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By Virginia H. Dale, Department of Ecology and Evolutionary Biology, University of

Tennessee, TN, Latha M. Baskaran, Jet Propulsion Laboratory, California Institute of Technology, Pasadena, CA, Esther S. Parish, Environmental Sciences Division, Oak Ridge National Laboratory, Oak Ridge, TN


This article was first printed in World Biomass 2020/2021, a publication by DCM Productions. It is reproduced here with their generous permission.




Applying an approach to assess effects of forest management practices on species of concern identifies mitigation activities that can reduce or avoid impacts of bioenergy pellet production on gopher tortoise (Gopherus polyphemus).


There is great concern about bioenergy wood pellet production effects on forest biodiversity in the southeastern United States (SE US). This article reviews the land-use history in the SE US, sets forth biodiversity concerns, gives a summary of pellet production activities in the SE US, and presents an approach for determining and reducing effects of forest management activities on biodiversity. An example of pellet production effects on gopher tortoise (Gopherus polyphemus) is provided.


History of Land Use in the SE US


The SE US has a long history of human activities that affected the natural landscape. For tens of thousands of years, more than two dozen native American groups actively managed the land for agriculture to grow crops such as maize (Zea mays subsp. mays), beans (Phaseolus spp.), and squash (Cucurbita spp.) and supplemented their diet with hunting, fishing, and foraging. Controlled burns were used to prepare farm plots, eliminate weeds, and manage wildlife habitat. As a result of occasional, managed fires, the SE US landscape consisted of a mosaic of grasslands and forests.


The arrival of European colonists greatly altered this intensively managed SE US landscape. As a result of rampant spread of smallpox and other diseases, many native people died, disrupting active management of the landscape. Furthermore, indigenous burning practices were suppressed by many of the colonists. Even so, the colonists often used controlled burns to clear their land or reduce the threat of wildfire, which resulted in fire patterns and ecological effects that were very different than those created by indigenous people. Two hundred years of land clearing, extensive forest conversion, and row crop cultivation resulted in high soil erosion rates. Fire suppression became official US federal policy by the early 20th century. Fire-dependent, native longleaf pine (Pinus palustris) forests that once covered large areas of the SE US were reduced to 3% of their original area as a result of settlement and fire suppression. Over the past 200 years, most bottomland forests have been converted to other land uses or managed for wood products. Even so, the bottomland forests seem to be maturing, as evidenced by the increase in area of large-diameter sized stands between 2002 and 2014 while that of medium- and small-diameter stands decreased.


During the 1900s much commercial agriculture moved from the SE US to the midwestern states, which have more suitable soils and climate for row crops. As a result, although many forests in the SE US were cleared or degraded by human activity, there is more forest cover on the SE US landscape now than there was one hundred years ago.


Biodiversity Concerns


Today the SE US supports a high diversity of plant and animal species, many of which occur nowhere else. An estimated 11% of the species in the region are currently at risk with the greatest threat to biodiversity in forest ecosystems being the spread of urban and suburban areas.


Most areas of special diversity including old-growth forests are under private or government protection. For example, some locations that support species listed as endangered or threatened by the Endangered Species Act are managed using a Safe Harbor Agreement, under which private or other non-federal property owners specify actions they employ to contribute to the recovery of those species Bottomland hardwood forests are of particular concern in the SE US, for they provide habitat for a variety of rare species. Major pressures on bottomland forest ecosystems today are not pellet production but rather conversion to urban areas; alterations in flooding patterns as a result of dikes, dredging, oil and gas extraction, and salt water intrusion; and intense grazing by high populations of white-tailed deer (Odocoileus virginianus).


Pellet Production Activities in the SE US


Commercial production of wood pellets in the SE US began in 2008 in response to European Union (EU) renewable energy targets to cut greenhouse gas emissions, the demise of pulp and paper operations in some SE US locations that resulted in stranded wood supplies, and the availability of residues from lumber and pulp mills in other places. Pellet production has helped to maintain some rural employment in the forest products industry. Approximately half of wood pellets in the SE US are produced using sawmill residues, which has no direct effect on forest habitat or biodiversity. Oceanic transport of the pellets is facilitated by carbon- and cost-efficient maritime shipping, direct shipping lanes, and ports located near productive timberlands with established forest product supply chains. Up to 2019 removals for pellet production constituted less than 5% of the total timberland removals per year in the SE US.

Studies that focused on the effects on biodiversity of pellet production in the SE US have found that local context and particular species must be considered when assessing effects. Management practices that are harmful for some species (e.g., thinning) are beneficial to other species. Responses of species to harvesting for wood-based pellets varies depending on the species’ life-history characteristics, forest management practices, forest types, landscape conditions, and scale of analysis. Therefore, we developed an approach to assessing impacts and recommending management practices that considers these conditions.


An Approach for Determining Effects of Land Management Activities on Biodiversity


Our approach addresses effects of management actions on life-history conditions of species of concern within a given landscape. The approach entails 5 steps (see below). (1) A species of concern is identified that is at risk of impact by specific management activities. (2) Key life-history conditions are determined for the species of concern. (3) Management practices associated with the activities under investigation are identified. (4) Potential effects of each management practice on each life-history condition for the focus species are assessed. And (5) mitigation practices are identified that can avert or minimize negative impacts on the species of concern. These 5 steps are accomplished by consulting the literature and experts in each topic area. This approach identifies life history conditions at risk, focuses the assessment, and identifies management practices that should be followed to reduce impacts on the species at risk.




Example Application of the Approach to Examine Effects of Pellet Production on Gopher Tortoise


Gopher tortoise (Gopherus Polyphemus) was selected as an example species for illustrating the approach. This large tortoise is a keystone species in the SE US, for it digs deep burrows upon which more than 360 other species depend. Gopher tortoise are of conservation concern in six SE US states that produce wood pellets for bioenergy and could potentially be affected by biomass harvesting for pellets throughout its range (Figure 4), which includes both naturally regenerating and planted pine forests. Tortoise prefer pine forest systems with well-drained sandy soils, herbaceous cover, and open canopy. Gopher tortoises have declined by about 80% in the past 100 years throughout the SE US due to loss of habitat, increased predation, and disease.


Five key life-history conditions of gopher tortoise that are affected by pellet production are burrowing, foraging, thermoregulation, reproduction, and survival. Conditions associated with dispersal, interactions (e.g., competition), and food consumption are not greatly affected by pellet production.


Sandy soils allow tortoise to dig deep, tunnel-like burrows, which maintain constant temperature and humidity conditions in spite of extreme weather and fire events. These burrows shelter not only the tortoises but also more than 360 other species, including several of conservation concern. These herbivorous tortoises graze on a variety of leaves and seeds as they forage on understory plants surrounding their burrows and beyond. On cool sunny days, these reptiles thermoregulate by basking in open areas. Reproduction is characterized by breeding from April to June and 100 days of egg incubation, but the eggs and young animals are often eaten by various predators. Survival is greater after the tortoise’s shell hardens (at about 6-7 years). Canopy closure can entice the tortoises to relocate to more open edge habitats, such as open roadsides where injury from vehicles is more likely. Outbreaks of upper-respiratory-tract disease (URTD) are induced by physiological stress brought on by disruption of normal behavior patterns and habitat degradation. After maturity and without disease or injury, gopher tortoises may live for more than 60 years.


Forest management practices associated with pellet production involve three practices that can impact gopher tortoise: logging, thinning, and dead wood removal. Logging practices common to timber and pulp and paper are also used for wood pellets and occur via uneven-aged management, two-aged management, and even-aged management through clearcuts. Thinning practices remove mid-story hardwood trees and small diameter or defective stem wood of low quality that is unsuitable for lumber or pulpwood. By reducing tree density, thinning can enhance forest health, biodiversity conservation, or fuel treatments. Removal of dead wood includes the branches and treetops often left in the forest during harvest to become downed woody debris that are typically burned or piled up and left to decompose.


Intersecting the three types of forest removals for wood pellet production with the five key life-history conditions of gopher tortoise yields 15 interactions that constitute potential effects on the tortoise (Figure 5). These interactions are listed below as organized by each pellet production practice.




A. Logging effects


  1. Burrowing can be negatively affected by burrow collapse and damage due to heavy machinery and abandonment due to loss of favorable habitat. Burrowing can be positively affected by an increase in open canopy sites suitable for burrowing and basking.

  2. Foraging can decline due to loss of herbaceous vegetation as a result of equipment traffic and site preparation for logging operations.

  3. Thermoregulation can be impeded because of habitat fragmentation, habitat islands, and reduced home range. Thermoregulation can be enhanced by creation of openings in the canopy.

  4. Reproduction can be impacted by low quality forage that can decrease clutch sizes and/or egg quality or by reduced mating success associated with low density of burrows within the home range of a tortoise.

  5. Survival can be impaired as a result of inadequate forage and higher risk to predation and vehicles accidents or from relocated tortoises contracting URTD.


B. Thinning effects


  1. Burrowing benefits from open canopy and better conditions for translocation.

  2. Foraging is enhanced by changes in herbaceous cover due to more open canopy, but equipment traffic can induce vegetation loss.

  3. Thermoregulation benefits from a more open canopy for movement and basking.

  4. Reproduction is enhanced by improved chances of finding a mate under a more open canopy with habitat corridors.

  5. Survival is enhanced, as thinning induces higher survival rates from URTD associated with more basking sites being available.


C. Dead wood removal effects


  1. Burrowing is compromised, for burrows can collapse when dead trees are removed and maybe damaged by heavy vehicle movement and vibrations.

  2. Foraging is impaired, as equipment traffic causes loss of herbaceous vegetation.

  3. Thermoregulation benefits from improved conditions for movement.

  4. Reproduction is impacted with delayed maturity, decreased clutch sizes and/or egg quality associated with low quality for age.

  5. Survival is diminished due to equipment collisions with tortoises and increased exposure to predators through loss of cover. But survival benefits from loss of habitat for predators (e.g., snakes).


Understanding these interactions leads to the identification of mitigation practices that can prevent or minimize negative impacts of pellet production on gopher tortoise. Tortoise burrowing, foraging, and survival can benefit from thinning, prescribed fire, and practices that deter vehicle activity within 4 meters of each burrow. Foraging can be enhanced by low-intensity harvesting. Thermoregulation can benefit from practices that open the canopy and maintain habitat corridors. Reproduction can be improved by harvesting practices that maintain habitat corridors and increase habitat connectivity.


This gopher tortoise example demonstrates that forest management practices for SE US pellet production management can be adjusted to protect habitat and life-history conditions for an at-risk species. Application of the approach reveals gaps in information, such as the optimal quantity of dead wood that should be left on the forest floor to protect gopher tortoise from predators. Protecting this keystone species can also benefit dozens of other species that depend on gopher tortoise and their burrows.




Conclusion


While many are concerned that increased pellet production may negatively impact biodiversity, SE US forest landscapes have experienced centuries of intensive management, and the major current pressure on them is urban and suburban expansion. Furthermore, timberland removals for pellet production currently constitute a very small proportion of the overall wood market. Even so, it is important to understand potential impacts on biodiversity and explore opportunities to minimize negative impacts. The example of intersecting key life-history conditions of the gopher tortoise with key forest management practices for pellet production shows that well designed management practices can minimize impacts on gopher tortoise and even enhance burrowing, foraging, thermoregulation, reproduction, and survival.

This straightforward approach can be applied to other species at risk from wood pellet production for bioenergy and other types of ecosystems. The approach is suitable for (1) ecosystems that support a species of special concern because it is rare, a keystone species, or has cultural, commercial, or recreational importance; (2) management activities that directly relate to life-history characteristics of that species; and (3) systems for which there is information available to identify mitigation practices that can avert or minimize negative effects on the species of concern.



NOTE: The article is based upon the paper by Parish et al. (2020), which should be consulted for further detail.




SUGGESTED RESOURCES FOR FURTHER INFORMATION


Dale VH, KL Kline, ES Parish, AL Cowie, R Emory, RW Malmsheimer, R Slade, CT Smith, TB Wigley, NS Bentsen, G Berndes, P Bernier, M Brandão, H Chum, R Diaz-Chavez, G Egnell, L Gustavsson, J Schweinle, I Stupak, P Trianosky, A Walter, C Whittaker, M Brown, G Chescheir, I Dimitriou, C Donnison, A Goss Eng, KP Hoyt, JC Jenkins, K Johnson, CA Levesque, V Lockhart, MC Negri, JE Nettles, M Wellisch. 2017. Status and prospects for renewable energy using wood pellets from the southeastern United States. Global Change Biology Bioenergy 9: 1296-1305. doi: 10.1111/gcbb. 12445. http://onlinelibrary.wiley.com/doi/10.1111/gcbb.12445/full


Dale VH, Parish ES, Kline KL, Tobin E. 2017. How is wood-based pellet production affecting forest conditions in the southeastern United States? Forest Ecology and Management 396:143-149.


Davis MB (ed.) (1996) Eastern Old Growth Forests: Prospects for Discovery and Recovery. Island Press, Washington, DC.


Demarais, S., Verschuyl, J. P., Roloff, G.J., Miller, D. A., & Wigley, T. B. 2017. Tamm review: terrestrial vertebrate biodiversity and intensive forest management in the US. Forest Ecology and Management, 385, 308-330.


Enviva Forest Conservation Fund. https://envivaforestfund.org/


Homyack, J. A. & Verschuyl, J. 2019. Effects of Harvesting Forest-Based Biomass on Terrestrial Wildlife. Chapter 2 of Renewable Energy and Wildlife Conservation by C. E. Moorman. S. M. Grodsky, and S. Rupp. JHU Press. 280 pages.


Parish ES, Baskaran L, Dale VH. 2020. Framework for assessing land-management effects on at-risk species: Example of SE USA wood pellet production and gopher tortoise (Gopherus Polyphemus). WIREs Energy and Environment https://doi.org/10.1002/wene.385.


Riffell, S., Verschuyl, J., Miller, D., & Wigley, T. B. 2011. Biofuel harvests, coarse woody debris, and biodiversity–a meta-analysis. Forest Ecology and Management 261(4): 878-887.


Rose, A.K., Meadows, J.S., 2016. Status and trends of bottomland hardwood forests in the Mid-Atlantic Region. USDA e-General Technical Report SRS-217. U.S. Department of Agriculture Forest Service, Southern Research Station, Asheville, NC. 10 p.


Stewart, O.C. 2002. Forgotten fires: Native Americans and the transient wilderness. Tulsa, OK: Univ. of Oklahoma Press. pp. 364. ISBN 978-0806140377.


Wear, D.N., Greis, J.G., 2013. The Southern Forest Futures Project: Technical Report. Gen. Tech. Pre. SRS-178. United States Department of Agriculture. Forest Service, Research and Development, Southern Research Station. 553 p


Acknowledgments


This research was supported by the US Department of Energy (DOE) under the Bioenergy Technologies Office. Oak Ridge National Laboratory (ORNL) is managed by UT-Battelle, LLC, for DOE under contract DEAC05-00OR22725. Latha Baskaran’s contributions were done as an extension of her prior work at Oak Ridge National Laboratory (managed by UT-Battelle), and not in her capacity as an employee of the Jet Propulsion Laboratory, California Institute of Technology. The views and opinions of the authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, expressed or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights.

“Sustainable biomass has played a central role in taking the UK off coal, provided an important back-up for wind power and is critical to achieving net zero by 2050 through Bioenergy with Carbon Capture and Storage (BECCS). The UK has world-leading sustainability criteria which prevent the supply of biomass for energy generation from areas where deforestation or land use change has occurred.

“In this case, a section of forest was legally harvested to supply wood for industries including construction, joinery and bioenergy. The harvest took place in line with Natura 2000 agreements and under strict controls and regulations and there’s nothing to suggest that this harvest was inappropriate. Moreover, tree cover in both Estonia and Latvia has increased in recent years, underlining the sustainable nature of the forestry operations there.

“Furthermore, this report incorrectly cites bioenergy as the main driver for harvesting in the Baltic region. This ignores basic forestry economics that clearly demonstrate that harvests are driven by the significantly more valuable timber used in housebuilding and furniture than the cheaper forestry residues that are used for bioenergy. The article also ignores important relevant context, for example, that economic recovery since the financial crash has led to a recovery of forestry operations to supply wood for housebuilding, among other things.

Updated: Jan 14

A recent report, covered by the Guardian, claims to investigate biomass supply chains from the Baltic region to the UK, among other countries. We’ve looked at some of the report’s key claims and corrected the misleading portrayal of the biomass industry and the sustainable forestry sector.



1) Emissions from biomass vs fossil fuels


First of all, the report repeats the claim made frequently by dedicated anti-biomass organisations that emissions from electricity generation from bioenergy are substantially (in the realm of 50%) higher than emissions for coal. This is simply not true. This claim is based solely on stack emissions, though even here the difference is much smaller. Biomass releases slightly more CO2e at the point of combustion than coal, but efficient plant, for example at Drax Power Station, reduce this to about 2%.


Crucially, this cherry-picking ignores the fundamental difference between fossil fuels, which introduce carbon into the atmosphere that was previously locked away for millennia, and biogenic carbon. Biogenic carbon is constantly exchanging between organic material and the atmosphere through organic growth and decay. Bioenergy makes use of this cycle. UK sustainability regulations ensure that the use of biomass for energy results in significant carbon savings compared to fossil fuels across the whole lifecycle, as do the updated EU regulations in RED II.


To take the UK (a leading example of sustainable biomass use), public support for biomass has allowed rapid decarbonisation of electricity grids. These subsidies have allowed us to reduce our dependence on coal, maintain flexibility on the grid and support thriving forests. The UK has reduced electricity emissions by 71.7% since 1990, with biomass playing a significant role in allowing coal to be phased out and supporting the development of intermittent renewables, such as wind and solar energy.



2) The “carbon debt” fallacy


Secondly, the report claims that harvesting wood creates a carbon debt. The following quote is taken from the report and is indicative of the misunderstanding of how sustainable forest management works: “If we count a period of, say, 40 years, in which the new trees have canceled the carbon debt, then yes that biomass can be seen as carbon neutral,” he says. "But if we consider a very short period of time, it is likely that the carbon debt will not be canceled.”


Yes, if one considers only an individual tree, or even only a specific stand of trees, then this may hold some weight. Forest management takes place at the landscape scale, however. Indeed, consideration of carbon sequestration and emissions in forests only makes sense if it is done at this landscape scale. Sustainable forest management is a matter of balancing growth and harvesting rates so that growth exceeds harvesting. That leads to year-on-year increases in the volume of growing trees, capturing more and more carbon each year. The report claims that small spruces will take decades to absorb the same amount as the felled tree, but this doesn’t address the big picture of growth across the forest.


A recent report from leading forestry consultancy Indufor concluded that Estonia’s forest area has increased to 52% of the total land in 2018 compared with 49% in 2010, and over the same period the total growing stock has increased by 52 million cubic metres with 40% of this growth in hardwood species.




3) Carbon accounting for biomass


The report refers to a “magic trick” of carbon accounting where emissions of biomass power are not counted at the power station, leading to the claim that the CO2 emissions have “effectively disappeared.” In fact, international carbon accounting standards, which include biomass power, do count the emissions of biomass power, they just do it under the AFOLU (i.e. forestry) sector rather than the energy sector. It reflects the fact that biogenic carbon is constantly being exchanged between the atmosphere and organic material. In a sustainably managed forest, ongoing growth balances out harvesting.


This is done for a number of reasons: a) to avoid emissions being counted twice, b) it’s simpler to track the real emissions accurately, and c) it allows for transporting biomass across borders, which happens a lot given the uneven spread of forest resources around the world (for example, the Southern USA’s forests cover an area three times the entire landmass of the UK).


This principle of carbon accounting (avoiding double counting) was re-examined and reaffirmed just last year by the UN’s Intergovernmental Panel on Climate Change (IPCC) and has been endorsed by the UK’s Climate Change Committee (CCC).


There’s more detailed information on the carbon accounting question here.




4) Biomass regulations – the importance of low-value wood


The report suggests that EU regulators were not following the science when they drew up the sustainability criteria for biomass and concentrates on the use of “whole trees” – a term that has no definition in the forestry industry. Leaving aside the carbon debt issue addressed above, it is important to understand that it is not the size of the tree which determines its value.


Bioenergy makes use of forest thinnings, which means small, diseased or misshapen trees that have low value for industries such as timber. They are removed to allow remaining trees more access to nutrients, meaning these trees will grow taller. This process maximises forest growth and also maximises carbon captured in structural timber or joinery wood. There is a clear, documented correlation between the productivity of forests and the volume of wood growing there. Reducing the ability to draw revenues from thinnings will reduce the ability of foresters to manage and invest in their forests. This white paper from September 2020 goes into more detail on the dangers of basing market interventions on arbitrary physical criteria.


The report claims that: “Since the revised Renewable Energy Directive and Estonian legislation does not ban the use of whole trees, Graanul Invest can harvest hectares of forests to turn into pellets in the name of sustainable management.” This simply does not make sense. It is the lowest quality wood that is used for bioenergy, as Graanul make clear here. The same is true for working forests all over the world – the raw material used for the production of wood pellets is always sourced from the bottom of the forest value chain.


Robert Matthews, a forestry expert for the UK government, was interviewed for the report, though all the information is not presented. His 15 recommendations from 2018 for sustainable biomass do allow for the use of “whole trees” as thinnings as part of sustainable forestry management. His recommendation (no. 12) on whole tree stems, runs as follows:


“Whole tree stems - Restrict supplies of forest bioenergy from whole tree stems to small/early thinnings with the aim of improving the quality of the remaining growing stock. Favour situations in which, otherwise, there would be limited incentives to thin and improve forest stands. Alternatively, favour supplies of wood biomass from small/early thinnings where a simply calculated but robust estimate of GHG emissions meets a defined minimum threshold.”


5) Certification


The report presents an overview of the various different certification regimes used for sustainable forest management, and heavily implies, through the presentation of a “flipside” for each one, that these schemes are inadequate. In many cases however, these schemes go beyond what is required by governments. The Sustainable Biomass Program (SBP) is singled out for criticism for using data from 2016 and saying that Estonian forest land is homogenous, as well as for its links to industry. This is a misleading representation of the situation.


SBP uses Regional Risk Assessments (RRAs) to understand the local geography and forest economy. This is updated every five years to take account of changing scientific evidence, market conditions and socio-political questions. The next review for Estonia is in 2021, so the authors of the report will get their wish as SBP will update the certification scheme’s baseline for Estonia. Latvia is due the following year.


SBP also has multi-stakeholder governance arrangements in place. Both civil society and commercial interests are represented at every level of governance, fostering dialogue, decision-making and implementation of solutions to common goals.


6) Estonian forestry regulations


The report concentrates on evidence of forestry operations in Haanja Nature Park, on land owned by Graanul Invest Group. Evidence is given through satellite images of clear-felling in Natura 2000 protected areas and used to paint a picture of deforestation and unsustainable practices. Important details have been left out, however.


The report’s portrayal ignores the reality of government-approved forest management in Estonia. The Nature Conservation Act in Estonia divides nationally protected areas into different protection zones: strict nature reserve, conservation zone and limited management zone. In the first two, human intervention is either completely prohibited or only allowed for non-economic purposes. The main purpose of the limited management zone, however, is to be a buffer zone between strictly protected areas and conventionally managed forests. In these limited management zones, forestry practices are permitted, though only with the express permission of the Estonian Environment Agency, and economic activities cannot interfere with conservation goals.


Clear-felling has been misrepresented in the report as an undesirable practice. In fact, it is the most widely used final forestry harvest system in the world. It is a normal part of forestry operations worldwide and is often the best way to ensure that the objectives of sustainable forest management are met. For its report on biomass in 2018, the CCC included an annex on Sustainable Forest Management. The first item in the list of sustainable forestry techniques? Clear-felling.


We also spoke with the Estonian Ministry of Environment, and they provided the following additional information.

  • “The carbon stock has increased [in Estonian forests] between 1990-2020 (by 15%) including the stock in above-ground and below-ground biomass, deadwood and soil, although the total felling volume has increased.”

  • “…during [the] last 5 years, the overall protected forest area has widened [by] more than 50,000 ha and more than 75,000 ha of different (mostly forest) habitats have been re-zoned from the limited management zone to strictly protected zone.”



To conclude…


The principles of forestry management are tried and tested and ensure that wood is directed to the most efficient end-use. This maximises carbon savings and revenues for foresters and incentivises the careful management of forests that will only grow more important as we fight against the dangers of climate change.


The biomass industry is playing a crucial role in reducing carbon dioxide emissions and supporting sustainable forest management. The regulations and carbon accounting principles for the use of biomass follow the science at every level, from national sustainability criteria, to the EU’s REDII, and the IPCC’s carbon accounting framework. These ensure that sustainable biomass provides tangible benefits for our climate and forests.

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