Energy and Climate Change CommitteeWritten evidence submitted by Calor Gas Ltd (BIO02)

Executive Summary

1. Burning biomass emits more greenhouse gases than burning fossil fuels: repaying the consequent carbon debt depends upon a meticulous choice of feedstocks and harvesting methods. Without effective application and policing of the supply chain, biomass risks being dirtier than coal and actually adding to net carbon in the atmosphere.

2. Approximately 80% of biomass demand in the UK is likely to be supplied by imports. Current policy worsens the trade imbalance and increases our reliance on third parties.

3. Emissions from biomass production have been discounted but they are significant. Drying biomass prior to use also has high negative environmental impacts. Government acknowledges that the transport of biomass has negative effects in the short, medium and long term.

4. Emissions of black carbon from the combustion of biomass and isoprene from its production risk significant damage to the atmosphere unless they are measured and controlled.

5. The damage to human health and life expectancy from larger fraction particulates emitted during the combustion of biomass will be reduced to an estimated cost of £1,399 million by the use of stricter filters, but the damage from finer particulates has not been quantified, and could, if anything, be greater.

6. The taxpayer is paying £45 per MWh of subsidy for the power generated by biomass. One power station alone—Drax—is likely to be costing us £550 million in subsidy a year by 2016.

7. Current sustainability standards suffer from weak supervision and enforcement; the use of waste wood in biomass combustion is far preferable to the use of tree trunks, but the official definition of waste wood is sadly capable of exploitation.

Introduction

1. Calor Gas Ltd is part of a global group of LPG companies owned by the Dutch company SHV Gas. SHV is an investor in biomass. Biomass has a legitimate role as a fuel as we move towards a decarbonised future, but that role must be guided by science and be in the context of achieving genuine carbon emission reductions through its use.

Are Genuine Carbon Reductions Being Achieved?

Biomass has been picked as a winner but its environmental impacts are not yet settled

2.1 In 2010, a Manomet report for the Commonwealth of Massachusetts¹ acknowledged, “Growing concerns about greenhouse gas impacts of forest biomass policies” and quoted the IEA report “Bioenergy (2009): “Conversion of land with large carbon stocks in soils and vegetation can completely negate the climate benefit of the sink/bioenergy establishment”. The UK Environment Agency is alert to this danger: using biomass for generating electricity and heat could help meet the UK’s renewable targets but “only if good practice is followed…worst practice can result in more greenhouse gas emissions overall than using gas”². Anna Repo of the Finnish Environment Institute concluded in a report to the European Parliament that, “Increasing biomass removals from forests reduces forest carbon stocks and their carbon sink capacity”.³

Biomass emits more GHGs than fossil fuels; its carbon debt is unlikely to be repaid

2.2 Manomet discussses the varying rates by which regrowing forests repay the carbon debt incurred by their removal and combustion: burning biomass emits more greenhouse gases than fossil fuels: “Forest biomass generally emits more greenhouse gases than fossil fuels per unit of energy produced. We define these excess emissions as the biomass carbon debt. Over time, however, re-growth of the harvested forest removes this carbon from the atmosphere, reducing the carbon debt.” In relation to electricity generation the ratios of the emission of carbon dioxide per BTU of heat generated are 863 for biomass: 642 for coal: 355 for natural gas. In relation to thermal heat generation, the ratios are 360 for biomass: 217 for heating oil: 138 for natural gas. Depending on what form of electricity generation it displaces biomass repays its carbon debt over a number of years: if it is displacing electricity generated by natural gas this repayment period may be up to 90 years. The report concludes: “So, over a long period of time, biomass harvests have an opportunity to recover a large portion of the carbon volume removed during the harvest. However, this assumes no future harvests in the stand as well as an absence of any significant disturbance event. Both are unlikely.” Recovering the carbon debt is a gamble, and it seems strange to be cracking open these cheap and natural stores of carbon while at the same time investing billions of pounds in trying to create as yet unproven carbon capture and storage technologies.

If low carbon alternatives exist or are viable within 20 years they should be preferred

2.3 Since the drive to biomass significantly increases the level of GHGs in the atmosphere potentially for decades, any environmental benefit from biomass is significantly in the future and uncertain; the report concludes that if low carbon technologies other than biomass can reliably come available within twenty years they may represent a better play: “If policymakers believe it will take a substantial amount of time to develop and broadly apply low or no carbon sources of energy, they may be more inclined to promote the development of biomass. Conversely, if they think that no or low carbon alternatives will be available relatively soon, say in a matter of one or two decades, they may be less inclined to promote development of biomass, especially for applications where carbon debts are relatively higher and where longer payoff times reduce future carbon dividends.”

Biomass forestry standards are commonly sub-optimal especially in the context of biomass imports becoming dominant and increasing our reliance on third parties

2.4 We welcome any move to develop and enforce robust sustainability standards for biomass. The Manomet report pinpoints certain of harvesting that can damage forest health and biodiversity. The report finds many state-imposed forestry Best Management Practices (BMPs) wanting: “Many biomass harvests use a two-pass system in which one piece of equipment cuts trees and stacks them and another piece eventually picks them up for transportation to the landing. Repeated equipment passes can cause greater degrees of soil compaction, resulting in increased soil strength, which can (1) slow root penetration and reduce the regeneration and tree growth (Greacen and Sands, 1980; Miller et al., 1996); and (2) reduce soil infiltration rates, thereby increasing the potential for erosion through changes in landscape hydrology…The ability to assure the public that sustainable forestry is being practiced is often confounded by vagueness and generalities in forestry BMPs or guidelines…Current regulations and BMPs, however, do not direct silvicultural or harvesting activities to sustain all the ecological values that might be negatively affected by increased biomass harvesting…Our literature review reveals these activities have the potential to degrade wildlife habitat, biodiversity, and soil nutrient levels. In addition, the current cutting plan process does not require sound silvicultural practice and the ecological safeguards that these proven practices offer in comparison to undisciplined harvesting…In most situations, however, there are no regulatory or voluntary guidelines in place that compel compliance.”

2.5. The report thus shows how even in the well-meaning Commonwealth of Massachusetts BMPs fall short of the ideal, are a work in progress, and are yet to be subject to a compliance regime. How much the UK’s BMPs are in advance or lag behind those being developed in Massachusetts we do not have the expertise to analyse, but we suggest strongly that the UK Government undertakes a compare and contrast analysis. There is an additional reason for concern about BMPs and their enforceability in Massachusetts—because we are probably sourcing much of our feedstock there: as the report indicates, “In Britain, two 300 MW biomass power plants are currently in the planning stages. These plants are projected to consume six million green tons of wood chips annually, purchased from around the globe, with New England identified as a possible source of woodchips”.

2.6. A report supported by the DG Development and DG Environment of the European Commission concluded in 2011: “Analysis of the data and trade statistics looked at in this report shows that the quantity of wood required to satisfy the 2020 targets is likely to be too large to be met by increased production within the EU…Most of the increase in imports will therefore most likely come from Canada, the USA, and perhaps also Russia (if the risks associated with imports from Russia do not become prohibitive when the EU’s Illegal Timber Regulation is fully implemented in 2013). This risks not only damaging ecosystems in other parts of the world, but will also increase the EU’s own carbon footprint”.⁴

2.7. DECC admits that, “The UK is expected to be increasingly reliant on biomass imports in the future”—this for a commodity that was once vaunted as decreasing our reliance on third parties. Unfortunately, HMG does not know how much wood is being imported for biomass combustion.⁵ We do know, however, that imports are increasing very fast: imports of wood pellets into the EU rose by 50% in 2010 alone⁶ and that DECC itself expects that approximately 80% of feedstock to come from imports. The RSPB, Friends of the Earth and Greenpeace conclude: “Demand for wood, for electricity generation, will therefore add to the existing trade imbalance”.⁷

Carbon debt from biomass needs to be measured under robust carbon stock methodology: biomass has been touted by HMG as a zero-carbon technology when it is anything but

2.8 Searchinger makes the point that the climate change impact of preserving a forest is not the same as burning the same forest: “Take an acre of forest. You cut it down, you burn it. You lose all the carbon that is stored in the trunks. You also lose the carbon in the roots. You lose on the order of 25% of the carbon in the soil is also lost to the atmosphere,”.⁸ Atlantic Consulting makes a distinction between good and bad biomass: “Most carbon footprints assume carbon neutrality of wood or other biomass used as fuel, ie biogenic CO₂ is assigned a GWP of zero. In recent years, however, this method has come into question. First came the issue of land-use change, which is no longer accepted as automatically carbon neutral. Losses of carbon stock due to land-use change (for instance, deforestation to create cropland) should now be included in most footprints. More recently, researchers such as Rabl (2007), Johnson (2009) and Searchinger et al (2009) have proposed that carbon-stock changes in general should be tracked in biofuels accounting. As Searchinger et al (2009) put it: “Under any crediting system, credits must reflect net changes in carbon stocks, emissions of non-CO2 greenhouse gases, and leakage emissions resulting from changes in land-use activities to replace crops of timber diverted to bioenergy”.⁹ The UK should apply detailed carbon stock methodology to its sustainability criteria.

2.9. The EEA Scientific Committee on Greenhouse Gas Accounting states that the assumption that burning biomass is carbon neutral is incorrect: “Using land to produce plants for energy typically means that this land is not producing plants for other purposes, including carbon otherwise sequestered.” if biomass production replaces forests, reduces forest stocks or forest growth, which would otherwise sequester more carbon, it can increase carbon concentrations net. If biomass displaces food crops—as biofuels did—this leads to hunger if crops are not replaced, and to emissions from land use change if they are. To reduce carbon in the air, the Committee concludes, bioenergy production must increase the net total of plant growth, or it must be derived from biomass wastes that would otherwise decompose. The Committee warns that the danger of this error is “immense”. It states, “Current harvests…have already caused enormous loss of habitat by affecting perhaps 75% of the world’s ice and desert free land, depleting water supplies and releasing large amounts of carbon into the air”.¹⁰

2.10. The RSPB, Friends of the Earth and Greenpeace comment that DECC’s flawed emission accounting on biomass has led to a situation where, “Burning whole trees in power stations would make global warming worse, undermining goals of reducing our greenhouse gases by 2050”⁷. On that basis they call for the withdrawal of public subsidies for generating electricity from feedstocks derived from tree trunks and to refocus support for bioenergy on the use of wastes and other feedstocks that are harvested sustainably. We agree.

2.11. Ed Davey, Secretary of State for Energy and Climate Change admitted: “We’ve made a real mistake in the EU [on biofuels] and we’ve got to end that mistake, the sooner the better.¹¹ We wonder whether bad biomass will follow biofuels in their walk of shame.

Is sufficient attention being given to potential impacts in other areas?

Biomass emissions have been underestimated, not least because of the drying process

3.1. The “UK Biomass Strategy” (2007, p.41) made a blasé and dangerous—assumption: “For all biomass resources no net emissions during production assumed”. All the emissions produced during planting, harvesting, sawing up, drying and delivery of these bulky and heavy items are ignored. E4Tech’s study on biomass prices for DECC¹² makes the assumption that for the wood pellet imports there would be 50km of road transport necessary for production purposes, 200km of road transport necessary in the country of origin, sea transport of 1500km and 50km of road transport necessary in the UK. This cannot be written off as equating to “no net emissions”. The Environment Agency pointed out2: “How a fuel is produced has a major impact on emissions: transporting fuels over long distances and excessive use of nitrogen fertilisers can reduce the emissions savings made by the same fuel by between 15 and 50% compared to best practice”.

3.2. Besides, and probably more importantly, biomass has to be dried before combustion can take place. Passive drying can take place but it takes much longer and still leaves 25–30% water content. Pellet mills generally require moisture contents of less than 15% to produce stable and durable pellets. Environmental emissions result from both the drying process and combustion in the boiler. These emissions typically include particulates, VOCs, and NOx to the extent that a common problem around biomass drying plant is so called noxious “blue haze”. “Biomass and Bioenergy“¹³ confirms that, “Forest residues require a drying stage, which involves high energy consumption and high environmental impact.” These environmental load caused by these emissions should be calculated and factored into policy.

3.3. The revised Draft NPS for Renewable Energy documents (December 2011) also revealed the damage to the environment likely from “considerable” transport movements: “Depending on the location of the facilities, air emissions and dust, which could impact sensitive flora, may also be increased through the high number of heavy goods vehicles transporting fuel and combustion residues” (p25). “There are potential negative environmental effects, including on climate change and air quality, of increased transportation throughout the lifetime of the facility…The overall effect of implementation on traffic and transport of biomass/waste combustion through the implementation of EN-3 is considered to be negative in the short, medium and long term. These effects are primarily from the movement of fuel and residue during the operational phase of the facility, although some significant, short term, local negative effects may result from the movement of component parts to the facility during construction” (p.39/40). The Revised Draft National Policy Statement for Renewable Energy Infrastructure (EN-3) now admits some of this environmental damage: “Biomass or EfW plants are likely to generate considerable transport movements. For example, a biomass or EfW plant that uses 500,000 tonnes of fuel per annum might require a minimum of 200 heavy goods vehicles (HGVs) movements per day to import the fuel. There will also be residues which will need to be regularly transported off site” (para.2.5.22).

We should measure and control emissions of black carbon and isoprene from biomass before we deem it sustainable

3.4. We need to adopt a precautionary principle in relation to the emissions of black carbon (BC) from biomass. BC is part of the particulate emissions caused by combustion. BC is the second largest contributor to global warming after CO₂. The UN’s Economic Commission for Europe found that, “Urgent action to decrease (black carbon) concentrations in the atmosphere would provide opportunities, not only for significant air pollution benefits (eg health and crop-yield benefits), but also for rapid climate benefits, by helping to slow global warming and avoid crossing critical temperature and environmental thresholds”.¹⁴ The possibility that biomass could potentially contribute significantly to global warming by emissions of BC would be perverse indeed.

3.5. The Government does not know how much black carbon is emitted, or potentially emitted specifically by burning biomass in the UK, nor has it assessed how international control measures in the pipeline on black carbon might undermine the principle of subsidizing biomass combustion.¹⁵ It should remedy these black holes of knowledge.

3.6. Attention is now also turning to the threat from biomass from poplar, willow or eucalyptus trees, used as fast-growing sources of renewable wood fuel, which emit high levels of the chemical isoprene as they grow. This creates ozone—and a recent estimate is that ozone from wood-based energy to meet the EU 2020 goal would cause nearly 1,400 premature deaths a year, costing society $7.1 billion, and a reduction in wheat and maize production costing a further $1.5 billion.¹⁶

Biomass combustion leads to early death and illness on a significant scale

3.7. Biomass combustion can kill people. The particulates it emits damage human health by attacking lungs, hearts and brains. The latest Public Health Observatory data puts the percentage of total mortality attributable to particulates in England at 5.6%. What part of that can be attributed to biomass? We can work out the damage in terms of lives shortened and lost from an Impact Assessment published by DECC on new standards designed to cut down on the current level of mortality from biomass combustion. The quantum of mortality caused by biomass boilers currently being sold can be calculated from the assessment at £4,343 million. The new limits will, if implemented, cut this reduction in life years to an equivalent of £1,399 million. However, the new limits apply only to the larger particulates, and evidence is growing that the smaller particulates are more harmful than the large. No sum of the mortality caused by smaller particulates from biomass has been given. One must assume nonetheless that the impact from these smaller particulates in reducing human life-spans will be considerable.

3.8. The Committee on the Medical Effects of Air Pollution estimated that the 2008 burden level of particulates cost an “associated loss of total population life of 340,000 life-years…a greater burden than the mortality impacts of environmental tobacco smoke or road traffic accidents”.¹⁷ Remarkably, this figure is exactly the level of extra burden of mortality to have been inflicted on the UK atmosphere by 2020 under the previous Government’s policy on biomass, with its target of 38TWh by that date. No wonder Government has resiled from a specific target. The last Labour Government, to be fair, was aware biomass boilers deteriorate as they age so proposed an annual MOT test on domestic biomass boilers—all mention of such an annual MOT test on boilers has since been dropped.

3.9. A rising output of particulates from biomass will add to our problem in complying with the EU air quality limits. Current UK emissions of particulates are acknowledged by the Government to be “relatively high” and could cause rack up fines for the UK’s infringements. The Government calculates that over 3,500t of larger particulates will be emitted to air in 2020 from biomass—a self-inflicted injury subsidised by the taxpayer, because without deliberate policy cherry picking of this technology and without significant subsidy mass generation of electricity from biomass would not be viable. At a subsidy of £45 per MWh, it has been calculated that Drax, just one power station in the UK will be getting a subsidy of £550 million a year by 2016 from the taxpayer. At that rate, it costs £225 to save one tonne of CO2 by switching from gas to wood6.

3.10. Biomass combustion also releases a wide variety of other pollutants into the air that we breathe. We know from recent PQs¹⁸ that non domestic burning of biomass emitted in 2010 160t of chromium, 130t of arsenic, and 16t of hexavalent chromium. Arsenic is poison: chromium and hexavalent chromium are carcinogenic (the latter being of Erin Brockovich fame). Bear in mind that these figures will rise as more biomass capacity comes on stream, and the related morbidity and mortality toll will rise. We suspect that a location near a biomass plant will reduce the value of the housing concerned.

To what extent is it possible to assess the sustainability of imported biomass?

4.1. The “Report from the Commission to the Council and the European Parliament on sustainability requirements for the use of solid and gaseous biomass sources in electricity, heating and cooling” (2010) admits particularly in relation to certain countries outside the EU: “At a global level, deforestation and forest degradation continue...Among the root causes for deforestation and forest degradation are weak governance structures for forest conservation and sustainable management of forest resources, in particular in developing countries. A large number of countries are party to intergovernmental initiatives to put in place criteria and indicators to monitor sustainable forest management, but they are not entirely based on common principles and criteria and do not have a mechanism for verifying compliance with the agreed principles.” Manomet also appears to regret the lack of legal foundation to compel compliance on a variety of management criteria in the USA (p.69).

4.2. This is not a matter to be ignored in the UK—we are already complicit in the illegal logging trade to a significant degree. The World Wildlife Fund stated on 17 September 2010: “The UK is the fourth largest importer of illegally harvested or traded timber and wood products in the world.” The Government’s policy is to deploy substantial subsidies to encourage the domestic and industrial take-up of biomass. Where there are significant subsidies the temptation to cheat increases proportionately.

4.3. We are not satisfied that sustainability criteria are sufficiently demanding. Wastes and residues are not subject to sustainability criteria. In theory, giving waste a free pass appears appealing, but what is “waste” and what are “residues”? The OFGEM guidance is remarkably vague and clearly capable of being exploited: “It is not possible to lay down definitive or absolute rules as to when particular materials will be considered as waste materials or not”.¹⁹ We fear that this complexity of definition could provide the unscrupulous with a loophole to exploit.

4.4. OFGEM effectively points to the weakness of the process of operators verifying the information they supply on sustainability: “Under the Orders, operators of generating stations for solid and gaseous biomass are not required to verify the information they provide to us in order to be eligible for ROCs”.²⁰ Reporting of sustainability criteria appears to rely too much on the honesty box principle, particularly in the context of “weak governance structures” at a global level.

References

1. “Biomass Sustainability and Carbon Policy” by The Manomet Centre for Conservation Sciences, (June 2010).

2. “Biomass—carbon sink or carbon sinner?” April 2009.

3. “Forest Bioenergy and Carbon Sequestration” 30 January 2013.

4. “Flows of biomass to and from the EU” (July 2011).

5. “Information collated by HM Revenue and Customs as part of its statistics on overseas trade do not indicate the final use for imported wood” Gregory Barker MP, WA, 1.12.2010, col.801W.

6. The Economist 6 April, 2013.

6. “Dirtier than Coal?” by RSPB, Friends of the Earth and Greenpeace 12 November 2012.

8. Daily Princetonian, 6 February, 2009.

9. “Black Carbon and Global Warming; Impacts of Common Fuels”, Atlantic Consulting, 2009.

10. “Opinion of the EEA Scientific Committee on Greenhouse Gas accounting in Relation to Bioenergy, 15 September, 2011.”

11. EuropeanVoice.com on 21^st March 2013

12. “Prices in the heat and electricity sectors in the UK” a report by E4 for DECC, January 1910.

13. “Volume 34, Issue 10, October 2010, pp. 1457–1465

14. UNECE’s Executive Body for the Convention on long-range transboundary air pollution, meeting in Geneva, 15–18 December 2008: Item 13 of provisional agenda.

15. The Minister of State for Agriculture and Food, Jim Paice MP : “The forthcoming revision of the United Nations Economic Commission for Europe Gothenburg Protocol provides an opportunity to highlight the importance of reducing black carbon as a component of particulate matter (PM) for both health and climate reasons. …To date, no assessment has been made of the likely effect of a revised protocol on the combustion of biomass in the UK” (Written Answer, 4 May 2011: Column 782W).

16. Nature Climate Change, Impacts of Biofuel Cultivation on Mortality and Crop Yields, 6.1.2103.

17. “The Mortality Effects of Long-Term Exposure to Particulate Air Pollution in the United Kingdom” (December 21st 2010).

18. WA, 23 May 2012.

19. Para. 2.44, Renewables Obligation: Sustainability Criteria for Solid and Gaseous Biomass for Generators.

20. Para. 2.19 ibid.

April 2013