Memorandum submitted by Calor Gas Ltd
The UK renewables strategy is over-reliant on
a mass switch to biomass combustion. The air quality damage in
terms of an increase in particulate emissions has been costed
by Government at potentially £557 million as a result of
premature death: in 2020one year aloneup to 1,175,000
life years will be lost. The corresponding impact of increased
morbidity (disease) has not yet been measured by Government. The
combustion of wood in large quantities will lead to rises in the
emissions of most of the other pollutants meant to be addressed
by the Air Quality Strategy, and in other dangerous pollutants
not targeted by the Strategy. The cost of these emissions in terms
of human health and the environment should be known, and thrown
into an ultimate judgement of the viability of the policy.
1. Our submission concentrates on aspects
relating to the air quality problems caused by particulates. Their
impact on mortality, morbidity and the environment are fairly
well understood, quantified and known to be highly significant.
2. There is one significant aspect of the
UK renewables strategy that will make the targets on particulates
harder to reachan aspect of policy which deliberately and
significantly increases the amount of particulate pollution in
the air. The Government's Air Quality Strategy 2007 reads at para
95: "Where practicable and sensible, synergistic policies
beneficial to both air quality and climate change will be pursued".
We describe below how the air quality strategy and the climate
change policy are in conflict.
3. The UK renewables strategy aims at a
big shift to the generation of heat and electricity by biomass:
"We will ramp up the supply and use of biomass for heat,
power and transport..." (The UK Renewable Energy Strategy
2009, p16). The renewable heat targets are to be met, "mainly
through encouraging switching by industrial, commercial and residential
customers located off the gas grid from oil, coal or electrical
heating, to biomass or other renewable technologies" (para.4.1.6
of "The UK Renewable Energy Strategy 2008"). The strategy
contemplates the target of 38TWh of small scale biomass installations.
What does it mean for air quality? And, what does it mean for
human health, given that air quality is correlated with levels
of cardiovascular disease.
4. Some of the problems with biomass are
frankly described in the consultation paper, "The UK Renewable
Energy Strategy 2008":
"4.6.14 The potential cumulative effect
on air quality of fine particles and nitrogen dioxide emissions
from a future large-scale deployment of biomass appliances or
plant is not yet well understood...In rural areas the impact on
air quality, and public health, is likely to be lower, due to
both lower population densities and `background' levels of pollution.
4.6.15 The results from preliminary analysis
undertaken by AEA Energy and Environment on behalf of DEFRA indicates
that if high levels of solid combustible biomass were used in
dense urban areas, where heat demand is highest, the impact on
air quality would be likely to be very significant. Stringent
emission controls on individual plant would mitigate this effect...".
"4.6.17 There is currently no clear
advice about the locations, types and sizes of boilers that would
not cause air quality issues, and there is currently no agreed
European test procedure.
4.6.18 In response to these issues we are
considering possible measures that will allow the deployment of
biomass-fired plant, in both rural and urban areas, at the maximal
sustainable rate that does not compromise our objectives on air
quality or public health...".
"4.6.25 Given that equipment deteriorates
over time and needs to be operated properly, we may need to update
regulations to ensure that installed equipment continues to be
run in a way that meets emissions standards...".
5. In sum, biomass boilers without stringent
controls will cause significant pollution in urban areas. The
resulting pollution is being directed to rural areas because of
lower existing levels of pollution in the countryside. We do not
yet know the effect of particulates and NOx from biomass boilersand,
as the boilers age, they will pollute more.
6. Para 5.17 of the Government's "Biomass
Strategy" (2007) states that, "Substitution of natural
gas with biomass, on the other hand, generally leads to increases
in emissions of all major pollutants". LPG has a similar
emissions profile to natural gas. So, insofar as the renewables
policy and RHIs manipulate a switch from natural gas or LPGas
is the clear intentionincreases in all major pollutants
are to be expected. We know from an AEA study ("Technical
Guidance: Screening Assessment for Biomass Boilers" July
2008) that a typical domestic wood burning boiler of <50kWth
would emit over 15kg of large particulates (PM10) and over 15kg
of small particulates (PM2.5) per year per household. The paper
states: "For modern appliances with well-designed combustion
the particles emitted are all thought to be less than 2.5?".
This is no comfort. As "The Air Quality Strategy" (2007)
states: "Recent reviews by WHO and Committee on the Medical
Effects of Air Pollutants (COMEAP) have suggested exposure to
a finer fraction of particles (PM2.5, which typically make up
around two thirds of PM10 emissions and concentrations) gives
a stronger association with the observed ill-health effects".
These observed ill-effects include congestive heart failure, heart
disease, cerebrovascular problems and asthmatic attacks.
7. On 26 March 2009, in a Written Answer
(col 695/6W) to Graham Stringer MP, the Government quantified
the social (=health costs in terms of increased mortality) costs
caused by emissions from biomass plants under various scenarios.
For an uptake of 52TWh of biomass the social costs were estimated
as £2,803,000,000 and for 38TWh (the Government target) the
comparable costs were £557,000,000these figures were
calculated on the basis of existing technology.
8. Andrew Tyrie MP asked a follow-up question
answered on 10 November (col 219W):
"Mr Tyrie: To ask the Secretary
of State for Energy and Climate Change what recent assessment
he has made of the effects of the use of biomass boilers installed
to meet Renewable Energy Strategy targets on (a) air quality,
(b) levels of particulate emissions and (c) levels of (i) morbidity
and (ii) mortality.
Jim Fitzpatrick: (a) The Government
have, in support of the development of the Renewable Energy Strategy
(RES), carried out modelling of the effect of an increase in the
use of biomass for heat and power on the emissions, ambient air
concentrations and public health impacts of fine particles (PM2.5),
coarser particles (PM) and nitrogen dioxide. The key air quality
results of this analysis are given in the Renewable Energy Strategy
on page 121.
(b) As part of the analysis the increases
in the emissions of particulates were estimated over a number
of different scenarios. For PM2.5 these were between 0.75 and
9.1 ktonnes from a baseline in 2007 of 82 ktonnes. For PM10, emissions
were estimated as being between 1.3 and 9.5 ktonnes from a 2007
baseline of 135 ktonnes.
(c) (i) The impacts on morbidity resulting
from the uptake of biomass as a renewable energy source were not
(ii) The mortality health impacts of these scenarios
were estimated to be between 340,000 and 1,750,000 measured as
the number of life years lost in 2020 from the impact on air quality
of increased biomass combustion".
9. Presumably, then, the social costs of
the increase in particulate emission would be higher than £557m
because this costing does not include morbidity. This could be
significant. The emission of particulates is estimated to advance
8,100 deaths a year (=mortality) in Great Britain and to cause
an additional 10,500 respiratory admissions to hospital (=morbidity)
("Quantification of the Effects of Air Pollution on Health
in the United Kingdom", DoH, 1998).
10. In relation to particulates, then, the
renewables strategy as currently conceived is significantly costly
in terms of damage to air quality and human health. The precautionary
principle would argue for examining whether there may be other
ways of meeting the carbon emission reduction targets other than
with such a heavy reliance on biomassespecially if, as
we would assert, other route maps would be dramatically less costly
(the "Impact Assessment" of UK renewables strategy undertaken
by Government costs the policy at £56 billion even after
taking into account all the climate change benefits).
11. The Government's Air Quality Strategy
covers the following pollutants: particulates, oxides of nitrogen,
ozone, polycyclic aromatic hydrocarbons, ammonia, sulphur dioxide,
benzene, 1,3 butadiene, lead and carbon monoxide. Wood smoke contains
emissions of all these pollutants except, perhaps, ammonia. We
are not aware of any work the Government have undertaken to quantify
the emissions of these pollutants which will be caused by the
full implementation of the biomass strategy. Once again, the precautionary
principle would suggest not proceeding with the policy until we
have assessed the likely impact on human health and the environment.
12. We would strongly urge the Committee
to consult the website www.burningissues.orgit is the website
of the American Clean Air Revival campaign (Calor has no connection
with this organization). This website catalogues, in harrowing
detail, backed up with overwhelming scientific data, the emissions
released by burning wood and the danger they present. The emissions
go far beyond those covered by the Air Quality Strategy, and therefore
presumably will not trigger any prophylactic measures to counteract
them. These include the carcinogens creosote, methyl chloride
and dioxins; and radioactive caesium. We will confine ourselves
to referencing just two points made by this very informative site:
the US study which 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 the WHO estimated in 1997
that wood smoke causes 2.7-3 million premature deaths worldwide.
We suggest that the full human and environmental risks of a mass
move to the large scale combustion of wood should be known before
the harvest of damage in terms of death and disease is established
ten or twenty years hence.
26 November 2009