Industry's Not-So-Golden Plan for California's Forests

Editor's note: The period for commenting on GSNR's draft environmental impact report closed 1/20/2025. Nearly 50,000 people, elected officials, and over 185 organizations called on California to reject GSNR's wood pellet production and export project. To read more about the close of the comment period and next steps, please read NRDC's expert blog, "Momentum builds to stop big biomass in California."

Golden State Natural Resources (GSNR) recently released its Draft Environmental Impact Report (DEIR) for a proposed project that will eat up forests, exacerbate climate change, and harm California communities. The public has until January 20, 2025 to send in comments. Take action now.

The report clarifies that GSNR intends to build two beastly industrial-scale wood pellet manufacturing facilities and an export terminal for foreign energy markets. California law requires that the report consider all of the proposed project’s impacts in a transparent process that meaningfully involves all stakeholders. Instead, GSNR ignored the massive impact this project will have on California’s forests, climate, and environmental justice efforts, employing a bad-faith public engagement effort and snubbing community input. Not only is Golden State Natural Resources not so golden, but its whole report shows that there's no such thing as a silver pellet when it comes to climate change, meaningful community protections, and wildfire mitigation efforts. 

GSNR's proposed facilities in Tuolumne and Lassen counties would increase the pace and scale of logging in the state. While GSNR has claimed it will burn wood from slash piles or wood chips already coming from mills, the DEIR makes clear that it will log whole trees (up to 40 inches in diameter) for pellets in a massive area that includes 18 national forests in California and extend operations into Nevada and Oregon. 

Having spent a decade fighting the bioenergy industry in the Southeast, I’m familiar with this song and dance. The industry says it will do one thing, then does something completely different. There, too, they came in promising to use wastewood, leftovers, and residues for wood pellets. But when the rubber hit the road and the companies needed to fill the massive demand of overseas utility customers, the industry expanded logging operations.

It’s the same story in Canada, where Drax—GSNR's partner in these California proposals—logged trees from old growth forests.

History and simple math point to GSNR doing what's most economical—not what’s most ecological—and California forests will suffer. State officials have admitted as much, saying that this project will lead to new logging initiatives springing up to accommodate the demand for trees. Indeed, nearly half (45 percent) of GSNR's demand will source from logging operations that are additional: they “would not occur without GSNR’s proposed project.”

The DEIR also claims that the proposed project will help combat climate change, advancing the Paris Agreement. This couldn’t be further from the truth. Industrial logging, industrial-scale wood pellet production, and eventual wood pellet combustion in power stations will increase—not reduce—atmospheric carbon emissions. While some countries have deemed forest biomass burning “carbon neutral” and subsidize it heavily, there is no way around the physics that burning wood for bioenergy emits carbon dioxide. Trees harvested may regrow, but regrowth is not inevitable, and even if it does occur, it cannot remove the excess CO2 from burning wood for many years. In the meantime, that excess carbon dioxide remains in the atmosphere and worsens global warming. Every stage of producing forest bioenergy—from the harvest, processing, transport, and eventual combustion at a power plant—releases CO2 into the atmosphere. Even if the industry solely uses so-called "wood waste," which takes years or decades to decompose, burning it releases carbon immediately. 

Finally, the project’s air pollution impacts on communities are not only "significant and unavoidable," to use GSNR’s own words. For environmental justice communities, they are seriously unjustifiable. At the facility in Lassen, which would churn out 700,000 tons of wood pellets every year, GSNR admits that the project’s emissions will exceed air pollution control district limits for scores of dangerous air pollutants like particulate matter (PM10 and PM2.5), NOx, and Carbon Monoxide (CO). In doing so, the project will conflict with Lassen County’s air quality plans. It will also pose serious cancer risks to nearby residents. Indeed, the project’s maximum individual cancer risk in Lassen County is 28.6—more than two times greater than CEQA's threshold—and in Tuolumne County is 40.9, more than four times greater than CEQA’s threshold. 

The Tuolumne County facility would also conflict with the APCD's air quality plans, exceeding the plan’s annual threshold for CO. Finally, at the wood pellet storage and export terminal at the Port of Stockton, the project would create significant NOx impacts–as well as cumulatively significant PM2.5 (fine soot) impacts in an area that is already failing national standards for PM2.5. The government should be figuring out ways to clean up this already unacceptable air pollution, rather than adding to the existing burden. 

As our partner Gloria Alonso Cruz's states, “We're seeing an environmental tragedy unfold."

This project won’t help mitigate fires or make forests more resilient. But it will result in a massive increase in carbon emissions and harm to communities and forests. It's an exercise in doublespeak, an ill-disguised attempt to make their destruction seem green. California must stop this disaster in its tracks before it’s too late.