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biomass faq bull august 2016 bull 1
biomass faqs
This briefing is intended to provide detailed information about the effects of wood-basedbiomass electricity and about the scale of and the subsidies for it in the UK We focus primarilyon biomass electricity rather than biomass heating because in the UK the vast majority ofwood burned for energy is burned in power stations and because most imported wood isburned for electricity If anything is not clear or your need information on something else wehavenrsquot discussed please drop us an email at biofuelwatchymailcom
What is biomass
Does burning biomass destroy forests How
What about burning biomass other than wood eg straw or miscanthus
Isnrsquot it just waste wood and residues which are being burned
Isnrsquot biomass carbon neutral or at least low-carbon
Can biomass ever be sustainable and low carbon
Is biomass electricity renewable energy
Does biomass pollute How does this affect peoplersquos health
How efficient is biomass electricity
What about Combined Heat and Power biomass Is this more efficientgreen
How much Biomass is currently being burnt for electricity in the UK
How much wood could be burned for electricity in the UK in future
August 2016
Hasnrsquot the UK government introduced rules under which only sustainable and low-carbon biomass will be subsidised
Why and how is biomass subsidised in the UK
How does the UKrsquos support for biomass compare to that for wind and solar power
Have local campaigns against biomass power stations been successful in the UK
References and notes
biomass faq bull august 2016 bull 2
Biomass refers to any organicmatter derived from organismswhich are or recently were alive Inthe context of energy the EUdefines biomass as ldquothebiodegradable fraction ofproducts waste and residues frombiological origin from agriculture(including vegetal and animalsubstances) forestry and related
industries including fisheries andaquaculture as well as thebiodegradable fraction ofindustrial and municipal wasterdquo(Renewable Energy Directive Article2(e)
The term lsquobiomassrsquo is commonlyused to describe solid biomass usedfor energy such as wood straw or
grasses rather than liquid fuelsmade from biomass which arecalled biofuels (when used fortransport) or bioloqiuids norbiogas which is produced throughanaerobic digestion of biomassBioenergy can come from biomassbiofuelsbioliquids or biogas
what is biomass
Clearcutting of coastal swamp forests in North Carolina which
supplies wood to an Enviva pellet mill Dogwood Alliance
On the current scale that we aredemanding biomass yes ndash and ifdemand rises as expected it woulddestroy forests on a far a greaterscale than today Excessivedemand for wood ndash especially in theglobal North - is one of the mainunderlying causes of deforestationand forest degradation worldwide[1] Anything that further drives upthe demand for wood is going toworsen this situation
Negative impacts may be direct orindirect Perhaps the strongestevidence of direct impacts onforests comes from the southernUS and specifically from Draxrsquosmain US supplier Enviva Enviva is
the biggest pellet producer in theUS Conservation NGOs such asDogwood Alliance and NaturalResources Defense Council (NRDC)as well as journalists havedocumented how Enviva is sourcingwood for pellet plants from theclearcutting of highly biodiversecoastal wetland forests
Perhaps the strongest evidence ofdirect impacts on forests comesfrom the southern US andspecifically from Draxrsquos main USsupplier Enviva Enviva is thebiggest pellet producer in the USConservation NGOs such asDogwood Alliance and NaturalResources Defense Council (NRDC)
as well as journalists havedocumented how Enviva is sourcingwood for pellet plants from theclearcutting of highly biodiversecoastal wetland forests
Experience with the global pulp andpaper industry shows thatclearcutting of biodiverse forests isoften followed by the establishmentof monoculture tree plantationsRich forest ecosystems whichprovide habitat for thousands ofspecies and play an important rolein nutrient cycling and in regionalrainfall cycles are thus lost foreverIndustrial tree plantations on theother hand provide habitat for veryfew species deplete soils andfreshwater and often require aerialspraying with agro-chemicals
Indirect impacts are by theirnature more difficult to proveHowever a greater demand forwood will always drive up woodprices which encourages moreintensive and extensive logging andmore land conversion to treeplantations worldwide Sawmillresidues or waste wood that areburned for energy might otherwisehave been used to make paperpanel board or other productsThis can force those otherindustries to resort to moredestructive logging instead
DOES BURNING BIOMASS DESTROY FORESTS HOW
biomass faq bull august 2016 bull 3
The vast majority of biomassburned for electricity in the UK theEU and worldwide is wood Mostconverted coal power stationsincluding Drax and in futureLynemouth Power Station can onlyburn high-quality wood pelletswhich means wood pellets madefrom slow-growing trees with littlebark [2]
Agricultural residues and lsquoenergycropsrsquo have long been promoted asbioenergy but there are seriousproblems with using such sourceson a large scale Agriculturalresidues are of great importance formaintaining soil carbon and soilfertility and thus future crop yieldsRemoving too many of them
depletes and erodes soils and stopsthem from holding enough waterthus making crops more vulnerableto drought Agricultural residuesserve other purposes too In partsof the England for example pigfarmers rely heavily on purchasingstraw from cereal farmers Thereare serious concerns that burningof straw in power stations couldpush up straw prices so much thatsome pig farmers would go out ofbusiness [3] This could harmforests and the climate too if small-scale pig farmers who keep free-range pigs are forced out ofbusiness they will ultimately bereplaced by industrial factoryfarming which relies heavily onimported soya which is a major
driver of deforestation in SouthAmerica
Perennial grasses and short-rotation coppicing for example ofwillow and poplar are oftenpromoted as a sustainable sourceof bioenergy However all of themrely on land and compete witheither food production or wildlifehabitats ndash just as biofuel plantationsdo already Despite subsidiesfarmers have been reluctant toconvert land to short-rotationlsquoenergy cropsrsquo Less UK land is usedfor miscanthus or short-rotationcoppicing today than it was in 2009[4] There is no evidence that similarplantations have been successful inother countries either
What about burning biomass other than wood eg strawor miscanthus
Energy companies and proponentsof large-scale biomass burningoften claim that only waste woodand residues are being burned butevidence shows otherwise
Across the EU burning waste woodis regulated in the same way asburning other forms of waste Theterm refers to wood which has beenused for another purpose in thepast for example for construction
Much of it willhave beenchemicallytreated Almost700000 tonnes ofwaste wood wereburned in the UKin 201415 out ofa total of 15million tonnes ofwood [5] Wastewood thusaccounts for lessthan 5 of theUKrsquos electricityfrom wood Notall power stationsburning wood are
technically capable andorpermitted to burn waste wood andno converted coal power station inthe UK could burn it
ISNrsquoT IT JUST WASTE WOOD OR residues WHICH areBEING BURNED
Whole logs used by Enviva to make pellets many of which are burned by Drax in the
UK Photo Dogwood Aliance
biomass faq bull august 2016 bull 4
timberrsquo They now argue that it isthe demand for high-quality andhigh-value timber by sawmills whichis responsible for the clearcutting offorests such as southern US wetlandforests They argue that all of thewood used for biomass electricityeffectively constituted residues leftover after sawmills have taken andused the wood they need [8]However as the US conservationNGO Dogwood Alliance hasexplained what Drax callslsquoresiduesrsquo accounts for 70 of aclearcut forest in the southernUS Without the demand for woodwhich sawmills cannot use therewould be no incentive for forestowners to clearcut entire forests [9]And out of the 30 of wood thatmight go to sawmills up to 50will be discarded as become alsquosawmill residuersquo which may alsobe used for biomass energy [10]Interestingly Drax in its reportto the electricity regulatorOfgem classifies nearly all of its
pellet use as lsquoresiduesrsquo but at thesame time states that 76-100 ofthem were made from saw logs
The UK follows the EuropeanCommissionrsquos guidance whichdefines processing residues as ldquoasubstance that is not the endproduct(s) that a productionprocess directly seeks to produceIt is not a primary aim of theproduction process and theprocess has not been deliberatelymodified to produce itrdquo In relationto lsquoforestry residuesrsquo it simplystates ldquoforestry residues areresidues that are directly producedby forestry they do not includeresidues from related industries orprocessingrdquo [11]
Effectively the term lsquoforestryresiduesrsquo is not defined at all Thisis why industry is getting away withclassing the wood they burn ndash mostof which comes from whole trees ndashas lsquolow gradersquo and lsquoresiduesrsquo
In 2012 the Governmentdepartment Defra published areview of research into the UKrsquoswaste wood market [6] It foundthat the UK is a net importer ofwaste wood and showed that thefact that a small and reducedproportion of waste wood still endsup in landfill is due to insufficientsegregated collections not to a lackof demand for waste wood Thewood panel industry was the largestconsumer of waste wood until 2013when it was overtaken by theenergy companies
The term lsquoresiduesrsquo on the otherhand is far more ambiguous andthus open to abuse Whenconservation NGOs startedpublishing photographic evidencethat pellet mills supplying Drax wereusing huge quantities of whole logs[7] Drax and their supportersincluding in the UKrsquos GreenInvestment Bank continued to classthose logs as lsquoresiduesrsquo or lsquolow-grade
Biomass is widely classed asinherently lsquocarbon neutralrsquo This isthe result of what scientists havedescribed as a serious lsquocarbonaccounting errorrsquo [12]
It goes back to negotiationspreceding the Kyoto Protocol whenit was decided that all emissionsassociated with loggingdeforestation and other landconversion associated withbioenergy should be attributed tothe land use and forestry sectorrather than to the energy sectorThis was to avoid the sameemissions being counted twice Butin reality it has led to them beingignored altogether policies aimedat reducing emissions from theenergy sector only look at emissionsin that particular sector So allowing
energy companies to class biomassburning as carbon neutral openedthe door to massive subsidies forbioenergy Meanwhile systemsaccounting for emissions fromlogging or land use change arenotoriously poor and flawed andthere are no incentives for reducingemissions related to importedbiomass at all
In reality biomass electricity alwaysresults in greater smokestackcarbon dioxide (CO2) emissions thanelectricity from coal (for the sameamount of electricity generated)lsquoCarbon neutralityrsquo means thatthose emissions are ignoredentirely based on the assumptionthat future plant growth willsequester all of that CO2 again butthis is a false assumption for
several reasons [13]
1 For the climate it makes nodifference at all what the differentsources of CO2 emissions are TheCO2 emitted from bioenergy causesglobal warming in the same way asCO2 emitted from burning fossilfuels Ignoring any type ofgreenhouse gas emissions mighthelp companies and policymakersbut it can never help the climate
2 If trees were not cut down forbioenergy then they would continueto grow and to sequester CO2 Yestrees and other vegetation mightgrow back and absorb CO2 in futurendash as they would have continueddoing in the absence of any loggingor land conversion for bioenergyOverall bioenergy still results in
Isnrsquot Biomass carbon neutral or at least low-carbon
biomass faq bull august 2016 bull 5
especially when they are clearcutEven when forests are left toregenerate rather than beinglogged again and again this cantake a very long time evencenturies In reality logged forestsare often converted to other landuses including to monoculture treeplantations which store far lesscarbon
5 Healthy forests play a majorrole in regulating the rainfall cyclestorm tracks and the nitrogen cycletoo all of which are vitallyimportant for a stable climateIndustrial tree plantations on theother hand deplete soils andfreshwater
There are often significant fossil fuelemissions associated with biomassenergy It takes a lot of energy tochip wood and far more still to turnit into wood pellets Logging
machines rely on diesel andshipping or trucking biomass relieson fossil fuels too However thosefossil fuel emissions areacknowledged by the UKgovernment and have to beaccounted for while the smokestackCO2 emissions and the emissionsassociated with logging are ignored
A list of scientific articles about theclimate impacts of wood-basedbiomass can be found atbiofuelwatchorgukbiomass-resourcesresources-on-biomass
more CO2 in the atmosphere andless CO2 sequestered
3 Even in the most optimisticscenario it takes decades for a newtree to grow back and re-absorb allof the carbon emitted when burningan existing tree So when trees arelogged for energy there will alwaysbe extra CO2 in the atmosphere fora period of several decades This iscalled the lsquocarbon debtrsquo and it is adebt which we cannot affordbecause climate science shows thatwe must drastically reduce carbonemissions now if we want to haveany chance of avoiding the worstimpacts of climate change
4 When forests are logged theymay not fully recover for a muchlonger period if ever A lot ofcarbon sequestered in forests isfound in soils and soil carbon is lostwhen forests are logged and
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 2
Biomass refers to any organicmatter derived from organismswhich are or recently were alive Inthe context of energy the EUdefines biomass as ldquothebiodegradable fraction ofproducts waste and residues frombiological origin from agriculture(including vegetal and animalsubstances) forestry and related
industries including fisheries andaquaculture as well as thebiodegradable fraction ofindustrial and municipal wasterdquo(Renewable Energy Directive Article2(e)
The term lsquobiomassrsquo is commonlyused to describe solid biomass usedfor energy such as wood straw or
grasses rather than liquid fuelsmade from biomass which arecalled biofuels (when used fortransport) or bioloqiuids norbiogas which is produced throughanaerobic digestion of biomassBioenergy can come from biomassbiofuelsbioliquids or biogas
what is biomass
Clearcutting of coastal swamp forests in North Carolina which
supplies wood to an Enviva pellet mill Dogwood Alliance
On the current scale that we aredemanding biomass yes ndash and ifdemand rises as expected it woulddestroy forests on a far a greaterscale than today Excessivedemand for wood ndash especially in theglobal North - is one of the mainunderlying causes of deforestationand forest degradation worldwide[1] Anything that further drives upthe demand for wood is going toworsen this situation
Negative impacts may be direct orindirect Perhaps the strongestevidence of direct impacts onforests comes from the southernUS and specifically from Draxrsquosmain US supplier Enviva Enviva is
the biggest pellet producer in theUS Conservation NGOs such asDogwood Alliance and NaturalResources Defense Council (NRDC)as well as journalists havedocumented how Enviva is sourcingwood for pellet plants from theclearcutting of highly biodiversecoastal wetland forests
Perhaps the strongest evidence ofdirect impacts on forests comesfrom the southern US andspecifically from Draxrsquos main USsupplier Enviva Enviva is thebiggest pellet producer in the USConservation NGOs such asDogwood Alliance and NaturalResources Defense Council (NRDC)
as well as journalists havedocumented how Enviva is sourcingwood for pellet plants from theclearcutting of highly biodiversecoastal wetland forests
Experience with the global pulp andpaper industry shows thatclearcutting of biodiverse forests isoften followed by the establishmentof monoculture tree plantationsRich forest ecosystems whichprovide habitat for thousands ofspecies and play an important rolein nutrient cycling and in regionalrainfall cycles are thus lost foreverIndustrial tree plantations on theother hand provide habitat for veryfew species deplete soils andfreshwater and often require aerialspraying with agro-chemicals
Indirect impacts are by theirnature more difficult to proveHowever a greater demand forwood will always drive up woodprices which encourages moreintensive and extensive logging andmore land conversion to treeplantations worldwide Sawmillresidues or waste wood that areburned for energy might otherwisehave been used to make paperpanel board or other productsThis can force those otherindustries to resort to moredestructive logging instead
DOES BURNING BIOMASS DESTROY FORESTS HOW
biomass faq bull august 2016 bull 3
The vast majority of biomassburned for electricity in the UK theEU and worldwide is wood Mostconverted coal power stationsincluding Drax and in futureLynemouth Power Station can onlyburn high-quality wood pelletswhich means wood pellets madefrom slow-growing trees with littlebark [2]
Agricultural residues and lsquoenergycropsrsquo have long been promoted asbioenergy but there are seriousproblems with using such sourceson a large scale Agriculturalresidues are of great importance formaintaining soil carbon and soilfertility and thus future crop yieldsRemoving too many of them
depletes and erodes soils and stopsthem from holding enough waterthus making crops more vulnerableto drought Agricultural residuesserve other purposes too In partsof the England for example pigfarmers rely heavily on purchasingstraw from cereal farmers Thereare serious concerns that burningof straw in power stations couldpush up straw prices so much thatsome pig farmers would go out ofbusiness [3] This could harmforests and the climate too if small-scale pig farmers who keep free-range pigs are forced out ofbusiness they will ultimately bereplaced by industrial factoryfarming which relies heavily onimported soya which is a major
driver of deforestation in SouthAmerica
Perennial grasses and short-rotation coppicing for example ofwillow and poplar are oftenpromoted as a sustainable sourceof bioenergy However all of themrely on land and compete witheither food production or wildlifehabitats ndash just as biofuel plantationsdo already Despite subsidiesfarmers have been reluctant toconvert land to short-rotationlsquoenergy cropsrsquo Less UK land is usedfor miscanthus or short-rotationcoppicing today than it was in 2009[4] There is no evidence that similarplantations have been successful inother countries either
What about burning biomass other than wood eg strawor miscanthus
Energy companies and proponentsof large-scale biomass burningoften claim that only waste woodand residues are being burned butevidence shows otherwise
Across the EU burning waste woodis regulated in the same way asburning other forms of waste Theterm refers to wood which has beenused for another purpose in thepast for example for construction
Much of it willhave beenchemicallytreated Almost700000 tonnes ofwaste wood wereburned in the UKin 201415 out ofa total of 15million tonnes ofwood [5] Wastewood thusaccounts for lessthan 5 of theUKrsquos electricityfrom wood Notall power stationsburning wood are
technically capable andorpermitted to burn waste wood andno converted coal power station inthe UK could burn it
ISNrsquoT IT JUST WASTE WOOD OR residues WHICH areBEING BURNED
Whole logs used by Enviva to make pellets many of which are burned by Drax in the
UK Photo Dogwood Aliance
biomass faq bull august 2016 bull 4
timberrsquo They now argue that it isthe demand for high-quality andhigh-value timber by sawmills whichis responsible for the clearcutting offorests such as southern US wetlandforests They argue that all of thewood used for biomass electricityeffectively constituted residues leftover after sawmills have taken andused the wood they need [8]However as the US conservationNGO Dogwood Alliance hasexplained what Drax callslsquoresiduesrsquo accounts for 70 of aclearcut forest in the southernUS Without the demand for woodwhich sawmills cannot use therewould be no incentive for forestowners to clearcut entire forests [9]And out of the 30 of wood thatmight go to sawmills up to 50will be discarded as become alsquosawmill residuersquo which may alsobe used for biomass energy [10]Interestingly Drax in its reportto the electricity regulatorOfgem classifies nearly all of its
pellet use as lsquoresiduesrsquo but at thesame time states that 76-100 ofthem were made from saw logs
The UK follows the EuropeanCommissionrsquos guidance whichdefines processing residues as ldquoasubstance that is not the endproduct(s) that a productionprocess directly seeks to produceIt is not a primary aim of theproduction process and theprocess has not been deliberatelymodified to produce itrdquo In relationto lsquoforestry residuesrsquo it simplystates ldquoforestry residues areresidues that are directly producedby forestry they do not includeresidues from related industries orprocessingrdquo [11]
Effectively the term lsquoforestryresiduesrsquo is not defined at all Thisis why industry is getting away withclassing the wood they burn ndash mostof which comes from whole trees ndashas lsquolow gradersquo and lsquoresiduesrsquo
In 2012 the Governmentdepartment Defra published areview of research into the UKrsquoswaste wood market [6] It foundthat the UK is a net importer ofwaste wood and showed that thefact that a small and reducedproportion of waste wood still endsup in landfill is due to insufficientsegregated collections not to a lackof demand for waste wood Thewood panel industry was the largestconsumer of waste wood until 2013when it was overtaken by theenergy companies
The term lsquoresiduesrsquo on the otherhand is far more ambiguous andthus open to abuse Whenconservation NGOs startedpublishing photographic evidencethat pellet mills supplying Drax wereusing huge quantities of whole logs[7] Drax and their supportersincluding in the UKrsquos GreenInvestment Bank continued to classthose logs as lsquoresiduesrsquo or lsquolow-grade
Biomass is widely classed asinherently lsquocarbon neutralrsquo This isthe result of what scientists havedescribed as a serious lsquocarbonaccounting errorrsquo [12]
It goes back to negotiationspreceding the Kyoto Protocol whenit was decided that all emissionsassociated with loggingdeforestation and other landconversion associated withbioenergy should be attributed tothe land use and forestry sectorrather than to the energy sectorThis was to avoid the sameemissions being counted twice Butin reality it has led to them beingignored altogether policies aimedat reducing emissions from theenergy sector only look at emissionsin that particular sector So allowing
energy companies to class biomassburning as carbon neutral openedthe door to massive subsidies forbioenergy Meanwhile systemsaccounting for emissions fromlogging or land use change arenotoriously poor and flawed andthere are no incentives for reducingemissions related to importedbiomass at all
In reality biomass electricity alwaysresults in greater smokestackcarbon dioxide (CO2) emissions thanelectricity from coal (for the sameamount of electricity generated)lsquoCarbon neutralityrsquo means thatthose emissions are ignoredentirely based on the assumptionthat future plant growth willsequester all of that CO2 again butthis is a false assumption for
several reasons [13]
1 For the climate it makes nodifference at all what the differentsources of CO2 emissions are TheCO2 emitted from bioenergy causesglobal warming in the same way asCO2 emitted from burning fossilfuels Ignoring any type ofgreenhouse gas emissions mighthelp companies and policymakersbut it can never help the climate
2 If trees were not cut down forbioenergy then they would continueto grow and to sequester CO2 Yestrees and other vegetation mightgrow back and absorb CO2 in futurendash as they would have continueddoing in the absence of any loggingor land conversion for bioenergyOverall bioenergy still results in
Isnrsquot Biomass carbon neutral or at least low-carbon
biomass faq bull august 2016 bull 5
especially when they are clearcutEven when forests are left toregenerate rather than beinglogged again and again this cantake a very long time evencenturies In reality logged forestsare often converted to other landuses including to monoculture treeplantations which store far lesscarbon
5 Healthy forests play a majorrole in regulating the rainfall cyclestorm tracks and the nitrogen cycletoo all of which are vitallyimportant for a stable climateIndustrial tree plantations on theother hand deplete soils andfreshwater
There are often significant fossil fuelemissions associated with biomassenergy It takes a lot of energy tochip wood and far more still to turnit into wood pellets Logging
machines rely on diesel andshipping or trucking biomass relieson fossil fuels too However thosefossil fuel emissions areacknowledged by the UKgovernment and have to beaccounted for while the smokestackCO2 emissions and the emissionsassociated with logging are ignored
A list of scientific articles about theclimate impacts of wood-basedbiomass can be found atbiofuelwatchorgukbiomass-resourcesresources-on-biomass
more CO2 in the atmosphere andless CO2 sequestered
3 Even in the most optimisticscenario it takes decades for a newtree to grow back and re-absorb allof the carbon emitted when burningan existing tree So when trees arelogged for energy there will alwaysbe extra CO2 in the atmosphere fora period of several decades This iscalled the lsquocarbon debtrsquo and it is adebt which we cannot affordbecause climate science shows thatwe must drastically reduce carbonemissions now if we want to haveany chance of avoiding the worstimpacts of climate change
4 When forests are logged theymay not fully recover for a muchlonger period if ever A lot ofcarbon sequestered in forests isfound in soils and soil carbon is lostwhen forests are logged and
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 3
The vast majority of biomassburned for electricity in the UK theEU and worldwide is wood Mostconverted coal power stationsincluding Drax and in futureLynemouth Power Station can onlyburn high-quality wood pelletswhich means wood pellets madefrom slow-growing trees with littlebark [2]
Agricultural residues and lsquoenergycropsrsquo have long been promoted asbioenergy but there are seriousproblems with using such sourceson a large scale Agriculturalresidues are of great importance formaintaining soil carbon and soilfertility and thus future crop yieldsRemoving too many of them
depletes and erodes soils and stopsthem from holding enough waterthus making crops more vulnerableto drought Agricultural residuesserve other purposes too In partsof the England for example pigfarmers rely heavily on purchasingstraw from cereal farmers Thereare serious concerns that burningof straw in power stations couldpush up straw prices so much thatsome pig farmers would go out ofbusiness [3] This could harmforests and the climate too if small-scale pig farmers who keep free-range pigs are forced out ofbusiness they will ultimately bereplaced by industrial factoryfarming which relies heavily onimported soya which is a major
driver of deforestation in SouthAmerica
Perennial grasses and short-rotation coppicing for example ofwillow and poplar are oftenpromoted as a sustainable sourceof bioenergy However all of themrely on land and compete witheither food production or wildlifehabitats ndash just as biofuel plantationsdo already Despite subsidiesfarmers have been reluctant toconvert land to short-rotationlsquoenergy cropsrsquo Less UK land is usedfor miscanthus or short-rotationcoppicing today than it was in 2009[4] There is no evidence that similarplantations have been successful inother countries either
What about burning biomass other than wood eg strawor miscanthus
Energy companies and proponentsof large-scale biomass burningoften claim that only waste woodand residues are being burned butevidence shows otherwise
Across the EU burning waste woodis regulated in the same way asburning other forms of waste Theterm refers to wood which has beenused for another purpose in thepast for example for construction
Much of it willhave beenchemicallytreated Almost700000 tonnes ofwaste wood wereburned in the UKin 201415 out ofa total of 15million tonnes ofwood [5] Wastewood thusaccounts for lessthan 5 of theUKrsquos electricityfrom wood Notall power stationsburning wood are
technically capable andorpermitted to burn waste wood andno converted coal power station inthe UK could burn it
ISNrsquoT IT JUST WASTE WOOD OR residues WHICH areBEING BURNED
Whole logs used by Enviva to make pellets many of which are burned by Drax in the
UK Photo Dogwood Aliance
biomass faq bull august 2016 bull 4
timberrsquo They now argue that it isthe demand for high-quality andhigh-value timber by sawmills whichis responsible for the clearcutting offorests such as southern US wetlandforests They argue that all of thewood used for biomass electricityeffectively constituted residues leftover after sawmills have taken andused the wood they need [8]However as the US conservationNGO Dogwood Alliance hasexplained what Drax callslsquoresiduesrsquo accounts for 70 of aclearcut forest in the southernUS Without the demand for woodwhich sawmills cannot use therewould be no incentive for forestowners to clearcut entire forests [9]And out of the 30 of wood thatmight go to sawmills up to 50will be discarded as become alsquosawmill residuersquo which may alsobe used for biomass energy [10]Interestingly Drax in its reportto the electricity regulatorOfgem classifies nearly all of its
pellet use as lsquoresiduesrsquo but at thesame time states that 76-100 ofthem were made from saw logs
The UK follows the EuropeanCommissionrsquos guidance whichdefines processing residues as ldquoasubstance that is not the endproduct(s) that a productionprocess directly seeks to produceIt is not a primary aim of theproduction process and theprocess has not been deliberatelymodified to produce itrdquo In relationto lsquoforestry residuesrsquo it simplystates ldquoforestry residues areresidues that are directly producedby forestry they do not includeresidues from related industries orprocessingrdquo [11]
Effectively the term lsquoforestryresiduesrsquo is not defined at all Thisis why industry is getting away withclassing the wood they burn ndash mostof which comes from whole trees ndashas lsquolow gradersquo and lsquoresiduesrsquo
In 2012 the Governmentdepartment Defra published areview of research into the UKrsquoswaste wood market [6] It foundthat the UK is a net importer ofwaste wood and showed that thefact that a small and reducedproportion of waste wood still endsup in landfill is due to insufficientsegregated collections not to a lackof demand for waste wood Thewood panel industry was the largestconsumer of waste wood until 2013when it was overtaken by theenergy companies
The term lsquoresiduesrsquo on the otherhand is far more ambiguous andthus open to abuse Whenconservation NGOs startedpublishing photographic evidencethat pellet mills supplying Drax wereusing huge quantities of whole logs[7] Drax and their supportersincluding in the UKrsquos GreenInvestment Bank continued to classthose logs as lsquoresiduesrsquo or lsquolow-grade
Biomass is widely classed asinherently lsquocarbon neutralrsquo This isthe result of what scientists havedescribed as a serious lsquocarbonaccounting errorrsquo [12]
It goes back to negotiationspreceding the Kyoto Protocol whenit was decided that all emissionsassociated with loggingdeforestation and other landconversion associated withbioenergy should be attributed tothe land use and forestry sectorrather than to the energy sectorThis was to avoid the sameemissions being counted twice Butin reality it has led to them beingignored altogether policies aimedat reducing emissions from theenergy sector only look at emissionsin that particular sector So allowing
energy companies to class biomassburning as carbon neutral openedthe door to massive subsidies forbioenergy Meanwhile systemsaccounting for emissions fromlogging or land use change arenotoriously poor and flawed andthere are no incentives for reducingemissions related to importedbiomass at all
In reality biomass electricity alwaysresults in greater smokestackcarbon dioxide (CO2) emissions thanelectricity from coal (for the sameamount of electricity generated)lsquoCarbon neutralityrsquo means thatthose emissions are ignoredentirely based on the assumptionthat future plant growth willsequester all of that CO2 again butthis is a false assumption for
several reasons [13]
1 For the climate it makes nodifference at all what the differentsources of CO2 emissions are TheCO2 emitted from bioenergy causesglobal warming in the same way asCO2 emitted from burning fossilfuels Ignoring any type ofgreenhouse gas emissions mighthelp companies and policymakersbut it can never help the climate
2 If trees were not cut down forbioenergy then they would continueto grow and to sequester CO2 Yestrees and other vegetation mightgrow back and absorb CO2 in futurendash as they would have continueddoing in the absence of any loggingor land conversion for bioenergyOverall bioenergy still results in
Isnrsquot Biomass carbon neutral or at least low-carbon
biomass faq bull august 2016 bull 5
especially when they are clearcutEven when forests are left toregenerate rather than beinglogged again and again this cantake a very long time evencenturies In reality logged forestsare often converted to other landuses including to monoculture treeplantations which store far lesscarbon
5 Healthy forests play a majorrole in regulating the rainfall cyclestorm tracks and the nitrogen cycletoo all of which are vitallyimportant for a stable climateIndustrial tree plantations on theother hand deplete soils andfreshwater
There are often significant fossil fuelemissions associated with biomassenergy It takes a lot of energy tochip wood and far more still to turnit into wood pellets Logging
machines rely on diesel andshipping or trucking biomass relieson fossil fuels too However thosefossil fuel emissions areacknowledged by the UKgovernment and have to beaccounted for while the smokestackCO2 emissions and the emissionsassociated with logging are ignored
A list of scientific articles about theclimate impacts of wood-basedbiomass can be found atbiofuelwatchorgukbiomass-resourcesresources-on-biomass
more CO2 in the atmosphere andless CO2 sequestered
3 Even in the most optimisticscenario it takes decades for a newtree to grow back and re-absorb allof the carbon emitted when burningan existing tree So when trees arelogged for energy there will alwaysbe extra CO2 in the atmosphere fora period of several decades This iscalled the lsquocarbon debtrsquo and it is adebt which we cannot affordbecause climate science shows thatwe must drastically reduce carbonemissions now if we want to haveany chance of avoiding the worstimpacts of climate change
4 When forests are logged theymay not fully recover for a muchlonger period if ever A lot ofcarbon sequestered in forests isfound in soils and soil carbon is lostwhen forests are logged and
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 4
timberrsquo They now argue that it isthe demand for high-quality andhigh-value timber by sawmills whichis responsible for the clearcutting offorests such as southern US wetlandforests They argue that all of thewood used for biomass electricityeffectively constituted residues leftover after sawmills have taken andused the wood they need [8]However as the US conservationNGO Dogwood Alliance hasexplained what Drax callslsquoresiduesrsquo accounts for 70 of aclearcut forest in the southernUS Without the demand for woodwhich sawmills cannot use therewould be no incentive for forestowners to clearcut entire forests [9]And out of the 30 of wood thatmight go to sawmills up to 50will be discarded as become alsquosawmill residuersquo which may alsobe used for biomass energy [10]Interestingly Drax in its reportto the electricity regulatorOfgem classifies nearly all of its
pellet use as lsquoresiduesrsquo but at thesame time states that 76-100 ofthem were made from saw logs
The UK follows the EuropeanCommissionrsquos guidance whichdefines processing residues as ldquoasubstance that is not the endproduct(s) that a productionprocess directly seeks to produceIt is not a primary aim of theproduction process and theprocess has not been deliberatelymodified to produce itrdquo In relationto lsquoforestry residuesrsquo it simplystates ldquoforestry residues areresidues that are directly producedby forestry they do not includeresidues from related industries orprocessingrdquo [11]
Effectively the term lsquoforestryresiduesrsquo is not defined at all Thisis why industry is getting away withclassing the wood they burn ndash mostof which comes from whole trees ndashas lsquolow gradersquo and lsquoresiduesrsquo
In 2012 the Governmentdepartment Defra published areview of research into the UKrsquoswaste wood market [6] It foundthat the UK is a net importer ofwaste wood and showed that thefact that a small and reducedproportion of waste wood still endsup in landfill is due to insufficientsegregated collections not to a lackof demand for waste wood Thewood panel industry was the largestconsumer of waste wood until 2013when it was overtaken by theenergy companies
The term lsquoresiduesrsquo on the otherhand is far more ambiguous andthus open to abuse Whenconservation NGOs startedpublishing photographic evidencethat pellet mills supplying Drax wereusing huge quantities of whole logs[7] Drax and their supportersincluding in the UKrsquos GreenInvestment Bank continued to classthose logs as lsquoresiduesrsquo or lsquolow-grade
Biomass is widely classed asinherently lsquocarbon neutralrsquo This isthe result of what scientists havedescribed as a serious lsquocarbonaccounting errorrsquo [12]
It goes back to negotiationspreceding the Kyoto Protocol whenit was decided that all emissionsassociated with loggingdeforestation and other landconversion associated withbioenergy should be attributed tothe land use and forestry sectorrather than to the energy sectorThis was to avoid the sameemissions being counted twice Butin reality it has led to them beingignored altogether policies aimedat reducing emissions from theenergy sector only look at emissionsin that particular sector So allowing
energy companies to class biomassburning as carbon neutral openedthe door to massive subsidies forbioenergy Meanwhile systemsaccounting for emissions fromlogging or land use change arenotoriously poor and flawed andthere are no incentives for reducingemissions related to importedbiomass at all
In reality biomass electricity alwaysresults in greater smokestackcarbon dioxide (CO2) emissions thanelectricity from coal (for the sameamount of electricity generated)lsquoCarbon neutralityrsquo means thatthose emissions are ignoredentirely based on the assumptionthat future plant growth willsequester all of that CO2 again butthis is a false assumption for
several reasons [13]
1 For the climate it makes nodifference at all what the differentsources of CO2 emissions are TheCO2 emitted from bioenergy causesglobal warming in the same way asCO2 emitted from burning fossilfuels Ignoring any type ofgreenhouse gas emissions mighthelp companies and policymakersbut it can never help the climate
2 If trees were not cut down forbioenergy then they would continueto grow and to sequester CO2 Yestrees and other vegetation mightgrow back and absorb CO2 in futurendash as they would have continueddoing in the absence of any loggingor land conversion for bioenergyOverall bioenergy still results in
Isnrsquot Biomass carbon neutral or at least low-carbon
biomass faq bull august 2016 bull 5
especially when they are clearcutEven when forests are left toregenerate rather than beinglogged again and again this cantake a very long time evencenturies In reality logged forestsare often converted to other landuses including to monoculture treeplantations which store far lesscarbon
5 Healthy forests play a majorrole in regulating the rainfall cyclestorm tracks and the nitrogen cycletoo all of which are vitallyimportant for a stable climateIndustrial tree plantations on theother hand deplete soils andfreshwater
There are often significant fossil fuelemissions associated with biomassenergy It takes a lot of energy tochip wood and far more still to turnit into wood pellets Logging
machines rely on diesel andshipping or trucking biomass relieson fossil fuels too However thosefossil fuel emissions areacknowledged by the UKgovernment and have to beaccounted for while the smokestackCO2 emissions and the emissionsassociated with logging are ignored
A list of scientific articles about theclimate impacts of wood-basedbiomass can be found atbiofuelwatchorgukbiomass-resourcesresources-on-biomass
more CO2 in the atmosphere andless CO2 sequestered
3 Even in the most optimisticscenario it takes decades for a newtree to grow back and re-absorb allof the carbon emitted when burningan existing tree So when trees arelogged for energy there will alwaysbe extra CO2 in the atmosphere fora period of several decades This iscalled the lsquocarbon debtrsquo and it is adebt which we cannot affordbecause climate science shows thatwe must drastically reduce carbonemissions now if we want to haveany chance of avoiding the worstimpacts of climate change
4 When forests are logged theymay not fully recover for a muchlonger period if ever A lot ofcarbon sequestered in forests isfound in soils and soil carbon is lostwhen forests are logged and
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 5
especially when they are clearcutEven when forests are left toregenerate rather than beinglogged again and again this cantake a very long time evencenturies In reality logged forestsare often converted to other landuses including to monoculture treeplantations which store far lesscarbon
5 Healthy forests play a majorrole in regulating the rainfall cyclestorm tracks and the nitrogen cycletoo all of which are vitallyimportant for a stable climateIndustrial tree plantations on theother hand deplete soils andfreshwater
There are often significant fossil fuelemissions associated with biomassenergy It takes a lot of energy tochip wood and far more still to turnit into wood pellets Logging
machines rely on diesel andshipping or trucking biomass relieson fossil fuels too However thosefossil fuel emissions areacknowledged by the UKgovernment and have to beaccounted for while the smokestackCO2 emissions and the emissionsassociated with logging are ignored
A list of scientific articles about theclimate impacts of wood-basedbiomass can be found atbiofuelwatchorgukbiomass-resourcesresources-on-biomass
more CO2 in the atmosphere andless CO2 sequestered
3 Even in the most optimisticscenario it takes decades for a newtree to grow back and re-absorb allof the carbon emitted when burningan existing tree So when trees arelogged for energy there will alwaysbe extra CO2 in the atmosphere fora period of several decades This iscalled the lsquocarbon debtrsquo and it is adebt which we cannot affordbecause climate science shows thatwe must drastically reduce carbonemissions now if we want to haveany chance of avoiding the worstimpacts of climate change
4 When forests are logged theymay not fully recover for a muchlonger period if ever A lot ofcarbon sequestered in forests isfound in soils and soil carbon is lostwhen forests are logged and
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 6
The impacts of biomass energydepend both on the sourcing of thebiomass and even moreimportantly on the scale Burningbiomass will always emit carboninto the atmosphere Howeverthere is a big difference between aninefficient power station such asDrax which burns wood sourcedfrom clearcutting large forests onthe one hand and coppicing treesto provide efficient local heating fora rural community on the otherhand
Small-scale use of local biomass bylocal rural communities can have alower-impact than the alternativesie fossil fuel burning ndash especiallywhen used for heating in off-gridareas But there is no way thatbiomass can sustainably replace asignificant proportion of fossil fueluse Thatrsquos because biomassespecially biomass electricity has amuch higher land footprint thanany other form of energy [14] It hassuch a high land footprint becausephotosynthesis is an extremely
inefficient way of capturing solarenergy Even fast-growing treesconvert just 1 of the solar energythey receive into biomass energy[15] - and the majority of that isthen lost as uncaptured heat whenthe biomass is burned in powerstations On the other hand a 15conversion efficiency of sunlight toenergy would be consideredrelatively low for a solar PV system[16]
Can biomass ever be sustainable and low-carbon
The EU Renewable Energy Directivedefines all biomass as renewableregardless of how it is produced orprocured [17] Biomass is thereforealso classified as renewable energyin the UK and currently accountsfor a large share of the UKrsquos socalled lsquorenewable energyrsquo [18] Inreality biomass allows energycompanies to attract vast subsidiesfor dirty energy falsely classed aslsquorenewablersquo rather than having toinvest in genuinely renewable
energy such as sustainable windand solar power
However the classification ofbiomass as renewable energycannot be reconciled with theInternational Energy Agencyrsquosdefinition of renewable energywhich is ldquoenergy derived fromnatural processes (eg sunlightand wind) that are replenished ata faster rate than they areconsumedrdquo [19] Clearly trees take
far longer to grow than they take tocut down and burn for energy
Biofuelwatch has joined 131 othercivil society groups in calling on theEU to exclude biomass (as well asbiofuels) from the scope of the EURenewable Energy Directivebiofuelwatchorguk2016bioenergyout-declaration
Is biomass electricity renewable energy
Yes Biomass power stations emit asimilar range and volume of airpollutants as coal power stationsalbeit more of some pollutants andless of others Compared to coalburning biomass burning emitsmore Volatile Organic Compoundsbut less sulphur dioxide and lessmercury [20]
These are some of the effects of thepollutants released by biomasscombustion on human health
bull Nitrogen dioxide (NO2) canaffect lung metabolism structure
function inflammation and hostdefence against pulmonaryinfections
bull Carbon monoxide (CO) inhibitsthe bloodrsquos ability to carry oxygen tovital organs such as the heart andbrain
bull Particulates PM exposure affectsthe respiratory and cardiovascularsystems in children and adults andextends to a number of largesusceptible groups within thegeneral population There are nosafe levels for small particulates
PM25 meaning that the slightestemissions of PM25 from a powerstation can harm health
bull Sulphur Dioxide Can result inbreathing problems for asthmaticchildren and shortness of breath
bull Heavy Metals and Dioxins andFurans Toxic and carcinogenic tohuman health Even lsquocleanrsquountreated wood can contain highconcentrations of heavy metalswhich when burnt can releasedioxins and furans Dioxinemissions are particularly high
DOES BIOMASS POLLUTE HOW DOES it AFFECT Peoplersquos health
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 7
Biomass power stations pose a clearrisk to local communities who livenearby and especially to vulnerablegroups ie people with underlyinghealth problems such as asthmachildren pregnant women andelderly people However across thewhole of the EU and UK populationthe health impacts of domesticwood stoves are especially severeAn article published in the BritishMedical Journal warns ldquoEmissionsfrom domestic wood burning are
increasing in the UK Theyaccounted for 17 of PM25emissions in 2013 only marginallyless than the 18 from all roadtransportrdquo [21]
when power plants are shut downand fired up
Burning chemically treated wastewood emits more differentpollutants and much greaterconcentrations of some pollutantscompared to burning virgin woodThis is discussed in detail in Chapter3 of our report Biomass ndash the Chainof Destructionbiofuelwatchorguk2013chain-of-destruction
Electricity from biomass isextremely inefficient Accordingto the International RenewableEnergy Agency conventionalbiomass power stations aretypically just 23-25 efficient [22]which means that they waste 75-77 of the biomass energy asuncaptured waste heat Efficiencyincreases with the size of a plant solarge biomass power stations tendto be more efficient than smallerones and may reach efficiency ratesas lsquohighrsquo as 35 which still meanswasting 65 of the energy in thewood Drax probably achieves thehighest conversion efficiency of anybiomass burning power station thatdoesnrsquot make use of heat around38 On the other hand some smallplants in particular small biomassgasification units which have beenproposed in the UK would reachefficiency rates of just 20 or evenless
Note that under EU RenewableEnergy Directive the UK is meant tobe promoting biomass technologieswhich provide at least 70efficiency rates [23]
It is worth being aware thatlsquoconversion efficiencyrsquo only looks atthe efficiency of the power stationitself It takes no account of theenergy used for example to chipwood or to turn it into pellets
HOW EFFICIENT IS BIOMASS ELECTRICITY
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 8
Most of the energy generated bypower stations is wasted asuncaptured heat Capturing andusing some or all of that heat willtherefore make plants moreefficient An efficient CombinedHeat and Power (CHP) plant canachieve 80 efficiency or evenmore [24]
However just because a biomassplant is classified as lsquoCHPrsquo it doesnot mean that it will be efficient
It is important to look at howmuch of its heat actually getsused Using just a small fraction ofthe waste heat will make littledifference to the plantrsquos overallcapacity The Governmentclassifies medium-size and largebiomass power stations as lsquoGoodQuality CHPrdquo if they achieve aslittle as 35 overall efficiencyThis is just half the efficiency levelwhich the EUrsquos Renewable EnergyDirective says governments shouldbe promoting Smaller powerstations can qualify as lsquoGood Quality
CHPrsquo with even lower efficienciesOnce a biomass power plant isclassed as lsquoGood Quality CHPrsquo itautomatically qualifies for a higherrate of subsidies if built beforeMarch 2017 and it can apply foreven more generous subsidies ifbuilt after that date whichelectricity-only biomass plants willnot get
35 efficiency is lower than theefficiency of many coal powerstations which donrsquot use any heat atall And it is much lower than theaverage efficiency of a modern gaspower station The lsquoGood QualityCHPrsquo definition basically allows anyoperator of a biomass powerstation to take advantage of lsquoCHPrsquosubsidies by using a tiny amount ofheat possibly just for drying thewoodchips they are going to burn inthe plant
In planning applications manydevelopers make optimistic claimsabout the amount of heat theycould supply It is important to
scrutinise these claims closely AlsquoHeat Supply Feasibility Assessmentrsquois not the same as a commitment toactually supply heat to anybodyAny power station is technicallycapable of supplying heat Thequestions are whether there arenearby industries and propertieswith a demand for this heat andwhether anybody is going to pay forthe heat pipes Heat pipes are notcheap and in the UK there has beenvery little investment in districtheating networks If an energycompany does not promise toinstall such heat pipes then theycannot be expected to actuallysupply any heat
It is also important to rememberthat efficient is not the same assustainable Degrading anddestroying forests for biomassenergy will never be sustainableregardless how efficiently the woodis burned
What about combined heat and power with biomassIs this more efficient and sustainable
According to the most recent Ofgemdata pellets and woodchips madefrom almost 15 million tonnes ofwood were burned in UK powerstation [25] By comparison theUKrsquos total wood production is 11million tonnes a year [26]
bull Just over 3 million tonnes of virginwood from the UK were burnedfor electricity which is 29 of theUKrsquos entire annual woodproduction
bull Nearly 700000 tonnes of UKwaste wood were burned forelectricity Since 2013 biomass hasovertaken panelboard productionas the single biggest use for wastewood [27]
bull All imported wood burned forelectricity has so far been burnedin converted coal power stations In201415 Drax burned importedpellets made from 91 milliontonnes of wood Most of thosecame from the southern US with
Canada and the Baltic States a jointsecond Ironbridge Power Stationburned pellets made from just over2 million tonnes of wood most ofthem from the southern USIronbridge Power Station has sincebeen closed but large new import-reliant power station projects areunderway (see below)
bull Drax power station continues toburn more biomass than any othercompany In 2015 they burnedpellets made from around 12
HOW MUCH BIOMASS IS CURRENTLY BEING BURNT FORELECTRICITY IN THE UK
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 9
biofuelwatchorgukaxedrax-campaign
In 2015 Drax burned more thanone-fifth of the global wood pelletproduction The EU is by far thebiggest consumer and importer of
wood pellets for energy in theworld and in turn the UK is thelargest consumer in the EU [28]
million tonnes of wood (even morethan during the period 201415) aswell as 6 million tonnes of coal Forfull details about Drax theirbiomass and coal burning theirsubsidies and the campaign toAxeDrax see
In addition to the 201415 figuressummarised above biomass powerstation projects which betweenthem could burn over 23 milliontonnes of wood a year have beenapproved or have recently opened ndashnot including smaller plants of lessthan 15 MW capacity (ie ones thatwould burn less than 150000tonnes of wood annually) Not all ofthe biomass plants that have beenapproved are likely to be builtHowever capacity for burning over6 million tonnes of wood a year hasrecently been opened is underconstruction or will start beingconstructed shortly More projectscould be proposed and approved atany time
The biggest and most imminentnew developments are
bull The conversion of the mothballedLynemouth Power Station tobiomass by the Czech energy
company EPH They will be burningpellets made from around 3 milliontonnes of wood a year Much of thewood will come from Enviva whoalso supply Drax and who havebeen shown to use wood fromclearcut biodiverse coastal swampforests See here for more detailsabout this projectbiofuelwatchorguk2016lynemouth-briefing
bull A massive 299 MW power whichUK company MGT Power is about tobuild at Teesport This will burn upto 3 million tonnes of wood a yearUp to two-thirds of this will besupplied by Enviva whorsquoresupplying Drax and who will supplyLynemouth Power Station too
Three very large biomass powerplants are proposed in Wales
bull Orthios Energy has announcedthat they want to build two massive
biomass power stations whichwould each be as big as the onebeing built by MGT Power atTeesport though one media reportsays that one of the two plants maybe even larger One of the powerstations would be built in PortTalbot the other in HolyheadAnglesey Planning permissions forbiomass power stations this sizewere granted in the past but it isnot clear in how far theycorrespond with Orthios Energyrsquosplans See here for moreinformationbiofuelwatchorguk2015welsh-biomass-proposals
bull A Cypriotic-Welsh company calledEgnedol Ltd has announced plansfor what ultimately be a 350 MWbiomass power station usinggasification technology This wouldbe built in Milford Haven Egnedol isapplying for planning consent for afirst 50 MW unit in the first
HOW Much wood could be burned for electricityin the UK in future
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 10
concerned about the local impactsof any attempts to operate such aplant See here for more detailsbiofuelwatchorguk2016blackbridge-report
Please see our UK map of existingapproved proposed closed and
abandoned biomass power stationsprojects of 15 MW or greatercapacity herebiofuelwatchorgukwp-contentmapsuk-biomasshtml
instance but has said that it wantsto scale it up seven-fold within threeyears (for which theyrsquod need newplanning consent) They state thatthey want to use both wood andwaste-derived fuel Biofuelwatchbelieves that the proposal is nottechnically credible but is
On 1st December 2015 the UKgovernment introduced greenhousegas and sustainability standard [29]Biomass electricity and heat whichdoes not meet the standards is noteligible for renewable energysubsidies [30] However there areso many loopholes in thesestandards that Biofuelwatchconsiders them to be meaningless[31] See here for a critical debate ofthe principle of bioenergysustainability standardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
The greenhouse gas standardssets a maximum level ofgreenhouse gas emissions whichmust not be exceeded by biomasselectricity or heat Until 2020 twodifferent levels exist for biomasselectricity One which must be metby biomass power stations builtafter March 2013 the other forolder biomass plants and forconverted coal power station unitssuch Draxrsquos converted units Themaximum emissions figure will bereduced in 2020 and again in 2025Until 2025 biomass can besubsidised as lsquolow carbonrsquo even ifthe carbon emission attributedto it are much higher than thosefrom burning natural gas
However an even more seriousflaw is the fact that the vastmajority of greenhouse gasemissions associated withbiomass energy are simplyignored All of the carbonemissions emitted when biomass isburned are ignored The onlyemissions which must be declaredare those arising from fossil fuelburning during logging woodprocessing (eg pellet production)and transport emissions fromfertiliser use on tree plantationsand carbon emissions from lsquolanduse changersquo However clearcuttinga forest is not classed as lsquoland usechangersquo as long as the forest is notconverted to agriculture or the landis used for construction Convertinga biodiverse carbon-rich forest to asterile industrial tree plantation isnot classed as lsquoland-use changersquoeither Nearly all of the emissionsassociated with logging aretherefore ignored
At first sight the sustainabilitystandards ndash or lsquoland criteriarsquo ndashmight appear more comprehensivethan the greenhouse gas standardsFor example they state thatbiomass must come from forests(or plantations) where the lsquohealthand vitality of ecosystemsrsquo ismaintained where biodiversity ismaintained and where harm toecosystems is lsquominimisedrsquo On
closer inspection however thesestandards are deeply flawed tooFirstly they emphasise the need forplans and policies for lsquomanagingrsquoforests and plantations rather thanthe need to observe for examplebiodiversity is actually protectedAnd secondly developers candemonstrate compliance withboth sets of standards by payinga consultant of their choice tolsquoconfirmrsquo that all of the standardsare met There is no independentverification or auditing at allThis is a recipe for fraud Forexample in 2013 the governmentadmitted in relation to biofuels fortransport which have been subjectto greenhouse gas andsustainability standards since 2010ldquothe Administrator noted that thevolumes of used cooking oil (UCO)derived biofuel being reported ascoming from the Netherlands wereimplausibly high based on thepopulation size In other wordscompanies must have wronglydeclared the origin of their biofuelsFor all we or the governmentknow some of the supposed lsquousedcooking oil from the Netherlandsrsquomay have been virgin palm oil fromIndonesia
Energy companies have yet anotheroption for lsquoprovingrsquo compliance withthe sustainability standards onewhich does not require energy
hasnrsquot THE GOVERNMENT INTRODUCed RULES UNDER WHICH ONLYSUSTAINABLE and low-carbon BIOMASS WILL BE SUBSIDISED
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 11
[33] The SBP claims lsquoindependencersquobecause their members and boardmembers are not directly involvedin the certification assessments Butthis is a spurious The standardsand all of the rules are set by theSBP themselves so they effectivelyguarantee the SBP members thecertificates they want
There is plenty of scope for the UKrsquosbiomass sustainability andgreenhouse gas standards to beimproved However thefundamental problem with the ideaof sustainability standards andcertification is that is for what isultimately an artificial market - anew market for wood created andmaintained through publicsubsidies After all the most seriousimpacts of biomass energy relate to
its scale No standards can evermake an unsustainable demandsustainable -standards cannotcredibly address the indirectimpacts of biomass energy Finallyany genuinely meaningful standardsare likely to be challenged throughthe World Trade Organisation andmay thus not be enforceable Seehere for a critical debate of theprinciple of bioenergy sustainabilitystandardsbiofuelwatchorguk2014biomass-sustainability-standards-briefing
companies to pay their ownconsultants to provide reports on allbiomass consignments They canshow that wood has been certifiedby an ldquoaccredited voluntarycertification schemerdquo Remarkablythe only scheme recognised inguidance to the legislation aslsquoprovingrsquo 100 compliance withthe sustainability standards is ascheme set up and administeredexclusively by European energycompanies The SustainableBiomass Partnership (SBP) [32]The SBP Board is chaired by noneother than Draxrsquos CEO DorothyThompson Not surprisingly Draxhas already been granted an SBPcertificate which qualifies all of thepellets produced by their own pelletmills in the southern US as meetingthe UKrsquos sustainability standards
The United Kingdom governmenthas a target to provide 15renewable energy by 2020 and isbound by EU law to do so Thegovernment predicts most of theoverall target will be met throughrenewable electricity Subsidies arethe main instrument used to tryand meet this target There arecurrently three subsidy schemes forrenewable electricity that applyacross the UK
Feed-in Tariffs (FiTs) Those areavailable for small-scale generationup to a capacity of 5 MW or 2kW formicro combined heat and powerusing bioenergy Feed-in tariffs havebeen particularly important forsolar PV but they have hardly everbeen used for biomass [34]
Renewables ObligationCertificates (ROCs) Any electricitygenerating project classed asrenewable automatically qualifiesfor ROCs provided that it is
commissioned by March 2017 (witha limited extension of that period insome cases) This includes allbiomass power plants provided thatthey meet the sustainability andgreenhouse gas standardsdiscussed above So far ROCs havebeen by far the biggest driverbehind the expansion of biomasselectricity in the UK Under theRenewables Obligation electricitycompanies are obliged to supply apercentage of their electricity fromrenewables which increases yearon year A penalty is imposed onthose suppliers who do not meetthe targets CorrespondinglyOfgem issues ROCs to electricitygenerators for every unit of eligiblerenewable electricity which theysupply The market value of ROCsvaries slightly On average one ROCwas worth pound4269 in 2015 [35]Different renewable electricitytechnologies are eligible fordifferent amounts of ROCs In201516 coal-to-biomass
conversion attracts one ROC perMWh So to calculate how muchsubsidy a biomass-burning powerplant attracts one has to multiplythe number of Megawatt hoursgenerated per year by the numberof ROCs for which the particularlytechnology is eligible
Energy suppliers pass the cost ofROCs onto customers via asurcharge on electricity bills Thegovernment estimated the totalsurcharge for ROCs as pound36 a yearout of an average annual electricitybill of pound627 a year - however thatincludes ROCs for wind and solarprojects which are genuinelyrenewable and low-carbon [36]
Contracts for Difference (CfDs)CfDs were introduced through theEnergy Act 2013 as part of the thengovernmentrsquos Energy MarketReform A CfD takes the form of alsquostrike pricersquo This is a fixed pricewhich generators of renewable
Why and how is biomass electricity subsidised in the UK
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 12
get both ROCs and a CfD for thesame scheme
From April 2017 onwards ROCs willno longer be available for newschemes (though there areprovisions for extending this periodfor schemes already underconstruction at that time)Companies which already receiveROCs will continue to do so until2027 but new ones have to applyfor a CfD instead
CfDs are awarded through acompetitive process in whichcompanies have to put a closed bidfor the lowest strike price they arehappy to accept into an auction Thelowest proposals are then chosenBefore each auction thegovernment announces which typesof schemes (ie which technologygroups) can compete There may beseparate auctions for differenttechnology groups at the sametime However the first awards ofCfDs made in 2014 were notsubject to competition and strikeprices for those awards had beenset by the government in advance
So far CfDs have been awarded tothree large biomass electricityprojects
bull The conversion of one of Draxrsquos sixpower station units to biomass (theother two converted units aresubsidised through Drax)
bull MGTrsquos large new biomass powerstation which has now attractedenough investment for constructionto start and which will burn pelletsfrom a US company shown to usewood from clearcut biodiversecoastal swamp forests
bull The conversion of the mothballedLynemouth Power Station tobiomass which will use pellets fromhat same US company (Enviva)
The CfD award to Drax is currentlybeing investigated by the EuropeanCommission which means thatDrax has not yet received thisparticular subsidy Further CfDallocations are expected later in2016
electricity (as well as nuclearpower) are guaranteed per unit ofelectricity Strike prices aresubstantially higher than the marketprice for the electricity Thedifference between the strike priceand the market price is the subsidy
There are two main differencesbetween ROCs and CfDs
bull Companies need to compete forCfDs and only a small number ofschemes will be awarded themwhereas companies have anautomatic entitlement to ROCsprovided they generate renewableelectricity that falls within the scopeof ROCs
bull CfDs are more generous thanROCs and they give energycompanies long-term priceguarantees and thus protect themfrom market fluctuations
From April 2014 to March 2017companies generating renewableelectricity can apply either for ROCsor for a CfD If they are refused aCfD then they can still apply forROCs instead However they cannot
UK governments have longsupported biomass electricity as akey component for meeting therenewable energy target Since theConservative Government came topower in 2015 they havesignificantly cut support foronshore wind and solar PVOnshore wind is currently the singlebiggest contributor to renewableelectricity generation in the UK(unless biomass is added togetherwith biogas and all types ofelectricity from waste in which caseit surpasses onshore wind) [37]However the Government has
announced that no new Contractsfor Difference will be granted foronshore wind and solar power andit has also stopped developers fromapplying for ROCs for such schemessince April 2016 Feed-in-tariffs forsolar PV and onshore wind havebeen cut And in England changesto planning policy make it far easyfor local objectors to stop onshorewind turbines [38] - lsquocommunityrightsrsquo which do not extend tocommunities objecting to wasteincinerators biomass plants andother polluting developments All ofthose policies are expected to
drastically curtail the expansion ofonshore wind and solar PV in theUK in future This means that theGovernment will have to rely evenmore heavily on biomass electricityif they want to meet renewableenergy targets
How does the UKrsquos support for biomass compare to thatfor wind and solar power
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 13
Several biomass power stationapplication have been rejected orwithdrawn in response to localcampaigns against them
Those include large import-reliantpower stations in Leith (Edinburgh)and Dundee which had beenproposed by Forth Energy a (nowdissolved) partnership of SSE andForth Ports two biomass powerstations proposed by the no longerexisting company Bio E Plc in Walesand a proposal that involved abioliquid and a biomass combinedheat and power plant as well as apellet mill in Anglesey Wales
In another case a company calledPrenergy obtained planning consentfor what would still be the worldrsquoslargest purpose-built biomasspower station in Port Talbot
However Prenergy went out ofbusiness after local campaignerspersuaded planners to refuse achange of their planning consentwhich would have allowed them toburn pellets as well as woodchips
Planning policies across the UK areheavily biased in favour ofdevelopers and it can be difficultand often impossible to stopapplications through the planningprocess Nonetheless there isstrong evidence that active localcampaigns can succeed even if theplanning consent they oppose isgranted several developments thatwere strongly and very publiclyopposed by local residents havebeen abandoned despite gettingplanning consent while others havebeen quietly shelved Those includethe two other large biomass power
stations proposed by Forth Energyin Grangemouth and Rosyth as wellas a large biomass power stationproposed by Helius Energy Someinvestors are reluctant to getinvolved in highly contentiousprojects And in some caseshighlighting particular risks andproblems associated with aproposal might put off otherinvestors
Biofuelwatch offers support andadvice to any local residentsconcerned about a biomass (orbioliquid) power plant proposal intheir area
Have local campaigns against biomass power stationsbeen successful in the uk
[1] See for example Getting to the Roots
Underlying causes of deforestation and
forest degradation and drivers of forest
restoration Global Forest Coalition 2010
globalforestcoalitionorgwp-
contentuploads201011Report-Getting-to-
the-roots1pdf
[2] This is due to the fact that other types of
biomass contain more alkali salts which
corrode coal power station boilers
biofuelwatchorgukdocsDECC20FoI20E
IR2013-034020Q120Documents20
Drax20etc209May202013pdf It
applies to all subcritical pulverised fuel coal
power stations which means to all coal
power stations in the UK and most
worldwide (albeit not to the Gardanne
power station which is being converted to
biomass by EOn in France) This doesnrsquot
apply to limited co-firing of biomass with
coal in the same power station unit only to
coal-to-biomass conversions
[3] dissexpresscouknewslatest-
newsthousands-of-jobs-at-risk-if-
mendlesham-straw-fired-power-station-
goes-ahead-says-claim-1-6076233
[4] govukgovernmentuploadssystem
uploadsattachment_datafile483812nonfo
od-statsnotice2014-10dec15pdf
[5] ofgemgovukpublications-and-
updatesbiomass-sust
[6] Wood waste A short review of recent
research Defra 2012 govukgovernment
uploadssystemuploadsattachment_datafi
le82571consult-wood-waste-
researchreview-20120731pdf
[7] dogwoodallianceorgwp-
contentuploads201211Whole-Tree-
Wood-Pellet-Production-Reportpdf
[8] draxcommedia41941biomass-
sustainabilty-faqspdf
[9] See interview with Danna Smith
Executive Director of Dogwood Alliance in
Biofuelwatchrsquos report Biomass The Chain of
Destruction 2013
biofuelwatchorguk2013chain-of-
destruction
[10] govukgovernmentuploadssystem
uploadsattachment_datafile343005Respo
nse_to_Biomass_Consultationpdfl 356
[11] Renewables Obligation Sustainability
Criteria (England Wales and Scotland)
references amp notes
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370
biomass faq bull august 2016 bull 14
Guidance 1st December 2015
ofgemgovuksitesdefaultfilesdocsro_sus
tainability_criteria_guidance_eswpdf page
13 citing European Commission
communication 2010C 16002
[12] See for example Corecting a
fundamental error in greenhouse gas
accounting related to bioenergy Helmut
Haberl etal Energy Policy June 2012
sciencedirectcomsciencearticlepiiS03014
21512001681
[13] See biofuelwatchorgukbiomass-
resourcesresources-on-biomass for a
complication of scientific studies on this
topic
[14] Energy Sprawl or Energy Efficiency
Climate policy impacts on natural habitats
for the United States of America Robert I
McDonald et al PLoS ONE August 2009
journalsplosorgplosonearticleid=101371
journalpone0006802
[15] treehuggercomrenewable-energyall-
biofuels-are-nonsense-says-nobel-winning-
photosynthesis-expert-hartmut-michelhtml
[16] greenmatchcoukblog201411how-
efficient-are-solar-panels
[17] eur-lexeuropaeulegal-
contentENTXTPDFuri=CELEX32009L002
8ampfrom=EN
[18] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf
[19] ieaorgaboutusfaqsrenewableenergy
[20] pfpinetair-pollution-2
[21] Another misguided policy ndash wood
stoves as many PM25 as roads amp increased
global warming Dorothy L Robinson British
Medical Journal June 215
bmjcomcontent350bmjh2757rr-0
[22] irenaorgDocumentDownloads
PublicationsRE_Technologies_Cost_Analysis-
BIOMASSpdf
[23] Article 18 (6) Renewable Energy
Directive 2009 eur-lexeuropaeulegal-
contentENTXT
PDFuri=CELEX32009L0028ampfrom=EN
[24] httpswwwieaorgpublications
freepublicationspublicationessentials3pdf
[25] See ofgemgovukpublications-and-
updatesbiomass-sustainability-dataset-
2014-15 Note Biofuelwatch has calculated
the total figures as comprising green tonnes
of virgin wood plus tonnes of waste wood
This is based on the following assumptions
bull One tonne of wood pellets requires two
green tonnes of wood
bull One tonne of sawdust or woodchips
requires 117 green tonnes of wood
bull Waste wood is not converted to green
wood because it is wood which has been
previously used for example as construction
or fencing material
bull A green tonne of wood refers to the weight
of freshly logged wood
[26] Annual UK wood production was 11
million green tonnes in 2015
forestrygovukforestrybeeh-a9zjnu
[27] letsrecyclecomnewslatest-
newsbiomass-is-now-largest-market-for-
waste-wood
[28] Based on figures in the US Department
of Agriculturersquos Global Agricultural
Information Network report ldquoEU 28 Biofuels
Annual 2016rdquo
gainfasusdagovRecent20GAIN20
PublicationsBiofuels20Annual_The2
[29] See legislationgovukuksi20151947
pdfsuksi_20151947_enpdf for the Statutory
Instrument and govukguidance
sustainability-standards-for-electricity-
generation-from-biomass
[30] for the guidance document Some
forms of biomass are exempt from either
the greenhouse gas or the sustainability
standards or both however nearly all virgin
wood used for biomass energy is covered
[31] biofuelwatchorguk2016uk-biomass-
standards-briefing
[32] sustainablebiomasspartnershiporg
[33] See theecologistorgessays2988028
are_the_uk_biomass_sustainability_standard
s_legitimisi
[34] Biomass only attracts Feed-in-tariffs
(FiTs) if burned in combined heat and power
units of up to 3 kW The government had
envisioned up to 30000 such units financed
through FITs but as of 2015 only 501 had
been installed govukgovernmentuploads
systemuploadsattachment_datafile53584
2FITs_ADmCHP_consultation_document_Ma
y_2016_1_-_14_July_deadlinepdf
[35] See epowerauctionscouk
eroclatesthtm
[36] govukgovernmentuploadssystem
uploadsattachment_datafile384404Pri
[37] govukgovernmentuploadssystem
uploadsattachment_datafile540953Chapt
er_6_webpdf table 64
[38] researchbriefingsparliamentuk
ResearchBriefingSummarySN04370