Energy and Climate Change CommitteeWritten evidence submitted by Friends of the Earth (BIO10)

Introduction

Friends of the Earth believes bio-energy has a role to play in bringing down greenhouse gas emissions, but only if it is done in a way that protects wildlife, people’s livelihoods and guarantees real cuts in net greenhouse gas emissions. The overall scale of the use of biomass in the UK should be kept to a sustainable level and must not exceed domestically available sustainable biomass resources.

The limited amount of domestically available sustainable biomass must be used in the most efficient way: ie in heat and combined heat and power, and should not be used in electricity-only generating installations.

Note

The Energy and Climate Change Committee’s call for evidence refers to both transport biofuels (mostly liquid fuels made from crops) and biomass used for heat and energy (mostly woody biomass). While there is some overlap in the sustainability issues of both, there are also distinct differences. Additionally the policies driving demand for both are separate pieces of legislation.

Therefore they are addressed separately in the following, with sections on “biofuels” referring to liquid transport biofuels (mostly made from crops) and “biomass” referring to woody biomass used for heat and energy.

What contribution can biomass make towards the UK’s decarbonisation and renewable energy targets? Are the Government’s expectations reasonable in this regard?

As detailed under the next question research has shown that huge differences exist in the real life cycle carbon impacts of different forms of bioenergy and that many forms of biomass and biofuels fail to achieve GHG savings compared to fossil fuel. In fact some result in worse emissions than fossil fuels.

However, due to erroneous accounting (lack of accounting of carbon debt and emissions from indirect land use change) Government still has high expectations regarding the decarbonisation potential of biofuels and biomass. In reality the potential is much smaller and requires strong policy guidance to be realised.

For woody biomass the pathways that deliver genuine and significant carbon reductions are limited to the use of forestry residues and energy crops grown on previously abandoned land. The domestic availability of both is strictly limited—an analysis by AEA expects UK supply of both forestry residues and energy crops to be less than 3 TWh by 20201—while the Government expects biomass deployment for primary energy to be 200 TWh in 2020.2

In regards to imports it would be unrealistic to expect that 10% of all global traded volumes of biomass will be available to the UK in 2020 (as assumed in the UK’s bioenergy strategy3) as other countries, not least in Europe are also increasingly relying on bioenergy to meet their renewable energy targets.

For the transport sector currently only biofuels made from used cooking oil (UCO) can deliver genuine and significant carbon savings on a significant scale without impacting on global food prices and food security. Again domestic availability of UCO is limited. The British Association for Biofuels and Oils estimates the volume of waste cooking oil in the UK at 100,000 tonnes a year. Barely enough to replace 1% of transport fuels.

While currently the amount of biofuel from UCO used under the Renewable Transport Fuels Obligation (RTFO) is high (45% of biofuels in the 20112012 reporting data) the vast majority of this has been imported (81%). Once other countries will have started to utilise this limited feedstock of sustainable biofuel for themselves it will no longer be available to the UK.

While there is a large potential for scaling up other areas of bioenergy eg from waste and landfill gas, the expectations for woody biomass for power and liquid transport biofuels to contribute to the UK’s decarbonisation are vastly overestimated and even their limited potential will only be realised if strong policy guidance is introduced that limits support to sustainable forms of bioenergy that deliver genuine carbon savings.

How well have the Government’s bioenergy principles (set out in the 2012 Bioenergy Strategy) been translated into policy?

Are genuine carbon reductions being achieved?

Biomass

This is the key issue as the primary justification for state support for bioenergy is its contribution to reduce climate changing emissions. The combustion of biomass is currently accounted as carbon neutral based on the assumption that combusted plant material will be replaced by new growth that will re-assimilate carbon from the atmosphere.

However recent science has refuted the idea of biomass combustion as carbon neutral and has instead painted a more complex picture.

The European Commission’s Joint Research Centre concluded in its recent report Carbon Accounting of Forest Bioenergy:

“The assumption of “carbon neutrality” is not valid since harvest of wood for bioenergy causes a decrease of the forest carbon stock, which may not be recovered in short time, leading to a temporary increase in atmospheric CO2 and, hence, increased radiative forcing and global warming. At the local scale or stand level, the additional harvest of wood for bioenergy creates a temporary decrease of the carbon stock, compared to what would otherwise happen without harvesting. However, at the landscape or national level the mosaic of stands where forest biomass is removed for bioenergy has to be considered, and the continuous rate of wood removals could translate into a permanent decrease of carbon stock”4

In effect, what actually happens is that wood is harvested and burnt, emitting CO2 into the atmosphere and creating a “carbon debt”. This debt may be repaid by sequestration from regrowth and from growth in the wider forest, but depending on the sequestration rate it may take many years for the end of pipe emissions to be neutralised. In a review of the evidence in 2011, the European Environment Agency concluded that:

“Producing energy from biomass is meant to reduce GHG emissions. But burning biomass increases the amount of carbon in the air if harvesting the biomass decreases the amount of carbon stored in plants and soils, or reduces ongoing carbon sequestration [...] legislation that encourages substitution of fossil fuels by bioenergy, irrespective of the biomass source, may even result in increased carbon emissions”.

A rapidly growing body of academic evidence has examined the impatcs of carbon debt.

Hudiburg et al.’s (2011) study of 80 forest types on the US West Coast showed “that fire prevention measures and large-scale bioenergy harvest in US West Coast forests lead to 2–14% higher emissions compared with current management practices over the next 20 years”.

Bernier & Paré (2013) model the net CO2 emissions from harvesting a Canadian boreal forest for bioenergy and calculate that they are neutralised by regrowth only after ninety years.

McKechnie et al. (2011) performed an integrated life-cycle and forest carbon analysis for wood harvested from a Canadian forest. They conclude “electricity generation from pellets reduces overall emissions relative to coal, although forest carbon losses delay net GHG mitigation by 16−38 years, depending on biomass source (harvest residues/standing trees).”

A list of further academic evidence of carbon debt is attached as ANNEX 1

In addition, DECC have recently released a prototype greenhouse gas calculator for biomass electricity that estimates the net emissions as a result of the CO2 that is released on combustion and the sequestration in the forest over a 20 year time period. The calculator also estimates the impact on emissions if wood is used by the energy industry instead of others, such as in construction. The emissions for scenarios that involve the intensification of forest management, ie increasing harvest rates, or diverting wood away from other industries mostly result in emissions that are significantly higher than fossil fuels. Only the scenarios based on using residues that would otherwise be unused and energy crops such as willow offer significant emission reductions.

Several scenarios in the DECC research result in GHG emissions significantly higher than coal.

A summary of emissions for a number of scenarios is shown in the graph on the following page in Graph 1.

In the current version of biomass sustainability criteria for the Renewable Obligation (RO) that are due to be published by DECC in late April/early May 2013 the results of this research are ignored and biomass combustion continues to be assumed to be carbon neutral (while only emissions for the transport and processing of biomass are being accounted for). As of April 2013 DECC had no plans to include its biomass carbon calculator in the forthcoming RO sustainability criteria for biomass.5

Graph 1

PRELIMINARY LIFECYCLE GREENHOUSE GAS EMISSIONS FOR SET SCENARIOS FOR BIOMASS POWER GENERATION FROM THE DECC PROTOTYPE BEAC MODEL (BIOMASS EMISSIONS AND COUNTERFACTUAL MODEL)

Government are proposing that biomass electricity generators must meet two standards in order to receive public subsidy, but unfortunately neither addresses the major sources of emissions from wood harvested from forests and used for energy—the net reduction in the carbon sink as a result of wood removal and combustion minus any sequestration, and indirect emissions as a result of using wood that would otherwise have been used in other industries.

The first requirement is for generators to use a carbon calculator administered by Ofgem to demonstrate a lifecycle emission reduction of 60% compared to the average grid must be achieved (=285gCO2/kWh). The calculator estimates emissions from harvesting, transporting and processing wood but it counts the emissions that are released on combustion of the wood as zero rather than calculating the actual change in carbon stock. Furthermore, the calculator assumes that any wood used for energy had no alternative use and that there are thus no indirect emissions. DECC’s new “Biomass Emissions and Counterfactual Model” (BEAC) accounts for both of these sources of emissions and demonstrates the huge significance of ignoring them.

The second requirement is for generators to ensure that any wood used should meet the Government procurement sustainability standards. This includes ensuring traceability as well as, ideally, accreditation under a sustainability certification scheme. Whilst these schemes can be useful in their own right they have little to do with carbon emissions from biomass electricity as they do not affect either of the major emission sources—carbon debt or indirect emissions.

Therefore the RO sustainability criteria will be unable to distinguish those biomass pathways that result in real carbon savings compared to fossil fuels and those that lead to higher emissions than coal.

Friends of the Earth strongly advices that publication of the RO sustainability criteria for biomass is delayed until real carbon accounting in line with DECC own research has been included.

Biofuel

For liquid biofuels made from crops the key issue in determining the overall carbon balance in indirect land use change (ILUC).

The production of biofuels can indirectly cause additional deforestation and land conversion, including of fragile ecosystems. When existing agricultural land is turned over to biofuel production, agriculture has to expand elsewhere to meet the previous and ever-growing demand for crops for food and feed—often at the expense of forests, grasslands, peat lands, wetlands, and other carbon rich ecosystems.

This results in substantial increases in GHG emissions from the soil and removed vegetation.

The government commissioned Gallagher review of biofuels concluded that “Current policies, if left unchecked, will reduce biodiversity and may even cause greenhouse gas emissions rather than savings.”

A study by the Institute for European Environmental Policy (IEEP) that quantified the ILUC effects based on the data published in member states National Renewable Energy Action Plans (NREAPs) found that the EU 10% biofuel target could result in up to 56 million tonnes of additional CO2 per year: the equivalent of adding an extra 26 million cars on Europe’s roads by 2020.6

Currently GHG emissions from ILUC are ignored in the carbon accounting mechanism under the EU’s Renewable Energy Directive as well as in the UK’s RTFO. A legislative proposal aimed at reforming biofuel policy published by the EU commission in late 2012 lacked a proposal for mandatory ILUC accounting.

Friends of the Earth strongly advices that UE and UK legislation needs to incorporate ILUC factors to account for ILUC emissions of different biofuel pathways.

Is bioenergy making a cost effective contribution to carbon emission objectives?

Biomass

As currently the RO sustainability criteria for biomass contain no mechanisms to distinguish between high and low carbon biomass pathways there is a danger that public support for bioenergy offered under the RO worth several hundred million pounds could end up supporting biomass pathways that result in higher emissions than coal.

In the absence of a comprehensive carbon accounting mechanism in the RO, bioenergy could end up making a highly cost-ineffective (if any at all) contribution to carbon emission objectives.

Biofuel

A recent Chatham House report calculated the carbon abatement cost of bioethanol from wheat to be $8500 (approx. £5560) per tonne of CO2 if Indirect Land Use Change is being accounted for, while biodiesel made from crops fails to result in any emission savings.7

Is support for bioenergy maximising the overall benefit to the economy?

As laid out above support for biomass can be a highly cost-ineffective (if any at all) contribution to carbon emission objectives.

Instead this money would be far more effectively used to support renewable energy sources delivering proven and substantial climate benefits.

Additionally subsidies for the burning of wood in power stations distort the market and divert wood away from other industries: Current plans to subsidise biomass electricity could see the sector consuming the equivalent of six times the UK’s annual forestry harvest by 2017.

This increased pressure on a scarce and valuable natural resource could threaten the survival of existing industries—in wood, wood panels, packaging, construction, furniture and paper.

Over 40,000 jobs rely on these industries and many of these could be at risk as a result for support for biomass electricity. 8,400 people rely on jobs in the wood panel industry.8 The sawmilling industry, which supports a further 12,000 jobs, could be jeopardised.9 In addition the paper industry in the UK represents at least 25,000 direct employees and, it is estimated, up to 100,000 indirect employees.10

Is sufficient attention being given to potential impacts in other areas, such as food security and biodiversity?

On Biofuels

After 30 years of fairly low and stable prices, we have seen three major spikes in international agricultural commodity prices since 2008.

A key driver of those price increases is the global demand for biofuels.11 More demand for the same supply of crops inevitably leads to higher prices. Recent modelling of the impact of the EU’s mandates on food prices suggests that, by 2020, EU biofuel mandates could be responsible for increases in oilseed prices of up to 20% and increases in vegetable oil prices of as much as 36%, and could push up maize prices by as much as 22%, sugar prices by as much as 21% and wheat prices by as much as 13%.12

Demand for food is inelastic, ie it changes very little in response to availability or price. People need to eat more or less the same amount of food even when harvests are poor or lost. If everyone is trying to buy the food they need, but there is not enough to go around, prices go up. People tend to buy less in response to high prices, but biofuel mandates need to be filled no matter how high prices go. By introducing an inelastic source of demand into the market, biofuel mandates take any slack out of the market and fuel food price spikes, leading to hunger and malnutrition.13

In 2011 the 10 biggest intergovernmental organisation including the World Bank, FAO, OECD and IMF mandated by the G20 to produce recommendations on food price volatility concluded that G20 governments, amongst which are the main biofuels producers and consumers, should “remove provisions of current national policies that subsidize (or mandate) biofuels production or consumption”.14

Additionally demand for biofuels is a significant driver of land grabs—large-scale acquisitions of agricultural in developing countries, by nations and private investors from wealthier countries in order to produce crops for exports. They are frequently linked to violations of land rights and human rights and to exploitation of the host country’s natural resources resulting in reduced food security.

The exact percentage biofuels play as driver of land grabs is difficult to determine. Globally, the World Bank found that 21 percent of land deals in 2009 were for biofuel production, while the International Land Coalition’s (ILC) more updated figures put this higher, at 44%.15

Currently there are no binding provisions in the sustainably criteria of the EU’s Renewable Energy Directive nor the UK’s RTFO that address or prevent social impacts of biofuels like land grabs and impacts on food prices apart from a reporting requirement.

On Biomass

So far there has been less evidence in regards to the social and biodiversity impacts of biomass demand from the UK compared to biofuels. However with rapidly increasing UK demand for wood from overseas we can expect to see more of these impacts over the coming years when more of this wood will come from countries with low standards of environmental laws and law enforcement. According to some reports long-term concessions for biomass plantations for export have been acquired by companies in countries including Guyana, Ghana, Republic of Congo and Brazil.16

Newly established tree plantations can have similar impacts as plantations for liquid biofuel in terms of competing with food production for land and water, driving land grabs and depriving forest-dependent people of their livelihoods.

Large-scale tree plantations often replace forests and are thus a direct cause of deforestation. There are few cases where large-scale tree plantations have been established on degraded land.

What challenges are there to scaling up the use of biomass in the UK (ie regulation, feedstocks, sustainability, supply chain and financing)?

On biomass

As laid out above there are huge differences between the GHG impacts of different biomass pathways. While many biomass pathways increase emissions compared to fossil fuel only the use of residues and energy crops on abandoned land lead to significant carbon savings. Therefore only these make sense to be supported as renewable energy.

However the availability of these feedstocks is highly limited. Currently there is little abandoned land in the UK and woody crops play only a minute role in the sourcing of biomass.

AEA analysis expects UK supply of both forestry residues and energy crops to be less than 3 TWh by 2020.17

There is however a large potential for scaling up of bioenergy in other areas outside of woody biomass and biofuels from crops eg from waste and landfill gas.

To what extent will the UK be able to provide its own biomass and how much is likely to be imported?

On biomass

While there are differing estimates to what percentage of demand for biomass in 2020 will be met by domestic biomass there is broad agreement (including from industry) that the vast majority will be imported.

In 2010, the UK imported around 81% of the wood material consumed internally.18 There is little to suggest that this proportion is to change in favour of domestic production.

The CCC’s Bioenergy Review estimates that only about 10% of UK’s solid biomass ambition for heat and power in 2020 will be met through combusting domestic forest biomass19 based on the medium scenario in the AEA assessment of bioenergy resources.20

DECC expects approximately 80% of feedstock to come from imports in the future.21

On biofuels

According to the UK’s national renewable action plan the UK is expected to depend to over 80% on imports of liquid biofuels by 2020.22

What factors will have to be addressed to ensure that biomass is sustainable and to what extent is it possible to assess the sustainability of imported biomass?

In order for energy to merit public subsidies as “green energy” the use of biomass must guarantee real cuts in net greenhouse gas emissions while avoiding serious negative environmental and social impacts, including (but not limited to) deforestation, biodiversity loss, reduction of carbon stocks, land grabbing, negative impacts on food availability and affordability, impacts on water availability, eutrophication and pesticide use.

Experience from liquid biofuels have shown that many of these impacts occur as a macroeconomic result of artificially increasing demand for a scarce resource. As a result sustainability criteria that operate on the scale of a particular production site can address some of the issues, but are unable to address macro-impacts (eg food security, the displacement of other form of agriculture into pristine habitats etc.) that are out of the control of a particular production sire. These impacts can only be addressed through carefully limiting demand to a sustainable level.

Additionally experience with certification schemes like the Roundtable on Sustainable Palm Oil (RSPO)23 have shown that implementation and enforcement are often poor on the ground.

In the light of globally increasing demand for bioenergy resources it would be short-sighted for the UK to rely on imported resources that

(a)Might soon no longer be available to the UK at economical prices.

(b)Are out of the UK’s legislative control.

ANNEX I

The following list provides references and links to literature related to carbon emissions from biomass power and, specifically the issue of carbon debt. This is not an exhaustive list.

Reports

Agostini, A, Boulamanti, A, Giuntoli, J, 2013, Carbon accounting of forest bioenergy, JRC Technical Notes

Bird N, Pena, N, and Zanchi, J, 2010, The upfront carbon debt of bioenergy, Joanneum Research, http://www.birdlife.org/eu/pdfs/Bioenergy_Joanneum_Research.pdf

Bowyer, C, Baldock, D, Kretschmer, B and Polakova, J, 2012, The GHG emissions intensity of bioenergy: Does bioenergy have a role to play in reducing GHG emissions of Europe’s economy? Institute for European Environmental Policy (IEEP): London, http://www.ieep.eu/assets/1008/IEEP_-_The_GHG_Emissions_Intensity_of_Bioenergy_-_October_2012.pdf

Colnes, A, et al, 2012, Biomass Supply and Carbon Accounting for Southeastern Forests, Biomass Energy Resource Centre, http://www.southernenvironment.org/uploads/publications/biomass-carbon-study-FINAL.pdf

European Environment Agency, 2011, Opinion of the EEA Scientific Committee On Greenhouse Gas Accounting in Relation to Bioenergy, http://www.eea.europa.eu/about-us/governance/scientific-committee/sc-opinions/opinions-on-scientific-issues/sc-opinion-on-greenhouse-gas/view

Holtsmark, B, 2010, Use of wood fuels from boreal forests will create a biofuel carbon debt with a long payback time, Discussion Paper No 367, Statistics Norway, http://www.ssb.no/publikasjoner/pdf/dp637.pdf

Zanchi, G A, et al, 2011, “Is woody bioenergy carbon neutral? A comparative assessment of emissions from consumption of woody bioenergy and fossil fuel” Global Change Biology: Bioenergy, DOI: 10.1111/j.1757–1707.2011.01149.x, http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2011.01149.x/abstract

Peer-Reviewed Literature

Bernier, P, Pare, D, 2012, “Using ecosystem CO₂ measurements to estimate the timing and magnitude of greenhouse gas mitigation potential of forest bioenergy”, Global Change Biology: Bioenergy (advance online publication July 16, 2012) DOI: 10.1111/j.1757–1707.2012.01197.x http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2012.01197.x/full

Bird, D N, Pena, N, Frieden, D, Zanchi, G, 2011, “Zero, one, or in between: evaluation of alternative national and entity-level accounting for bioenergy”, Global Change Biology: Bioenergy, 4, 5:576–587, http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2011.01137.x/abstract

Böttcher, H, et al, 2012, “Projection of the future EU forest CO₂ sink as affected by recent bioenergy policies using two advanced forest management models”, Global Change Biology: Bioenergy, 4,6 :773–783, http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2011.01152.x/abstract

Cherubini, F, et al, 2011, “CO₂ emissions from biomass combustion for bioenergy: atmospheric decay and contribution to global warming”, Global Change Biology: Bioenergy, 3, 5:413–426, http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2011.01102.x/abstract

Cherubini, F, et. al, 2011, “Effects of boreal forest management practices on the climate impact of CO2 emissions from bioenergy”, Ecological Modelling, 223:59–66, http://pubget.com/paper/pgtmp_8cebeb0f1caf71aa1540890f9fd4f0ff/Effects_of_boreal_forest_management_practices_on_the_climate_impact_of_CO_2_emissions_from_bioenergy

Haberl, H, et al, 2012, “Correcting a fundamental error in greenhouse gas accounting related to bioenergy”, Energy Policy, doi:10.1016/j.enpol.2012.02.051, http://www.cccep.ac.uk/Publications/research-articles/error-greenhouse-gas-accounting-bioenergy.pdf

Holtsmark, B, 2011, “Harvesting in boreal forests and the biofuel carbon debt” Climatic Change, DOI: 10.1007/s10584–011–0222–6 http://www.springerlink.com/content/m818k271ml24696t/fulltext.pdf

Hudiburg, T, et al, 2011, “Regional carbon dioxide implications of forest bioenergy production”, Nature: Climate Change, 1:419–423, http://www.nature.com/nclimate/journal/v1/n8/pdf/nclimate1264.pdf

Mckechnie, J, et al, 2011, “Forest Bioenergy or Forest Carbon? Assessing Trade-Offs in Greenhouse Gas Mitigation with Wood-Based Fuels”, Environmental Science & Technology, 45, 789–79, http://pubs.acs.org/doi/abs/10.1021/es1024004

Mitchell, S, Harmon, M, O’Connell, K, 2012, “Carbon debt and carbon sequestration parity in forest bioenergy production”, Global Change Biology: Bioenergy (advanced online publication May 11, 2012), DOI: 10.1111/j.1757- 1707.2012.01173.x, http://onlinelibrary.wiley.com/doi/10.1111/j.1757–1707.2012.01173.x/abstract

Walker, T, et al, 2010, “Biomass sustainability and carbon policy study”, Manomet Center for Conservation Sciences, Brunswick Maine, http://www.mass.gov/eea/docs/doer/renewables/biomass/manomet-biomass-report-full-hirez.pdf

Schulze, E, et al, 2012, “Large-scale bioenergy from additional harvest of forest biomass is neither sustainable nor greenhouse gas neutral”, Global Change Biology: Bioenergy, doi: 10.1111/j.1757–1707.2012.01169.x, http://ncfp.files.wordpress.com/2012/04/biomass-energy-not-sustainable-or-carbon-neutral.pdf

Searchinger, T, 2012, “Global Consequences of the Bioenergy Greenhouse Gas Accounting Error,” in O. Inderwildi and Sir David King (eds.), Energy, Transport, & the Environment, Springer-Verlag, London, http://www.amazon.co.uk/Energy-Transport-the-Environment-ebook/dp/B00A9YG8XK/ref=sr_1_1?ie=UTF8&qid=1353407731&sr=8–1

April 2013