Local action.
Lasting carbon.

Biochar Coalition requests explicit recognition of portable onsite biochar production, including flame-cap kilns, as biomass carbon removal and storage under proposed section 95702(d), clear definitions under section 95701, and a practical certification pathway under section 95705. We ask CARB to designate a staff lead and publish a workplan with practitioners, researchers, and independent verifiers. [1]

CAL FIRE's 2023 review of biomass transportation subsidies cites modeling in which transport represented 64-69% of harvest operating costs. Shorter processing distances delivered the largest modeled cost reductions. [2] A portable-biochar study modeled lower transport impacts from near-forest production, with financial viability varying by equipment, utilization, and support. [3] Modular onsite methods could help wildland-urban interface communities with limited road access and processing options. [6]

Forest ecosystems can serve as valuable carbon reservoirs and potential sources of carbon-credit revenue for continued stewardship and local jobs. A 2026 Caldor Fire study linked unburned fuel piles with higher fire severity and tree mortality in some treated areas. [4] A 2025 Central Sierra Nevada study linked thinning with reduced fire severity and stronger live-carbon retention. [5] Converting suitable residues that would otherwise decay or burn into biochar can add durable carbon storage. [6,7] Ecosystem management should therefore play a central role in SB 905's nature-based and biomass carbon-removal pathways, with methods that verify net benefits, preserve ecological retention, and prevent double counting. Profitability would depend on project eligibility, implementation and verification costs, and buyers. [1,3]

Our field operations and workforce training provide an implementation model to contribute. Published portable-kiln methods and U.S. field measurements are available. [7,8] A 2026 controlled study reported mean methane emissions of 2.9 versus 28.7 grams per kilogram of dry biochar for its dry and moist feedstock groups. Earlier studies also show strong dependence on feedstock and operating conditions. [9-11] Yet Isometric's distributed-production module excludes flame-curtain kilns over concerns about measuring emissions. [12] Without an accepted way to evaluate these emissions, practitioners face a barrier to certification and potential carbon revenue. CARB should establish criteria for accepting representative data, uncertainty deductions, and operating limits.

Entry to verified carbon crediting should be practical for community operators alongside oil companies and other well-capitalized enterprises. Occidental's November 2026 capital cost estimate for its STRATOS direct air capture (DAC) facility is $1.8 billion. [19] DOE's 2024 Project Cypress fact sheet describes about $101 million and 2-3 years for initial planning, development, and design. [20] California should also enable qualified mobile systems already operating in the field to demonstrate verified removals. [7,8] Proportionate requirements and shared administration could accelerate participation while larger facilities are developed.

We request a workplan addressing:

1. Test the complete production cycle

   Representative emissions testing over the full production cycle, including quenching; conditions for accepting validated emission factors or alternative measurements; operator competencies; and applicable air-pollutant safeguards. [6,9-11]

2. Use defensible net carbon metrics

   Defensible carbon metrics based on dry biochar mass, organic carbon content, durability evidence, life-cycle emissions, and documented final use, with conservative baselines and uncertainty treatment. [3,13-15]

3. Make shared verification practical

   Accountable aggregation of kilns and properties, with batch traceability, clear carbon rights, shared administration, and independent verification. Evaluate how Isometric's grouping, composite-sampling, and digital-record methods could support smaller batches, with independent validation for flame-cap kilns. [1,7,12]

4. Provide an accessible assessment tool

   A publicly accessible measurement and assessment tool with validated calculations, clear instructions, field data entry, and exportable records. Landowners, community participants, and professionals should be able to contribute consistent data for review; credit claims would remain subject to verification. [7,13,15]

5. Plan for implementation costs

   An implementation assessment identifying costs, technical assistance, agency responsibilities, review milestones, and potential existing-program support. Testing, laboratory analysis, verification, and sustained technical participation require resources community organizations cannot routinely absorb. [2,3]

Coordinate this work with CAL FIRE, the Board of Forestry and Fire Protection, the Wildfire and Forest Resilience Task Force, resource conservation districts, and local air districts on operator competencies, model permitting guidance, and demonstrations. The November 2026 draft biochar market strategy prepared for the Board's Joint Institute already proposes model air permits and a registration category for small portable units; the Task Force has an existing workforce-development forum. [16,17] Eligible Proposition 4 programs could support implementation and workforce training, subject to appropriations and program rules. [18]

Biochar Coalition can contribute training materials, operating records, and practical guidance through a supported collaboration. The workplan should identify how qualifying activities could access existing incentives and potential carbon revenue, helping individual landowners and community crews participate alongside regional programs while contributing verifiable outcomes to California's climate goals.