Here are some comments on…

Here are some comments on the Forest Biomass Action Plan (FBAP). In general, I think that it should be a 10-year action plan to coincide with Sustainable Growth: Ontario’s Forest Sector Strategy (FSS). I also think that it could be restructured to illustrate how it provides actions to meet FSS objectives and action areas. FBAP should also prescribe targets for certain actions - so that it provides direct support to Ontario’s Forest Sector Strategy.

The FBAP is well written and provides valuable information about the potential for biomass, however, I feel that there are several shortcomings in the proposed actions. In my opinion, there are some missed opportunities that should be addressed, and measureable targets should be established. FBAP does provide a good description of Ontario’s forest biomass advantages and its challenges. FBAP also has valuable insights from the Working Group members about the importance of bioenergy to existing forest product supply chains.

The first sentence in the document indicates that the FBAP is a part of “Sustainable Growth: Ontario’s Forest Sector Strategy” (FSS). FBAP is being put in place to secure jobs and encourage sustainability in the forest sector, while supporting economic development through the use of forest biomass. It goes on to say that Actions identified in the FBAP will help to realize the goals and vision set out in the FSS. This is admirable; however, neither the FSS nor any of its goals and actions are referenced again in the FBAP. I believe there should be direct links to uniquely describe how the FSS vision, goals, and objectives are being met by actions identified in FBAP. FBAP is a key component of the FSS, and as such its actions should be directly linked to FSS objectives. Putting an action plan in place that leads to using more forest biomass can help address many actions within all four FSS pillars. Here is my cursory view on how FBAP can help to meet specific FSS action areas, including (but not limited to):

Pillar 1: Stewardship and Sustainability
1. Earning Recognition for Our Sustainable Forest Management Practices
Using biomass can contribute significantly to the sustainable management of Ontario’s forests. Using biomass leads to higher stocking, higher regeneration success, less competition, increased growth and better yields.
2. Conducting Applied Research and Best Science
Using biomass is consistent with best science and information practices. It will significantly contribute to mitigating the impacts of a changing climate. This should perhaps be spelled out better in FBAP
3. Establishing and Strengthening Partnerships with Indigenous Peoples
Objective 4 in FBAP, and its associated actions, highlights some of the ways that Ontario will continue working with Indigenous communities. Key performance indicators could be added so that progress can be tracked.
4. Determining Effects of a Changing Climate & Responding to a Changing Climate to Mitigate its Effect
Surprisingly, the FBAP is pretty silent on the how using biomass can potentially help Ontario mitigate climate change. The FSS promotes the use of renewable forest biomass as a means of mitigating climate change. Key performance indicators could be inserted in the FBAP that indicate the amount of biomass used by industry and as an energy source to provide heat and potentially both heat and power for northern, rural and Indigenous communities. Using biomass helps to build resiliency in forests, and reduce the potential impacts from wildland fires.

Pillar 2: Putting More Wood to Work
5. Removing Policy Barriers to Accessing Wood
Objective 3 in FBAP purports to address Policy barriers to accessing wood – but there is no indication of $ or time savings, or the potential volume of biomass that could be used as result.
6. A Path to Increase Forest Growth
I find it highly unusual that the word ‘silviculture’ does not appear anywhere in the FBAP, given that the silvicultural benefits of using biomass are immense. The FSS action of increasing forest growth is likely not possible without using more biomass. Increasing forest growth is predicated on increasing plantable spots and available land base so that full stocking can be achieved. Biomass must be removed to achieve this FSS action – by removing currently ‘unmerchantable’ and ‘unmarketable’ biomass from the site. Surely this must be addressed in the FBAP.
7. Providing Wood Supply Certainty, Ensuring Use and Attracting New Investment
Objective 5 of FBAP provides high level actions – but there are no key performance indicators or other tangibles. The FSS action indicates that a range of actions to support existing forest operations that encourage the use of wood and facilitate its availability will be developed, including strategies to support these actions. I feel that more detail is required in this section regarding effective and efficient mechanisms to see wood utilized and made available in a way that supports existing mills and forest operators, but that also attracts new business and new investment for underutilized wood supply.
8. Harvesting Our Sustainable, Available Wood Supply
This FSS action is simply not possible without the increased use of biomass. Biomass is part of the sustainable available wood supply, and as such targets for the increased use of biomass should be established in the FBAP.

Pillar 3: Improving Cost Competitiveness
9. Lowering Taxes
Establishing a new, or adding a biomass consuming process to an existing facility can help companies to lower taxes – as they accelerate write-offs of capital investments
10. Maximizing the Use of Mill By-products
While FBAP provides a definition for mill by-products – there are no associated actions to maximize their use. There is a specific FSS action which recognizes the use of mill by-products (e.g. bark, sawdust and shavings) to provide sources of biomass heat, steam and energy for manufacturing in place of fossil fuels. I believe that FBAP should address this action specifically.
11. Reviewing Certain Components of Stumpage
This FSS action encourages a review of components of stumpage so that more wood can be used. I think that a ‘negative stumpage’ could be investigated and implemented in intensive management areas to encourage greater timber utilization and the harvest of species and lower quality logs that currently have no markets. Currently companies get paid for piling slash and burning it. Doesn’t it make more sense to pay to have the slash removed (negative stumpage), and make energy or other products and re-distribute the ash over the entire cut area…
12. Reducing Regulatory Burden/Streamlining
See pillar 2 above – there should be targets regarding streamlining in the FBAP
13. Enhancing the Alignment of the Trusts
This FSS action could support items in ‘reviewing certain components of stumpage’ above. FBAP should have an explicit action related to the use of biomass as it enhances forest management, increases available wood supplies and contribute to cost competitiveness.
14. Realizing Benefits from Forest Inventory Investments
There is no mention of this FSS action in the FBAP. While many aspects of the new LiDAR based inventory are yet to be worked out, targets should be set that pertain to opportunities to undertake better analysis of biomass supply.

Pillar 4: Fostering Innovation, Markets and Talent
15. Making Strategic Investments
FBAP could set targets for investments in biomass activities. The Forest Sector Investment and Innovation and the Northern Ontario Heritage Fund Corporation (NOHFC), provide for projects
16. Promoting Innovation
It is great that an action in FBAP indicates that CRIBE will be involved in an economic fibre supply model. Certainly other biomass related ‘innovation’ actions could highlighted that include working with industry leaders, CRIBE, FPInnovations, OFRI (or whatever it is called now), Indigenous communities, and universities and colleges to support the commercialization of innovative forest products and processes.
17. Increasing Wood Use
Again, I believe that a target is necessary if objectives are to be measured. FBAP provides plenty of detail on the Ontario Bioheat Initiative – but it does not have anything that is measurable.
18. Reaching New Markets
The FSS and the FBAP will not be successful without achieving this objective. New markets are imperative to growth and advancement of the forest sector. Definitive strategies should be implemented and targets should be set in this regard.
19. Making Ontario Wood the Natural Choice
I believe that this FSS action should be identified in FBAP. Ontario is growing the domestic market, and Ontario produced biomass (pellets, chips, fuelwood) can play a role.
20. Collaborating on Carbon Analysis
FBAP can contribute to this FSS Action as well. Using biomass for heating, electricity, and cooling systems will provide a means by which the private sector, municipalities and provincial entities can account for the carbon footprint of their building assets.
21. Adopting New Technologies
With respect to new technologies, FBAP actions include publishing a report and facilitating discussions… How much economic activity will these actions lead to… FBAP should set targets with the forest industry, CRIBE, FPInnovations, Indigenous Communities and others to explore mechanisms for the adoption of innovative tools that optimize industrial processes, harvesting, and renewal.