Energy and Climate Change CommitteeWritten evidence submitted by Kate de Selincourt (BIO25)

I am assuming that by biomass you mean solid biomass—woody, and farmed. I will talk mostly about forest biomass.

I haven’t written an executive summary, but would summarise my response as this: UK proposed biomass burning policies are certain to increase atmospheric CO2 in the short and medium term, and may not decrease it in the long term, even compared to fossil fuel burning. If you compare biomass burning to more intelligent energy policies such as demand reduction and non-emitting renewables, then biomass burning could never contribute to anything other than a relative INCREASE in CO2 emissions.

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

Since genuine reductions—even from burning residues—are not likely to occur for 20–40 years or more, if at all (see below), biomass cannot easily contribute to carbon reduction targets between now and 2050. The only other plausible reason for the renewables policy is to increase energy self-sufficiency, and biomass doesn’t do this either, (or not at the scale anticipated—we haven’t got enough and can’t spare the space to grow all that much more), to my mind this means the renewables targets should either exclude bioenergy, or better still be scrapped altogether in preference for a rational, least cost, demand reduction, energy security and decarbonisation policy.

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

Not well. Biomass support appears to be proceeding despite lack of sound evidence that emissions are reducing relative to most alternative scenarios, even high fossil fuel ones—and plenty of evidence that emissions are already increasing, and are set to soar, for decades.

2.1 The RO consultation from DECC following the publication of the strategy, firstly admitted that it was setting sustainability standards despite not really knowing what the emissions impact really was, so it was by definition unable to guarantee savings, and secondly, insisted that sustainability standards would have to be set with a view to “what the market can realistically deliver” ie, that absolutely carbon-increasing biomass would have to be accepted as “sustainable” if that is all there was to be had. This is plainly in direct contradiction to the bioenergy strategy. And, of course, entirely pointless, since the fuel won’t even be indigenous.

3. Are genuine carbon reductions being achieved?

No. Following the work commissioned by DECC from Robert Matthews, and much other analysis, it is very clear that “carbon reductions” does not mean anything anyway, unless it is defined as relative to what scenario, and over what timeframe. But whatever the comparator, remember that an immediate increase in atmospheric CO2 is inevitable when biomass is burned for electricity, even relative to the worst-case alternative, as biomass is a higher carbon-per-kilowatt hour fuel than most fossil fuels. But as well as defining the kind of fuel, you must be clear about the following before you can put any figures to the carbon impact of bioenergy burning:

3.1 Increases/reductions in relation to what alternative scenario So this has to be defined as, for example, increase/reduction in atmospheric CO2 compared to current generation; or to the expected generation mix over the lifetime of any plant being supported by the policy; or to increases or reductions in relation to an equivalent investment in demand reduction (certain to be an increase); increases or reductions in relation to an equivalent investment in non-emitting renewables eg large scale solar, wind, etc (again, pretty sure to be an increase even when the capital CO2 of the renewables plant is taken into account). Counter-factuals must also include—option to increase standing biomass by leaving woods unharvested (emergency sequestration, if you like) and of course careful examination of “market mediated” effects—such as for example, causing more concrete to be poured because wood resources become too expensive for the construction industry, etc.

3.2 Reductions over what timescale. Almost all biomass burning leads to an initial INCREASE in emissions, even compared to burning coal for the same energy—the all important question is what is your critical timeframe? Some biomass fuels could be expected to revert to CO2 quite quickly even if not burned for energy—in these cases, there may be a net decrease relative to burning coal or even gas, after a few decades; Some fuel however would be expected to remain stable or even, increase carbon storage (big trees, for instance) for decades and centuries, if left in peace, and burning them could never contribute to anything other than acceleration of climate change. A great deal of fuel is in the middle ground: stumps, dead but still-standing trees, etc, which are gaily regarded as “oh, going to rot anyway” but the fact is they represent significant carbon sequestration for quite some time—maybe showing “reductions over fossil fuels” after a century, but causing an emissions increase over 20 and perhaps 40 or even 60 years (see 3.3 below), even relative to fossil fuel—which many would see as a dangerous step to take, climate-wise.

3.3 and this is one you might not have heard about before; you should be considering the issue of “CUMULATIVE EMISSIONS”—and cumulative climate forcing. This is really important and almost always ignored. When comparing two scenarios (eg burning gas vs burning wood) it seems now generally to be accepted, as I set out above, that to begin with the emissions from the wood will be higher, but as the biomass source is allowed to regenerate (assuming this does in fact happen, which of course, since its the future, can never be guaranteed), the net emissions fall again, until at some point they fall back to the same carbon balance as created by the “counterfactual” energy source eg the amount emitted by lower-carbon but non-regenerating gas. Generally this is taken as the “break-even point”—HOWEVER, IN CLIMATE FORCING TERMS IT IS NOT BREAK EVEN—and won’t be for a while longer!

3.3a Climate forcing is cumulative; the heat energy added to the earth system is proportional to the carbon GHG concentration in the atmosphere and to the time for which those GHGs dwell in the atmosphere. This means a temporary emission causes a permanent heating of the planetary system. I will attempt to illustrate this concept with a sketch, though I’m afraid I am no artist!

fig 1—cumulative emissions, comparing biomass energy and gas over 60 years

3.3b What I am trying to show here is that because climate forcing is proportional to the tonne years in the life of an emission, and not just to the tonnage at a single point in time, even when the CO2 has been re-absorbed, the heating is still there. Thus a big emission for a short time has the same impact as a small emission for a long time. I am not making any claims about the actual figures here, just illustrating the principle. The green biomass CO2 balance line is curved down to represent reverse emissions ie CO2 uptake from biomass regrowth. If I was also to add the “forgone sequestration” the green line would swoop even higher before eventually coming back down—it might not return to zero, either, but that is a separate issue.

3.3c As you see, eventually the same net amount of warming would eventually have been caused by the smaller but more enduring pulse from gas, and the big shorter lived pulse from biomass, but it takes longer to break even in climate forcing terms, than is generally assumed.

3.3d I haven’t added in the impact of re-absorption of CO2 in oceans etc (problematic in itself of course)—this applies to all CO2 so I am not sure how much difference it makes to the overall relative shape.

3.3e What I am suggesting is that burning even quite short-lived biomass (as suggested here, I think this might approximate to larger branches, ie “roundwood”) could have a lingering climate forcing impact ABOVE even fossil fuel alternatives—never mind, above low-carbon alternatives such as demand reduction, for a lot longer than has been assumed. And a lot longer than we can afford.

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

Very unlikely, since it is not reducing emissions in the immediate term, but increasing them, cost-effectiveness is currently negative (ie the more we spend on subsidy, the worse the CO2 balance gets), and may only improve after decades, and only then if we are given a reliable and genuinely sustainable sourcing policy, and scale back our ambitions to what can be supplied this way. Current proposals are unable to specify that only very short-life biomass is used (eg, no whole trees), so they cannot guarantee even medium-term carbon savings. In fact, they guarantee nothing at all, as only 70% of any consignment is required to meet any standard at all. Therefore, the subsidy for biomass could very easily be characterised as using bill payers’ money to increase carbon emissions.

What is so shocking about this is that investment opportunities offering GUARANTEED EMISSIONS SAVINGS NOW, AT LOW COST OR EVEN NET PROFIT, are being ignored. I am talking about, in particular, demand reduction. We are forcing the fuel poor to pay to destroy forests and add CO2 to the atmosphere (while worsening the balance of payments by importing so much of the stuff) when we could be creating jobs, increasing treasury revenues, cutting cold-related mental and physical health problems and SAVING ENERGY AND CARBON with the same money.

And believe me, efforts on demand reduction in this country are PITIFUL! If you believe the Green Deal is going to do more than scratch the surface, think again and think fast. EEDO has not yet taken the world by storm either, has it? SO much more could be done.

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

Nothing like as much as the same spend on, for example building retrofit or replacement of inefficient plant and services would. For example, the German Treasury found that low-interest loans for retrofit returned 5x the government spend on subsidising these loans, in vat receipts, employer and employee NI, and reduced jobless benefits payment.

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

No, it is being wilfully ignored by everyone who thinks that oil based agriculture can go on producing more food from less land—even the UN say yields can go on growing, but this is a finite planet, my friends. We need land for food and land for biodiversity, and land for stabilising the climate via standing trees and soil carbon. Even “abandoned farmland” is being used by some plants and creatures, and possibly by people too—though when no money changes hands, they are dangerously invisible and powerless. Adding a whole new industrial-scale demand into the mix means something has to give. Usually, it is the poorest and hungriest—and the climate of course.

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

(pass)

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

Look around you. What do you think? Have you seen the size of those stores at Drax? Drax freely admits it’s going to be importing, as do plenty of the other would-be biomass plants, so this is a very silly question.

9. 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?

9a The scale, actually, is the first factor to address, without which you have little hope of even knowing, never mind controlling, “sustainability”. Bear in mind that “sustainable” forestry where woody matter is harvested for products, represents a different carbon balance to using the same “sustainable” techniques to harvest for fuel, because the afterlife of the carbon is different in the two scenarios. For products, carbon is released slowly, (think 500 year old wooden buildings) for fuel—released immediately.

9b This means that although the forestry may be sustainable in terms of “able to regrow” the carbon balance is unsustainable as in “unwanted and possibly even dangerous shift in carbon balance towards atmosphere—and a permanent shift, so long as the burning operation continues”. A permanent increase in burning leads to a permanent shift in the carbon balance, even if the harvesting is “steady state”, which does not reverse until the burning operation is closed down, and the necessary recovery period has passed—perhaps 40 years later still.

9c This is because the balance between sequestered and atmospheric carbon undergoes a one-off step change when the system moves form one “steady state” to another, in this instance, one involving more biomass burning. An increase in burning means a decrease in something else—eg:

a decrease in unharvested and still-growing biomass (ie, intensified management, which reduces carbon stocks per hectare over the producing area)

a decrease in production of wood products eg chipboard, paper, joists, etc—all of which have a longer life than a wood chip in a furnace, so represent a balance of less CO2 in the atmosphere than the new bioenergy scenario

A decrease in soil carbon from the natural incorporation of decaying residues into the soil/soil life system. No residue rots 100% to the atmosphere, some remains locked in the soil more or less permanently. If it didn’t, we wouldn’t have topsoil as we know it. And destroying the topsoil as we know it has destroyed less rapacious civilisations than our own, so we should take heed.

a decrease in an alternative land use. If essential food production is displaced for biofuel production, either More fossil-fuel-powered fertiliser must be applied to intensify production, or another non-food use is displaced, eg natural forest. Of course, if golf courses were planted up for growing fuel, this might be a good thing. However BEWARE: the carbon “credits” from growing new biomass cannot be credited to the bioenergy—they must be credited to the forestry operation. Planting trees today may well be a good thing—but when the day comes to harvest or not to harvest, that bioenergy operation will still be answerable for the emissions from burning. After all, if humanity has found a better way by then, those trees might go on growing—or they might be turned into lovely energy efficient homes. The choice then will determine the carbon balance implications..

10. Many of these assertions can be proven by thought experiment and deduction, and I have references for all the rest. I am happy to supply all references, and to talk anyone who is interested through the thought processes, if required.

April 2013

Prepared 1st May 2014