Memorandum submitted by Calor Gas Ltd
SUMMARY
— Clear, reliable definitions of "green",
"renewable" and "zero carbon" are required.
Greenness should not be solely defined by CO2 reduction, and there
is a risk of carbon eclipsing the consideration of other pollution.
Classifying biofuels as "renewable" has been an embarrassing
policy mistake; doubts are cast over the renewability of biomass.
The credibility of "zero carbon" rests in turn upon
the definition of "renewables".
— 1,000,000 zero carbon homes built
by 2020 appears a heroic target, and one that might be very expensive
either for taxpayers or consumers. Current estimates for carbon
displacement technologies often cost more than the carbon they
displace; the cost of a zero carbon home may be 41-65% more than
current homes.
— Pending the move to zero carbon homes,
HMG is using the Building Regulations system to reduce carbon
emissions, but the Regulations contain no assessment of greenhouse
gas emissions other than CO2—a gas responsible for only
a minor contribution to global warming; many CO2 emissions are
conveniently ignored, especially in rural areas, by the use of
a blatant fix—the scientific-sounding but crude "fuel
factor index". Nor do the Building Regulations marry the
climate change policy with HMG's own Air Quality Strategy.
— The Code for Sustainable Homes suffers
two deep flaws: it is based on a SAP system of calculation which
by taking the cost of energy as an analogue for carbon emissions
risks delivering the perverse result of some house-builders and
purchasers choosing more polluting fuel systems; and, almost incredibly,
it sets no minimum standards for pollution demonstrating a carbon
obsession to the exclusion of wider environmental considerations.
— We suggest a number of simple, basic
common-sense tests to be applied to avoid inadvertent, perverse
consequences of policies designed to reduce pollution actually
increasing it.
THE IMPORTANCE
OF DEFINITIONS
What is "Greener"?
1.1 The Committee invites submissions on
providing "Greener Homes for the Future"? Careful attention
to language and logic is essential. Sometimes, the jargon surrounding
political debate becomes so stylised and prefabricated that basic
concepts become overlooked. There was a time when greenness and
environmentalism was associated with air or water quality, for
instance. There is a danger that current obsessions with carbon
alone are distorting the overall environmental approach. Greener
homes are not simply those that are built with carbon emissions
in mind.
1.2 What is a greener home? Is it one that
is constructed with a view to minimising the impact of a home
on the environment through its construction or through its habitation?
The questions posed by the Committee would seem to imply that
the emphasis is solely on the environmental costs of its use rather
than construction. The same questions seem to imply that a carbon
obsession has ousted most considerations about air quality (see
below). In this, HMG risks falling into the same trap that the
Mayor of London has fallen into regarding the London Congestion
Charge where low carbon emission cars are favoured, and favour
removed from cars with low emissions of particulates etc which
are responsible for ongoing death and morbidity amongst Londoners.
1.3 A prime example of "greenwash"
in delivering "green credentials" is the "Merton
Rule, which makes costly obeisance to the concept of renewables
without necessarily delivering higher usage of renewables. This
rule, widely copied by local authorities, reads, "All new
non-residential development above a threshold of 1,000m2 will
be expected to incorporate renewable energy production equipment
to provide at least 10% of predicted energy requirements."
Householders do not have to use the renewable source—indeed,
they are likely to remain unused used because of cost and practicality.
What is a "Zero Carbon Home"?
1.4 The Government has its own definition
contained in HMRC leaflet BN26 (21.3.07). In short, a zero carbon
home will have to export renewable power to the grid from the
home which will balance the import of grid power over the year.
In addition, each home must currently provide an amount of renewable
electricity equal to an amount calculated to approximate the average
appliance energy consumption.
1.5 No calculation is made of the amount
of carbon equivalent emissions generated through the process of
construction or sourcing materials. Nor are questions of durability
raised.
1.6 What is "renewable"? We are
predicating future energy policies on the basis of unsound or
unproven science. There is no better example of this than the
impending demise of biofuels, once the indispensable fashion accessory
of parts of the "Green" movement. Heavily subsidised
by the taxpayer, UK and European, great profits are being made
in the USA at the expense of the environment and with a risk according
to Ban-Ki Moon to "social progress and security". Jean
Ziegler, UN Special Rapporteur on the Right to Food has called
the production of biofuels "a crime against humanity".
We must be careful before we make similar mistakes—we fear
there is a risk over biomass (see below). If we are building generations
of homes, effectively determining winners and losers in the energy
market we must be careful to get the basic assumptions right.
ACHIEVABILITY
2.1 Government policy requires 2,000,000
homes to be built by 2016. By 2016, all new homes are to be zero
carbon. Government requires 1,000,000 homes to be built 2016-20
as zero carbon homes. With very few zero carbon homes being built
at present, these goals appear to us to be "heroic".
2.2. Leaving aside any questions over the
health of the house building market, targets for 2010-13 may be
achievable using advanced insulation methods primarily to reduce
thermal load of the home, together with enhanced efficiency appliances
(ie SEDBUK A rating), and some renewable input. But, 2016 zero
carbon compliance currently seems to be viable only by using renewable
sources eg solar PV to provide power for lighting plus heat pumps
etc, together with "renewable" heating eg biomass. There
are problems with this approach: not least the quantity of, the
logistics of and the embedded carbon of biomass and the capital
cost of PV, making zero carbon very expensive to implement, in
conflict with mass market deployment. If this approach is adopted
the putative "best" solutions are very much the enemy
of the "good" approach of utilising high efficiency
energy appliances and effective insulation that is making a substantial
contribution to emissions reductions today.
2.3 Do the economics make sense from a policy
perspective? The Energy White Paper (2007) put the cost of carbon
displacement by solar PV at £446/tonne; solar water power
at £288/tonne; and, micro-wind at £265/tonne. This is
at a time when the social cost of carbon is broadly estimated
to be £70/tonne (Stern Report).
2.4 Do the economics make sense from the
consumer's point of view? It is hard to assess what the cost of
a zero carbon home would be in the absence of any market for them,
and in current economic conditions but here is one assessment:
"The estimated build cost of a simple zero-carbon home would
be about £120,000 to £140,000, compared to around £85,000
for a similar sized traditional property. However, that does not
include the cost of land—an expensive commodity in Britain—or
developer's profits. The total basic cost of a zero-carbon home,
without subsidies, is unlikely to be less than £350,000 to
£400,000, although the more that are built the cheaper the
technology and expertise will become. Meanwhile, developers would
be more likely to build them in expensive areas, where the price
of land will push them towards the £500,000 threshold,"
(Simon Lambert, This is Money, 22.3.07). If the ratios are anywhere
near correct, zero carbon homes could end up at least 41-65% higher
in cost than current homes. Is this a viable or acceptable cost
for homeowners in the current and foreseeable economic climate?
2.5 HMG is providing some subsidy in the
form of Stamp Duty Land Tax. It applies only to houses built under
the criteria outlined by HMRC and is a time-limited relief expiring
on 30.10.2012. The total Exchequer cost of this measure is estimated
at £15 million by close of scheme. A £15 million injection
of taxpayers' money to stimulate a falling housing market that
will be 41-65% higher in cost than currently is unlikely to prove
significant.
DISTORTING UNDERLYING
ASSUMPTIONS IN
DRIVING TOWARDS
"GREENER HOMES"
3.1 With a dramatic move to zero carbon
homes looking futuristic, Government is moving on a number of
fronts to reduce carbon emissions. The danger is that market-shaping
decisions will be taken in a way that not only unfairly distorts
competition, but actually undermines the goals which Government
is trying to reach. We propose four common-sense tests which should
inform the whole of policy-making in this area:
— Any measures employed to reduce carbon
emissions should favour technologies emitting lower carbon over
those emitting more.
— Measures designed to reduce carbon
pollution should not be outweighed by the external costs inflicted
by other forms of pollution.
— Any measures proposed to batten down
on carbon should be proofed against unintended consequences.
— Measures which batten down on carbon
should not ignore other global warming gases other than CO2.
3.2 One of the tools the Government is using
is the Building Regulations. Let us scrape below the surface.
The underlying assumptions about buildings CO2 emission figures
are described in a paper by Christine Pout of the Building Research
Establishment "CO2 Emission Figures for Policy Analysis".
The methodology restricts consideration of greenhouse gas emissions
to CO2. CO2 is not the only greenhouse gas: it causes only a fraction
of global warming (9-26%). Other greenhouse gases have a far higher
global warming potential (GWP) than CO2: HFC-410 for instance,
has a GWP of 2,340. These greenhouse gases—where the bulk
of the problem lies—are left out of consideration in the
Building Regulations. The reason given in the BRE paper is that
this is appropriate, as the EU Energy Performance of Buildings
Directive states: "The energy performance of a building shall
be expressed in a transparent measure and may include a CO2 indicator."
The Directive does not preclude consideration of the impact other
greenhouse gases, but sloppy drafting of a Directive does not
excuse sloppy policy formulation thereafter. Further, methane
losses from the pipeline network are highly significant (one source
puts it at 4.5TWh/yr in UK). The BRE paper justifies ignoring
methane on the grounds that the EU Directive cited does not require
it. But, as the GWP of methane is 23 times that of CO2, a really
effective climate change policy would not ignore it.
3.3 Having established that the Building
Regulations ignore most of the global warming gases, can we be
assured that they really bite on CO2? Sadly, no. In setting the
standards for new dwellings, the CO2 pollution potential of each
fuel is taken into account by using a comparison of CO2 emissions
with those of mains gas. (This is done at the level of the individual
building, ignoring the GWP of distribution network leakage.)
3.4 If the increased construction costs
of insulation etc required to reduce CO2 emissions were fully
applied to new homes away from the gas network that relied on
other fuels, the homes would become too expensive to build. In
order to allow electricity, oil and coal to "come under the
bar" a "fuel factor" is applied. This allows the
extent of the CO2 emissions of fuels other than mains gas to be
mitigated—it amounts to pretending that some emissions are
not there. For 2006, this fuel factor index is 0.5. Electricity
generation produces about three times more CO2 than mains gas
for the same power output, but the index allows the building standards
to pretend that it produces only 1.5 times more CO2. For oil,
which is about 73% more CO2-polluting than gas, the fuel factor
index system allows the pretence that it is only 36% more polluting.
3.5 The formula has no scientific basis.
Why divide the ratio by two? Why not 3 or 4? The reason the figure
has been chosen is to allow the continued use in buildings, particularly
in rural areas, of fuels whose CO2 output should really rule them
out. The Government, though facing failure in meeting its Kyoto
targets on CO2 emissions, has chosen to fudge its own price signalling
system so that it reduces incentives to meet its own targets.
Oil produces more CO2 than gas, and electricity also has a high
carbon cost. In areas on the gas network, gas wins hands down.
Policy makers have decided that rural homes off the mains gas
network with the same insulation standards as urban homes will
effectively be allowed to pollute more.
3.6 This crude device has been worked back
from the policy decision to allow oil and electricity to remain
as viable fuels for rural homes off the mains gas network. This
is starkly revealed by a schoolboy howler in the formula. Para
11 of "Standards for New Dwellings" gives the formula
for calculating TER (Target Emissions Rate for the building) as:
(Ch x fuel factor + Cl)
x (1—improvement factor).
Ch is the emissions calculated using SAP 2005 that arises
from the provision of heat and hot water. Using this formula actually
accentuates the carbon emissions problem. (Ch x 1.10) for instance
would be higher than Ch, thus providing an impediment rather than
a relaxation. The only way that the fuel factor can mitigate the
problem would be if it were used as a divisor i.e:
Ch
fuel factor
The fuel factor "fix" is superficially scientific
but actually a part of the climate change machinery deliberately
disabled.
3.7 If there is a "fix" in order to allow the
continued construction of homes in rural areas at an affordable
cost, it ought at least be transparent, and it ought at least
to provide a real, biting incentive to reduce emissions. For instance,
instead of a formula which allows all fuels to be used, notwithstanding
their pollution profile, why not set a standard or bar which the
cleaner fuels can pass, but not the dirtier fuels? The bar could
be gradually lowered as technology moves on, encouraging innovation,
and actually acting to reduce CO2 rather than permit business
as usual pollution. Where this bar should be set is a matter for
judgement and consultation, but as a starting point we would suggest
that rural homes be allowed a relaxation of, say, 10% in TER compared
with urban homes on the gas main.
3.8 DCLG's Building Regulations (2007) implicitly recognize
that the fuel factor indices as currently applied are indefensible.
The proposed index for 2010 is 0.4 which removes some of this
relaxation and a similar reduction is proposed for 2013 along
the way to no relaxation in 2016. By 2016 the full cost of CO2
pollution should be borne within the cost of the building. Given
the immediacy of the climate change problem, this is remarkably
complacent. There can be no scientific justification for moving
to 0.4 (dividing by 2.5) in 2010—why 0.4 and why 2010? They
are figures plucked out of the air to allow polluting technologies
to continue to pollute over a phase out period. During this period,
homes will be built using polluting fuels. The fuel factor indices
are simply a licence to pollute.
3.9 Given that most greenhouse gases do not count in
the Building Regulations system, that not all CO2 counts, particularly
in rural areas, can we be assured that the Building Regulations
are also helping deliver the Government's Air Quality Strategy
(AQS) designed to reduce a range of 10 pollutants harmful to human
health, life expectancy and the environment? These pollutants
are causing damage now—not simply potentially. Larger particulates
alone—PM10s—are estimated to cause damage in the UK
valued at £10.5bn-26bn annually, to advance 8,100 deaths
a year and to cause 10,500 extra hospital admissions a year. The
same AQS points out that progress on road transport measures and
in electricity generation has produced benefits in reduced pollution
worth up to £69 billion to date. This is pollution that it
pays to fight rather than ignore.
3.10 The latest AQS rightly marries the climate change
policy with the pollution control policy: "Where practicable
and sensible, synergistic policies beneficial to both air quality
and climate change will be pursued," (Para. 95). However,
such synergistic policies have not reached the Building Regulations.
It should theoretically be possible to weight the fuel factor
formula in such a way as to send out price signals to builders
and house buyers about the relative emissions of pollutants other
than CO2. We suspect that this is evidence once again of a carbon
obsession at the cost of other pollution. Thus, the current drive
to "greener homes" using Building Regs ignores most
greenhouse gases, some far more polluting than CO2; ignores much
CO2 emission in rural areas in order to prop up more polluting
fuels in terms of climate change and air quality; and, ignores
a whole range of other harmful emissions. It does not seem very
"green" in practice.
Are Heat Pumps Green?
3.11 Heat pumps are generating some excitement as being
a potential partial solution, but the solution is illusory because
it depends on the corruption implicit in the fuel factor. Without
the "help" given by the arbitrarily chosen index, they
would not be economically viable in rural areas. They may be an
efficient product, but they rely on electricity—very polluting
from a climate change point of view. Electricity generation produces
over twice as much carbon pollution as natural gas (217%). The
fuel factor for electricity makes it appear acceptable to construct
a house with a heat pump in non-mains gas areas, in spite of that
house having high green-house emissions.
3.12 As an illustration, the Elmhurst House (a standard
3/4 bedroom detached house built to a modern standard) on conventional
electric heating would have a Dwelling Emission Rating of 34.37
against a TER of 29.53. It would be too expensive to build. However,
given the slack cut to electricity by the current fuel factor
a house with an air source heat pump has a Dwelling Emission Rating
of 20.59. This air source heat pump would achieve Level 4 of the
Code for Sustainable Homes (ie 44% lower emissions than the current
Building Regulations). The fuel factors are picking winners that
do not deserve to win. If the fuel factor fudge is not rectified,
as the building regulations tighten, rural customers will be forced
into far more expensive, more polluting, electric heating solutions
carried by an over-stretched electric-mains network If all new
systems in non-mains gas dwellings over the next 10 years were
heat pumps, an additional 1,600MW of power would need to be sourced
from predominantly coal or gas stations at a minimum emission
of 420g CO2/kWh.
3.13 The installation cost of heat pumps is likely to
be between two to five times the cost of an LPG system but with
no or little CO2 emission advantage. The outdoor units of heat
pumps vary in noise production between 30-60 dB(A), whereas Local
Authorities intend to limit the transmitted noise in gardens to
40 dB(A). Most heat pumps will struggle to get the temperature
necessary for sanitary water and their efficiency drops markedly
when trying to raise temperatures to the 60-70C requirement for
sanitary water. Additional electric immersion heaters therefore
need to be added, and this sharply increases the emissions of
the heat pumps—well above that of LPG in many cases.
3.14 Government has become a victim of its own mathematical
methodology, and currently has a policy of supporting electric
heat pumps. The Energy Efficiency Commitment, for instance, gives
Renewable Obligation Certificates to the Utilities for funding
heat pumps. Similarly, the Low Carbon Building Programme gives
grants of up to 50% for installation of a heat pump.
3.15 Those installing heat pumps should be aware that
HMG intends to move the goalposts and make the technology redundant
in three years' time when the fuel factors are corrected. Such
considerations remove the logic behind government grant funding
for heat pumps. A better use of these resources would be to help
the 5,000,000 customers with older, less efficient boilers to
move to the latest SEDBUK "A" rated boilers.
CODE FOR
SUSTAINABLE HOMES
Built on a Flawed EPC/SAPs System
4.1 The Code for Sustainable Homes, mandatory by 2008,
purportedly aims to provide a stronger incentive to developers
and purchasers to build or buy houses that demonstrate quantifiable
environmental advantages over standards already set as a minimum
by the Building Regulations. The 1* to 6* ratings under this Code
will be applied to nine aspects of the home: 1* represents an
improvement over current standards: 6* supposedly represents "exemplar"
development in sustainability terms.
4.2 The energy efficiency ratings are designed to help
reduce the impact of buildings on global warming by providing
incentives for reductions in emissions of carbon. 1*, for instance,
would represent a 10% improvement in emissions over the current
Building Regulations: 6* would effectively equal a "zero
carbon" home. At first sight this all seems a good idea.
However, the problem is that the EPC/SAP rating system which underpins
the Code and provides the baseline for all measurements in this
rating system is deeply flawed. The edifice of the Code is built
on untrustworthy sand. Since the Building Regulations and the
Code for Sustainable Homes which extends their impact will have
fundamental impacts on the fuels we can choose it is important
that the scientific case for and against each fuel is fully understood.
Otherwise, Government risks choosing undeserving winners: and,
the Code will not be an effective instrument for a low carbon
(eventually zero-carbon) future.
4.3 Energy Performance Certificates (EPCs) are designed
to influence consumer behaviour in the purchase and alteration
of homes; and, it is hoped that house builders will have an eye
to favourable EPCs being awarded after construction. The aim is
to push the housing market towards lower carbon outputs. They
suffer from a fundamental flaw inherited from a system of grading
houses by their notional cost of providing energy for heating
and hot water per square metre. SAP ratings between 1 and 120
must be provided before buildings can be erected or converted.
The lower the energy cost, the higher the rating. These SAP ratings
are effectively transposed into the EPCs where they are shown
in the form of bands from A (cheap to heat) to G (expensive to
heat). The essential purpose was, as a Government consultation
put it: "A reduction in the carbon emissions they [homes]
would otherwise produce." The flaw at the heart of the system
is the link assumed between heating costs and carbon output. HMG
is using the wrong analogue especially when carbon output can
be calculated. It is unfair to a premium fuel such as LPG which
is often cleaner in its emission profile on a range of pollutants
(information available). Using the current SAPS system our data
shows that a fuel such as LPG, which produces considerably less
CO2 than both heating oil and electricity, is penalised and given
a far poorer rating. If the house builder or purchaser chose oil
over LPG on these calculations, he or she would be moving to a
dirtier fuel (on CO2 and a wide range of other pollutants). This
is an unintended perverse result breaking our common-sense tests.
4.4 The Scottish EPC system is different. It contains
a banding system A-G, but this is solely related to relative carbon
output. In England there are two illustrations side by side—the
first being the A-G banding based on cost called an Energy Efficiency
Rating, and the second being the Environmental Impact Rating (CO2
emissions). The Scottish system does not unfairly skew the housing
market, complies with EU legislation, and gives useful information
on how to save money. If consumers thinking of purchasing or renting
a home, or house builders are forced to comply with a system of
skewed price signals it could alter the pattern of our housing
stock for the worse, not the better.
4.5 The English EPC system has another flaw because the
snapshot taken of heating costs does not take the relative volatility
of fuel prices adequately into account. Volatility in energy prices
over recent years has been influenced by more labile meteorological
patterns, and by political factors—not least nervousness
over the price of oil, and by relatively sharp variations in demand,
including, for instance, dramatically increased levels of demand
for energy in China. With continued uncertainties over pipeline
integrity in chronically unsettled parts of the world, and with
the decline in North Sea production such volatility might increase
rather than decrease. The UK is seeing a tightening of markets
because of declining UKCS gas production, making us more susceptible
to the vagaries of European gas prices derived from a less liberalised
market context. A statement of the relative expense of one form
of domestic heating over another is therefore unlikely to hold
stable over a 15 year period, and the risk is that the certificate
will be an unreliable indicator. The volatility over a 15 year
span is illustrated by table 2 of "Building Regulations:
Energy Efficiency Requirements for New Dwellings", July 2007
(DCLG):
4.6 OFGEM finds: "The traded gas markets have seen
unprecedented volatility|in recent weeks with significant and
rapid movements seen in both prompt and forward gas prices on
a number of days. The increase in gas prices has also had a significant
impact on the wholesale price of electricity|since September 2003,
the wholesale price of electricity has risen by over 43%. This
has been largely driven by increases in gas prices although increases
in international coal prices have also played a part," ("Probe
Into Wholesale Gas Prices" Oct. 2004). So, there is energy
price volatility, and although the prices of oil and gas are linked:
"As competition develops in key European markets the link
between oil prices and gas prices is likely to break down or be
significantly diluted".
4.7 The SAP derived EPC rating is therefore a poor guide
to future heating costs. Worse, it is based on what is already
an historical snapshot. Para 10.2 of SAPS 2005 makes it clear
that the fuel prices on which it is based are derived from the
average of the three years previous to 2005. A corrective formula
can be applied for relative movements of fuels within the RPI
basket, but Table 12 admits, "Individual SAP ratings are
affected by relative changes in the price of particular heating
fuels". Thus, an EPC relating to the heating costs of a home
delivered in one month may have little bearing on the outturn
price, and increasingly in future fuels may be expected to vary
relatively in price over time rather than maintain a constant
or predictable relationship. This is another reason for adopting
the Scottish format.
Carbon Obsessed at the Expense of other Environmental Pollutions
4.8 The AQS attempt to marry air quality policy with
the climate change policy is absent in the Code for Sustainable
Homes. Under the Pollution rating the GWP of insulation and NOx
emissions from space and water heating are given consideration,
but there are no minimum standards set for pollution. Even the
consideration that the GWP of insulation and NOx emissions receive
is confined to a minimal contribution to an overall points rating
of the house (2.5 at most). The trend in policy-making—as
we have noted—is to emphasise the carbon emissions, apparently
at the expense of emissions of other pollutants. Since part of
the rationale behind the Code for Sustainable Homes is to bring
home to developers and purchasers the "wider social costs
("externalities") of a home's environmental impact"
(Summary, "The future of the Code for Sustainable Homes—Making
a Rating Mandatory", para. 22) these omissions are questionable.
Why should the pollution a house causes other than carbon be ignored?
It should be possible to weight the fuel factor/the Code in such
a way as to send out price signals to builders and house buyers
about the relative emissions of pollutants other than CO2.
ARE ALL
RENEWABLES GREEN?
Biofuels
5.1 HMG doggedly favours biofuels but the green credentials
of most biofuels are looking threadbare. The Building Regulations
raised the possibility that the fuel factor for heating fuel could
be improved if it were to incorporate a percentage of biofuels
but this would be an increasingly perverse course of action, leaving
aside the issue of having to redesign the technology of oil tanks,
and the expensive retrofitting of technology that such a policy
would entail. Since June 2007 food prices have risen by 55% (UNO);
the price of grain rose 130% between June 2007 and March 2008.
Direct competition for grain seems to have arisen between petrol
tanks and human stomachs.
5.2 Eric Johnson and Russell Heinen writing in "Chemistry
and Industry" (23.4.07) pose the question: "Do biofuels
really reduce global warming?" They compare rape oil as the
primary feedstock in Europe for biofuels with petroleum diesel
refined from crude oil. About two-thirds of the emissions of greenhouse
gases from rape oil-derived diesel occur during the farming of
the crop since cropland emits N2O—a greenhouse gas with
a GWP of 200-300. Fertiliser and tilling also generate significant
carbon emissions. The analysis found that rape-oil derived diesel
and petroleum diesel emit almost the same GWP in total per unit
of energy delivered. The journal, "Atmospheric Chemistry
and Physics" as reported in The Times (22.9.07) reports on
research that rapeseed and maize biofuels produce up to 70% and
50% more greenhouse gases respectively than fossil fuels.
5.3 Deepak Rughan of "Biofuel Watch" said:
"If you add in all the various factors involved in actually
growing and manufacturing biofuels, then the latest scientific
research shows that biofuel use results in between two and eight
times the carbon emissions you get from burning fossil fuels|What's
not taken into account are the emissions caused by destroying
natural ecosystems to create farmland—deforestation or the
removal of the sensitive peat ecosystems of south-east Asia."
There is a massive carbon cost that is being externalized from
all our equations. The environmentalist, George Monbiot, comments:
"The governments using biofuel to tackle global warming know
that it causes more harm than good. Biofuel is worse for the planet
than petroleum|Run your car on virgin biofuel and other people
will starve" (Guardian 6.11.07).
Biomass
5.4 One of the current front runners for local microgeneration
to make zero carbon homes viable is burning wood pellets. Wood
logs/chips/pellets are classified as "renewables" and
are attributed (relatively low) fuel emission factors of 0.025kgCO2/kWh.
This is to take account of planting, harvesting, sawing up, and
delivery of these bulky and heavy materials to the point of use.
What is the basis for wood's low score? The BRE paper (op. cit.)
explains: "These estimates are notional and are not based
on detailed assessments." In other words, it's a guess to
encourage a putative "renewable" energy source. Because
wood is treated as being a renewable, wood burning receives favourable
treatment. There are questions about the renewability of wood;
there is no question that burning it produces a range of dangerous
chemicals.
5.5 Scottish Power, for instance has appliance targets
for 2008-11 that it will support with its grant system and these
include 30,000 wood pellet boilers. Clearly a significant move
towards wood burning is under way. The apparent assumption that
wood burning is "clean" should be treated with considerable
caution.
5.6 Wood-burning produces a variety of pollutants other
than the release of sequestrated carbon:
— Creosote (carcinogenic and possibly teratogenic).
— Carbon Monoxide (an AQS pollutant, dangerous for
those with existing coronary or lung disease).
— Methane (a potent greenhouse gas and asphyxiant).
— Ozone (an AQS target: an irritant greenhouse gas
reducing lung function and increasing incidence of respiratory
symptoms).
— Methyl Chloride (toxic, mutagenic, carcinogenic,
possibly teratogenic).
— PAHs (an AQS target; carcinogenic—main source
in UK: domestic coal and wood burning).
— Particulates (an AQS target: carrying quantified
large risks to human health and life expectancy).
— Nitrogen Dioxide (an AQS target, harmful to human
health).
— Sulphur Dioxide (causes and aggravates symptoms
particularly in patients with pre-existing asthma. In association
with particles, it raises mortality both in the short and the
longer term; SO2 advances 3,500 deaths/yr. in Gt. Britain and
provokes an additional 3,500 hospital admissions for respiratory
problems.
— Dioxins, powerful carcinogens, exceeded only in
toxicity by radioactive waste, lasting for seven years in the
human body and washed into plants and contaminating our food supply.
Burning 1kg of wood produces 160mcg of total dioxins. Wood burning
is the third largest source of dioxins in the USA.
— Lead—burning 2.2lbs of wood produces 0.1mg-3mg
of lead which we absorb by respiration. Lead is a neurotoxin associated
with lower intelligence and delinquent behaviour.
— Radioactive caesium—a US study found that
fireplace wood ash contained up to 100 times more radioactive
caesium than would be allowed as a discharge from a nuclear plant.
— and wood smoke (carcinogen chemically active in
body 40 times longer than tobacco smoke, estimated to cause 2.7-3m
premature deaths worldwide [WHO, 1997]).
5.7 The American EPA states that "Residential wood
smoke" is "a very important source of particle pollution."
Wood-burning stoves are banned in certain parts of the USA during
times of high air pollution. Currently, the UK is projected to
miss its AQS objectives on emissions of particles and ozone. Does
the supposed renewability of wood outweigh such externalities?
We do not believe that this question has yet been answered. Similarly,
if there is to be a move to wood-burning to generate electricity
has fully-costed consideration been taken of the pollutants other
than CO2 which emerge from the stack, and whether pollution caused
by multiple lorry movements to feed the electricity plant with
its wood stocks been fully factored in?
5.8 HMG should not adopt measures which might worsen
our problems rather than alleviate them. The apparent assumption
that fossil fuel consumption is bad whilst wood-burning is "good"
is worth testing before large-scale shifts in technology are adopted.
Government needs to examine these questions:
— Might wood be better deployed as a continuing
carbon store by use in construction, furniture etc, rather than
by burning it?
— How many saplings need to be planted to replace
the carbon sequestration effect of a growing mature tree?
— If this gives rise to a multiplier effect in the
overall number of trees how long will it be before we run out
of space?
— What is the mechanism to ensure that a removed
quantum of carbon-bearing wood is replaced by an equivalent or
higher quantum of vegetable material able to sequestrate carbon?
— Are we satisfied that planting trees in the Northern
hemisphere will have a net cooling effect when there is considerable
evidence to the contrary (because the forests' dark canopy absorbs
heat)?
— Are we sure that the carbon sequestration effect
of planting trees outweighs the pollution caused by arboreal methane
emissions?
— What proportion of energy generation and domestic
fuel consumption will be based upon wood burning over a planning
period, what will be the impact on production of other pollutants
what will be the associated external costs?
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