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The UK government is strongly supportive of biomass. It regards biomass as a means of increasing energy security, and new biomass plants as part of the necessary replacement of the extensive generation capacity that will be shut down over the next decade. It also regards biomass as  a major contributor to meeting the UK’s EU renewable energy target (15% of all energy by 2020), and as an important contributor to carbon reductions – though it has stressed that not all biomass is sustainable, in climate or biodiversity terms.  And it regards biomass expansion as a good means of strengthening the British agricultural and forestry sectors. 

Beyond – an increasingly within – government there is an extensive and highly contested debate about the role that biomass should play in the transition to low-carbon energy. The debate about biofuels has been active for several years, across Europe and in the UK.  Since 2009, when the Environment Agency published its report Biomass: carbon sink or carbon sinner?, the debate has been extended to solid biomass, with government ministers and officials and environmental NGOs acknowledging the importance of the issue – though not yet reaching conclusions or taking firm positions. The EU has adopted mandatory sustainability criteria for biofuels, but it is still up to member-state governments whether to implement the sustainability criteria for biomass. The UK government has opted to implement them.

The UK’s 2010 National Renewable Energy Action Plan, published after the change of government, envisages that bioenergy will account for around half of the UK’s target of 15% of all energy to comes from renewables by 2020. This plan envisages that around 30% of electricity, 12% of heat and 10% of transport fuel will be from renewables by 2020.

The last UK biomass strategy was published in 2007. The Energy White Paper and Renewables Roadmap aren’t particularly explicit on biomass  (see The UK’s Energy White Paper and Renewables Roadmap). DECC is currently working on a bioenergy strategy, which will cover biomass, biogas and biofuels. This is promised for ‘late summer’.

Environment Agency’s 2009 Report

The Environment Agency’s 2009 report Biomass: carbon sink  or carbon sinner? concludes that:

Greenhouse gas emissions from energy generated using biomass are generally, but not always, less than from fossil fuels.

The report recognises the emissions reduction potential of short rotation coppice chips, but notes that using straw can produce over 35% more emissions for each unit of electricity than a combined cycle gas turbine power station.

How a fuel is produced has a major impact on emissions.

“Transporting fuels over long distances and excessive use of nitrogen fertilisers can reduce the emissions savings made by the same fuel by between 15% and 50% compared to best practice.”

Land use change can negate any emission savings.

“Using formerly fallow land to grow bioenergy crops can reduce emission savings from a fuel by up to 10 per cent.  Planting on permanent grassland is worse, with emissions savings significantly reduced and in some cases reversed.”

By 2030, all biomass electricity will need to be produced using good practice.

“In the short term, improvements in energy conversion efficiency and lifecycle emissions from biomass fuels will help to reduce emissions. However by 2030 some fuels will be at risk of becoming redundant….It is difficult, if not impossible in some cases, to retrofit a combined heat and power system, which makes it imperative that biomass plants – like all other new power stations – are designed to utilise heat from the outset. If they are not, and if the plants cannot be retro-fitted, operators risk being left with stranded assets within 20 years.”

Co-firing biomass is a good short term measure to reduce emissions, but unless carbon capture and storage can be deployed and preferably the heat utilised, it does not have a long term role.

“By 2030 the carbon intensity of the electricity grid will mean that even with co-firing of biomass, coal-fired power stations will have to have carbon capture and storage operational. There should also be a strong presumption in favour of combined heat and power for new plant.”

The report calls for the “development of mandatory minimum standards for the greenhouse gas savings achieved by biomass fuels used to generate heat and power”.

The Environment Agency has been widely criticised by biomass producers and users for the unhelpfulness of this report, but not on the accuracy of the arguments or statistics. The only factual criticism has been about direct land use change. The Agency report suggests that permanent grassland is being converted into miscanthus production. The biomass industry and farmers argue that this is not happening. (In fact, it is in some places, but is not widespread.)

EU biomass sustainability standards

The EU has mandatory sustainability standards for biofuels, but the standards for solid biomass are voluntary, so national governments can decide whether or not to use them. The UK government has opted to do so.

The 2009 Renewable Energy Directive required to European Commission to assess the need for sustainability criteria for biomass other than biofuel. A Commission report in February 2010 argued that mandatory biomass criteria were not necessary. Instead, it put forward recommended criteria, similar to those already in force for biofuels, under which the use of biomass would have to deliver  at least 35% lower greenhouse gas emissions than would a fossil fuel comparator. This minimum emissions reduction would increase to 60% by 2017.

The Commission view that mandatory criteria were not needed for biomass was based on four factors:

• Existing legislation and voluntary schemes at European and national levels provide for a framework for sustainable biomass production in the agriculture and forestry sectors as well as a framework for waste management.
• Countries outside the EU might have lower sustainability standards, but In 2007-2008 only 3-5% of biomass for energy was imported into the EU.
• The life-cycle greenhouse gas performance of most types of solid and gaseous biomass used in electricity, heating and cooling was assessed to be high.
• There are many small-scale and local producers of bio-heat and bio-electricity in the EU who might not be able to bear the additional administrative costs of proving sustainability, even though production is sustainable.

The Öko-Institut  published a report in April 2011, Sustainable Bioenergy:  Key Criteria and Indicators.  This was funded by the European Commission. It states that:

• By 2020, all land with a potential for biomass cultivation should be fully recognized in a global GIS database sufficiently in resolution to unanimously identify high-biodiverse areas.
• The EU’s recommended sustainability criteria are a good start, but minimum reduction levels for bioenergy should also be set  for 2020 and 2030.
• Effects from direct land use changes  are already factored into the calculation, but indirect land use changes must be taken into account as well. (‘Direct land use change’ means where, for example, forests are felled to provide land to grow energy crops. ‘Indirect land use change’ is when energy crops are grown on arable land formerly used to grow food, so that further land has to be found to grow the food, leading potentially to deforestation or ploughing up of grasslands.)
• Water used for irrigation of bioenergy feedstock cultivation and in bioenergy plants must not result on more water being used in a region than is naturally replenished.

The Commission is committed to producing a further report by the end of 2011, on whether there should be EU-wide sustainability criteria. A number of countries, including the UK, Germany, the Netherlands and Belgium are in favour of strong mandatory EU standards.  Sweden, Finland and the Baltic countries oppose mandatory EU standards. Swedish and Finnish opposition is because they currently use standards which are strong on wildlife and landscape protection but do not include the carbon footprint.

Renewables trade associations  are increasingly in favour of sustainability criteria for biomass being agreed and set at European level, because the existence of several national schemes makes their operations more difficult and costly.

The UK has adopted the EU’s non-mandatory standards for biomass sustainability. In April 2011 the Government began using bio-energy sustainability standards under the Renewables Obligation.  These will not be changed in the banding review or white paper.  These standards state that solid biomass and biogas electricity must have a carbon intensity of 285.12 kgCO2/MWh or lower to be eligible for ROCs from April 2013. Direct land use is taken into account in calculating the carbon footprint – using the criteria included in the EU Renewable Energy directive. DECC has said that it will also consider including indirect land use change criteria in the assessment of biomass and biogas – as the European Commission is currently considering for biofuels.

These standards include a mandatory reporting obligation for all generators above 50Mw, which builds on the reporting requirements in place since 2009.

Biomass wholly derived from waste, landfill gas or sewage gas will not need to meet the sustainability criteria and will not need to report on sustainability. This is because these are already covered by EU waste directives.

DECC is not under pressure to lower the standards in order to make biomass use more extensive. The standards are basically about removing the worst forms of biomass – such as cleared rainforest timber being shipped round the world – rather than setting very high standards.

NGO attitude to biomass

The NGO most active on biomass is Friends of the Earth (FoE).  FoE accepts that biomass is part of the solution to climate change, as long as the biomass is sustainable. It argues that the risks include: increasing emission of climate change gases;  damaging food security; damaging ecosystems and biodiversity; exacerbating social conflict.

FoE supports: anaerobic digestion of food and agricultural waste: use of waste wood (burnt in clean, wood-only burners); sustainable production of local energy crops for local consumption; use of cereal straw; short rotation coppice (willow/poplar).  FoE also argues that there should be “upper limit set for biomass according to what can be produced sustainably in Europe”.

There is growing public opposition to biomass being imported into the UK, based on the import of wood or energy crops into the UK being seen as counter-intuitive. Nevertheless, the government remains committed to biomass expansion.  It has continued to co-finance (with the EU) the Energy Crops Scheme. The Renewable Heat Incentive will provide a further framework for increased use of biomass.

Despite its continuing support, the government is increasingly aware that biomass is a complex issue. It is seeking a factual evidence-base to underlie decisions on support/subsidy/constraints, and to motivate innovation on sustainable biomass.  It sees a tension between its 2050 ambitions, which require extensive use of biomass, particularly for industry and transport, and its 2020 Renewable directive target, which will only be met if biomass is used extensively in power generation.

The government has a working group, the Biomass & Biogas Sustainability Criteria Implementation Group. Members are:

• UK government: Defra, DECC and DfT.
• Devolved administrations of Wales, Scotland and Northern Ireland.
• Environment Agency.
• Forestry Commission.
• Natural England.
• Ofgem.
• Scottish Natural Heritage (SNH).
• National Non-Food Crops Centre (NNFCC).
• NGOs: (Friends of the Earth, Greenpeace, National Trust, RSPB, WWF-UK.
• Business & Trade Bodies: Association of Electricity Producers, Combined Heat & Power Association, Confederation of Forest Industries, Country Land & Business Association,National Farmers’ Union (NFU), Renewable Energy Association (REA).
• Industry: Centrica, Drax, Eco2, Eon UK, Future Biogas, Helius Energy, RWE Npower, SSE.

The Conservatives and Liberal Democrats have closer links to farmers than does the Labour Party.  So there has been more talk about promoting UK energy crops since the change of government. Many environmental and development NGOs are concerned about energy crops due to their lifecycle carbon footprint and the possibility of taking land out of food production.

The Forestry Commission published the Woodfuel Implementation Plan in 2010. This sets a target of bringing an additional 2 million tonnes to market, annually, by 2020, representing 50% of the estimated unharvested available material in English woodlands. The Forestry Commission argues that this strategy would help conserve woodlands and reverse the decline in woodland biodiversity, and create economic opportunity, particularly in rural areas by developing a sustainable biomass industry. This two million tonnes would constitute around 2% of the UK’s 2020 renewable energy target.

The coalition government revised the UK Energy National Policy Statements which are part of the land use planning system under the Planning Act 2008. However, there were no significant changes to the text on biomass.

The UK Energy Research Centre (UKERC) published a report in April 2011 on the potential of planting short rotation coppice (poplar and willow) in England. This concluded that with efficient land use, England could produce enough biomass to generate approximately 4% of current UK electricity demand, without compromising environmental sustainability or food production.

A figure in the 2010 National Renewable Energy Action Plan has only around 2% of UK renewable energy coming from co-firing in 2020, though the government states that this is only illustrative.

Coalition government ministers have avoided making many statements on co-firing.  Co-fired plants will not be eligible for the RHI.  Energy Minister Charles Hendry was asked specifically about Drax and co-firing in the House of Commons in 1 July 2010.  His response was:

“The co-firing of biomass can make an important contribution, but we have to be certain that it is done sustainably. There are questions about the great deal of shipping involved in the transportation of biomass, but it can certainly make a contribution to reducing our carbon emissions.”

The Environment Agency remains of the view that co-firing will only be appropriate until about 2030, unless carbon capture and storage becomes available.

FoE opposes co-firing, and the use of biomass for electricity generation without CHP.