Energy and Climate Change CommitteeWritten evidence submitted by ActionAid UK (BIO23)
About us
Founded as a British charity in 1972, ActionAid is an international NGO working in 45 countries worldwide, and our positions and recommendations reflect the experiences of our staff and partners in Africa, Asia, the Americas and Europe. Our vision is a world without poverty and injustice in which every person enjoys the right to a life with dignity. We work with poor and excluded people to eradicate poverty and injustice.
Drawing on ActionAid’s long experience of promoting food rights, this submission highlights in particular our concerns and recommendations on the impact of bioenergy on global food security and land.
Executive Summary
ActionAid welcomes this inquiry.
Sustainable and domestic supplies of bioenergy from solid (woody/virgin) biomass, wastes and residues and energy crops could contribute to greenhouse (GHG) emissions reductions. However, solid virgin biomass (ie from trees) and liquid biofuels, which are the main bioenergy feedstocks for heat, power and transport are currently not delivering carbon savings and threatening food security.
Indeed, as we write, the UK is negotiating with its counterparts at the EU level the future of biofuels as evidence shows that they may be adding to GHGs to the atmosphere when indirect land use change is included in their carbon balance.
Solid virgin biomass also incurs a carbon debt (Answers 1 and 2), and the Scientific Committee of the European Environment Agency (EEA)1 strongly criticised the EU’s current policy, stating that “legislation that encourages substitution of fossil fuels by bioenergy, irrespective of the biomass source, may even result in increased carbon emissions—thereby accelerating global warming” (Answer 1).
Additionally, in recognition of their impacts on food security, part of the current talks is also about deciding whether to cap the amount of biofuels that can be produced from food crops. It seems indeed that the UK’s bioenergy policies are not taking into account their impacts on food security, and on people and communities more generally. ActionAid has witnessed first-hand the effects of biofuel plantations (many of which will be supplying the EU market) on local food security. UK biomass demand is likely to have a similar impact on local communities (Answer 3).
Current EU biofuel feedstocks are predominantly food crops—wheat, soy, maize, rapeseed etc. This has had the effect of pushing up global food prices. Recent modelling of the impact of the EU’s biofuels targets on food prices suggests that, by 2020, it could increase oilseed prices by up to 20%, vegetable oil prices by as much as 36%, and cereals maize by as much as 22%2 (Answer 3).
The sheer scale of demand for both biomass and biofuels means that most will have to be imported. Claims of sustainability need to be taken with extreme caution, particularly because social impacts are often overlooked and the carbon accounting is flawed (Answers 4 and 5).
Recommendations to the Committee
For bioliquids:
As part of the ongoing negotiations to revise EU biofuels policy:
Urge the government to support the European Commission’s proposal to cap food for fuel at 5%, with a view to eventually phasing out land based biofuels by 2020.
Urge the government to accept the true scale of carbon emissions from biofuels, and for this to be accounted for at the EU level, by including “indirect land use change” in calculations.
Ensure that social criteria are included into sustainability standards.
Urge the UK government to invest more heavily in renewable energy sources that do not cause food insecurity or land grabs.
Current generation biofuels (food-to-fuel) must not be subsided or financially supported.
For biomass:
Ensure that biomass in the EU (and elsewhere) should no longer be counted automatically as zero carbon. A comprehensive accounting system should be developed that includes carbon debt and indirect emissions, ie from land use change. This should apply to the Renewable Energy Directive and the EU-Emission Trading Scheme, as well as all other relevant international and national legislation.
No public subsidies should be available for generating electricity or industrial-scale heat from solid virgin biomass.
Biomass must comply with a strict set of environmental, social and ethical standards including land, food security, biodiversity, local pollution, groundwater abstraction, erosion, community benefit, labour conditions, community control and free, prior and informed consent.
Any biomass burned on an industrial scale must be subject to independent (non-industry funded) monitoring and verification. Wastes and residues should only be sourced from genuinely sustainable sources which is compatible with a zero waste strategy.
Much more government support should be given to insulation, energy (including transport) demand reduction and efficiency, as well as other forms of renewable energy such as solar, wind, wave, tidal, and geothermal.
Terminology: The committee is right to suggest that biomass is the generic term for organic material that can be used to generate heat or power, or to produce transport biofuels. However the use of the term biomass is generally taken as the feedstock for heat and power (either as “solid virgin biomass” such as wood pellets, coppice or wastes and residues); this differentiates it from biogas (biomethane) and liquid biofuels; in the UK, the latter is used almost exclusively as a transport fuel.
1. What contribution can biomass make towards the UK’s decarbonisation and renewable energy targets? Are the Government’s expectations reasonable in this regard?
1.1 Solid virgin biomass is currently defined as both renewable and “carbon neutral” (ie zero carbon) in EU law, ie there are no net emissions from burning wood because carbon was sequestered during tree growth. However, ActionAid believes that solid virgin biomass from trees currently makes no contribution to decarbonisation because of the following reasons. Until this carbon accounting error is rectified, it is clear that solid virgin biomass should not be part of the renewable energy mix:
1.
2.
3.
1.2 The questionable carbon-neutrality of biomass was formally discussed by the Scientific Committee of the European Environment Agency (EEA) in September 2011; the Committee then released a statement that strongly criticised the EU’s current policy, stating that “legislation that encourages substitution of fossil fuels by bioenergy, irrespective of the biomass source, may even result in increased carbon emissions—thereby accelerating global warming”.5 This position represents a growing consensus amongst scientists that classifying all biomass as “carbon neutral” is simply incorrect.6
1.3 Perversely, another piece of EU law—the Large Combustion Plant Directive (LCPD)7—is also deliberately encouraging an increase in biomass power.8 The LCPD requires large power plants that emit more than a particular level of sulphur dioxide to be either retrofitted or closed by 2015. A number of coal plants (including E.ON’s Ironbridge and RWE Npower’s Tilbury B in the UK9) are therefore hoping to gain permission to keep operating beyond this date by adding enough wood into their fuel mix to bring their sulphur emissions down to a legal level.
1.4 That is not to say that all biomass is a net contributor to carbon emissions. Given land use constraints, sustainable but limited volumes of energy crops is one option; the sustainable production of wood from UK forests (grown specifically for energy) is another; sustainable and domestic quantities of wastes and residues will also have positive GHG balances.
1.5 But many issues need to be resolved before we embark on the use of wastes and residues:
Clear definitions of all wastes and residues are required.
Life cycle analysis must be conducted for all bioenergy feedstocks.
A series of environmental and social safeguards must be put in place, to ensure that only sustainable quantities of wastes and residues are used.10
Competing uses must be assessed (almost all wastes and residues have existing uses and may have better end uses in terms of carbon abatement, ie forestry residues in the board industry).
Policies are in place and implemented to prevent waste in the first place (and priority given to ruse and recycling above waste-to-fuel).
2. 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?
2.1 Genuine carbon reductions are currently not being achieved.
2.2 In part this is due to increasing use of solid biomass (as outlined in our answer to question one). But this is also the case for liquid biofuels. The correct carbon accounting of biofuels, including indirect land use change (ILUC), shows that UK and EU biofuel policy will increase carbon emissions rather than reduce them. But ILUC is currently not included in EU and UK biofuel policies.
2.3 If ILUC is included, the total net GHG emissions from biofuels within the EU could be as much as 56 million tonnes of extra CO2 per year, the equivalent of an extra 12 to 26 million cars on Europe’s roads by 2020. Split into member states the UK alone could be adding up to 13 million tonnes of greenhouse gas emissions into the atmosphere (of the 56 million tonnes) because of ILUC, the equivalent of putting 6 million extra cars onto UK roads.11
3. How well have the Government’s bioenergy principles (set out in the 2012 Bioenergy Strategy) been translated into policy? Is sufficient attention being given to potential impacts in other areas, such as food security?
3.1 Whilst ActionAid welcomed the attention to food security in the UK Bioenergy Strategy (even warranting a mention in the first paragraph of the foreword), the impacts of bioenergy on food security in the strategy are then played down: “The Government is clear that the production of biomass for bioenergy must not pose a threat to food security, in the UK or internationally. Our analysis suggests that while UK policy has had limited detrimental impacts so far, there are some tensions and these could grow if bioenergy develops in the wrong way, for example if suitable environmental or social controls are lacking.”12
3.2 But there are no specific “social controls” on biomass or biofuel use (ie the Renewable Energy Directive omits social issues from its sustainability criteria). This is particularly worrying given the scale of demand (both biomass and biofuels) and the levels of imports that will be required by 2020 and beyond (see question 4). For biomass, the UK government appears to be relying on forest certification to provide many of the necessary environmental and social safeguards. But a number of prominent certification schemes have been found to be flawed (see question 5).
3.3 Tree plantations, and the increasing use of solid biomass for heat and power, will inevitably involve localised food insecurity. Tree growing, like biofuels, is often associated with the most productive land, with good water availability and with access to transport links and export terminals.
3.4 As far as ActionAid is aware, less research to date has been conducted on the link between tree plantations, land and food insecurity. However, one example is a tree plantation in Mozambique, run by Scandinavian companies. This was criticised as follows: “Of more serious concern is the potential longer term threat to local livelihoods. Already the plantation has reduced the area readily available for cultivation near to people’s homes. Several people interviewed said they had managed to find alternative plots of land for their fields, but that these are much more distant from home and could take hours to get there. This increasing problem of distance—as the plantation takes up more of the previous land used for farming near to the town or villages—is likely to impact food security in the future.”13
3.5 To date, ActionAid’s main area of expertise has been on the localised food security impact of biofuels plantations, particularly where the activities are being conducted by European companies for export back into Europe.
3.6 ActionAid’s research of European biofuel activities in Africa between 2009 and 2013 has documented 98 biofuel projects covering some 6 million hectares of land.14 The biggest investors of biofuels in sub-Saharan Africa (SSA) are from the UK (30 projects), Italy (18) and Germany (8), and the average size of European investments is 68,000 hectares (ha). Many have the explicit aim to supply European markets.
3.7 For example, an Italian company applied for lease of 50,000 ha in 2008 to produce biofuels in the Dakatcha woodlands in Kenya. 20,000 people of the Watha and Giriama communities live on the land and their access to shelter and food was threatened. Local organisations mobilised, resulting in the suspension of the project in mid-2010. At the time of writing, biofuel plantations have been banned in this region of Kenya (the coastal region).15
3.8 Since 2011, people in the North of Senegal have been struggling to hold on to their land for food and livestock production. Social conflict has increased and arrests and deaths have occurred. An EU company is currently scheduled to cultivate 10,000 hectares of land to produce biofuels and food from sunflower and sweet potatoes; this area includes 37 villages where about 9,500 people could be displaced. The risks to food security have not been evaluated even though the project will necessarily have an impact on local food crops and above all on livestock farming—an estimated 100,000 animals—while the company plans to export all or part of its production to the European market.16
3.9 But biofuels are also responsible for driving up global food prices because the main feedstocks are all food items (the “food-to-fuel” issue); Recent modelling of the impact of the EU’s biofuels targets on food prices suggests that by 2020, it could increase oilseed prices by up to 20%, vegetable oil prices by as much as 36%, maize by as much as 22%, sugar by as much as 21% and wheat by as much as 13%.17 Indeed according to the World Bank, OECD, WTO, IFPRI, IMF and five other UN food agencies: “prices are substantially higher than they would be if no biofuels were produced.”18 These effects on prices are particularly alarming for developing countries where people spend up to 80% of their income on food.
4. To what extent will the UK be able to provide its own biomass and how much is likely to be imported?
4.1 The answer to this question rather depends on the scale of UK biomass demand to 2020 and beyond. This is not clear.
4.2 In the UK, the biomass-burning plants proposed by energy companies would, if built, consume around 90 million tonnes of wood per year by 2020 for electricity production alone.19 This is four to six times the amount predicted in the UK Government’s National Renewable Energy Action Plan (NREAP), which would require 15–20 million tonnes of wood by 2020 for both electricity and heat.20 If the UK biomass industry gets its way, it could end up burning as much wood in 2020 as European governments are expecting to burn in the whole of the EU.
4.3 Even assuming optimistic levels of sustainable wastes and residues, the level of demand for solid biomass in the form of wood pellets (or even short rotation coppice or other energy crops) will be substantial. And because of land constraints and sustainable “wood” production in the UK, the vast majority will be imported.
4.4 The UK already has a number of large plants that have received planning consent to convert either partly or completely to biomass:21 Tilbury B (RWE Npower), Ironbridge (E.On), Drax, Eggborough, Alcan Lynemouth (recently bought by RWE Npower); these power stations alone would burn around 50 million tonnes of green wood a year (about 25 million tonnes of pellets). To put that into come kind of perspective UK forests and woodlands are currently producing some 10 million tonnes of wood per annum.
DECC expects that approximately 80% of biomass feedstocks will be imported in the future.22 Similarly, the NREAP predicts that imports will comprise over 80% of UK biofuel demand by 2020.23
5. 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?
5.1 Key factors are as follows:
For biomass (and biofuels), correct carbon accounting is essential.
There must be binding environmental and social criteria covering such issues as land, food security, biodiversity, local pollution, groundwater abstraction, erosion, labour conditions, community benefit, community control and free, prior and informed consent.
Any biomass burned on an industrial scale must be subject to independent (non-industry funded) monitoring and verification.
5.2 That said, the sheer scale of biomass demand in the UK and the EU will make claims of sustainability very difficult to verify. For example the Forest Stewardship Council (FSC) certification, and Programme for the Endorsement of Forest Certification (PEFC) have been subject to serious criticism by numerous civil society organisations. A recent report from Biofuelwatch cites a series of worrying case studies where certification companies have classed forestry schemes as “sustainable”, even where land-grabbing, social conflict, forced evictions, deforestation and/or habitat destruction have clearly taken place.24
5.3 And by their very definition, certifications have to be conducted on direct impacts at the plantation level; sustainability cannot be assessed for indirect impacts, on biodiversity, on food prices and insecurity and so on.
5.4 It is also far from sustainable for the UK to continue to source resources from overseas, particularly from developing countries that are themselves energy insecure. There must be a presumption in favour of domestic sources, not least because claims of sustainability are easier to track and verify. And domestic waste and residues are almost certainly more sustainable than solid virgin biomass.
6. Recommendations to the Committee
6.1 For bioliquids:
As part of the ongoing negotiations to revise EU biofuels policy:
Urge the government to support the European Commission’s proposal to cap food for fuel at 5%, with a view to eventually phasing out land based biofuels by 2020
Urge the government to accept the true scale of carbon emissions from biofuels, and for this to be accounted for at the EU level, by including “indirect land use change” in calculations
Ensure that social criteria are included into sustainability standards
Urge the UK government to invest more heavily in renewable energy sources that do not cause food insecurity or land grabs
Current generation biofuels (food-to-fuel) must not be subsided or financially supported.
6.2 For biomass:
Ensure that biomass in the EU (and elsewhere) should no longer be counted automatically as zero carbon. A comprehensive accounting system should be developed that includes carbon debt and indirect emissions, ie from land use change. This should apply to the Renewable Energy Directive and the EU-Emissions Trading Scheme, as well as all other relevant international and national legislation
No public subsidies should be available for generating electricity or industrial-scale heat from solid virgin biomass (ie wood pellets made from trees)
Biomass must comply with a strict set of environmental, social and ethical standards including land, food security, biodiversity, local pollution, groundwater abstraction, erosion, labour conditions, community benefit, community control and free, prior and informed consent
Any biomass burned on an industrial scale must be subject to independent (non-industry funded) monitoring and verification. Wastes and residues should only be sourced from genuinely sustainable sources which is compatible with a zero waste strategy
Much more government support should be given to insulation, energy (including transport) demand reduction and efficiency, as well as other forms of renewable energy such as solar, wind, wave, tidal, and geothermal
April 2013
References
1 www.eea.europa.eu/about-us/governance/scientific-committee/sc-opinions/opinions-on-scientific-issues/sc-opinion-on-greenhouse-gas
2 IEEP, 2012. http://www.ieep.eu/assets/947/IEEP_Biofuels_and_food_prices_June_2012.pdf
3 Searchinger, T 2010. http://iopscience.iop.org/1748-9326/5/2/024007/fulltext/
4 Haberl et al, 2012. http://www.sciencedirect.com/science/article/pii/S0301421512001681
5 www.eea.europa.eu/about-us/governance/scientific-committee/sc-opinions/opinions-on-scientific-issues/sc-opinion-on-greenhouse-gas
6 http://www.guardian.co.uk/environment/2012/apr/02/eu-renewable-energy-target-biomass
7 http://ec.europa.eu/environment/air/pollutants/stationary/lcp/legislation.htm
8 http://www.publications.parliament.uk/pa/ld201213/ldselect/ldsecleg/123/12306.htm
9 http://media.lsiutilitybroker.co.uk/media/downloads/Daily_Energy_Report_300112.pdf
10 IEEP, 2013. http://www.ieep.eu/publications/2013/03/the-sustainability-of-advanced-biofuels-in-the-eu
11 “Driving to Destruction”, http://www.actionaid.org/sites/files/actionaid/driving_to_destruction_nov_2010.pdf
12 DECC, 2012. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/48337/5142-bioenergy-strategy-.pdf
13 http://www.docstoc.com/docs/145344887/Social-Analysis-Report---Moz---The-Open-University
14 Adding Fuel to the Flame, ActionAid, 2013, http://www.actionaid.org/eu/publications/adding-fuel-flame
15 See ActionAid, 2012. Fuel for Thought. http://www.actionaid.org.uk/doc_lib/biofuels_report_7_lo_res.pdf
16 See http://climate-connections.org/2012/08/20/senegalese-villagers-vow-to-fight-biofuels-project/
17 IEEP, 2012. http://www.ieep.eu/assets/947/IEEP_Biofuels_and_food_prices_June_2012.pdf
18 World Bank et al, 2011. Price Volatility in Food and Agricultural Markets: Policy Responses.
http://www.oecd.org/agriculture/pricevolatilityinfoodandagriculturalmarketspolicyresponses.htm
19 Biofuelwatch, 2013. http://www.biofuelwatch.org.uk/2013/biomass-faq-2/
20 At http://ec.europa.eu/energy/renewables/action_plan_en.htm
21 Biofuelwatch, 2013. http://www.biofuelwatch.org.uk/uk-campaign/coal-biomass-conversions/
22 RSPB, FoE, Greenpeace, 2012. Dirtier than Coal.
23 IEEP, 2010. Anticipated Indirect Land Use Change Associated with Expanded Use of Biofuels and Bioliquids in the EU – An Analysis of the National Renewable Energy Action Plans.
24 Biofuelwatch, 2013. http://www.biofuelwatch.org.uk/2012/biomass_myth_report/