typically faster growing species, but they are shorter 

lived. Thus, they can be responsible for an immediate increase 

in carbon biomass but will slow and decline after 50–60 years, 

whereas shade tolerant and intermediate shade tolerant species 

would persist in the stand and continue accumulating carbon for 

a longer period. However, Exhibit 5-5 above illustrates that the 

interaction between starting condition and the amount removed 

during a harvest are major drivers of carbon accumulation after 

a harvest. 

5.4.4 Role of Tops and Limbs in Carbon Budget

We evaluated the carbon implications of the removal of tree 

tops and limbs during a harvest. We chose to simulate a removal 

rate of 65% tops and limbs based upon the standards recommended in Chapter 4 and the operability limitations described in 

Chapter 3. Removal of 65% tops and limbs generates on average 
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Biomass Sustainability and Carbon Policy Study

Exhibit 5-6a: Unmanaged TSC Accumulation by Cover Type

Exhibit 5-6b: BAU 32% Removal TSC Accumulation by Cover Type
Manomet Center for Conservation Sciences 91 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Exhibit 5-6c: Heavy Harvest BA40 TSC Accumulation by Cover Type

Exhibit 5-7: Ownership Similarities in Carbon Accumulation Over Time by Cover Type (TSC)
Manomet Center for Conservation Sciences 92 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Exhibit 5-8: Tops and Limbs Contribution to Total Stand Carbon

Note: Comparison of harvest scenarios with all tops and limbs retained onsite following harvest versus removing 65% of tops and limbs (BAU 32%, 

Heavy Harvest BA40, and Commercial Clearcut). Total Stand Carbon values reflect the movement of carbon from tops and limbs into the down dead 

and forest floor carbon pools over time.

Exhibit 5-9: Carbon Pool Comparison

Note: Carbon pools after a Heavy Harvest (BA40) when 100% of Tops and Limbs are retained vs. 65% removed. 
Manomet Center for Conservation Sciences 93 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

very quickly returns to approximately the same as the unmanaged growth rate. Over time these BAU stands approach 

unmanaged carbon stocking but do not quite catch up after 

90 years. When considered in the context of the amount of 

forest harvested annually in Massachusetts there is little 

impact of harvesting on the onsite forest carbon balance 

across the state. 

• The scenarios we defined as “biomass” harvests (Biomass 40%, 

Biomass BA40, Biomass BA60) maintain high growth rates 

for several decades. Because of this increased growth rate, 

even the heavier harvested stands can reach almost 90% of 

the volume that could have been achieved in an unmanaged 

scenario. So, over a long period of time, biomass harvests 

have an opportunity to recover a large portion of the carbon 

volume removed during the harvest. However, this assumes 

no future harvests in the stand as well as an absence of any 

significant disturbance event. Both are unlikely. 

• The FVS NE Variant is an effective tool to evaluate standlevel response of forest carbon to harvesting for relatively 

long time periods in Massachusetts. The model has known 

limitations but generally reflects what we know about trends 

in forest stand dynamics. 

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5.5 Conclusion

What do we know about modeling carbon accumulation patterns 

with and without harvesting?

• The basic elements of stand dynamics (and thus carbon 

dynamics) are the interaction among: space, light, species 

silvical characteristics (how they grow, regenerate, light 

tolerance, moisture tolerance), and site characteristics. The 

FVS model handles the first three elements quite well. We 

have held the fourth element constant throughout.

• Starting condition matters. No two acres of “natural” forest 

will be exactly alike. Stand development (particularly in 

the form of carbon growth and yield) is the reflection of 

the unique attributes of a given acre, but broad patterns are 

somewhat predictable based on what we know about the 

silvical characteristics of individual species and how they 

interact with each other. Starting diameter distribution (or 

mean diameter) is a driver of carbon accumulation rates 

since growth rates will depend on the current diameter of 

the individual trees making up the stand.

• Basal Area (square feet per acre) in combination with Trees 

Per Acre (density) is a driver of carbon accumulation rates 

since it reflects the space available to grow and regenerate.

• Species composition of a plot/stand is also a driver. Differential 

rates of growth drive differential rates of carbon accumulation. Allometric equations of hardwood vs. softwood are 

also a factor (e.g., taper, tree architecture).

• The above elements all relate to the influence of stand history 

on current conditions as well. This history includes the impacts 

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hurricane). From a modeling and stand dynamics perspective, 

stand age (and tree age) also influences biomass/carbon growth 

rates. Some opportunities exist to “reset” an understocked or 

degraded stand. Conventional wisdom of foresters often says 

you would be better off starting over; it appears that can be 

true if regeneration yields desirable species—but it may just 

be a carbon/biomass response and the quality species mix 

for long-term growth may be sacrificed.

• The removal of tops and limbs generally has little impact 

on stand level carbon dynamics in Massachusetts forests. 

Tops and limbs that are not removed during a harvest decay 

quickly, generally within 10 years. If tops and limbs are a 

small proportion of the total harvest, then new growth will 

compensate for the removal within 10 years as well. 

• Apart from severely understocked or degraded stands, carbon 

accumulation onsite in unmanaged stands will exceed onsite 

storage in managed stands in the long term (i.e., greater than 

90 years).

• The current “business-as-usual” light harvest in the canopy 

increases the growth rate in the initial ten-year period, but 
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northeastern United States: net effects of harvesting frequency, 

post-harvest retention, and wood products. Forest Ecology and 

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Perez-Garcia, J., Lippke, B., Comnick, J., Manriquez, C., 2005. 

An assessment of carbon pools, storage, and wood products 

market substitution using life-cycle analysis results. Wood Fib. 

Sci. 37, 140–148. 

Ray, D.G., Saunders, M.R., Seymour, R.S., 2009. Recent changes 

to the northeast variant of the forest vegetation simulator and 

some basic strategies for improving model outputs. Northern 

Journal of Applied Forestry 26, 31–34.

Smith, J.E., L.S. Heath, K.E. Skog, and R.A. Birdsey. 2006. 

Methods for Calculating Forest Ecosystem and Harvested Carbon 

with Standard Estimates for Forest Types of the United States. 

Gen. Tech. Rep. NE-343. USDA For. Serv., Northeastern Res. 

Stn., Newtown Square, PA.

Urbanski, S., C. Barford, S. Wofsy, C. Kucharik, E. Pyle, J. 

Budney, K. McKain, D. Fitzjarrald, M. Czikowsky, and J. W. 

Munger (2007), Factors controlling CO2 exchange on timescales 

from hourly to decadal at Harvard Forest, J. Geophys. Res., 112, 

G02020, doi:10.1029/2006JG000293.
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Chapter 6

Carbon Accounting for Forest 

Biomass Combustion

6.1 Introduction

Greenhouse gas (GHG) emissions from bioenergy systems raise 

complex scientific and energy policy issues that require careful 

specification of an appropriate carbon accounting framework. This 

accounting framework should consider both the short and long term 

costs and benefits of using biomass instead of fossil fuels for energy 

generation. In most cases, the carbon emissions produced when 

forest biomass is burned for energy are higher than the emissions 

from burning fossil fuels. But over the long term, this carbon can be 

resequestered in growing forests. A key question for policymakers 

is the appropriate societal weighting of the short term costs and the 

longer term benefits of biomass combustion. This chapter provides 

analysis designed to help inform these decisions. 

As discussed in Chapter 1, government policies have reflected a 

widely-held view that energy production from renewable biomass 

sources is beneficial from a GHG perspective. In its simplest form, 

the argument has been that because growing forests sequester 

carbon, then as long as areas harvested for biomass are remain 

forested, the carbon is reabsorbed in growing trees and consequently the net impact on GHG emissions is zero.1 In this 

context, biomass combustion for energy production has often 

been characterized as “carbon neutral.”

Assumptions of biomass carbon neutrality—the view that forest 

biomass combustion results in no net increase in atmospheric GHG 

levels—have been challenged on the grounds that such a characterization ignores differences in the timing of carbon releases and 

subsequent resequestration in growing forests (Johnson, 2008). 

Burning biomass for energy certainly releases carbon in the form 

of CO2 to the atmosphere—in fact, as will be discussed below, per 

unit of useable energy biomass typically releases more CO2 than 

natural gas, oil or coal. In “closed loop” bioenergy systems—for 

example biomass from plantations grown explicitly to fuel bioenergy facilities—energy generation will be carbon neutral or close to 

carbon neutral if the biomass plantation represents stored carbon 

that would not have been there absent the biomass plantation. Net 

GHG impacts of biomass from sources other than natural forests 

may also be carbon neutral (or close) where these materials would 

have quickly entered the atmosphere through decay (e.g., residue 

from landscaping and tree work, construction waste). But for 

natural forests where stocks of carbon are harvested for biomass, 

forest regeneration and growth will not instantaneously recapture 

all the carbon released as a result of using the woody material for 

energy generation, although carbon neutrality—resequestering all 

the forest biomass carbon emitted—may occur at some point in the 

1 Even when lifecycle biomass production emissions are taken into 

account, the argument is that net impacts on GHG, while perhaps 

not zero, are at least very low.

future if the harvested land is sustainably managed going forward, 

for example under one of the widely recognized forest certification 

programs (e.g., FSC, SFI or PEFC). How long this will take for 

typical Massachusetts forest types and representative energy facilities, and under what conditions, is a primary focus of this study.

6.1.1 Brief Review of Previous Studies

The issue of net GHG benefits from burning forest biomass has 

been a topic of discussion since the early to mid-1990s. Beginning 

in 1995, Marland and Schlamadinger published a series of papers 

that addressed the issue, pointing out the importance of both sitespecific factors and time in determining the net benefits of biomass 

energy (Marland and Schlamadinger, 1995; Schlamadinger and 

Marland, 1996a, 1996b and 1996c). This work initially was based 

on insights from a simple spreadsheet model, which evolved over 

time into the Joanneum Research GORCAM model (Marland 

et al., undated). A variety of other models are now available for 

performing similar types of bioenergy GHG analyses. These 

include CO2Fix (Schellhaas et al., 2004), CBM-CFS3 (Kurz et 

al., 2008), and RetScreen (Natural Resources Canada, 2009). 

Generally these models differ in their choice of algorithms for 

quantifying the various carbon pools, their use of regional forest 

ecosystems information, and the methods used to incorporate 

bioenergy scenarios. Other studies have addressed these issues 

for specific locations using modeling approaches developed for 

the conditions in the region (Morris, 2008). Work on the development of appropriate models of biomass combustion carbon 

impacts continues to be a focus of the Task 38 initiatives of the 

International Energy Agency (Cowie, 2009).

In general, the scientific literature on the GHG impacts of forest 

biomass appears to be in agreement that impacts will depend on 

the specific characteristics of the site being harvested, the energy 

technologies under consideration, and the time frame over which 

the impacts are viewed (IEA, 2009). Site-specific factors that may 

have an important influence include ecosystem productivity, 

dynamics and disturbance (e.g., dead wood production and decay 

rates, fire, etc.); the volume of material harvested from a site for 

biomass; the efficiency of converting biomass to energy; and the 

characteristics of the fossil fuel system replaced. Recent research 

has also raised several other site-specific issues. Cowie (2009) cites 

research at Joanneum on albedo effects, which in some locations 

have the ability to offset some or potentially all the GHG effects 

of biomass combustion.2 The effect of climate change itself on 

carbon flows into and out of soil and above-ground live and 

dead carbon pools is another factor that has yet to be routinely 

incorporated into biomass energy analyses. 

Because of the site-specific nature of biomass GHG effects, we 

have developed an approach to evaluating impacts using available 

data on the characteristics of regional energy facilities and a forest 

2 This has generally been considered a more serious issue for 

harvests in forests located at higher latitudes than Massachusetts—

areas where harvests interact with longer periods of snow cover to 

increase reflectivity. 
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The conceptual modeling framework for this study is intended 

to address the question of how atmospheric GHG levels will 

change if biomass displaces an equivalent amount of fossil fuel 

generation in our energy portfolio. With this objective, the 

modeling quantifies and compares the cumulative net annual 

change in atmospheric CO2e for the fossil and biomass scenarios, 

considering both energy generation emissions and forest carbon 

sequestration. In the fossil fuel scenarios, there is an initial CO2e 

emissions spike associated with energy generation—assumed 

here to be equivalent to the energy that would be produced by 

the combustion of biomass harvested from one acre—which is 

then followed by a drawing down over time (resequestration) of 

atmospheric CO2e by an acre of forest from which no biomass is 

removed for energy generation. For the biomass scenario, there 

is a similar initial release of the carbon from burning wood 

harvested from an identical acre of natural forest, followed by 

continued future growth and sequestration of carbon in the 

harvested stand.

This process is summarized in the hypothetical example shown 

Exhibit 6-1 below. Energy emissions represent flows of carbon 

to the atmosphere and forest sequestration represents capture 

of carbon that reduces atmospheric levels. We assume the fossil 

fuel and biomass scenarios produce exactly the same amount 

of useable energy. The example is based on a fossil fuel facility 

that generates 10 tonnes of lifecycle C emissions and a BAU 

(timber cutting but no biomass removals) where total stand 

carbon (TSC) in all pools is rising by 0.15 tonnes per year. 

In the biomass scenario, lifecycle bioenergy emissions are 15 

tonnes of C and TSC on the forest, which was harvested for 

both timber and biomass, is increasing by 0.25 tonnes of C 

per year, a reflection of higher rates of forest growth that can 

result from increases in sunlight and growing space in the more 

heavily harvested stand. 

The bottom row of Exhibit 6-1 shows the incremental emissions 

from biomass energy generation (5 tonnes C) and the incremental 

(beyond a BAU forest management scenario) change in forest 

carbon sequestration (0.1 t/C/y or 1 tonne of carbon per decade). 

The cumulative net change (referred to hereafter as the carbon 

“flux”) in atmospheric C is equivalent for the two feedstocks at 

the point in time where cumulative TSC increases, above and 

beyond the accumulation for the fossil fuel scenario, just offset 

the incremental C emissions from energy generation. In the 

example this occurs at year 2060 when the forest has sequestered 

an additional 5 tonnes of C, equivalent to the initial “excess” 

biomass emissions. Before that time, cumulative carbon flux is 

higher for the biomass scenario, while after 2060 the biomass 

scenario results in lower cumulative atmospheric C flux. In this 

comparison, not until after 2060 would the biomass energy 

option become better than the fossil fuel with respect to impact 

on GHGs in the atmosphere. Furthermore, in the example full 

carbon neutrality would not be achieved, assuming no change 

in growth rates, until five decades after 2110, at which point 

the entire 15 tonnes of biomass energy emissions will have been 

recovered in new forest growth. 

ecosystems model that represents conditions in Massachusetts. 

In the next section, we discuss the overall carbon accounting 

framework for our analysis.

6.1.2 Carbon Accounting Framework

Energy generation, whether from fossil fuel or biomass feedstocks, releases GHGs to the atmosphere. The GHG efficiency—

the amount of lifecycle GHG emissions per unit of energy 

produced—varies based on both the characteristics of the fuel 

and the energy generation technology. However, biomass generally produces greater quantities of GHG emissions than coal, 

oil or natural gas. If this were not the case, then substituting 

biomass for fossil fuels would immediately result in lower GHG 

emissions. The benefits of biomass energy accrue only over time 

as the “excess” GHG emissions from biomass are recovered from 

the atmosphere by growing forests. Researchers have recently 

argued that the carbon accounting framework for biomass must 

correctly represent both the short term costs and the longer term 

benefits of substituting biomass for fossil fuel (Hamburg, 2010). 3

At the most general level, the carbon accounting framework we 

employ is constructed around comparisons of fossil fuel scenarios 

with biomass scenarios producing equivalent amounts of energy. The 

fossil fuel scenarios are based on lifecycle emissions of GHGs, using 

“CO2 equivalents” as the metric (CO2e).4 Total GHG emissions 

for the fossil scenarios include releases occurring in the production 

and transport of natural gas, coal or oil to the combustion facility 

as well as the direct stack emissions from burning these fuels for 

energy. Similarly, GHG emissions from biomass combustion include 

the stack emissions from the combustion facility and emissions 

from harvesting, processing and transporting the woody material 

to the facility. Most importantly, both the fossil fuel and biomass 

scenarios also include analyses of changes in carbon storage in 

forests through a comparison of net carbon accumulation over 

time on the harvested acres with the carbon storage results for 

an equivalent stand that has not been cut for biomass but that 

has been harvested for timber under a business-as-usual (BAU) 

scenario. Our approach includes the above- and below-ground live 

and dead carbon pools that researchers have identified as important 

contributors to forest stand carbon dynamics.5

3 More broadly, climate and energy policies should consider the 

full range of alternative sources of energy. Energy conservation and 

sources such as wind, solar or nuclear have no or very low carbon 

emissions and may also provide additional, potentially competing, 

options for reducing GHGs.

4 These adjustments incorporate the IPCC’s normalization factors 

for methane and nitrous oxides.

5 Typically wood products would also be included as an important 

carbon pools but because we assume these products are produced 

in the same quantities in both the BAU forest management and 

biomass scenarios, there will be no net change and thus there is 

no reason to track these explicitly. We also have not modeled soil 

carbon explicitly as recent papers suggest that this variable is not 

particularly sensitive to wood harvests (Nave et al., 2010).
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Biomass Sustainability and Carbon Policy Study

growth of the stand following the biomass harvest (relative to the 

BAU harvest) that is needed to recover the biomass carbon debt 

and begin accruing carbon dividends (calculated as the difference in growth between the biomass and BAU harvests). In the 

example, the carbon debt (9 tonnes) is shown as the difference 

between the total C harvested for biomass (20 tonnes) and the 

C released by fossil fuel burning (11 tonnes) that produces an 

equivalent amount of energy. 

Exhibit 6-2a and 6-2b: Total Stand Carbon and Carbon 

Recovery Times (tonnes carbon) (see next page)

The carbon dividend is defined in the graph as the fraction of the 

equivalent fossil fuel emissions (11 tonnes) that are offset by forest 

growth at a particular point in time. In the example, after the 9 

tonne biomass carbon debt is recovered by forest growth (year 32), 

atmospheric GHG levels fall below what they would have been 

had an equivalent amount of energy been generated from fossil 

fuels. This is the point at which the benefits of burning biomass 

begin to accrue, rising over time as the forest sequesters greater 

amounts of carbon relative to the BAU. Throughout this report 

we quantify these dividends as the percentage of the equivalent 

fossil fuel emissions that have been offset by forest growth. By 

approximately year 52, the regrowth of the stand has offset an 

additional 6 tonnes of emissions beyond what was needed to 

repay the carbon debt—representing an offset (or dividend) equal 

to 55% of the carbon that would have been emitted by burning 

fossil instead of biomass feedstocks.6 In this context, a 100% 

carbon dividend (almost achieved in year 100 in the example) 

represents the time at which all 20 tonnes of emissions associated with burning biomass have been resequestered as new forest 

growth. In a benefit-cost analytical framework, decisionmakers 

would decide whether the tradeoff of higher initial atmospheric 

carbon levels—occurring in the period before the carbon debt 

is fully recovered—is an acceptable cost given the longer term 

benefits represented by the carbon dividends.

6 The carbon dividend, expressed as the percentage of the equivalent 

fossil fuel emissions offset by the growing forest, is calculated as the 

6 tonnes of reduction (beyond the debt payoff point) divided by the 

11 tonnes of fossil fuel equivalent that would have been needed to 

generate the energy produced by burning wood that released 20 

tonnes of carbon.

Exhibit 6-1: Carbon Accounting Framework (tonnes-carbon)

Scenario

Energy 

Generation 

Emissions

Forest Stand Cumulative Total Carbon Accumulation

Year 2010 2020 2030 2040 2050 2060 2070 2080 2090 2100 2110

Biomass -15 2.5 5.0 7.5 10.0 12.5 15.0 17.5 20.0 22.5 25.0

Fossil -10 1.5 3.0 4.5 6.0 7.5 9.0 10.5 12.0 13.5 15.0

Net Change -5 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0

Adoption of this conceptual framework allows a useful and 

potentially important reframing of the biomass carbon neutrality 

question. From a GHG perspective, environmental policymakers 

in Massachusetts might prefer biomass to fossil fuels even if 

biomass combustion is not fully carbon neutral—that is even 

if biomass burning increases carbon levels in the atmosphere 

for some period of time. For example, it is possible that over 

some policy-relevant time frame burning biomass for energy 

could result in cumulatively lower atmospheric CO2e levels than 

generating the same amount of energy from coal, oil or natural 

gas—although these levels may still represent an increase in GHGs 

relative to today’s levels. Rather than focusing all the attention 

on the carbon neutrality of biomass, our approach illustrates that 

there is a temporal component to the impacts of biomass GHG 

emissions to the atmosphere. The questions then become: (1) do 

policymakers seek to promote an energy source that could benefit 

the atmosphere over the long term, but that imposes increased 

GHG levels relative to fossil fuels in the shorter term (perhaps 

several decades); and (2) do the long term atmospheric benefits 

outweigh the short term costs?

A useful way to understand the relative carbon dynamics is to 

isolate the key drivers of net carbon flux. From this perspective, the incrementally greater amount of CO2e associated with 

biomass energy is the relevant starting point. Following on the 

terminology developed by Fargione et al. (2008), we refer to these 

incremental emissions as the biomass “carbon debt.” 

In addition, we introduce the concept of “carbon dividends,” 

which represent the longer term benefits of burning biomass. In 

the example in Exhibit 6-1, these dividends can be thought of as 

the reductions in future atmospheric carbon represented in the 

years after the carbon debt has been recovered (i.e., after 2060). For 

example, by 2100 all 5 tonnes of excess C from biomass burning 

have been recovered plus another 4 tonnes (the dividend) that 

reflects additional reductions in emissions beyond what would 

have resulted if only fossil fuel had been used to generate energy. 

Graphically, the concepts of carbon debt and carbon dividend 

are illustrated in Exhibit 6-2. Exhibit 6-2a shows hypothetical 

carbon sequestration profiles for a stand harvested in a “business 

as usual” timber scenario and the same stand with a harvest that 

augments the BAU harvest with removal of 20 tonnes of additional 

carbon. Exhibit 6-2b shows the net carbon recovery profile for 

the biomass versus BAU harvest. This represents the incremental 
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Exhibit 6-2a and 6-2b: Total Stand Carbon and Carbon Recovery Times (tonnes carbon)
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Biomass Sustainability and Carbon Policy Study

when net cumulative GHG flux from biomass is below that of 

the fossil fuel alternative. In this case, longer time periods are 

needed to reach the point defined as “fully-offset damages.” The 

higher the discount rate—indicative of a greater preference for 

lower GHG levels in the near-term, the longer the time to reach 

the point of fully-offset damages. 

6.1.3 Other Considerations: Landscape or

Stand-Level Modeling

A key question in developing the conceptual framework for 

biomass GHG analysis is whether to analyze the problem at the 

level of the individual stand or across the entire landscape affected 

by biomass harvests. A recent formulation of the biomass carbon 

neutrality argument focuses on the forested landscape across 

the entire wood supply zone for a biomass plant—as opposed 

to individual harvested stands—and suggests that as long as 

landscape-scale forest growth is in excess of harvests, then biomass 

is embedded in the natural carbon cycle of the forests and is 

causing no net increase in GHG emissions (Miner, 2010). In our 

view, however, this landscape approach to carbon neutrality is 

incomplete because it does not fully frame the issue with respect 

to the carbon sequestration attributes of the forested landscape in 

a “business as usual” scenario. In general, the carbon accounting 

model should be premised on some knowledge of how lands 

will be managed in the future absent biomass harvests, and this 

becomes a critical reference point for analyzing whether burning 

biomass for energy results in increased or decreased cumulative 

GHG emissions over time.

Consequently, appropriate characterization of the BAU baseline 

is essential to the development of an accurate carbon accounting 

model of forest biomass combustion. In the case of the landscape 

argument for carbon neutrality, the conclusion that biomass 

burning has no net impact on GHG emissions does not account for 

the fact that in the absence of biomass harvests, the forests would 

likely have continued to sequester carbon anyway.7 Therefore, a 

well-framed landscape analysis needs to consider the net carbon 

emissions of biomass burning relative to the BAU scenario of 

continued carbon accumulation by forests across the landscape. 

Framing the problem this way does not necessarily negate the 

landscape carbon neutrality argument—it simply recognizes 

that the landscape level carbon accounting problem is a more 

complicated one. However, when a complete representation of 

the baseline is taken into account, the landscape-scale and the 

7 This assumes that additional biomass stumpage revenues will 

not dramatically alter the acreage devoted to commercial forestry 

activities. We believe this is a reasonable assumption given the 

current low prices for biomass stumpage. At $1 to $2 per green ton, 

few, if any, landowners would see enough change in revenue from 

biomass sales to alter their decisions about whether to keep forest 

land or sell it to someone who is looking to change the land use 

(e.g., a developer). As a result, we do not address the carbon issues 

associated with conversion of natural forests to energy plantations. 

We also do not address “leakage” issues that might arise if productive 

agricultural land is converted to energy plantations and this leads to 

clearing forests somewhere else to create new cropland.

To see why carbon debt is an important driver of impacts, consider 

the hypothetical case where a biomass fuel’s lifecycle CO2e emissions from electricity production are one gram less per megawatthour (MWh) than that of coal (i.e., the carbon debt is negative). 

All else equal, one would prefer biomass from a GHG perspective 

since the emissions are initially lower per unit of energy, and this 

is the case even if one ignores that fact that cumulative net carbon 

flux to the atmosphere will fall further in the future as carbon 

is resequestered in regenerating forests. In the example, biomass 

would not be immediately carbon neutral, but would still have 

lower emissions than coal and would begin to accumulate carbon 

dividends immediately.

From an atmospheric GHG perspective, the policy question 

only becomes problematic when CO2e emissions from biomass 

are above that of the fossil fuel alternative (i.e., where the carbon 

debts for biomass are positive). Because wood biomass emissions 

are typically higher than coal, oil and natural gas at large-scale 

electric, thermal or CHP facilities, this is in fact the decision 

policymakers face. 

Framing the problem this way shifts the focus away from total 

emissions, allowing the net carbon flux problem to be viewed in 

purely incremental terms. In our forest carbon accounting approach, 

the question then becomes how rapidly must the forest carbon sequestration rate increase after a biomass harvest in order to pay back the 

biomass carbon debt and how large are the carbon dividends that 

accumulate after the debt is recovered? The debt must be paid off 

before atmospheric GHG levels fall below what they would have 

been under a fossil fuel scenario. After that point, biomass energy 

is yielding net GHG benefits relative to the fossil fuel scenario. 

In this framework, the net flux of GHGs over time depends critically on the extent to which the biomass harvest changes the rate 

of biomass accumulation on the post-harvest stand. If the rate of 

total stand carbon accumulation, summed across all the relevant 

carbon pools increases very slowly, the biomass carbon debt may 

not be paid back for many years or even decades, delaying the 

time when carbon dividends begin to accumulate. Alternatively, 

for some stands, and especially for slow-growing older stands, 

harvesting would be expected to increase the carbon accumulation rate (at least after the site recovers from the initial effects of 

the harvest) and lead to relatively more rapid increases in carbon 

dividends. Determining the time path for paying off the carbon 

debts and accumulating carbon dividends is a principle focus of 

our modeling approach.

In this context, it is also important to note that the point at 

which the cumulative carbon flux from biomass just equals the 

cumulative flux from fossil fuels (the point at which the biomass 

carbon debt is paid off) is not necessarily the point at which a 

policymaker is indifferent between the biomass and fossil fuel 

scenarios. For example, the policymaker might only be indifferent at the time when the discounted damages resulting from 

the excess biomass emissions just equals zero—this is the point in 

time at which early damages due to increased GHG levels from 

biomass are just offset by lower biomass damages in later years 
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Biomass Sustainability and Carbon Policy Study

this case by 5 tonnes. The result makes clear that when the BAU 

baseline is correctly specified, the net change in GHG from 

biomass is equivalent to the biomass carbon debt, and therefore 

that carbon neutrality is not achieved immediately. 

Introducing the assumption that additional stands are harvested 

in subsequent years to provide fuel for a biomass plant—while 

adding greater complexity to the analysis—does not alter the basic 

conclusions as long as stands are harvested randomly (e.g., stands 

with rapid carbon recovery rates are no more or less likely to be 

harvested than stands with slower carbon recovery). For each 

additional year of harvests, a carbon debt is incurred and these 

are additive over time. Similarly, the period required to pay off the 

debt is extended one year into the future for each additional year 

of harvests. Finally, the longer-term dividends are also additive 

and will accumulate over time as greater quantities of fossil fuel 

emissions are offset by forest growth. 

The one area where landscape scale analysis might alter conclusions about carbon debts and dividends is a situation where the 

stands with more rapid carbon recovery profiles can be scheduled 

for harvest sooner than the slower recovery stands. This has the 

potential to accelerate the time to debt payoff and the onset of the 

carbon dividends. To implement such an approach, one would 

need to be able to identify the characteristics of the rapid carbon 

recovery stands and be able to influence the scheduling of harvests 

across the landscape. Detailed analysis to clearly identify rapid 

recovery stands is beyond the scope of the analysis in this report. 

Nonetheless, we would like to note that, while harvest scheduling 

may be possible for large industrial forest ownerships, it would 

be difficult to accomplish across a landscape like Massachusetts 

that is fragmented into many small ownerships. For this report, 

we have confined our focus to stand level analyses, which should 

provide useful indicators of the timing and magnitude of carbon 

debts and dividends in Massachusetts.

6.2 Technology Scenarios and 

Modeling Assumptions

6.2.1 Overview of Technologies and 

Approach

To illustrate the relative carbon life-cycle impacts associated with 

various energy scenarios, we compare the emission profiles for a 

representative set of biomass energy generation facilities relative 

to their appropriate fossil fuel baselines. Our analysis considers 

the following technologies:

• Utility-Scale Electric: A utility-scale biomass electric plant 

(50 MW) compared to a large electric power plant burning 

coal or natural gas.

• Thermal Chips: A thermal generation facility relying on 

green biomass chips relative to a comparable facility burning 

fuel oil (#2 or #6) or natural gas.

stand-level frameworks may yield the same result. The following 

simplified numerical example provides an illustration of why 

this is the case.

The example assumes an integrated energy/forest system made 

up of three carbon pools—the forest, atmosphere, and fossil 

fuel pools—each initially containing 1000 tonnes of carbon. In 

addition, we assume burning biomass releases 50 percent more 

emissions than burning fossil fuels for an equivalent level of 

energy production—close to the estimate of carbon debts when 

comparing biomass and coal-fired electricity generation. Finally, 

we specify that an average forest’s total stand carbon across the 

above- and below-ground carbon pools increases by 5% per year, 

or 50 tonnes in our example. 

In year one of a coal-fired electric scenario, we assume energy 

production at a level that transfers 10 units of carbon from the 

fossil fuel pool to the atmosphere. In the same year, the forest 

removes 50 tonnes of carbon from the atmosphere. The net values 

for each pool after one year are: 

• Fossil Fuel Carbon Pool: 990 tonnes (1000 tonnes–10 

tonnes released from energy production)

• Forest Carbon Pool: 1050 tonnes (1000 tonnes + 50 tonnes 

forest sequestration)

• Atmospheric Carbon Pool: 960 tonnes (1000 tonnes+ 10 

tonnes emissions–50 tonnes forest sequestration).

Alternatively, we consider a change in energy production that 

replaces fossil fuel with biomass, in this case releasing 15 tonnes 

of carbon versus 10 tonnes in the equivalent energy fossil scenario. 

We also assume that cutting the forest does not reduce total carbon 

sequestration (i.e., that the harvested areas of the forest still add 

carbon at the 5 percent rate).8 At the end of the first year, the 

carbon pools are as follows:

• Fossil Fuel Carbon Pool: 1000 tonnes (no change)

• Forest Carbon Pool: 1035 tonnes (1000 tonnes–15 tonnes 

biomass + 50 tonnes forest sequestration)

• Atmospheric Carbon Pool: 965 tonnes (1000 tonnes + 15 

tonnes emissions–50 tonnes forest sequestration).

In the example, it is true that forest growth across the landscape 

exceeds the amount of biomass harvested (50 tonnes of new 

sequestration versus 15 tonnes of biomass removals)—the condition under which advocates of landscape-level carbon neutrality 

would argue that biomass burning is embedded in a natural 

cycle in which forest sequestration (50 t-C/y) exceeds removals 

for biomass (15 t-C/y). But it is also true that the initial effect of 

switching to biomass is to increase atmospheric carbon levels, in 

8 This is likely a conservative scenario for the first year after harvest 

when the stand is recovering from the impacts of the cut. Assuming 

a lower than 5% rate of carbon growth on these acres would lower the 

overall average across the landscape to below 5%; the assumptions 

made above therefore may overstate the amount of carbon in the 

forest pool and understate the carbon in the atmosphere.
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Biomass Sustainability and Carbon Policy Study

removes approximately 32% of the above-ground live biomass, and 

a lighter BAU that removes 20%. The heavier BAU is intended to 

represent the case where the landowners who decide to harvest 

biomass are the ones who cut more heavily in the BAU. The 

lighter harvest BAU represents a scenario where the distribution 

of landowners harvesting biomass is spread more evenly across 

the full range of landowners who currently harvest timber, as 

specified in the Massachusetts Forest Cutting Plan data discussed 

in Chapter 3. We assume in the BAU that all logging residues 

are left in the forest.

Using the FVS model, described in Chapter 5, we quantify changes 

in total stand carbon by decade through an evaluation of carbon 

in the above- and below-ground live and dead carbon pools for the 

following six biomass harvest scenarios. Carbon recovery profiles 

represent averages for a set of 88 plots in the Massachusetts FIA 

database with an initial volume of more than 25 tonnes of carbon 

per acre in the above-ground live pool.

Exhibit 6-3: BAU and Biomass Harvest Scenarios

Harvest 

Category Description

Carbon 

Removed 

(tonnes)

AboveGround 

Live 

Carbon 

Harvested 

(%)

Logging 

Resi- dues 

Left 

On-Site 

(%)

BAU 20% Lighter BAU 

removal

6.3 20 100

BAU 32% Heavier BAU 

removal

10.2 32 100

Biomass BA60 Moderate 

biomass removal: 

BAU & Biomass 

removal down to 

60 ft2 of stand 

basal area

19.3 60 35

Biomass 40% Lighter biomass 

removal: BAU 

plus biomass 

removal equals 

40% stand 

carbon

12.0 38 35

Biomass BA40 Heavier biomass 

removal: BAU & 

Biomass removal 

down to 40 ft2 of 

stand basal area

24.3 76 35

The results of the FVS analysis provide profiles of total stand 

carbon and above-ground live carbon over time for the BAU and 

biomass harvest scenarios. These are graphed on the next page in 

Exhibits 6-4 and 6-5.

• Thermal Pellets: A thermal generation facility relying on 

wood pellets relative to a comparable facility burning fuel 

oil or natural gas.

• CHP: A combined heat and power (CHP) facility compared 

to a similar facility burning oil or natural gas.

We selected these scenarios to illustrate the range of likely woodbased bioenergy futures that we judge to be feasible in the short- to 

mid-term in Massachusetts. This choice of technologies reflects 

differences in scale, efficiency and fuel choice. The emission 

profiles of more advanced technologies—such as cellulosic ethanol 

production and biomass pyrolysis—are not modeled based on 

lack of commercial demonstrations, scale requirements that make 

development in Massachusetts unlikely, or because of a lack of 

available GHG emissions data.

As detailed in our conceptual framework, each scenario is made 

up of two primary components: a stand-level forest carbon model 

and an energy facility GHG emissions model. In the fossil fuel 

scenarios, we assume the stand is harvested for timber but not 

for biomass. We then track the total amount of C in the stand’s 

various carbon pools—including above- and below-ground live 

and dead wood—over a 90-year time frame. For the biomass 

scenarios, consistent with the supply analysis discussed in Chapter 

3, we assume a heavier harvest that removes additional material 

in the form of logging residues and low-quality trees. For each 

scenario, we then model the change in total stand carbon over 

the same 90-year time frame in order to provide comparisons of 

net changes in total stand-level carbon relative to the baseline 

“no biomass” scenario. The energy facility emissions model is 

designed to take into account both the direct stack emissions 

of energy generation as well as the indirect emissions that come 

from producing, processing and transporting fuels to the facility. 

These are expressed as (1) biomass carbon debts, which denote 

the incremental percentage of carbon emissions due to harvesting 

and combusting wood relative to the lifecycle GHG emissions 

of the alternative fossil fuel, and (2) biomass carbon dividends 

which are the longer term benefits from reducing GHGs below 

fossil baseline levels. For each scenario, the combined forest and 

energy carbon models provide an appropriate accounting for the 

emissions from energy production and the carbon sequestration 

behavior of a forest stand that has been harvested (1) only for 

timber or (2) for both timber and biomass. 

The details of the forest harvest scenarios are described below, 

followed by a discussion of the GHG modeling process for energy 

facilities.

6.2.2 Forest Harvest Scenarios

We take the individual stand as the basis for our carbon accounting 

process. For the fossil fuel baseline scenarios, we assume a “business as usual” forest management approach where the stand is 

harvested for timber but not for biomass. The model provides a 

dynamic baseline for comparisons with the biomass alternative. 

The scenarios are summarized in Exhibit 6-3 below and include 

two alternative BAU specifications, one a relatively heavy cut that 
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Exhibit 6-4: Total Stand Carbon

Exhibit 6-5:Above-Ground Live Stand Carbon
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Emissions from Biomass Harvest, Processing and Transportation: For the biomass technologies, we include estimates 

of the CO2e releases associated with harvesting, processing and 

transporting the biomass fuel to a bioenergy facility. For green 

chips (delivered to a large-scale electric, thermal or pellet facility), 

the estimates are based on releases of CO2 associated with diesel 

fuel consumption in each of these processes. We estimated harvest 

and chipping costs using the U.S. Forest Service’s Fuel Reduction 

Cost Simulator (also used to estimate harvesting costs for the wood 

supply analysis and described in Chapter 3). We assumed chips 

were transported 100−120 miles (round-trip) to the combustion 

facility, using trucks carrying 25−30 green tonnes with an average 

fuel efficiency of 5 mpg. Our results were verified for consistency 

with other relevant studies including: CORRIM (2004); Department of Forest Resources, University of Minnesota (2008); Finkral 

and Evans (2008); and Katers and Kaurich (2006).

Indirect CO2e emissions make a very small contribution to the 

overall life-cycle emissions from biomass energy production, 

generally on the order of 2%. A simple way to understand this 

is as follows. Diesel consumption in harvesting and processing 

forest biomass is typically less than one gallon (we have calculated an average of 0.75 gallons per green ton based on the 

sources described above). Diesel consumption in transport is 

also assumed to be less than one gallon (we have calculated 

0.85 gallons per green ton). The combustion of a gallon of 

diesel releases 22 pounds of CO2, while the combustion of a 

ton of green wood (45% moisture) releases one ton of CO2 9; 

thus, CO2 emissions per gallon of diesel are equivalent to about 

1% of stack emissions. The amount of carbon dioxide released 

per MWh or per MMBtu will of course depend on the green 

tonnes of wood required, but the ratio between indirect CO2e 

emissions and combustion emissions will remain the same.

Lifecycle Emissions from Utility-Scale Electric: For these 

facilities, all emissions are initially calculated as CO2e /MWh of 

electrical output, and then expressed as C/MWh. The biomass 

estimate is based on analysis of electricity generation and wood 

consumption from a set of power plants in this region with efficiencies in the 20% to 25% range. These data have been compiled 

from a combination of information from company websites and 

financial reports. On average, these plants release about 1.46 

tonnes of CO2 (399 kg of C) per MWh. When combined with 

the indirect emissions discussed above, lifecycle CO2e for biomass 

plants total approximately 1.49 tonnes per MWh (or 406 kg of C). 

The comparable data for natural gas and coal have been developed 

by NREL (Spath and Mann, 2000 and Spath et al., 1999) and 

include the full lifecycle CO2e emissions. On a per MWh basis, 

9 A bone-dry ton of wood is assumed to be 50% carbon. A green 

ton of wood with 45% moisture weighs 1.82 tons. Thus, the 

ratio of green wood (45% moisture) to its carbon content is 3.64 

(or 1.82 / 0.5). This is essentially the same as the ratio of a ton of 

carbon dioxide to its carbon content (3.67, equal to the ratio of the 

molecular weight of CO2 to C, or 44/12). So, the combustion of 

one green ton of wood releases one ton of CO2.

Due to model constraints, the FVS analyses rely on “thin-fromabove” harvest strategies to simulate both BAU and biomass 

harvests, although we conducted some limited analysis of the 

sensitivity of the results to alternative assumptions. For all the 

biomass harvests, we assume 65% of the logging residues are 

removed from the forest, with the remainder left on the ground. 

The results were analyzed to determine how the stands harvested 

for biomass responded relative to their response in the BAU 

scenario. This analysis is designed to show relative rates of recovery 

of forest carbon stocks following biomass harvests. 

6.2.3 Biomass and Fossil Fuel GHG Emissions 

To estimate biomass carbon debts relative to fossil fuel technologies, we assembled estimates of GHG emissions per unit of energy 

produced by each technology. These estimates included both the 

direct combustion emissions as well as the indirect emissions 

related to feedstock production, processing and transportation. 

To the extent that data were available, we work in CO2 equivalents (CO2e), a metric that considers other greenhouse gases (e.g., 

methane from coal mines) and expresses them in terms of the 

amount of CO2 that would have an equivalent global warming 

effect. The emissions estimates for both the biomass and fossil 

fuel technologies are shown below in Exhibit 6-6, where they have 

been converted to kilograms of carbon per energy unit.

Exhibit 6-6: Carbon Emission Factors by Technology*

Kilograms per Unit of Energy**

Scenarios Biomass Coal Oil 

(#6)

Oil 

(#2)

Natural 

Gas

 Utility-Scale Electric Kilograms/MWh

 Fuel Prod & Transport 7 9 34

 Fuel Combustion 399 270 102

 Total 406 279 136

 Thermal Kilograms/MMBtu

 Fuel Prod & Transport 1 6 6 6

 Fuel Combustion 35 27 25 17

 Total 36 33 31 23

 CHP Kilograms/MMBtu

 Fuel Prod & Transport 1 7 6 6

 Fuel Combustion 35 29 27 18

 Total 36 35 33 24

* As discussed below, emissions factors for pellets are characterized relative 

to the thermal technology using green chips which is shown in this table.

** Sources and calculations for these data are described in the text.
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2006) suggest that the increased efficiencies in boiler combustion 

achieved with pellets approximately offsets most of the increased 

emissions from plant operations and additional transport of pellets 

from the plant to their final destination.

Lifecycle Emissions from CHP Facilities: Emissions for CHP 

facilities are also expressed on the basis of MMBtu of heat output, 

in which electrical energy is converted to a Btu equivalent. The 

analysis of these operations depends critically on the mix of thermal 

and electrical output in the plant design. In general, thermal-led 

facilities tend to relative emissions profiles that are similar to their 

thermal counterparts, while electric-led facilities more closely 

resemble the emissions profiles of electric power plants. While 

some variations can result from the scale of facilities, the specifics 

of the design, and the type of heat recovery systems employed, 

the utility-scale electric and dedicated thermal technologies 

provide approximate bounds for the wide range of possibilities 

for CHP facilities.

Carbon Debt Summary: Exhibit 6-7 below summarizes the 

carbon debts for biomass relative to each technology and fuel. 

These are expressed as the percentage of total biomass-related 

emissions accounted for by the incremental GHG releases from 

biomass relative to a specific fossil fuel and technology combination. For example, using the data from Exhibit 6-6, we calculate 

the 31% for coal electric as ((406–279)/406)*100.

Exhibit 6-7: Carbon Debt Summary Table*

(Excess Biomass Emissions as % of Total Biomass Emissions)

Scenarios Coal Oil (#6) Oil (#2) Natural 

Gas

Electric 31% 66%

Thermal 8% 15% 37%

CHP 2% 9% 33%

* See text for pellet applications.

It is clear from this table that carbon debt depends on both the 

choice of fuel (and hence its heating value) and the choice of 

technology. Carbon debt for biomass compared to natural gas 

in electric power is much higher than the carbon debt in the 

thermal scenario. These differences are attributable to the relative efficiencies of the technologies in each scenario—natural 

gas electric power has a large advantage in this case due to the 

assumed use of combined-cycle technology.

Carbon debts for CHP raise another important issue when 

comparing biomass fuel with other technological alternatives. 

While comparisons of biomass CHP and CHP using oil or 

natural gas may be straightforward, there are no data on how 

much fossil-fuel based CHP capacity is now operating in Massachusetts and could potentially be a candidate for replacement. 

Nevertheless, this comparison may still be useful in assessing the 

relative carbon merits of constructing a new biomass CHP plant 

or a new fossil fuel-fired CHP plant. On the other hand, it is 

interesting to note that if biomass CHP facilities were developed, 

lifecycle CO2e emissions for a large (505 MW) combined-cycle 

natural gas power plant are approximately 0.5 tonnes (136 kg of 

C) per MWh, of which 75 percent results from the combustion 

facility itself and 25 percent is from gas production and transportation. The comparable lifecycle estimate for a large coal generating 

station is approximately 1.0 tonne (279 kg of C) per MWh, with 

97 percent of the emissions attributable to the generating station 

emissions and the remainder to mining and transportation of the 

coal. The natural gas plant was assumed to be very efficient at 48% 

due to the combined-cycle technology, while the coal plant was 

closer to average efficiency at 32%. These plants were selected to 

bracket the range of emissions of fossil fuel plants relative to their 

biomass electric counterparts. 

We note that co-firing of biomass with coal represents another 

technology variant for electric utilities. The emissions characteristics of co-firing biomass with coal are expected to similar to those 

from a stand-alone utility scale biomass electricity plant since the 

biomass combustion efficiency will be similar in both types of 

operations. As long as this is the case, the results for utility-scale 

biomass electricity are indicative of the emissions characteristics 

of biomass emissions at electricity plants using co-firing. 

Lifecycle Emissions from Thermal Facilities: All emissions 

for these facilities are expressed as C/MMBtu of thermal output. 

Biomass is based on a typical thermal plant with 50 MMBtu’s 

per hour of capacity and 75% efficiency, which has heat input of 

120,000 MMBtu/yr (see Chapter 2 for a more detailed description of this pathway and technology). Assuming the gross heating 

value of oven-dry wood to be 8,500 Btu’s/lb, the total lifecycle 

estimate for carbon emissions is 36 kg/MMBtu.

Emissions data for heating oil and natural gas thermal plants 

were developed assuming that the typical capacity of the plants 

was also 50 MMBTH (these technologies and pathways are 

described in Chapter 2). The oil facilities were assumed to run at 

80% efficiency, while the natural gas plants were assumed to be 

more efficient at 85%. We consider oil facilities that use distillate 

fuel oil (#2 or #4) and residual fuel oil (#6). The majority of the 

commercial and industrial facilities in Massachusetts use distillate 

oil (about 70%), but it is possible that wood biomass may compete 

more directly with plants burning residual fuel oil. For natural 

gas, indirect emissions were calculated using the same percentages 

available in the NREL analysis of electric power plants. Indirect 

emissions from oil are based on estimates from the National 

Energy Technology Laboratory (Gerdes, 2009). Lifecycle carbon 

emissions were calculated to be 33 kg/MMBtu for #6 fuel oil, 

31 kg/MMBtu for #2 fuel oil, and 23 kg/MMBtu for natural 

gas. Because of the differences in relative combustion efficiencies, 

the gap between biomass and fossil fuel technologies for thermal 

facilities is smaller than the gap for utility-scaled electric facilities.

Lifecycle Emissions from Pellet Applications: Emissions for 

thermal pellet applications require the addition of emissions from 

plant operations and for transport and distribution of pellets 

from the plant to the final consumer. The limited analysis that we 

have seen for these operations (for example, Katers and Kaurich, 
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increased demand for forest biomass may introduce substantial 

uncertainty in the projections of forest carbon recovery rates. 

Third, modeling the carbon dynamics of forest stands is complex, 

and although our analysis provides indications of broad general 

trends, these are subject to considerable uncertainty about standlevel changes in carbon pools. 

In the remainder of this chapter, the presentation of results in 

organized around three principal topics:

• How do choices about biomass technology and assumptions 

about the fossil fuel it will replace affect carbon recovery times?

• How do forest management choices with respect to harvest 

intensity and silvicultural practice interact with the biophysical properties of forests to determine carbon recovery profiles?

• What are the carbon dividend levels associated with the 

various biomass energy scenarios?

To answer these questions, we first present data from our modeling 

of the various energy/forest scenarios. We then summarize our 

overall conclusions and discuss some considerations regarding 

how our results are most appropriately interpreted and used in 

energy and environmental policymaking processes. 

6.3.2 Energy Technology and Carbon Debt 

Recovery

A key insight from our research is the wide variability in the magnitude of carbon debts across different biomass technologies. This results 

from the way specific lifecycle GHG characteristics of a bioenergy 

technology combine with the GHG characteristics of the fossil 

fuel energy plant it replaces to determine carbon debts. As shown 

in Exhibit 6-7, carbon debts for situations where biomass thermal 

replaces oil-fired thermal capacity can be as low as 8%, whereas the 

debt when biomass replaces combined-cycle natural gas in large-scale 

electricity generation can range as high as 66%. 

Exhibit 6-8 illustrates how debt payoff varies with technology, with 

detailed supporting numbers included in the table in Exhibit 6-9. The 

scenario represented in this exhibit is one that assumes a relatively 

heavy BAU harvest of timber—32% removal of above-ground live 

carbon using a diameter limit partial harvest—and a biomass harvest 

that extends the diameter limit approach to removal of all trees down 

to a residual basal area of 60 ft2 per acre. Exhibit 6-8(a) illustrates the 

FVS model results for total stand carbon in stands harvested only 

for timber (BAU) and for the same stands where the BAU harvest 

is augmented by the additional removals of biomass including the 

harvest of 65% of all tops and limbs. Exhibit 6-8(b) captures the 

relative differences in growth between the two stands, indicating an 

initial harvest of 38 green tons of biomass.11 For these scenarios, 

11 This relative difference in growth is derived by subtracting the 

BAU recovery curve from the biomass harvest recovery curve in 

Exhibit 6-8(a) In this case, the relationship in Exhibit 6-8(b) can 

be interpreted as the incremental growth in the stand harvested for 

biomass relative to growth of the BAU stand. Only through this 

incremental growth will carbon debts be recovered.

it is likely that they would replace a mix of independent thermal 

and electric applications. Since a large amount of heat is wasted 

in producing stand-alone electricity, these comparisons may show 

biomass CHP with no carbon debt at the outset. For example, 

if thermal-led biomass CHP at a commercial location replaces 

a current mix of heat from oil and power from coal, then total 

carbon emissions generated at the new site are likely to decline 

relative to the fossil scenario as long as a significant percentage of 

the waste heat is utilized. In contrast, if natural gas is consumed 

in the current energy mix, the situation may be reversed.

6.3 Forest Biomass Carbon

Accounting Results

6.3.1 Introduction

As discussed in the conceptual framework section, our carbon 

accounting analysis for biomass focuses on biomass carbon 

debt, biomass carbon dividends and the number of years until 

debts are paid off and dividends begin accumulating. These are 

a function of the bioenergy technology as well as the biophysical 

characteristics of the forest and management practices used. The 

transition from debt to dividend occurs at the point when the 

atmospheric carbon level resulting from the lifecycle biomass 

emissions falls to the point where it just equals the level resulting 

from lifecycle fossil fuel emissions.10

To examine the carbon debts, dividends and the timing of the transition from one to the other, we analyzed a wide array of integrated 

energy technology/forest management scenarios. These consider 

the impacts of potential differences in (1) energy technology and 

efficiency and (2) the biophysical characteristics of the forest and 

assumptions about the intensity and type of silvicultural approach 

used for harvests in both the BAU and biomass scenarios.

Our analysis approaches the problem by establishing integrated 

technology and forest scenarios that we find to be representative of average or typical conditions and management practices. 

Energy technologies are characterized in terms of typical lifecycle 

carbon emissions. Representative forest carbon recovery paths are 

estimated using FVS model simulations averaged across 88 actual 

forest stands that are included in the U.S. Forest Service’s system 

of FIA sampling plots in Massachusetts. Overall these analyses 

provide guidance on the range of average forest carbon recovery 

times for each technology. It is important to note, however, that 

care should be exercised when translating these average results 

into policy. Our concern is primarily the result of three factors. 

First, energy technologies are continually evolving and the characteristics of any specific project proposal could differ from the 

typical existing configurations that we have analyzed. Second, our 

lack of knowledge of how stands will be harvested in response to 

10 Offsetting of earlier damages from higher biomass GHG levels 

would require additional years of lower GHG levels (or dividends) in 

the biomass scenario. Full carbon neutrality would not be achieved 

until the point at which the entire release of carbon from burning 

biomass has been resequestered in the forest carbon pools. 
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Exhibit 6-8(b): Carbon Recovery Rates under Scenario 1 

(tonnes carbon)

The carbon debt recovery periods are also plotted in Exhibit 

6-8(b) for biomass replacement of coal and natural gas electricity 

generation. The results make clear that technologies with higher 

carbon debts have longer payoff times, indicative of carbon dividends that do not appear until further in the future. Technology 

scenarios with shorter payoff times have lower GHG impacts 

than scenarios with higher carbon debts. In general, the analysis 

indicates that thermal carbon debts can be substantially lower 

than debts from large-scale electricity generation. 

Our analyses also considered the carbon debt characteristics of 

wood pellet technology and CHP systems. In general, we find that 

carbon debts associated with burning pellets in thermal applications do not differ significantly from debts resulting from use of 

green wood chips. The differences relate primarily to location of 

GHG emissions associated with water evaporation from green 

wood rather than the overall magnitude of the lifecycle GHG 

emissions. For CHP, carbon debts generally fall somewhere 

between those of thermal and large-scale electric, depending 

upon whether the CHP plant is designed to optimize thermal 

or electric output; however, in our cases, initial carbon debts are 

shown to be lower than thermal because all waste heat is fully 

utilized and some reductions in the gross efficiency of oil and gas 

are recognized due to higher electrical efficiencies.

The technology scenario rankings described above generally hold 

true as long as the forest management and silvicultural practices are 

the same for the various energy generation technologies (however, 

as demonstrated below in Section 6.3.3.4, this may not be the case 

if harvesting methods preclude the removal and use of tops and 

limbs). Within this general hierarchy, however, the absolute and 

relative timing of carbon recovery for the different technologies 

will vary depending on the specific harvesting assumptions and 

results from the forest modeling process (discussed in detail in 

Section 6.3.3 below). 

In interpreting the technology/carbon debt results, it is important 

to recognize that the carbon debts discussed above are based on 

average levels of GHG emissions per unit of energy for typical 

the graph shows that post-harvest biomass stands sequester carbon 

more rapidly than BAU stands harvested only for timber. In this 

scenario, the biomass harvest removed an additional 9.1 tonnes 

of above-ground live carbon from the stand (and resulted in the 

loss of another 0.5 tonnes of below ground carbon). After one 

decade of growth, the total carbon in the biomass stand has 

increased by approximately 1.1 tonnes compared to the BAU 

stand and continues to increase to a cumulative total 6.2 tonnes 

of carbon after 90 years. At this point in time, the biomass stand 

has recovered approximately 65% of the carbon removed from 

the stand and used for biomass energy generation (6.2 tonnes 

versus 9.6 tonnes harvested). 

Exhibit 6-8(a): Forest TSC Sequestration Rates under 

Scenario 1 (tonnes carbon)

Exhibit 6-8(b) also indicates the time required on average for 

the stands to recover the carbon debt for various technologies. 

Oil-fired thermal facilities are represented by the horizontal line 

indicating that for the equivalent level of energy production 

they emitted about 12% less carbon than a thermal biomass 

plant when full lifecycle carbon emissions are taken into 

account.12 The intersection of the thermal-oil emissions line 

and the forest carbon recovery curve identifies the year in which 

the carbon debt is fully recovered in this scenario—about 

10 years for replacement of oil-fired thermal capacity with 

biomass. At that time, the net atmospheric levels of GHGs are 

equivalent for the biomass and fossil fuel technologies. Prior 

to that point, biomass resulted in higher GHG levels, but in 

later years biomass GHG levels are lower than those for fossil 

fuels because the forest continues to remove relatively greater 

amounts of the carbon than the stand in the BAU scenario. 

These are the benefits we characterize as carbon dividends.

12 This represents an average of residual fuel oil (#6) and distillate 

fuel oil (#2).
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and 6 tonnes of carbon per acre (approximately 20 to 25 green 

tons). Using FVS, we modeled this baseline through a removal 

of 20% of above-ground live stand carbon using a “thin from 

above” silvicultural prescription. 

We also analyzed an alternative baseline in which we assume a 

significantly heavier BAU harvest, one that removes approximately 

32% of the above-ground live carbon. We include this BAU to 

account for uncertainty regarding which landowners will be more 

likely to harvest biomass. This scenario would be consistent with 

the assumption that landowners who have harvests that are heavier 

than statewide averages would be more likely to harvest biomass. 

We then created three biomass harvest options, designed to model 

light, medium and heavy biomass cuts, all of which include the 

removal of 65% of all tops and limbs. These were combined with 

the two BAUs to generate six scenarios representing the impact of 

different management and harvest assumptions on the timing of 

the transition from carbon debt to carbon dividends. The results for 

the six scenarios are summarized in the table included as Exhibit 

6-9 (next page). For each scenario, the table shows the quantity of 

carbon removed in the biomass harvest (i.e., the carbon removal 

incremental to the harvest in the timber only BAU) and statistics 

on the recovery by decade of this carbon through growth of the 

stand. For each scenario, the first row provides the difference in 

tonnes of total stand carbon between the BAU stand and the 

biomass stand in years 10 through 90. The second row indicates 

the tonnes of carbon recovered by the biomass stand relative to 

the BAU. The third row presents the cumulative percentage of 

the original biomass carbon recovered by decade.14 

6.3.3.1 Impacts of Alternative BAUs

The results graphed in Exhibit 6-10 demonstrate that carbon 

recovery times are somewhat, but not highly, sensitive to assumptions about the volume of timber removed in the BAU harvest. 

The graph shows carbon recovery curves for Scenarios 1 and 5, the 

light and heavy BAU harvests, followed by a medium-intensity 

biomass cut, in this case removal via a diameter limit cut of biomass 

down to a residual stand basal area of 60 ft2. The results indicate 

that the heavier BAU results in a somewhat, but not dramatically, 

more rapid recovery of carbon in the stand following the biomass 

harvest. Carbon debts resulting from biomass replacement of coalfired electricity capacity would take about 20 years in the heavy 

BAU case, and about 25 years in the light BAU scenario. After 

these points in time, carbon dividends begin to accrue because 

atmospheric GHG levels are below those that would have resulted 

had an equivalent amount of energy been generated using fossil fuel. 

14 For example, in Scenario 1, in year 1 the harvest resulted in an 

initial loss of 9.6 tonnes of total stand carbon (of which 9.1 tonnes 

is above-ground live carbon). By year 10, the difference in total 

stand carbon has narrowed to 8.5 tonnes, the relative differences in 

stand carbon accumulation between the two stands. In this case the 

biomass stand accumulated an additional 1.1 tonnes of carbon more 

than the BAU stand (9.6 tonnes minus 8.5 tonnes). This represents 

recovery of 11.1% of the original carbon removed in the biomass 

harvest (1.1/9.6).

energy generation systems readily available today.13 Biomass 

energy technology, however, is evolving and there are technologies that have yet to be commercialized in the U.S. that are more 

efficient and thus produce less GHG emissions per unit of useable 

energy—for example the biomass CHP gasification technologies discussed in Chapter 2. Bioenergy proposals based on new 

technologies with lower carbon debts are feasible and have the 

potential to reduce GHG impacts and associated carbon debts. 

6.3.3 Forest Management and Carbon

Recovery

Within the broad context of biomass carbon debts and dividends 

for specific technologies, the timing of carbon recovery is a direct 

function of two factors related to forests and forest management—

(1) the biophysical characteristics of Massachusetts forests and (2) 

assumptions about the intensity and type of silvicultural approach 

used for harvests in both the BAU and biomass harvest scenarios.

As described in Chapter 5, we rely on FIA data for basic biophysical 

information about Massachusetts forests, and we evaluate carbon 

dynamics using the U.S. Forest Service FVS model. The FIA data 

are intended to provide a set of forest stands that is representative 

of the range of forest cover types, tree size distributions, species 

growth characteristics, and per-acre wood inventories across 

Massachusetts. For presentation and analysis purposes we generally 

characterize our results as carbon recovery rates averaged across 

the 88 stands in our FIA database that are at a stage in their 

development that makes them available for biomass harvests (i.e., 

stands with greater than 25 tonnes of carbon in the above-ground 

live carbon pool). This approach provides a reasonable basis for 

capturing the impact on carbon debt recovery of differences in 

the biophysical characteristics of the forests.

Assumptions about the nature of forest management in both the 

BAU and biomass harvest scenarios also have important impacts 

on the timing of the transition from carbon debt to carbon dividends. In order to analyze biomass harvest scenarios, we need 

to specify the BAU harvest level, the incremental amount of 

material removed in the biomass cut, the percentage of tops and 

limbs left on-site, and the silvicultural approaches used to harvest 

the material. For all scenarios, the biomass carbon calculations 

assume that in the absence of biomass demand, landowners will 

continue to manage their forests for timber and other wood 

products. To establish the BAU baseline, we define both the 

silvicultural practice used in harvesting the wood and the total 

quantity removed in the baseline harvest. Generally speaking, our 

knowledge of logging practices in the state suggests a relatively high 

probability that landowners would apply diameter limit, partial 

harvest approaches, removing the largest and best quality trees 

in the stand. Chapter 3 indicates that based on Forest Cutting 

Plan data, average harvests historically have removed between 4.5 

13 In the case of large-scale electricity generated by natural gas, the 

scenario here assumes a very efficient combined-cycle technology, 

and this provides a high-end estimate of carbon debts compared to 

biomass replacement at less efficient natural gas facilities.
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tonnes of biomass carbon is removed. In this example, both oilthermal and coal-electric debts are recovered in the first decade 

and natural gas electric debts are paid back in approximately 50 

years. As discussed in Section 6.3.3.4 below, the rapid recovery 

occurs because the small removal is comprised of a much greater 

proportion of logging residues that would have been left on the 

ground to decay in a BAU harvest. This relatively large magnitude 

of the decay losses in the BAU results in a rapid recovery of lost 

carbon in the biomass harvest. Such light harvest, however, would 

not necessarily produce the supplies forecast in Chapter 3 and 

may not be the economic choice of landowners.

As harvest intensity increases, however, recovery times become 

longer. Scenarios 1, 4 and 5, where biomass harvests range from 

5.7 to 13.0 tonnes of carbon, all have carbon recovery profiles 

that are longer than Scenario 2, although all three show steady 

progress in the recovery of carbon debts. In the three scenarios, 

oil-thermal debts are recovered roughly between years 10 and 20 

and coal-electric debts are recovered between years 20 and 30. For 

Scenarios 3 and 6, where the biomass removal is close to what would 

be considered a clearcut, the stand harvested for biomass actually 

loses carbon relative to the BAU stand in the first decade, creating 

a delay in carbon recovery that persists for many decades. This may 

be the result of complex interactions between regeneration and 

woody debris decay in the years immediately following harvest, 

although in the case of these more extreme harvests, we may be 

pushing the model to an extreme case where its results are simply 

less robust. Given the low likelihood that most biomass harvests 

will be in the form of clearcuts (see Chapter 3), we do not view 

the uncertainties in the Scenario 3 and 6 results as having great 

relevance to the overall patterns of carbon recovery.

Exhibit 6-10: Graph of Carbon Recovery Times for Scenarios 

1 and 5 (tonnes carbon)

6.3.3.2 Impacts of Alternative Biomass 

Harvest Intensities

Next we examined the impact of varying the intensity of the 

biomass harvest on carbon debt recovery. Exhibit 6-9 shows the 

impact of the light, medium and heavy biomass harvests when 

combined with the heavy harvest BAU and the comparable results 

when a lighter BAU harvest is assumed. 

The results suggest that for very light biomass harvests, the time 

required to pay off the carbon debt and begin accumulating 

dividends is relatively rapid. This is evident in Scenario 2—a 

heavy BAU coupled with a light biomass harvest—where only 3 

Exhibit 6-9: Graph of Carbon Recovery Times for Scenarios 1 and 5 (tonnes carbon)

Scenario BAU vs. Biomass Total Stand Carbon Difference by Year

Number Description Harvest 10 20 30 40 50 60 70 80 90

BAU32%-BioBA60 9.1 8.5 6.7 5.1 4.6 4.5 4.4 4.1 3.7 3.4

1 CumRecovered 1.1 2.9 4.5 5.0 5.1 5.2 5.5 5.9 6.2

%Recovery 11.1 30.2 47.1 52.5 53.1 54.5 57.2 61.6 64.8

BAU32%-Bio40% 1.8 2.1 1.7 1.3 1.1 0.9 0.7 0.6 0.5 0.4

2 CumRecovered 0.8 1.2 1.6 1.9 2.0 2.3 2.3 2.5 2.6

%Recovery 28.1 41.0 54.6 63.4 68.5 77.3 79.0 84.1 86.4

BAU32%-BioHHBA40 14.1 14.4 12.1 9.6 8.3 7.7 6.9 6.2 5.3 4.7

3 CumRecovered -0.4 2.0 4.4 5.7 6.4 7.1 7.8 8.8 9.3

%Recovery -2.6 14.0 31.2 41.0 45.4 50.5 55.5 62.5 66.7

BAU20%-Bio40% 5.7 5.7 4.9 4.0 3.2 2.6 2.0 1.7 1.4 1.2

4 CumRecovered 0.0 0.8 1.8 2.5 3.2 3.7 4.0 4.3 4.5

%Recovery 0.7 13.4 28.5 41.5 51.3 60.1 65.3 69.9 73.5

BAU20%-BioBA60 13.0 12.1 9.9 7.7 6.6 6.1 5.7 5.2 4.6 4.2

5 CumRecovered 0.7 3.0 5.1 6.2 6.7 7.1 7.6 8.2 8.6

%Recovery 5.6 23.0 39.9 48.2 52.1 55.4 59.5 63.8 67.4

BAU20%-BioHHBA40 18.0 17.9 15.2 12.3 10.3 9.3 8.3 7.3 6.2 5.5

6 CumRecovered -0.7 2.0 5.0 6.9 7.9 8.9 9.9 11.0 11.7

%Recovery -4.2 11.7 28.8 39.9 46.1 51.9 57.6 64.0 68.3
Manomet Center for Conservation Sciences 109 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

6.3.3.4 Impacts of Harvesting Methods and the 

Role of Tops and Limbs

The harvest and use of tops and limbs for biomass can have an 

important influence on carbon recovery times and profiles: tops 

and limbs decay quickly if left in the forest and so their use comes 

with little carbon “cost” which tends to shorten carbon recovery 

times. Conversely, if tops and limbs from a biomass harvest of 

cull trees were left in the woods to decay, this “unharvested” 

carbon would delay recovery times, effectively penalizing wood 

biomass relative to fossil fuels. Tops and limbs are available from 

two “sources” in our biomass harvest scenarios: (1) the material 

left behind following an industrial roundwood harvest in a BAU 

scenario and (2) tops and limbs from standing trees harvested 

specifically for bioenergy in the biomass harvest scenarios.

As discussed in the wood supply analysis in Chapter 3, the harvest 

of tops and limbs would likely be economical only when harvested 

with whole-tree systems. Biomass harvested in this manner can be 

used for any type of bioenergy technology. However, biomass can 

also be harvested with traditional methods or cut-to-length methods 

when these systems are preferred due to operating restrictions and/

or landowner preferences. These roundwood operations tend to be 

more costly, but yield higher-quality bole chips that are preferred 

by thermal, CHP and pellet facilities. Importantly, leaving tops 

and limbs behind as forest residues would increase carbon recovery 

times for bioenergy technologies that utilize the bole chips that 

are produced. The discussion that follows helps to demonstrate 

how the use of tops and limbs affects our carbon recovery results.

The carbon recovery times in the six scenarios presented in Exhibit 

6-9 are all based on the assumptions that 100% of tops and limbs 

are left in the forest in the BAU scenarios and 65% of all tops 

and limbs (from both the BAU and the incremental biomass 

harvest) are harvested in the biomass scenarios. These carbon 

recovery times (for the three BAU32 scenarios) are compared 

with the carbon recovery times when all tops and limbs are left 

in the forest in Exhibit 6-12.

6.3.3.3 Impacts of Alternative Silvicultural 

Prescriptions

The impact of different silvicultural prescriptions has been more 

difficult to evaluate using the FVS model. The present set of 

scenarios uses a thin-from-above strategy linked to residual stand 

carbon targets for all harvests. These types of harvests tend to open 

the canopy and promote more rapid regeneration and growth 

of residual trees. While this silvicultural approach may provide 

a reasonable representation of how a landowner who harvests 

stands heavily in a BAU is likely to conduct a biomass harvest, it 

is less likely that someone who cuts their land less heavily would 

continue to remove canopy trees for biomass (unless they had 

an unusual number of canopy cull trees remaining after the 

timber quality trees are removed). More likely in this case is that 

the landowners would harvest the BAU timber trees and then 

selectively remove poor quality and suppressed trees across all 

diameter classes down to about 8 inches. We hypothesized that 

this type of harvest would result in a slower recovery compared 

to thinning from above. Unfortunately, the complexity of this 

type of harvest was difficult to mimic with FVS. 

Although project resources were not adequate to manually simulate 

this type of harvest for all FIA stands, we did conduct a sensitivity 

analysis for two stands with average volumes. For each of these 

stands we simulated a BAU harvest removing 20% of the stand 

carbon, followed by removal of residual trees across all diameter 

classes above 8 inches down to basal areas similar to the target in 

Scenario 4. For these two stands, the results, shown in Exhibit 

6-11, do indicate a slowing of carbon recovery profiles relative 

to Scenario 4, although two stands are not enough to draw any 

conclusions about average impacts of this silvicultural prescription. What can be said is that stands harvested in this manner 

will probably recover carbon more slowly than would be suggested 

by Scenario 4; how much more slowly on average we did not 

determine; it is clear however that on a stand-by-stand basis the 

magnitude of the slowdown can vary considerably. 

Exhibit 6-11: Carbon Recovery Times 

Alternative Harvest Analyses (tonnes carbon)

Scenario BAU vs. Biomass Total Stand Carbon Difference by Year

Number Description Harvest 10 20 30 40 50 60 70 80 90

BAU20:Bio40DBH 7.5 8.1 6.6 3.6 2.3 1.7 0.5 -0.2 -0.7 -0.9

1 CumRecovered -0.6 0.9 3.9 5.2 5.8 7.0 7.8 8.2 8.5

%Recovery -9.6 15.1 63.5 84.6 94.8 113.9 126.4 133.6 137.8

BAU20:Bio40 5.9 6.0 4.4 2.4 2.1 3.3 1.6 1.8 -0.5 0.2

1 CumRecovered 0.0 1.5 3.5 3.8 2.7 4.4 4.2 6.5 5.8

%Recovery -0.3 25.6 59.2 64.4 44.7 73.7 70.2 108.9 97.1

BAU20:Bio40 4.2 4.3 4.4 4.3 3.2 1.3 1.6 0.4 0.6 0.0

2 CumRecovered -0.1 -0.3 -0.1 0.9 2.9 2.6 3.8 3.5 4.2

%Recovery -2.7 -6.4 -3.1 22.6 68.6 62.5 90.4 84.4 100.9

BAU20:Bio40 6.4 6.0 5.1 4.1 3.5 1.9 2.0 0.0 0.5 0.4

2 CumRecovered 0.4 1.3 2.2 2.8 4.4 4.4 6.3 5.9 5.9

%Recovery 6.1 20.4 34.8 44.6 69.5 69.1 99.4 92.3 93.5
Manomet Center for Conservation Sciences 110 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

6.3.3.5 Impacts of Differences in Stand 

Harvest Frequencies

A final factor that merits consideration in interpreting the 

modeling results is the effect of harvest frequencies on the timing 

of the transition of carbon debt to carbon dividend. Frequent 

re-entry to the stand to remove biomass has the general effect 

of extending carbon recovery times. For example, if a stand is 

re-entered before the time at which carbon levels have recovered 

to the point where atmospheric concentrations are equivalent 

to those from fossil fuel burning, a new carbon debt is added to 

what remains of the initial one and the period required for that 

stand to reach the equivalent flux point is extended. Conversely, if 

a second harvest is not conducted until after the stand has begun 

contributing to actual reductions in GHG levels relative to a fossil 

fuel scenario, net benefits in the form of carbon dividends will 

have been positive; additional benefits will depend on the amount 

of carbon debt incurred in the second harvest and the growth 

rate of the forest following the additional removal. 

As a result of this effect, it is clear that carbon recovery times are 

sensitive to the frequency at which a landowner chooses to harvest. 

Data on frequency of harvests indicates landowners who manage 

for timber typically cut their stands relatively frequently, which 

suggests our estimated carbon recovery times may be shorter 

than would actually occur in practice; as a result actual times 

to the to pay off carbon debts and begin accumulating carbon 

dividends may be longer.

6.3.3.6 Carbon Dividends 

Beyond the point in time when the carbon debt is paid off, and 

as long as the total carbon recovery rates of stands harvested 

for biomass are at least as high as the recovery rates in the BAU 

stands, the carbon dividends from biomass energy continue to 

accumulate. This means that in the years after the point of carbon 

debt repayment, there will be less carbon in the atmosphere than 

had a comparable amount of energy been generated with fossil 

fuel. As long as the stand harvested for biomass is accumulating 

carbon faster than the BAU stand, this benefit—lower GHG 

concentrations relative to the fossil fuel scenario—continues to 

increase. Even if the two stands ultimately reach a point where 

carbon accumulates at the same rates, there continues to be a 

dividend in the form of an ongoing reduction in GHG levels from 

what they would otherwise have been. As a result, the magnitude 

of carbon dividends varies depending on the year in which they 

are evaluated. Exhibit 6-13 indicates the year in which the carbon 

debt is paid off and provides estimates of the percentage carbon 

dividend in 2050 and 2100, 40 and 90 years respectively after 

the modeled biomass harvest.15

As discussed in more detail in Section 6.1.2, the carbon dividends 

in the table indicate the extent to which burning biomass has 

15 FVS simulations become increasingly uncertain as they are 

extended over long time periods. We believe 90-year simulations 

represent a reasonable length of time for providing insights into 

long-term carbon recovery effects.

When tops and limbs are left on-site, all three scenarios show net 

carbon losses between the initial period and the 10-year mark; 

in addition, carbon losses in year 10 are substantial relative to 

the recovery levels in the scenarios in which tops and limbs are 

taken and used for bioenergy. Scenario 2 (the lightest biomass 

harvest) shows the greatest impact from not utilizing tops and 

limbs, with carbon recovery times delayed by about three decades 

(about 50% of the original biomass harvest was comprised of 

tops and limbs). Thus, if BAU32 was followed by a light biomass 

harvest of only roundwood for use by a thermal facility, carbon 

debt recovery would require 20 to 30 years (when compared to 

oil-based thermal), rather than occurring in less than 10 years 

when tops and limbs are taken in whole-tree harvests. 

In contrast, in the heavier biomass harvests, recovery times are 

extended only about ten years. In Scenario 1, the carbon debt 

incurred by replacing oil thermal by biomass thermal would 

be recovered in 20 years instead of the 10 years indicated when 

tops and limbs are utilized. In Scenario 3, carbon debt recovery 

times for replacement of oil thermal are extended from 20 years 

to 30 years.

Finally, it is interesting to consider the “harvest” and use of just 

tops and limbs. While this may not be directly applicable to forest 

management in Massachusetts (due to poor markets for pulpwood 

and limited opportunities for log merchandizing), it may be 

representative of situations involving non-forest biomass sources, 

such as tree trimming/landscaping or land clearing. The results 

in this case (also shown in Exhibit 6-12) indicate rapid recovery, 

with nearly 70% of the carbon losses “recovered” in one decade. 

Thus, all bioenergy technologies—even biomass electric power 

compared to natural gas electric—look favorable when biomass 

“wastewood” is compared to fossil fuel alternatives.

Exhibit 6-12: The Impact of Tops and Limbs on Carbon 

Recovery Times in BAU32

Number of Years from Initial Harvest

10 20 30 40 50

Scenario 1

 Original (with T&L) 11% 30% 47% 53% 53%

 No T&L -9% 11% 31% 38% 38%

Scenario 2

 Original (with T&L) 28% 41% 54% 63% 68%

 No T&L -12% -4% 16% 31% 39%

Scenario 3

 Original (with T&L) -3% 14% 31% 41% 45%

 No T&L -22% -6% 14% 25% 31%

Tops and Limbs Only 68% 87% 93% 96% 97%
Manomet Center for Conservation Sciences 111 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

the last year (2050) at which time the difference in carbon is 

equal to the difference in year one, or in other words, it is equal 

to the initial carbon debt.17 This allows us to compute the total 

carbon “savings” from burning biomass for a 40-year period, and 

then compare this value with the total amount of carbon that 

would have been released by using fossil fuel. When expressed 

in this manner, the concept is identical to our carbon dividend; 

however, rather than calculating a dividend at a single point in 

time, we now have measured the cumulative dividend in 2050, 

which indicates the total net change in atmospheric carbon at 

that time due to 40 years of biomass use.

The cumulative dividend net of forest carbon resequestration 

results from these calculations are shown in Exhibit 6-14: a value 

of 0% indicates that the carbon dividends during the 2010−2050 

period have exactly offset the carbon debt; a positive value indicates 

that the cumulative carbon dividends have more than offset the 

carbon debts and have reduced atmospheric carbon compared 

to what would have been the case had fossil fuels been used (for 

example, 22% for oil (#6), thermal in harvest scenario 1 indicates 

that atmospheric carbon is 22% lower in 2050 due to the replacement of oil with biomass); a negative value indicates that total 

carbon dividends have not yet offset the cumulative debt levels 

(for example, -13% for natural gas, thermal in harvest scenario 

1 indicates that there is still 13% more carbon in the atmosphere 

in 2050 as a result of having replaced a natural gas thermal plant 

with biomass and operating it for 40 consecutive years.

Several key observations can be made from these results: (1) the 

percentage carbon dividend for the entire 2010−2050 period is 

significantly less than the single year percentage dividend in 2050 

that was based only on emissions in 2010 (shown in Exhibit 6-13, 

next page)—the dividend resulting from only the initial year of 

emissions will always be the maximum because our empirical 

analysis has shown that forest carbon resequestration is generally 

an increasing function (at least after the first few decades); (2) 

cumulative carbon dividends are positive for oil (#6), thermal for 

all harvest scenarios; using biomass to displace residual fuel oil 

in thermal applications would result lower atmospheric carbon 

levels by an average of about 20% in 2050; (3) cumulative carbon 

dividends are mostly negative in 2050 for the three other fossil fuel 

technologies indicating that 40 years is not sufficient for biomass 

to reduce atmospheric carbon levels using these technology/fuel 

combinations. 

Finally, it should be noted that extending this analysis beyond 

2050 will continue to show higher cumulative dividends over 

17 Mathematically, there are several ways to compute these values: 

1) sum the carbon differences in 2050 for each harvest year, as 

described above; 2) sum the total carbon released from biomass (net 

of forest carbon recapture) from 2010−2050 and compare this with 

the total carbon released from 40 years of burning fossil fuel; or, 

equivalently, 3) sum the total excess carbon generated from burning 

biomass (the excesses prior to the point of equal carbon flux) and 

compare these with the sum of carbon reductions relative to fossil 

fuel during the phase when dividends are positive. 

reduced GHG levels beyond what they would have been had 

the same energy been generated from fossil fuels. For example, 

if a biomass thermal plant with an initial carbon debt of 15% 

emitted 150 tonnes of lifecycle carbon, and the harvested forest 

recovered an incremental 115 tonnes of carbon over 60 years 

compared to a BAU scenario, the carbon dividend is 73%. This 

indicates that the biomass carbon debt has been completely 

recaptured in forest carbon stocks and in addition GHGs have 

been reduced by 73%16 from what they would have been if fossil 

fuels had been used to generate the equivalent amount of energy. 

In this context, a carbon dividend of 100% indicates that biomass 

combustion has achieved full carbon neutrality—all the energy 

emissions from biomass burning have been fully offset in the 

form of newly sequestered carbon. 

As was the case for carbon debt payoff, the dividend levels clearly 

indicate benefits are strongly a function of the fossil technology 

that is being replaced. Where whole-tree harvesting is used, 

replacement of oil-fired (#6) thermal by biomass thermal results 

in carbon dividends in excess of 38% by 2050 even in the slowest 

carbon recovery scenario. These reductions in GHG levels relative 

to a fossil fuel baseline rise to greater than 60% by 2100. With 

the exception of biomass replacement of natural gas electric 

capacity, carbon dividends after 90 years always result in fossil 

fuel offsets that exceed 40%. These dividends, however, are potentially reduced if stands are re-entered and additional material is 

harvested prior to the 90-year reference point discussed above. 

Carbon dividends are consistently low (and in one case negative) 

for biomass replacement of natural gas electricity generation.

Another way of comparing the relative contributions of carbon 

debts and carbon dividends is to estimate the difference in cumulative net atmospheric carbon emissions between using biomass 

and fossil fuel for energy at some future point in time. Due to the 

importance of demonstrating progress in reducing greenhouse gas 

emissions by 2050 as part of the Massachusetts Global Warming 

Solutions Act, we have provided such a comparison for our six 

harvest scenarios in Exhibit 6-14.

Conceptually, the analysis is perhaps best understood as follows. 

In the first year, a bioenergy plant consumes a specified volume 

of wood and establishes a carbon debt relative to the amount of 

carbon that would have been released in generating the same 

amount of energy from a fossil fuel alternative. The pattern is 

then repeated each year and continues until the year 2050. We 

then calculate the total difference in atmospheric carbon in 

2050 from each harvest year and sum the results. For example, 

the difference in carbon from the first year is simply equal to 

our estimate of the carbon dividend in year 2050, 40 years after 

our initial harvest. The difference in carbon from the second 

year is the carbon dividend that we observe after 39 years, the 

difference in carbon from the third year is the carbon dividend 

that we observe after 38 years, etc. The process continues until 

16 Carbon dividend = (total carbon recovered – carbon debt)/

(total carbon emissions –carbon debt) or (115 –(0.15*150))/(150-

(150*0.15)) = 73%
Manomet Center for Conservation Sciences 112 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

The interpretation of the carbon dividend results should recognize that neither carbon dividends nor carbon debts provide 

direct indications of the associated environmental benefits or 

damages. This would require a detailed analysis of the actual 

climate impacts of increased GHG levels in the period before 

carbon debts are paid off and lower GHG levels after that point 

in time. Potential non-linearity in the climate damage functions 

make such formal benefit-cost analysis challenging and beyond 

the scope of this study; consequently we leave this analysis to 

other researchers. Nonetheless, information on initial carbon 

debts, dividends accrued up to a point 90 years in the future, and 

estimates of the number of years needed to pay off carbon debts 

and begin accruing benefits should help inform the development 

of biomass energy policies. 

6.3.4 Discussion of Results

The analyses presented above make clear that technology choices for 

replacing fossil fuels, often independent of any forest management 

considerations, play an important role in determining the carbon 

cycle implications of burning biomass for energy. The choice of 

biomass technology, and the identification of the fossil capacity 

it replaces, will establish the initial carbon debt that must be 

recovered by forest growth above and beyond BAU growth. These 

carbon debts vary considerably across technologies. For typical 

existing configurations, replacement of oil-fired thermal systems 

with biomass systems leads to relatively low carbon debts. Carbon 

debts for large-scale electrical generation are higher. Because of its 

much lower GHG emissions per unit of useable energy, replacing 

natural gas for either thermal or electric applications results in 

significantly higher carbon debts than incurred in replacing other 

fossil fuels.18 The carbon recovery profile for combustion of wood 

pellets is roughly similar to burning green wood chips in terms of 

total lifecycle GHG emissions. CHP facilities, particularly those 

that optimized for thermal rather than electricity applications, 

also show very low initial carbon debts. 

While the relative ranking of technologies by their carbon recovery 

times provides useful insights on relative carbon emissions per 

unit of useable energy, the specific time required in each case to 

pay off carbon debts and begin realizing the benefits of biomass 

energy, represented in this study by the carbon dividends, depends 

on what happens in the forests harvested for biomass fuel. The 

results of our analyses provide some broad insights into biomass 

carbon dynamics but are also subject a number of uncertainties 

that are difficult to resolve.

A key finding of our work is that the magnitude and timing of 

carbon dividends can be quite sensitive to the forest management practices adopted by landowners. Carbon recovery times 

can differ by decades depending upon assumptions about (1) 

the intensity of harvests; (2) the silvicultural prescriptions and 

cutting practices employed; (3) the fraction of the logging residues removed from the forest for biomass; and (4) the frequency 

18 Cowie (2009) draws similar conclusions in a recent presentation 

of work on IEA Bioenergy Task 38.

time. When cumulative dividends through 2100 are considered 

(Exhibit 6-15), they are higher than the results shown for 2050, 

although these longer term results will overstate benefits if biomass 

comes from forests that are harvested more than once or experience significant mortality-causing natural disturbance during 

the 2010−2100 period.

Exhibit 6-14: Cumulative Carbon Dividends: 2010 to 2050

Harvest

Scenario

Fossil Fuel Technology

Oil (#6), 

Thermal

Coal, 

Electric

Gas, 

Thermal

Gas, 

Electric

1 22% -3% -13% -110%

2 34% 11% 3% -80%

3 8% -22% -34% -148%

4 15% -13% -24% -129%

5 16% -11% -22% -126%

6 7% -25% -36% -153%

Exhibit 6-15: Cumulative Carbon Dividends: 2010 to 2100

Harvest

Scenario

Fossil Fuel Technology

Oil (#6), 

Thermal

Coal, 

Electric

Gas, 

Thermal

Gas, 

Electric

1 40% 19% 12% -63%

2 56% 42% 36% -18%

3 31% 8% 0% -86%

4 43% 24% 17% -54%

5 37% 16% 9% -69%

6 31% 8% -1% -86%

Exhibit 6-13: Carbon Debt and Dividends

Harvest

Scenario

Fossil Fuel 

Technology

 Carbon 

Debt Payoff 

(yr)

Carbon Dividend

2050 2100

1

Oil (#6), Thermal 7 47% 58%

Coal, Electric 21 32% 46%

Gas, Thermal 24 26% 41%

Gas, Electric >90 -38% -9%

2

Oil (#6), Thermal 3 64% 75%

Coal, Electric 12 54% 68%

Gas, Thermal 17 50% 65%

Gas, Electric 45 7% 35%

3

Oil (#6), Thermal 14 38% 62%

Coal, Electric 30 21% 52%

Gas, Thermal 36 13% 47%

Gas, Electric 89 -61% 3%

4

Oil (#6), Thermal 10 53% 76%

Coal, Electric 27 40% 70%

Gas, Thermal 31 34% 67%

Gas, Electric 59 -22% 39%

5

Oil (#6), Thermal 15 46% 64%

Coal, Electric 25 31% 54%

Gas, Thermal 28 24% 49%

Gas, Electric 86 -41% 6%

6

Oil (#6), Thermal 15 39% 66%

Coal, Electric 32 22% 56%

Gas, Thermal 37 14% 52%

Gas, Electric 85 -59% 11%
Manomet Center for Conservation Sciences 113 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

• Our carbon analysis considers only biomass from natural 

forests. Tree care and landscaping sources, biomass from 

land clearing, and C&D materials have very different GHG 

profiles. Carbon from these sources may potentially enter the 

atmosphere more quickly and consequently carbon debts 

associated with burning these types of biomass could be paid 

off more rapidly, yielding more immediate dividends. Our 

results for biomass from natural forests likely understate the 

benefits of biomass energy development relative to facilities 

that would rely primarily on these other wood feedstocks.

• Our analyses of recovery of carbon recovery by forests have 

focused primarily on average or typical forest conditions 

in Massachusetts. The responses of individual stands vary 

around these average responses, with some stands recovering 

carbon more rapidly and others less rapidly than the average. 

Due to the complexity of responses at the individual stand 

level, this study has not been able to isolate the characteristics 

of rapidly recovering stands using FVS. Should better data 

become available on this topic, it might be possible to design 

and implement forest biomass harvest policies that accelerate 

the average carbon recovery times reported here.

• Some landowners may face alternative BAU baselines that we 

have not considered, and this raises issues about generalizing 

our results too widely—particularly beyond Massachusetts 

and New England. We have used the historical harvest 

trends in Massachusetts as the basis for our BAUs and we 

believe this is the most likely future for landowners in the 

Commonwealth. However, we cannot rule out other BAU 

scenarios that could change the carbon recovery results in 

important ways. For example, if no biomass plants are sited 

in Massachusetts, will landowners actually face an alternative BAU where they can sell this material to out-of-state 

energy facilities? If so, GHG impacts are likely the same as 

if the material were used in state. Or is there an alternative 

BAU for an out-of-state facility that sells renewable energy to 

Massachusetts—for example bioenergy facilities in Maine that 

may be competing for biomass supplies that would otherwise 

go to paper production and enter the GHG system relatively 

more quickly? The existence of alternative baselines would 

result in different carbon debts and recovery profiles than 

those that we have identified for Massachusetts.

• Views about how long it will take before we have truly low or 

no carbon energy sources play a critical role in biomass policy 

decisions. If policymakers believe it will take a substantial 

amount of time to develop and broadly apply low or no carbon 

sources of energy, they may be more inclined to promote the 

development of biomass. Conversely, if they think that no or 

low carbon alternatives will be available relatively soon, say in 

a matter of one or two decades, they may be less inclined to 

promote development of biomass, especially for applications 

where carbon debts are relatively higher and where longer 

payoff times reduce future carbon dividends.

at which landowners re-enter stands to conduct future harvests. 

If the landowners responding to demands for increased biomass 

are the same ones who harvest their lands heavily today, then it 

is probably reasonable to assume that carbon debts are recovered 

relatively rapidly, along the lines suggested by our Scenario 1. In 

this case, the transition from debt to dividends that results from 

replacing oil-fired thermal with biomass is between 10 and 20 

years and the biomass coal-electric transition occurs after 20 to 

30 years. But if the response is more evenly distributed across all 

landowners and the biomass harvests are more heavily focused 

on removal of suppressed and understory cull trees, we expect 

that recoveries would likely be slower. How much slower, and 

the impact on subsequent carbon dividends, cannot be predicted 

without a better understanding than we currently have about 

future landowner forest management practices. While detailed 

landowner surveys might improve our understanding of this 

issue, this uncertainty cannot be completely resolved until we 

can observe actual landowner behavior in response to increased 

biomass demand. 

Finally, it is important to emphasize that after the point in time 

where GHG levels are equivalent for biomass and fossil fuels, 

biomass energy provides positive reductions in future GHG 

levels. Over time, under some scenarios these carbon dividends 

can become substantial, reducing GHGs by up to 85% in some 

scenarios relative to continued fossil fuel use. But the key question 

remains one of the appropriate weighting of near-term higher 

GHG levels with long-term lower ones. Policymakers will need 

to sort out these issues of societal time preferences and weight 

near term higher GHG emissions against longer term lower ones.

6.4 Final Considerations

The Massachusetts Department of Energy Resources has indicated 

that it hopes this study will provide valuable information to help 

guide its decisions on biomass energy policy. The study discusses a 

complex subject that is technically challenging and inevitably we 

have not been able to resolve all critical uncertainties. Policymakers 

should carefully weigh the significant uncertainties that remain, 

as well as other factors not addressed by our study, in deciding 

whether to encourage or discourage biomass development. In light 

of that, we conclude with some general observations on how the 

results of our carbon accounting analyses should be interpreted 

by policymakers and the public at large.

• As suggested in the discussion of carbon recovery, we have 

used average and/or typical values for GHG emissions from 

biomass and fossil fuel energy facilities. With continually 

evolving technology, biomass developers may be able to 

demonstrate lower GHG emissions per unit of useable energy. 

This can be expected to reduce carbon debts and change the 

overall time required to pay off these debts through forest 

growth. Consequently, our carbon debt and dividend conclusions should be viewed as representative of typical or average 

conditions today, a state of affairs that will likely change in 

the future given the evolution of technologies. 
Manomet Center for Conservation Sciences 114 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

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Marland, G., B. Schlamadinger, and L. Canella. Undated. The 

Model GORCAM. www.joanneum.at/gorcam.htm.

Miner, R. 2010. Biomass Carbon Neutrality. National Council 

for Air and Stream Improvement (NCASI). url: nafoalliance.

org/wp-content/uploads/NCASI-Biomass-carbon-neutrality.pdf.

Morris, G. 2008. Bioenergy and Greenhouse Gases. Green 

Power Institute, The Renewable Energy Program of the Pacific 

Institute. Berkeley.

Natural Resources Canada. 2009. RETScreen International. 

url:www.retscreen.net/.

Schelhaas, M.J., P.W. van Esch, T.A. Groen, B.H.J. de Jong, M. 

Kanninen, J. Liski, O. Masera, G.M.J. Mohren, G.J. Nabuurs, 

T. Palosuo, L. Pedroni, A. Vallejo, T. Vilén. 2004. CO2FIX V 

3.1 - description of a model for quantifying carbon sequestration 

in forest ecosystems and wood products. ALTERRA Report 

1068. Wageningen, The Netherlands.

Schlamadinger, B. and G. Marland. 1996a. Carbon Implications 

of Forest Management Strategies, pp. 217-232 in M.J. Apps and 

D.T. Price (eds.) Forest Ecosystems, Forest Management and 

the Global Carbon Cycle, Proceedings of a NATO Advanced 

Research Workshop, NATO ASI Series I, Volume 40, SpringerVerlag, Berlin.

Schlamadinger, B., and G. Marland. 1996b. The Role of Forest 

and Bioenergy Strategies in the Global Carbon Cycle, Biomass 

and Bioenergy 10: 275-300.

Schlamadinger, B. and G. Marland. 1996c. Full Fuel-Cycle Carbon 

Balances of Bioenergy and Forestry Options, Energy Conservation and Management 37: 813-818.

Spath, P.L. and M.K. Mann. 2000. Life Cycle Assessment of 

Natural Gas Combined-Cycle Power Generation System. NREL 

(National Renewable Energy Laboratory). NREL/TP-570-27715.

Spath, P.L., M.K. Mann, D.R. Kerr. 1999. Life Cycle Assessment 

of Coal-fired Power Production. NREL (National Renewable 

Energy Laboratory). NREL/TP-570-25119.

• Concerns about the relative importance of short- versus longterm consequences of higher carbon emissions may also play 

a role in how one interprets the results of this study. Those 

who believe that short-run increases in GHG levels need 

to be avoided at all costs will be less likely to favor biomass 

development than those focused on the potentially quite 

significant, but longer term benefits of reduced GHG levels 

that could ultimately result from biomass development.

In light of all these factors, we stress that our work should be viewed 

as providing general indicators of the time frames for recovery of 

biomass carbon and the key factors that influence these estimates. 

Uncertainties remain and we have tried to be transparent about 

them. For the variety of reasons discussed above, the carbon recovery 

and dividend profile for a specific facility is likely to deviate from 

the average facilities analyzed in this report. As such, we suggest 

that new energy and environmental policies that rely on insights 

from this study should clearly take into account the impacts of the 

various uncertainties embedded in the report’s analytic framework, 

assumptions and methods. 

References

Bauen, A., G. Berndes, M. Junginger , M. Londo, and F. Vuille. 

2009. Bioenergy – A Sustainable and Reliable Energy Source: A 

review of status and prospects. IEA Bionenergy, ExCo: 2009:06.

CORRIM (Consortium for Research on Renewable Industrial 

Materials). 2004. Forest Resources: Pacific Northwest and Southeast, Phase I Final Report, Module A. 

Cowie, A. 2009. Global challenges for sustainability of biofuels: 

life cycle assessment of GHG emissions. IEA Bioenergy Task 38. 

url: www.iea.org/work/2009/bangkok/2_2_Cowie.pdf.

Department of Forest Resources, University of Minnesota. 2008. 

Assessment of Carbon Flows Associated with Forest Management 

and Biomass Procurement for the Laskin Biomass Facility. Staff 

Paper Series No. 198.

Fargione, J., J. Hill, D. Tilman, S. Polasky and P. Hawthorne. 

2008. Land Clearing and the Biofuel Carbon Debt. Science Vol. 

319 1235-1238.

Finkral, A.J. and Evans, A.M. 2008. The effects of thinning 

treatment on carbon stocks in a northern Arizona ponderosa 

pine forest. Forest Ecology and Management 255 (2008) 2743−2750.

Gerdes, K.J. 2009. NETL’s Capability to Compare Transportation Fuels: GHG Emissions and Energy Security Impacts. 

National Energy Technology Laboratory. http://www.netl.doe.

gov/energy-analyses/pubs/Petroleum%20Fuels%20GHG%20

Modeling_Feb%2025a.pdf

Hamburg, S. 2010. Biomass feedstocks and the climate implications of bioenergy. Presentation at EIA 2010 Energy Conference: 

Short-Term Stresses Long-Term Change. url: www.eia.doe.gov/

conference/2010/session2/hamburg.pdf
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Appendix 1-A

Federal, State and Regional 

Biomass Energy Policies

The following summary of federal and select state policies and 

incentives related to the development of biomass energy facilities 

addresses the following areas:

• A summary of relevant federal policies affecting the development of biomass energy; 

• A review of relevant regional policies and regulatory initiatives 

impacting the development of biomass energy;

• A summary of current policies in the State of Massachusetts 

that relate to renewable energy and biomass facilities as well 

as state policies related to sustainable forestry issues; and 

• A review of notable biomass policies and incentives in other 

states, with a particular focus on renewable energy, forest 

sustainability, carbon regulation, and climate change issues.

The information presented here is drawn from several sources 

including work prepared for the Biomass Energy Resources 

Center by Shems Dunkiel Raubvogel & Saunders PLLC, research 

conducted by Charles Niebling of New England Wood Pellet, 

analysis conducted by the Biomass Thermal Energy Council, 

analysis conducted by Jesse Caputo of the Environmental and 

Energy Study Institute, and analysis provided by the Pinchot 

Institute for Conservation. 

This discussion includes a historical review of prior federal policies 

under the Public Utility Regulatory Policy Act of 1978 (PURPA), 

which spurred development of many existing biomass energy 

facilities in the U.S. 

I. Federal Policies & Incentives Relevant to Biomass 

Federal incentives for renewable energy (including biomass) 

have taken many forms over the past four decades. The focus 

of most of these programs has been on encouraging renewable 

electricity generation and, more recently, production of renewable 

transportation fuels, such as ethanol with little attention to or 

investment in the thermal energy sector. Consequently, biomass 

as an energy source is being primarily directed into the large scale 

production of liquid biofuels and/or large scale electric generation. In addition, existing renewable energy policy provides little 

or no connection to efficiency requirements, sustainable forestry 

provisions or carbon sequestration goals.

As discussed below, federal policy initially focused on encouraging renewable electricity generation by requiring utilities to 

purchase electricity from renewable energy generators at a fixed 

cost through the Public Utility Regulatory Policy Act (PURPA). 

More recently, federal policy has shifted towards encouraging 

renewable energy through tax incentives and direct grants—with 

the primary focus on renewable transportation fuels and renewable electricity generation. 

A. Historical Review of Major Federal Policies Incentivizing Biomass 

Development 

Development of biomass energy facilities in the U.S. in the last 

four decades has been largely driven by federal energy policies and 

incentives designed to encourage renewable energy development 

and diversification of energy sources. Historically speaking, the 

most important of these federal policies was the Public Utility 

Regulatory Policy Act (PURPA). PURPA was passed in 1978, 

primarily in response to the sharp spike in oil prices during the 

1970s, and embodied a national effort to reduce reliance on foreign 

oil and diversify domestic energy generation. 

To achieve these goals, PURPA contained several provisions 

specifically designed to spur development of renewable energy 

generation in the U.S. Chief among these provisions was the 

requirement that utilities purchase the power output from certain 

small renewable energy generators—known as “qualified facilities” (QF)—at the utility’s “avoided cost.” The certainty of these 

guaranteed, highly favorable rates led to a dramatic increase in 

renewable energy generation, including an estimated three-fold 

increase in biomass facilities in the 1980s and early 1990s. 

But the spike in biomass facilities developed under PURPA 

was relatively short lived and market conditions and regulatory 

changes have limited the value and application of the “avoided 

cost” provisions of PURPA. Deregulation efforts in the 1990s also 

led to increased competition among energy generators in many 

parts of the U.S., opening the grid to a greater number of small 

or independent power producers. Due to the perceived increase 

in competition in power markets, Congress revised PURPA in 

2005 and, combined with subsequent regulator action, PURPA 

no longer serves as a significant incentive for the development of 

biomass facilities in the US. 

B. Current Federal Policies Related to Biomass Energy Development

Current federal policies and incentives for renewable energy facilities take many different forms. This review focuses on incentives 

relevant to biomass power or combined heat and power vs. the 

production of liquid biofuels, which is beyond the scope of this 

project. These incentives have moved away from the “guaranteed cost” approach implemented under PURPA, and now rely 

primarily on either (1) federal tax incentives, or (2) direct federal 

grants or loans from federal agencies. Specific examples of these 

two types of incentives are summarized below. 

Federal Tax Incentives

Overall, existing federal tax incentives for renewable energy focus 

on electric power generation and the production of liquid biofuels. 

Consequently, biomass feedstocks are being directed preferentially towards these types of energy applications. In addition, 

existing federal tax incentives provide little or no connection to 
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typical bonds, which pay interest to the bondholder, the tax-credit 

bonds provide bondholders a credit against their federal income 

tax, effectively providing the issuer of the bonds a 0% loan with 

the federal treasury covering the interest payments. The 2009 

ARRA allocated an additional $1.6 billion for this program.1

5. Five-Year Modified Accelerated Cost Recovery System 

(MACRS) (IRS Code Section 168)

Certain biomass facilities are also eligible for the Modified Accelerated Cost-Recovery System (MACRS). Under the MACRS 

program, businesses may recover investments in certain properties through accelerated depreciation deductions. At the present 

time, combined heat and power facilities powered by biomass are 

in the five-year accelerated depreciation class for this program.

6. New Market Tax Credits

Although not specific to biomass projects, The New Markets Tax 

Credit (NMTC) Program could potentially provide an additional 

tax incentive for biomass facilities, depending on the location 

of the facility, and potentially, on the clients the facility serves. 

The purpose of the NMTC program is to encourage development that would benefit low income people and populations. It 

provides a tax credit against Federal income taxes for taxpayers 

making qualified equity investments in designated Community 

Development Entities (CDEs). The potential application of this 

tax credit program to any particular project is very site specific. 

A map of NMTC-qualifying areas in western Massachusetts can 

be found at http://www.ceimaine.org/content/view/215/233/. 

$13.4 billion in NMTC have been finalized or committed by May 

2009 out of $19.5 billion awarded through 2008. An additional 

$1.5 billion was awarded in May 2009.

Federal Grants and Loans

The second major category of incentives is direct grants and loans 

from federal agencies including primarily the Department of Agriculture (USDA) and the Department of Energy (DOE). Some of 

the relevant programs from each agency are discussed below. The 

major portion of these funds are available through the Department of Energy, with the Exception of USDA’s Biomass Crop 

Assistance Program (as discussed below). While there are several 

important programs at USDA that address smaller scale biomass 

energy options, these initiatives generally have low appropriations 

levels and, in many cases, have never been funded. By contrast the 

DOE programs generally focus on large scale production of liquid 

biofuels and/or electric generation and are funded at much higher 

levels than the array of USDA programs. Again, this creates incentives for certain biomass energy applications—biofuel production 

and electricity generation—at the federal level.

A. USDA Grant & Loan Programs

1 http://www.taxalmanac.org/index.php/Sec._54._Credit_to_

holders_of_clean_renewable_energy_bonds.

efficiency requirements, sustainable forestry provisions or carbon 

sequestration goals. 

1. Production Tax Credit (IRS Code Section 45)

The Renewable Energy Production Tax Credit (PTC) provides a 

tax credit for owners or operators of qualifying renewable electric 

generation facilities for the first ten years of operation. Qualifying 

resources include both “closed-loop biomass” and “open loop 

biomass” facilities that sell power to the public. Co-fired units 

(those burning both fossil fuel and biomass) are not eligible. 

The 2009 American Recovery and Reinvestment Act recently 

extended the PTC for projects placed into service from the end 

of 2010 through the end of 2013. The benefit of this production tax credit can only be realized by an entity with sufficient 

taxable income to take advantage of the credit; the PTC will not 

provide an incentive to entities that do not pay federal taxes unless 

they partner with other entities with federal tax exposure. This 

program is not subject to annual appropriations, but does need 

to be extended every year. 

2. Business Energy Investment Tax Credit (IRS Code Section 48)

The Business Energy Investment Tax Credit (ITC) provides 

a credit based on the value of the investment in certain types 

of electrical generation and combined heat and power (CHP) 

biomass facilities and was also recently expanded to apply to 

general closed and open loop biomass facilities. The CHP ITC 

is a 10 percent tax credit for the first 15MW of a system up to 

50MW. The CHP ITC extends through December 31, 2016. The 

2009 ARRA also expanded the availability of the ITC to other 

closed loop and open loop biomass facilities (besides CHPs) that 

are otherwise eligible for the PTC. Under this new provision, the 

owner of a biomass facility that qualifies for the PTC may elect 

to claim an ITC in lieu of the PTC. 

3. Grant in Lieu of Investment Tax Credit 

The 2009 ARRA also created a new program that allows taxpayers 

eligible for the ITC to elect to receive a grant from the U.S. Treasury. This is technically a direct federal grant, not a tax credit, 

but is covered here for sake of continuity with the related ITC 

and PTC provisions. This cash grant may be taken in lieu of the 

federal business energy investment tax credit (ITC). Eligible 

CHP property includes systems up to 50 MW in capacity that 

exceed 60 percent energy efficiency. The efficiency requirement 

does not apply to CHP systems that use biomass for at least 90 

percent of the system’s energy source. 

4. Clean Renewable Energy Bonds (CREBs) (IRS Code Section 

54)

The Clean Renewable Energy Bonds (CREBs) program was 

created by the Energy Policy Act of 2005. The program provides 

“tax-credit” bonds to renewable energy projects developed by 

governments or electric coops. The bonds are awarded to eligible 

entities on a competitive basis by the IRS. Both closed-loop and 

open-loop biomass facilities are eligible for the program. Unlike 
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However, the launch of this new program has proved problematic. 

Rather than focusing funding on the front-end of the program, 

establishment of new energy crops, the Farm Service Agency (FSA) 

announced funds for the back-end of the program (via a Notice 

of Funding Availability (NOFA) for the Collection, Harvest, 

Storage and Transportation (CHST). It also interpreted CHST 

as an “entitlement” and allowed payment for a broad range of 

agricultural and forested materials delivered to an approved BCF. 

The result amounted to a substantial, new subsidy for the existing 

wood market with significant market impact. Large numbers 

of existing biomass conversion facilities (led by lumber, pellet 

and paper mills currently burning wood for their own energy 

use without a federal subsidy) submitted applications to USDA 

to be approved as qualifying facilities. Consequently, funds 

obligated (though not yet spent) for BCAP through the end of 

March 2010 soared to over $500 million, more than seven times 

BCAP’s estimated budget of $70 million in the 2008 Farm Bill. 

The USDA now estimates BCAP costs at $2.1 billion on CHST 

from 2010 through 2013.

The proposed rule for BCAP was announced February 8 with a 

final rule anticipated late summer 2010. 

4. Forest Biomass for Energy (Sec. 9012)

Authorizes new competitive research and development program 

to encourage use of forest biomass for energy. To be administered 

by USDA’s Forest Service; priority project areas include:

• developing technology and techniques to use low-value forest 

biomass for energy production

• developing processes to integrate energy production from 

forest biomass into biorefineries

• developing new transportation fuels from forest biomass

• improving growth and yield of trees intended for renewable 

energy

Authorizes appropriation of $15 million annually for FY 2009-12. 

5. Community Wood Energy Program (Sec. 9013)

The Community Wood Energy Program is administered by the 

USDA and provides grants of up to $50,000 to state and local 

governments to develop community wood energy plans. Once 

a plan has been approved, qualified applicants may request up 

to 50% matching grants toward the capital costs of installing 

biomass energy systems. The Farm Bill authorizes $5 million 

per year from FY 2009 through FY 2012 for this program, but 

to date, no funds have actually been appropriated.

6. Business and Industry Guaranteed Loan Program

The Business and Industry Guaranteed Loan Program administered by USDA Rural Development. The purpose of the B&I 

Guaranteed Loan Program is to improve, develop, or finance 

business, industry, and employment and improve the economic 

The majority of relevant USDA biomass programs are based 

on provisions of the 2008 Farm Bill. The relevant portions of 

the bill are focused on encouraging development of renewable 

biomass facilities. The Farm Bill specifically includes biomass in the 

definition of renewable energy, and defines “renewable biomass” 

broadly as “any organic matter that is available on a renewable 

or recurring basis from non-Federal land” and certain materials 

from public lands, if harvested during preventative treatments to 

reduce hazardous fuels, address infestation, or restore “ecosystem 

health.” The following specific programs may provide incentives 

for biomass facilities and projects.

1. The Rural Energy for America Program (Sec. 9007 of 2008 

Farm Bill)

The Rural Energy for America Program (REAP) provides financial 

assistance to rural communities in order for them to become more 

energy independent through increased production of renewable 

energy and energy efficiency. Grants and loan guarantees are 

available for energy efficiency and renewable energy investments 

(including biomass) for agricultural producers and rural small 

businesses. Grants may be up to 25% of project cost (up to a 

maximum of $500,000 for renewable energy projects), loan 

guarantees are capped at $25 million/loan and grants and loan 

guarantees together may be up to 75%. A portion of grants are 

reserved for small projects. 

2. The Rural Energy Self-Sufficiency Initiative (Sec. 9009 of 2008 

Farm Bill)

Authorizes a new program to provide financial assistance to 

increase energy self-sufficiency of rural communities. Provides 

grants to conduct energy assessments, formulate plans to reduce 

energy use from conventional sources, and install integrated 

renewable energy systems. Integrated renewable energy systems 

are defined as community-wide systems that reduce conventional 

energy use and incorporate renewable energy use. Federal-cost 

share for any grant is limited to 50% of project cost. The 2008 bill 

authorizes appropriations of $5 million annually for FY 2009-12.

3. Biomass Crop Assistance Program (BCAP) (Sec. 9011)

Created in the 2008 Farm Bill, BCAP is an innovative program 

intended to support establishment and production of eligible crops 

for conversion to bioenergy, and to assist agricultural and forest 

landowners with collection, harvest, storage, and transportation 

(CHST) of these eligible materials to approved biomass conversion facilities (BCF). 

The program pays for up to 75% of establishment costs of new 

energy crops. In addition, farmers participating in a selected BCAP 

project area surrounding a qualifying BCF can collect 5 years of 

payments (15 years for woody biomass) for the establishment of 

new energy crops. An additional matching payment of up to $45/

ton (on a $1 to $1 basis) to assist with collection, harvest, storage 

and transportation (CHST) of an eligible material to a BCF will 

also be available for a period of 2 years. 
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directly to states or local municipalities and is typically awarded 

on a competitive basis.

4. Sec. 471, Energy Independence and Security Act of 2007

Sec. 471 of the 2007 Energy Bill authorizes a program for 

Energy Efficiency and Sustainability Grants for implementing 

or improving district energy systems, combined heat and power 

applications, production of energy from renewable resources, 

developing sources of thermal energy and other applications. These 

funds would leverage investments by eligible public sector entities including institutions of high education, local governments, 

municipal utilities and public school districts. The Act authorizes 

$250 million for grants and $500 million for loans under this 

program for FY2009-2013 with maximum grants limited to 

$500,000. The program has never been funded.

5. Other ARRA Programs and Funding Opportunities Specific 

to Combined Heat and Power Facilities.

In addition to these major programs, the 2009 ARRA authorized 

a number of small grant and loan programs through DOE, some 

of which apply to potential biomass facilities including CHP and 

thermal district energy facilities. Of these, two grant opportunities were particularly relevant to biomass energy applications.

DOE-FOA-0000044, issued through the National Energy Technology Laboratory, provided $156 million for deployment of CHP 

systems, district energy systems, waste energy recovery systems, 

and efficient industrial equipment. Approximately 350 responses 

were submitted representing $9.2 billion in proposed projects 

with a $3.4 billion federal share, a demand far in excess of the 

available funding. DE-FOA-0000122, provided $21 million for 

community renewable energy development, with awards going 

to 5 projects nationwide. 

The Department of Energy also has other solicitations specifically 

for combined heat and power systems. For example, the Industrial 

Technologies Program (ITP), part of DOE’s Office of Energy 

Efficiency and Renewable Energy, recently released a funding 

opportunity for or up to $40 million in research, development 

and demonstration of combined heat and power (CHP) systems, 

based on annual appropriations, not ARRA funds. 

II. Review and summary of Massachusetts state policies 

relevant to biomass energy and sustainable forestry. 

Massachusetts has implemented policies to increase the use 

of biomass to meet energy needs in the electricity sector, the 

transportation sector, and the building heating sector, although 

state policies are focused primarily on implementing biomass to 

replace fossil fuels in the electricity and transportation sectors. 

Combined with the state’s regulatory scheme designed to implement the Regional Greenhouse Gas Initiative (RGGI) (which sets 

an emissions cap on fossil fuel fired electrical generation systems 

of 25 megawatts or greater), this has created significant incentives 

in the state driving biomass towards larger scale electric generation capacity vs. smaller scale or thermal applications. A recent 

and environmental climate in rural communities. A borrower may 

be a cooperative, corporation, partnership, or other legal entity 

organized and operated on a profit or nonprofit basis; an Indian 

tribe on a Federal or State reservation or other federally recognized 

tribal group; a public body; or an individual. A borrower may be 

eligible if they are engaged in a business that will reduce reliance 

on nonrenewable energy resources by encouraging the development and construction of renewable energy systems. 

7. Rural Business Enterprise Grants (RBEGs)

The RBEG program provides grants for rural projects that finance 

and facilitate development of small and emerging rural businesses 

(defined as those that will employ 50 or fewer new employees 

and have less than $1 million in projected gross revenues). The 

program is not specific to biomass projects, but biomass projects 

could benefit from the grants. 

B. Department of Energy Grant & Loan Programs

1. Renewable Energy Production Incentive

The Renewable Energy Production Incentive (REPI) provides 

financial incentive payments for electricity generated and sold by 

new qualifying renewable energy generation facilities. Qualifying 

facilities- including biomass facilities—are eligible for annual 

incentive payments for the first 10-year period of their operation, 

subject to the availability of annual appropriations in each Federal 

fiscal year of operation. This program serves as an alternative to 

the PTC for entities that are not eligible to take advantage of that 

tax program (i.e. entities that do not have federal tax liabilities). 

2. DOE Loan Guarantee Program

Title XVII of the Energy Policy Act of 2005 authorizes DOE 

to provide loan guarantees for energy projects that reduce air 

pollutant and greenhouse gas emissions. DOE recently released 

its second round of solicitations for $10 billion in loan guarantees 

for energy efficiency, renewable energy, and advanced transmission 

and distribution projects under EPACT 2005 with a primary 

focus on transportation and electric generation. The final regulation provides that the DOE may issue guarantees for up to 100 

percent of the amount of a loan. The 2009 ARRA extended the 

authority of the DOE to issue loan guarantees and appropriated 

$6 billion for this program. Under this legislation, the DOE may 

enter into guarantees until September 30, 2011.

3. Energy Efficiency and Conservation Block Grants

The Energy Efficiency and Conservation Block Grant (EECBG) 

Program provides federal grants to local government, Indian 

tribes, states, and U.S. territories to improve energy efficiency and 

reduce energy use and fossil fuel emissions in their communities. 

Activities eligible for funding include energy distribution technologies that significantly increase energy efficiency, including 

distributed generation, CHP, and district heating and cooling 

systems. A total of $3.2 billion was appropriated for the EECBG 

Program for fiscal year 2009. This funding will generally flow 
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definition of “eligible biomass” for purposes of the Massachusetts 

RGGI program. 

Biomass facilities may qualify as RPS Class I or Class II generation units as long as they are classified as “low-emission, advanced 

biomass Power Conversion Technologies using an Eligible Biomass 

Fuel.” Both the Class I and Class II RPS regulations also allow 

generators that co-fire to qualify as RPS Renewable Generation 

as long as certain requirements are met. This provision in the RPS 

program is analogous to the biomass exemption from carbon 

dioxide emissions accounting in the RGGI program.

In 2008, the Massachusetts Green Communities Act established 

new Renewable and Alternative Energy Portfolio Standards (RPS 

and APS) allowing Combined Heat and Power facilities to be 

included as an eligible technology provided the thermal output of 

a CHP unity is used in Massachusetts. APS eligible CHP units 

receive credits for the useful thermal energy of a CHP unit delivered to Massachusetts end-uses, subject to the formula included 

in the regulations. The DOER rules issued for this program will, 

for the first time in the Commonwealth, promote the installation and effective operation of new CHP units for appropriate 

residential, commercial, industrial, and institutional applications. 

There are two other regulatory programs, aside from the DOER 

process for RPS approval, which could address the sustainability 

and the carbon neutrality of biomass-fueled electricity generation. 

The first is the Energy Facilities Siting Board review process for 

generation facilities, and the second is the Massachusetts Environmental Policy Act (MEPA). 

All electricity generation facilities proposed in Massachusetts 

must be approved by the Energy Facilities Siting Board within the 

Department of Public Utilities. The Board reviews the environmental impacts of generation facilities to ensure that the plans for 

the facility are consistent with current health and environmental 

protection policies and the commonwealth’s energy policies; and 

that the plans minimize environmental impacts and related mitigation costs. The Board is also responsible for adopting performance 

standards for emissions from generating facilities. The Board also 

has the authority to preempt other state agency or local regulatory 

bodies that pose hurdles to electricity facility siting. In making such 

decisions, the board has already has a track record of taking issues 

of carbon neutrality and sustainable fuel supplies into account.

The other regulatory vehicle for screening the sustainability 

and carbon neutrality of biomass electric generation facilities 

is environmental impact review through MEPA. However, as 

MEPA review is only mandatory for any new electric facility 

with a capacity of 100 MW or more, it may not have a great deal 

of promise for effective implementation of regulatory goals for 

biomass because facilities are unlikely to meet this size threshold. 

Further, the process is “informal,” and “MEPA and [its implementing regulations] do not give the Secretary the authority to 

make any formal determination regarding . . . consistency or 

compliance” with “any applicable Federal, municipal, or regional 

statutes and regulations.” 

exception to this trend is the Massachusetts Green Communities 

Act of 2008 which established new Renewable and Alternative 

Energy Portfolio Standards (RPS and APS) which allow eligible 

CHP units to receive credits for useful thermal energy. This 

program promotes the installation and effective operation of new 

CHP units for appropriate residential, commercial, industrial, 

and institutional applications. It does not, however, eliminate or 

counterbalance the overall focus on encouraging development of 

the biomass electric power sector. 

Following is a summary of the range of statutory and regulatory 

provisions that directly address biomass in Massachusetts, with 

an emphasis on biomass policy within the electricity sector.

A. Biomass in Renewable Energy Policy

1. Electricity

Massachusetts has two regulatory schemes that directly impact 

the incentives for developing biomass-fueled electricity in the 

state. The first is the Massachusetts Renewable Portfolio Standard (RPS), which is administered by the Department of Energy 

Resources (DOER), and the second is the implementation of the 

state’s membership in the Regional Greenhouse Gas Initiative 

(RGGI), which is administered by the Department of Environmental Protection (DEP). We discuss RGGI and the Massachusetts regulatory scheme implementing RGGI in Part III, in the 

context of regional biomass policy initiatives. In this section of the 

paper, we discuss the implications for biomass energy under the 

RPS program regulations as currently written, recognizing that 

DOER has suspended RPS review of all proposed biomass-fueled 

electricity generators pending completion of the Manomet study. 

The Massachusetts RPS program currently mandates that all retail 

electricity suppliers must include minimum percentages of RPS 

Class I Renewable Generation, RPS Class II Renewable Generation, and RPS Class II Waste Energy in the retail electricity they 

sell to consumers. For 2010, the Class I requirement is 5 percent, 

the Class II Renewable requirement is 3.6 percent, and the Class 

II Waste requirement is 3.5 percent. The definition of “eligible 

biomass fuel” under the RPS program is:

Fuel sources including brush, stumps, lumber ends and 

trimmings, wood pallets, bark, wood chips, shavings, 

slash and other clean wood that are not mixed with other 

unsorted solid wastes; by-products or waste from animals 

or agricultural crops; food or vegetative material; energy 

crops; algae; organic refuse-derived fuel; anaerobic digester 

gas and other biogases that are derived from such resources; 

and neat Eligible Liquid Biofuel that is derived from such 

fuel sources.

It is notable that this definition contains no “sustainability” 

requirement. The RGGI definition, by contrast, does contain 

such a requirement, though the criteria for sustainability in that 

definition are not fleshed out at this time. This definition also 

includes liquid biofuels, which are expressly excluded from the 
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The Massachusetts Department of Conservation and Recreation 

(DCR) is the regulatory agency charged with administering 

timber harvesting on public and private forest lands. DCR has 

jurisdiction over all commercial forest cutting that produces more 

than 25,000 board-feet or 50 cords on any parcel of land. Under 

the regulations, any landowner planning a cut within DCR’s 

jurisdiction must complete a “forest cutting plan.” Proposed 

cuts that include a clearcut exceeding 25 acres are subject to 

additional regulatory process mandated by the Massachusetts 

Environmental Policy Act. 

In addition to administering the Forest Cutting Practices regulations DCR has joined with DOER to form the Sustainable 

Forest Bioenergy Initiative (SFBI). The goal of the SFBI is to 

“provide research and development on forest management and 

market infrastructure needs, and enable the state to provide the 

resources necessary to develop the biomass supply market.” The 

Initiative has produced a number of technical reports regarding 

woody biomass energy, woody biomass supply in the state, forest 

harvesting systems for biomass production, economic impact 

analyses, and silvicultural and ecological considerations for forest 

harvesting. 

Documents produced under the SFBI state that the “carbon 

dioxide produced by burning wood is roughly equal to the amount 

absorbed during the growth of the tree.” Other documents estimate between 500,000 and 890,000 dry tons of biomass from 

public and private forests located in the state can be sustainably 

harvested per year, and that the demand for woody biomass from 

forestry is approximately 526,000 dry tons per year. The SFBI 

has carried out extensive state-specific work on biomass energy 

and forest sustainability issues relevant to this study.

C. Other Massachusetts Incentives Related to Renewable or 

Alternative Energy Development and Biomass

The following paragraphs comprise a set of tax incentives and other 

programs available in Massachusetts that may have an impact on 

biomass development in the Commonwealth. 

1. Renewable Energy Trust Fund—Two separate public benefits 

funds to promote renewable energy and energy efficiency for 

all customer classes. The renewable energy fund, known as the 

Massachusetts Renewable Energy Trust (MRET), is supported 

by a surcharge on customers of all investor-owned electric utilities 

and competitive municipal utilities in Massachusetts. The Massachusetts Technology Collaborative (MTC), a quasi-public research 

and development entity, administers the MRET with oversight 

and planning assistance from the Massachusetts Department of 

Energy Resources (DOER) and an advisory board. The MRET 

may provide grants, contracts, loans, equity investments, energy 

production credits, bill credits and rebates to customers. The 

fund is authorized to support a broad range of renewable energy 

technologies including low-emission advanced biomass power 

conversion technologies using fuels such as wood, by-products 

or waste from agricultural crops, food or animals, energy crops, 

2. Transportation and Heating

The focus of Massachusetts policy on biomass in the transportation and heating sectors seems to be on liquid biofuels. In 

2006, the commonwealth instituted a policy requiring the use 

of a minimum percentage of biofuels in state vehicles and instituting a pilot study on the use of biofuels in heating systems in 

state buildings. Additionally, the commonwealth created the 

“Advanced Biofuels Task Force” in late 2007 to explore how 

Massachusetts could accelerate use of advanced biofuels.2 The 

Task Force issued a report, which explores the environmental life 

cycle of biofuels, and contains recommendations heavily focused 

on the transportation sector, in the spring of 2008. (Advanced 

Biofuels Task Force, 2007) 

Following the report’s publication, the commonwealth passed 

the Clean Energy Biofuels Act, which exempts cellulosic biofuels 

from the state gasoline tax, requires transportation diesel and 

home heating oil to contain 2-5% of cellulosic biofuels from 2010-

2013, and requires the commonwealth to develop a low-carbon 

fuel standard that will reduce transportation GHG emissions by 

10%. DOER has been implementing the Biofuels Act through 

regulations related to the tax exemptions for cellulosic biofuels. 

The proposed regulation includes a definition of “Lifecycle Greenhouse Gas Emissions” and eligibility criteria for the tax exemption 

that include requirements for the reductions in lifecycle GHG 

emissions achieved by eligible biofuels compared to fossil fuels.

B. Biomass and Forestry

Massachusetts has a statutory framework as well as administrative regulations addressing forest harvesting. By statute, the 

Commonwealth recognizes that:

the public welfare requires the rehabilitation, maintenance, 

and protection of forest lands for the purpose of conserving 

water, preventing floods and soil erosion, improving the 

conditions for wildlife and recreation, protecting and 

improving air and water quality, and providing a 

continuing and increasing supply of forest products for 

public consumption, farm use, and for the woodusing 

industries of the commonwealth.

 Accordingly, it is the policy of the Commonwealth that:

all lands devoted to forest growth shall be kept in such 

condition as shall not jeopardize the public interests, and 

that the policy of the commonwealth shall further be one 

of cooperation with the landowners and other agencies 

interested in forestry practices for the proper and profitable 

management of all forest lands in the interest of the owner, 

the public and the users of forest products. 

2 Advanced Biofuels Task Force. (2007). Retrieved 2010 from 

http://www.mass.gov/?pageID=eoeeaterminal&L=4&L0=Hom

e&L1=Energy%2c+Utilities+%26+Clean+Technologies&L2=A

lternative+Fuels&L3=Clean+Energy+Biofuels+in+Massachuse

tts&sid=Eoeea&b=terminalcontent&f=eea_biofuels_biofuels_

report&csid=Eoeea
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Biomass Energy Policy and Market Development Program 

promoted biomass with a comprehensive biomass energy policy 

initiative to improve the policy and market conditions and foster 

biomass economic development. The project informed the Renewable Portfolio Standard eligibility criteria for biomass projects 

and forestry management, assessed the regional woody biomass 

resource, and evaluated the potential for rural economic development. It increased the use of biofuels and biodiesel for building 

heating through outreach, formal collaboration with other state 

agencies to formalize comprehensive biomass energy policy and 

implementation plan, engaging with public and private sectors 

to inform policy discussions and understand and address issues, 

promote project activities within state agencies and private market 

to adopt bioenergy fuels, legal review and input, outreach policy 

and project development to industry, municipalities, concerned 

citizens, and renewable energy developers.

8. Alternative Energy and Energy Conservation Patent Exemption 

(Corporate)—Corporate excise tax deduction for (1) any income 

received from the sale or lease of a U.S. patent deemed beneficial 

for energy conservation or alternative energy development by the 

Massachusetts Department of Energy Resources, and (2) any income 

received from the sale or lease of personal property or materials 

manufactured in Massachusetts and subject to the approved patent. 

9. Alternative Energy and Energy Conservation Patent Exemption (Personal)—Personal income tax deduction for any income 

received from a patent deemed beneficial for energy conservation 

or alternative energy development. The Massachusetts Commissioner of Energy Resources determines if a patent is eligible. 

10. Biodiesel Blend Mandate (Massachusetts Session Law 206)—

All diesel motor vehicle fuel and all other liquid fuel used to 

operate motor vehicle diesel engines must contain at least 2% 

renewable diesel fuel by July 1, 2010; 3% renewable diesel fuel 

by July 1, 2011; 4% renewable diesel fuel by July 1, 2012; and 

5% renewable diesel fuel by July 1, 2013. For these purposes, 

eligible renewable diesel fuel includes diesel fuel that is derived 

predominantly from renewable biomass and yields at least a 50% 

reduction in lifecycle greenhouse gas (GHG) emissions relative to 

the average lifecycle GHG emissions for petroleum-based diesel 

fuel sold in 2005. The Massachusetts Department of Energy 

Resources must also study the feasibility, benefits, and costs of 

applying the percentage mandates on a statewide average basis 

rather than for every gallon of diesel motor fuel sold.

11. Biofuels Incentives Study (Massachusetts Session Law 

206)—A special commission is established to study the feasibility and effectiveness of various forms of incentives to promote 

the development and use of advanced biofuels in Massachusetts, 

including, but not limited to, production credits, the production 

and harvesting of woody biomass, feedstock incentives and direct 

consumer credits for the use of advanced biofuels in various applications. The commission reported the results of its investigation 

and recommendations in March 2009.

biogas, liquid biofuels; and combined heat and power (CHP) 

systems less than 60 kilowatts (kW). 

2. Large Onsite Renewables Initiative (Massachusetts Renewable 

Energy Trust Fund)—Program funds support grid-tied renewableenergy projects (excluding PV) greater than 10 kilowatts (kW) in 

capacity that are located at commercial, industrial, institutional 

and public facilities that will consume more than 25% of the 

renewable energy generated by the project on-site. The applicant 

and project site must be a customer of a Massachusetts investorowned electric distribution utility or a municipal utility that pays 

into the Renewable Energy Trust. Grant awards may be used to 

facilitate the installation of renewable-energy projects on existing 

buildings (retrofits) or in conjunction with new construction/

major renovation projects, including green buildings.

3. Business Expansion Initiative—The Massachusetts Technology 

Collaborative (MTC), as administrator of the state’s Renewable 

Energy Trust Fund, offers loans to support renewable energy 

companies entering or expanding within the manufacturing 

stage of commercial development. Companies that currently, 

or plan to, manufacture renewable energy technology products 

in Massachusetts are generally eligible. Products may be new or 

existing, or a combination of the two.

4. Clean Energy Pre-Development Financing Initiative (Massachusetts Technology Collaborative)—Offers grants and loans 

to support the development of grid-connected renewable energy 

systems in New England. Eligible technologies or resources include 

wind energy; naturally flowing water and hydroelectric power; 

landfill gas; anaerobic digestion; and low-emission, advanced 

power-conversion technologies using “eligible biomass fuel.” Biomass 

and wind energy projects must have a minimum capacity of three 

megawatts (MW), and hydroelectric, landfill gas and digester gas 

projects must have a minimum capacity of 250 kilowatts (kW). 

Projects must be designed to lead to the development of new 

renewable grid-connected generating capacity for the wholesale 

electricity market. Therefore, more than 50% of the renewable 

energy produced must be provided to the wholesale market.

5. Massachusetts Technology Collaborative (MTC) - Sustainable 

Energy Economic Development (SEED) Initiative—Provides 

financial assistance to support renewable-energy companies in 

the early stage of development. Applicants are companies that 

generally have a unique technology but have not yet demonstrated 

commercial viability to an extent sufficient to attract venture 

capital. Awards of up to $500,000 are available as a convertible loan 

on a competitive basis. Since 2004, the Massachusetts Renewable 

Energy Trust has invested over $4.9 million in Massachusettsbased renewable energy companies through the SEED Initiative. 

6. Net Metering—The state’s investor-owned utilities must 

offer net metering. Municipal utilities may do so voluntarily. 

(The aggregate capacity of net metering is limited to 1% of each 

utility’s peak load. 

7. The Biomass Energy Policy and Market Development Program 

(U.S. Department of Energy’s State Energy Program)—The 
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Biomass Sustainability and Carbon Policy Study

exemption provides that any carbon dioxide emissions attributable to “eligible biomass” may be deducted from a facility’s total 

carbon dioxide emissions when calculating whether the facility’s 

emissions are within its carbon-allowance budget. 

The Model Rule defines “eligible biomass” as follows: 

Eligible biomass includes sustainably harvested woody and 

herbaceous fuel sources that are available on a renewable or 

recurring basis (excluding old-growth timber), including 

dedicated energy crops and trees, agricultural food and 

feed crop residues, aquatic plants, unadulterated wood and 

wood residues, animal wastes, other clean organic wastes 

not mixed with other solid wastes, biogas, and other neat 

liquid biofuels derived from such fuel sources. Sustainably 

harvested will be determined by the [participating state’s 

designated regulatory agency].

In Massachusetts, the regulation defines “eligible biomass” identically except that it deletes the language “and other neat liquid 

biofuels.” Additionally, the Massachusetts definition states, “Liquid 

biofuels do not qualify as eligible biomass.” It is unclear why the 

Massachusetts regulators decided to eliminate liquid biofuels from 

the definition, especially since liquid biofuels are included in the 

“eligible biomass fuel” definition in Massachusetts’ RPS program. 

As illustrated in Table 1, below, several other states similarly 

exclude liquid biofuels from their RGGI definitions of “eligible 

biomass.” In Massachusetts, the Department of Environmental 

Protection is charged with defining the sustainable harvesting 

criteria for sustainable harvesting of biomass under RGGI.

Exhibit A-1: Summary of biomass provisions in the RGGI 

implementing regulations of the ten participating RGGI states.

State

Allows 

deduction for 

biomassattributable 

emissions 

Includes 

liquids as 

eligible 

biomass

Uses 

December 

2008 Model 

Rule for 

biomass 

calculation

Uses 

January 

2007 Model 

Rule for 

biomass 

calculation

Massachusetts X X

Connecticut X X

Delaware X X X

Maine

Maryland X Not found X

New 

Hampshire X X X

New Jersey X X X

New York X X

Rhode Island X X

Vermont

 

12. Massachusetts - Green Power Purchasing Commitment—In 

April 2007, Massachusetts Governor Deval Patrick signed Executive Order 484, “Leading by Example: Clean Energy and Efficient 

Buildings.” This order establishes energy targets and mandates for 

state government buildings and directed state government agencies 

to procure 15% of annual electricity consumption from renewable 

sources by 2012 and 30% by 2020. This mandate may be achieved 

through procurement of renewable energy supply, purchase of renewable energy certificates (RECs), and/or through the production of 

on-site renewable power. Only renewable sources that qualify for 

the Massachusetts renewable portfolio standard (RPS) are eligible. 

13. Boston - Green Power Purchasing—In April 2007, Boston 

Mayor Thomas Menino issued an executive order that established 

a green power purchasing goal of 11% for the city government, 

and a goal of 15% by 2012. The executive order also requires all 

existing municipal properties to be evaluated for the feasibility of 

installing solar, wind, bio-energy, combined heat and power (CHP), 

and green roofs and set goals for greenhouse gas emissions reductions, recycling, green building, vehicle fuel efficiency, biofuels use, 

and the development of the Boston Energy Alliance, a non-profit 

corporation dedicated to implementing large-scale energy efficiency, 

renewable energy, and demand response projects citywide. 

III. Review and summary of regional policy and regulatory 

initiatives impacting development of biomass energy. 

A. Regional Greenhouse Gas Initiative 

Massachusetts is a member of the Regional Greenhouse Gas Initiative (RGGI), a group of ten New England and Mid-Atlantic states 

that has agreed to cap greenhouse gas (GHG) emissions from the 

generation of electric power and to lower this cap over time. Under 

the RGGI agreement, each participating state has been assigned a 

certain number of carbon dioxide allowances, serving as that state’s 

emissions cap. The individual states are responsible for assigning 

carbon allowances to the covered emissions sources within the state, 

and to adopt rules to implement the emissions accounting, trading, 

and monitoring necessary to achieve the initial cap and subsequent 

reductions of GHG emissions. Eight of the ten participating states, 

including Massachusetts, exempt biomass-fueled electricity generation from carbon dioxide emissions accounting such that any carbon 

dioxide emitted from biomass-fueled processes is not counted against 

that state’s carbon cap. The RGGI emissions cap applies to fossil fuelfired electricity generators with a capacity of 25 megawatts or greater. 

As a consequence of this program, Renewable Energy Credits are 

issued in Massachusetts (and the other RGGI states) for biomassfueled electric power generation, providing a significant incentive 

and market driver for large scale biomass-fueled electric power 

generation over other uses such as thermal, Combined Heat and 

Power, or smaller scale applications. 

In addition to the complete exemption from the RGGI system 

for generators whose fuel composition is 95 percent or greater 

biomass, the RGGI Model Rule and all participating states except 

for Maine and Vermont provide partial exemptions for facilities 

that co-fire with smaller percentages of biomass. This partial 
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IV. Review and summary of outstanding state policies 

impacting development of biomass energy, with a focus on 

renewable energy, forest sustainability and climate issues. 

This section provides a summary of relevant policies in several 

states with notable approaches to biomass development, with a 

particular focus on renewable energy incentives, forest sustainability and climate change issues. Specifically, this section: characterizes the state-level approach to biomass usage in general; 

reviews the typical basket of state policies that address biomass; 

highlights some outstanding state policies with regard to biomass; 

and concludes with a listing of relevant state policies. It is based 

on a review of eleven states’ policies regarding biomass: Arizona, 

California, Connecticut, Maryland, Minnesota, Missouri, Oregon, 

Pennsylvania, Vermont, Washington, and Wisconsin.

The thrust of state policies promoting biomass and/or biofuels is 

focused on electric generation and less so on transportation and 

thermal. All surveyed states have numerous policies, programs 

and/or incentives to promote electric generation from renewable 

sources of energy, including biomass. A few states have policies to 

support the use of biomass/biofuels for transportation (California, 

Minnesota, Oregon, Pennsylvania, Washington, and Wisconsin) 

and/or for thermal production (Arizona, Connecticut, Missouri, 

Oregon, Pennsylvania, Vermont, Washington, and Wisconsin).

Typically, states include biomass as one of a number of sources of 

renewable energy in a variety of policies and programs aimed at 

increasing electric generation from renewable energy. A common 

method to advance biomass electric generation policies is via renewable portfolio standards, which typically mandate that utilities 

provide a certain percentage of renewably generated electricity 

by a certain date. Other common state policies supportive of 

biomass electric generation are net metering programs; public 

benefits funds which, among other activities, distribute grants 

and/or loans for biomass research and/or development; other 

grant and/or loan programs for biomass research and/or development; power purchasing programs at the state and/or local 

level; and a variety of tax incentives. The range of tax incentives 

includes: production tax incentives such as energy production 

tax credits, or deductions or exemptions for installing certain 

types of biomass manufacturing systems; sales tax incentives for 

purchasing qualifying equipment for harvesting, transportation, 

and manufacturing or processing of biomass; personal tax incentives such as income tax credits and deductions for installation 

of certain types of renewable energy systems; and property tax 

incentives such as exemptions, exclusions and credits for property 

(including equipment) used for the siting of qualifying manufacturing facilities or the transport of biomass.

States with large sources of biomass supply, such as Minnesota, 

Missouri, Oregon, Washington and Wisconsin, also tend to 

have biomass-specific policies or programs in addition to general 

programs such as renewable portfolio standards. These states are 

also likely to have biomass working groups or a biomass program 

(Connecticut, Minnesota, Oregon, Pennsylvania, and Vermont). 

Some have produced biomass reports, including woody biomass 

B. Midwestern Greenhouse Gas Reduction Accord and Western 

Climate Initiative

While RGGI is the only fully developed and implemented regional 

cap and trade program for GHG emissions reductions in the 

United States, several Midwestern states and the Canadian 

province of Manitoba have joined together to achieve GHG 

emissions reductions through their own regional cap and trade 

system. The Midwestern agreement is called the Midwestern 

Greenhouse Gas Reduction Accord (Accord), and in June 2009, 

the Accord’s Advisory Group issued a set of recommendations 

for emissions reductions targets and for designing a regional 

cap-and-trade system. The Advisory Group recommended that 

a broader set of sectors be included in the emissions reduction 

program than RGGI covers, such that the program would cover 

not only electricity generation, but also industrial sources, fuels 

serving residential, industrial, and commercial buildings, and 

transportation fuels. However, the recommendations include an 

exemption for carbon dioxide emissions “from the combustion of 

biomass or biofuels, or the proportion of carbon dioxide emission 

from the combustion of biomass or biofuels in a blended fuel,” 

which essentially mirrors the RGGI exemption.

After the Advisory Group recommendations were published, 

the Accord issued a draft Model Rule in October 2009 The 

rule contains a definition of “eligible biomass” that is exactly 

identical to the RGGI Model Rule definition, including the 

liquid biofuels measure. Additionally, the Accord’s Model Rule 

includes the same provision allowing a GHG source to deduct 

all biomass-attributable GHG emissions from its total GHG 

emissions when determining compliance with the source’s GHG 

allowance budget. The Accord’s Model Rule does not, however, 

contain any provision detailing how the biomass-attributable 

GHG emissions are to be calculated. 

Similar to RGGI and the Midwestern Accord, several western 

states and Canadian provinces have joined in the Western Climate 

Initiative to enact similar GHG emissions reductions through a 

cap-and-trade system. The WCI, like the Accord, recommends 

that the program cover not just electricity, but also transportation, industrial and commercial fossil fuel combustion, industrial 

process emissions, and residential fuel use. Further, the WCI has 

issued draft program recommendations, which include a recommendation that “biomass determined by each WCI Partner 

jurisdiction to be carbon neutral” should not be included in the 

cap-and-trade program, except for reporting purposes. Further, the 

recommendations state that “[c]arbon dioxide emissions from the 

combustion of pure biofuels, or the proportion of carbon dioxide 

emissions from the combustion of biofuel in a blended fuel” would 

not be included in the program. The WCI recommendations also 

indicate that each participating jurisdiction “will assess whether 

and how to include upstream emissions from biofuel and fossil fuel 

production.” These recommendations, unlike the RGGI Model 

Rule or the Accord’s recommendations and Model Rule, exhibit 

more caution regarding the carbon neutrality of biomass fuel use.
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The Vermont Standard Offer for Qualifying SPEED Resources

was enacted as part of the 2009 Vermont Energy Act. It requires 

all Vermont retail electricity providers to purchase electricity 

generated by eligible renewable energy facilities through the 

Sustainably Priced Energy Enterprise Development (SPEED) 

Program. This “feed-in tariff” is intended to provide a reasonable 

return on investment to renewable energy facility developers, 

thereby spurring deployment of renewable energy. The program 

establishes a set price that utilities must pay to purchase renewable 

energy from certain qualifying sources, by means of long-term 

contracts. The standard offer price will be available to facilities 

with a plant capacity of 2.2 MW or less, for a total of 50 MW 

of renewable power state-wide. The applications for 50 MW of 

SPEED standard-offer contracts are fully subscribed and a lottery 

was implemented to select final solar and biomass projects. Wood 

biomass is included as a potential qualifying renewable energy 

source, but may only receive the standard offer if the plant’s system 

efficiency is 50% or greater. If the program’s goals (included in 

the appendix) are not met, then the RPS will become mandatory 

and require the state’s electric utilities to meet any increase in 

statewide retail electricity sales between 2005 and 2012 by using 

renewables with associated attributes, by purchasing RECs, or 

by making an alternative compliance payment to the Vermont 

Clean Energy Development Fund. 

Oregon is a biomass leader. It has developed a comprehensive 

wood biomass supply assessment at state and regional levels. The 

state’s active Forest Biomass Working Group has produced a 

comprehensive analysis of forest biomass opportunities map that 

includes existing wood-based energy facilities and the power 

transmission grid. The Oregon Strategy for Greenhouse Gas 

Reduction aims to reduce wildfire risk by creating a market for 

woody biomass from forests. It incorporates use of biomass into 

discussions linking climate change, wildfire protection plans, 

and economic development for rural communities. It notes that 

an additional 100 MW produced from woody biomass plants 

would result in the thinning of 2.4 million acres over 30 years, 

and the average annual sequestration from reduced crown fires 

and improved forest health would be 3.2 million metric tons of 

CO2. This CO2 reduction is in addition to, and does not include, 

displacing fossil fuels with biomass fuels. It promotes biofuels use 

and production, and expands research on how climate change 

could affect expanded production of renewable power including 

bioenergy. Oregon House Bill 2200 authorized the State Forester 

to establish programs to market, register, transfer or sell forestry 

carbon offsets on behalf of state forestland beneficiaries, the Forest 

Resource Trust, and other non-federal forest landowners. The bill 

recognizes a wide range of forest management activities—those 

designed to protect our environment as well as those designed 

to provide our wood products—as having the potential to give 

rise to forestry carbon offsets. Oregon’s Biomass Logging Bill

(SB 1072) promotes the use of biomass from logging projects on 

federal land as both a restoration tool and electricity generation 

mechanism. It also directs the Oregon Department of Forestry 

to participate in federal forest project planning and land management. It spells out that the “Policy of the State” of Oregon is 

supply assessments. (Arizona, California, Minnesota, Oregon, 

Vermont, Washington, and Wisconsin). These reports typically 

focus more on biomass promotion and less on sustainability, 

and some discuss the linkage between biomass utilization and 

climate change. Finally, some states have produced woody biomass 

harvesting guidelines that focus on best management practices 

for harvesting woody biomass in an ecologically sensitive and 

sustainable manner (Minnesota, Missouri, Pennsylvania, and 

Wisconsin). All such harvesting guidelines are voluntary, guidance only.

The following state programs stand out regarding the sustainable 

utilization of biomass for renewable energy generation: 

The Vermont Energy Act of 2009 aims to expand the market 

for renewable-energy technologies in Vermont in a number of 

innovative programs that address the issue from different directions. Its key elements include: clarification that the Clean Energy 

Development Fund’s grants and loans also apply to thermal 

energy projects (discussed further below); a standard offer for 

renewable energy (discussed further below); incentives that allow 

utilities to recover permitting costs for renewable energy; pilot 

downtown-community renewable-energy projects in two towns, 

Montpelier and Randolph (Village Green Program); improvements 

to residential- and commercial-building standards; provision for 

the creation of clean energy assessment districts so that towns, 

cities, and incorporated villages can use municipal bonds to 

finance residential renewable-energy or energy-efficiency projects; 

and limitations on the power of municipalities and deeds to 

prohibit residential installation of renewable-energy and energyefficiency devices, such as solar panels, residential wind turbines, 

and clothes lines.

The Vermont Clean Energy Development Fund, Vermont’s principle renewable energy incentive program, has provided millions 

of dollars to wind, solar, biomass, and other renewable energy 

projects in the form of grants and loans over the past several years. 

The Vermont Energy Act of 2009 clarified the scope of the CEDF 

to include thermal energy and geothermal resources, including 

combined heat-and-power systems, which sets Vermont’s program 

apart from most state programs. Grant funding is available to four 

categories of projects: pre-project financial assistance, small-scale 

systems (microturbines, fuel cells, and CHP), large-scale systems, 

and special demonstration projects. Proposed projects must 

have an electric generation component and be grid-connected; 

off-grid projects and thermal projects (except CHP systems) are 

not eligible. There is a special funding opportunity in 2009 for 

municipalities, public schools, and colleges to explore renewable 

energy projects and feasibility up to $5,000. Low-interest fixedrate loans are available to individuals, companies, nonprofits and 

municipalities for purchasing land and buildings for qualifying 

projects, purchasing and installing machinery and equipment, 

and providing working capital. Eligible clean electric-energy 

technologies include solar, wind, biomass, fuel cells and combined 

heat and power. 
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to support efforts to build and place in service biomass fueled 

electrical power generation plants that utilize biomass collected 

from forests or derived from other sources such as agriculture 

or municipal waste. It requires the Oregon Board of Forestry 

to direct the State Forester to enter into stewardship contract 

agreements with federal agencies to carry out forest management 

activities on federal lands. Finally, the Oregon Renewable Energy 

Action Plan (REAP) outlines a plan of action for renewables. 

Specifically for biomass, it provides that twenty-five megawatts 

of new biomass-fueled electric generation will be built or under 

construction, in addition to 5 megawatts of biogas facilities; it 

allows biomass facilities to qualify for net metering and allows 

the Oregon Public Utility Commission to adopt rules to increase 

the 25-kilowatt limit on a net metering facility for customers of 

Portland General Electric and Pacific Power; it encourage the 

development and utilization of small energy efficient biomass 

heating and electrical systems for heating and providing power to 

institutions, state offices, schools, etc., especially in rural Oregon; 

and it promotes greater public awareness of the primary and 

secondary benefits of biomass energy production.

California’s State Biofuels Development Plan / Biofuels 

Production Mandate and Alternative Fuel Use Study is notable 

for its ambition. California plans to use biomass resources from 

agriculture, forestry, and urban wastes to provide transportation 

fuels and electricity to satisfy California’s fuel and energy needs. 

The state will produce its own biofuels at a minimum of 20% 

by 2010, 40% by 2020, and 75% by 2050. Regarding the use of 

biomass for electricity, the state shall meet a 20 percent target 

within the established state goals for renewable generation for 

2010 and 2020. The Bioenergy Action Plan includes: research 

and development of commercially viable biofuels production 

and advanced biomass conversion technologies; evaluation of 

the greenhouse gas reductions benefits of bio-fuels and biomass 

production and use; evaluation of the potential for biofuels to 

provide a clean, renewable source for hydrogen fuel; and state 

agencies’ purchase of flexible fuel vehicles as 50% of total new 

vehicles by 2010.
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Appendix 2-A

18 Selected Technology Pathways

Pathway #1: Power Plant—Electricity (green wood)

This technology pathway is fueled by green wood with bark. On 

average, woodchips have roughly 40 percent moisture content. 

This means that while one ton of dry woodchips would produce 

16.5 million Btus 1 (MMBtu) of heat, one ton of green woodchips 

would produce only 9.9 MMBtu. The green wood with bark will 

have some implications on the emissions of this system as bark 

has high ash content. This technology pathway will use direct 

combustion using a fluidized bed. This combustion technique 

suspends the woodchips in midair using jets of upward-blowing 

air. This increases the contact between carbon and oxygen and 

hence increases efficiency. A medium (like sand, or lime) is used 

to make the process uniform and controllable. The resulting hot 

gases travel up from the furnace to the boiler to heat water and 

convert it into a high-pressure steam.

The high-pressure steam then travels to a condensing steam turbine, 

the secondary process in this pathway. When steam enters the 

turbine, it is hotter per unit weight than when it exits the turbine. 

Upon leaving, the exhaust steam is condensed below atmospheric 

pressure which increases the pressure drop between input and 

exhaust steam. This produces greater power per unit weight of 

the input steam. The spinning turbine creates electrical energy.

Lastly, when the hot gases travel out of the furnace, they are 

likely carrying some ash, fines, and other particulates. In order 

to reduce the particulate emissions from this pathway, an electrostatic precipitator (ESP) removes particles from the air using an 

electrostatic charge. Gases are not impeded as they move through 

the ESP, but particulates like dust and smoke remain instead of 

leaving with the gas. The clean flue gases are discharged to the 

atmosphere through a high stack.

Pathway #2: Power Plant—Electricity (co-fired, 20% green 

wood, 80% coal)

In this pathway, green wood with bark is most commonly co-fired 

with coal. In co-firing, biomass can burn simultaneously with 

coal, comprising 20 percent of the load that is combusted in a 

regular coal boiler system. No efficiency is lost in the process. The 

intent is to reduce the use of fossil fuel and substitute renewable 

biomass, which is low-carbon if sustainably managed, and sulfur 

oxide emissions are lowered because biomass has nearly no sulfur 

content. When the two fuels are burned and release hot gases, 

they heat water in the boiler which in turn heats the high-pressure 

steam needed for the condensing steam turbines (as described in 

Pathway #1). The turbines create electrical energy. 

1 Btu: British thermal unit, a standard unit of energy equal to the 

heat required to raise the temperature of one pound of water one 

degree Fahrenheit

In some current applications, co-firing has been found to increase 

PM emissions. In this pathway, an ESP will be an important 

component in collecting particulates from the flue gases. 

Pathway #3: Power Plant—Electricity (coal)

This technology pathway utilizes bituminous coal, which is the 

most abundant type of coal in the United States. It is second 

highest in energy output (after anthracite). The coal is used in a 

direct combustion furnace. The hot gases created in the furnace 

travel upward to the boiler to heat water and convert that into a 

steam. The steam then moves into a condensing steam turbine, as 

used in Pathway #1. The spinning turbine creates electrical energy.

An ESP is used in this pathway to capture particulates.

Pathway #4: Power Plant—Electricity (natural gas)

This pathway utilizes natural gas. Natural gas is composed mostly 

of methane, has drastically more energy per unit than either oil or 

propane, and emits lower amounts of nitrogen oxides and carbon 

dioxide than oil or coal. In this pathway, it is combusted directly 

to create steam using simple cycle technology representative of 

most existing gas-fired systems. The steam moves to a gas turbine, 

also known as a combustion turbine. Three steps are involved 

in this process. First, incoming air gets compressed to a very 

high pressure. Then, the combustor burns the fuel, producing a 

high-pressure, high-velocity gas. As the gas moves through the 

combustion chamber, it spins the turbine that creates electricity. 

No emissions control equipment is associated with this technology pathway.

Pathway #5: Thermal Energy (cordwood)

Green wood with bark is used in this pathway in the form of 

cordwood. Firewood is commonly measured in units of cords 

which are a measure of volume, not weight. A standard cord of 

stacked wood is equal to the amount of wood in a four foot by 

four foot by eight foot stack (this is equivalent to 128 cubic feet). 

The energy content of cordwood can vary widely based on species 

and moisture content. It is very important to note that cords are 

also used as a volume measure of roundwood and this roundwood 

cord measure is different (a cord of roundwood is only 85 cubic 

feet, compared to 128 cubic feet of cordwood). This difference 

between the two measures is due to less air space between pieces 

of cordwood that are cut, split, and neatly stacked. 

The cordwood is loading by hand and combusted directly in a 

traditional boiler, such as may be found in a home’s basement or 

possibly even an outdoor boiler. This boiler heats water which is 

used for domestic water and heating purposes (thermal energy) 

in a residential setting. 

Pathway #6: Thermal Energy (cordwood)

This pathway also utilizes cordwood but is combusted in an EPAcertified boiler in a residential setting. These boilers combine high 

efficiency combustion with hydronic thermal storage. The hot 
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A fabric filter or baghouse will collect the particulates to lower 

the emission rates.

Pathway #9: Thermal Energy (heating oil)

This pathway involves the direct combustion of residual heating 

oil, which includes number 5 and 6 heating oils. These are often 

referred to as “heavy oils” because they are what remain after 

gasoline and distillate oils have been extracted in the distillation process. This oil is laden with high amounts of pollutants, 

sulfur dioxide being one of the greatest. Residual oil has a high 

viscosity so before it can be used in a boiler, it must be heated so 

that it flows more smoothly. Once this has been achieved, the 

oil gets combusted directly in a furnace where it heats water for 

thermal applications.

No emissions control equipment is associated with this technology pathway.

Pathway #10: Thermal Energy (natural gas)

This pathway involves the direct combustion of natural gas. The 

gas is combusted in a furnace where it heats water for thermal

applications.

No emissions control equipment is associated with this technology pathway.

Pathway #11: CHP—Electricity (green wood)

In this pathway, the green wood with bark goes through direct 

combustion in a fluidized bed (as described in Pathway #1). In this 

pathway, the high-pressure steam moves through to the second 

part of the process that is in a backpressure steam turbine. The 

steam enters the turbine where it expands. During expansion, 

some of its thermal energy is converted into mechanical energy 

that runs an electrical generator. The low pressure steam that 

exits the turbine returns to the plant to satisfy thermal applications. As backpressure turbines satisfy both process and heating 

requirements, they are ideal for combined heat and power (CHP) 

applications that are far more efficient than electrical energy 

production alone. 

An ESP will serve as the pollution control equipment to remove 

particulates from the air.

Pathway #12: Gasifier—Electricity (green wood)

In this pathway, the green wood with bark is used to create a 

producer gas using the process of gasification. Gasification is a 

thermo-chemical process that converts solid fuel materials into 

combustible gases that can then be used for heat and power. 

When biomass is heated with a fraction of what is needed for 

efficient combustion, it gasifies into the interim product, a 

mixture of carbon monoxide and hydrogen—synthesis gas or 

syngas or producer gas. Combustion occurs as a result of mixing 

oxygen with hydrocarbon fuel. Because gaseous fuels mix with 

oxygen more easily than liquid fuels, which in turn mix more 

easily than solid fuels, syngas inherently burns cleaner and more 

water storage aids in increasing the system’s efficiency because 

the boiler does not have to operate during times of low-load as 

long as enough thermal storage is available to meet the demand. 

Pathway #7a: Wood Pellets (green wood)

This technology pathway produces pellets and is fueled by green 

wood with bark. The wood is processed so that it can go through 

the drying and densification process, in which the air is expelled 

from the wood at very high pressures and then formed into pellets. 

Natural plant lignin in the pellet material is melted during the 

extrusion process and holds the pellets together without glues or 

additives. Pellets have significantly lower moisture content than 

the woodchips from which they were created (six percent versus 

an average of 40 percent, respectively) which means they produce 

greater Btus per unit. This pathway, combined with 7b, represent 

the full energy implications of using pellets from forst, through 

production and combustion of pellets.

Pathway #7b: Thermal Energy (pellets)

After the densification of green wood with bark to create pellets, 

the process in this pathway is to use direct combustion to burn 

the pellets to create thermal energy. This combustion occurs in 

the furnace in which the pellets come in direct contact with the 

fire. The purpose of biomass burner technologies is to get all of the 

carbon in pellets to react with oxygen in the air to make carbon 

dioxide. As this is an exothermic reaction, it will generate a lot 

of heat. The challenge here is to convert all the carbon and get 

maximum heat. When the flue gas travels out of the furnace, 

water captures the heat and is then piped throughout the building 

or number of buildings for heating and domestic hot water. The 

water used for heating the air is then piped back to the furnace 

to be re-heated and looped out again. 

The emission control device utilized in this pathway is a cyclonebaghouse combination. With the correct design and choice of 

fabric, particulate control efficiencies of over 99 percent can 

be achieved even for very small particles (one micrometer or 

less) by fabric filters or baghouses. The lowest emission rate for 

large wood-fired boilers controlled by fabric filters reported is 

0.01 lb/MMBtu. For large thermal-only applications (boilers 

over four to five MMBtu), a baghouse is usually sufficient to 

handle particulate matter (PM) control (along with a multicyclone which is generally included with the boiler by the 

manufacturer). Considered with Pathway 7a, this represents an 

application using pellets at the commercial scale, from forest 

to combustion.

Pathway #8: Thermal Energy (green wood)

This technology pathway is fueled by green woodchips with bark 

and undergoes direct combustion in a fluidized bed (as described 

in Pathway #1). The interim product is hot water (and not high 

pressure steam). The water in the boiler will capture the heat 

from the combustion chamber and will then be piped through 

the building for heat and hot water, or thermal energy. The cold 

water will be piped back to boiler.
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Pathway #16: Bio-oil & Bio-Char (green wood)

In this Pathway, green wood with bark undergoes a primary process 

of pyrolysis at a bio-refinery. Pyrolysis is the rapid chemical decomposition of wood in the absence of oxygen, and occurs spontaneously when the temperature is high enough. This process breaks 

the wood down into a gas, liquid (bio-oil), and a solid (Biochar). 

By rapidly decomposing the biomass at high temperatures, it will 

result in a greater amount of bio-oil whereas slow pyrolysis will 

produce Bio-Char. Bio-oil can be substituted for conventional 

liquid fuels, and while it contains roughly 54 percent the heating 

value of #6 fuel oil (Innovative Natural Resource Solutions, 2004), 

its benefit is that it is sourced from a renewable resource rather 

than a non-renewable fossil fuel. 

As bio-oil can be substituted for conventional fuels, it can be 

burned in a furnace to heat water for thermal energy applications. 

This pathway utilizes an ESP as its emissions control equipment.

Pathway #17: Bio-products (green wood)

This pathway also utilizes green wood with bark to create a 

syngas through the process of gasification. Syngas is composed 

of hydrogen and carbon monoxide. The Fischer–Tropsch process 

(or Fischer–Tropsch Synthesis) is a set of chemical reactions that 

convert a mixture of carbon monoxide and hydrogen into liquid 

hydrocarbons. The process, a key component of gas-to-liquids 

technology, produces a petroleum substitute, typically from 

biomass for use as synthetic lubrication and as synthetic liquid 

fuel, such as ethanol. Electricity is also created by combusting 

lignin, the by-product of ethanol production.

An ESP is used to remove the particulates from the air exiting 

the plant.

Pathway #18: Gasification—Cellulosic Ethanol (green wood)

In technology pathway #6, green wood with bark undergoes a 

primary process of fast pyrolysis at a bio-refinery. The bio-oil

produced from fast pyrolysis can be used to produce a variety 

of bio-products, such as plastics, glues, organic fertilizers, and 

fuel additives.

efficiently than the solid biomass from which it was made. One 

advantage of gasification technology is that it is a decentralized 

energy conversion system that operates economically even when 

used in small-scale applications. Although the technology is 

currently not commercially available in the United States, it 

has proven to be economical in many locations. 

The producer gas is then used in an internal combustion engine

to power a generator. The generator spins to create electrical 

energy while waste heat from both the gasifier and the internal 

combustion engine can be captured and used as thermal energy, 

thereby creating a CHP system. 

Pathway #13: CHP—Electricity (heating oil)

Residual heating oil is combusted directly, in this pathway, to create 

steam. This pathway differs from the former because the steam 

moves through to a backpressure steam turbine. As backpressure 

turbines create both electrical and thermal energy, they are ideal 

for CHP applications that are far more efficient than electrical 

energy production alone. 

No emissions control equipment is associated with this technology pathway.

Pathway #14: CHP—Electricity (natural gas)

In this technology pathway, natural gas is combusted directly 

to create steam. The steam travels to a backpressure steam 

turbine as described in Pathway #11. The electricity produced 

by the spinning generator and the over-pressurized steam that 

satisfies thermal applications at the plant fulfills the CHP

component.

No emissions control equipment is associated with this technology pathway.

Pathway #15: Cellulosic Ethanol (green wood)

In order to create ethanol, green wood with bark goes through a 

primary process of hydrolysis and fermentation (ERRE, 2009). 

This is a multiple step process. First, sulfuric acid is mixed with 

the woodchips at which point a hydrolysis reaction occurs. Here, 

the complex chains of sugars that make up the hemicellulose 

in the wood get broken and release simple sugars. Later in the 

process, what cellulose remains gets hydrolyzed into glucose. This 

glucose then goes through the fermentation process, in which 

microorganisms convert it to ethanol. 

As a by-product of ethanol production, lignin can get combusted 

directly to produce the electricity required for the production 

process, or, since more electricity is generally created than is 

needed, selling the electricity may help the process economics.

An ESP can be applied to the furnace in which the lignin is 

burned to reduce PM emissions.
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This pathway utilizes an ESP as its emissions control equipment. 
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Appendix 2-B: Technology Pathways Summary

Technology Pathways Summary Table

Orange = Formulas

Yellow = Typical Values assumed by BERC

Green = Calculated Values

Blue = Values taken from References

References (identified by cell)

Published Data by Biomass Power Plant: J5, K5

NREL: J7, K7, J11, K11, J13, K13

Published data by vendors: J15, K15, J18, K18, J21, K21, J23, K23, J26, K26, J28, K28,J30, K30, J32, K32, J35, K35, J38, K38, J41, 

K41, J46, K46, J48, K48, J50, K50

EERE, DOE: J44, K44

Calculated based on conversion of all carbon to carbon dioxide: P5, P7, P15, P18, P21, P23, P26, P32, P35, P44, P46, P48, P50

EIA: P8, P11, P13, P28, P30, P38, P41

Conversion Factors and Assumptions

1) 1 MWH = 3.412 MMBtu

2) High Heating Value of cellulosic ethanol = 84,100 (DOE)

3) High Heating Value of Bio-oil = 71,200 (DOE)

4) High Heating Value of Wood pellets (dry basis) = 17 MMBtu/ton (BERC)

5) High Heating Value of Wood chips (dry basis) = 17 MMBtu/ton (BERC)

6) High Heating Value of Coal = 10,506 Btu/lb (DOE)

7) High Heating Value of Natural Gas = 1,028 Btu/cubic ft.(DOE)

8) High Heating Value of #6 oil = 152,000 Btu/gallon(DOE)

9) 1 lb. Carbon = 3.6667 lbs CO2

10) From Cell K12: co-firing with 20% biomass

NREL: Life Cycle Assessment of Coal Fired Power Production by Pamela L Spath & others at http://www.nrel.gov/docs/fy99osti/25119.pdf

EERE, DOE: Theoretical Ethanol Yield Calculator http://www1.eere.energy.gov/biomass/ethanol_yield_calculator.html

EIA: U S Energy Information Administration Independent Statistics and Analysis Voluntary Reporting of Green House Gases 

program (Fuel & energy Source Codes & emission coefficients) www.eia.doe.gov/oiaf/1605/coefficients.html
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 Appendix 2-C

Affordable Price of Biomass—Calculation Assumptions
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Appendix 3-A

Review of Previous Studies of 

Massachusetts Biomass Availability

In the past few years, the Massachusetts Sustainable Forest 

Bioenergy Initiative has funded two studies that address forest 

biomass availability in Massachusetts: Silvicultural and Ecological 

Considerations of Forest Biomass Harvesting in Massachusetts 

(Kelty, D’Amato, and Barten, 2008) and Biomass Availability 

Analysis—Five Counties of Western Massachusetts (Innovative Natural Resource Solutions (INRS), 2007). Here we review 

the components of these studies that focus on forest biomass, 

considering both their methodologies and results.

The general approach to forest biomass fuel used in these two 

studies is quite similar: both studies estimate net forest growth 

over an operable land base and equate this volume to biomass 

availability; thus, they assess how much wood could be harvested 

on an ongoing basis so that inventories do not decline below 

current levels. However, there are several important differences 

in the methods and details of implementing this approach and 

comparing their results with each other is not straightforward.

As will be seen in the following discussion, the data provided by 

Kelty et al. (2008) are presented in a manner that is most directly 

comparable to our own analysis. Kelty et al. (2008) provides two 

estimates of forest biomass availability on private lands to cover 

the wide range of potential responses by private landowners. The 

average of these two estimates is 750,000 green tons per year. 

When compared with our analysis, this average is consistent with 

our estimate of biomass supply at high biomass stumpage prices 

(the High-Price Biomass scenario). Kelty et al. (2008) is focused 

on forest growth and does not consider harvesting costs, energy 

prices, or general operational issues. This suggests that the biomass 

availability estimates provided by Kelty et al. would be reasonable estimates of supply only if bioenergy plants pay substantially 

higher prices for wood than in current markets.

Our adjustment of the INRS (2007) estimate to a statewide 

total suggests that biomass availability in Massachusetts would 

be about 1.4 million green tons per year. However, given the 

assumptions in this study, it is not clear how to adjust these 

estimates for sawtimber volumes and the split between private 

and public lands. Based on our review of this analysis, it would 

seem that the appropriate range for only biomass fuel on private 

lands would be about half of this volume, which suggests about 

700,000 green tons, similar to the average of Kelty et al. (2008).

Review of “Silvicultural and Ecological 

Considerations of Forest Biomass Harvesting 

in Massachusetts”

The portion of this report that is focused on statewide biomass 

availability states that the question is: “what is the total annual 

sustainable harvest from Massachusetts forests (that is, the total 

annual harvest that would not exceed the total annual [net] forest 

growth)?” The report states that the intention was to assess the 

biomass levels that “exist in Massachusetts forests” on land that 

is “likely to be involved in timber harvesting.” The report also 

provides a detailed analysis of biomass availability at the stand 

level, however, this analysis appears to be independent of the 

statewide analysis and have no influence on those results.

The methodology consists of three basic steps: 1) calculate average 

per-acre growth rates for timber stands in Massachusetts, with private 

and public lands evaluated separately; 2) identify the acreage available for harvesting; 3) adjust this total volume growth to separate 

sawtimber from other standing wood. These steps are described in 

more detail below and some key data are shown in Exhibit 3A-1.

Growth rates were developed on the basis of 50-year projections using 

the Forest Vegetation Simulator for the Northeast. The mean value of 

this time period was used as a measure of the growth rate in the future.

Two scenarios were established for private land areas because of 

the difficulty in predicting harvest activity among private landowners: one included all lands in size classes greater than or equal 

to 10 acres, while the other included only land greater than or 

equal to 100 acres. These two groups of private forest land areas 

were then reduced by 7% due to operational constraints such as 

terrain and wetland areas. Private lands were further reduced by 

30% to adjust for landowners that were assumed would not be 

willing to harvest their lands for timber production.

Public forest land areas were reduced for operational constraints 

only. The reduction was 7%, the same as for private lands.

Total annual volumes of sustainable wood harvest were then 

calculated by multiplying growth per-acre growth rates times 

the number of acres available in each case. These data were then 

adjusted downward by 36% to account for timber that would likely 

be removed for sawtimber and not available to bioenergy facilities.

Results are presented ion Exhibit 3A-1. “Sustainable” biomass 

availability was estimated to be about 500,000 green tons per 

year from public lands. For private lands, annual volumes ranged 

from 400,000-to-1.1 million green tons. Thus, the combined 

statewide total for biomass availability was estimated to range 

from 900,000-to-1.6 million green tons per year.

Exhibit 3A-1: Calculations for Biomass Availability Based 

on Kelty et al. (2008)

Public Private

 ≥ 100 acres ≥ 10 acres

Growth (dry tons/acre) 0.94 0.89 0.89

Growth (green tons/acre) 1.71 1.62 1.62

Net Land Area (acres) 465 379 1,073

Total Volume Growth (gt/yr) 795 614 1,736

Biomass Fuel Only (gt/yr) 509 393 1,111

Note: Data for dry tons and land areas taken directly from Exhibit 

3-10 in Kelty et al. (2008). Data for green tons have been calculated 

assuming 45% moisture content.
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Review of “Biomass Availability Analysis—Five 

Counties of Western Massachusetts”

The INRS (2007) report is comprehensive in its coverage of a 

wide range of sources of woody biomass. It is focused on the five 

western “core” counties of Massachusetts (Middlesex and Norfolk 

counties also are included as buffer counties, but are not reported 

separately from the buffer region). As above, we focus only on the 

portion of this study that addresses forest biomass.

This study considers forest biomass growth and forest residues

separately. Forest biomass growth is estimated using net growth 

and removals from FIA data along with an adjustment factor for 

the growth of tops and branches. Net growth less removals results 

in estimated annual growth of 1.9 million green tons for western 

Massachusetts This volume is then reduced by half: “because 

of landowner constraints, access issues, economic availability, 

nutrient concerns and the need to harvest less than growth to 

address landscape-level forest sustainability concerns, INRS 

suggest that half of this wood be considered actually ‘available’ 

to the marketplace” This leaves a total of 960,000 green tons per 

year of biomass availability. An additional 110,000 green tons of 

forest residue are estimated to be available in this region (based on 

TPO data), resulting in an annual total of 1.1 million green tons.

These estimates do not consider the share of wood that might be 

used for sawtimber. The INRS report indicates that their estimate 

likely overstates the availability of forest biomass for this reason and 

others: “In practical terms, it is highly unlikely that this volume 

of wood could be harvested in an economic or environmentally 

responsible manner to supply biomass fuel. Further, some of this 

wood is sawlogs or other high-value material, and as such would 

be sent to other markets.”

We have attempted to put these estimates on a basis that is comparable to the Kelty et al. (2008) analysis by adjusting them to 

the state level (growth and forest residues are not considered 

separately because of the small residue share). There are several 

alternatives for increasing these data from the western region to 

the state total, but it is not obvious which method would be most 

appropriate. Relative measures of timberland area, timber inventory, and growth-drain ratios result in expansion factors ranging 

from 20% to 40%. Thus, the total for biomass availability would 

be increased to 1.3-to-1.5 million green tons per year.

These estimates are close to the high end of the range (1.6 million 

green tons) provided by the Kelty et al. (2008). However, it is 

unclear how to adjust these estimates for potential sawtimber 

volumes. Kelty et al. (2008) project total net growth and then 

subtract the sawtimber component, whereas the INRS report 

projects “net growth less removals” so the growth estimates 

already partially reflect an adjustment for sawtimber. In addition, for purposes of comparison, it would be useful to separate 

the INRS volumes by private and public ownerships; however, 

the analysis reduces net growth on all forest lands by 50% and 

there appear to be no explicit assumptions regarding the mix of 

wood available from the two ownerships.
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that are consistent with the TPO methodology, we have applied 

the timber utilization matrices underlying the TPO estimates to 

their estimates of roundwood harvests.

According to the production data from the TPO reports, industrial roundwood production in Massachusetts is comprised 

of essentially two “products,” sawlogs and pulpwood. (“Other 

industrial products” is a third category and accounts for 1% of 

the industrial roundwood total).4 The volume of logging residues 

generated per unit of roundwood production is shown in Exhibit 

3A-1. Logging residues from softwood harvests are less than for 

hardwoods because of differences in tree geometry and differences 

in end-use markets and products. Logging residues for pulpwood 

are less than for sawlogs because of the ability to utilize a higher 

proportion of the main stem.

The TPO data for Massachusetts in 2006 indicate that sawlogs 

accounted for 87% of the industrial roundwood production, 

and that softwood accounted for 60% of the sawlog production. 

Applying the coefficients in Exhibit 3B-1 to these data suggest 

that logging residues totaled 4.27 million cubic feet in 2006, or 

50% of roundwood production. This implies that approximately 

128,000 green tons of logging residues were generated in 2006 

(using a conversion of 30 green tons per thousand cubic feet).

Exhibit 3B-1: Logging Residue Generation in Massachusetts

By Product and Species Group

(cubic feet of logging residues per cubic foot of roundwood)

Softwood Hardwood

Sawlogs 0.43 0.67

Pulpwood 0.36 0.56

Source: Personal communication with USFS.

Importantly, these data appropriately measure only unutilized 

residues—wood left behind after a logging operation—and thus 

would be the correct measure of the total volume of residues that 

could be available for biomass. However, as noted earlier, a closer 

look at these data suggests that a significant share of this material 

can be attributed to breakage or residual stand damage, and thus 

could not be transported to a landing during a harvesting operation. For this reason, it is often assumed that 50% of “logging 

residues” are recoverable. Using this assumption, 64,000 green 

tons of logging residues would have been available for biomass 

supply in 2006.

Concerns about the TPO data and with implementing those 

estimates in a manner that is consistent with our projection and 

harvesting methodology have led us to a second approach: estimation of logging residue generation by calculating the volume of tops 

and limbs associated with harvesting trees of varying diameter 

4 There is also a large volume of fuelwood production; in fact, the 

volume is substantially higher than industrial roundwood production. 

However, the TPO methodology assumes that residential fuelwood 

harvests do not contribute to logging residues.

Appendix 3-B

Logging Residue Data and Estimation

Although estimation of this supply would seem to be straightforward, problems with logging residue data make it difficult to 

estimate both the total volume of residues that are generated as 

well as the share that is recoverable. Some of these problems are 

general conceptual issues, while others are specific to the Northeast 

and/or Massachusetts. An important issue relates simply to the 

definition of logging residues. Logging residues are not defined 

by the parts of a tree, but by what is left behind in the forest after 

a site has been logged. In addition to the obvious candidates for 

unused material after felling, such as crowns and branches, trees 

that have been killed or damaged during a logging operation are 

considered to be part of logging residues.1 Thus, this becomes 

a difficult empirical issue because harvesting is dynamic and 

logging residues will change and evolve with technology, timber 

demand, and relative costs and prices. Once utilized, the material 

no longer conforms to the definition of logging residues and this 

can be a source of confusion.

Another important problem with logging residue data is that the 

parameters used to derive these estimates are from mill and timber 

utilization studies that are dated. The primary source of logging 

residue data in most studies is the Timber Products Output (TPO) 

reports from the U.S. Forest Service. These reports contain data 

on both softwood and hardwood residues and are disaggregated 

to the county level.2 In the Northeast, these studies were last 

conducted in 1985, and thus do not reflect current utilization 

standards, prices, costs, and technologies. In addition, the calculation of logging residues requires a combination of surveys, each 

with its own problems and sampling errors. These problems are 

likely to be more serious in small states (where interstate trade is 

important) because wood flows and sourcing patterns can change 

substantially over time.

As it turns out, the logging residue data reported by TPO for 

Massachusetts could not be used because the on-line program 

generates the data incorrectly.3 In order to generate logging residues 

1 According to Forest Resources of the United States, 2002 (Smith 

et al.), logging residues are defined as: “The unused portions of 

growing stock and non-growing stock trees cut or killed by logging 

and left in the woods.” This includes material that is sound enough 

to chip (and excludes rotten wood), downed dead trees, and downed 

cull trees. Material that has been badly damaged during logging but 

is still standing should be included in logging residues; however, the 

definitions are confusing in this regard.

2 The reports are available on-line (www.fia.fs.fed.us/tools-data/

other/) and can be accessed on the National Renewable Energy 

Laboratory website.

3 The on-line TPO program reports that 8.451 million cubic feet 

of industrial roundwood products were produced in Massachusetts 

in 2006. The same number is reported as the total for “Logging 

Residues” and also for “Mill Residues.”
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classes. From a biomass perspective, this approach provides a more 

useful estimate of “logging residues” since this material has a much 

better chance of being delivered to a landing at a reasonable cost 

using whole-tree harvesting methods.5

Exhibit 3B-2 shows the average volume of tops and limbs as a 

share of the merchantable tree volume in the standing inventory of 

live trees in Massachusetts. These data suggest that for all species 

combined, reasonable estimates of “logging residues” generated 

would be about 22%, on average, for sawtimber harvests and 35% 

for pulpwood. Thus, using the same data on industrial roundwood 

production as above (from TPO for 2006), logging residues 

would have been about 2.0 million cubic feet, or 60,000 green 

tons. Given that this material could be moved to a landing more 

easily because it consists strictly of tops and limbs, the recovery 

rate of this material for biomass fuel use could be considerably 

higher than 50%.

Exhibit 3B-2: Volume of Tops and Limbs as a Share of 

Merchantable Tree Volume

Based on Massachusetts Inventory Data, 2008

DBH, inches Share

5.0–6.9 38%

7.0–8.9 31%

9.0–10.9 27%

11.0–12.9 24%

13.0–14.9 22%

15.0–16.9 21%

17.0–18.9 19%

19.0–20.9 18%

21.0–22.9 18%

23.0–24.9 17%

Source: Based on USFS, FIA data. DBH is tree diameter measured at 

breast height (4.5 feet above ground level).

5 One shortcoming of this approach is that it is not possible to 

estimate how much of this topwood and limbwood may already be 

being utilized due to differing utilization standards for products, or 

for harvests of firewood.
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by landowners cutting for their own use. We have assumed that 

forest biomass harvests are unlikely to be integrated with harvests 

of residential fuelwood due to: 1) the number of acres cut in a 

typical fuelwood harvest; 2) the volume of logging residue left 

behind on each acre; and 3) the type of equipment used in these 

logging operations.

Appendix 3-C

Firewood Data

Fuelwood is by far the largest market for timber cut in Massachusetts, but fuelwood data are poor because the market is unregulated 

with large numbers of consumers and producers, and there is a 

large personal use sector where consumers cut their own wood. The 

FCPs show some data on fuelwood harvests, but these numbers 

are small and only pertain to volumes that are associated with 

larger-scale commercial-based harvesting. The large majority of 

fuelwood cut in Massachusetts is not registered in these plans.

The Timber Product Output reports provide one estimate of 

fuelwood production in Massachusetts; however, these data are 

derived from U.S. Census data rather than collected directly from 

U.S. Forest Service surveys (the source of other TPO data). TPO 

data indicate that fuelwood production in Massachusetts in 2006 

was 41.3 million cubic feet (517,000 cords or 1.3 million green 

tons), which would suggest that it would have accounted for about 

83% of the timber harvest in Massachusetts (see Exhibit 3C-1.) 

According to this report, virtually all of the fuelwood comes from 

non-growing stock sources, which includes cull trees (rough and 

rotten), dead trees, tops and stumps of growing stock trees, and 

non-forestland sources of trees such as yard trees.

Exhibit 3C-1: Fuelwood Production in Massachusetts, 2006

Million Cubic Feet

Industrial Fuelwood Total Fuelwood 

(cords)

Growing Stock 7.0 1.2 8.2 15

Non-Growing Stock 1.5 40.1 41.6 502

Total 8.5 41.3 49.8 517

Source: TPO Reports (USDA, FS).

Unlike the data on industrial roundwood products, the data on 

fuelwood have not been collected by the USFS since some time 

prior to 1980. Since then, the data have been collected by Energy 

Information Administration as part of their Residential Energy 

Consumption Survey. These data are surveyed at the Census 

division level and allocated to individual states on the basis of 

the total number of housing units. In the case of Massachusetts, 

this methodology clearly overstates fuelwood consumption since 

Massachusetts accounts for about half of the housing units in 

New England. For example, in 2007, New England consumption was estimated to be about 927,000 cords, and 439,000 cords 

were allocated to Massachusetts. Prior to the time when this 

methodology was adopted, Massachusetts share of New England 

fuelwood consumption was only 35% in 1975 (and jumped to 

49% when housing units were used as the basis of the allocation).

An important question in assessing biomass supplies in Massachusetts is how the residential fuelwood sector might interface with 

an expanded harvest of forest biomass fuel. Fuelwood is typically 

harvested in relatively small volumes and on small areas, often 
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The Relationship of Timber Harvest to 

Inventory Levels

A key metric that is often used to measure tightness in the timber 

market is the ratio of timber harvest to timber inventory (FIA data). 

We have compiled these estimates for the three New Hampshire 

regions to see if they provide any additional information about 

harvest potential (see Exhibit 3D-1). The cut-to-inventory ratio 

statewide is 1.1% (as noted in the table, the harvest data do not 

include residential fuelwood and logging residues which would 

likely move this ratio closer to 1.5%). These ratios decline as one 

moves from north to south: the ratio is 1.3% for the northern 

counties, 1.1% for the central counties, and 0.9% for the southern 

counties. As might be expected, timber inventories are growing 

more slowly in the central and northern areas. In fact, harvesting in 

the north has outpaced growth and timber inventories on private 

lands have declined an average of 500,000 green tons per year 

according to FIA estimates. These higher rates of harvesting in 

the north are also reflected in stocking levels which we estimate 

to be only 50 green tons per acre on private lands in the north, 

compared to 66 tons/acre in the central region, and 75 tons/acre 

in the south.

These data seem to suggest that if there are opportunities for 

expansion in New Hampshire, they may lie in the south. However, 

one cannot draw this conclusion on the basis of cut/inventory 

ratios or stocking levels alone unless the land in the inventory is 

similar and managed the same way. For example, it is common 

to see high cut/inventory ratios for industrial land ownerships 

(there are forest industry lands in northern New Hampshire) and 

lower cut/inventory ratios on non-industrial private lands where 

timber production may not be the most important objective of 

landowners.

Exhibit 3D-1: Harvest Ratios in New Hampshire

000 Green Tons and Percent

Harvest Cut/Inv

New Hampshire 3,238 1.1%

North 1,731 1.3%

Central 809 1.1%

South 698 0.9%

Notes: Harvest data is the average for 2000−2006 and includes sawlogs, 

pulpwood, fuelwood, and whole-tree chips. “Cut/Inv” is the ratio of harvest 

to growing stock on private and public timberland. Harvest data exclude 

residential fuelwood and logging residues and thus understate timber 

removals.

In spite of low cut/inventory ratios and expanding timber inventories in the southern counties of New Hampshire, the harvesting 

data have shown the south’s position as a timber producer has 

been relatively stable. The southern counties are not growing in 

an absolute sense, nor have harvest levels increased relative to 

the central or northern areas. Importantly, we have also seen 

that whole-tree harvesting is already prevalent in southern New 

Hampshire. Thus, opportunities for expansion as part of integrated 

Appendix 3-D

A Closer Look at Biomass Potential 

in Southern New Hampshire

The analysis of inventories, industry location, and landowner 

attitudes in this report suggests that the border counties in New 

Hampshire, Vermont, and New York hold the most potential for 

increasing supplies of forest biomass. The New Hampshire border 

zone is the largest of these areas and the one with perhaps the 

best data. Here we look more closely at recent historical harvests 

(New Hampshire Report of Cut, 2008) and prices trends (New 

Hampshire Timberland Owner’s Association, Timber Crier) in 

New Hampshire to see if there are any patterns that suggest than 

an expansion of timber production looks likely.

Timber Harvest Trends

In New Hampshire, the sawlog harvest declined from 2000 

to 2006, with most of the decrease occurring by 2003. This is 

somewhat surprising given the strength of the housing market 

during this period. Part of this decline was offset by an increase 

in pulpwood and fuelwood harvest. Whole-tree chip production 

was fairly stable over these seven years, averaging about 800,000 

green tons per year, equivalent to about 25% of New Hampshire’s 

roundwood harvest.6

The harvest in the three counties of southern New Hampshire has 

been fairly stable as a share of the total cut in the state, fluctuating in 

the range of 20%−23% during 2000−2006. Similar to overall state 

trends, sawlog production declined (from 400,000 green tons in 2000 

to 300,000 green tons in 2006), while pulpwood rose and wholetree chip production remained steady at about 230,000 green tons.

Several aspects of these trends have implications for our analysis: 

1) in spite of rising timber inventories in New Hampshire, recent 

harvest levels have been declining; 2) the southern counties share 

of the harvest has been stable; 3) in the southern counties, wholetree harvests have been stable as a share of the overall harvest.

Overall trends do not show New Hampshire as a state that is 

expanding its forest products industries and its harvest levels. In 

general, this is not a positive trend for a bioenergy industry that 

is thought to have it biggest advantage when its raw material 

comes from integrated harvests that depend on other commercial products. Also, the southern share of state harvests has been 

stable: if the share were rising, one might have some evidence 

that the region has some competitive advantage, possibly in the 

area of wood supply.7

6 Similar to Massachusetts, harvesting of fuelwood does not need to 

be reported if the volume is considered to be small and for personal 

use. For New Hampshire, this maximum volume is set at 20 cords.

7 When sawlog production declines, the production and availability 

of mill residues will also decline (assuming sawlogs are milled 

in the “home” market). This is another factor that has negative 

consequences for biomass fuel supply.
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References

Innovative Natural Resource Solutions LLC. 2007. Biomass 

Availability Analysis—Five Counties of Western Massachusetts.

Kelty M.J., D’Amato A.W., and Barten P.K. 2008. Silvicultural 

and Ecological Considerations of Forest Biomass Harvesting in 

Massachusetts. Department of Natural Resources Conservation, 

University of Massachusetts, Amherst, MA.

New Hampshire Report of Cut. 2008. Summary data generated by 

Matt Tansey, New Hampshire Division of Forest & Lands.

New Hampshire Timberland Owner’s Association. Timber Crier. 

Various issues.

New Hampshire Timberland Owner’s Association. 2010. Website: 

www.nhtoa.org.

Northeast State Foresters Association. 2007a. The Economic 

Importance and Wood Flows from the Forests of Maine, New 

Hampshire, Vermont and New York, 2007.

Northeast State Foresters Association. 2007b. The Economic 

Importance and Wood Flows from Vermont’s Forests, 2007.

University of Massachusetts Amherst. 2008. Southern New England 

Stumpage Price Report. MassWoods, maintained by Paul Catanzaro. 

www.masswoods.net/sne_stumpage/

U.S. Department of Agriculture, Forest Service. Forest Inventory and 

Analysis National Program. Forest Inventory Data Online: www.fia.

fs.fed.us/tools-data.

U.S. Department of Agriculture, Forest Service. Timber Product 

Output Mapmaker Version 1.0. On-line software for the Timber 

Product Output Database Retrieval System (TPO). www.fia.fs.fed.

us/tools-data/other/

Vermont Department of Taxes. 2010. Annual Report. Division of 

Property Valuation and Review.

Vermont Forest Resource Harvest Summary. Various years. Vermont 

Department of Forests, Parks & Recreation.

operations might be more limited than in other border zones 

where whole-tree harvesting is much less common.

Prices and Pockets of Opportunity

The final measure we consider—perhaps the single best indicator—

is relative pricing. In a market in equilibrium, prices will track 

together. If prices deviate from the overall trend, particularly if 

they are drop lower at times, this may be due to weaker demand 

and might be an indicator that more timber can be harvested 

with the region remaining competitive. In Exhibit 3D-2, we have 

compared white pine sawtimber stumpage prices for the three 

regions of New Hampshire. We selected white pine because it 

accounts for about 50% of the sawtimber harvest and is widely 

distributed through the state (spruce/fir is the next largest species 

group with 13%, but it is almost entirely produced in the northern 

zone). We selected sawtimber because: 1) biomass is generally 

expected to be a follower of higher-valued commercial harvest; 

and, 2) biomass stumpage prices can easily diverge within regions 

because they are such a small share of total delivered costs.

Prices for white pine sawtimber stumpage in southern New 

Hampshire fall right in line with those in the central region 

suggesting that the buyers of wood can access both areas on an 

equal footing; hence the south would not appear ripe for greater 

expansion relative to other New Hampshire regions. The north is 

a bit more erratic, dropping below the southern price at times and 

for an extended period in 1997−2000. The data do not suggest 

any obvious gaps in the south that would be an incentive to build 

new capacity; in fact, the data suggest that such opportunities may 

have existed in the north during the 1990s. Although forests in 

the north have been cut more intensively than elsewhere in the 

state, prices have not moved higher suggesting that overall pressures on the resource remain similar in the three regions when 

ownership, attitudes, management objectives and other variables 

are taken into account.

Exhibit 3D-2: White Pine Sawtimber Stumpage 

Prices in New Hampshire

Dollars per 1,000 board feet International log rule

Source: New Hampshire Timberland Owner’s Association, Timber Crier, 

various issues: mid-range stumpage prices.
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Appendix 4–A

Ecology of Dead Wood in the 

Northeast

Alexander M. Evans and Matthew J. Kelty

Table of Contents

1. Introduction............................................................................139

2. Ecology of Dead Wood in the Northeast.......................139

2a. Dead Wood and Stand Development............................139

2b. Wildlife and Biodiversity..................................................140

2c. Soil Productivity..................................................................141

2d. Quantities of Dead Wood................................................142

3. Research by Forest Type......................................................142

3a. Spruce-Fir Forests................................................................143

3b. Northern Hardwood Forests...........................................144

3c. Transition Hardwood Forests..........................................144

3d. White Pine and Red Pine Forests...................................145

4. References................................................................................146

1. Introduction

Although dead wood and decaying trees have historically had little 

commercial value, they do have substantial ecological value. This 

paper reviews the scientific literature to provide the background 

necessary to craft recommendations about the amount and type 

of dead wood that should be retained in the forest types of the 

northeastern U.S. Establishing the ecological requirements for 

dead wood and other previously low-value material is important 

because of the increased interest in this material for energy and 

fuel. More intensive extraction of biomass from the forest may 

impinge on the forest’s ability to support wildlife, provide clean 

water, sequester carbon, and regenerate a diverse suite of plants. 

This background paper covers the topics of dead wood, soil compaction, nutrient conservation, and wildlife habitat in temperate forests 

generally as well as in specific forest types of the Northeast. Complex 

issues related to carbon storage in forests and the climate impacts 

of using forest material for energy and fuel are very important 

and deserve an in-depth investigation beyond the scope of this 

paper. Similarly, this paper will not discuss the state of biomass 

harvesting in the U.S. (Evans 2008, Evans and Finkral 2009) or 

existing biomass harvesting guidelines (Evans and Perschel 2009) 

which have been addressed in other recent publications.

The goal of this background paper is to provide a concise summary 

that can inform discussions about biomass harvesting standards 

in the Northeast. However, it is important to note that this document makes no suggestions about how a biomass harvest should 

be conducted or what should be left in the forest after a harvest. 

Rather we have attempted to lay out the basic science on which 

recommendations can be built.

2. Ecology of Dead Wood in the Northeast

2a. Dead Wood and Stand Development

Dead wood is important not only in terms of total volume or 

mass in a stand, but also in terms of piece size—usually measured 

as diameter at breast height (DBH) for snags (and for live trees) 

or diameter of the large end for down woody material (DWM). 

Large-diameter snags or down logs are important habitat for 

numerous animal species, persist for long periods, store nutrients, 

and provide substrate for seed germination. 

The process of dead wood accumulation in a forest stand consists 

of the shift from live tree to snag to DWM unless a disturbance has 

felled live trees, shifting them directly to DWM. The graphs below 

(Figures 1, 2, and 3) show the general pattern of the production 

of dead wood in total amount and size. The data in these graphs 

are taken from research in northern hardwood forests (Gore and 

Patterson 1986, Goodburn and Lorimer 1998, Hale et al. 1999, 

McGee et al. 1999, Nyland et al. 2000). The 4 in (10 cm) diameter size is within the range of the minimum size used in most 

coarse woody material (CWM) inventories. Fine woody material 

(FWM) refers to smaller-sized dead material. The graphs depict 

the patterns for a stand that had been harvested as a conventional 

clearcut, leaving a large amount of small woody material (nearly 

all <10 in (25 cm) diameter), but no trees >4 in (>10 cm) DBH 

and no snags. The pattern is shown from just after the clearcut 

(age 0)–age 100 years, and in the old-growth condition.

Figure 1. General Pattern of Tree Density Over Time
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2b. Wildlife and Biodiversity

Dead wood is a central element of wildlife habitat in forests 

(Freedman et al. 1996). Many forest floor vertebrates have benefited or depended on DWM (Butts and McComb 2000). In the 

southeastern U.S., more than 55 mammal species, over 20 bird 

species, and many reptiles and amphibian species were relying 

on dead wood (Lanham and Guynn 1996, Loeb 1996, Whiles 

and Grubaugh 1996) with similar numbers for the forests of the 

Pacific Northwest (Carey and Johnson 1995, McComb 2003). 

In New England, De Graaf and colleagues (1992) catalogued at 

least 40 species that rely on DWM.

Some examples of relationships between animals and DWM in 

the Northeast include a study showing that low densities of highly 

decayed logs (less than one highly decayed log/ha ) had a negative 

impact on red-back voles (Clethrionomys gapperi) in a northern 

hardwood forest in New Brunswick, Canada (Bowman et al. 

2000). DWM retention increased spotted salamander (Ambystoma maculatum) populations in a Maine study (Patrick et al. 

2006). While DWM is important habitat for red-backed voles 

in Maine, it did not effect populations at volumes as low as 543 

ft3/ac (38 m3/ha; McCay and Komoroski 2004). The quantity of 

DWM had no effect on white-footed mice (Peromyscus leucopus) 

abundance in an Appalachian study, but at the micro-site scale, 

mice were more often located near DWM (Marcus et al. 2002). 

Similarly, shrew (Tupaia sp.) showed minimal or no response 

to drastic decreases in the abundance of large logs in managed 

loblolly pine (Pinus taeda) forests of the southeastern coastal 

plain (McCay and Komoroski 2004) .

In aquatic environments, DWM provided crucial refuge from 

predation (Angermeier and Karr 1984, Everett and Ruiz 1993). 

Logs that fell in the water formed a critical component of aquatic 

habitat by ponding water, aerating streams, and storing sediments (Gurnell et al. 1995, Sass 2009). In fact, removal of large 

woody material from streams and rivers had an overwhelming 

and detrimental effect on salmonids (Mellina and Hinch 2009).

DWM is a key element in maintaining habitat for saproxylic 

insects (Grove 2002). For example, some specialist litter-dwelling 

fauna that depend on DWM appear to have been extirpated from 

some managed forests (Kappes et al. 2009). A study from Ontario 

suggests that overall insect abundance was not correlated with the 

volume of DWM, though abundance of the fungivorous insect 

guild was positively related to the volume of DWM (Vanderwel 

et al. 2006b). Extensive removal of DWM could reduce species 

richness of ground-active beetles at a local scale (Gunnarsson et 

al. 2004). More generally, a minimum of 286 ft3/ac (20 m3/ha) 

of DWM has been suggested to protect litter-dwelling fauna in 

Europe (Kappes et al. 2009).

Dead logs served as a seedbed for tree and plant species (McGee 

2001, Weaver et al. 2009). Slash could be beneficial to seedling 

regeneration after harvest (Grisez, McInnis, and Roberts 1994). 

Fungi, mosses, and liverworts depended on dead wood for nutrients 

and moisture, and in turn, many trees were reliant on mutualistic 

relationships with ectomycorrhizal fungi (Hagan and Grove 1999, 

The young stand produces large numbers of trees (~600 stems/ac or 

~1500 stems/ha) at age 30, and the intense competition among these 

trees causes mortality of smaller stems, which creates an increasing 

number of small snags (Figure 2). Trees begin to grow into 10 in (25 

cm) DBH size by age 40, and trees of this size begin to dominate the 

stand by age 80. Snags of the 10 in (25 cm) DBH size begin to appear 

at age 60 as mortality of larger trees occur. Large live trees (>20 in or 

>50 cm) begin to appear at age 90—100, with snags of that size as well. 

Figure 2. General Pattern of Snag Density Over Time

The large amount of DWM present just after the clearcut (which 

consists mostly of pieces <10 in (<25 cm) diameter) decomposes 

rapidly in the first 25 years and continues to decline in mass to age 

40. From age 40—100 years, DWM increases as small snags fall, 

and then larger snags begin to contribute to DWM that include 

pieces >10 in (>25 cm) diameter. Very few large (> 20 in or >50 

cm) pieces of DWM are produced. Large DWM often results from 

wind or other disturbances that fell large trees in the old-growth 

stage. Thus, large DWM tends to accumulate periodically from 

these disturbance pulses; whereas small DWM accumulates in a 

more predictable pattern in earlier stages of stand development. 

This process produces the U-shaped pattern that is often described 

with a dearth of DWM in the intermediate ages (Figure 3). This 

pattern shows the importance of retaining large live trees and large 

snags at the time of harvest; they will contribute large DWM to 

the forest floor throughout the development of the stand.

Figure 3. General Pattern of DWM Density Over Time Downed woody material (Mg/ha)
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DWM in Northern coniferous forests suggested that DWM may 

play a small role in nutrient cycling in those forests (Laiho and 

Prescott 2004). The same review showed that DWM contributes 

less than 10 percent of the nutrients (Nitrogen (N), Phosphorus 

(P), Potassium (K), Calcium (Ca), and Magnesium (Mg) returned 

in aboveground litter annually, and approximately five percent 

of the N and P released from decomposing litter or soil annually 

(Laiho and Prescott 2004). Although DWM is often low in N 

itself, N fixation in DWM was an important source of this limiting 

nutrient in both terrestrial and aquatic ecosystems (Harmon et 

al. 1986). There was a wide range of non-symbiotic N fixation, 

but temperate forests received average input of about 1.8–2.7 lb/

ac/yr (2–3 kg/ha/year) of N (Roskoski 1980, Yowhan Son 2001).

A review of scientific data suggests that when both sensitive sites 

(including low-nutrient) and clearcutting with whole-tree removal 

are avoided, then nutrient capital can be protected (see also Hacker 

2005). However, there is no scientific consensus on this point 

because of the range of treatments and experimental sites (Grigal 

2000). It is important to emphasize that the impact on soil nutrients is site dependent. Low-nutrient sites are much more likely to 

be damaged by intensive biomass removal than sites with great 

nutrient capital or more rapid nutrient inputs. A report on impacts 

of biomass harvesting from Massachusetts suggested that with 

partial removals (i.e., a combination of crown thinning and low 

thinning that removes all small trees for biomass and generates 

from 9–25 dry t/ac or 20–56 Mg/ha) stocks of Ca, the nutrient 

of greatest concern, could be replenished in 71 years (Kelty et al. 

2008). The Massachusetts study was based on previous research with 

similar results from Connecticut (Tritton et al. 1987, Hornbeck et 

al. 1990). Leaching, particularly of Ca due to acidic precipitation, 

can reduce the nutrients available to forests even without harvests 

(Pierce et al. 1993). However, the Ca-P mineral apatite may provide 

more sustainable supplies of Ca to forests growing in young soils 

formed in granitoid parent materials (Yanai et al. 2005). 

15 years of data from Hubbard Brook Ecosystem Study indicate that 

a whole-tree clear cut did not result in the depletion of exchangeable Ca pools (Campbell et al. 2007). The Environmental Impact 

Statement from the White Mountain National Forest (2005 p. 

3–19) demonstrated the variation in Ca removed by treatment 

and forest type, though even whole-tree clear cut was estimated 

to remove only four percent of the total Ca pool. A study of an 

aspen/mixed-hardwood forest showed that even with a clearcut 

system, Ca stocks would be replenished in 54 years (Boyle et al. 

1973). Minnesota’s biomass guidelines present data that showed 

soil nutrient capital was replenished in less than 50 years even 

under a whole-tree harvesting scenario (Grigal 2004, MFRC 

2007). Whole-tree clearcutting (or whole-tree thinning, e.g., 

Nord-Larsen 2002) did not greatly reduced amounts of soil carbon 

or N in some studies (Hornbeck et al. 1986, Hendrickson 1988, 

Huntington and Ryan 1990, Lynch and Corbett 1991, Olsson et 

al. 1996, Johnson and Todd 1998). Lack of significant reduction in 

carbon and N may be due to soil mixing by harvesting equipment 

(Huntington and Ryan 1990). However, intensive cutting, such 

as clearcutting with whole-tree removal, can result in significant 

nutrient losses (Hendrickson 1988, Federer et al. 1989, Hornbeck et 

Åström et al. 2005). In general, small trees and branches hosted 

more species of fungus per volume unit than larger trees and logs; 

however larger dead logs may be necessary to ensure the survival 

of specialized fungus species such as heart-rot agents (Kruys and 

Jonsson 1999, Bate et al. 2004).

2c. Soil Productivity

DWM plays an important physical role in forests and riparian 

systems. DWM added to the erosion protection by reducing 

overland flow (McIver and Starr 2001, Jia-bing et al. 2005). 

DWM also had substantial water-holding capacity (Fraver et al. 

2002). DWM in riparian systems provided sites for vegetation 

colonization, forest island growth and coalescence, and forest 

floodplain development (Fetherston et al. 1995).

In many ecosystems, CWM decomposed much more slowly 

than foliage and FWM, making it a long-term source of nutrients (Harmon et al. 1986, Johnson and Curtis 2001, Greenberg 

2002, Mahendrappa et al. 2006). DWM decomposed through 

physical breakdown and biological decomposition (Harmon et 

al. 1986). The diameter of each piece of DWM, temperature of 

the site, amount of precipitation, and tree species all influenced 

the rate of DWM decomposition (Zell et al. 2009). In general, 

conifers decayed more slowly than deciduous species (Zell et al. 

2009). Other factors that encouraged decomposition included 

warmer temperatures, rainfall between 43 and 51 in/year (1100 

and 1300 mm/year), and small-sized pieces (Zell et al. 2009). 

While there is great variation across ecosystems and individual 

pieces of DWM, log fragmentation generally appears to occur 

over 25–85 years in the U.S. (Harmon et al. 1986, Ganjegunte 

et al. 2004, Campbell and Laroque 2007). 

In some ecosystems, DWM represents a large pool of nutrients 

and is an important contributor to soil organic material (Graham 

and Cromack Jr. 1982, Harvey et al. 1987). However, review of 
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The gray bar shows the range of DWM measurement, the black 

line shows the median value, and each dot represents one measurement of DWM.

In contrast, a study of U.S. Forest Service inventory plots found 

a mean of 3.7 t/ac (8.3 Mg/ha) and a median of 2.9 t/ac (6.5 Mg/

ha) of DWM across 229 plots in the Northeast (Chojnacky et al. 

2004 see Figure 2). This low level of DWM across the landscape 

may be due to widespread clearcutting in the 1880-1930 period.

Figure 5. U.S. Forest Service Inventory Estimates of Deadwood Data from Chojnacky et al. 2004

3. Research by Forest Type

The following section uses the best available scientific literature 

to examine the dead wood dynamics of specific forest types in 

the Northeast. This region encompasses three ecological provinces including Northeastern mixed forest, Adirondack-New 

England mixed forest-coniferous forest, and Eastern broadleaf 

forest (McNab et al. 2007). Major forest types in the region are 

white/red/jack pine (Pinus sp.), spruce-fir (Picea sp. - Abies sp.), 

oak-hickory (Quercus sp. - Carya sp.) or transitional hardwood 

forests, and northern hardwood forests (Eyre 1980). 

The average year round temperature in the Northeast is 46°F 

(8°C). Winter temperatures average 24°F (-4.3°C) while summer 

temperatures average 67°F (19.6°C; National Climate Data Center 

2008). The prevailing wind direction, from west-to-east, creates 

a continental climate except for coastal areas moderated by the 

Atlantic Ocean (Barrett 1980). On average, the region receives 41 

in (104 cm) of precipitation which is evenly distributed throughout 

the year (National Climate Data Center 2008). Elevations range 

from sea level to mountain tops above 5,300 ft (1,600 m), but much 

of the region is set on upland plateaus between 500 ft and 1500 

ft (150 and 460 m; Barrett 1980). Glaciation created young soils 

which vary considerably across small spatial scales (Barrett 1980).

Much of the southern portion of Northeastern forests was cleared 

for agriculture in the early 19th century, leaving less than one 

percent of the forest cover in an old-growth condition (Cogbill et 

al. 2002). Currently much of the region is comprised of second- or 

third-growth forest that has yet to reach late seral stages (Irland 

1999). There are about 80 million ac (32 million ha) of timberlands 

(areas where commercial timber could be produced) and about 4 

million ac (1.6 million ha) of reserved forest where harvests are 

al. 1990, Martin et al. 2000, Watmough and Dillon 2003)—in one 

case, 13 percent of Ca site capital (Tritton et al. 1987). 

Low-impact logging techniques that reduce soil disturbance 

can help protect nutrient capital (Hallett and Hornbeck 2000). 

Harvesting during the winter after leaf fall can reduce nutrient 

loss from 10–20 percent (Boyle et al. 1973, Hallett and Hornbeck 

2000). Alternatively, if logging occurs during spring or summer, 

leaving tree tops on site would aid in nutrient conservation. 

Nordic countries have demonstrated that leaving cut trees on 

the ground in the harvest area until their needles have dropped 

(one growing season) can also reduce nutrient loss (Nord-Larsen 

2002, Richardson et al. 2002). 

2D. Quantities of Dead Wood

Site productivity and the rate of decomposition helped determine 

the amount of dead wood in a given stand (Campbell and Laroque 

2007, Brin et al. 2008). As mentioned above, DWM decomposition varies greatly but generally occurs over 25–85 years in the 

U.S. (Harmon et al. 1986, Ganjegunte et al. 2004, Campbell 

and Laroque 2007). All mortality agents including wind, ice, 

fire, drought, disease, insects, competition, and senescence create 

dead wood (Jia-bing et al. 2005). Of course, these mortality agents 

often act synergistically.

A review of 21 reports of quantitative measures of DWM in 

Eastern forest types shows great variability across forest types and 

stand development stages (Roskoski 1980, Gore and Patterson 

1986, Mattson et al. 1987, McCarthy and Bailey 1994, Duvall 

and Grigal 1999, Idol et al. 2001, Currie and Nadelhoffer 2002). 

The reports ranged from 3–61 t/ac (7 to 137 Mg/ha) with a 

median of 11 t/ac (24 Mg/ha) and a mean of 15 t/ac (33 Mg/

ha; see Figure 4). Measurements of old forests (>80 years old), 

had a median of 11 t/ac (24 Mg/ha) and a mean of 13 t/ac (29 

Mg/ha) in DWM.

Figure 4. Distribution of DWM Measured in Eastern Forests
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forest had 10 t/ac (23 Mg/ha) of DWM. The harvest in this study 

increased the mass of DWM, but more of the pieces were small 

diameter (Fraver et al. 2002). While the harvest method (whole 

tree, tree length, or cut to length) and harvest system affect the 

amount of DWM left after harvest, many studies do not specify 

how material was removed.

Snag densities in 

balsam fir forests of 

N e w f o u n d l a n d 

followed a similar 

pattern over time. 

Stands contained 

nearly 16 snags/ac 

(40/ha) the first year 

post harvest; then 

the density declined 

below the 4 snags/ac 

(10/ha) required by 

the regional forest 

management guidelines at 20 years post harvest; and finally the number of snags 

returned to initial levels in the 80–100 years post-harvest stands 

(Smith et al. 2009). Smith and colleagues (2009) recommended 

retention and recruitment of white birch snags to ensure sufficient 

snag and DWM density. The Canadian province of Newfoundland and Labrador requires retention of 4 snags/acre while Maine 

recommends retention of 3 snags greater than 14 inches DBH 

and one greater than 24 inches DBH (Flatebo et al. 1999, Smith 

et al. 2009). Other guidelines recommend between 5 and 6 snags/

acre greater than 8 inches and an additional 4–6 potential cavity 

trees (Woodley 2005).

A study of two old-growth balsam and black spruce sites demonstrated a wide range of average DWM piece sizes even in unmanaged lands. In the two study sites, the average diameter of the 

DWM structures were 54.8 cm and 16.1 cm; average height of 

snags was 4.73 m and 2.52 m; and length of logs were 5.91 m and 

4.81 m (Campbell and Laroque 2007). The differences between 

the two sites are due, in part, to differences in rates of decomposition, i.e., higher rates of decomposition reduce the average size 

of DWM pieces.

One study of pre-commercial thinning in spruce-fir forests 

showed that the mass of DWM was reduced from 29–15 t/ac 

(64–34 Mg/ha; Briggs et al. 2000). In one study of a sprucefir whole tree clearcut in Maine, 35 percent of organic matter 

was in trees and 12 percent was in woody litter and forest 

floor (Smith Jr et al. 1986). In that study, 23 t/ac (52 Mg/

ha) of DWM were left after the harvest, but the whole-tree 

removal took about 91 percent of N, P, K, and Ca from the 

site, which was between 2 and 4 times the nutrient removal 

from a bole-only harvest (Smith Jr et al. 1986). Depletion of 

Ca is of some concern in Maine, though not as great a concern 

as in the Central and Southeastern U.S. (Huntington 2005). 

Spruce-fir forests generally incorporate Ca into merchantable 

wood at 1.6 kg Ca/ac/yr (1.6 kg ha-1yr-1; Huntington 2005). 

not permitted (Alvarez 2007). Approximately 1,272 million 

ft3 (36 million m3) of wood are harvested annually out of 3,157 

million ft3 (89 million m3) of net tree growth (Alvarez 2007).

3a. Spruce-Fir Forests

Spruce-fir forests dominate the inland areas of Maine as well as 

the mountain tops northernmost portions of New York, New 

Hampshire, and Vermont. These forests have cold temperatures 

and relatively coarse, acidic soils (Barrett 1980). Dead wood is 

important in spruce-fir ecosystems. For example, in Maine (the 

state with the greatest area of spruce-fir forests in the Northeast), 

DWM, snags, and cavity trees are important habitat for 20 percent 

of bird, 50 percent of mammal, 44 percent of amphibian, and 58 

percent of reptile species found there (Flatebo et al. 1999). Animals 

that rely on DWM in spruce-fir forests include pine marten 

(Martes americana atrata) (Kyle and Strobeck 2003) and may 

include some saproxylic vertebrates (Majka and Pollock 2006).

In 2001, researchers 

found the volume of 

down dead wood in 

Maine’s spruce-fir 

forest to be 530 ft3/

ac (37 m3/ha) or 3.4 

t/ac (7.5 Mg/ha) 

( H e a t h a n d 

Chojnacky 2001, 

Table 36). While the 

average was 3.4 t/ac 

(7.5 Mg/ha) non-industrial private lands only had 3 t/ac, public 

lands had 3.3 t/ac, while industrial lands had 3.7 t/ac (Heath and 

Chojnacky 2001, Table 37). The quadratic-mean, large-end diameter of down wood in Maine’s spruce fir-forests measured 6.7 in 

(17 cm; Heath and Chojnacky 2001). The number of dead trees 

in nine red spruce-balsam fir forests ranged from 85–232/ ac 

(210–574/ ha) or from 11–43 percent of the basal area (Tritton 

and Siccama 1990). The nine paper birch-red spruce-balsam fir 

stands survey ranged from 33–86 dead trees/ac (81–212/ha) or 

11–35 percent of basal area (Tritton and Siccama 1990), and 

overall, 14 percent of the trees in Maine were standing dead 

(Griffith and Alerich 1996). Dead wood provided an important 

substrate for spruce and hemlock seedling development (Weaver 

et al. 2009). While a commercial clearcut reduced the area of 

dead wood available for seedling growth, 5- and 20-year-selection 

cutting cycles were not statistically different from the uncut 

reference stand with 362–501 ft2/ac (83–115 m2/ha) of dead 

wood (Weaver et al. 2009). 

As described above, spruce-fir forests tend to have two peaks in 

DWM over time: one early in stand development and a second 

peak after the stem exclusion phase (Figure 3). For example, one 

study showed a change from 63 t/ac (28 Mg/ha) in a stand <20 

years, 22 t/ac (10 Mg/ha) in the 41–60-year age class, to 117 t/ac 

(52 Mg/ha) in the 61–80-year age class, and returning to less than 

56 (25 Mg/ha) in the 101–120-year age class (Taylor et al. 2007). 

Fraver and colleagues (2002) showed that pre-harvest an Acadian 
Manomet Center for Conservation Sciences 144 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Estimates of the volume of down dead wood in Maine’s northern 

hardwood forests are 598 ft3/ac (42 m3/ha) or 9 t/ac (20.5 Mg/ha Heath 

and Chojnacky 2001). Keeton (2006) estimates a volume of 600 ft3/

ac (42 m3/ha) of DWM in a multi-aged northern hardwood forest.

The number of dead trees in five hemlock-yellow birch forests range 

from 16–45/ac (40–112/ha) or from 3–14 percent of the basal 

area (Tritton and Siccama 1990). The 14 sugar maple-beech-yellow 

birch stands survey ranged from 14–99 dead trees/ac (35–245/

ha) or 5–34 percent of basal area (Tritton and Siccama 1990). 

Other estimates of snag densities in northern hardwood forests 

include 5/ac (11/ha) (Kenefic and Nyland 2007), 15/ac (38/ha) 

(Goodburn and Lorimer 1998), and 17/ac (43/ha) (McGee et al. 

1999). Tubbs and colleagues (1987) recommend leaving a between 

of one and ten live decaying trees/acre of least 18 inches DBH.

The number of cavity trees is another important habitat element 

in northern hardwood forests that is reduced by harvest. For 

example, studies in northern hardwood forests have shown a 

reduction from 25 cavity trees/ac (62/ha) before harvest and to 

11 (27/ha) afterward (Kenefic and Nyland 2007). Another study 

measured 7 cavity trees/ac (18/ha) in old-growth, 4/ac (11/ha) 

in even-aged stand, and 5/ac (13/ha) in a stand selection system 

(Goodburn and Lorimer 1998).

3c. Transition Hardwood Forests

Oak-hickory forests occupy the southernmost portions of the region. 

The oak-hickory forests are also considered a transitional forest type 

between the northern hardwood forests type and the Appalachian 

hardwoods that dominate further south (Westveld 1956). 

As with the other forest types discussed, DWM density tends to 

follow a ‘U’ shape in oak-hickory forests. For example, Idol and 

colleagues (2001) found 61 t/ac (137 Mg/ha) in a one-year postharvest stand, 18 t/ac (40 Mg/ha) in a 31-year-old stand, and 26 t/ac 

(59 Mg/ha) in a 100-year-old stand. Tritton and colleagues (1987) 

measured 5.8 t/ac (13 Mg/ha) in an 80-year-old stand in Connecticut.

Some sites such as Weymouth Point, Maine, have documented 

Ca-depletion problems (Smith Jr et al. 1986, Hornbeck et al. 

1990, Briggs et al. 2000). The rate of weathering replenishment 

of Ca in Maine is uncertain, and the Ca-rich mineral apatite 

may be an important source of Ca (Huntington 2005, Yanai 

et al. 2005). Climate change and the associated warming and 

species composition shift may exacerbate Ca depletion in 

spruce-fir forests (Huntington 2005).

3b. Northern Hardwood Forests 

Northern hardwood forests are dominated by maple (Acer sp.), 

beech (Fagus grandifolia), and birch (Betula sp.) and cover lower 

elevations and southern portions of Maine, New York, New 

Hampshire, Vermont, and the northern portion of Pennsylvania. 

Northern hardwood forests also include conifers, e.g., hemlock 

(Tsuga canadensis) and white pine (Pinus strobus), in the mixture 

(Westveld 1956).

In general, the amount of DWM in northern hardwood forests 

follows the ‘U’ pattern mentioned above. Young stands have 

large quantities of DWM; mature stand have less; and older or 

uncut stands have more. For example, a study in New Hampshire 

measured 38 t/ac (86 Mg/ha) of DWM in a young stand, 14 

t/ac (32 Mg/ha) in mature stands, 20 t/ac (54 Mg/ha) in old 

stand, and 19 t/ac (42 Mg/ha) in an uncut stand (Gore and 

Patterson 1986). Gore and Patterson (1986) also note that 

stands under a selection system had lower quantities of DWM, 

i.e., 16 t/ac (35 Mg/ha). A review of other studies identified 

similar temporal patterns and quantities of DWM (see Figure 

6 from data described in Roskoski 1977, Tritton 1980, Gore 

and Patterson 1986, McCarthy and Bailey 1994, McGee et al. 

1999, Bradford et al. 2009).

Figure 6. Quantities of DWM in Northern hardwood forests 

Forests

Data described in Gore and Patterson 1986, McCarthy and Bailey 1994, McGee et al. 

1999, Bradford et al. 2009, and Roskoski 1977
Manomet Center for Conservation Sciences 145 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

both initiation 8.9 t/ac (20 Mg/ha) and at 90 years 2.9 t/ac 

(6.6 Mg/ha). The same review showed the unmanaged stand 

had 30 snags/ac (74/ha) while the managed forest had 6.9/

ac (17/ha; Duvall and Grigal 1999). Red and white pine that 

fall to the ground at time of death will become substantially 

decayed (decay class IV of V) within 60 years (Vanderwel et 

al. 2006a).

While not a recognized forest type, stands with a mix of oak, 

other hardwoods, white pine, and hemlock are common. Many 

of the red oak and white pine stands on sandy outwash sites 

are susceptible to nutrient losses because of a combination of 

low-nutrient capital and past nutrient depletion (Hallett and 

Hornbeck 2000).

Figure 7. DWM in Oak-Hickory Forests

Data described in (Tritton et al. 1987, Idol et al. 2001)

Estimates of the volume of down dead wood in Maine’s oak-hickory 

forests are 244 ft3/ac (17 m3/ha) or 0.7 (1.5 Mg/ha; Heath and 

Chojnacky 2001). Wilson and McComb (2005) estimated the 

volume of downed logs in a western Massachusetts forest at 143 

ft3/ac (10 m3/ha).

Out of seven oak stands in Connecticut, the number of dead 

trees ranged from 19–44/ac (46–109/ha) or 5–15 percent of basal 

area (Tritton and Siccama 1990). The decadal fall rates of snags 

in a Massachusetts study varied from 52–82 percent (Wilson 

and McComb 2005). Snags, particularly large-diameter snags, 

provide important nesting and foraging sites for birds (Brawn 

et al. 1982). In general, wildlife habitat requirements for dead 

wood are poorly documented, but it is clear that some wildlife 

species rely on dead wood in oak-hickory forests (Kluyver 1961, 

DeGraaf et al. 1992).

A study in Appalachian oak-hickory forests showed that the 

decomposing residues left after a sawlog harvest increased concentration of Ca, K, and Mg in foliage and soils after 15 years in 

comparison to a whole-tree harvest (Johnson and Todd 1998). 

However, the study found no impacts on soil carbon, vegetation 

biomass, species composition, vegetation N or P concentration, 

soil-bulk density, or soil N because of the whole-tree harvest 

(Johnson and Todd 1998).

3d. White Pine and Red Pine Forests

Pine forests are found in the coastal areas of Maine and New 

Hampshire and much of central Massachusetts. Pine forests 

tend to occupy sites with coarse-textured, well-drained soils 

(Barrett 1980). 

Estimates of the volume of down dead wood in Maine’s pine 

forests are 255 ft3/ac (18 m3/ha) or 1.6 t/ac (3.5 Mg/ha; Heath 

and Chojnacky 2001). A review of research on DWM in the 

red pine forests of the Great Lakes area showed that there 

were 50 t/ac (113 Mg/ha) of DWM in an unmanaged forest 

at stand initiation and 4.5 t/ac (10 Mg/ha) in a 90-year-old 

stand (Duvall and Grigal 1999). In comparison, the managed 

stand Duvall and Grigal (1999) studied had less DWM at 
Manomet Center for Conservation Sciences 146 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

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Appendix 4–B

Revised Assessment of Biomass 

Harvesting and Retention Guidelines

Alexander M. Evans, Robert T. Perschel, and 

Brian Kittler

Table of Contents

1. Introduction................................................................................................. 150

1a. Woody Biomass................................................................................... 150

1b. Coarse Woody Material....................................................................151

1c. Why “Biomass” Guidelines?.............................................................151

1d. An Examination of Current Guidelines......................................152

2. Biomass Retention Guidelines for Timber Harvesting in New York 

and New England............................................................................................152

2a. Maine.......................................................................................................152

2b. New Hampshire...................................................................................153

2c. Vermont..................................................................................................154

2d. New York ..............................................................................................154

2e. Rhode Island.........................................................................................154

2f. Connecticut...........................................................................................154

3. Review of State Biomass Harvesting and Retention Guidelines 154

3a. Michigan Woody Biomass Harvesting Guidance....................154

3b. Minnesota: Biomass Harvesting Guidelines for Forestlands.155

3c. Missouri: Best Management Practices for Harvesting Woody 

Biomass...........................................................................................................155

3d. Pennsylvania: Guidance on Harvesting Woody Biomass for 

Energy .............................................................................................................155

3e. Maryland: Development of Forest Biomass Harvesting Guidelines................................................................................................................. 156

3f. Wisconsin’s Forestland Woody Biomass Harvesting Guidelines156

3g. California Forest Practice Rules..................................................... 156

4. Biomass Guidelines and Policy in Canada..........................................157

5. Biomass Guidelines and Policy in Northern Europe.......................157

5a. Sweden..................................................................................................... 158

5b. Finland.................................................................................................... 158

5c. Denmark..................................................................................................159

5d. The United Kingdom..........................................................................159

6. Other Organizations and Certification Systems.............................160

6a. International Organizations.............................................................160

6b. Federal Biomass Policy.......................................................................160

6c. Forest Stewardship Council: U.S. National Forest Management 

Standard..........................................................................................................161

6d. Other Voluntary Certification Systems........................................ 162

7. Common Elements of Biomass Harvesting Guidelines................ 162

7a. Dead Wood...........................................................................................162

7b. Wildlife and Biodiversity.................................................................162

7c. Water Quality and Riparian Zones............................................... 162

7d. Soil Productivity..................................................................................162

7e. Silviculture.............................................................................................162

7f. Biomass Guidelines Development.................................................. 162

8. Conclusion................................................................................................... 163

9. Acknowledgments.....................................................................................164

10. References...................................................................................................164

11. Appendix I: Summary Table of Biomass Guidelines................... 167

12. Appendix II: Links to Biomass Harvesting Guidelines.............168

1. Introduction

Interest in removing low-grade wood from forests has increased 

because of rising fossil fuel costs, concerns about carbon emissions 

from fossil fuels, and the risk of uncharacteristic wildfires.1, 19

Most existing forest practice rules and recommendations did not 

anticipate this increased extraction of woody biomass and offer no 

specific guidance on how much removal is healthy for ecosystems. 

Intensification of biomass utilization, particularly for energy and 

fuel needs, presents a range of potential environmental risks.31,

29 This report provides a review of guidelines put forth by states 

and other entities to avoid these environmental risks and promote 

the ecological sustainability of forest biomass utilization, and can 

inform a similar process to develop guidelines in Massachusetts. 

1a. Woody Biomass

While definitions of biomass are usually similar, there can be 

surprising differences. For instance, the definition of biomass in 

New Brunswick, Canada’s guidelines excludes pulpwood fiber 

from whole-tree chipping.42 Technically, the term woody biomass 

includes all the trees and woody plants in forests, woodlands, or 

rangelands. This biomass includes limbs, tops, needles, leaves, and 

other woody parts.44 In practice, woody biomass usually refers to 

material that has historically had a low value and cannot be sold as 

timber or pulp. Biomass harvesting might even remove dead trees, 

down logs, brush, and stumps.37 Markets determine which trees 

are considered sawtimber material and which are relegated to the 

low-value biomass category. Changing markets and regional variations determine the material considered biomass, but in general 

it is a very low quality product. In some cases, woody biomass is 

defined by how the material is used. For example, in Pennsylvania 

any material burned for energy is defined as biomass.46

In this report, the term biomass refers to vegetation removed 

from the forest, usually logging slash, small-diameter trees, tops, 

limbs, or trees that cannot be sold as higher-quality products such as 

sawtimber. This report does not discuss biomass from agricultural 

lands and short-rotation woody biomass plantations.

Biomass can be removed in a number of ways. Some harvests remove 

only woody biomass, some combine the harvest of sawtimber or 

other products with biomass removal, and some remove biomass 

after other products have been removed. This report focuses on 

what remains in the forest after harvest and not on the type of 

harvest. The goal is to ensure the forest can support wildlife, provide 

clean water, sequester carbon, protect forest soil productivity, and 

Photo: Zander Evans
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• landscape-level concerns, and

• following the lead of others.

More specifically, biomass harvesting guidelines are designed to 

fill the gaps where existing BMPs and forest practice regulations 

may not be sufficient to protect forest resources under new biomass 

harvesting regimes. In other words, BMPs were developed to 

address forest management issues at a particular point in time; as 

new issues emerge, new guidelines may be necessary. Existing 

guidelines did not anticipate the increased rate or new methods 

of biomass removal and offer no specific guidance on the amount 

of extraction that is acceptable for meeting a range of forest management objectives. For example, Pennsylvania’s old BMPs encouraged 

operators “to use as much of the harvested wood as possible to 

minimize debris,” while the new guidelines recommend leaving 

“15 to 30 percent of harvestable biomass as coarse woody debris.”46

Michigan’s guidelines point out that while the state “has a rich 

history of utilizing woody biomass for bioenergy and biobased 

products such as lumber, pulp and paper, composites, heat and 

electrical generation,” as “market opportunities expand for woody 

biomass, it is crucial that harvesting and removal of woody biomass 

be done using sustainable forest management principles and 

practices that are ecologically, economically, and socially appropriate.”36 Concerns about long-term site productivity, biodiversity, 

and wildlife populations drove the Minnesota state legislature to 

call for biomass harvesting guidelines, and the resulting guidelines 

are intended to be implemented in close conjunction with the 

existing Minnesota forestry guidelines, which cover a range of 

additional management considerations.37 More generally, biomass 

guidelines focus on DWM levels, wildlife and biodiversity, water 

quality and riparian zones, soil productivity, silviculture, and, in 

some cases, other issues. For example, Maine’s guidelines focus 

“on the amount of biomass that should be left on-site after harvest 

and the effect on soil productivity, water quality, and 

biodiversity.”7

continue to produce income after a biomass harvest or repeated 

harvests. In some regions, current wood utilization is such that 

no woody material is available for new markets such as energy. 

For these high-utilization areas, following biomass guidelines 

may result in more biomass being left in the forest. 

1b. Coarse Woody Material

Woody material is sometimes divided into coarse woody material 

(CWM), fine woody material (FWM), and large woody material. 

CWM has been defined as being more than 6 inches in diameter 

at the large end and FWM as less than 6 inches in diameter at 

the large end.37 The U.S. Forest Service defines CWM as down 

dead wood with a small-end diameter of at least 3 inches and a 

length of at least 3 feet and FWM as having a diameter of less 

than 3 inches.62 FWM tends to have a higher concentration of 

nutrients than CWM. Large downed woody material, such as logs 

greater than 12 inches in diameter, is particularly important for 

wildlife. In this report, we use the term downed woody material 

(DWM) to encompass all three of these size classes, but in some 

circumstances we discuss a particular size of material where the 

piece size is particularly important.

1c. Why “Biomass” Guidelines?

Good biomass harvesting practices can enhance and improve 

forest land; poor practices can damage and devalue it.46 

In the United States, forestry on private and state forests is regulated primarily at the state level. At least 276 state agencies across 

the country have some oversight of forestry activities, including 

agencies focused on forestry and other state agencies, such as 

wildlife or environmental protection.17 Federal law requires states 

to address non-point source pollution of waterways. All 50 states 

have Best Management Practice (BMP) programs that are intended 

to protect water quality and other values. The programs usually 

include sections on timber harvesting, site preparation, reforestation, 

stream crossings, riparian management zones, prescribed burning 

and fire lines, road construction and maintenance, pesticides and 

fertilizers, and wetlands. Programs in states vary from laws that 

prescribe mandatory practices to states that use voluntary BMPs 

and education and outreach programs. These programs can be 

categorized in four ways: non-regulatory with enforcement, regulated, and combination of regulatory and not regulatory. In the 

northeast, Massachusetts and Connecticut are considered regulated, 

Vermont and New Hampshire are non-regulated with enforcement 

and Rhode Island, New York, and Maine use a combination of 

approaches. These programs are routinely monitored and literature 

suggests that when these BMPs are properly implemented they do 

protect water quality.51 With so much existing regulation, why 

are additional biomass harvesting guidelines necessary? Reasons 

for biomass harvesting guidelines are likely to mirror the reasons 

forestry is regulated in general, which include16: 

• general public anxiety over environmental protection,

• the obligation to correct misapplied forestry practices,

• the need for greater accountability,

• growth of local ordinances,

Photo: Zander Evans
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Therefore, the state undertook a collaborative effort between the 

Maine Forest Service, the University of Maine, and the Trust 

to Conserve Northeast Forestlands to develop woody biomass 

retention guidelines. Participating committee members included 

Manomet Center for Conservation Sciences, the Forest Guild, the 

Maine Forest Products Council, and other forestry professional 

and environmental organizations. After a multi-year process and 

several drafts, Consideration and Recommendations for Retaining 

Woody Biomass on Timber Harvest Sites in Maine was released in 

2010.7 The project’s goal was to address the growing interest in 

woody biomass and concerns about long-term sustainability of 

biomass harvesting by developing guidelines for the retention of 

woody biomass. The Maine guidelines define woody biomass as 

“logging residues, previously un-merchantable stems, and other 

such woody material harvested directly from the forest typically 

for the purposes of energy production.”40 These new guidelines 

augment the current Water Quality BMPs, which are effectively 

applied in most harvests (77 percent of stream crossings and 89 

percent of approaches to the crossings39). 

The biomass harvesting recommendations report includes an 

extensive background section and literature review, including 

three key documents:

• Best Management Practices for Forestry,38

• Site Classification Field Guide,9

• Biodiversity in the Forests of Maine: Guidelines for Land 

Management.18

It also includes appendices that summarize regional recommendations pertaining to wildlife trees and biomass harvesting. The 

background section covers soil productivity, water quality, and 

forest management, as well as forest biodiversity; at the end of 

each section are voluntary guidelines. In earlier drafts, the voluntary guidelines offered after each section were more specific and 

stringent, but the final version lacks specific targets. Earlier drafts 

referred to the entire effort as “Guidelines,” but the reframing of 

the title indicates the struggle the committee members had in 

agreeing on specific targets and the vagueness of the final product. 

For example, the voluntary guidelines for soils indicate forest litter 

should be left on-site “to the extent possible” and that operators 

should “minimize removal” of FWM on low-fertility sites. 

This lack of specificity is found in other sections as well. The 

commentary on setting targets for the Forest Biodiversity section 

helps shed light on the decision-making dynamics that led to the 

dilution of the final product. The background information for the 

Forest Biodiversity section draws heavily on Biodiversity in the 

Forests of Maine. This report, a comprehensive manual outlining 

recommended guidelines for maintaining biodiversity in the 

forests of Maine, was the culmination of a multi-year process in 

the 1990s that included a wide range of stakeholders, including 

industry representatives, forest professionals, and environmental 

organizations. Originally published by Flatebo and colleagues22, 

it was updated by Elliot.18 Although the final version of the 

current biomass retention report utilizes the recommendations 

from the biodiversity report as background information and 

1d. An Examination of Current Guidelines

This report reviews the biomass harvesting or retention guidelines 

from New York and New England, other states with specific 

biomass guidance, parts of Canada, Northern European counties, 

and other organizations, including the U.S. federal government 

and certification groups. We have grouped New York and the 

New England states together to offer a snapshot of the current 

situation in states geographically near Massachusetts. Maryland, 

Minnesota, Missouri, Michigan, Pennsylvania, Wisconsin, and 

California are also covered, because of their forest practices guidance on biomass harvest and retention. In some states guidelines 

are still under review at the time of this writing and subject to 

change. Readers are encouraged to use the links in Appendix II 

to check the latest drafts of the guidelines. 

The examples in this report detail the status of rules and recommendations for removing biomass from our forests. Entities 

interested in addressing concerns about biomass removal have 

taken at least three different approaches. One is to verify that 

existing forest practice regulations cover the issues raised by biomass 

harvests, obviating the need for new guidelines. In instances where 

existing rules or recommendations are found to be insufficient, 

some entities—including Minnesota, Missouri, Pennsylvania, 

Wisconsin, and Maine—have taken a second type of approach 

and chosen to craft separate biomass guidelines that augment 

existing forest practice guidance. In the third case, entities such 

as the Forest Stewardship Council (FSC) have chosen to address 

concerns particular to biomass harvests by revising existing rules 

or recommendations. 

The existing guidelines cover topics such as dead wood, wildlife 

and biodiversity, water quality and riparian zones, soil productivity, 

silviculture, and disturbance. Appendix I lists the commonly used 

subtopics for each and identifies which are covered in a given set of 

guidelines. In some cases, a subtopic is noted as covered because it 

appears in another set of forestry practice rules or recommendations instead of that state’s biomass guidelines. The list of subtopics 

was developed from section headings in all the various existing 

guidelines and is similar to other criteria for sustainable production 

and harvest of forest biomass for energy.31 It should be noted that 

each set of guidelines takes a slightly different approach, addressing 

topics with a greater or lesser degree of specificity. The precepts 

of sustainable forest management call for identifiable criteria 

and indicators, such as those identified through the Montreal 

Process, for the purpose of benchmarking and measuring forest 

practices. The critique that follows does not always address why 

topics are covered with more or less specificity, but presumes that 

more specificity will increase the likelihood that guidelines will 

encourage sustainable management. 

2. Biomass Retention Guidelines for Timber

Harvesting in New York and New England

2a. Maine

In Maine, “guidelines specific to woody biomass retention are 

missing from existing best management practices and regulations.”40
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are voluntary, but the guide Good Forestry in the Granite State: 

Recommended Voluntary Forest Management Practices for New 

Hampshire includes sections on soil productivity, DWM, and 

retention of forest structures for wildlife habitat.13Good Forestry 

does not provide specific guidance on retention of tops and limbs, 

though it does recommend leaving “some cull material” in the 

woods after a biomass harvest. The section on soil productivity 

provides recommendations that would limit biomass removal on 

sites with nutrient-poor soils:

• Identify low fertility soils from maps and descriptions.

• Use bole-only harvesting (taking out the main portion of 

tree only, leaving branches and limbs in the woods) on lowfertility soils, or where fertility is unknown, as a precaution 

against nutrient loss.

• If whole-tree harvesting hardwoods, try to plan harvests 

during leaf-off periods to retain leaves and nutrients on site.

• Limit disruption of soil organic layers except when needed 

to accomplish silvicultural objectives (such as regeneration 

of species that need a bare mineral soil seedbed).13

Similarly, the Habitat section recommends retention of cavity 

trees and snags:

• In areas under uneven-aged management, retain a minimum 

of 6 secure cavity and/or snag trees per acre, with one exceeding 

18 inches DBH and 3 exceeding 12 inches DBH. In areas 

lacking such cavity trees, retain trees of these diameters with 

defects likely to lead to cavity formation.

• In areas under even aged management, leave an uncut patch 

for every 10 acres harvested, with patches totaling 5 percent 

of the area. Patch size may vary from a minimum of 0.25 acre. 

Use cavity trees exceeding 18 inches DBH or active den trees 

as nuclei for uncut patches. Remember, the larger the tree, 

the more species that can use it. Riparian and other buffers 

can help to satisfy this goal.

• Retain live trees with existing cavities.13

The Good Forestry in the Granite State guide also has recommendations for retention of DWM:

• Avoid damaging existing downed woody debris, especially 

large (18+ inches) hollow or rotten logs and rotten stumps 

during harvesting operations (including tree falling, skidding, 

and road and skid trail layout).

• Leave cull material from harvested trees, especially sound 

hollow logs, in the woods. Some cull material should be left 

behind during whole-tree or biomass harvesting operations 

that may otherwise utilize this material. Large pieces of cull 

material bucked out on the landing should be returned to 

the woods.

• Avoid disrupting downed logs in and adjacent to streams, 

ponds, and wetlands.

indicates that woody biomass harvesting practices “will have to 

comply with established recommendations for biodiversity as 

defined for non-biomass harvests,”7 the specific targets listed in 

the biodiversity report are never incorporated as guidelines. The 

report indicates that since there was “not widespread acceptance 

of those guidelines within Maine’s forest industry, specific targets 

for maintenance of site-level biodiversity are not included” in the 

relevant section.7

The result for the Forest Biodiversity section is that the Voluntary 

Guidelines call for leaving “as much fine woody material as possible” 

without the specific guidelines for DWM retention found in 

some other state guidelines. The guidelines also call for leaving 

“some wildlife trees” without incorporating targets for numbers 

of trees per acre suggested in Biodiversity in the Forests of Maine. 

The report indicates that this vagueness in the guidelines reflects 

the challenges of setting specific targets at site levels18 and that 

although science can direct selection of biological indicators, it 

is still weak in selecting specific target levels.24

2b. New Hampshire

While New Hampshire currently has no specific biomass 

harvesting guidelines, existing recommendations and rules address 

the major biomass harvesting topics. New Hampshire’s Slash Law 

(RSA 227-J:10) focuses on “debris left after a timber harvest” and 

states that “these branches, leaves, stems, unmerchantable logs, 

and stumps may take several years to decompose. Slash represents 

a fire hazard and, often, a messy appearance.” The Slash Law sets 

a limit on the height of slash that can be left on-site, but does not 

set any minimum to retain on site.

New Hampshire’s Basal Area Law (RSA 227-J:9) states that no 

more than 50 percent of the basal area can be cut near streams, 

water bodies, and public roads. Intensive biomass removal may 

decrease this law’s ability to prevent erosion, provide wildlife 

habitat, protect stream temperature and aquatic life, and preserve 

the aesthetics of the landscape, because removal of DWM is not 

regulated by a basal area restriction. In New Hampshire, BMPs 

Photo: Christopher Riely
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However, when New York initiated its renewable portfolio standard, it established an eligibility procedure for electrical power 

generators utilizing forest biomass. The resulting requirements 

are modeled after Vermont’s and include procurement plans 

for each facility to include forest management plans for source 

forests and harvest plans filed for all harvests. Adherence to these 

standards is monitored periodically by state foresters. New York 

varied slightly from Vermont’s approach by providing exemptions 

to properties that are accredited by FSC, Sustainable Forestry 

Initiative, or Tree Farm.

2e. Rhode Island

Rhode Island’s BMP guidance is encapsulated in the document 

Rhode Island Conservation Management Practices Guide.

12 The 

Guide includes water-quality protections such as filter strips 

between harvested areas and streams or ponds. Rhode Island 

does require the registration of “woods operators” with the Division of Forest Environment and notification of intent to harvest 

timber (RI State Statues, Title 2, Chapter 2-15, Sections 1 and 

2). Rhode Island has no current intentions to develop biomass 

harvesting guidelines, although it is aware of the issue and may 

address it in the future.

2f. Connecticut

Connecticut’s BMP field guide was revised in 2007 and focuses 

specifically on water-quality issues.15 This guide, like New York’s 

and Rhode Island’s, has little effect on biomass removals or DWM 

retention.12, 15, 45 Connecticut is now seeking funding to address 

biomass harvesting guidelines. Current BMPs recommend keeping 

slash out of water bodies and vernal pools. Connecticut’s BMPs 

do suggest that “brush and slash may be placed in skid trails and 

on slopes to slow water flow and retain sediment.”15 One layer 

of protection is the state’s certification program for foresters and 

loggers. Connecticut is watching the development of the biomass 

market carefully and would like to have some guidelines in place. 

It is now looking for funding for developing guidelines, possibly 

through a joint project between the state forestry department 

and the Connecticut Forest and Parks Association.

3. Review of State Biomass Harvesting and 

Retention Guidelines

3a. Michigan Woody Biomass Harvesting 

Guidance

Since 2008, the Michigan Department of Natural Resources has 

worked with a stakeholder group drawn from academia, environmental groups, forest industry, and state and federal agencies to 

develop biomass harvesting guidelines.36 These guidelines were 

designed to be used in conjunction with Michigan’s Sustainable 

Soil and Water Quality Practices on Forest Land manual.35 They 

emphasize that “not every recommendation listed in this guidance can or should apply to every situation.” While the Michigan 

guidelines provide a list of scientific references, there are no specific 

citations to support the retention or removal of forest biomass. 

• Avoid disrupting upturned tree roots from May to July to 

protect nesting birds.

• Maintain or create softwood inclusions in hardwood stands 

to provide a supply of longer-lasting down woody material.13

A revision of Good Forestry in the Granite State is currently 

underway and the recommendations for DWM in the draft are 

similar to the existing language. 

2c. Vermont

Although Vermont’s guide to Acceptable Management Practices 

for Maintaining Water Quality on Logging Jobs in Vermont is in 

its ninth printing, there is very little in the guide that would affect 

biomass harvesting or retention.60 The guide’s intent is to prevent 

discharges of mud, petroleum, and wood debris from getting into 

waterways. These BMPs are not mandatory unless a landowner is 

participating in Vermont’s Use Value Act. The state’s two woodpowered power plants in Burlington and Ryegate are required by 

the Public Service Board to ensure that their wood supply comes 

from sales with a harvest plan cleared by the Vermont Department 

of Forests, Parks and Recreation. The main focus of the review 

of harvest plans is to protect deer wintering areas. Related rules 

include the Heavy Cutting rules (Act 15), which require clearcuts 

(a reduction of basal area below the C-level) larger than 40 acres 

to have a permit (Title 10 V.S.A. Chapter 83, Section 2622). 

Another regulation that has some relevance to biomass harvesting 

is the requirement that whole-tree chip harvesters obtain a license 

(Title 10 V.S.A. Chapter 83, Section 2648).

An act of the Vermont Legislature created a Biomass Energy 

Development Working Group in 2009. That group is meeting 

regularly in a two-year initiative to address the major charges of 

(1) enhancing and developing Vermont’s biomass industry while 

(2) maintaining forest health. As part of its process, subgroups 

are addressing issues such as economic incentives, supply models, 

available technology, and workforce availability. A Forest Health 

subgroup will consider guidelines for retention of woody biomass, 

forest health indicators, and emerging research on carbon and 

biomass harvesting issues.

2d. New York

New York’s forest practice regulations are based the Environmental 

Conservation Law (§ 9-0105), though the regulations appear to 

only cover prescribed fires. The Best Management Practices for 

Water Quality has no recommendation about retention of DWM, 

snags, or other elements specific to biomass harvesting.45 These 

BMPs cover planning, landings, stream crossings, roads and 

trails, vernal pools, erosion control techniques, and post-harvest 

considerations. This document is under revision and will include 

expanded sections on riparian and wetland zone management 

but nothing on the ecological or silvicultural aspect of biomass 

harvesting. New York currently has no immediate plans to develop 

biomass harvesting guidelines. They are monitoring developments in other states and a biomass study now taking place at the 

Adirondack Research Consortium.
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Minnesota can remove woody biomass without significant negative impacts on snags and DWM. The test harvest had a small 

effect on the number of snags and on the amount of DWM. 

Reductions in DWM were small (2 tons per acre or less) and one 

site showed an increase in DWM.5 In addition, of the seven test 

sites where snags were measured, only three had a lower number 

of snags after harvest.5

3c. Missouri: Best Management Practices for 

Harvesting Woody Biomass

The catalyst for the development of biomass harvesting guidelines 

in Missouri was state legislation introduced in February 2007 

concerning cellulosic ethanol.34 In response to the lack of BMPs for 

biomass harvests, the Top of the Ozarks Resource Conservation and 

Development (RC&D), in partnership with Big Springs RC&D, 

Bootheel RC&D, the Eastern Ozarks Forestry Council, and 

the Missouri Department of Conservation, 

applied for and received 

a grant from the Northeastern Area State and 

Private Forestry branch 

of the U. S. Forest 

Ser vice to develop 

BMPs for biomass 

harvesting. The BMPs 

development process 

continued to emphasize 

participation through a 

stakeholder meeting for 

a cross-section of interested parties to discuss issues and possible 

criteria to be addressed in the BMPs for harvesting woody biomass. 

A technical committee brought expertise on soil science, wildlife 

biology, hydrology, forest management, and silviculture to the 

process. Meeting announcements and notes were provided online 

to allow for transparency in the development of BMPs.

The Missouri guidelines cover the major biomass harvesting 

topics (see Appendix I). Subtopics not covered in the Missouri 

guidelines include regeneration, removal of litter and forest floor, 

and fuel reduction. A section on pesticides was included in an 

early version of the biomass guidelines, but was later dropped 

because of its lack of relevance to biomass.

3d. Pennsylvania: Guidance on Harvesting 

Woody Biomass for Energy

Pennsylvania’s guidelines are a direct result of increased interest in 

woody biomass for energy. The passage of Pennsylvania’s Alternative Energy Portfolio Standards Act (Act 213 of 2004) helped 

drive that interest by requiring “all load-serving energy companies 

in the state to provide 18 percent of their electricity using alternative sources by the year 2020.” In response to the interest in using 

Pennsylvania’s forests to help meet alternative energy goals, the 

Department of Conservation and Natural Resources (DCNR) 

created biomass harvesting guidelines, intending to balance the 

need for alternative energy sources with the need to protect forest 

Topics such as riparian zones and pesticide use are covered by 

Sustainable Soil and Water Quality Practices and not in the biomass 

harvesting guidelines. Though brief, Michigan’s biomass guidelines, 

in combination with Sustainable Soil and Water Quality Practices, 

cover most of the major biomass harvesting topics (see Appendix 

I). However, there is little guidance on retention of snags. Michigan’s guidelines also lack specificity in some areas. For example, 

they suggest retention of anywhere from one-sixth to one-third 

of material less than 4 inches in diameter from harvested trees. 

3b. Minnesota: Biomass Harvesting Guidelines 

for Forestlands

The Minnesota state legislature directed the Minnesota Forest 

Resources Council (MFRC) and the Minnesota Department of 

Natural Resources (DNR) to develop guidelines for sustainably 

managed woody biomass.37 The goal of the guidelines was to help 

natural resource managers, loggers, equipment operators, contractors, and landowners make decisions about biomass harvesting. 

With the support of the DNR’s Ecological Services, Fisheries 

and Wildlife, and Forestry divisions, the MFRC directed the 

guideline development process. The 12-member interdisciplinary 

technical committee developed separate guidelines for brushland 

as well as for forestland. The technical committee reflected a 

range of expertise deemed pertinent to the development of these 

guidelines, including soil science, wildlife biology, hydrology, 

forest management, and silviculture. Meeting summaries were 

provided online, and the committee’s work was peer-reviewed 

and open to public comment. Minnesota’s biomass harvesting 

guidelines were crafted to be part of the MFRC’s 2005 forest 

management guidebook, Sustaining Minnesota Forest Resources, 

and the existing guidelines were integrated into the new biomass 

recommendations.

Minnesota’s biomass harvesting guidelines are rooted in precepts 

of ecological forestry. For example, the guidelines recommend 

emulating natural disturbances with silviculture and maintaining 

biological legacies after harvest. The guidelines make the case that, 

in Minnesota, biomass harvesting increases the disparity between 

managed stands and 

their natural analogs 

because it reduces the 

biological legacies left 

after harvest, such as 

slash and fallen logs. 

The guidelines cover 

almost all of the 

topics and subtopics 

related to biomass 

harvesting we considered in our analysis 

(see Appendix I). The 

only topics not obviously included or referenced were aesthetics, forest diseases, and 

land conversion.

A recent field test—an experimental biomass harvest—suggests 

that the harvesting practices utilized for biomass harvest in 

Photo: Eli Sagor

Photo: Zander Evans
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review of relevant statutes and regulatory and non-regulatory 

programs that operate within the state. 

3f. Wisconsin’s Forestland Woody Biomass 

Harvesting Guidelines

Wisconsin’s biomass guidelines were motivated by new price 

incentives to produce wood-based renewable energy and concerns 

about the environmental impacts of increased woody biomass 

removal.26 The Wisconsin Council on Forestry created an advisory committee with members from tribal, state, non-profit, and 

private forestry organizations. The guidelines were also reviewed 

by subject experts.

The guidelines cover much of the same ground as the other state 

guidelines (Table 1). They take advantage of the existing guidance provided by Wisconsin’s Silviculture and Forest Aesthetics 

Handbook and Forestry Best Management Practices for Water 

Quality. Issues such as regeneration, water quality, and aesthetics 

are dealt with in the existing manuals rather than the new biomass 

guidelines. A major focus of the Wisconsin guidelines is the 

identification of soil types, such as shallow, sandy, or wetland, 

that are most at risk of nutrient depletion.

3g. California Forest Practice Rules

California has some of the most comprehensive forest management regulations in the world. While there are currently no 

rules designed to specifically address intensive removal of forest 

biomass, the existing regulations address all of the main topics 

and most of the subtopics of woody biomass removal (Appendix 

I). For example, the California Forest Practice Rules point out that 

snags, den trees, and nest trees are a habitat requirement for more 

than 160 species and play a vital role in maintaining forest health. 

The importance of snags translates into regulations that require 

retention of all snags except where specific safety, fire hazard, 

insect, or disease conditions require they be felled.11

resources for all citizens and future generations. Pennsylvania’s 

guidelines include short-term rotational biofuel crops that might 

not traditionally fall under forest management guidelines.

Harvests on state forests are required to follow Pennsylvania’s 

guidelines. The guidelines also supply recommendations for 

private lands; these are drawn from Best Management Practices for 

Pennsylvania’s Forests, which was published by the Forest Issues 

Working Group in 1997. However, the new biomass guidelines 

did not draw on wider stakeholder participation, in part because of 

the time pressure to produce guidelines before forest-based energy 

projects were initiated. Pennsylvania’s guidelines are also unusual 

in that they include comments on biomass policy and a supply 

assessment. For example, the guidelines suggest that facilities 

requiring 2,000 tons per year are better suited to Pennsylvania 

than larger facilities. The guidelines also make a case for woody 

biomass as a carbon-neutral fuel source. 

Since Pennsylvania’s state forestlands are certified as meeting 

the standards of FSC, their biomass harvesting guidelines 

directly reference FSC standards. Pennsylvania’s DCNR uses 

the FSC’s Appalachia Regional Standard, but the state biomass 

harvesting guidelines provide greater specificity on woody 

biomass removals. For example, the FSC standard requires 

that “measures to protect streams from degradation of water 

quality and/or their associated aquatic habitat are used in all 

operations.” The Pennsylvania biomass guidelines extend this 

idea by adding “biomass harvesting of any materials along stream 

and river banks or along bodies of water is unacceptable.” The 

Pennsylvania biomass guidelines cover the range of potential 

biomass harvesting subtopics. Non-point source pollution 

and pesticides are not dealt with in the biomass harvesting 

guidelines, but these are covered in general forestry guidelines 

for Pennsylvania.

3e. Maryland: Development of Forest Biomass 

Harvesting Guidelines

Maryland is currently in the process of developing biomass 

harvesting guidelines. The Pinchot Institute for Conservation 

is facilitating a committee of individuals representing state 

forestry, environmental and energy agencies, cooperative extension, private landowners, non-profit conservation organizations, 

and local governments. Specialists in ecology, forest hydrology, 

forestry, economics, and other disciplines are included on the 

advisory committee. The guidelines will address the charge of the

Maryland Climate Action Plan, which states, “All biomass will 

be sustainably harvested without depriving soils of important 

organic components for reducing erosion, but will maintain 

soil nutrient structure, and will not deplete wildlife habitat or 

jeopardize future feedstocks in quantity or quality.” As such, 

Maryland’s biomass guidelines will address the protection of 

forest soils, water quality and aquatic resources, wildlife habitat 

and biodiversity, and silviculture and vegetation management. 

Other topics may also be included in the final version of the 

guidelines document. This guideline document is also linked to a 

technical support document that addresses the potential impacts 

associated with forest biomass harvesting in Maryland and a 

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and its associated regulated manuals and procedures). In British 

Columbia, biomass removals during current forest practices (e.g., 

full-tree with processing at roadside) are already covered under 

the Forest and Range Practices Act (FRPA). Regulations under 

the FRPA require the retention of at least 1.6 logs per acre (at 

least 16 feet in length and 12 inches in diameter on the coast 

and 6.5 feet in length and 3 inches in diameter in the interior; 

FRPA §68). In addition, a strategic plan for increased biomass 

removals is being developed, and scientists have begun to collate 

data that will be used to formulate guidelines for increased slash 

harvesting.

A 2008 conference entitled “The Scientific Foundation for Sustainable Forest Biomass Harvesting Guidelines and Policies,” hosted 

by Canada’s Sustainable Forest Management Network, helped set 

the stage for future policy development by providing an overview 

of existing research on biodiversity,33 site productivity considerations for biomass harvests,55 and existing knowledge gaps.56

5. Biomass Guidelines and Policy in

Northern Europe

Woody biomass provides a large contribution to the heat of 

Northern Europe and is also utilized for co-firing with coal and 

for straight biopower facilities in some countries such as the 

Netherlands and in the UK. Though management guidelines 

are similar across Northern Europe, their integration under the 

broader forest management policy is more varied. For example, 

the UK and Finland have determined that biomass harvesting 

guidelines work best as independent reference documents to help 

guide practitioners, whereas Austria and Sweden have integrated 

biomass harvesting protocols directly into their broader forest 

management protocols and regulations. The following section 

will review the approach that countries in Northern Europe have 

taken to biomass harvesting standards.

California’s regulations demonstrate the tradeoffs between the 

ecological benefits and the potential fire hazards of retaining dead 

wood on-site in fire-adapted ecosystems.10 For example, the California Forest Practice Rules emphasize the ecological importance 

of DWM for soil fertility, moisture conservation, and the support 

of microorganisms, but regulations dictate slash removal rather 

than retention. However, in riparian areas the Forest Practice 

Rules require operations to “protect, maintain, and restore trees 

(especially conifers), snags, or downed large woody debris” that 

provide stream habitat.11

A technical team of the Interagency Forestry Working Group is 

currently reviewing whether forest practice regulations in the state 

assure the ecological sustainability of forest biomass production 

and harvest. This technical team will also examine the carbon 

sequestration and storage impacts of both forest management 

and catastrophic fires.

4. Biomass Guidelines and Policy in Canada

As with state biomass guidelines in the U.S., woody biomass 

policy and guidelines in Canada are designed and implemented 

at the provincial level, not by the central government. Another 

similarity between the U.S. and Canada is the shift from a greater 

proportion of private holdings in the East to greater government 

(i.e., Crown) land ownership in the West. While provincial 

biomass guidelines would apply to public land and not private 

land, private landowners in eastern Canada are asking provincial 

governments for guidance on how best to manage their private 

land for bioenergy. 

An overview of biomass policy and guidelines from east to west 

in Canada reveals variation similar to that in the United States.48

Nova Scotia has formed a multi-stakeholder biomass committee of 

government, industry, and environmental groups that is discussing 

guidelines. There is currently a two-year moratorium on harvesting 

logging residue there to allow for input from this committee and 

then the creation of a government policy. In New Brunswick, the 

Department of Natural Resources has prepared draft guidelines 

on forest biomass harvesting. New Brunswick’s guidelines take 

advantage of a decision support tool for sustainable biomass 

allocation that evolved from a model used to predict impacts of 

atmospheric deposition. The guidelines exclude harvests on highrisk (low-nutrient) areas, and harvest and silviculture planning 

remain separate processes guided by the Crown land management 

framework. The policy calls for biomass harvesting sustainability 

to be assessed over an 80-year time period, which is “equivalent 

to the life span of an average forest stand.”42 The New Brunswick 

guidelines define biomass such that the guidelines do not apply 

to pulpwood fiber from whole-tree chipping. 

Like New Brunswick, Quebec is in the process of developing 

biomass guidelines based on soil properties. Ontario’s policy 

establishes objectives such as “to improve the utilization of forest 

resources by encouraging the use of forest biofibre for the production of energy and other value-added bioproducts.” However, the 

management and sustainable use of forest biomass is still guided 

by existing legislation (e.g., the Crown Forest Sustainability Act 
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deposition in these different regions. WTH clearcut operations 

are prohibited where they may negatively impact endangered 

species. The guidelines also stipulate that at least 20 percent of 

all slash must be left on-site. In addition to these site-specific 

guidelines, Swedish guidelines and regulations include criteria and 

indicators for sustainable forest management, forest certification, 

legislation, soil fertility, soil organic matter, wood production, 

biodiversity and wildlife, insects and fungi, hydrology and water 

quality, archaeological resources, cultural resources, recreational 

resources, nature conservation, silviculture, retention of tree species 

that are less commonly left in the stand, and stump harvesting.53

To hedge against the risk of soil nutrient depletion, the Swedish 

Forest Agency introduced additional wood ash recycling requirements in 2008; these supplement existing guidance on fertilization. The updated guidelines and regulations require that ash be 

applied to sites if the amount of harvest residues removed over the 

course of a rotation exceeds a half ton per hectare (0.2 tons per 

acre). For areas where biomass removals do not exceed this limit, 

ash recycling is deemed unnecessary; however, the regulation 

stipulates that ash be recycled in areas of high acid deposition, 

such as the southwest portion of the country. In Sweden, typical 

biomass removals are 0.5–1 ton per hectare, so recycling is de facto 

required on most sites. The prescription is to apply 2–3 tons per 

hectare every ten years and not to exceed two applications (i.e., 

6 tons of ash per hectare). Ash is also supposed to meet certain 

chemical composition standards and be hardened when applied to 

facilitate infiltration of nutrients into soils.32 Sweden’s guidelines 

also suggest that it is acceptable to apply ash in stands that have 

not yet been harvested, as a means to mitigate potential loss of 

site productivity if whole-tree removals are planned. Sweden is 

a strong proponent of forest certification, and the Swedish FSC 

standards specify that the recommendations of the Swedish 

forest agency are to be followed where biomass is used for energy.

5b. Finland

Finland is 74 percent forested with boreal and sub-boreal mixed 

softwood forests largely dominated by pine, spruce, and birch 

species. Upwards of 80 percent of the domestic roundwood supply 

comes from the three-quarters of the land base that is in private 

ownership.27 This land base supports a robust bioenergy sector. 

A full 20 percent of Finland’s total energy consumption comes in 

the form of bioenergy, with 11 percent of the nation’s electricity 

production coming from wood.25, 27, 50 Approximately 47 percent 

of the annual Finnish roundwood supply is consumed in the 

production of energy.25 Finland also imports an estimated 21 

percent of the total wood it consumes for energy.30 Finnish forest 

policy has made a goal of increasing the annual use of wood for 

energy by 5 million cubic meters, or nearly 5 million green tons.52

As in Sweden, harvests in Finland are highly mechanized, and 

WTH clearcuts are common practice. It is estimated that typical 

harvests of this nature remove between 60 and 80 percent of 

the total site biomass.54, 28, 47, 50, 61 Finnish biomass harvesting 

guidelines suggest that 30 percent of residue should remain 

and be distributed evenly over the site following clearcuts. In 

addition to final harvests, biomass is also produced though 

5a. Sweden

The use of forest-based bioenergy in Sweden increased in the 1980s 

as a result of growing concern over a reliance on imported oil and 

nuclear power. In 1991, the Swedish government introduced a 

carbon tax on fossil fuels used for heat and transportation. Since 

this time, the use of forest-based biomass for energy generation 

has more than doubled and forest-based bioenergy now accounts 

for more than 27 percent of total Swedish energy consumption 

(Swedish Energy Agency, 2008). Harvest regimes have responded 

to this growing demand for biomass by becoming increasingly 

mechanized, with preference for whole-tree harvesting (WTH) 

systems for both thinnings and final clearcut harvests.4, 8, 50, 32

From 50 to 80 percent of slash is typically removed, depending 

on site conditions and economic constraints.32 By some estimates, 

the share of bioenergy in Sweden could feasibly double before 

environmental and economic considerations fully constrain 

this supply.43

Sweden is 67 percent forested, and the vast majority of these 

forests are held by private owners with high willingness to manage 

their forest and harvest timber. The responsibility for ensuring 

that energy wood harvests are done in a sustainable manner is 

largely left to individual landowners, and the greatest area of 

concern that landowners have about the sustainability of biomass 

harvesting centers on nutrient cycling and site productivity.52

WTH clearcutting systems can increase soil nutrient losses by 

up to 7 percent, lead a reduction in site productivity of up to a 

10 percent, and have been linked to an increased rate of loss of 

biodiversity in managed forests in Sweden.54, 8, 49 In an attempt 

to mitigate these risks, the Swedish Forest Agency developed a 

set of recommendations and good-practice guidelines for WTH 

in 1986; these were updated in the 1990s and codified in the 

Swedish Forest Act of 2002. This legislation seeks to control 

WTH practices in order to limit impacts to forest soils, water 

resources, and long-term site nutrient balances. 

The general approach of Sweden’s guidelines and regulations is 

to classify different sites according to the risks associated with 

biomass removal at these sites. Different recommendations are 

then applied based on these classifications. In Sweden these 

specifications are to ensure that 

• all forest residues are dried and needles are left on-site before 

biomass removal, 

• sites in northern Sweden with abundant lichens should be 

avoided, and 

• sites with acidified soils, peat lands, or sites with a high risk 

of nitrogen depletion should be compensated with ash and 

nitrogen application. 

Like other Nordic countries, Sweden prohibits in-stand drying 

of forest residues in late spring and early summer to manage 

risks associated with bark beetle infestations. The guidelines 

and regulations also specify appropriate forest residue removal 

rates for different regions of Sweden, based on the risk of soil 

nutrient loss associated with historic and current patterns of acid 
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5c. Denmark

Denmark has less forestland than Finland or Sweden but woody 

biomass is still an important energy source. The Danish Biomass 

Agreement of 1993 called for increasing the rate of biomass 

produced for energy (primarily heating) by 1.4 million tons 

annually, with woody biomass to contribute 0.2–0.4 million 

tons annually.52

In Denmark, whole-tree chipping of small diameter trees from 

mid-rotation thinning is common; guidelines for public forestry 

lands recommend that these materials dry for at least two months 

before they are chipped, to avoid nutrient losses.47 It is not common 

practice to harvest slash associated with final clearcut harvests 

because of the logistical constraints in removing this biomass and/

or because of concerns about soil nutrient depletion and impacts 

to plant and animal communities.50 Issues addressed in Danish 

guidance documents include soil fertility, soil organic matter, 

management of insects and fungi, silviculture, stump harvesting, 

and production costs.52, 53 Danish guidance documents classify 

sites according to the dominance of hardwoods or softwoods and 

recommend that “stand-wise evaluations” be completed prior to 

harvests and that forest residues are dried for at least two months 

during the spring or summer. Other recommendations focus on 

stands of special conservation value for flora and fauna, and others 

for which wood production is not a primary objective. Guidance 

recommends avoiding exposed forest edges, nature conservation 

areas, and rare forest types.

Danish forest policy generally suggests that nutrients lost in logging 

may be compensated for through fertilization, and that stumps 

are not to be removed.52, 53 Forest policy also suggests that the 

maximum allowable amount of wood ash that should be applied 

over ten years ranges from 0.5 to 7.5 tons per hectare, although 

this depends on the specific chemical composition of the ash.

5d. The United Kingdom

With the UK’s biomass-based energy sector growing, the UK 

Forestry Commission has released a series of technical reference 

documents designed to help forest managers assess risks associated with biomass harvests.41, 59, 57, 58 These documents cover slash 

removal and stump removal as well as the associated risks to soil 

fertility, soil organic matter, biodiversity and wildlife, hydrology 

and water quality, archaeological resources, cultural resources, 

recreational resources, and nature conservation. 

The UK biomass harvesting guidance encourages managers to first 

classify sites according to their susceptibility to risks associated 

with biomass removal. In 2009, the UK Forestry Commission 

reevaluated the existing system of site classification used to assess 

the acceptability of biomass harvests. The previous classification 

had restricted the overall biomass supply by classifying large 

portions of the UK as sensitive forestland. The new classification 

was implemented to facilitate a more reliable biomass supply 

without adversely impacting natural resources.58 The guidance 

classifies sites according to soil types as being of low, medium, or 

high risk and lists associated slash and stump removal management 

early and mid-rotation thinning of small-diameter trees. This 

activity is not widespread across Northern Europe, due to 

operational and economic constraints, with the exceptions 

being Denmark, some Baltic states, and Finland.2, 50 Finland 

subsidizes both early rotation thinnings and the subsequent 

production of energy in order to support the production of 

commercial timber products.53

The Finnish approach to ensuring forest sustainability is to classify different sites according to the risks associated with biomass 

removals from these sites and to then apply different management 

recommendations based on these classifications. Site classifications include: mesic uplands and sites with fertile soils, sub-xeric 

and xeric sites, barren upland sites with lichens, peatland forest 

sites, stands with rocky soils, stands with low levels of available 

nutrients, water conservation areas, managed stands with more 

than 75 percent spruce, and stands where biomass removals have 

previously been performed through WTH clearcutting systems.53

Finnish guidelines contain operational protocols for site preparation, stump harvests, storing energy wood at roadside, and 

management of rotten wood.3 Additional issues addressed include 

wood production, biodiversity, wildlife habitat, insects and fungi, 

recreational resources, silviculture, stump harvesting, and biomass 

production costs (Stupak et al., 2008). Specific recommendations 

include that large dead trees either standing or on the ground 

should not to be collected or damaged. Exceptions can be made 

for certain salvage harvests in the wake of a significant disturbance 

event, and protocols for this are explicit. Riparian areas must be 

left unharvested, and the requisite width of riparian management 

zones depends on site characteristics (e.g., slope of harvesting sites 

and other watershed characteristics). 

In Finland, it is also common and recommended practice to 

remove stumps and roots in certain circumstances. This is done 

mainly in spruce stands as a part of preparing the site for the 

next planting and as a risk-management practice used to avoid 

root rot.27, 52 Stump wood cannot be removed from riparian 

areas or steep slopes unless “preventative measures” are taken. 

Stumps are also not to be removed from wetlands, sites with 

rocky soils, dry soils, or thin soils, or if stumps are less than 6 

inches in diameter. Stump removal protocols also recommend 

leaving a certain target number of stumps per acre for different 

soil types.21 Finland prohibits in-stand drying of forest residues 

in late spring and early summer to manage risks associated with 

bark beetle infestations.

While Finland does not require ash recycling through regulations, 

it is estimated that more than 10 percent of wood ash produced 

is typically returned to forests, usually in peat soils where it acts 

as a fertilizer. Finnish guidelines recommend that wood ash be 

spread on peat land after thinnings to act as a fertilizer, or if logging 

residues or stumps are extracted from nutrient-poor sites.53 Ash 

is commonly spread with forwarders at a rate of about 3–5 tons 

per acre every ten years, i.e, slightly more than is recommended 

in Sweden.47, 53 
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6. Other Organizations and Certification

Systems

6a. International Organizations

A number of international organizations have take up the issue of 

biomass harvest and retention. The International Energy Agency 

(IEA) conducts research through several programs. For example, 

Task 43 (feedstocks to energy markets) considers environmental 

issues, establishment of sustainability standards, exploration of 

supply chain logistics, and appropriate connections between 

harvesting standards and international trade and energy markets 

(www.ieabioenergy.com). The Global Bioenergy Partnership 

(GBEP) seeks to develop a common methodological framework to 

measure greenhouse gas emissions from biofuels and to developing 

science-based benchmarks and indicators for sustainable biofuel 

production. Throughout 2009, a GBEP task force was focused 

on the development of a set of relevant, practical, science-based, 

voluntary criteria and indicators as well as examples of best practices 

for biomass production. The criteria and indicators are intended 

to guide nations as they develop sustainability standards and to 

facilitate the sustainable development of bioenergy in a manner 

consistent with multilateral trade obligations (www.globalbioenergy.org). The Ministerial Conference on the Protection 

(MCPC) of Forests is a pan-European process to identify criteria 

and indicators for sustainability and adaptive management. In 

2007, the MCPC initiated a special project to assess the need for 

sustainability criteria given the increased demand for biomass. 

The implications of carbon balances on biomass energy are also 

being explored and may impact the EU’s 2009 Renewable Energy 

Directive (www.foresteurope.org).

6b. Federal Biomass Policy

U.S. federal policy on the use of woody biomass from forests 

has focused on how to define biomass and how or if sustainable 

should be legislated. Key areas of legislative focus are the type of 

wood that qualifies as renewable biomass, what kinds of ownerships can provide woody biomass, and the types of forest from 

which woody biomass can be procured. The following summary 

highlights aspects of federal law and proposed legislation that 

most directly influence the use of woody biomass from forests 

for energy. 

• Section 45 of the U.S. Internal Revenue Code The tax code 

defines what kinds of biomass are eligible for producing energy 

that qualifies for federal tax incentives such as the federal renewable energy production tax credit and investment tax credit. 

“Closed-loop biomass” is defined as “any organic material from 

a plant which is planted exclusively for purposes of being used at 

a qualified facility to produce electricity,” whereas “Open-loop 

biomass” includes a number of opportunity fuels, such as “any 

agricultural livestock waste nutrients,” “any solid, nonhazardous, 

cellulosic waste material or any lignin material which is derived 

from...mill and harvesting residues, pre-commercial thinnings, 

slash, and brush,” a variety of “solid wood waste materials,” and 

agricultural biomass sources. 

actions for each of these soil classifications. The assessment of site 

suitability for biomass harvests is to be based on the most sensitive soil type that covers greater than 20 percent of the site area. 

The guidelines suggest that site-specific risk assessments should 

be carried out before each harvest and should include a soil test. 

The guidance documents also recognize that there are significant 

uncertainties about the long-term sustainability of removing 

these materials and suggests that additional research is required 

to assess the full range of impacts, including net carbon balance. 

In the UK, biomass harvests typically occur in conifer plantations 

where slash is windrowed and left for 3–9 months following final 

timber harvests. This material is subsequently bailed and collected.58

Thinnings also supply biomass, but this volume is currently not 

significant. The guidelines suggest that thinnings pose less of an 

immediate risk to soil nutrient and base cation balance than do final 

clearcut harvests. In addition to removing timber harvest residues, 

there is increased interest in harvesting stumps. The UK Forestry 

Commission recently released interim guidance on stump removal, 

which states that in some instances the benefits of stump harvesting 

will outweigh the potential disadvantages, but that the removal of 

stumps very much requires a site-by-site evaluation. The report 

acknowledges that stump removal “poses a number of risks to the 

forest environment that can threaten both sustainable forest management and the wider environment,” including soil compaction, rutting, 

sedimentation, soil carbon loss, removal of macro- and/or micronutrients, and loss of soil buffer capacity due to loss of base cations.59

It is important to note that the slash removal guidance states that 

residue removals are acceptable on all high risk soil types as long as 

compensatory applications of fertilizer or wood ash are used. The 

guidelines in turn warn that application of wood ash may induce 

either nitrogen deficiency on nutrient-poor soils, or leaching of 

nitrates and/or soil acidification on nitrogen-saturated sites. The 

guidelines also point out that the application of fertilizers and 

wood ash may not be acceptable under forest certification programs 

that have stringent standards for the application of chemicals.

Photo: UK Forestry Commission
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produced while ensuring “the maintenance and enhancement of 

the quality and productivity of the soil” and promoting the “wellbeing of animals.” The future fate of the federal biomass definition 

is likely to be part of the large climate-change legislation being 

debated in Washington. Climate-change legislation may include 

a national Renewable Energy Standard (i.e., a renewable portfolio 

standard) that would dictate what kind of woody biomass can 

be included to meet renewable electricity generation goals. Some 

proposals would shift the burden of sustainability to the states 

and require biomass harvesting guidelines or regulations that 

meet some federal oversight.

6c. Forest Stewardship Council: U.S. National 

Forest Management Standard

The FSC standards for the 

U.S. do not specifically 

address biomass or whole 

tree harvests. In other 

words, “biomass and whole 

tree harvests are addressed 

along with other types of 

removals.”23 The FSC U.S. 

National Standard covers 

biomass harvesting at a 

more general level than 

most state guidelines, since 

they are nationwide. The main sections that affect biomass harvest 

are Criterion 6.2 (habitat for rare species), 6.3 (ecological functions), and 6.5 (soils and water quality). For example, Indicator 

6.3.f of the guidelines requires that “management maintains, 

enhances, or restores habitat components and associated stand 

structures, in abundance and distribution that could be expected 

from naturally occurring processes”; these habitat components 

include “live trees with decay or declining health, snags, and 

well-distributed coarse down and dead woody material.” This 

proposed requirement would place some limits on biomass removal, 

but it is not specific about the amount of DWM that should be 

retained on-site. Indicator 6.5.c limits multiple rotations of whole 

tree harvesting to sites where soil productivity will not be harmed.

Since FSC guidelines are not focused solely on biomass harvests, 

they go beyond other biomass guidelines in areas such as habitat 

connectivity. By the same token, because FSC guidelines cover 

many different kinds of harvests in many different forest types 

with diverse forest management objectives, the standards do 

not contain many subtopics that are specific to biomass harvest 

(Appendix I). 

The FSC standards are considered “outcome focused.” Rather 

than prescribing how to achieve desired outcomes, they allow a 

variety of practices to be used, so long as the management objectives and the FSC standards are not compromised. For example, 

one element that shows up in some biomass guidelines is re-entry, 

but FSC does not include this. Missouri’s guidelines advise, 

“Do not re-enter a harvested area [for the purposes of biomass 

harvesting] once the new forest has begun to grow,” in order 

to reduce the risk of compaction, which is a recommendation 

• Farm Security and Rural Investment Act of 2002 Public 

Law 107–171—May 13, 2002 This law included both “trees 

grown for energy production” and “wood waste and wood 

residues” in its definition of biomass. 

• Energy Policy Act of 2005 Public Law 109–58—Aug. 8, 

2005 The Energy Policy Act defined biomass to include “any 

of the following forest-related resources: mill residues, precommercial thinnings, slash, and brush, or non-merchantable 

material,” as well as “a plant that is grown exclusively as a fuel for 

the production of electricity.” This definition was more detailed 

than the previous 2002 Farm Bill and excluded material that 

would traditionally sell as timber.

• The Energy Independence and Security Act of 2007 Public 

Law 110–140—Dec. 19, 2007 The Energy Independence and 

Security Act included the Renewable Fuels Standard (RFS) and 

provided the most detailed definition of biomass to date. One of 

the most important distinctions it made was to separate woody 

biomass from private and federal lands. Biomass from federal 

lands was excluded and could not be used to produce renewable 

fuels. However, an exception was provided for woody biomass 

removed from the “immediate vicinity of buildings” for fire 

protection. The RFS also excluded biomass from certain types 

of forests seen as rare: “ecological communities with a global or 

state ranking of critically imperiled, imperiled, or rare pursuant 

to a State Natural Heritage Program, old growth forest, or late 

successional forest.” The RFS made an effort to discourage 

conversion of native forests to plantations by excluding woody 

biomass from plantations created after the enactment of the 

law. The RFS also established a subsidy of up to $20 per green 

ton of biomass delivered for facilities producing electric energy, 

heat, or transportation fuels.

• Food, Conservation, and Energy Act of 2008 Public Law 

110–246—June 18, 2008 The 2008 Farm Bill continued the 

trend toward great specification in the definition of renewable 

biomass. This time woody biomass from federal lands was 

included where it was the byproduct of preventive treatments 

to reduce hazardous fuels, contain disease or insect infestation; 

or restore ecosystem health. On private lands, the definition 

included essentially all trees and harvest residues. The exclusion for rare forests in the 2007 RFS was not included. The 

2008 Farm Bill also initiated the Biomass Crop Assistance 

Program (BCAP) to improve the economics of establishing and 

transporting energy crops and collecting and transporting forest 

biomass. Regarding eligibility requirements for this program, 

forest lands producing biomass must be covered by a “forest 

management plan.” The determination of what constitutes 

an “acceptable plan” is at the discretion of the State Forester. 

Other legislation has been proposed that includes more specific 

provisions designed to ensure the sustainability of biomass production. For example, HR 2454 would require that biomass from 

federal land be “harvested in environmentally sustainable quantities, as determined by the appropriate Federal land manager.” S 

1733, introduced September 9, 2009, stipulates that biomass be 

Photo: Zander Evans
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7b. Wildlife and Biodiversity

Many of the potential wildlife and biodiversity impacts stem 

from leaving too little dead wood on-site. The biomass guidelines 

reviewed here agree on the importance of avoiding sensitive sites for 

wildlife. These include areas of high biodiversity or high conservation value such as wetlands, caves, and breeding areas. Obviously, 

areas inhabited by threatened or endangered animals and plants 

receive special consideration. However, as the Minnesota guidelines 

point out, biomass harvesting may still be appropriate if management plans include specific strategies for maintaining habitat for 

rare species and/or to restore degraded ecosystems. Pennsylvania’s 

guidelines suggest that biomass removal may be an opportunity 

to “develop missing special habitats, such as herbaceous openings 

for grouse and other species, through planting, cutting, or other 

manipulations.” Additional suggestions from state guidelines 

include inventorying habitat features on the property, promoting 

individual trees and species that provide mast, and retaining slash 

piles that show evidence of use by wildlife. Missouri’s guidelines 

make the case against forest conversion in terms of wildlife: “Do 

not convert natural forests into tree plantations or pasture; natural 

forests provide more wildlife food and habitat.”

7c. Water Quality and Riparian Zones

In general, water quality and riparian concerns do not change 

with the addition of biomass removals to a harvest plan. Streams 

and wetlands tend to be protected by existing regulation. For 

example, Maine’s guidelines cite the existing laws governing water 

quality protection as well as the publication Protecting Maine’s 

Water Quality. Where restrictions in wetlands and riparian zones 

are defined in terms of basal area, more specific guidance may be 

needed for biomass harvests, which can have a large ecological 

impact with a small change in basal area. An example of riparian 

recommendations from Minnesota’s guidelines is to “avoid harvest 

of additional biomass from within riparian management zones 

echoed in the Minnesota and Pennsylvania guidelines. The FSC 

standards, however, do not specifically advise against re-entering 

a stand for the purpose of biomass harvesting. Instead, issues of 

compaction and the impacts of other soil disturbing activities 

are addressed in relation to all management activities under 

both 6.5 and 6.3.

6d. Other Voluntary Certification Systems

Other voluntary certification systems have standards which may 

influence forest biomass harvest and retention. For example, the 

Council for Sustainable Biomass Production (CSBP) released 

draft standards in 2009 and plans to release a preliminary standard in 2010.14 The draft standards were open for stakeholder 

and expert review and comment. The CSBP standards address 

soil, biological diversity, water, and climate change. As with FSC 

standards, CSBP makes general recommendations such as “retain 

biomass materials required for erosion control and soil fertility” 

(1.1.S3), but do not provide specific guidance on retention of 

DWM or snags.

7. Common Elements of Biomass Harvesting 

Guidelines

Though the existing biomass guidelines cover different ecosystems, 

they share a number of important elements. The following sections 

assess the similarities and differences between the guidelines’ 

recommendations on dead wood, wildlife and biodiversity, water 

quality and riparian zones, soil productivity, and silviculture. 

In addition, we compare the process used to develop each set of 

guidelines.

7a. Dead Wood

One of the central concerns in biomass removal is the reduction 

of the quantity of dead wood on-site. Maine’s guidelines recommend leaving tops and branches scattered across the harvest area 

“where possible and practical.” To ensure sufficient DWM debris 

is left on-site, Michigan’s draft guidelines recommend retention 

of one-sixth to one-third of the residue less than four inches in 

diameter. Minnesota guidelines recommend leaving all preexisting 

DWM and to “retain and scatter tops and limbs from 20 percent 

of trees harvested.” Wisconsin’s guidelines recommend retaining 

all pre-harvest DWM and tops and limbs from 10 percent of the 

trees in the general harvest area, with a goal of at least 5 tons of 

FWM per acre. Wisconsin’s guidelines also point out that “some 

forests lack woody debris because of past management,” and that 

extra DWM should be left in those areas. Pennsylvania’s guidelines suggest leaving 15 to 30 percent of “harvestable biomass” 

as DWM, while Missouri’s suggest 33 percent of harvest residue 

(with variations for special locations such as stream sides). 

Maine, Minnesota, Pennsylvania, and Wisconsin suggest leaving 

all snags possible. Except for some hazard exceptions, California 

requires retention of all snags. Missouri provides an example of 

clear and specific recommendations by suggesting 6 per acre in 

upland forests and 12 per acre in riparian corridors. Michigan 

does not have a specific recommendation for snag retention.

Photo: Zander Evans
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focus on the residual stand more than the trees being removed, 

and avoid high grading. Wisconsin’s guidelines suggest retaining 

“reserve trees and patches at 5–15 percent crown cover or stand 

area” in even-aged regeneration cuts and three or more large-cavity 

trees, large mast trees, and trees that can become large trees in the 

future. Maine’s guidelines recommend retention of cavity and 

mast trees while Wisconsin’s guidelines recommend retaining five 

percent of the area unharvested in salvage operations following 

severe disturbances.

Another operational recommendation that Minnesota, Missouri, 

and Pennsylvania all make is to avoid re-entering a stand to 

remove biomass. Re-entering a site where timber was recently 

harvested can increase site impacts such as soil compaction and 

harm post-harvest regeneration. For this reason, the Missouri 

guidelines advise that “woody biomass should be harvested at the 

same time as sawlog timber to avoid re-entry.” Maine’s guidelines 

recommend that woody biomass removal be integrated with 

traditional forest operations where possible.

7f. Biomass Guidelines Development

The process of developing guidelines can be as important as the 

specific recommendations. Most guidelines try to draw from the 

most recent forest science. Developing new biomass guidelines 

allows states to incorporate new research and ideas. Minnesota 

used funding from the University of Minnesota Initiative for 

Renewable Energy and the Environment to conduct a review of 

the scientific literature on biomass harvests. Other guidelines 

borrow from existing guidelines. For example, Pennsylvania’s 

guidelines borrow extensively from Minnesota’s guidelines and 

summarize the FSC’s standards for the region. 

The amount of stakeholder participation varies across the guidelines. While Pennsylvania’s guidelines were created from within 

the DCNR, Minnesota, Missouri, and Wisconsin included 

public participation and a technical committee from the wider 

forestry community. Public participation can be unwieldy, but 

often generates greater public support for forestry projects.20

Some of the biomass guidelines, such as those from New Brunswick, Canada, focus on the identification of geographies where 

biomass harvesting is most appropriate. Wisconsin takes a 

complementary approach, identifying soil types where biomass 

removal is inappropriate. By mapping soil types, guidelines can 

highlight those areas where concerns about nutrient depletion 

are lowest. Suitability mapping also permits the consideration of 

the landscape-scale impacts of biomass harvesting. Pennsylvania’s 

guidelines are notable because they consider the supply of biomass 

from forests as well as the appropriate scale of utilization. As 

mentioned previously, Pennsylvania’s guidelines make a case for 

small-scale (less than 2,000 tons of biomass per year) biomass 

utilization facilities.

8. Conclusion

This revised assessment of biomass guidelines reviews a wide range 

of approaches to the sustainable use of biomass that can inform 

over and above the tops and limbs of trees normally removed in 

a roundwood harvest under existing timber harvesting guidelines.” 

Though the Missouri Watershed Protection Practice already 

includes requirements for stream and river management zones, 

the Missouri biomass guidelines reiterate how to protect streams 

and rivers during a harvest.

7d. Soil Productivity

As with water quality, some aspects of soil productivity are usually 

included in standard forestry BMPs. For instance, Minnesota’s 

biomass guidelines point readers to the state’s timber harvesting 

guidelines, which contain sections titled “Design Outcomes to 

Maintain Soil Productivity” and “Minimizing Rutting.” However, 

Minnesota’s biomass guidelines do add warnings about harvesting 

biomass on bog soils and shallow soils (less than 8 inches) over 

bedrock. An appendix to Wisconsin’s guidelines lists over 700 

specific soil map units which are nutrient poor and unlikely to be 

able to support sustainable biomass removal. Maine’s guidelines 

use the Briggs classification of soil drainage classes to identify sites 

that are more sensitive to biomass removals.9 Missouri’s guidelines 

contain a specific section on sustaining soil productivity, especially 

on steep slopes and shallow soils. Michigan recommends leaving 

more than one-third of harvested tops on shallow, nutrient-poor 

or semi-organic soils. However, Michigan’s guidelines suggest 

that the amount of retention can be reduced on jack pine stands 

on nutrient poor sites.

Another concern that arises with biomass harvest is removal 

of the litter layer or forest floor. Maine, Michigan, Minnesota, 

Pennsylvania, and Wisconsin’s guidelines state that forest floor, 

litter layer, stumps, and root systems should all be left.

7e. Silviculture

Many silvicultural prescriptions call for the removal of small, 

unhealthy, or poorly formed trees to open up more growing space 

for crop trees or regeneration, but these types of removals often 

cost money rather than generate income. By providing income 

from the removal of this material, biomass markets can help 

support good silviculture. At the same time, biomass removals 

raise some silvicultural concerns. The Minnesota guidelines point 

out that an increase in the amount of live vegetation removed may 

cause swamping, i.e., a decrease in transpiration and an increase 

in soil moisture. Swamping can kill seedlings and negatively 

impact regeneration. Removal of tree tops and branches may also 

remove seeds or cones, which may reduce the amount of natural 

regeneration. Biomass removals can help deal with forest insect 

problems, but removing the biomass material from the site must be 

timed to avoid contributing to pest problems such as bark beetles.

Some states have used biomass guidelines to make silvicultural 

recommendations that may improve stands but are not directly 

related to biomass harvesting. The Missouri biomass guidelines 

provide silvicultural suggestions for the number of crop trees per 

acre for stands in different stages of development. Pennsylvania’s 

guidelines suggest that forest stewards “provide for regeneration 

each time harvests are made under the uneven-aged system,” 
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Biomass Sustainability and Carbon Policy Study

guidelines, the new guidelines should provide clear references to the relevant sections of the existing rules and guidelines both for convenience and to increase the likelihood of 

implementation.

• Take advantage of the opportunity to create new forestry 

recommendations that encourage excellent forestry: forestry 

that goes beyond minimum BMPs and enhances the full 

suite of ecological values. For example, biomass guidelines 

may be an opportunity to suggest alternatives to high grading 

and other practices that damage the long-term health of the 

forest. Similarly, biomass guidelines can present the chance 

to advocate for appropriately scaled biomass utilization, as 

Pennsylvania guidelines already do.

9. Acknowledgments

This report benefited from the comments of Don Arnosti, Amber 

Ellering, Kathryn Fernholz, Ehrhard Frost, Brad Hutnik, Ken 

Laustsen, Darcie Mahoney, Eunice Padley, Michael Palko, David 

Ray, Christopher Riely, Paul Trianosky, and Pieter van Loon.

Special thanks to Doug Enyart, Clearwater Forestry Consultants, 

LLC, for help with developing the section addressing the Missouri 

guidelines, Brian Titus, Research Scientist, Natural Resources 

Canada, for his help with the Canadian section, and to Hillevi 

Eriksson, Swedish Forest Agency for her help with the section 

that details activities in Europe.

10. References

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Biomass for Energy: Survey of State Foresters, State Energy Biomass 

Contacts, and National Council of Forestry Association Executives. 

Journal of Forestry 107(6):297-306.

2 Ahtikoskia, A., J. Heikkila, V. Aleniusa, and M. Sirenc. 2008. 

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3 Aijala, O., K. M., and M. Halonen. 2005. Energy Wood Harvest 

from Clear Cuts, Guidelines. Quality Project of Energy Wood 

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the development of guidelines in Massachusetts. The section on 

New York and New England may be the most helpful, because 

these states are dealing with similar timber types and land ownership patterns. However, there are number of other state-based 

approaches, such as those of Minnesota and Michigan, that can 

be readily transferable. Northern Europe has a long history of 

intensive biomass use, and while their harvesting systems and 

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Massachusetts. The sections on other organizations and federal 

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be influenced or integrated with other approaches. 

The final section, which explores the common elements of biomass 

harvesting guidelines, offers a structure to develop guidelines 

tailored to Massachusetts. The Forest Guild has used that structure 

to develop a set of guidelines, Biomass Retention and Harvesting 

Guidelines for the Northeast, which is readily applicable to Massachusetts. These guidelines are included as a separate document. 

The following recommendations for the development of future 

biomass guidelines in Massachusetts are based on the existing 

guidelines and available science, and will change as more is learned 

about biomass removals:

• Develop guidelines that are based on sound science and 

include wide stakeholder engagement. As the Minnesota 

guidelines describe it, “Provide the best scientific judgment, 

tempered by the consensus process among a broad group of 

forest management interests, related to practices that will 

sustain a high level of biodiversity.”

• Define “woody biomass” and other important terms clearly.

• Base biomass harvesting recommendations on local ecology. 

They should recognize state or local natural communities, 

disturbance regimes, and other ecological traits. Technical 

committees and scientific literature provide a firm base for 

harvest recommendations.

• Consider developing guidelines for each of the subtopics listed 

in Appendix I—though not all subtopics will be appropriate 

for every location. 

• Make clear and specific recommendations for the retention 

of standing dead trees, existing CWM, CWM generated by 

the harvest, FWM, and forest floor and litter layer. Because 

reduction of dead wood is one of the key differences between 

biomass removal and traditional harvest, it should be a focus 

of future guidelines. Nutrients removed from the site should 

be replenished. For even-aged systems, nutrients should be 

replenished to adequate levels by the end of the rotation. 

Uneven-aged systems should maintain nutrient levels close 

to the optimum. Nutrient levels may be temporarily reduced 

after each entry, but should return to adequate levels by the 

next cutting cycle.

• Make biomass guidelines practical and easy to follow. Where 

biomass guidelines supplement existing forestry rules and 
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18 Elliot, C., editor. 2008. Biodiversity in the Forests of Maine: 

Guidelines for Land Management. University of Maine Cooperative 

Extension. Bulletin 7174, Orono, ME.

19 Evans, A. M., and A. J. Finkral. 2009. From Renewable Energy 

to Fire Risk Reduction: A Synthesis of Biomass Harvesting and 

Utilization Case Studies in Us Forests. Global Change Biology 

Bioenergy 1(3):211-219.

20 Evans, A. M., and G. McKinley. 2007. An Evaluation of Fuel Reduction 

Projects and the Healthy Forests Initiative. Forest Guild, Santa Fe, NM.

21 Fernholz, K., S. Bratkovich, J. Bowyer, and A. Lindburg. 2009. 

Energy from Woody Biomass: A Review of Harvesting Guidelines 

and a Discussion of Related Challenges. Dovetail Partners, Inc., 

Minneapolis, MN.

22 Flatebo, G., C. R. Foss, and S. K. Pelletier. 1999. Biodiversity in 

the Forests of Maine: Guidelines for Land Management. University 

of Maine, Cooperative Extension, Orono, ME.

23 FSC. 2009. Us Forest Management Standard Draft 8.1. Forest 

Stewardship Council, Washington, DC.
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54 Sverdrup, H., and K. Rosen. 1998. Long-Term Base Cation Mass 

Balances for Swedish Forests and the Concept of Sustainability. 

Forest Ecology and Management 110(1-3):221-236.

55 Titus, B. D., S. M. Berch, D. M. Morris, R. L. Fleming, P. 

W. Hazlett, D. Pare, and P. A. Arp. 2008. Synopsis of on-Going 

Canadian Research on Biomass Harvesting and Site Productivity. in 

Proceeding of The Scientific Foundation for Sustainable Forest Biomass 

Harvesting Guidelines and Policies. Sustainable Forest Management 

Network, Edmonton, AB.

56 Titus, B. D., C. T. Smith, D. Puddister, J. R. Richardson, and C. 

Young. 2008. Notes from Facilitated Discussions. in Proceeding of 

The Scientific Foundation for Sustainable Forest Biomass Harvsting 

Guidelines and Policies. Sustainable Forest Management Network, 

Edmonton, AB.

57 UK Forestry Commission. 2009. Forests and Soils Guidelines 

Consultation Draft, July 2009. Forest Research, the Research Agency 

of the UK Forestry Commission. http://www.forestry.gov.uk/pdf/

FCGL008consultation.pdf/$FILE/FCGL008consultation.pdf

58 UK Forestry Commission. 2009. Guidance on Site Selection for 

Brash Removal. Forest Research, the Research Agency of the UK 

Forestry Commission. http://www.biomassenergycentre.org.uk/pls/

portal/docs/PAGE/BEC_TECHNICAL/BEST%20PRACTICE/

BRASH_RESIDUE_PROTOCOL-1.PDF

59 UK Forestry Commission. 2009. Stump Harvesting: Interim 

Guidance on Site Selection and Good Practice. Forest Research, 

the Research Agency of the UK Forestry Commission. http://

www.biomassenergycentre.org.uk/pls/portal/docs/PAGE/

BEC_TECHNICAL/BEST%20PRACTICE/FC_STUMP_

HARVESTING_GUIDANCE_APRIL09.PDF

60 VT DFPR. 1987. Acceptable Management Practices for 

Maintaining Water Quality on Logging Jobs in Vermont. 

Department of Forests, Parks, and Recreation, Waterbury, VT.

61 Walmsley, J. D., D. L. Jones, B. Reynolds, M. H. Price, and J. R. 

Healey. 2009. Whole Tree Harvesting Can Reduce Second Rotation 

Forest Productivity. Forest Ecology and Management 257(3):1104-

1111.

62 Woodall, C. W., and V. J. Monleon. 2008. Sampling Protocol, 

Estimation, and Analysis Procedures for the Down Woody Materials 

Indicator of the Fia Program. NRS-GTR-22, U.S. Forest Service, 

Newtown Square, PA.

41 Moffat, A., B. M. Jones, and B. Mason. 2006. Managing Brash 

on Conifer Clearfell Sites. Practice Note, UK Forestry Commission, 

Farnham, England.

42 New Brunswick DNR. 2008. Forest Biomass Harvesting. New 

Brunswick Department of Natural Resources, Fredericton, New 

Brunswick.

43 Nilsson, L. J., B. Johansson, K. Astrand, K. Ericsson, P. 

Svenningsson, and P. Borjesson. 2004. Seeing the Wood for the 

Trees: 25 Years of Renewable Energy Policy in Sweden. Energy for 

Sustainable Development 8(1).

44 Norton, G., S. Abraham, and A. Veneman. 2003. Memorandum 

of Understanding on Policy Principles for Woody Biomass 

Utilization for Restoration and Fuel Treatments on Forests, 

Woodlands, and Rangelands. U.S. Forest Service and Bureau of Land 

Management, Washington, DC.

45 NYSF. 2007. Best Management Practices for Water Quality. New 

York State Forestry, Albany, NY.

46 PA DCNR. 2008. Guidance on Harvesting Woody Biomass 

for Energy. Pennsylvania Department of Conservation and Natural 

Resources, Harrisburg, PA.

47 Raison, R. J., P. Hakkila, D. G. Neary, J. A. Burger, P. Angelstam, 

G. Mikusinski, and M. Breuss. 2002. Effects of Very Intensive Forest 

Biomass Harvesting on Short and Long Term Site Productivity. in J. 

Richardson, R. Björheden, P. Hakkila, A. T. Lowe, and C. T. Smith, 

editors. Bioenergy from Sustainable Forestry: Guiding Principles and 

Practice. Kluwer Academic Publishers, Hingham, MA.

48 Ralevic, P., J. Karau, T. Smith, and J. Richardson. 2008. Iea 

Bioenergy Task 31 Country Report: Canada. International Energy 

Agency, Ottawa, Canada.

49 Raulund-Rasmussen, K., I. Stupak, N. Clarke, I. Callesen, H.-S. 

Helmisaari, E. Karltun, and I. Varnagiryte-Kabasinskiene. 2008. 

Effects of Very Intensive Forest Biomass Harvesting on Short and 

Long Term Site Productivity. Pages 29-78 in D. Röser, A. Asikainen, 

K. Raulund-Rasmussen, and I. Stupak, editors. Sustainable Use of 

Forest Biomass for Energy. Springer Netherlands.

50 Röser, D., A. Asikainen, K. Raulund-Rasmussen, and I. Stupak, 

editors. 2008. Sustainable Use of Forest Biomass for Energy—a 

Synthesis with Focus on the Baltic and Nordic Region. Springer.

51 Shepard, J. P. 2006. Water Quality Protection in Bioenergy 

Production: The Us System of Forestry Best Management Practices. 

Biomass and Bioenergy 30(4):378–384.

52 Stupak, I., A. Asikainen, M. Jonsell, E. Karltun, A. Lunnan, D. 

Mizaraite, K. Pasanen, H. P. rn, K. Raulund-Rasmussen, D. R. ser, 

M. Schroeder, I. Varnagiryte, L. Vilkriste, I. Callesen, N. Clarke, T. 

Gaitnieks, M. Ingerslev, M. Mandre, R. Ozolincius, A. Saarsalmi, 

K. Armolaitis, H.-S. Helmisaari, A. Indriksons, L. Kairiukstis, K. 

Katzensteiner, M. Kukkola, K. Ots, H. P. Ravn, and P. Tamminen. 

2007. Sustainable Utilisation of Forest Biomass for Energy—

Possibilities and Problems: Policy, Legislation, Certification, and 

Recommendations and Guidelines in the Nordic, Baltic, and Other 

European Countries. Biomass and Bioenergy 31:666–684.

53 Stupak, I., T. Nordfjell, and P. Gundersen. 2008. Comparing 

Biomass and Nutrient Removals of Stems and Fresh and Predried 

Whole Trees in Thinnings in Two Norway Spruce Experiments. 

Canadian Journal of Forest Research 38(10):2660–2673.
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ME MN MO PA WI FSC

Dead Wood

Coarse woody material √ √ √ √ √ √

Fine woody material √ √ √ √ √ √

Snags √ √ √ √ √ √

Wildlife and Biodiversity √

Wildlife √ √ √ √ √ √

Sensitive wildlife species √ √ √ √ √ √

Biodiversity √ √ √ √ √ √

Plants of special concern √ √ √ √ √ √

Sensitive areas √ √ √ √ √ √

Water Quality and Riparian Zones

Water quality √ √ √ √ √ √

Riparian zones √ √ √ √ √ √

Non-point source pollution √ √ √ √ √ √

Erosion √ √ √ √ √ √

Wetlands √ √ √ √ √ √

Soil Productivity

Chemical (Nutrients) √ √ √ √ √ √

Physical (Compaction) √ √ √ √ √ √

Biological (Removal of litter) √ √ √ √

Silviculture

Planning √ √ √ √ √

Regeneration √ √ √ √

Residual stands √ √ √ √ √ √

Aesthetics √ √ √ √

Post operations √ √ √ √ √

Re-entry √ √ √

Roads and skid trail layout √ √ √ √ √ √

Disturbance

Insects √ √ √ √ √

Disease √ √ √ √

Fire √ √ √ √

Fuel reduction √ √ √

Pesticides √ √

Invasives √ √ √

Conversion from forest √ √ √

11. Appendix I

Summary Table of Biomass Guidelines
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Biomass Sustainability and Carbon Policy Study

12. Appendix II

Links to Biomass Harvesting 

Guidelines

• Considerations and Recommendations for Retaining 

Woody Biomass on Timber Harvest Sites in Maine http://

www.maine.gov/doc/mfs/pubs/biomass_retention_guidelines.html

• Minnesota: Biomass Harvesting Guidelines for Forestlands 

http://www.frc.state.mn.us/FMgdline/BHGC.html

• Missouri: Best Management Practices for Harvesting 

Woody Biomass 

http://mdc4.mdc.mo.gov/applications/MDCLibrary/

MDCLibrary2.aspx?NodeID=2055

• Pennsylvania: Guidance on Harvesting Woody Biomass 

for Energy 

http://www.dcnr.state.pa.us/PA_Biomass_guidance_final.pdf

• Wisconsin Council on Forestry: Use of Woody Biomass 

http://council.wisconsinforestry.org/biomass/

• Forest Stewardship Council 

http://www.fscus.org/standards_criteria/

• Canada: The Scientific Foundation for Sustainable Forest 

Biomass Harvesting Guidelines and Policies

http://www.sfmnetwork.ca/html/biomass_workshop_e.html

• New Brunswick: Forest Biomass Harvesting Policy

http://www.gnb.ca/0078/Policies/FMB0192008E.pdf
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Appendix 4–C

Forest Biomass Retention and 

Harvesting Guidelines for the 

Northeast

Table of Contents

1. Introduction and Background............................................................. 169

The Forest Guild Guidelines..................................................................... 169

Creating the Guidelines..................................................................... 170

“Sustainability” and Biomass Harvesting............................................. 170

Definitions..................................................................................................... 170

Biomass................................................................................................... 170

Downed Woody Material................................................................. 170

2. Guidelines for Biomass Retention and Harvesting for All Forest 

Types................................................................................................................ 170

Site Considerations to Protect Rare Forests and Species.................. 171

Retention of Downed Woody Material ....................................... 171

Maintenance of Soil Fertility........................................................... 171

Guidelines for DWM Retention............................................................. 171

Retention of Forest Structures for Wildlife and Biodiversity......... 171

Water Quality and Riparian Zones........................................................ 172

Harvesting and Operations....................................................................... 172

3. Relevant Research for Northeastern Forest Types......................... 173

Measurements of Downed Woody Material............................... 173

Spruce–Fir Forests....................................................................................... 173

Northern Hardwood Forests.................................................................... 173

Transitional Hardwood /Oak-Hickory Forests.................................. 173

White and Red Pine Forests..................................................................... 173

4. Carbon considerations and Guidelines..............................................174

Strategies that Improve the Carbon Budget on Managed Forests..174

Determining the Carbon Impact of Biomass Harvesting .......174

Guidelines for Carbon Storage................................................................ 175

5. Resources and References...................................................................... 175

BMPs and Other State Guides........................................................ 175

Forest Guild Reports.......................................................................... 175

References....................................................................................................... 175

1. Introduction and Background

Interest in removing wood with a historically low economic 

value from forests has increased because of rising fossil fuel costs, 

concerns about carbon emissions from fossil fuels, and the risk of 

catastrophic wildfires. Even as federal, state and regional programs 

encourage the utilization of forest biomass, there are concerns 

about its potential adverse effects on biodiversity, soil productivity, wildlife habitat, water quality, and carbon storage. At the 

same time, biomass removal and utilization have the potential to 

provide a renewable energy source, promote the growth of highervalue trees and forest products, reduce forest fire risk, support 

the removal of invasive species, and help to meet the economic 

development goals of rural communities. These guidelines are 

designed to encourage protection of soils, wildlife habitat, water, 

and other forest attributes when biomass or other forest products 

are harvested in the Northeastern United States.

Our Principles

1. The well-being of human society is dependent on responsible forest management that places the highest priority 

on the maintenance and enhancement of the entire forest 

ecosystem.

2. The natural forest provides a model for sustainable 

resource management; therefore, responsible forest 

management imitates nature’s dynamic processes and minimizes impacts when harvesting trees and other products.

3. The forest has value in its own right, independent of 

human intentions and needs.

4. Human knowledge of forest ecosystems is limited. 

Responsible management that sustains the forest requires 

a humble approach and continuous learning.

5. The practice of forestry must be grounded in field observation and experience as well as in the biological sciences. 

This practical knowledge should be developed and shared 

with both traditional and non-traditional educational 

institutions and programs.

6. A forester’s or natural resource professional’s first duty 

is to the forest and its future. When the management directives of clients or supervisors conflict with the Mission and 

Principles of the Guild, and cannot be modified through 

dialogue and education, a forester or natural resource 

professional should disassociate

The Forest Guild Guidelines

The Forest Guild guidelines are designed to augment and enhance 

existing Best Management Practices (BMPs) or new state-based 

biomass guidelines that may, in some cases, leave managers and 

policy makers looking for more detailed recommendations. While 

these guidelines were developed to address biomass harvesting, 

they also are intended to inform all harvests in northeastern 

forests. We developed these guidelines to assist several audiences: 

field foresters, loggers, state-based policy makers charged with 

developing biomass guidelines and standards, biomass facilities 

wishing to assure sustainability, third party certifiers, and members 

of the public interested sustainable forest management. 

These guidelines are based on the Forest Guild’s principles (see 

text box). Forest Guild members are concerned with reconciling 

biomass removals with the principles of excellent forestry—forestry 

that is ecologically, economically, and socially responsible. Excellent forestry exceeds minimum best management practices and 

places the long-term viability of the forest above all other considerations. It uses nature as a model and embraces the forest’s many 

values and dynamic processes. Excellent forestry maintains the 

functions, structures, and composition that support the health 

of the entire forest ecosystem. Excellent forestry is different in 
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Biomass Sustainability and Carbon Policy Study

are presented not as static targets to be maintained at all times 

in all places, but rather as guideposts on a path to sustainability. 

Definitions

Biomass

In a scientific context, the term “biomass” includes all living or 

dead organic matter. In common parlance, biomass usually refers 

to woody material that has historically had a low value and was 

not considered merchantable in traditional markets. Biomass 

harvesting can also involve the removal of dead trees, downed 

logs, brush, and stumps, in addition to tops and limbs. Changing 

markets and regional variations determine which trees are considered sawtimber or pulpwood material and which are relegated to 

the biomass category. This report does not discuss biomass from 

agricultural lands and short-rotation woody biomass plantations.

In this report, the term biomass refers to vegetation removed from 

the forest, usually logging slash, small-diameter trees, tops, limbs, or 

trees not considered merchantable in traditional markets. Similarly 

we use the phrase biomass harvesting to refer to the removal of 

logging slash, small-diameter trees, tops, or limbs. 

Biomass can be removed in a number of ways. Some harvests remove 

only woody biomass, some combine the harvest of sawtimber or 

other products with biomass removal, and some remove biomass 

after other products have been removed. This report focuses on postharvest forest conditions and not on the type of harvest. The goal 

is to ensure the forest can support wildlife, maintain biodiversity, 

provide clean water, sequester carbon, protect forest soil productivity, and continue to produce income after a biomass harvest or 

repeated harvests. In some regions, current wood utilization is 

such that very little woody material is available for new markets 

such as energy. For these high-utilization areas, application of 

these guidelines may result in more biomass being left in the forest.

Downed Woody Material

Woody material is sometimes divided into coarse woody material (CWM) and fine woody material (FWM). CWM has been 

defined as more than 6 inches in diameter at the large end and 

FWM that is less than 6 inches in diameter at the large end.17 

The USDA Forest Service defines CWM as downed dead wood 

with a small-end diameter of at least 3 inches and a length of 

at least 3 feet, and FWM as having a diameter of less than 3 

inches.25 FWM has a higher concentration of nutrients than 

CWM. Large downed woody material, such as logs greater than 

12 inches in diameter, is particularly important for wildlife. In 

this report, we use the term downed woody material (DWM) 

to encompass all three of these size classes, but in some circumstances we discuss a specific size of material where the piece size 

is particularly important.

2. Guidelines for Biomass Retention and 

Harvesting for All Forest Types

The following recommendations are applicable across a range of forest 

types in the Northeast. However, different forest types naturally 

each ecoregion, but is guided by science, place-based experience, 

and continuous learning. 

Forest Guild members acknowledge their social responsibilities 

as forest stewards to address climate change and mitigate the 

buildup of atmospheric carbon. In addition, we understand how 

renewable fuels derived from well-managed forests can provide 

energy security and enhance rural communities. At the same 

time, we have an ecological imperative to ensure that all our 

harvests—including biomass harvests—maintain or enhance 

the ecological values of the forest. 

Creating the Guidelines

Our working group consisted of 23 Forest Guild members representing public and private field foresters and resource managers, 

academic researchers and members of major regional and national 

environmental organizations. The process was led by Forest Guild 

staff and was supported by two Forest Guild reports: Ecology of 

Dead Wood in the Northeast 4 and An Assessment of Biomass 

Harvesting Guidelines.5 Wherever possible we base our recommendations on peer-reviewed science. However, in many cases 

research is inadequate to connect practices, stand level outcomes, 

and ecological goals. Where the science remains inconclusive, 

we rely on field observation and professional experience. The 

guidelines provide both general guidance and specific targets 

that can be measured and monitored. These guidelines should 

be revisited frequently, perhaps on a three-year cycle, and altered 

as new scientific information and results of field implementation 

of the guidelines become available.

“Sustainability” and Biomass Harvesting

Using a common definition, sustainable biomass harvests would 

“meet the needs of the present without compromising the ability 

of future generations to meet their needs” (Brundtland Commission 1987). Crafting a more precise definition of sustainable forest 

management is inherently complex because forest ecosystems are 

simultaneously intricate, dynamic, and variable. Sustainable forest 

management must integrate elements of ecology, economics, 

and societal well being. These guidelines primarily pertain to 

issues of sustaining ecological function and productivity; they 

are not meant to replace a comprehensive assessment of forest 

sustainability.

In general, the sustainability of managed forests must be judged 

on timelines that span generations. Individual trees can persist 

for centuries and management decisions made today will have 

important implications well beyond the tenure of any one manger. 

The indigenous focus on the impact of decisions seven generations 

into the future is more appropriate. Similarly, sustainability must 

be judged on scales larger than that of the individual forest stand. 

For example, large mammal home ranges, water quality, and a 

viable forestry industry all depend on landscapes that encompass 

multiple stands. Due to the difficulties of defining appropriate 

time frames and spatial scales, the concept of forest sustainability 

is best thought of as an adaptive process that requires regular 

monitoring and recalibration. Consequently, these guidelines 
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Biomass Sustainability and Carbon Policy Study

steep slopes, and other erosion-prone sites as sensitive to biomass 

removals. We encourage states to identify low-nutrient soil series 

where biomass harvesting should not occur and those soil series 

where biomass harvests require particular caution. Wisconsin’s 

Forestland Woody Biomass Harvesting Guidelines is an excellent 

example.11

In areas that do not qualify as low-nutrient sites, where 1/3 of 

the basal area is being removed on a 15- to 20-year cutting cycle, 

it is our professional judgment that retaining 1/4 to 1/3 of tops 

and limbs will limit the risk of nutrient depletion and other negative impacts in most forest and soil types. Additional retention 

of tops and limbs may be necessary when harvests remove more 

trees or harvests are more frequent. Similarly where the nutrient 

capital is deficient or the nutrient status is unknown, increased 

retention of tops, branches, needles, and leaves is recommended. 

Conversely, if harvests remove a lower percentage of basal area, 

entries are less frequent, or the site is nutrient-rich, then fewer 

tops and limbs need to be retained on-site.

Guidelines for DWM Retention

• In general, when 1/3 of the basal area is being removed on a 15 

to 20 year cycle, retain 1/4 to 1/3 of the slash, tops, and limbs 

from harvest (i.e., DWM).

• Three main factors influence the percentage of tops and limbs 

that should be left onsite: 

- number of live trees left on-site, 

- time between harvests, and 

- available soil nutrients.

• As harvesting intensity increases (and the three preceding 

factors decrease) more slash, tops, and limbs from harvests 

should be left on-site

• As harvesting intensity decreases (and the three factors increase) 

less slash, tops, and limbs from harvests are required to protect 

site productivity.

• Avoid harvesting on low-nutrient sites or adjust retention of 

tops, branches, needles, and leaves.

• Retain DWM of all sizes on-site including FWM, CWM and 

large downed logs. 

• In general, leave DWM distributed across the harvest site. 

However, there may be cases where piles of DWM provide 

habitat, or redistribution of DWM collected at the landing 

would cause excessive damage to soil or regeneration.

• Minimize the removal of needles and/or leaves by harvesting 

in winter, retaining FWM on-site, or leaving felled trees on-site 

to allow for needle dro

Retention of Forest Structures for Wildlife 

and Biodiversity

• Leave and protect litter, forest floor, roots, stumps, and large 

downed woody material.

• Leave and protect live cavity trees, den trees, other live decaying 

trees, and snags (i.e., dead standing trees >10”). Individual 

develop different densities of snags, DWM, and large downed logs. 

Unfortunately, even after an exhaustive review of the current science 

there is too much uncertainty to provide specific targets for each 

forest type. The recommendations in this section set minimum 

retention targets necessary for adequate wildlife habitat and to 

maintain the integrity of ecological process such as soil nutrient 

cycling. Wherever possible, exceed the targets as a buffer against 

the limitations of current research. Section 3 presents research 

that may help landowners and foresters interested in additional 

tree, snag, and DWM retention tailored to specific forest types. 

Site Considerations to Protect Rare Forests 

and Species

• Biomass harvests in critically imperiled or imperiled forest 

types (i.e., globally recognized or listed as S1 or S2 in a State 

National Heritage Program) should be avoided unless necessary to perpetuate the type. Management of these and other 

rare forest types (for example, those ranked S3 by state Natural 

Heritage Programs) should be based on guidance from the local 

Natural Heritage Program and/or other local ecological experts.

• Biomass harvesting may be appropriate in sensitive sites to 

control invasive species, enhance critical habitat, or reduce 

wildfire risk. However, restoration activity should be guided 

by ecological goals and not designed solely to supply biomass. 

It is unlikely that restored sites will contribute to the long-term 

wood supply, because biomass removals for restoration may not 

be repeated at regular intervals.

• Old growth forest stands with little or no evidence of harvesting 

are so rare in the Northeast that they should be protected 

from harvesting, unless necessary to maintain their structure 

or ecological function. Areas with scattered old growth trees 

or late-successional forest characteristics should be carefully 

managed to ensure retention of their ecological functions. 

Biomass generally should not be removed from these areas. 

Retention of Downed Woody Material 

Though CWM represents a large pool of nutrients in some ecosystems, it likely plays a relatively small role in nutrient cycling for 

managed Northeastern forests. A review of scientific literature 

suggests that biomass harvesting is unlikely to cause nutrient 

problems when both sensitive sites (including low-nutrient sites) 

and clearcutting with whole-tree removal are avoided (see Evans and 

Kelty 2010 for a more detailed discussion of the relevant scientific 

literature). However, there is no scientific consensus on this point 

because of the limited range of treatments and experimental sites.

Maintenance of Soil Fertility

Biomass harvesting on low-nutrient sites is a particular concern. For 

example, Hallett and Hornbeck note that “red oak and white pine 

forests growing on sandy outwash sites are susceptible to nutrient 

losses due to inherently low-nutrient capitals and/or nutrient 

depletion by past activities such as farming, fire, and intensive 

harvesting.”9 Maine’s Woody Biomass Retention Guidelines1 list 

shallow-to-bedrock soils, coarse sandy soils, poorly drained soils, 
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Biomass Sustainability and Carbon Policy Study

• Management that maintains multiple vegetation layers, from 

the overstory canopy to the midstory, shrub, and ground layers 

will benefit wildlife and plant species diversity.

Water Quality and Riparian Zones

In general, water quality and riparian concerns do not change 

with the addition of biomass removals to a harvest plan. Refer 

to state water quality best management practices (BMPs) and 

habitat management guidelines for additional measures to protect 

streams, vernal pools, and other water bodies (see Appendix I for 

a list of these BMPs and habitat management guidelines).

• DWM retention described above is also important for water 

quality, because DWM reduces overland flow and holds water. 

• Leave and protect existing woody material in streams, ponds, 

and lakes. DWM in riparian systems provides sites for vegetation colonization, forest island growth and coalescence, and 

forest floodplain development.

• Leave and protect live decaying trees (e.g., cavity/den trees), 

snags, and large downed logs in riparian or stream management zones. 

• Keep vernal pools free of slash, tops, branches, and sediment 

from forestry operations. If slash falls into the pool during the 

breeding season, it is best to leave it in place to avoid disturbing 

egg masses or other breeding activity that may already be 

occurring.

• Within 100 feet of the edge of a vernal pool, maintain a shaded 

forest floor to provide deep litter and woody debris around 

the pool. Also avoid ruts, bare soil, or sources of sediment 

near vernal pools.

• Extra care should be taken working in or around forested 

wetlands because of their importance for wildlife and ecosystem 

function. Wetlands are often low-fertility sites and may 

support rare natural communities, so removal of DWM may 

be inappropriate. 

Harvesting and Operations

Most concerns about the operational aspects of biomass harvesting 

are very similar to all forestry operations. However, some key 

points are worth emphasizing:

• Protect forest land from conversion to non-forest use and native 

forest from conversion to plantations.

• Involve a professional forester (or a licensed forester in states 

where available) in development of a long-term management 

plan and supervision of harvests.

• Engage a certified logger from the Master Logger Certification 

Program or other similar program when harvesting.

• Follow all best management practices (BMPs) for the state 

or region.

• Plan and construct roads and skid trails based on professional 

advice and BMPs.

• Integrate biomass harvesting with other forest operations. 

Re-entering a site where timber was recently harvested to remove 

snags that must be felled for safety requirements should not be 

removed from the forest. 

Table 1. General Guidelines for Retaining Forest Structures

Structure

Minimum Target 

(per acre) Considerations

Number Basal 

area (ft2)

Live decaying 

Trees 12 –18 

inches DBH

4 3–7

Where suitable trees for 

retention in these size 

classes are not present 

or may not reach these 

targets due to species or 

site conditions, leave the 

largest trees possible that 

will contribute toward 

these targets.

Live decaying 

trees >18 

inches DBH

1 2

Snags >10 

inches DBH 5 3

Worker safety is top 

priority. Retain as 

many standing snags as 

possible, but if individual 

snags must be felled for 

safety reasons, leave them 

in the forest.

Table 1 is based on the scientific literature review in The Ecology of 

Dead Wood in the Northeast4 as well as other biomass harvesting 

and retention guidelines5. These guidelines are not meant to be 

attained on every acre, at all times. Rather, they are average targets to 

be applied across a stand, harvest block, or potentially an ownership.

• If these forest structures do not currently exist, select and 

identify live trees to become these structures in the future. 

Retaining live decaying trees helps ensure sufficient snags in the 

future. Similarly, both decaying trees and snags can eventually 

become large downed logs.

• If forest disturbances such as hurricanes, ice storms, and insect 

infestations create large areas of dead trees, leaving all snags or 

decaying trees may be impractical. If an area is salvage logged, 

leaving un-salvaged patches totaling 5% to 15% of the area will 

provide biological legacies important to wildlife. However, the 

potential for insect populations to build up in dead trees may 

prohibit retention of unsalvaged patches in some situations.

• Since there are differences in decay rates and wildlife utilization, retain a variety of tree species as snags, DWM, and large 

downed logs.

• In areas under even-aged management, leave an uncut patch 

within or adjacent to every 10 acres of regeneration harvest. Uncut 

patches, including riparian buffers or other set-asides within the 

management unit, should total 5% to 15% of the harvest area.

• Build retention patches around large legacy trees, den or cavity 

trees, large snags, and large downed logs, to maximize structural 

and habitat diversity.

• Marking retention trees will help ensure that sufficient numbers 

are retained during the current harvest, and that and they will 

not be removed in subsequent harvests.
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Spruce–Fir Forests

Research data on DWM in Maine’s spruce-fir forest include 3.4 

tons per acre10 and a range from 22 to 117 tons per acre.20 The 

low estimate of 3.4 tons per acre is from a survey that includes 

intensively-managed lands that may not have enough DWM to 

maintain ecosystem processes and retain soil nutrients,10 while 

the higher estimates come from unmanaged lands.20

The basal area of dead trees from a survey of paper birch-red 

spruce-balsam fir and red spruce-balsam fir stands ranged from 

11 to 43 percent of stand basal area.23 The Canadian province 

of Newfoundland and Labrador requires retention of 4 snags 

per acre, while Maine recommends retaining 3 snags and/or 

cavity trees greater than 14 inches DBH and one greater than 

24 inches DBH.6, 19 Smith and colleagues recommend retention 

and recruitment of white birch snags to ensure sufficient snag and 

DWM density.19 Other guidelines recommend between 5 and 

6 snags per acre greater than 8 inches DBH and an additional 4 

to 6 potential cavity trees at least 10 inches DBH.26

Northern Hardwood Forests

Measures of the DWM in northern hardwood forests are as low 

as 3.1 tons per acre (Roskoski 1977), but 16 other measurements 

from 6 scientific articles average 17 tons per acre, with a low of 

8 tons per acre.18, 21, 8, 14, 16, 2 Dead trees made up 3 to 14 percent 

of the basal area in five hemlock-yellow birch stands and 5 to 34 

percent of basal area in sugar maple-beech-yellow birch stands.23

Other research suggests retention of between 5 and 17 snags per 

acre.7, 15, 13 Tubbs and colleagues recommend leaving between 

one and ten live decaying trees per acre at least 18 inches DBH.24

Research has documented a range of 7 to 25 to cavity trees per 

acre in unmanaged stands.7, 13

Transitional Hardwood /Oak-Hickory Forests

Measures of the DWM in transitional hardwood forests, i.e., 

oak-hickory forests of southern New England, range from 5.8 to 

18 tons per acre.22, 12 Out of seven oak stands in Connecticut, 

the number of dead trees ranged from 19 to 44 per ac or 5 to15 

percent of basal area.23

White and Red Pine Forests

Estimates of the volume of downed dead wood in white and red 

pine forests range from 1.6 to 50 tons per acre of DWM.3, 10 

Unmanaged red pine stands in the Great Lakes area had 30 snags 

per acre while a managed forest had 6.9 per acre.3 Many of the red 

oak and white pine stands on sandy outwash sites are susceptible 

to nutrient losses because of a combination of low-nutrient capital 

and past nutrient depletion.9

4. Carbon Considerations and Guidelines

To date, forestry or biomass harvesting BMPs have not included 

guidelines for the management of carbon. However, climate 

change has the potential to fundamentally change both forests 

and forestry over the next century. Moreover, climate change 

has added carbon management to the responsibilities of forest 

biomass can increase site impacts such as soil compaction and 

may harm post-harvest regeneration.

• Use low impact logging techniques such as directional felling 

or use of slash to protect soil from rutting and compaction 

from harvest machines.

• Use appropriate equipment matched to site and operations.

3. Relevant Research for Northeastern

Forest Types

Although there is too much scientific uncertainty to provide 

specific targets for each forest type, the research described below 

may help landowners and foresters interested in additional tree, 

snag, and DWM retention tailored to specific forest types. We 

hope the need to better quantify decaying tree, snag, and DWM 

retention requirements will catalyze new research efforts and the 

retention target can be updated based on new science.

Measurements of Downed Woody Material

Most of the scientific research measures DWM in terms of dry tons 

per acre rather than percentage of DWM retained after harvest. 

Tons per acre may not currently be a useful measurement unit for 

forester and loggers, but we present data in those units here because 

of their prevalence in scientific literature. This measurement unit 

may become more prevalent as biomass harvesting increases. 

Field practitioners typically have not paid a great deal attention 

to volumes of DWM. Measurement techniques are available to 

integrate DWM sampling into forest inventories; over time, field 

practitioners will develop an awareness of volumes-per-acre of 

DWM, similar to standing timber volumes. The Natural Fuels 

Photo Series illustrates various levels of DWM and can be used 

to assist this process (http://depts.washington.edu/nwfire/dps/).

In general, stands have the most DWM when they are young (and 

trees are rapidly dying from competition) or when they are old (and 

trees are in various states of decline). Healthy, intermediate-aged 

stands tend to have less DWM. The following table represents 

a target range for the mass of DWM left on-site after harvest 

(including both existing and harvest-generated DWM). The 

table is based on a number of studies that documented the ranges 

of observed DWM in managed and unmanaged stands in the 

Northeast (see Evans and Kelty 2010 for more details). The selected 

target ranges reflect measurements from unmanaged stands more 

than those from managed stands and take into account patterns 

of DWM accumulation during stand development.

Table 2. DWM Ranges by Forest Type

Northern 

HW

SpruceFirOakHickory

White 

and Red 

Pine

Tons of DWM 

per acre* 8–16 5–20 6–18 2–50

* Includes existing DWM and additional material left during 

harvesting to meet this target measured in dry tons per acre.
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increased mean carbon stocking volume and a potential increase 

in carbon in harvested wood products stored offsite.

The use of logging slash for energy production has a lower carbon 

impact than the use of live trees for energy because logging slash 

will decay and emit carbon and other greenhouse gases, while live 

trees will continue to sequester carbon. Similarly, since trees naturally die, decay, and emit carbon, harvests that focus on suppressed 

trees likely to die in the near future produce fewer carbon emissions overall than the harvest of trees that are healthier, sequester 

carbon faster, and have long life expectancies. By using biomass 

harvests to remove suppressed trees with shorter life expectancies, 

the remaining healthier trees, “crop trees,” can grow faster and 

larger and produce higher-value products. These more valuable 

products have the potential to store carbon off-site longer than 

products with a shorter life cycle, such as paper or shipping pallets. 

These products also will meet human needs while emitting less 

carbon than alternatives such as steel or concrete. However, the 

harvest of future crop trees for energy is the worst case scenario: 

such a harvest reduces on-site carbon, probably limits the economic 

productivity of the stand, and reduces the opportunity to produce 

higher-value products that provide long-term carbon storage and 

displace more carbon-intensive products.

Determining the Carbon Impact of Biomass Harvesting

While the use of forest biomass for energy production can be 

helpful in mitigating climate change, accounting procedures for 

carbon mitigation programs must accurately account for all of 

the impacts of the proposed biomass use. The accounting should 

be based on a life cycle analysis that evaluates the effects of forest 

management and biomass removals on forest carbon . In order to 

determine the carbon impact of a biomass harvest, the analysis 

must include the following elements:

1. The amount of carbon removed from the site.

2. The amount of carbon used to grow, remove and transport the 

material to utilization.

3. The efficiency and carbon emissions of the use of forest biomass 

for energy, compared to business-as-usual (i.e., no biomass harvest) 

alternatives.

4. Future carbon sequestration rate for the site.

5. The impact of biomass removals on the site’s capacity to grow 

forest products that store carbon or replace other carbon-intensive 

products.

6. The time required to re-sequester the carbon removed from 

the site and the time required to re-sequester the carbon that 

would have been sequestered in the business-as-usual scenario.

7. The business-as-usual scenario which includes

a. Predicted harvest rates for the forest type and site in question

b. Carbon emissions factors for the production, transportation, 

and use of the business-as-usual fuel, most likely a fossil fuel.

managers and landowners (Forest Guild Carbon Policy Statement 

2010). Protecting forests from conversion to other land uses is 

the most important forest management measure to store carbon 

and mitigate climate change. Biomass harvests may reduce the 

incentive to convert forests to other uses by providing additional 

income to forest landowners, and maintaining the forest industry 

and availability of markets.

The extent to which forest biomass can serve as a low-carbon 

alternative to fossil fuels is currently the subject of intense debate. 

In 2010, the Forest Guild is engaged in a comprehensive study 

commissioned by the Massachusetts Department of Energy 

Resources and led by Manomet Center for Conservation Sciences. 

Together with Manomet and other partners, we are investigating 

the impact of various forest practices on atmospheric carbon 

between managed and unmanaged forests. The results of this 

study will be available by June 2010 and will be used to expand 

this section on the carbon considerations for biomass harvesting. 

The Manomet study will model different biomass harvest scenarios 

to help determine which forest practices have less of an impact 

on the accumulation of atmospheric carbon. 

In the interim, the following sections offer suggestions based on 

research that is currently available. It is important to recognize 

that in some cases a practice that contributes to a significant 

reduction in atmospheric carbon may be, or may appear to be, in 

conflict with considerations regarding biodiversity or long-term 

site productivity, as outlined in previous sections of this document. For example, while utilizing logging slash for energy may 

prove important in a scenario designed to reduce atmospheric 

carbon, the retention of some logging slash post harvest may 

also be important for the maintenance of forest productivity. In 

such cases, as in many areas of forestry, divergent goals must be 

balanced for the specific operating unit or ownership. As discussed 

in previous sections, the guidelines in this report are primarily 

intended to support decision making about the maintenance of 

ecological function and value in a forest management context.

Strategies that Improve the Carbon Budget on Managed 

Forests

Some forest management strategies can increase carbon sequestration rates and store more carbon over time than others. Silviculture 

that encourages the development of structural complexity stores 

more carbon than silvicultural methods that create homogenous 

conditions. Uneven-aged management is often used to promote 

a structurally complex forest and can sequester more carbon 

than less structurally complex forests managed with even-age 

methods. Even-aged management systems periodically remove 

most of the forest carbon. When used in existing mature forests 

they may have a greater negative carbon impact, particularly since 

near-term carbon emission reductions are most important. Where 

even-aged management systems are appropriate, encouraging 

advance regeneration, or retaining residual components of the 

original stand, may be the fastest way to build up or maintain 

forest carbon. Extending rotation length will also result in an 
Manomet Center for Conservation Sciences 175 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

• Northeast Master Logger Certification Program

http://www.masterloggercertification.com/ 

• Natural Fuels Photo Series

http://depts.washington.edu/nwfire/dps/ 

Forest Guild Reports

• Ecology of Deadwood in the Northeast

• www.forestguild.org/publications/research/2010/ecology_

of_deadwood.pdf

• An Assessment of Biomass Harvesting Guidelines

www.forestguild.org/publications/research/2009/biomass_

guidelines.pdf

• Synthesis of Knowledge from Biomass Removal Case 

Studies www.forestguild.org/publications/research/2008/

Biomass_Case_Studies_Report.pdf

• A Market-Based Approach to Community Wood Energy: 

An Opportunity for Consulting Foresters www.forestguild.

org/publications/research/2008/Market_Based_CWEP_

Approach.pdf

References

1 Benjamin, J. G. 2010. Considerations and Recommendations 

for Retaining Woody Biomass on Timber Harvest Sites in Maine.

Miscellaneous Publication 761, University of Maine, Maine 

Agricultural and Forest Experiment Station, Orono, ME

2 Bradford, J., P. Weishampel, M.-L. Smith, R. Kolka, R. A. Birdsey, 

S. V. Ollinger, and M. G. Ryan. 2009. Detrital Carbon Pools in 

Temperate Forests: Magnitude and Potential for Landscape-Scale 

Assessment. Canadian Journal of Forest Research 39(4):802–813

3 Duvall, M. D., and D. F. Grigal. 1999. Effects of Timber 

Harvesting on Coarse Woody Debris in Red Pine Forests across 

the Great Lakes States, USA. Canadian Journal of Forest Research 

12(29):1926-1934

4 Evans, A. M., and M. J. Kelty. 2010. The Ecology of Dead Wood in 

the Northeast. Forest Guild, Santa Fe, NM

5 Evans, A. M., and R. T. Perschel. 2009. An Assessment of Biomass 

Harvesting Guidelines. The Forest Guild, Santa Fe, NM

6 Flatebo, G., C. R. Foss, and S. K. Pelletier. 1999. Biodiversity in 

the Forests of Maine: Guidelines for Land Management. University of 

Maine, Cooperative Extensive, Orono, ME

7 Goodburn, J. M., and C. G. Lorimer. 1998. Cavity Trees and 

Coarse Woody Debris in Old Growth and Managed Northern 

Hardwood Forests in Wisconsin and Michigan. Canadian Journal of 

Forest Reseach 28:427–438

8 Gore, J. A., and W. A. Patterson, III,. 1986. Mass of Downed 

Wood in Northern Hardwood Forests in New Hampshire: Potential 

Effects of Forest Management. Canadian Journal of Forest Research

16(2):335-339

9 Hallett, R. A., and J. W. Hornbeck. 2000. Managing Oak and Pine 

Stands on Outwash Sands: Protecting Plant Nutrients. Northern 

Journal of Applied Forestry 17(2):57-61

10 Heath, L. S., and D. C. Chojnacky. 2001. Down Dead Wood 

Statistics for Maine Timberlands, 1995. RB-NE-150, Forest Service, 

Northeastern Research Station, Newtown Square, PA

A full accounting that includes these elements can help answer 

complex questions regarding forest management and carbon 

impacts. For example, logging slash plays a number of functions. 

It is a valuable source of nutrients, provides biodiversity habitat, 

stores carbon on-site and is a potential source of renewable energy. 

Biomass retention guidelines provide targets for how much to retain 

for ecological reasons. But how much to remove as a renewable fuel 

versus how much to leave for on-site carbon storage can only be 

answered by comprehensive modeling of carbon flows over time.

Guidelines for Carbon Storage

• When managing for shade-tolerant and mid-tolerant species, a 

shift from even-aged to uneven-aged management will increase 

the retention of carbon on-site.

• When appropriate to the tree species, a shift to regeneration 

methods that encourage advanced regeneration, such as from 

clearcut to shelterwood, will retain carbon on-site for longer 

periods.

• Retain reserve trees or standards or delay their removal. 

• Delay regeneration harvests or lengthen harvest cycles to grow 

trees for longer times and to larger sizes. 

• Encourage rapid regeneration.

• Capture natural mortality as efficiently as possible while 

retaining adequate numbers of snags, decaying trees, and DWM.

• Use biomass harvests to concentrate growth on healthy crop 

trees that can be used to manufacture products that hold 

carbon for long periods or replace carbon-intensive products.

5. Resources and References

BMPs and Other State Guides

• Maine’s Woody Biomass Retention Guidelines

http://www.maine.gov/doc/mfs/pubs/biomass_retention_

guidelines.html

• Biodiversity in the Forests of Maine: Guidelines for Land 

Management

http://www.maine.gov/doc/mfs/pubs/pdf/

biodiversity_forests_me.pdf 

• Vernal Pool Habitat Management Guidelines (Maine)

http://www.maine.gov/doc/mfs/pubs/pdf/vernal_pool_

hmg.pdf

• Good Forestry in the Granite State: Recommended Voluntary Forest Management Practices for New Hampshire 

http://extension.unh.edu/resources/files/Resource000294_

Rep316.pdf

• Acceptable Management Practices for Maintaining Water 

Quality on Logging Jobs in Vermont http://www.vtfpr.org/

watershed/documents/Amp2006.pdf 

• Massachusetts Forestry Best Management Practices Manual

http://www.mass.gov/dep/water/drinking/forstbmp.pdf

• Connecticut Best Management Practices for Water Quality 

while Harvesting Forest Products http://www.ct.gov/dep/

cwp/view.asp?A=2697&Q=379248 
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11 Herrick, S., J. Kovach, E. Padley, C. Wagner, and D. Zastrow. 

2009. Wisconsin’s Forestland Woody Biomass Harvesting Guidelines.

PUB-FR-435-2009, WI DNR Division of Forestry and Wisconsin 

Council on Forestry, Madison, WI

12 Idol, T. W., R. A. Figler, P. E. Pope, and F. Ponder. 2001. 

Characterization of Coarse Woody Debris across a 100 Year 

Chronosequence of Upland Oak-Hickory Forests. Forest Ecology and 

Management 149(1-3):153-161

13 Kenefic, L. S., and R. D. Nyland. 2007. Cavity Trees, Snags, and 

Selection Cutting: A Northern Hardwood Case Study. Northern 

Journal of Applied Forestry 24(3):192-196

14 McCarthy, B. C., and R. R. Bailey. 1994. Distribution and 

Abundance of Coarse Woody Debris in a Managed Forest Landscape 

of the Central Appalachians. Canadian Journal of Forest Research

24(7):1317–1329

15 McGee, G. G. 2001. Stand-Level Effects on the Role of Decaying 

Logs as Vascular Plant Habitat in Adirondack Northern Hardwood 

Forests. The Journal of the Torrey Botanical Society 128(4):370-380

16 McGee, G. G., D. J. Leopold, and R. D. Nyland. 1999. Structural 

Characteristics of Old-Growth, Maturing, and Partially Cut 

Northern Hardwood Forests. Ecological Applications 9(4):1316-1329

17 MFRC. 2007. Biomass Harvest Guidelines. Minnesota Forest 

Resources Council, St. Paul, MN

18 Roskoski, J. P. 1977. Nitrogen Fixation in Northern Hardwoods 

Forests. Yale University, New Haven, CT

19 Smith, C. Y., M. T. Moroni, and I. G. Warkentin. 2009. Snag 

Dynamics in Post-Harvest Landscapes of Western Newfoundland 

Balsam Fir-Dominated Boreal Forests. Forest Ecology and 

Management 258(5):832-839

20 Taylor, A. R., J. R. Wang, and H. Y. H. Chen. 2007. Carbon Storage in 

a Chronosequence of Red Spruce (Picea Rubens) Forests in Central Nova 

Scotia, Canada. Canadian Journal of Forest Research 37(11):2260–2269

21 Tritton, L. M. 1980. Dead Wood in the Northern Hardwood Forest 

Ecosystem. Yale University, New Haven, CT

22 Tritton, L. M., C. W. Martin, J. W. Hornbeck, and R. S. Pierce. 

1987. Biomass and Nutrient Removals from Commercial Thinning 

and Whole-Tree Clearcutting of Central Hardwoods. Environmental 

Management 11(5):659-666

23 Tritton, L. M., and T. G. Siccama. 1990. What Proportion of 

Standing Trees in Forests of the Northeast Are Dead? Bulletin of the 

Torrey Botanical Club 117(2):163-166

24 Tubbs, C. H., R. M. DeGraaf, M. Yamasaki, and W. M. Healy. 

1987. Guide to Wildlife Tree Management in New England Northern 

Hardwoods. GTR-NE-118, US Forest Service, Northeastern Forest 

Experiment Station, Broomall, PA

25 Woodall, C. W., and V. J. Monleon. 2008. Sampling Protocol, 

Estimation, and Analysis Procedures for the Down Woody Materials 

Indicator of the Fia Program. NRS-GTR-22, U.S. Forest Service, 

Newtown Square, PA

26 Woodley, S. 2005. Snag and Cavity Tree Retention. Pages 

61-64 in M. G. Betts and G. J. Forbes, editors. Forest Management 

Guidelines to Protect Native Biodiversity in the Greater Fundy 

Ecosystem. New Brunswick Co-operative Fish and Wildlife Research 

Unit, University of New Brunswick, Fredericton, NB
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Appendix 5

Summary of Public Input to Study

The intent of the public meeting held on December 17, 2009 in 

Holyoke, Massachusetts was: 

1) to share information about the study and the questions it will 

address; and

2) solicit public input about additional questions the research 

team should consider (within the scope of the DOER RFP).

Nearly 200 people attended the public meeting. Following an 

overview presentation, those that were interested in providing 

input were broken into to small groups where the questions and 

comments were recorded and reported out. Those questions and 

comments are contained in the table below. The team reviewed 

these inputs and addressed those that were relevant to the study 

and within the scope of what DOER asked the team to assess. 

Additional input was solicited via the internet. The internet site 

was meant to be a venue for the submission of additional comments 

and not a forum for discussion with the study team. Maintaining 

an ongoing public dialogue during the study was outside the scope 

and budget of the study commissioned by DOER.

Outside of the public meeting, many additional submissions of 

comments, opinion, technical resources, and relevant articles were 

also submitted to the team and distributed to the appropriate 

subject matter expert. Submissions were made by a range of 

concerned citizens, organizations, and technical experts.

Comments/Questions developed during small group breakout sessions at December 17, 2009 input meeting in Holyoke, MA 

(note: several submissions were illegible)

Comment Category

Why weren’t researchers working on this issue in west included on panel? Comments/Questions to DOER

Will each of these questions be explicitly dealt with in a public way? Comments/Questions to DOER

Why aren’t they looking at emissions/pollution? Comments/Questions to DOER

How is study being coordinated with adjacent states? Comments/Questions to DOER

If we gave this level of scrutiny to every other power producer, would anything get built? Comments/Questions to DOER

Are new technologies (such as combined heat and power) being encouraged for existing 

power plants? Comments/Questions to DOER

Can (we) guarantee exactly what emissions are emitted? Comments/Questions to DOER

Sustainable communities - where is power going? (local or distant) Comments/Questions to DOER

What happens when the wood runs out, will you turn to waste? Trash? And are there 

adequate standards in place to govern trash? Comments/Questions to DOER

What if your assumptions and study results are wrong and the biomass plants are built? Comments/Questions to DOER

What if your assumptions are based on sustainable harvesting and there is no enforcement after the plants are built, and illegal clearcuts are rampant? Comments/Questions to DOER

Why isn’t this being run as a MEPA Study? Comments/Questions to DOER

Will you also consider water resources needed for biomass electric? Comments/Questions to DOER

Are they delaying biomass plants until these studies are done? If not, what is the purpose 

of these studies? Can’t this be studied in lab or research? What if state is [?] without 

proper data?

Comments/Questions to DOER

What is states statutory authority to ban issuance of new qualifications for REC and 

effect on ongoing biomass projects? Need explanation of RPS in MA and neighbors. 

Address electricity market fundamentals as it drives biomass.

Comments/Questions to DOER

Adequacy of DCR to oversee forest cutting on private lands and state & capacity to 

expand question to other states. Comments/Questions to DOER

What can be done to prevent invasive species transfer with increasing wood transport of 

other tree parts? Comments/Questions to DOER

Why won’t the state halt existing permitting process for biomass while study in progress 

instead of issuing permits in environment of uncertainty? Comments/Questions to DOER
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How can the state prevent clustering of incinerators? Comments/Questions to DOER

When are sociological impacts of biomass to be studied? Comments/Questions to DOER

Why are there four proposals at this time for biomass plants? Comments/Questions to DOER

What are the impacts of biomass plants on river ecology and water resources? Comments/Questions to DOER

How can you be permitting the plants before the sustainability has been determined? Comments/Questions to DOER

Is there a regional solution to biomass plants? Comments/Questions to DOER

This is all second growth forest, why cut and destroy the best carbon sequesters we have 

(which don’t charge)? Comments/Questions to DOER

The wind blows for free, how much do you charge? Comments/Questions to DOER

If 1/3 of biomass in MA is proposed to use construction and demolition debris, then 

why are we only studying woody forest biomass? Comments/Questions to DOER

Will you examine the impact of increased biomass harvesting on the economics of 

tourism and recreation that exists in western MA? Comments/Questions to DOER

Please consider the possibility of a statewide referendum in 2012 to stop all logging on 

public lands. Comments/Questions to DOER

Why do we need biomass? Comments/Questions to DOER

Carbon accounting of corporate energy consumption vs. future energy consumption. Comments/Questions to DOER

What will harvesting of forests do to tourism industry? Comments/Questions to DOER

What are the consequences of continued over-reliance on fossil fuels vs. various biomass 

scenarios? Comments/Questions to DOER

With overall electric consumption projected to go down, why do we need biomass 

plants? Comments/Questions to DOER

Why not put subsidies to conservation or non-emission technologies? Comments/Questions to DOER

Will Governor be able to take wood from private lands by eminent domain? Comments/Questions to DOER

How can we allow biomass combustion when we cannot remove particulate matter < 

2.5? Comments/Questions to DOER

Concern if RECs for sustainable forestry for biomass, then we’ll lose control of forest. Comments/Questions to DOER

Who will answer the question about human health? Comments/Questions to DOER

90% of the energy used in MA is from fossil fuels, 4.5% from hydro. Wind and solar 

are minimal. If we can’t use biomass, then how will we get to the 10% RPS? What’s the 

solution for getting off fossil fuels?

Comments/Questions to DOER

When and how, if at all, will the state address it’s August, 2009 decision to only include 

waste sources in the renewable fuel standard? What about non-food energy crops? 

Cellulosic ethanol? Algae and direct-to-fuel microbes and processes? Is this study going 

to be the main input to the state’s stance on biofuel feedstocks? If so, then why is the 

focus only on forests and wood? What about fallow lands? Non-thermal transformation of feedstocks and other advanced technologies? 

Comments/Questions to DOER

Have they considered the ballot initiative where sufficient signatures were just collected 

fort the 2010 ballot and the fact that if it passes, incinerators will not be eligible for 

renewable energy credits and how this will impact the economics of the biomass effort? 

Related: citizen consideration of a similar ballot in 2012 for prohibition of all logging on 

public lands?

Comments/Questions to DOER

Will the research address the advisability of any biomass harvesting or removal first? All 

other questions follow. Comments/Questions to Team

What is the definition of clearcutting (is it prohibited, is it proceeding?)? Comments/Questions to Team

Are you aware state not FSC cert and has not been since April 10th? And there are 

serious conditions open on their forestry practices? Comments/Questions to Team
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Water quality and hydrology issue? Comments/Questions to Team

How much non-renewable energy is used to produce renewable energy? Comments/Questions to Team

Clean wood vs. construction/demo wood Comments/Questions to Team

Alternative transportation of wood opportunities. Comments/Questions to Team

Nitrogen cycles/methane cycles. How are they affected by biomass harvesting? Comments/Questions to Team

How will biomass harvesting (removal of organic matter) affect acid rain impacts on 

forest soil? Comments/Questions to Team

Where will you get your information on the technological aspects of burning biomass? Comments/Questions to Team

How will biomass harvesting contribute to the spread of invasive species? Comments/Questions to Team

Silvicultural perspective - what markets other than biomass are there for low grade 

wood? Comments/Questions to Team

Is there a realistic time frame for the scope of study? Is there a way to address the time 

issue? Comments/Questions to Team

How are they defining “forest health” and “forest sustainability”? Comments/Questions to Team

Where will the displaced animals go? Comments/Questions to Team

Incentives to landowners? Comments/Questions to Team

Shifting balance of renewable? Comments/Questions to Team

Will you consider energy security of local fuel? Comments/Questions to Team

What are the positions of the Audubon Society and other environmental groups on 

biomass energy? Comments/Questions to Team

Need to consider project finance implications in order to avoid considering unfeasible 

options or recommendations. Comments/Questions to Team

Will DOER-funded SFBI studies be considered/utilized? Comments/Questions to Team

Look at long experience with biomass energy in New England (especially southern 

NH). Comments/Questions to Team

Look at other uses of biomass (ethanol etc.). Comments/Questions to Team

Are BMPs required to be followed on public land? Concern they have not been followed 

in the past consistently. Comments/Questions to Team

Where are you drawing the circle for supply of biomass per plant? Is it limited to 50 mile 

radius for each plant? Are you looking at a limit on plants with regard to supply (e.g., 

when several new plants are proposed and there are existing plants)?

Comments/Questions to Team

Are they considering pyrolysis as an alternative technology? Comments/Questions to Team

Are you comparing biomass to other renewables or only to carbon based fuels? Comments/Questions to Team

Are they starting with an hypothesis or asking questions without an hypothesis? What 

method are they using - published sources - for answering questions? Are they bringing a 

bias that they are trying to prove as true?

Comments/Questions to Team

Whate about the impact on wood prices? Are the changes in prices being considered in 

the economic impact analysis? The mix of biomass sources could change in price and so 

could carbon.

Comments/Questions to Team

Is there representation on the team from agricultural interests? Look at impacts on 

farmland. Comments/Questions to Team

What about non-forest biomass resources? Are they being considered? Comments/Questions to Team

What about infrastructure limits? (e.g., we have XX tons/day - but no way to get it to 

where [facilities are]). Comments/Questions to Team

Are the total scope of impacts being considered? Co-firing issue needs to be taken into 

account more fully. Comments/Questions to Team
Manomet Center for Conservation Sciences 180 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

NY study - How will their results affect our study? Or be taken into account as we 

embark on this? Comments/Questions to Team

What is the geography being studied - just within Massachusetts? Comments/Questions to Team

Are other pollutants being considered besides carbon (e.g., black carbon)? Comments/Questions to Team

Are you factoring in the impacts of climate change over the next 50 years when evaluating the resource? Comments/Questions to Team

BMPs are based on historical records. Comments/Questions to Team

Are you considering energy to dry biomass? Comments/Questions to Team

Why wasn’t the study done prior to permitting plants? Comments/Questions to Team

Are you looking at all scale technologies (e.g., home wood stoves) or only on larger-scale 

institutional level? Comments/Questions to Team

Are you considering that biomass may not be sustainable or a good idea for harvesting 

for energy at all? Comments/Questions to Team

After you establish the baseline, could you then create a model that would examine 

the impact of a biomass plant within 50-75 miles radius of the plant and compare the 

environmental impact of biomass to the other fuel sources used within that region, like 

wind, hydro, coal, oil, etc., and not include areas with no proposed biomass plants?

Comments/Questions to Team

Will this report dive right in or preface with layperson friendly terms and fundamental 

terms? Providing something accessible to public including life cycle of a tree and forest 

as it relates to carbon sequestration.

Comments/Questions to Team

Will they share report on progress or black box final issue? Comments/Questions to Team

Existing Pine Tree Biomass already burning biomass. Are they addressing the draw of 

biomass plants to pull in new wood products? Do we need additional constraints on any 

plant? Need to address impossibility of ensuring fuel specifications.

Comments/Questions to Team

Will baseline study - look at each energy source, compare sustainability, renewability 

and carbon consequences including conservation, solar, efficiency, wind. Comments/Questions to Team

See how more advanced country (Japan, Scandinavia, etc.) have dealt with biomass 

reducing fossil fuel. Comments/Questions to Team

Climate models see MA as warmer - more erratic weather. Potential of drought to kill 

forest if too dense. Will model consider drought effect on unmanaged forest? Comments/Questions to Team

Can the team openly address skepticism toward state and skepticism about panel 

members’ past activities as a delay tactic. Biomass developers have applauded this study. Comments/Questions to Team

Address biochar benefits/feasibility. Comments/Questions to Team

When studying levels of carbon sequestration in between managed and unmanaged 

forest, distinguish “poorly managed forest” from “well managed forest”. Comments/Questions to Team

Will you study different biomass harvesting systems (i.e., cut-to-length vs. whole tree) in 

terms of stand damage, soil nutrient levels, and democratizing access to biomass markets 

(i.e., allowing all loggers to participate in the market, not just those with expensive 

logging/chipping systems) - This would require new biomass plants to accept round 

wood.

Comments/Questions to Team

Assessing amount of clean wood waste generated (i.e., tree trimming; ice storm wood; 

sawmill remains; waste pallets; secondary manufacturing waste; roadside trimming). Comments/Questions to Team

Full transparency of funding sources of the members of the study group. Comments/Questions to Team

Define “biomass”. Is it woody biomass? Comments/Questions to Team

Consider pyrolysis as technology. Comments/Questions to Team

Consider methane production from natural forest decomposition. Comments/Questions to Team

Assess the impact of residential use of biomass vs. commercial use of biomass. Comments/Questions to Team
Manomet Center for Conservation Sciences 181 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Will MA DFW goals of early successional habitat creation be considered? Comments/Questions to Team

Regulations by basal area. Is this the best way to regulate whole tree harvesting? Comments/Questions to Team

Are you considering that management on stand land may change? Comments/Questions to Team

What capacity of mechanized operators will be required? Comments/Questions to Team

It is not just a question of “sustainability”. Is it a good idea to burn forests when we have 

too much pollution, too much carbon in the atmosphere, and already stressed forests. Comments/Questions to Team

What is the impact of biomass market on incentives for private forest landowners? Will 

this help keep forest land in forests? Comments/Questions to Team

Add other indicators of forest health. Comments/Questions to Team

What were the positions of the consultants on biomass prior to being commissioned for 

this study? Comments/Questions to Team

Research Question 2 may want to factor in diesel and gasoline truck transportation of 

forest fuels to the biomass plants as that relates to sustainability. Comments/Questions to Team

How many invasive species will come to visit when we truck in wood from the whole 

northeast? Worcester has had to euthanize a whole bunch of its trees. Comments/Questions to Team

Will you look at the impact of increased wood harvesting for biomass on the market for 

firewood? A concern in Franklin County is that the wood market will drive up the price 

of firewood for people who rely on it to heat.

Comments/Questions to Team

How is waste biomass byproduct factored into biomass equation? Comments/Questions to Team

More clarification on assumptions in study. Comments/Questions to Team

Why so many men on the study team? Comments/Questions to Team

Will efficiency of different biomass energy technologies be taken into consideration? Comments/Questions to Team

What are environmental and economic impacts of inefficient combustion of biomass? Comments/Questions to Team

Will building/construction of power plants be factored into LCA? Comments/Questions to Team

Will biomass harvesting be like strip mining and how do we prevent it? Comments/Questions to Team

Consider indirect impacts in addition to land impacts. Comments/Questions to Team

Balance effect of development and managed forests. Comments/Questions to Team

Is construction and demolition material included in the study? Comments/Questions to Team

Will the policy address the need for innovation in bioenergy and recognize new technologies such as gas pyrolysis and alternative feedstockes such as wastewood, construction debris, etc.

Comments/Questions to Team

Is construction and demolition material included in the consideration for the study? Comments/Questions to Team

How much trucking will there be and how will that affect local traffic patterns and the 

quality of life? What is the energy impact of the trucking and will that be considered as 

part of the life-cycle analysis? Why are four plants so close together all being proposed 

at the same time and where will the wood come from?

Comments/Questions to Team

Indirect impacts – in addition to the land impacts, what is the environmental cost of 

the “growth induced impacts”? (such as the growth of the local economy? Comments/Questions to Team

How can we balance the effect of development versus managed forests. What will 

be the land ownership incentive? The incentive to hold land in private hands? If we 

become too restrictive, then people will not be able to earn income from their land 

and have to sell off to developers. Concern about incentives for land ownership. Also, 

concern if REC’s for sustainable forestry for biomass are impacted, then we will lose 

control of our forests.

Comments/Questions to Team
Manomet Center for Conservation Sciences 182 Natural Capital Initiative

Biomass Sustainability and Carbon Policy Study

Request to include long-term anthropological perspective of human forest use in the 

area and how social and economic situations, values, etc. affect the use of forest. Going 

all the way back to native American Indians; through colonial times, to industrialization to the present. (editor comment: are we so vain as to think we will leave no 

heritage)?

Comments/Questions to Team

What is the H2O content of the wood being considered? Comments/Questions to Team

Are we going to include extreme scenarios in the baseline such as a complete cut-off 

of foreign oil (i.e. middle east nuclear scenario) and the ability of the state (and the 

country) to continue to function? Will an extreme case be included in the baseline?

Comments/Questions to Team

How will more smaller plants with more lax air quality regulations and controls affect 

health? Public Health Concerns

Look at health issues. Public Health Concerns

Will you be looking at the broadest range possible of forest health indicators? Should 

make sure to also overlay analysis with the other detailed biodiversity planning in state, 

including Woodlands and Wildlands and TNC Ecoregional Plans.

Public Health Concerns

Call on state to address the medical society’s statement that biomass incinerators pose 

unacceptable health risks. Public Health Concerns

Why propose biomass within city limits or in a valley with a high percentage of respiratory illness? Are you mad? Public Health Concerns

Air quality changes from biomass. Public Health Concerns

Fine particulate given off by large trucks and impact on air quality. Public Health Concerns

Other emissions from biomass combustion (other health impacts). Public Health Concerns

What will happen to remnants from burning – the ash? Will there be environmental 

problems from it? Public Health Concerns

Who will answer the question about human health and local environments? These 

plants are in low-lying valleys with poor air circulation and bad air quality already. 

What about the local climate and weather and current health issues (such as already 

high cancer rates)?

Public Health Concerns