Memorandum submitted by the Wood Panel
Industries Federation
EXECUTIVE SUMMARY
1. The Wood Panel Industries Federation
believes that Emissions Performance Standards are necessary to
ensure that the forthcoming generation of power plants based on
renewable technologies, in particular biomass, deliver real cuts
in the UK's carbon emissions.
2. The Wood Panel Industries Federation
notes that the direct CO2 emissions from the combustion
of wood chip for electricity production are over six times that
of coal as measured on a kg/MWh basis.
3. The Federation notes that the markedly
lower life-cycle CO2 figures claimed for electricity
produced from biomass are heavily reliant on the replanting of
carbon-absorbing biomass ie trees.
4. It further notes that, in order to absorb
the carbon released from the initial combustion of woody biomass,
replacement trees would need to be left to grow for a number of
decades.
5. Therefore, the Wood Panel Industries
Federation believes that in order to achieve real reductions in
levels of CO2 in the short to medium term, there is
a demonstrable need for Emissions Performance Standards and their
application to large-scale (<50MW) electricity-only power plants.
ABOUT THE
WOOD PANEL
INDUSTRIES FEDERATION
6. The Wood Panel Industries Federation
(WPIF) is headquartered in Grantham, Lincolnshire. It is the representative
organisation giving voice to the industrial manufacturers in the
United Kingdom and Ireland of Wood Chipboard, Oriented Strand
Board (OSB) and Medium Density Fibreboard (MDF).
7. Total gross UK employment attributable
to wood panel manufacture amounts to just under 8,700 full-time
equivalent jobs. Its total economic impact is around £1 billion
per annum.
THE EMISSIONS
PERFORMANCE STANDARD
8. According to the Biomass Energy Centre,
managed by the Forestry Commission, the direct CO2
emissions from combustion of wood chip for electricity in a large-scale
plant are 2100 kg/MWh. The direct CO2 emissions for
the combustion of hard coal are 345 kg/MWh.[22]
9. The Biomass Energy centre does state
that the approximate life-cycle CO2 emissions for large-scale
electricity production utilising biomass are 58 kg/MWh compared
to hard coal's 484 kg/MWh. However, this figure of 58 kg/MWh is
wholly dependent on the replanting of new trees to produce fresh
biomass. Furthermore, these new plantings would require around
30-40 years before they had absorbed the carbon initially released
in the combustion of biomass. Therefore, in the short to medium
term, new large-scale biomass plants will massively increase carbon
emissions.
10. Given this life-cycle, without carbon
capture and storage technology in place, the proposed new generation
of large-scale electricity-only biomass power plants will not
be operating on a carbon neutral basis by 2030—the point
at which the Committee on Climate Change says that the UK will
need to have decarbonised its power sector.
11. Whilst the WPIF accept the conclusions
of the Biomass Energy Centre that burning biomass is nearly carbon
neutral over the life-cycle compared to fossil fuels, it
is still the case that, compared to wood panelboard production,
electricity produced from the burning of biomass is a significant
source of carbon dioxide.
12. The comparison of carbon emissions between
electricity from biomass and panelboard manufacture is vital because
of the combination of an extremely tight supply of domestic wood
and the distortion of the wood market caused by the Renewables
Obligation. The UK wood panel sector is entirely reliant on domestic
sources of wood (virgin and recycled fibre). The Renewables Obligation
gives biomass energy companies much greater purchasing power in
a market experiencing supply problems. Therefore, if the current
subsidy regime remains, there is a distinct chance of displacement
of both the wood panel industry and the important contribution
it makes to both carbon sequestration (in wood products) and renewable
heat (it is the largest industrial sector generator in the UK).
13. The enclosed report by CarbonRiver shows
that, if the wood panel industry were displaced by the renewable
biomass energy industry, the UK would see a net increase in its
carbon dioxide emissions of six million tonnes per annum. This
is equivalent to a 1% increase in the UK's carbon dioxide emissions.
14. Given the much greater carbon emissions
arising from the combustion of biomass in the short to medium
term, an EPS is essential for meeting the emissions targets set
to take place under the EU ETS. Without Emissions Performance
Standards, the continued development of large-scale electricity-only
biomass plants will result in vastly increased levels of carbon
dioxide being produced in the UK.
15. At present, large-scale electricity-only
biomass power producers can merely promise to invest in replanting
forestry or defer their obligation to account for their carbon
emissions by relying on forestry companies to manage a sustainable
supply of feedstock. In effect, there is no guarantee that carbon
neutrality will be achieved, even in the long term.
16. Large-scale growth of biomass usage
for electricity production will not only be detrimental to the
wood processing industries, including the sawmills. It will likely
start to put greater pressure on land presently used for farming
food crops, both in the UK and abroad.
17. The UK needs to make reductions in its
carbon emissions in the short to medium term. The large-scale
production of electricity from biomass will, in this timeframe
(10-20 years), lead to a significant rise in carbon emissions.
SUGGESTED ACTIONS
18. The Wood Panel Industries Federation
urges the Committee to recommend that Government make provision
for legislating for Emissions Performance Standards.
19. It urges the Committee to ask that Emissions
Performance Standards apply to all power generators regardless
of feedstock.
20. It further requests that that the Committee
work with colleagues both at home and abroad to push for a harmonized
Emissions Performance Standard throughout the European Union.
September 2010
22 http://www.biomassenergycentre.org.uk/portal/page?_pageid=75,163182&_dad=portal&_schema=PORTAL Back
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