USA BioEnergy, Forest Persistence and the Bon Wier Bet

June 10, 2025 |

We are reporting this week in the Digest that USA BioEnergy has signed a letter of intent with Louisiana-Pacific for a long-term supply agreement for sustainably sourced wood fiber to support operations at USAB’s planned Texas Renewable Fuels biorefinery in Bon Wier, Texas. Once finalized, the agreement would provide for up to 2.2 million tons of woody biomass annually for an initial term of 20 years. 

This advanced biorefinery will convert forest thinnings into Sustainable Aviation Fuel and other renewable fuels. With more than five decades of experience in forestry and timber operations in East Texas, LP is expected to serve as the exclusive procurement agent for TRF under the future agreement, leveraging its regional expertise to source feedstock responsibly and sustainably.

In January, USABE closed on the acquisition of over 1,600 acres of land in East Texas for its new $2.8 billion advanced biorefinery, designed to convert wood waste into sustainable, net-zero sustainable aviation fuel (SAF). The planned greenfield facility is currently in detailed design and engineering and aims to address airlines’ growing demand for SAF by converting sustainably sourced forest thinnings into sustainable aviation fuel. The landmark SAF facility has secured a 20-year offtake agreement with Southwest Airlines.

The single site

So many project developers announce large project slates — quite a few companies talk up their 10+ project development plans. LP’s decision to partner with a massively and long-term supply contract with a single, high-profile site is a signal. The Bon Wier project—quiet, persistent, structurally dense—is a systems-built survivor. With a 20-year feedstock contract, firm offtake, and strong regional roots, it may prove that single-site depth can rival multi-site breadth when aligned with local trust vectors.

How and why? Our General Theory of Evolutionary Systems & Information (GTESI) framework analyzes with rigorous math derived from hard sciences such as quantum mechanics and thermodynamics. Yes, you really can look at project resilience that way. More about GTESI here. 

Meanwhile, let’s see what our GTESI vector analysis says about the news from LP and USABioEnergy.

GTESI VECTOR ANALYSIS

1. IPR – Information Persistence Rate

Bon Wier/USABE:

High IPR. Despite a low public profile, the project retains technical and regulatory expertise, builds on legacy forestry infrastructure, and secures third-party audits—encoding trust and credibility across cycles.

Forest Owners Like LP:

Medium IPR. LP carries decades of silviculture and regional supply experience but has been slow to translate that memory into new fuels investment. Vendor role here suggests cautious testing of trust thresholds.

2. SCD – Structural Continuity Density

Bon Wier/USABE:

Very High SCD. This is the project’s core strength. A long-term feedstock deal matched to debt tenor, with local and federal buy-in, tax incentives, DOE engagement, and a major airline contract—this is scaffolding as survival architecture. The Wizard of Washington, Mark Riedy, is hovering in the mix, always a good sign.

Forest Majors (e.g. LP, Weyerhaeuser):

High latent SCD, often unrealized. Their land, roads, mills, and human networks are structurally rich but under-leveraged for low-carbon transformation.

3. TRFI – Thermodynamic-Response Friction Index

Bon Wier/USABE:

Low TRFI (a good thing). This project hasn’t moved fast, but it hasn’t stalled either. It adapts under pressure—aligning incentives, capturing political capital, and evolving without public thrashing.

LP and Others:

Medium TRFI. Historically slow to enter new markets. Their friction is not from incapacity, but from incentive misalignment—real returns often sit in wood product cycles, not fuels.

4. EED – Entropy Export Delta

Bon Wier/USABE:

Moderate-to-High EED. By monetizing waste biomass and storing CO₂, Bon Wier moves disorder out of the woods and into permanent carbon stores. The single-site model may limit entropy dispersion compared to a distributed network, but what it does, it does cleanly.

LP and Forestry Partners:

Low-to-Moderate EED. LP has traditionally exported value, not entropy. This deal could signal a shift—if it’s repeatable.

The Old Tools, the New Fuel

The Bon Wier play may not look fast, but it’s long. It resonates. It’s scaled like a timber harvest, not a software sprint. Every piece—land, trust, feedstock, offtake, debt—matches in rhythm and term. This is a GTESI-aligned system with slow-burn persistence, and that’s rare. Now, let’s look at how resilient the project is, the risks that pop up later that the best project developers are already preparing for.

GTESI RESILIENCE FORECAST: Bon Wier SAF Project

Project Timeline (2025–2030 and beyond)

Phase Milestone GTESI Assessment
2025–2026 Finalize detailed engineering/design Stable; secured land, strong partners (Honeywell, LP)
2027–2028 Begin and complete construction Moderate risk; reliant on stable capital flows and skilled labor
2029 Commissioning period (6–12 months) Sensitive to integration risk; good adaptive plan in place
2030+ Full operations (65M gallons/year, CI -335) High resilience if execution aligns with current infrastructure and offtake commitments

Potential Fracture Points

Fracture Point Description GTESI Vector Severity
Market Saturation Feedstock price spikes from regional competition (pulp & OSB) EED, TRFI ⚠️ Moderate–High
Labor Pipeline Education and vocational systems in Newton County are limited (1.5-star K–12 rating, 10% lower HS grad rate) IPR, TRFI ⚠️ Moderate
Social Infrastructure Weak post-secondary pipeline, limited housing, average hospital & retail access SCD ⚠️ Low–Moderate
Seasonal Disruptions Weather and mill cycle sensitivity may cause short-term volatility TRFI, EED ⚠️ Low
Sawmill Residual Fluctuations Large year-over-year variation from 170k–500k gt/yr; reliant on cyclical markets IPR, EED ⚠️ Moderate
Policy Volatility Dependence on policy-linked incentives (DOE, tax credits, SAF mandates) TRFI ⚠️ Moderate

Reinforcement Strategies

Reinforcement Impacted Vectors Notes
Workforce Development Partnership IPR, SCD Establish formal link with Angelina College and Stephen F. Austin State University to build tailored SAF technician pipeline
Microgrid or Resilience Energy Overlay TRFI On-site generation could reduce commissioning and operational risk from utility interruption
Dual-Rail Routing and Long-Term BNSF Contracts EED Leverage existing 4,500 feet of rail to lock in redundancy during peak logistics demand
Feedstock Diversification Plan TRFI, EED Avoid overdependence on pulpwood and residuals by testing harvest residuals and non-merchantable fiber streams
Community Engagement Corps IPR, SCD Establish a permanent local liaison office with economic dev boards, ISD, and Texas Forest Country Partnership for dynamic trust management

Non-Feedstock Asset Strength Summary

Asset Category Highlights GTESI Benefit
Infrastructure 2 transmission lines, natural gas, 4 large water wells, highway and rail access, strong drainage/wastewater systems Strong SCD; supports scalable energy-intensive ops
Land & Zoning 1600+ acres, flexible for expansion, already industrial-zoned Long-term SCD with spatial and permitting headroom
Governance & Policy $150M in incentives; DOE Loan Guarantee Part II; Chapter 313 agreement with school district Resilient TRFI if sustained; watch for 2026–2028 federal/state electoral impacts
Community & Social Trust Active local involvement; however, education and housing systems require targeted investment Moderate IPR; trust systems exist but underbuilt for next-gen scale

Forecast Summary

Overall Resilience Rating: Moderate to High

Bon Wier has strong structural and capital alignment (SCD), strong trust formation with LP and Southwest Airlines (IPR), and reasonable entropy export capability (EED) through its negative-carbon-intensity model and supply chain structure. The greatest risks lie in education/workforce bottlenecks, cyclical supply from the sawmill sector, and broader policy volatility. Yet, for a project that has yet to break ground, there’s a a high level continuity already built up.

Now, let’s turn away from USA BioEnergy for a moment and look towards the forest. Specifically, forest owners and biomass suppliers. What type of project engagement gets the highest resiliency ratings?

Typology of Forest Owner Roles in the Bioeconomy

GTESI Comparative Framework

Role Type Description IPR (Memory) SCD (Structure) TRFI (Friction) EED (Entropy Export) Archetypes
Vendor Sells biomass or fiber under contract, often long-term; no equity or R&D stake in fuels or tech ⚫⚫⚪⚪ (low) 

Short-term memory; rarely invests in downstream knowledge

⚫⚫⚫⚪ (moderate) 

Land, mills, logistics, but isolated

⚫⚫⚫⚫ (low friction) 

Highly flexible

⚫⚫⚪⚪ (moderate) 

Waste exported, but not upgraded

LP Building Solutions (Bon Wier)

Weyerhaeuser (contract mode)

Co-Investor Supplies biomass and equity or tech integration, typically as minority partner in projects ⚫⚫⚫⚪ (strong) 

Learns from ops and tech side

⚫⚫⚫⚪ (moderate–high) 

Begins to co-build with energy infra

⚫⚫⚪⚪ (medium friction) 

Strategic, but slower to pivot

⚫⚫⚫⚪ (higher) 

Begins to close local entropy loops

UPM (Finland)

PotlatchDeltic (prospective)

Platform Developer Fully integrates forestry assets with energy/fuel/chemical platforms; builds IP and market interface ⚫⚫⚫⚫ (very high) 

Retains tech, policy, ops, brand memory

⚫⚫⚫⚫ (very high) 

Vertically and symbolically integrated

⚫⚫⚪⚪ (moderate) 

Strategic burden but agile

⚫⚫⚫⚫ (very high) 

Converts waste to high-value products

SunGas (w/ C2X)

Origin Materials (hybrid model) 

UPM’s Lappeenranta model

GTESI Commentary on Roles

Vendor

  • Strength: Low friction and scalable across projects; flexible pricing, good infrastructure.
  • Weakness: Minimal memory of project performance; doesn’t help future-proof system.
  • Example: LP’s Bon Wier role — sells 2.2M tons/year, supports bankability, but contributes little to adaptive learning or tech evolution.
  • Resilience risk: If the buyer collapses, the vendor relationship dies with it.

Co-Investor

  • Strength: Retains knowledge, participates in performance, starts to shape the system.
  • Weakness: Often lacks final control or platform vision; still responds to external drivers.
  • Example: UPM’s early investments in biodiesel were strategic bets with partial control.
  • Potential: High if paired with skilled partners, but friction increases with complexity.

Platform Developer

  • Strength: Operates across IPR, SCD, TRFI, and EED domains; builds replicable system.
  • Weakness: Capital intensive; depends on high-trust ecosystems and long-term vision.
  • Example: SunGas–C2X–Timber Network is building a new GTESI-aligned forest-energy architecture.
  • Key GTESI advantage: Encodes memory, exports entropy, adapts faster than policy cycles.

Evolution Between Roles

Direction Typical Drivers GTESI Signal
Vendor → Co-Investor Price volatility, desire to hedge exposure, ESG mandates Rising IPR & EED pressures
Co-Investor → Platform Learning loops, vertical integration opportunities Expanding SCD, lowering TRFI
Platform → Collapse or Pivot Over-complexity, poor market fit, tech failure TRFI spike, IPR or SCD fragility

Strategic Forecast

Forest Owner Type GTESI Persistence Outlook
Weyerhaeuser (current vendor model) 🟡 Neutral. Strong assets but low EED/IPR engagement
Georgia-Pacific 🔴 Weak. Koch’s vertical firewall keeps forest assets isolated from energy flows
LP (at Bon Wier) 🟡🟢 Improving. Acting as a Vendor, but project alignment with USABE offers strategic learning
UPM 🟢 Strong. Platform thinker with fuel and chemical product lines fully integrated into fiber supply

Before we complete our project assessment, let’s look now towards policy. Yes, financiers look at technology and project fundamentals; yes, they look at feedstock supply and key project partners. Yet, their scrutiny often spikes when it comes to looking at government intent, those tax credits, loan guarantees and carbon credits which represent the social premium placed on energy diversification. We’ll introduce some basic concepts, then turn back specifically to this Bon Wier project.

Interpreting Policy Volatility in GTESI Terms

1. IPR – Information Persistence Rate

What it captures: Can the system encode lessons across political cycles?

  • Policy Risk Framing: When tax credit rules (e.g. 45Z) are announced but undefined, or redefined mid-cycle, systems built on past eligibility assumptions lose informational continuity.
  • GTESI Signal: High IPR systems embed regulatory intelligence in project architecture—e.g. modular eligibility, parallel tech-paths, or adaptive offtake strategies.
  • Example: A SAF plant assuming a $1.75/gal LCFS+45Z uplift but designing only for FT diesel may hit a wall if feedstock disqualifies under new rules.

IPR mitigation: Build projects with multi-credit eligibility pathways, and partner with legal/policy teams who specialize in recursive compliance modeling.

2. SCD – Structural Continuity Density

What it captures: Can the system maintain its functional form when rules shift?

  • Policy Risk Framing: DOE Loan Guarantees often fail not due to technology, but because projects lack rating comparables or don’t “fit the form.” Structural friction emerges from legal, insurance, and permitting misalignments.
  • GTESI Signal: Projects with high SCD pre-build institutional trust—standardized data rooms, modular debt structures, and multi-path permitting maps.
  • Example: Novel pyrolysis tech that produces mixed outputs may be structurally penalized even if it works, because lenders can’t categorize it in traditional silos.

SCD mitigation: Design plants and capital stacks to match existing financial and permitting archetypes — even if the tech is novel, the wrapper must feel familiar.

3. TRFI – Thermodynamic Response Friction Index

What it captures: Can the system adapt quickly when inputs or policy incentives shift?

  • Policy Risk Framing: RFS RIN values or LCFS credits can move 30–70% in months. High TRFI systems are brittle: a $3/gal assumption that drops to $1.80 can kill the PPA, financing, and partner trust.
  • GTESI Signal: Low TRFI systems build variable-margin envelopes — flexing feedstock mix, product outputs (SAF, naphtha, diesel), and transport modes to survive credit stress.
  • Example: A plant modeled for 82% SAF, 18% naphtha may need to pivot to 50/50 if CI thresholds or demand curves shift — but only if the internal systems allow.

TRFI mitigation: Design-in slack. Use Monte Carlo ranges for credit forecasts, not fixed targets. Ensure operational flexibility is paired with off-take optionality.

4. EED – Entropy Export Delta

What it captures: Can the system discard disorder without collapsing?

  • Policy Risk Framing: Frequent regulatory reinterpretation (especially for novel feedstocks or pathways) generates “entropy shocks” — excess compliance cost, legal ambiguity, or rejection from benefit eligibility.
  • GTESI Signal: High EED systems treat regulatory flux as a design variable, not a fixed externality. They shed policy entropy through adaptive lobbying, coalitional pressure, and symbolic anchoring (e.g. climate narrative alignment).
  • Example: A CDR-linked SAF plant that fails to get pathway approval may collapse, unless it has parallel channels for monetizing sequestration — e.g. soil carbon stacking, aviation partnerships.

EED mitigation: Build redundancy in benefit streams, pre-negotiate with IRS/Treasury/DOE during design, and maintain symbolic clarity (so allies will fight for you when rules shift).

Reframing Policy Risk in GTESI

Instead of treating policy risk as a static external shock, GTESI treats it as a signal-to-friction amplifier. Systems that survive do three things:

  1. Anticipate disorder by encoding modularity.
  2. Absorb shock by diffusing adaptation across time and roles.
  3. Export narrative and legal entropy through pre-compliance and multi-layer symbolic alignment.

GTESI Policy Persistence Score (GPPS)

Here, we define a supplemental metric — the GPPS — to evaluate how well a project handles shifting policy:

Score Component Description
IPR–Policy Horizon Years of continuity assumed vs. years realistically supported
SCD–Regulatory Redundancy Number of policy instruments that could underwrite the same revenue
TRFI–Flex Envelope Percent of output/products/feedstock that can pivot without redesign
EED–Symbolic Resilience Degree of alignment with national/international climate goals or social license narratives

GTESI Policy Persistence Score (GPPS)

Project: Bon Wier SAF Facility (USA BioEnergy)
Date: June 2025 | Status: Engineering & Design Phase

GPPS Vector Evaluation Metric Bon Wier Status Score (1–5) Notes
IPR – Policy Horizon Match between long-term credit assumptions and realistic duration of policy stability ⚫⚫⚫⚫⚪ (4/5) 20-year offtake and debt horizon align with feedstock supply, but policies like 45Z and RFS are only secure 3–5 years forward.
SCD – Regulatory Redundancy Number of distinct and substitutable revenue-eligible policies (e.g., 45Z, LCFS, RFS, Chapter 313, state/local credits) ⚫⚫⚫⚫⚪ (4/5) Project taps multiple streams: LCFS, 45Z (provisional), DOE LGP (Part II), Texas state/local tax relief. Lacks fallback EU-style carbon monetization.
TRFI – Flex Envelope Ability to pivot feedstock, output, or process to maintain eligibility if definitions shift ⚫⚫⚫⚪⚪ (3/5) Designed for woody biomass to SAF/naphtha only. High-quality, but limited elasticity if CI thresholds change or pathways are rejected.
EED – Symbolic Resilience Strength of alignment with climate, resilience, and domestic fuel narratives to retain public/political support ⚫⚫⚫⚫⚫ (5/5) Carbon-negative (CI ~ –335), American wood, airline offtake, rural jobs — hits all symbolic chords for bipartisan support and public visibility.

Total GPPS: 16 / 20 → “High Policy Persistence”

Range Rating Interpretation
17–20 🟢 Very High Strong buffer against policy shifts; project can survive credit loss or reinterpretation
13–16 🟢🟡 High Good redundancy and alignment, but vulnerable to multi-pathway disqualification or timeline mismatch
9–12 🟡 Moderate One or two policy anchors dominate viability; system needs adaptive redesign or narrative support
<9 🔴 Low Fragile structure; likely to fail under modest regulatory change

Recommendations for Bon Wier to Achieve GPPS 18–20:

  1. Broaden Feedstock Flexibility: Model and pre-permit a secondary feedstock stream (e.g. storm salvage, ag waste, or pellet intermediates) to increase TRFI.
  2. Secure Parallel Product Offtakes: Add redundancy by establishing conditional offtake for renewable diesel or marine fuels (especially if SAF credits tighten).
  3. Pre-negotiate Symbolic Endorsements: Anchor the project with named endorsements from USDA, Texas Forestry Commission, or DoD aviation.
  4. Map Credit Overlap Zone: Publicly release a “credit durability map” showing that even if LCFS or 45Z falter, the project can run profitably on RINs plus regional offsets.

Category: Thought Leadership, Top Stories

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