Reforestation as a Corporate Compliance Measure for Air Pollution Mitigation: The Case of Ground-Level Ozone

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1 Reforestation as a Corporate Compliance Measure for Air Pollution Mitigation: The Case of Ground-Level Ozone Timm Kroeger Central Science, The Nature Conservancy, Arlington, VA, USA ACES and Ecosystem Markets

2 The Problem Ground-level ozone: NO x + VOC = O 3 Harmful to human health, ecosystems, crops 43 ozone non-attainment areas in the U.S. (1997 8hr NAAQS); 129 million people States are responsible for compliance with NAAQS: State Implementation Plans (SIP) 2

3 The Problem (contd.) SIPs impose NO x and VOC emission limits on regulated point sources Despite large control efforts, problem persists: 1) Available Control Technology often not sufficient to achieve compliance 2) Economic growth More emission sources More stringent controls Rising marginal control costs (NO x, VOC)

4 The Opportunity Emerging and Voluntary SIP Measures Policy (EPA, 2004) Encourage states to explore novel approaches to achieve NAAQS compliance Emerging measures: 1. Higher quantification uncertainty than traditional measures 2. Still, must be Surplus (additional), Enforceable, Quantifiable, Permanent Tree planting specifically mentioned in EPA policy 4

5 Question Could reforestation be a cost-effective ozone precursor abatement strategy? 1. Issue has never been explored 2. Nationwide applicability of strategy if cost-effective 3. Large potential co-benefits compared to conventional, gray control approaches 5

6 Buccaneerlandscape.com Why forests instead of trees? Bigger air quality improvement (and associated benefits) Lower maintenance costs Lower monitoring and reporting costs Higher conservation benefits Pella Tree Service Inc.

7 Test case: potential site in Houston area Test case: 1,000-acre bottomland hardwood reforestation 1,500 seedlings planted /ha (most cost-effective design) Grow-out modeled over 30 years to estimate ozone and NO 2 removal 7

8 Several hundred thousand acres of land available for reforestation 165, ,000 acres of potential hardwood land available Additional 40,000 acres of upland hardwood and pine forests Avoided conversion of existing forests also creditable for SIP and C offset purposes! Potential areas for bottomland hardwood reforestation: 165,000 acres Currently grass/shrub Currently forest /woodland (non bottomland) 650,000 acres includes woodlands and forests Currently agriculture max. 8 HGB non-attainment area

9 Methods 1. Canopy modeling Species-specific growth and mortality rates (Staudhammer et al., 2011; Lawrence et al. 2009; Bond, 2006) DBH-crown width functions (Martin et al., 2012) 2. Pollutant removal modeling (NO 2, O 3, SO 2 ) UFORE-D dry deposition model (v. 1.3) (Hirabayashi et al., 2012) 3. C storage modeling (Jenkins et al., 2003) 4. VOC emission modeling (isoprene, monoterpenes, OVOC) UFORE-B biogenic emission model (v. 1.0) (Hirabayashi, 2012) 9

10 Results from test case Estimated project cost: $470,000 Assumes no cost of land (reasonable for many lands) Actual project will have known cost (based on contract bids) Estimated removal, 30-yr totals: 300t ozone 56t NO 2 42t SO 2 25,500t C (93,600t CO 2 e) Downward bias: does not include removal and C storage through natural self-regeneration of planted forest (additional canopy from ~yr 25 on) EPA policy encourages states to incorporate emerging and voluntary measures (reforestation could be used for either) into SIPs by allowing provisional pollutant reduction credit upfront. 10

11 Comparison of cost / ton of removal for green & gray solutions Reforestation can be cost-competitive for NO x control: Reforestation vs. NO x allowances $/t NO x (30 yrs) Reforestation $2,400-$4,000* Reforestation w/ carbon credits $890-$1,630** Conventional control options $3,500-$5,000*** NO x allowances $3,300 # Notes: All in 2012 present values; 7% discount rate; 30-yr time horizon * Includes site preparation, planting, trees and SIP monitoring; based on high and low removal estimate, respectively. **Includes offset protocol monitoring and verification costs; adjusted for mandatory contribution to forest project risk buffer account; at current CAR compliance offset prices *** Industry average abatement costs # Perpetuity cost of $100,000/ton, spread over 30 years (i.e., 30 tons) 11

12 Cost-competitiveness through Scalability Reforestation projects are uniquely scalable Plant just enough trees to achieve desired NO x removal ($1 million or less) Alternative gray infrastructure increments have very high cost and provide very large NO x reduction increments $ millions >57t/yr of NO x 12

13 Public benefits of reforestation Carbon storage by 1000-acre reforestation project could result in avoided climate-related costs to society at large of $500, ,000 (PV) Based on Interagency Working Group on Social Cost of Carbon middle SCC estimates Costs: foregone output, health costs, infrastructure damages, other (valued at market prices) Restoration of critical migratory bird habitat in area Potential additional benefits depending on project location: Recreation Property value premiums (green space amenities) 13

14 Now what? Continue discussions with regulatory agencies (TX and U.S. EPA) on methodology Get reforestation included in SIP revisions Texas Commission for Environmental Quality strongly supportive 14

15 Thanks to: Francisco Escobedo (U. FL Gainesville) José Hernandez (ENVDAT Consulting) Sonia Delphin (U. FL Gainesville) Mark Estes (TCEQ) Sebastián Varela (WRI EMBARQ Mexico) Janice Waldron (Dow) Prentice James (Dow) 15

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