Submission from the National Farmers'
Union of England and Wales (NFU)
The National Farmers' Union of England and Wales
(NFU) represents the interests of some 55,000 members involved
in commercial agriculture, horticulture and farmer controlled
The NFU welcomes recent Government policy measures
that will stimulate the market for a broader range of renewable
energy generation technologies. We believe that agriculture and
the land-based renewables have an important role to play in the
context of climate change and renewable energy targets. It is
our aspiration that every farmer should have the opportunity to
become a net exporter of low-carbon energy services. We raise
a number of specific points below that may impact upon the market
opportunities for farmers to provide renewable fuels for power
generation, or to engage in on-site renewable generation, for
domestic use or for export to the electricity grid.
1. The European Union's 2020 targets for
renewable energy, agreed by Heads of State in March this year,
have added a sense of urgency to the measures announced in May
in the 2007 Energy White Paper. Given the likely constraints on
renewable transport fuel supply, and the almost total absence
of policy support for renewable heat, perhaps as much as 35-40%
of UK electricity may need to come from renewable sources by 2020.
This represents a huge nine to 10-fold increase from the present
modest baseline, assuming smaller proportions for renewable heat
(17%) and transport fuels (10%), in order to achieve 20% renewable
2. Together with offshore wind power, marine
energy and tidal power, the twin drivers of climate change response
and sustainable energy targets will create opportunities for a
diversity of land-based renewables, including smaller-scale decentralised
technologies such as anaerobic digestion and biomass-fired mini
power stations. The proposed "banding" of the Renewables
Obligation (RO) is a key measure that will stimulate "post-demonstration"
technologies such as straw-fired or wood-fired power generation
(eligible for 1.5 RO certificates), as well as "emerging
technologies" such as gasification or anaerobic digestion
of biomass, biomass-fired CHP, energy crops for power generation,
and photovoltaics (eligible for double RO certificates).
3. The NFU notes that enhanced revenue-based
support for many of these technologies will create new opportunities
for agricultural diversification and rural incomes. In particular,
we anticipate new investment in biogas digesters (both single-farm
and centralised) producing electricity and heat, small-scale combined
heat and power (CHP) units, and the possible use of solar photovoltaics
to meet some electricity use in farm buildings. Also significant
will be a likely increase in the market (and improved terms of
trade) for perennial energy crops as power station feedstock.
4. In this brief response, the NFU would
like to highlight a number of possible concerns with government
energy policy in general, and with some of the details of the
consultation on "banding" of the Renewables Obligation
(RO). Firstly, it is worrying that the Government's own projections
suggest that the banded RO will only just fulfil its original
expectations of 15% renewable electricity by 2015, correcting
a likely shortfall in the previously unadjusted RO. This is still
a long way from the massive deployment required to address the
EU targets, to mitigate climate change, and to create opportunities
for UK entrepreneurs to export low-carbon technologies to emerging
5. While the focus of this submission is
on electricity generation, we are also concerned about the lack
of attention paid to renewable heat and transport in the recent
Energy White Paper (EWP). On the latter subject, the Government
has so far failed to establish a stretched target for the Renewable
Transport Fuels Obligation beyond 2010, although the obligatory
goal for 2020 agreed by EU Heads of State does provide some long-term
market signal. Renewable heating appears in the EWP only under
the heading of "Distributed Energy". The Government
is said to be "still considering" a consultants' report
on this subject and "developing its thinking in this area";
and its Biomass Strategy, while a welcome recognition of the potential
of bioenergy, offers little beyond what is already obviousthat
industrial heating and CHP offer the best-value carbon savings.
The NFU believes its members can play an important role in providing
renewable heating services or fuels (such as energy crops or woodland
thinnings) for low or zero-carbon building developments in rural
and urban fringe areas of the country, and that planning as well
as energy policy should reflect this.
6. The NFU looks forward to the forthcoming
establishment of a product standard, exempt from waste management
regulation, for the digestate by-product from biogas digesters.
This will reduce the regulatory burden upon operators of single-farm
anaerobic digesters when land-spreading or selling raw or processed
digestate as a fertiliser or a possible fuel. Simplification of
regulations to enable movement of digestate between farms, without
a waste carrier licence, would also enable smaller livestock farmers
to collaboratively operate one digester between several farms.
7. The NFU notes that the growing of perennial
energy crops, which require low inputs and may therefore have
a very positive "carbon balance", will be increasing
important for "decarbonising" the economy. These crops
also offer improved biodiversity and nutrient management benefits
compared to arable crops or grassland. However, the present modest
areas of planting (about 0.1% of arable land area) of both short
rotation coppice willow and miscanthus have so far failed to establish
a working market. Through consultation with growers and contractors,
the NFU has established that what they most need is a stable,
consistent framework of government support, with announcements
and timetables that reflect the seasonality of agricultural decision-making.
Past delays in government announcements about the future of support
mechanisms have seriously eroded the confidence of farmers, who
have seen little evidence of any other public-sector demonstration
or commitment to these crops. The grant application process in
England is excessively bureaucratic and time-consuming compared
to the online, fast-track procedure in Scotlandand there
is presently no such support available in Wales.
8. Notwithstanding the recent announcement
of a new programme of energy crop establishment grants under the
draft Rural Development Programme for England 2007-13, the NFU
continues to be concerned by Defra's stop-start support for perennial
energy crops and the impact this has on the industry. The previous
scheme closed in June 2006, and a timetable has yet to be announced
for the new establishment grant applications. Most farmers will
decide this summer what to plant for next year, so we anticipate
a low take-up of this scheme for Spring 2008 planting.
9. The NFU is extremely concerned that the
definition of "energy crops" has not been clearly established
between Defra and DTI (now DBERR). As is evident from the above
discussion, the original use of this term applied to new types
of crops that offer significant environmental benefits (in terms
of reduced inputs, improved carbon balance and enhanced biodiversity)
compared to conventional crops. Generally, these characteristics
are confined to perennial crops, which avoid the energy costs
associated with the land preparation and sowing of annual crops.
The EU definition of energy crops, as applied to the Energy Crops
Aid payment of 45 euros/hectare, already blurs this definition
by including also annual crops grown expressly for energy purposes.
The NFU is aware that some stakeholders would like annual crops,
or the by-products from processing of biofuel crops (possibly
including tropical agricultural residues such as palm kernel shell),
included within those "energy crops" feedstocks eligible
for double ROCs under the proposed banding of the Renewables Obligation.
We do not believe this is consistent with the intention of the
RO banding, which is evidently targeted at "emerging technologies"
(ie those that would not otherwise find a market).
10. The Energy White Paper 2007 does state
clearly "there is a case for continuing to support energy
crops so as to promote the development of an effective domestic
supply chain for this valuable resource" (Paragraph 5.2.42).
However, there is only one mention (Box 3.1) where the term is
given more explicitly as "perennial energy crops". Together,
these occurrences imply that energy crops are grown domestically,
and that they are perennials. However, the NFU believes this is
a definition which does need to be defined more explicitly in
government proposals to incentivise new agricultural supply chains
for renewable energy.