Emissions Performance Standards

Memorandum submitted by the Wood Panel Industries Federation (EPS 11)

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 6 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 i.e. 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/MWh1.

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 6 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

[1] http://www.biomassenergycentre.org.uk/portal/page?_pageid=75,163182&_dad=portal&_schema=PORTAL