To read the critique by Dovetail Partners, click here (http://dovetailinc.org/reportsview/2009/responsible-consumption/pdr-jim-...).

In September, 2009, Dovetail Partners distributed a critique of a report that I authored for The Wilderness Society entitled Wood Products Carbon: Can Increased Production Help Solve the Climate Crisis? Scientists in the research department of The Wilderness Society have a long history of asking difficult questions and producing credible research aimed at filling information voids in policy debates. We therefore take Dovetail’s critique seriously, and welcome the opportunity to respond, in hopes of clarifying some complex issues and perhaps even highlighting areas of agreement.

The major focus of the Dovetail critique seems to be that The Wilderness Society’s report covers only a portion of the overall topic of wood products and climate. I’d like to start by acknowledging that this is the case. The territory covered in the report has received little attention to-date, compared to the wealth of information on the benefits of storing carbon in wood products and substituting wood for other materials. I agree with the Dovetail reviewers that in many cases wood may be a climate-friendly option compared to its alternatives, but I also believe that any decision to expand current levels of wood use should consider the system-wide repercussions that were touched on in our report. I’d like to focus this general response on three topics that I believe are central to Dovetail’s criticisms. For a more detailed reply to the full critique please see: http://dovetailinc.org/files/tws_dovetail_reply_detail.pdf. (1)

Life-Cycle Assessment: A life-cycle assessment (LCA) is designed to trace the impacts of a particular product or process, including upstream (raw materials) and downstream (use and disposal) effects. The report drew from many LCAs for individual products, as well as on other less comprehensive data, to illustrate a range of GHG impacts for different types of wood products. An LCA boundary should include the most significant impacts while excluding those so tiny or indirect that it is no longer worth measuring them. Impacts of harvesting on the source forest are relatively direct and potentially large. For instance, harvest activity speeds up the release of carbon from logging residue (compared to the decomposition that would have occurred eventually through natural mortality) and may reduce carbon stored in the soil. For this reason, a wood product LCA focused on climate impacts should include effects in the forest. Boundary judgments do differ, however, as evidenced by arguments over the inclusion of indirect land use changes in greenhouse gas assessments for ethanol.

Greenhouse gas inventories are a second analytical tool used to understand and control GHG emissions. The IPCC guidance referred to in the Dovetail review presents a GHG inventory methodology that covers all sources and sinks while avoiding double counting, and EPA, USDA Forest Service and others follow this methodology to construct the official US GHG inventory. IPCC recommends dividing the economy into distinct sectors for reporting purposes, with somewhat artificial but convenient boundaries between sectors. An LCA will cross many of these boundaries as it traces the full impacts of a product.(2)

Substitution: If we acknowledge the possibility of honest disagreements over LCA boundaries, an LCA clearly does not include effects that result from substituting the product in question for alternative materials. An LCA that included avoided emissions would be unduly influenced by choosing the highestemissions alternative, regardless of the likelihood it will actually be used. Emissions associated with an alternative material would instead be reflected in a separate LCA for that product, and a decision-maker would compare the two LCAs to select the product with least impact.

I stand guilty as charged that I did not directly compare wood product LCAs with those for concrete, steel or other oft-cited alternatives. Many such studies are readily available. Our report does clearly acknowledge that wood products and wood biomass fuels often have a lower GHG footprint than common substitutes. Due to the incredible diversity of wood processing streams (and also to a lesser extent of alternative materials which might be recycled or otherwise low-impact), it is important to look at the particular products in question. Detailed LCAs for a broad array of products and wood types will improve decisions about what materials to use in building projects. Without this detailed information, well-intentioned individual decisions and public policies based on broad generalizations could actually result in higher GHG emissions.

Once we have clear information about the GHG footprints of alternative materials, what policies best encourage use of climate-friendly options? Expanding use of wood will not itself guarantee a decline in use of fossil-fuel-intensive alternatives. Policies that subsidize wood use without documenting that substitution actually occurs might simply encourage increased consumption, including expanded exports, without reducing emissions. A comprehensive cap-and-trade system would impose climate costs on fossil-fuel-intensive materials and encourage substitution of lower-GHG-emitting alternatives, including possibly wood materials and fuels, without requiring targeted subsidies through offsets or other policy mechanisms.

Offsets: Which brings us to probably the muddiest of the topics covered in our report. Some of the muddiness arises from the fact that forests and other lands are often exempted from a GHG cap for practical reasons (too difficult to track emissions or enforce requirements for landowners to cover those emissions by purchasing allowances). Under some program designs, uncapped sectors may be rewarded for GHG reductions through offsets. Forests that store more carbon relative to a baseline, for instance, might receive compensation by selling their surplus sequestration services to regulated emitters. Forests that increase net emissions, on the other hand, pay no penalty, so the incentive structure is a bit lopsided.

Making offsets available to forest landowners is a policy decision that arises out of the sector’s good fortune not to have its emissions systematically regulated. Since offsets allow capped sectors to release GHGs above the regulatory cap, offsets must produce GHG benefits in the most effective way possible. Forest offsets, for instance, should keep carbon out of the atmosphere as long as possible and minimize the fossil energy used to accomplish that goal. As noted above, wood products and wood energy will already have a price advantage under a comprehensive climate policy. Carbon sequestration in the forest, on the other hand, currently has no price, and offsets represent a unique opportunity to reward this important ecosystem service.

Introducing carbon sequestered in wood products and landfills into the carbon equation, though clearly required in the case of a comprehensive GHG inventory, and appropriate to include in an LCA, becomes somewhat confusing in the case of an offset program. Allowing offset providers to claim credit for harvested wood carbon essentially expands the boundaries of their project to include the entire offforest journey of those carbon-containing wood molecules. Once the carbon leaves the source forest, it must undergo a series of processing, transport, maintenance and disposal transformations in order to prevent its release into the atmosphere. Many of these off-site practices release GHGs. (3) Yet the forest landowner does not control the fate of off-site wood, nor does the landowner take on the emissions allowance burden associated with storing that harvested carbon. The mingling of capped with noncapped entities and activities leads to many unresolved questions about who “owns” the carbon once it leaves the forest, hence who benefits from storage subsidies or pays penalties when carbon is released.

Despite these complexities, I do not suggest that wood product carbon should be ignored in offset project accounting. I do believe that project accounting should reflect the actual pathway followed by the wood, in order to reward those who emphasize production of long-lived products and improve efficiency and wood waste recovery. Offset project accounting based on regional averages rewards the wasteful along with the thrifty. Harvested wood carbon crediting should also reflect the use of fossil fuels to store carbon in products and landfills, and the methane released as wood decomposes. As the Dovetail reviewers emphasize, expanded wood processing may not increase total net GHG emissions by the full amount associated with the processing activities, because the increased availability of wood might cause reduced use of more fossil-fuel-intensive materials. But we cannot assume that 100% of wood products have this effect, so some emissions discount for offset projects claiming harvested wood credits would be appropriate.

Conclusion: A major theme in the Dovetail critique is that The Wilderness Society’s wood products carbon report assumes that the alternative to harvesting more timber and producing more wood products and biomass fuels is to “do nothing” (cut no trees and build no homes or furniture). Though I did not actually make that assumption, I also do not assume that we are locked into building new homes and furniture and consuming more energy at an ever increasing rate. The right set of policies that encourage moderate consumption, re-use and waste recovery, could encourage substitution of wood for other materials while at the same time maintaining or even reducing timber harvest volumes. Only a more comprehensive analysis than that undertaken in our report would reveal whether a full suite of effective GHG-reduction policies implies expanded or contracted timber harvest.

I believe that the Dovetail reviewers and I agree on many climate goals, though our emphasis may differ. The Wilderness Society’s wood carbon report acknowledges the potential benefits of substituting wood for more fossil-fuel-intensive materials. Dovetail’s reviewers acknowledge in turn the importance of more transformative economic changes: “any serious attempt to reduce carbon emissions will necessitate attention to the demand side of the equation.” I would also agree with Dovetail’s statement that “we can clearly have healthy, thriving, carbon-storing forests at the same time that we enjoy wood homes and a myriad of products that themselves store vast quantities of carbon.” But I would emphasize that we cannot expand the latter indefinitely without harming prospects for the former. And I fear that overemphasis on expanding wood use could distract us from harder-to-implement priorities such as protecting forestland from conversion and reducing overall energy and materials usage.

I welcome continued discussion about these complex issues, and I thank Dovetail for providing a forum for this conversation.

Ann Ingerson, Resource Economist, The Wilderness Society

Citation: IPCC. 2006. Guidelines for National Greenhouse Gas Inventories. Simon Eggleston, Leandro Buendia, Kyoko Miwa, Todd Ngara and Kiyoto Tanabe (eds). National Greenhouse Gas Inventories Programme. IGES, Japan. http://www.ipcc-nggip.iges.or.jp/public/2006gl/index.html.

(1) Our more detailed response acknowledges several specific criticisms contained in the Dovetail review, including: data for softwoods and hardwoods were combined; analysis inadequately reflected recovery of processing and home demolition wastes to manufacture other products; report failed to mention emerging technologies such as wood framing in high-rise buildings; and energy facilities located at wood mills have no emissions associated with wood fuel transport.

(2) Our report does not suggest revising the EPA’s GHG inventory, as implied on p. 4 of the Dovetail critique. It merely points out that a change in wood product volume will have effects in both the harvested wood products and forest sections of the Land Use, Land Use Change and Forestry sector of the inventory, as well as in the energy and waste sectors, and all should be included in an LCA.

(3) Some of these emissions will be subject to the regulatory cap, but sources below the regulatory size threshold or occurring beyond U.S. boundaries will not be capped, so if offset projects involve such activities they could well increase overall emissions.