Energy and Climate Change CommitteeWritten evidence submitted by WWF-UK (BIO26)
Summary
1. WWF-UK welcomes the opportunity to respond to this inquiry. We are becoming increasingly concerned about:
the heavy reliance on biomass which several countries in the EU, including the UK, are choosing to adopt in order to meet 2020 renewable energy targets. This concern applies in particular to the power sector for which there are many alternative renewable energy sources; and
the full lifecycle emissions, particularly from forest feedstocks, of different bioenergy pathways and broader sustainability impacts.
2. As we recognise that the scientific understanding of key sustainability issues such as the “carbon debt” of biomass is far from settled and is evolving rapidly, this response focuses on highlighting our key concerns to date on some aspects of biomass use, rather than providing detailed policy recommendations. However, based on the three main concerns highlighted in our response, we believe that the sustainability of biomass use could be greatly improved if the following issues were taken into account:
prioritising the use of biomass in those sectors of the economy that need it the most (such as high temperature heat processes in industry, long-distance freight, etc.) due to a lack of alternatives to reduce emissions in those sectors;
continue to prioritise energy efficiency improvements across the economy, as this will provide more technological options to reduce carbon emissions on the supply side;
considering the introduction of sustainability criteria that take into account the “carbon debt” of biomass use, which would consider in particular whether the use of biomass sources will deliver a net increase in carbon dioxide emissions to the atmosphere rather than a net reduction over a certain time frame; and
introducing a requirement to ensure that biomass-fired power plants do not emit more than 200gCO2/kWh, as previously recommended by the Committee on Climate Change.
3. When considering the environmental impacts of biomass, it is important to acknowledge that the scientific community’s understanding on carbon debt and other sustainability issues is evolving and that there are therefore still uncertainties. It is important that Government policy on biomass acknowledges this by acting under the EU’s principle of precautionary action and takes into account the dynamic nature of scientific understanding in this area.
4. It is worth highlighting here that recent research commissioned by WWF in the UK (through GL Garrad Hassan)1 and the EU (through Ecofys)2 shows that renewable technologies can be the driving force towards reducing power sector emissions and maintaining security of supply with only a small share of biomass. For instance, WWF’s Re-Energising Europe report, found that renewables could provide around 65% of the EU’s electricity demand in 2030, with only 2.8% of electricity demand being met by biomass-fired plants.
Introduction
5. To have a chance of avoiding the worst impacts of climate change, global average temperature rise must not exceed 2ºC above the pre-industrial average. The provision of energy from fossil fuels currently accounts for around two-thirds of global greenhouse gas emissions. The International Energy Agency (IEA) warned in its World Energy Outlook 2012 report that at least two-thirds of the world’s proven fossil fuel reserves need to stay in the ground if the world wants to prevent temperature rises in excess of 2ºC.3
6. There is therefore an urgent need for a rapid transition towards an energy efficient system powered by low-carbon technologies on the supply side. WWF International’s Energy Report, based on analysis by energy consultants Ecofys, concluded that developing an energy efficient world economy powered almost 100% by sustainable forms of renewable energy by 2050 was not only technically possible but could save the world economy up to €4trillion/year by that date (roughly equivalent to 2% of world GDP).4 Recent research from WWF’s European Policy Office, based on analysis by CE Delft, showed that following such a technological path in the EU would have the advantage of avoiding excessive reliance on the deployment of other technologies such as nuclear or carbon capture and storage, which both currently carry a significant risk of under-delivery5 compared to previous deployment forecasts.
7. As made clear in WWF International’s Energy Report, the first step to drastically reduce emissions is to limit the growth in energy demand as much as possible by using energy much more efficiently. The IEA indicated in its World Energy Outlook 2012 report that around four-fifths of the global potential to reduce energy use in buildings and more than half the potential in industry has not yet been tapped into. Their “Efficient World Scenario” shows that if the barriers to energy efficiency investment were addressed (none of which involve technological breakthroughs), this could halve the global growth in primary energy demand by 2035.6
8. The second step is to scale up energy supply from low-carbon technologies, especially in the renewables sector where several technologies such as wind power and solar have already fallen rapidly in cost and others such as offshore wind7 are expected to follow suit. Within the EU, the 2020 renewable energy targets for Member States have played a crucial role in driving investment in the deployment of these sources of energy across Europe. Between 2000 and 2012, 51.2% of new power capacity in the EU has been in renewable energy, with in particular a growth of 96.7GW in wind power and 69GW in solar PV. New renewables and gas plant combined amount to 91.2% of all installed capacity in the EU since 2000 with a sharp decline in coal (-12.7GW), fuel oil (-17.4GW) and nuclear capacity (-14.7GW).8
9. As shown in WWF International’s Energy Report, the use of bioenergy is one of the key options that can be used to help us deliver a low carbon energy system in some hard to treat sectors of the economy where there are limited technological options to reduce emissions at present. However, as the UK Government’s Bioenergy Strategy notes, “used in the wrong ways bioenergy can actually confound our aims, releasing more carbon into the atmosphere and putting at risk fundamental objectives such as food security”.9 It is therefore important to incentivise in priority the most sustainable forms of renewable energy, such as for instance solar, wind, water and geothermal ahead of bioenergy use, which needs to be supported under strict sustainability conditions.
10. In the European Union however, it is expected that 10% of final energy consumption will be provided by biomass in 2020, with these resources then making up around 50% of the overall renewable energy consumption in the region10. The UK, according to the Government’s National Renewable Energy Action Plan, may be the fourth biggest user of bioenergy in the EU by 2020, potentially using over 10 million tonnes of oil equivalent which could deliver half of the UK’s renewable energy target.11 12 13
Key Areas of Concern
Concern 1: Proposals to use a substantial amount of biomass in the power sector (in which many alternative sources of renewable energy exist) could undermine the use of this finite resource in other sectors of the economy that may need it more.
11. In the power sector, the burning of biomass is often seen as the “low-hanging fruit” of the renewable electricity options available. The conversion of existing coal fired power stations in full or in part to enable them to burn biomass is currently the cheapest and quickest way to deliver renewable electricity to the grid14 , 15 (although one should note the rapid reductions in cost of other renewable energy technologies such as onshore wind and solar PV).
12. By 2020, the UK Government anticipates that biomass may make up around 30% of the renewable electricity mix. This would deliver around 32–50TWh of electricity annually from around 6GW of plant,16 requiring 23Mt or more of solid biomass per year.1718 According to current industry indications, it is likely that most of this will be in the form of imported wood pellets.19 To put this into context, according to the Committee on Climate Change’s (CCC) Bioenergy Review (2011), only around 0.7Mt of wood is currently burnt in UK power stations.
13. In terms of efficiency, it is anticipated that most of this biomass will be burnt in old coal plants, which are either co-firing or have converted fully to run on biomass. Given that the thermal efficiency of existing coal plants is around 34–39% and that the burning of biomass, which has a lower calorific content and bulk density, will lower the efficiency of plant even further, this does not appear to be a very efficient use of a finite resource if done on a large scale. To put these efficiencies into context, a new CCGT is around 60% efficient and the conversion efficiency of biomass used solely to generate heat is around 80%.20
14. The UK Government appears to see such a ramp up in the use of biomass in the power sector as transitional, especially because competition for biomass use from other harder-to-decarbonise sectors will increase over time.21 However, the Government currently does not have a clear strategy for ensuring that this will happen, eg by mandating closure dates for plant in the post-2020 period. There is a risk that investments in converting old coal plants being considered now could lead to further upgrades, which will enable them to comply with the air pollution requirements under the EU’s Industrial Emissions Directive. This could, in the absence of mandatory and robust sustainability criteria and clear carbon accounting rules, have the consequence of locking-in an inefficient use of biomass in the UK (and EU) over the long-term, well after 2020.
15. It is worth highlighting here that recent research commissioned by WWF in the UK (through GL Garrad Hassan)22 and the EU (through Ecofys)23 shows that renewable technologies can be the driving force towards reducing power sector emissions and maintaining security of supply with only a small share of biomass. For instance, WWF’s Re-Energising Europe report, found that renewables could provide around 65% of the EU’s electricity demand in 2030, with only 2.8% of electricity demand being met by biomass-fired plants.
16. Initial Recommendation: Government policy should take an economy wide view of how biomass is used and incentivise its use in those sectors of the economy where it is most efficient to do so. In the case of the power sector, this is particularly important over the long-term where the lock-in of biomass use in inefficient plants should be avoided.
Concern 2: The UK Government’s proposed carbon calculator for biomass may underestimate the full climate impact of forest biomass and could lead to a use of biomass in the power sector which delivers a net increase in carbon dioxide emissions.
17. At the EU level, there are currently no carbon accounting (or wider sustainability) criteria mandated for the use of solid biomass or biogas in energy generation, and no reporting requirements. The Renewable Energy Directive only mandates such criteria for bioliquids.24 The UK Government’s proposed biomass and biogas carbon gas calculator for biomass electricity25 covers emissions from cultivation, harvesting, transport, distribution and processing but does not currently take into account any emissions that may result from a change in forest carbon, forgone carbon sequestration of the land,26 land clearing or indirect emissions from substitution.27
18. Whilst it is important to note that scientific understanding in this area is still evolving rapidly, DECC’s draft Biomass Emissions Counterfactual model released earlier this year suggests that, in several scenarios, emissions from these additional sources may be substantial and could lead to an increase in carbon dioxide emissions from power stations to the atmosphere (a “carbon debt”), rather than a reduction when considered over a 20 year (and in many cases even a 40 year) time frame.28 29 DECC are currently consulting on the model over the next few months and have indicated that they hope to publish an online version in July. However, it is not currently planned that the implications of the model will be incorporated into the Government’s biomass and biogas carbon calculator.
19. The CCC have noted that the near-term market is likely to be predominantly supplied by forest biomass due to the presence of existing markets and infrastructure for the timber sector and limited market penetration of alternative feedstocks.30 Depending on the proportion of forest biomass in the supply chain that is at risk of “carbon debt” (ie where the use of some feedstocks can result in a net increase in emissions over a particular time frame), there is a risk that burning biomass in power stations could lead to a net increase rather than a decrease in carbon dioxide emissions from the electricity sector.
20. Initial Recommendation: In order to ensure that the use of biomass delivers a net reduction in carbon emissions compared to the use of fossil fuel alternatives, there is a need for robust sustainability criteria and monitoring requirements at UK or EU level that include carbon accounting criteria.
Concern 3: A heavy reliance on imported forest based feedstocks may make it harder to guarantee that these resources are sourced from sustainably managed forests.
21. As previously mentioned, it is currently anticipated that the UK will be heavily dependent on imported forest biomass feedstocks, in the short term at least. This is supported by research commissioned by DECC undertaken by Forest Research which observes, “The possibility that [UK bioenergy demand] might be met from on-going management of forest areas already in production was explored, but finally discounted on both a pure theoretical basis and in the light of evidence on likely changes to patterns for wood demand. Instead it was concluded that a significant increase in requirement for imported wood in the UK would entail intensification of the management of forests in other countries, similar in some respect to restoration of management in neglected forests.”31
22. Indeed, the Government’s bioenergy strategy shows that the majority of solid biomass supply is likely to come from imported sources as does the CCC’s Bioenergy Review (2011). Furthermore and with regards to the supply of biomass to the UK power sector, the CCC also notes that the dispersed nature of UK forestry resource suggests a limited role in supplying bioenergy for large-scale power.32
23. Whilst importing biomass from third countries is not an indicator on its own of unsustainability, there are risks inherent in importing large amount of biomass into the UK market. Forest habitat destruction as well as the over-exploitation of forests as a consequence of poor management is a key driver of the current deterioration of global forest biodiversity.33 With regards to bioenergy, the RSPB has raised concerns that the risks of unsustainable harvesting from forests are greatly increased for imported wood given the longer supply chains and often weaker legislative enforcement environments in other countries.34 A report by the Institute for European Environmental Policy also observes that it will be “much harder to monitor and enforce sustainability standards which will be required in future if they have to encompass all forms of bioenergy drawn from a range of third countries of supply”.35 Indeed, the CCC has noted that there is generally more certainty about the sustainability of UK-grown biomass.36
24. Initial Recommendation: The UK and EU should develop robust criteria to ensure the sustainability of imported feedstocks and should prioritise/encourage the development supply chains for low-risk biomass feedstocks.
May 2013
1 “Positive Energy: How renewable electricity can transform the UK by 2030”, WWF-UK, October 2011: www.wwf.org.uk/positiveenergy
2 “Re-energising Europe – putting the EU on track for 100% renewable energy”, WWF European Policy Office, January 2013: http://www.wwf.eu/what_we_do/climate/climate_energy_publications.cfm?207608/WWF-report-Putting-the-EU-on-Track-for-100-Renewable-Energy
3 “World Energy Outlook 2012”, the International Energy Agency, November 2012: http://iea.org/publications/freepublications/publication/English.pdf
4 www.panda.org/energyreport
5 “Cutting Energy Related Emissions The Right Way”, WWF European Policy Office, December 2012: http://wwf.panda.org/?206942/wwf-report-cutting-energy-related-emissions-the-right-way
6 “World Energy Outlook 2012”, the International Energy Agency, November 2012: http://iea.org/publications/freepublications/publication/English.pdf
7 See in particular the Crown Estate’s “Offshore Wind Cost Reduction Pathways Study”, June 2012: http://www.thecrownestate.co.uk/news-media/news/2012/reducing-the-lifetime-costs-of-offshore-wind-pathways-to-success/
8 “Wind in Power”, 2012 European Statistics, EWEA, February 2013: http://www.ewea.org/statistics/
9 UK Bioenergy Strategy. Dft, DECC and DEFRA, April 2012
10 WWF’s recommendations for sustainability criteria for forest based biomass used in electricity, heating and cooling in Europe, WWF, 2012
11 National Renewable Energy Action Plan for the UK, DECC, 2010.
12 The role of bioenergy in the National Renewable Energy Action Plans: a first identification of issues and uncertainties, IEEP, 2010.
13 Although the Government clearly has ambitions that it could contribute a much higher proportion. For example in a recent MP debate on biomass power generation John Hayes the Conservative Energy Minister said “With the right criteria in place, by 2020 as much as 11 per cent of the UK’s total primary energy demand - for heat, transport and electricity – could be met from sustainable sourced, biologically derived biomass” (20 March, 2013). If this were the case then bioenergy would deliver some 73% of the UK’s 2020 renewable energy target
14 http://www.decc.gov.uk/en/content/cms/consultations/cons_ro_review/cons_ro_review.aspx
15 Renewable Energy Roadmap, DECC, 2011.
16 Renewable Energy Roadmap, DECC, 2011.
17 Bioenergy Review – technical paper 4, biomass in power generation, Committee on Climate Change, December 2011
18 Across the EU around 90Mt per year of solid biomass may be burnt in power stations by 2020 (Bioenergy Review – technical paper 4, biomass in power generation, Committee on Climate Change, December 2011.)
19 Presentation by Anna Stephenson from DECC to NGOs of DECC’s draft Bioenergy Emissions and Counterfactual Model, 4 April 2013.
20 Bioenergy Review – technical paper 4, biomass in power generation, Committee on Climate Change, December 2011.
21 Indeed the Government’s Bioenergy Strategy notes that their modelling suggests that biomass use in the power sector beyond 2020 would be limited to uses of waste, CHP and biomethane in CCGT and OCGT to provide peak electricity - UK Bioenergy Strategy. DfT, DECC and DEFRA, April 2012
22 ‘Positive Energy: How renewable electricity can transform the UK by 2030’, WWF-UK, October 2011: www.wwf.org.uk/positiveenergy
23 “Re-energising Europe – putting the EU on track for 100% renewable energy”, WWF European Policy Office, January 2013: http://www.wwf.eu/what_we_do/climate/climate_energy_publications.cfm?207608/WWF-report-Putting-the-EU-on-Track-for-100-Renewable-Energy
24 http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:140:0016:0062:en:PDF – See Articles 17, 18 and 19.
25 http://www.ofgem.gov.uk/Sustainability/Environment/RenewablObl/FuelledStations/bbcc/Pages/bbcc.aspx
26 This requires a consideration about what would have occurred in the absence of bioenergy production, the “counterfactual”. For example if bioenergy production replaces forests, reduces forest stocks or reduces forest growth, which would otherwise sequester carbon, it can increase the atmospheric carbon concentration (Opinion of EEA Scientific Committee on Greenhouse Gas Accounting in Relation to Bioenergy. EEA Scientific Committee, 15 September 2011).
27 Indirect emissions from substitution may result where the use of wood for the generation of energy results in wood being diverted from existing uses such as the construction of wood panels and leads to the substitution with either imported wood or non-wood alternatives such as concrete and plastics (Dirtier than Coal? Why Government plans to subsidise the burning of trees are bad news for the planet. RSPB, FoE and Greenpeace, 2012).
28 The 12 set power generation scenarios modelled show that the carbon savings only come out positive over a 20 year timeframe (when compared to the UK grid average carbon intensity of 600gCO2/KWh) if an energy crop is used (short rotation coppice or Eucalyptus) or if residues are used. In all scenarios that involve intensification of management or diversion of wood away from other industries the increase in emissions is substantial. The picture is not significantly altered if emissions are considered over a 40 year time frame.
29 The IPCC has highlighted in the past the value of taking into account the impact of carbon emissions from forests over a 20 year period.
30 Bioenergy review – technical paper 4, biomass in power generation, Committee on Climate Change, 2011
31 Carbon impacts of using biomass in bioenergy and other sectors: forests, Forest Research and Northe Energy, 2011.
32 Bioenergy review- technical paper 2 – global and UK bioenergy supply scenarios, CCC, December 2011.
33 “Review of the status, trends of, and threats to, forest biological diversity”, The Convention on Biological Diversity, 2010; Ecosystems and human wellbeing. UNEP, 2005.
34 RSPB response to Government consultation on biomass: Part A – sustainability criteria, 2012. “Securing biomass for energy – developing an environmentally responsible industry for the UK now and into the future”, IEEP, 2011.
35 “Securing biomass for energy – developing an environmentally responsible industry for the UK now and into the future”, IEEP, 2011.
36 Bioenergy Review, CCC, December 2011.