Harvesting Woody Biomass in Kentucky – results of this summers biomass workshops. August 12, 2011
Three biomass harvesting workshops conducted by the UK Department of Forestry Extension in July attracted over 300 participants. Results of participant surveys and input from logging and woodland owner focus groups participating at the meeting provided valuable insight into how a woody biomass market and its harvesting are viewed by woodland owners and what opportunities and impediments exist for loggers.
Woodland Owners Sixty-five percent of woodland owners indicated that they thought that woody biomass harvesting might be in their future. Only 8.9 percent indicated that in no way, shape, or form would they allow the harvesting of biomass from their woodlands. Woodland owners clearly understood that woody biomass is a high volume product with little margin associated with its harvesting and transportation and therefore cannot be viewed as huge moneymaker. This was news to many woodland owners participating. However, it was also clear that a woody biomass market would provide opportunities for some low quality woods to be regenerated and/or improved commercially whereas only the availability of a government program would allow for this to occur now. Woodland owners also realized that the use of proper harvesting guidelines for woody biomass is important to maintain the health and productivity of their woods. These guidelines are currently under development by a committee developed by the Kentucky Division of Forestry.
Loggers While less than 10 percent of the loggers present were currently harvesting biomass approximately 60 percent thought that it might be in their future. When asked to rank a set of factors that might affect their interest in biomass harvesting the results was as follows: market prices and stability was their top concern followed closely by equipment cost. Government programs, loans, and workers compensation insurance were significantly less important.
Where Do We Go From Here? While woody biomass initiatives have not developed as quickly as many thought they might, there are some developments in Kentucky. The wood burning facility that is developing steam for industrial use in Louisville is under construction and will provide an opportunity for a few loggers. There is currently some biomass chipping going on for limited markets in the northeast and limited markets in western and west-central Kentucky. EcoPower’s initiative in Hazard Kentucky is still proposed and they are working hard to get agreements in place that will allow them to proceed with development. Their current timeline is wood procurement in 2012/13. But that egg has not yet hatched. When it does it will definitely provide and opportunity for loggers to bring in round wood (with similar specifications as pulpwood) to the facility. The plans are that most loggers would not have to have in-woods chippers.
The loggers that will be most able to respond to woody biomass markets are those that are able to skid whole trees and process small diameter wood like pulpwood. This requires mechanized harvesting, grapple skidding or forwarding, and mechanized delimbing. This can and has been done in steep terrain, but there will minimum acreage requirements that will be dictated by terrain and location that may limit some woodland owners from benefiting from a woody biomass market. Further haul distances will be critical. Haul distances from the woods will probably remain in the 50 or 60 mile range and will probably be relegated to high capacity hauling with 18 wheelers.
So we are still generally in a holding pattern. BCAP rules for woody biomass have still not come out and no large scale woody biomass initiatives have developed. Regardless, the potential is still there and loggers and woodland owners should stay tuned for developments over the next 1 to 3 years.
This is the blog* of the University of Kentucky Department of Forestry Extension group.
Thursday, August 11, 2011
EPA – Haul Road Ruling Clarification - Sort Of. August 11, 2011
Clarifications have begun to emerge relative to the recent decision in the NEDC vs. Brown case by the Ninth Circuit US Court of Appeals (Ninth) removing the silvicultural exemption from the Clean Water Act associated with constructed logging roads in this region. This ruling opened up the possibility of classifying forest roads (as generally defined as constructed harvesting roads that collect storm water runoff, channel it, and deliver it directly or indirectly to streams and rivers) as a point source of pollution nationwide, thus requiring permitting (general or otherwise).
In May, 44 members of congress submitted a letter to Lisa Jackson, EPA Administrator indicating their concern over the ruling, how the EPA may respond, and requesting that the EPA reaffirms that the BMP approach to managing runoff from responsible forest management is the appropriate response to take in lieu of the Ninths ruling (Kurt Schrader_Letter to EPA).
EPA’s response dated July 1, (EPA_Response Letter) while not directly reaffirming the BMP approach as a blanket response dealing with forest management runoff it did so indirectly and did provide some clarification on the definition of forest roads that was encompassed by the Ninth’s ruling. The latter was helpful for Kentucky. The EPA indicated that the ruling pertained to constructed logging roads that intentionally diverted muddy water runoff into ditches, channels and culverts that directly flowed into waters (streams, rivers, etc.). Further the EPA acknowledged that forest road standards (BMPs) that provided for stormwater flow diversion onto porous forest soils for infiltration so they do not flow into waters were not covered by the Ninth’s ruling. Further the EPA indicated that if logging roads were properly located, designed and maintained to meet the criteria provided above they would not fall under NPDES (National Pollutant Discharge Elimination System) permitting jurisdiction.
So What? This indicates that Kentucky’s current Forestry BMP minimum criteria and recommendations, if adhered to would allow forest and logging road construction and use (under most common circumstances) to be undertaken without permitting (NPDES). It is critical that in all materials, including educational and administrative products, clear wording indicates the need for construction, maintenance and use of forest and logging roads to provide for water control that results in the deposition of stormwater runoff onto porous soils including forest soils and avoids delivery of stormwater runoff directly or indirectly (i.e. through a ditches or ephemeral channels) into waters (streams, rivers, etc.). Surface water occurring from seeps and springs that naturally flow into other waters can and certainly should be allowed to continue to drain directly into streams and other waters and provisions should be used allow for proper crossing of these surface flows. Logic would indicate that we continue to stress this in KML logger education and training and in KFCA timber harvesting inspections.
There may be other ramifications of this ruling that will emerge both within the Ninth’s region and beyond. It certainly would be prudent to ensure that in Kentucky we are developing and maintaining proper BMP use and keep abreast of information coming from EPA either directly through policy change or indirectly through changes in regulatory response.
Clarifications have begun to emerge relative to the recent decision in the NEDC vs. Brown case by the Ninth Circuit US Court of Appeals (Ninth) removing the silvicultural exemption from the Clean Water Act associated with constructed logging roads in this region. This ruling opened up the possibility of classifying forest roads (as generally defined as constructed harvesting roads that collect storm water runoff, channel it, and deliver it directly or indirectly to streams and rivers) as a point source of pollution nationwide, thus requiring permitting (general or otherwise).
In May, 44 members of congress submitted a letter to Lisa Jackson, EPA Administrator indicating their concern over the ruling, how the EPA may respond, and requesting that the EPA reaffirms that the BMP approach to managing runoff from responsible forest management is the appropriate response to take in lieu of the Ninths ruling (Kurt Schrader_Letter to EPA).
EPA’s response dated July 1, (EPA_Response Letter) while not directly reaffirming the BMP approach as a blanket response dealing with forest management runoff it did so indirectly and did provide some clarification on the definition of forest roads that was encompassed by the Ninth’s ruling. The latter was helpful for Kentucky. The EPA indicated that the ruling pertained to constructed logging roads that intentionally diverted muddy water runoff into ditches, channels and culverts that directly flowed into waters (streams, rivers, etc.). Further the EPA acknowledged that forest road standards (BMPs) that provided for stormwater flow diversion onto porous forest soils for infiltration so they do not flow into waters were not covered by the Ninth’s ruling. Further the EPA indicated that if logging roads were properly located, designed and maintained to meet the criteria provided above they would not fall under NPDES (National Pollutant Discharge Elimination System) permitting jurisdiction.
So What? This indicates that Kentucky’s current Forestry BMP minimum criteria and recommendations, if adhered to would allow forest and logging road construction and use (under most common circumstances) to be undertaken without permitting (NPDES). It is critical that in all materials, including educational and administrative products, clear wording indicates the need for construction, maintenance and use of forest and logging roads to provide for water control that results in the deposition of stormwater runoff onto porous soils including forest soils and avoids delivery of stormwater runoff directly or indirectly (i.e. through a ditches or ephemeral channels) into waters (streams, rivers, etc.). Surface water occurring from seeps and springs that naturally flow into other waters can and certainly should be allowed to continue to drain directly into streams and other waters and provisions should be used allow for proper crossing of these surface flows. Logic would indicate that we continue to stress this in KML logger education and training and in KFCA timber harvesting inspections.
There may be other ramifications of this ruling that will emerge both within the Ninth’s region and beyond. It certainly would be prudent to ensure that in Kentucky we are developing and maintaining proper BMP use and keep abreast of information coming from EPA either directly through policy change or indirectly through changes in regulatory response.
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