Cut Carbon Not Forests (CCNF)                            DEF0013

Written evidence submitted by Cut Carbon Not Forests (CCNF)

The following response is submitted on behalf of the Cut Carbon Not Forests coalition, which is composed of UK, Canadian, and American NGOs. Our members include: Biofuelwatch, Dogwood Alliance, the Natural Resources Defense Council (NRDC), the Southern Environmental Law Center (SELC) and Stand.earth. As well as representing communities, academics and environmental organisations across the UK, our coalition critically includes groups based in the source countries where UK biomass is obtained. Both Dogwood Alliance and SELC are based in the SouthEast US, where the majority of UK pellets are sourced, whilst Stand. Earth is based in Canada, the second biggest UK supplier. Additionally, we work in partnership with environmental groups in Estonia, who actively monitor and conduct on the ground surveys of UK pellet sourcing. The members of our coalition would also be very willing to provide additional information and testify through oral evidence to the Committee, as well as being able to connect you with further organisations and individuals on this topic.

The UK relies heavily on bioenergy, which is its single biggest source of “renewable” energy. UK demand for wood pellets to generate this energy is harming forests and ecosystems across the globe that we need to fight both climate change and biodiversity loss, including protected nature reserves. Not only is this devastating for our planet, but it runs counter to many UK laws and commitments, including its 2050 net zero target in the Climate Change Act, its global and domestic laws and commitments on nature and biodiversity, the UK’s sustainability criteria for imported biomass, and the UK’s pledge to tackle global deforestation. Additionally, the Government’s proposed strategy to scale up domestic sources of biomass is not feasible due to the significant amount of trees required to support the UK biomass industry.

The UK must acknowledge these realities in the new Biomass Strategy it plans to publish in late 2022, and the new approach must acknowledge that large scale biomass electricity generation is incompatible with the UK's commitments to address the climate crisis and tackle global deforestation.

We therefore call on the Committee to recommend the following:

  1. The Government must recognise that bioenergy is not zero carbon and has serious environmental and social impacts.
  2. The Government should redirect existing and harmful biomass electricity subsidies towards genuinely non-emitting and renewable alternatives like wind and solar and energy efficiency measures that save billpayers’ money (e.g., heat pumps, insulation).
  3. The Government should not provide the biomass industry with new subsidies for biomass or BECCS. The Office for Environmental Protection should conduct an investigation of biomass sourcing for the UK energy market to determine whether all imports comply with the UK’s sustainability criteria and halt all imports of wood pellets until such investigation has been completed.

1. Growing the UK timber industry

1.1. and 1.2. Does the UK Government have an adequate understanding of the future demand for timber, and have an effective, joined-up plan to increase the production and use of sustainable, domestically grown timber in the UK to reduce its reliance on imports?

No, the UK’s demand for timber is only increasing, fuelled by imported wood pellets. The UK burns more wood for large-scale electricity than any other country in the world - even though burning forest biomass actually emits more carbon than burning coal, per unit of energy produced.[1] Currently, the UK relies overwhelmingly on wood pellet imports to fuel its biomass power stations and less than 1% of the biomass burned at Drax Power Station, Europe’s largest biomass plant, is sourced from within the UK.[2] Drax is also a very inefficient power station, burning the equivalent of 127% of the UK’s entire wood production each year, yet meeting less than 0.8% of the UK’s primary energy demand.[3] Thus, for every ten trees cut down for burning, six are wasted on producing uncaptured heat.

While Drax and the UK claim to desire to use more domestic wood for biomass, Drax’s actions show that this is simply a red herring and, in reality, it’s doubling down on its strategy of relying on imported wood. For example, over the past two years, Drax has purchased two pellet mills in Canada, including Canada’s largest pellet mill–Pinnacle.[4][5]

The new MGT Teesside biomass plant will only exacerbate this demand. The MGT Teesside plant – which is set to be the largest dedicated biomass-burning power station in the world– will burn up to 1.5 million tonnes of imported wood pellets a year if it is ever successfully commissioned. The pellets will be made from around 3 million tonnes of green wood: wood that has been recently cut and therefore has not had an opportunity to dry by evaporation of the internal moisture. So far, MGT Teesside has entered a sourcing contract with Enviva, the biggest US pellet producer,[6] for one million tonnes of pellets each year. A significant proportion of their wood is sourced from clearcutting highly biodiverse coastal wetland forests on the North American Coastal Plain, which has been declared a Global Biodiversity Hotspot. If it begins operating, the MGT plant will cause the destruction of more than 50 acres of forest every day, which will be pelletised, transported to the UK and burned at little over 35% efficiency.

The bottom line is that the Government’s plan to scale up the biomass supply chain with domestic sources – as outlined in its Biomass Policy Statement and other documents – is not feasible and is simply a distraction.[7] The only way the Government can scale bioenergy to the level it envisions is by importing more wood pellets from other countries than it ever has before. This is because the amount of trees required to support the UK biomass industry is equivalent to the size of the New Forest every five months.[8] Under the Climate Change Committee (CCC’s) Balanced Net Zero pathway, meeting biomass demand for BECCS would require converting up to 700,000 hectares of UK land (3% of the UK’s total land area, or more than four times the size of Greater London) to grow energy crops, in addition to imports.[9] The UK simply doesn’t have enough land to support the scale of bioenergy the Government would like.

Further, dedicating a huge percentage of the UK’s land to bioenergy crops would be impossible given the degree to which it would reduce croplands and water availability. Indeed, reducing the land available for food production in the UK risks greater intensification of agriculture, a reduction in food security at a time of global pressure on food chains, and increased water stress due to the need to irrigate the bioenergy crops. The Intergovernmental Panel on Climate Change (IPCC) recently recognised that “BECCS . . . can significantly impact food prices via demand for land and water” and that “[a] growing list of studies have documented the detrimental trade-offs between small-holder food systems and large-scale biofuel production, which include dispossession and impoverishment of small-holder farmers, food insecurity, food shortages, and social instability.”[10] The IPCC also found that irrigating large areas of bioenergy crops needed to increase bioenergy will significantly increase water stress, “doubl[ing] the global area and population living under severe water stress.”[11] The decision by the Environment Agency to have declared a drought for 11 of the 14 areas of England this summer reinforces how water is a precious resource that we need to use wisely, especially as climate projections point to hotter summers in the UK going forward.

Dedicating such large areas of UK land to bioenergy crops would also leave little room for nature. The UK is already one of Europe’s most nature depleted and least wooded countries.[12] Converting more land to plantations simply to burn for energy would move the country in the wrong direction, amidst a global biodiversity crisis. The IPCC recently underscored the “serious emerging conflicts” between climate mitigation and biodiversity, particularly “as a result of afforestation strategies and potentially large areas devoted to bioenergy, including bioenergy with carbon capture and storage (BECCS).”[13] In other words, taking up huge areas of land to grow bioenergy crops will harm ecosystems and the wildlife that depends on them. The IPCC also noted that “if bioenergy were a major component of climate change mitigation strategies,” it would likely have “severe impacts on species.”[14]

Replacing UK natural habitats and ecosystems with bioenergy crops to the level that would be necessary to implement the scale of bioenergy the UK envisions would also interfere with many of the promises the UK has made regarding nature, including its target to protect 30% of its land by 2030 as part of the “30 by 30” initiative under the Convention on Biological Diversity (CBD). Given that Wildlife and Countryside Link found that only 3% of England’s land is currently protected for nature and in good condition, the country has a long way to go to meet this goal.[15]

Finally, setting an international precedent for reliance on biomass to meet net zero targets poses a massive risk, especially as the Government does not have a Plan B if BECCS does not work. Globally, the IPCC’s medium scale BECCS deployment of 12Gt CO2e per year could require up to 0.8 billion hectares of land, if the technology was to ever become technically and economically viable.[16] Betting our planet’s future on a technology that may never actually materialise, is significantly expensive, will negatively impact biodiversity and may not reduce emissions is ludicrous.

1.3. Are there sustainable sources of biomass for UK energy generation either from imported or domestically grown wood for pellet or woodchip?

We do not possess expertise on the sustainability of domestically-grown biomass. However, we do know that the biomass the UK is importing is not sustainable. The UK sustainability criteria require that at least 70 percent of all woody biomass be made from a sustainable source—the remaining 30 percent need only be legally obtained according to the laws of the source country.[17] Woody biomass is considered “sustainably sourced” if it meets a set of additional criteria, including (but not limited to) the following:

        Harm to ecosystems is minimised, in particular by (among other things):

        Protecting water, soil, and biodiversity

        Health and vitality of ecosystem is maintained

        Biodiversity is maintained – in particular by:

        Implementing safeguards to protect rare, threatened, and endangered species;

        Conserving key ecosystems in their natural state; and

        Protecting features and species of outstanding and exceptional value

        Those responsible for the management of the area have regard to (among other things):

        Legal, customary and traditional rights of tenure and land use.

Biomass imported into the UK from the U.S., Canada, the Baltics and other areas clearly violates these standards, and is routinely sourced using environmentally-damaging practices such as clearcutting, the logging of whole trees, and logging in biodiverse and/or unique forest ecosystems.[18]  Even Drax reports that more than 50% of its feedstock worldwide comes from whole standing trees taken directly from forests, with nearly 56% of the U.S. wood they burned in 2021 coming from whole trees (what Drax calls “low-grade roundwood”(33%) and “thinnings”(23%)).[19] A recent investigation by Channel 4 News exposed how wood from a clearcut of an old and biodiverse Estonian forest not only ended up burned at Drax Power Station but was certified as “sustainable.”[20] Similarly, a CNN investigation found that Enviva took one-quarter of the trees from a clearcut of a one hundred year old wetland forest to turn into wood pellets at its pellet mill in Northampton, North Carolina, which supplies Drax.[21]

A recent CCNF report on this, entitled Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass, provides further evidence on this point, showing that sourcing in Estonia employs destructive logging practices in sensitive ecosystems, including areas protected under Estonian and EU law.[22] For more information on these destructive practices, please see our answer to Question 2.2 below. 

Fortunately, a growing number of entities are acknowledging that the UK’s biomass is not sustainable. Notably, the Government’s recent Biomass Policy Statement acknowledged gaps in the UK’s biomass sustainability criteria, governance, and regulations that must be addressed, declaring that any negative impacts from biomass on the environment, including on air quality and biodiversity loss, should be fully understood and mitigated.[23] The S&P’s Global Clean Energy Index dropped Drax due to concerns over its climate impacts,[24] and Citi downgraded its stance on Drax to “neutral” from “buy” as it does “not fundamentally see biomass as a sustainable source of energy.”[25] This has even been acknowledged by Secretary of State for Business, Energy and Industrial Strategy Kwasi Kwarteng MP, who has admitted that the importing of wood to burn in Drax power station “is not sustainable” and “doesn’t make any sense.”[26]

2. The effectiveness of UK efforts to reduce global deforestation

2.2. How effectively is the Government monitoring the UK’s contribution to global deforestation and its progress in tackling the issue? And what progress has been made by Government to develop an indicator on overseas environmental impacts of UK consumption of key commodities?

The UK is the world’s largest importer of timber for biomass energy. Demand for wood pellets to generate biomass energy is growing significantly and is contributing to increased levels of logging in the United States, Canada, Estonia, Latvia, and elsewhere.

As discussed in our response to Question 1.3, the UK relies on “sustainability criteria” for wood pellet imports to attempt to ensure its sourcing is not harming the environment of countries from which it comes. However, as the case studies below demonstrate, investigations into UK wood sourcing from clearcuts of rare and ecologically sensitive forests show a clear pattern: the UK’s “sustainable sourcing” criteria are completely inadequate to determine what is occurring on the ground in sourcing countries. This, combined with often relaxed laws regarding logging in sourcing countries, is actually causing deforestation. 

By subsidising biomass energy with billions per year – a number that could increase exponentially if the Government decides to fund the installation of BECCS technology at Drax – the UK Government is worsening climate change and degrading forests.

Case Study: Estonia

Between 2001 and 2019, Estonia’s Natura 2000 areas, which are nationally protected under the Nature Conservation Act and are networks of core breeding and resting sites for rare and threatened species, lost an area almost the size of Manchester, due in part to biomass production.[27] And between 2009 and 2018, the Estonian Government allowed logging in 60,000 hectares of Estonia’s 380,000 hectares of Natura 2000 areas.[28]

Many of the damaging logging practices that occur in Estonia take place on land that supplies, or is owned by, Estonia’s biggest wood pellet company – Graanul Invest. Graanul Invest manufactures wood pellets that are exported to power stations primarily in the UK, Denmark, and the Netherlands, and is Drax’s main partner in Estonia, having supplied between 2-11% of Drax’s woody biomass imports between 2014 and 2018.[29] Since 2018, Drax has continued to import wood pellets from Estonia, with over half of such imports coming from whole, standing trees – a category of biomass scientists have concluded is particularly high-carbon.[30] In 2021, whole trees accounted for 59 percent of Drax’s imports from Estonia.[31]

Evidence now suggests that logging for biomass in Estonian forests violates the UK’s sustainability criteria for biomass sourcing by employing destructive logging practices in sensitive ecosystems, which are home to hundreds of imperilled species.[32] These investigations have uncovered that logging for biomass in Estonia includes destructive practices, such as:

        Logging in areas of Estonia protected under Estonian law and those designated as part of Europe’s Natura 2000 reserve system;[33]

        Damage to watersheds around rivers and streams;[34]

        Damage to carbon-rich peat soils;[35]

        Logging in ways that harm biodiversity (including clearcutting and other types of harmful logging in habitat for species protected under EU and/or Estonian law due to their imperilled status);[36] and

        Logging culturally significant trees.[37]

Further, according to Estonian environmental groups, at least some of the clearcuts in Estonia (including those conducted by Graanul) have not been replanted. The fact that the UK has potentially imported wood from Estonia that is certified as meeting sustainability criteria, yet was sourced using the destructive methods described herein, show that the UK’s sustainability criteria do not protect forests.

Case Study: Southeast United States

Global demand for wood pellets is devastating forest ecosystems in the Southeast United States, which is where the UK derives the vast majority of its wood pellets. Investigations by media and independent watchdogs over the past decade have exposed the damaging logging practices used by companies – including the world’s largest pellet producer Enviva – to supply the UK biomass industry, especially Drax Power Station.[38] By following logging trucks to the forest and back to an Enviva pellet plant, these investigations have found, among other things, that:

        A high proportion of Envivaʼs pellets in Virginia and North Carolina is made from hardwood, which is typically not found on tree plantations and instead comes from the region’s natural forests.

        Enviva is making wood pellets sourced from clearcut forests in the US South.

These findings contradict industry claims that it only uses sawmill waste and the “wastes and residues” of logging and thinnings from softwood plantations for wood pellets. Repeated observations have shown that Enviva relies primarily on standing trees for wood pellets.

These investigations are further bolstered by new research by Clark University using satellite imagery.[39] This research concludes that ecologically valuable hardwood forests in Virginia and North Carolina have been harvested at a higher rate since Enviva’s pellet mills started operating and consuming primarily hardwoods, likely contributing to overall declines in carbon stocks in the area’s hardwood forests.[40] Additionally, this analysis found that from 2001-2016, forest harvesting in Enviva’s sourcing area exceeded growth, resulting in a net loss of forested area.[41] Moreover, in the time period after Enviva’s three mills started operating (2011-2016), the area’s hardwood forests suffered a net loss.[42] From 2012 to the end of 2021, Enviva harvested 770,000 acres of forests to produce 32 million tons of pellets.[43] The carbon emissions from this production activity are 69 million tons of carbon dioxide equivalent, or 13.5 million extra cars on the road in a year.[44]

Sadly, the forests being logged in the U.S. Southeast for UK biomass are extremely valuable ones from both a biodiversity and a climate change perspective. Much of the area where the logging is concentrated has been designated as an internationally-recognised biodiversity hotspot – the North American Coastal Plain biodiversity hotspot – which is home to 1,816 endemic species of vascular plants, 138 endemic species of freshwater fish, 57 endemic species of amphibians, as well as many endangered bird, reptile and mammal species.[45] Bottomland hardwood forests, in particular, provide “habitat for one of the highest concentrations of endangered species in North America” and support critical ecosystem services, including water filtration, flood prevention, soil protection, and carbon sequestration and storage.[46]

IMAGES FROM 2019 INVESTIGATION INTO SOURCING FOR ENVIVA, TOP SUPPLIER TO DRAX

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In the early spring of 2019, investigators tracked logging trucks from a mature hardwood forest going to Enviva’s Northampton, North Carolina facility. The clearcut was located in the Tar-Pamlico River Basin, alongside Sandy Creek, feeding into the Pamlico Sound of North Carolina. Images: Dogwood Alliance.

Case Study: Canada

Canada is the world’s second largest wood pellet producer, exporting primarily to the UK.[47] Last year’s wood pellet imports from Canada increased by 79% to 1.06 million tonnes.[48] Unfortunately, this number is likely to increase significantly given that Drax’s share of British Columbia’s pellet output increased to 66% over the past year with its purchase of Pinnacle (the world’s largest pellet producer), along with the sales contracts of Pacific Bioenergy, another pellet mill.[49] In February of 2022 a complaint was filed with the Competition Bureau in British Columbia claiming “Drax has come to monopolise much of the wood pellet product in British Columbia and Alberta and lessen competition in the process.[50]

UK demand for wood pellets is contributing to the destruction of Canada’s forests, which are some of the most important ones in the world when it comes to combating climate change and biodiversity loss. Investigations show that industry clearcuts extensively, sometimes under the pretence of harvesting insect-infested trees.[51] Research in British Columbia has shown that it takes at least 13 years after a clearcut for a logged and replanted area to sequester carbon.[52] This analysis suggests that clearcutting is preventing forests from removing an additional 26.5 million tonnes of carbon dioxide per year from the atmosphere.[53] The combined figure is equivalent to the annual emissions from almost 15 million passenger vehicles.[54]

Drax has admitted to logging old growth forests for pellet production in British Columbia and Alberta, stating that it will continue to produce wood pellets from old growth forests as long as the provincial governments allow it.[55] These forests store far more carbon than younger forests and are particularly rich in biodiversity.[56] Further, across Canada, about a third of the pellet industry is in the boreal forest–the world’s largest remaining intact forest,[57] whilst in British Columbia, one-third of the industry is located within the Inland Temperate Rainforest.[58]

These forests are incredibly important from a climate change standpoint. They absorb one-third of human-caused greenhouse gas emissions and store vast amounts of carbon, keeping it out of the atmosphere. The Canadian boreal forest alone stores twice as much carbon as the world’s oil reserves.[59] Mature, old-growth, and intact forests and trees have unparalleled, irreplaceable value for the climate and biodiversity, with intact forests storing 30-70% more carbon than logged forests.[60] When these older and intact forests are logged, the carbon debt can last for centuries.

The Canadian forests being logged for biomass also support indispensable biodiversity. Pellets are likely being made with wood sourced from critical habitat for the endangered Woodland Caribou.[61] Logging for biomass is also putting additional strain on other imperilled species like the Canada Lynx, Pine Marten, and bird species that rely on Canada’s forests and are classified as “threatened with extinction” on the International Union for Conservation of Nature’s (IUCN) Red List.[62]

2.5. What role can sustainable certification and Government Buying Standards (GBS), have in tackling deforestation? How can the UK Government support the private sector to reduce its contribution to furthering deforestation?

Sustainable certification programs – at least as they pertain to wood bioenergy – do not have a role in tackling certifications.

These certification schemes do not cover carbon/climate impacts whatsoever.

While 70% of solid biomass must be certified as sustainable, 30% is still permitted to be just legal, but need not be certified as sustainable.

Most wood pellets are certified by the Sustainable Biomass Program (SBP), which is deeply flawed. SBP standards were developed entirely by industry, and do not require any site inspections to verify claims about forest management at all. The SBP is used by, amongst others, Enviva and Drax to certify their biomass. While Enviva and Drax claim the SBP ensures their wood pellets are sustainable, repeated investigations by NGOs and the media show that whole trees are routinely taken from clearcut biodiverse forests to pellet mills that supply Drax.[63] Even more rigorous certification schemes, such as the Forestry Stewardship Council (FSC), have certified clearcuts of mature and biodiverse forests in Estonia that ultimately supplied wood to Drax as “sustainable”clear proof of their ineffectiveness.[64] Additionally, none of the sustainable forestry certifications programs – even the most rigorous programs – include a carbon accounting mechanism and thus do not provide evidence that biomass harvested for energy production is carbon-beneficial. Finally, large-scale wood bioenergy increases the overall demand for wood leading to harmful impacts on forests, biodiversity and wildlife. Some of those impacts are indirect ones, i.e. causing other wood product industries to switch to more harmful wood sources (e.g. from sawmill residues to imported roundwood) through competition for wood. Certification schemes are not designed to address indirect impacts.

3. Working with international partners to tackle deforestation

3.1. How effectively is the UK engaging with international partners to tackle deforestation? Is the Glasgow Leaders Declaration on Forests and Land Use an effective mechanism for halting and reversing forest loss? How can the UK ensure its £1.5bn commitment to the Global Forest Finance Pledge is used to best effect?

The Glasgow Declaration is not an effective mechanism for halting and reversing forest loss. Whilst its purpose – to recognise the importance of forests in fighting climate change – is important, it leaves out big pieces that are critical to protecting the world’s forests.

One of the most glaring omissions is the Declaration’s failure to prohibit countries from logging forests to convert to wood pellets for biomass energy. The Declaration omits this key piece by focusing only on preventing “deforestation,” which refers to the permanent loss of forests when land is converted to another use (e.g., agriculture, development).[65] This term largely exempts logging for biomass because trees are assumed to eventually regrow (either by being replanted or growing back naturally), even though the logged forests – and their value for the climate and biodiversity – are essentially irreplaceable.  Indeed, replacing complex, carbon-rich natural forests with industrial tree plantations and/or saplings that take years to regrow creates a completely different ecosystem, harming the biodiversity that once lived in the forest and decimating its carbon storage capacity.[66] Additionally, by using the term “deforestation,” the Declaration also largely exempts the Global North for its own forest clearcutting in some of the world’s most climate-critical forests, which includes logging for biomass.[67]

Further, even if the Declaration’s principles were strong enough to halt and reverse forest loss, many of its signatories – including the UK – are flouting their commitments under the Declaration. For example, as a signatory, the UK has committed to "[f]acilitate the alignment of financial flows with international goals to reverse forest loss and degradation, while ensuring robust policies and systems are in place to accelerate the transition to an economy that is resilient and advances forest, sustainable land use, biodiversity and climate goals." The UK is breaking this commitment by subsidising biomass energy. Signatories also agreed to “[c]onserve forests and other terrestrial ecosystems and accelerate their restoration,” which runs counter to the UK subsidising biomass and allowing forests to be logged for biomass energy.

The UK can help ensure its £1.5bn commitment to the Global Forest Finance Pledge is used effectively by ending it’s £2bn subsidies to biomass. Indeed, the UK’s biomass subsidies – which fund the destruction of forests – completely undermine its commitment to protecting them. In its forest finance pledge, the UK govt is recognising the important role of indigenous peoples and local communities, but in biomass subsidies it is riding roughshod over them and putting them in harm's way.

3.2. What impact will the UK’s measures to tackle deforestation have on producer countries, indigenous peoples and local communities?

Biomass harms biodiversity, imperilling both species and ecosystems across the world. 

 

The United Nations predicts that one million species face extinction, many within decades. Sadly, logging for biomass energy is accelerating the threat to forests and wildlife while scientists are calling for “transformative change” – not business as usual – to save our planet and ourselves.

The forests being logged for biomass are some of the most ecologically rich and diverse in the world. Removing trees, branches, roots, and deadwood (e.g., stumps) from the forest for biomass and other purposes eradicates habitat, including nesting and breeding grounds, for thousands of bird species the world over.[68] These activities also diminish food on which birds rely, such as insects, fish, and aquatic invertebrates. The North American Coastal Plain – where most UK biomass imports come from – is a global biodiversity hotspot – providing habitat for hundreds of imperilled species, including the Red Wolf, Cerulean Warbler, and Louisiana Black Bear. In Canada, logging for biomass is putting an additional strain on imperilled species like the Woodland Caribou, Canada Lynx, and Pine Marten, along with the over 3 billion birds that rely on the boreal for nesting and breeding. Biomass is likewise adding pressure to log the last remaining old growth forests in Estonia and Latvia, furthering endangering species like Flying Squirrels, Capercaillie, and Black Stork. The Lithuanian Government now allows logging in regional and national forest parks to meet biomass demand, despite their protected status, impacting many bird species listed as endangered in Lithuania’s Red Data Book like the Pygmy Owl, White-Tailed Eagle, Black Grouse, and White-Backed Woodpecker and prompting criticism from the European Commission.[69] As the world’s top importer and subsidiser of biomass, the UK plays a huge role in this destruction.[70]

 

Burning biomass for electricity pollutes the air and is not “clean energy”

 

Forests are often referred to as the “lungs of the earth” due to their capacity to absorb nearly a third of all anthropogenic greenhouse gas emissions. However, burning biomass emits air pollutants that are linked to an array of health problems, from respiratory problems, to cancer, to heart attacks and strokes, resulting in A&E visits, hospitalisations and premature deaths.[71] In its 2019 Clean Air Strategy, the government said it would consult on closing subsidies to new coal-to-biomass conversions to help reduce deadly emissions of PM 2.5.[72] Yet it exempts existing biomass plants—a source of today’s emissions.[73] Wood pellet production also releases unsafe air pollution, at times at levels that violate plant permits and U.S. law, and has led to legal challenges against Drax’s supplier Enviva.[74] Drax has been cited for serious air quality violations at all three of its own U.S. pellet mills, with a 2019 study showing that the accumulated emissions of burning wood pellets from Drax’s own U.S.-based mills increases carbon pollution in the atmosphere for more than 40 years, well beyond the timeframe identified by the IPCC as critical for tackling climate change.[75]

 

Logging for biomass worsens climate change by releasing the carbon stored by forests and reducing their ability to suck carbon from the air. Further, once a forest has been clearcut, it takes decades, if not centuries, before it can regrow to recover its original level of ecosystem productivity. Additionally, it is worth noting that the UK sustainability criteria for biomass only account for the fossil fuel related carbon emissions from processing and transporting wood pellets on the site; they do not take into account the carbon emitted when the biomass is combusted or the carbon lost on the landscape from harvesting in the forest.

 

UK demand for biomass energy harms marginalised communities in the U.S. South

 

As previously stated, the U.S. Southeast is the primary sourcing ground for UK wood pellets, with almost a dozen companies (including Enviva) opening wood pellet facilities in the region. These facilities are 50% more likely to be located in “environmental justice” communities–that is, impoverished communities where at least 25% of the population is black, indigenous, or people of colour (BIPOC).[76] These same communities are disproportionately targeted for the siting of other dirty industries, such as coal, waste-to-energy plants, and landfills.

This is negatively impacting these vulnerable communities. Pellet mills emit hazardous or toxic air pollutants that are known to cause cancer and other serious health impacts even at relatively small amounts. A 2018 report by the Environmental Integrity Project found that 21 wood pellet mills exporting to the European Union emit thousands of tons of fine particulate matter or PM2.5 (fine dust), carbon monoxide, nitrogen oxides (smog), and volatile organic compounds (VOCs) every year, which the U.S. Environmental Protection Agency associates with illnesses ranging from respiratory and heart disease to cancer to slowed lung function in children.[77]

While each of these pollutants has serious health or environmental impacts, PM2.5 is especially harmful to human health, causing up to 200,000 excess deaths in the United States every year.  PM2.5 consists of tiny airborne particles that can pass deep into a person’s lungs and even into the bloodstream, causing heart attacks, decreased lung function, worsening asthma symptoms, and leading to premature death, especially among people of colour. In Northampton County, North Carolina, where the world’s largest pellet producer, Enviva, owns a pellet mill, more than one in ten adults suffered from asthma in 2018 and residents describe a constant cloud of dust flowing from the plant onto their homes, cars, gardens, and into their lungs.[78]

The National Association for the Advancement of Colored People (NAACP) found that African Americans who live near biomass power plants are more likely to suffer from increased exposure to a number of dangerous emissions, such as smog, asbestos, sulphur dioxide, and other toxins, than any other racial group in America.[79] Several southern chapters of the NAACP opposed the siting of wood pellet production facilities in their communities, with one Georgia chapter stating that the siting of such a facility in their community was “a clear cut example of environmental racism.[80]  Similarly, a CNN report on operations by Enviva found that they were harming marginalised communities of colour in the U.S. South and perpetuating decades of environmental racism.[81]

Despite these horrible health impacts on nearby communities, one-third of pellet mills in the U.S. South were in violation of emissions limitations set in their permits in 2017, according to the Environmental Integrity Project.[82] In fact, violations of air quality laws have resulted in numerous enforcement actions, fines, and community-led lawsuits against pellet mills in the U.S. Southeast. For example, Drax has been cited for serious air quality violations at all three of its U.S. pellet mills and was fined $2.5 million dollars at one of these mills for air pollution three times above the legal limit.[83] Enviva has had seven violations at five separate plants for air quality and other environmental concerns.[84]

The logging of forests around the pellet mills is also concerning because of the critical ecosystem services the trees provide to surrounding communities. Trees remove nutrients and other pollutants from water, meaning logging is negatively impacting water quality in marginalised communities. Intensive logging in these areas also leaves nearby communities more vulnerable to increasingly frequent extreme weather events caused by climate change.

Forests—particularly wetland forests like the ones being logged for biomass in the U.S. Southeast—act as storm buffers, shielding communities from floods and hurricanes. Without these trees, nearby communities are unprotected. For example, Northampton County residents say that two-inch rains now spike flood waters as much as a four-inch rain did a decade ago. Reports from the Cape Fear River—downstream from Enviva’s Sampson, North Carolina, plant—have reported similar findings.

While the pellet industry claims that their business brings jobs and money to these impoverished areas, this has not proven to be the case. Instead, in North Carolina’s Northampton and Sampson counties, the poverty rates increased after Enviva opened plants there,[85] and in Hertford County, NC, the poverty rate has held steady since the Ahoskie plant opened in 2011.[86] The presence of these mills may actually hurt residents financially by lowering property values, raising property taxes, and destroying roads with large logging trucks.[87] Further, the jobs the industry does provide are dangerous, given the myriad of fire and explosion-related incidents that have occurred at them.[88] Since 2001, at least 52 fires and/or explosions have occurred at U.S. bioenergy facilities.[89] Eight of the 15 largest U.S. wood pellet facilities (including six owned by Enviva) have had fires or explosions since 2014.[90]

The sad truth is that these impacts on already-suffering people are likely to get worse in the face of rising demand for wood pellets from the UK and elsewhere. For example, Enviva, the world’s largest wood pellet manufacturer and a top supplier of biomass to Drax, is planning expansions in poor, rural communities in North Carolina and the Gulf South.

 

September 2022

 


[1] IndexBox (2021). Global Wood Pellet Imports Reach Record $4.5B. [online] Global Trade Magazine. Available at: https://www.globaltrademag.com/global-wood-pellet-imports-reach-record-4-5b/#:~:text=highest%20point%20ever.-,The%20UK%20remains%20the%20largest%20wood%20pellet%20importer%2C%20accounting%20for,%2B4.3%25%20y%2Do%2Dy%20in%202020. [Accessed 7 Sep. 2022].

[2] Drax Group plc Annual report 202 at p. 54, https://www.drax.com/wp-content/uploads/2021/03/Drax_AR2020.pdf.   

[3] Total UK wood production in 2019 was 11.1 million tonnes: https://www.forestresearch.gov.uk/tools-and-resources/statistics/forestry-statistics/. At a 2:1 tonnes conversion, Drax burned the equivalent of 14.1 million tonnes of green wood, generating 13.4 TWh of electricity: www.drax.com/wp-content/uploads/2020/03/Drax_AR2019_Web.pdf. The UK’s final energy demand in 2019 was 142.7 mtoe, equal to 1,659.6 TWh: www. gov.uk/government/statistics/electricity-chapter-5-digest-of-united-kingdom-energy-statistics-dukes    

[4]https://www.drax.com/northamerica/press_release/drax-completes-acquisition-of-pinnacle-renewable-energy-inc/

[5]biomassmagazine.com. (2022). Drax to acquire Canadian pellet plant from PSPC | Biomassmagazine.com. [online] Available at: https://biomassmagazine.com/articles/19213/drax-to-acquire-canadian-pellet-plant-from-pspc [Accessed 6 Sep. 2022].

[6] Voegele, E. (2016). Tees REP finalizes project financing, Enviva off-take agreement | Biomassmagazine.com. [online] biomassmagazine.com. Available at: https://biomassmagazine.com/articles/13579/tees-rep-finalizes-project-financing-enviva-off-take-agreement [Accessed 6 Sep. 2022].

[7] Department for Business, Energy and Industrial Strategy. 2021. Biomass Policy Statement, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1031057/biomass-policy-statement.pdf

[8]Hayley Dixon. June 17, 2022. “Dirty cost of keeping the Government’s net zero strategy alive revealed.” The Telegraph, https://www.telegraph.co.uk/politics/2022/06/16/exclusive-dirty-cost-keeping-governments-net-zero-strategy-alive/.

[9] Climate Change Committee. Dec. 9, 2020. Sixth Carbon Budget, https://www.theccc.org.uk/publication/sixth-carbon-budget/.   

[10] Intergovernmental Panel on Climate Change (IPCC). 2022. Climate Change 2022: Impacts, Adaptation and Vulnerability: Summary for Policymakers, https://www.report.ipcc.ch/ar6wg2/pdf/IPCC_AR6_WGII_FinalDraft_FullReport.pdf.

[11] Id.

[12]Royal Society for the Protection of Birds (RSPB). Biodiversity Loss; The UK’s global rank for levels of biodiversity loss, https://www.rspb.org.uk/globalassets/downloads/about-us/48398rspb-biodivesity-intactness-index-summary-report-v4.pdf; Forest Research. 2021. Forest cover: international comparisons, https://www.forestresearch.gov.uk/tools-and-resources/statistics/forestry-statistics/forestry-statistics-2018/international-forestry/forest-cover-international-comparisons/.

[13] Intergovernmental Panel on Climate Change (IPCC). 2022. Climate Change 2022: Impacts, Adaptation and Vulnerability: Summary for Policymakers, https://www.report.ipcc.ch/ar6wg2/pdf/IPCC_AR6_WGII_FinalDraft_FullReport.pdf.

[14] Id.

[15] Wildlife and Countryside Link, 30 by 30: Land for Nature’s Recovery, November 2020, https://www.wcl.org.uk/docs/Link_30x30_paper_18%20November.pdf.

[16] Mathilde Fajardy, Dr. Alexandre Koberle, Dr. Niall MacDowell & Andrea Fantuzzi. Jan. 2019. BECCS deployment: a reality check. Imperial College London, Grantham Institute Briefing paper No 28, https://www.imperial.ac.uk/media/imperial-college/grantham-institute/public/publications/briefing-papers/BECCS-deployment---a-reality-check.pdf.  

[17] Department of Energy & Climate Change. Dec. 22, 2014. Woodfuel Advice Note, https://www.assets.publishing.service.gov.uk/government/uploads/system/uploads/ attachment_data/file/390145/141222_Woodfuel_Advice_Note_-_Guidance_final.pdf.   

[18] Cut Carbon Not Forests (CCNF). Mar. 2021. UK Biomass Imports Threaten Global Biodiversity, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/03/uk-biomass-threatens-global-biodiversity-fs.pdf; Dogwood Alliance, NRDC & SELC June 2019. Global Markets for Biomass Energy are Devastating U.S. Forests, https://www.nrdc.org/sites/default/files/global-markets-biomass-energy-06172019.pdf.

[19] Drax Group plc Annual Report 2021, https://www.drax.com/wp-content/uploads/2022/03/Drax_AR2021_2022-03-07.final_.pdf; Drax Group plc Annual report 2020 at 54, https://www.drax.com/wp-content/uploads/2021/03/Drax_AR2020.pdf.  

[20] Channel 4 News. July 5, 2021. “Fears biomass green revolution could be fuelling habitat loss,” https://www.channel4.com/news/fears-biomass-green-revolution-could-be-fuelling-habitat-loss; Biofuelwatch & Global Forest Coalition. 2020. Can Sustainability and Greenhouse Gas Standards Protect the Climate, Forests and Communities from the Harmful Impacts of Wood-Based Bioenergy?, https://www.biofuelwatch.org.uk/wpcontent/uploads/Biomass-Sustainability-Standards-Briefing.pdf.

[21] Majlie de Puy Kamp. July 9, 2021. “How marginalized communities in the South are paying the price for ‘green energy’ in Europe." CNN, https://www.cnn.com/interactive/2021/07/us/american-south-biomass-energy-invs/.

[22] Cut Carbon Not Forests. July 2022. Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass, https://www.cutcarbonnotforests.org/wp-content/uploads/2022/08/Biomass-Sourcing-in-Estonia.pdf.

[23] Department for Business, Energy and Industrial Strategy. 2021. Biomass Policy Statement, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1031057/biomass-policy-statement.pdf

[24] Jillian Ambrose. Oct. 19, 2021. “Drax dropped from index of green energy firms amid biomass doubts,” The Guardian, https://www.theguardian.com/business/2021/oct/19/drax-dropped-from-index-of-green-energy-firms-amid-biomass-doubts.

[25] Michele Maatouk. Dec. 2, 2021. “Citi downgrades Drax on less attractive risk/reward,” ShareCast,https://www.sharecast.com/news/broker-recommendations/citi-downgrades-drax-on-less-attractive-riskreward--8748996.html.

[26] Carrington, D. (2022). Burning imported wood in Drax power plant ‘doesn’t make sense’, says Kwarteng. [online] the Guardian. Available at: https://www.theguardian.com/environment/2022/aug/11/burning-imported-wood-in-drax-power-plant-doesnt-make-sense-says-kwarteng  [Accessed 6 Sep. 2022].

[27]Cut Carbon Not Forests. July 2022. Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass, https://www.cutcarbonnotforests.org/wp-content/uploads/2022/08/Biomass-Sourcing-in-Estonia.pdf.

[28] Human/vrpo, Money to Burn: The unexpected consequences of Europe’s renewable energy subsidies on Estonia’s forests, https://www.vpro.nl/argos/lees/onderwerpen/money-to-burn/interactive.html.

[29] Indufor. Catchment Area Analysis in Estonia: Final Report, https://www.drax.com/wp-content/uploads/2020/03/8515-Drax-Catchment-Area-Analysis-Estonia-FINAL-REPORT-v3.pdf.  

[30] Drax Group Annual Report and Accounts 2021 at table on p. 46, https://www.drax.com/wp-content/uploads/2022/03/Drax_AR2021_2022-03-07.final_.pdf.

[31] Id.

[32] Cut Carbon Not Forests. July 2022. Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass, https://www.cutcarbonnotforests.org/wp-content/uploads/2022/08/Biomass-Sourcing-in-Estonia.pdf.

[33] Sanne van der Wal. July 2021. Wood pellet damage How Dutch government subsidies for Estonian biomass aggravate the biodiversity and climate crisis. SOMO, https://www.somo.nl/wp-content/uploads/2021/07/Wood-pellet-damage.pdf; Estonian Fund for Nature & Eswatch. 2021. How well are protected forests of high conservation value cared for? Changes in logging pressures and restrictions of protected forest habitats within the Natura 2000 network in Estonia, https://media.voog.com/0000/0037/1265/files/Natura-logging-Estonia-2021.pdf; Estonian Fund for Nature. Dec. 2020. Hidden inside a wood pellet: Intensive logging impacts in Estonian and Latvian forests, https://media.voog.com/0000/0037/1265/files/Biomass_report_ENG%20_2020.pdf. Human/vrpo, Money to Burn: The unexpected consequences of Europe’s renewable energy subsidies on Estonia’s forests, https://www.vpro.nl/argos/lees/onderwerpen/money-to-burn/interactive.html

[34] Id.

[35] Id.

[36] Id.; Estonian Fund for Nature & Eswatch (2021); Estonian Fund for Nature (2020); Thomson, Alex. July 5, 2021. Fears biomass revolution could be fuelling habitat loss. Channel 4 News, https://www.channel4.com/news/fears-biomass-green-revolution-could-be-fuelling-habitat-loss,

[37] Sanne van der Wal. July 2021. Wood pellet damage How Dutch government subsidies for Estonian biomass aggravate the biodiversity and climate crisis. SOMO, https://www.somo.nl/wp-content/uploads/2021/07/Wood-pellet-damage.pdf;

[38] Dogwood Alliance, NRDC & SELC. (2020). Global Markets for Biomass Energy are Devastating U.S. Forests, https://www.nrdc.org/sites/default/files/global-markets-biomass-energy-06172019.pdf.

[39] Thomas Buchholz, John S. Gunn & Benktesh Sharma. (May 10, 2021). When Biomass Electricity Demand Prompts Thinnings in Southern US Pine Plantations: A Forest Sector Greenhouse Gas Emissions Case Study. Front. For. Glob. Change, https://www.frontiersin.org/articles/10.3389/ffgc.2021.642569/full; see also SELC. (2022). Satellite images show link between wood pellet demand and increased hardwood forest harvesting, https://www.southernenvironment.org/wp-content/uploads/2022/03/Biomass-White-Page.pdf.

[40] Id.

[41] Id.

[42] Id.

[43] Dogwood Alliance. Fact Sheet: Destroying Southern Forests for International Export, August 2017, https://media.dogwoodalliance.org/wp-content/uploads/2017/08/Acres-of-Pellets-Fact-Sheet.pdf.

[44] Calconic. Calculating Impacts from Tons of Pellets, https://www.calconic.com/calculator-widgets/co2e-in-wood-pellets-calculator/627a972218addd002aefd9e7?layouts=true

[45] SELC. (2018). Burning Trees for Power: The Truth about Woody Biomass, Energy & Wildlife, https://www.southernenvironment.org/wp-content/uploads/legacy/words_docs/Biomass_Biodiversity_white_paper.pdf

[46] SELC. (2022). Satellite images show link between wood pellet demand and increased hardwood forest harvesting, https://www.southernenvironment.org/wp-content/uploads/2022/03/Biomass-White-Page.pdf.

[47] Carbon Brief. (Jan. 7, 2020). Analysis: UK low-carbon electricity generation stalls in 2019, https://www.carbonbrief.org/analysis-uk-low-carbon-electricity-generation-stalls-in-2019.

[48] Personal communication, Sept. 1, 2022.

[49] Drax Group. Apr. 13, 2021. Acquisition of Pinnacle Renewable Energy by Drax Group Now Complete. Canadian Biomass, https://www.canadianbiomassmagazine.ca/acquisition-of-pinnacle-renewable-energy-by-drax-group-now-complete/; Drax Group. Dec. 14, 2021. Drax acquires Pacific Bioenergy’s contracts to supply 2.8Mt of biomass. Canadian Biomass, https://www.canadianbiomassmagazine.ca/drax-acquires-pacific-bioenergys-contracts-to-supply-2-8mt-of-biomass/.

[50] thestar.com. (2022). Competition Bureau urged to review pellet company takeovers. [online] Available at: https://www.thestar.com/news/canada/2022/02/16/competition-bureau-urged-to-review-pellet-company-takeovers.html [Accessed 6 Sep. 2022].

[51] STAND.earth. (2020). Investigation: Canada’s growing wood pellet export industry threatens forests, wildlife and our climate at 5, https://www.stand.earth/sites/stand/files/report-canada-wood-pellet-industry.pdf.

[52] Sierra Club BC. (Dec. 2019). Clearcut Carbon, https://sierraclub.bc.ca/wp-content/uploads/2019-Clearcut-Carbon-Executive-summary.pdf

[53] Id.

[54] Environmental Protection Agency. (Dec. 2019), Greenhouse Gas Equivalencies Calculator, https://www.epa.gov/energy/

greenhouse-gas-equivalencies-calculator

[55] Drax Group plc annual report 2021, https://www.drax.com/wp-content/uploads/2022/03/Drax_AR2021_2022-03-07.final_.pdf.

[56] CCNF. (March 2021). UK Biomass Imports Threaten Global Biodiversity, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/03/uk-biomass-threatens-global-biodiversity-fs.pdf  

[57] STAND.earth, Canada’s growing wood pellet export industry threatens forests, wildlife and our climate, Feb 2022, https://www.stand.earth/sites/stand/files/report-canada-wood-pellet-industry-updated-01-2022_1.pdf?ea.tracking.id=homepage

[58] Id.

[59]Study (2019). Study Shows Boreal Deforestation Is Far Higher than Reported. [online] NRDC. Available at: https://www.nrdc.org/experts/anthony-swift/new-study-shows-canada-underreporting-deforestation-rates [Accessed 6 Sep. 2022].

[60] CCNF. March 2021. UK Biomass Imports Threaten Global Biodiversity, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/03/uk-biomass-threatens-global-biodiversity-fs.pdf  

[61] STAND.earth (2020) at 10; STAND.earth (2021). Risk Map: Primary Forest and Threatened Caribou Habitat Overlap with Preliminary Estimated Wood Pellet Haul Zones for Pinnacle/Drax in British Columbia, https://www.stand.earth/publication/forest-conservation/forests-and-wood-pellets/risk-map-primary-forest-and-threatened.

[62]IUCN Red List of Threatened Species. (2022). The IUCN Red List of Threatened Species. [online] Available at: https://www.iucnredlist.org/#:~:text=What%20is%20The%20IUCN%20Red,animal%2C%20fungi%20and%20plant%20species . [Accessed 6 Sep. 2022].

[63] NRDC, Dogwood Alliance & SELC. June 17, 2019. Global Markets for Biomass Energy are Devastating U.S. Forests, https://www.nrdc.org/sites/default/files/global-markets-biomass-energy-06172019.pdf.

[64] NRDC & Dogwood Alliance. June 2017. The Sustainable Biomass Program: Smokescreen for Forest Destruction and Corporate Non-Accountability, https://www.nrdc.org/sites/default/files/sustainable-biomass-program-partnership-project-ip.pdf; Cut Carbon Not Forests. 2021. Parliamentary Briefing: UK Biomass Sustainability Criteria Fail to Protect Forests and Biodiversity, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/07/CCNF_Parliamentary-Briefingon-Biomass-Sustainability-Criteria-202107.pdf.

[65] Elly Pepper. Nov. 9, 2021. “What Does the Glasgow Declaration Mean for Biomass?” NRDC Expert Blog, https://www.nrdc.org/experts/elly-pepper/what-does-glasgow-declaration-mean-biomass.

[66] Forest Defenders Alliance, “The Glasgow Declaration on Forests Doesn’t Go Far Enough,” https://forestdefenders.eu/the-glasgow-declaration-on-forests-doesnt-go-far-enough/; Earth Institute. Jan. 3, 2020. Biodiverse Forests Better at Storing Carbon for Long Periods, Says Study. Columbia Climate School State of the Planet,  https://news.climate.columbia.edu/2020/01/03/biodiverse-forests-carbon-capture/

[67]Jen Skene (NRDC). Nov. 3, 2021. “Glasgow Declaration Requires a Reckoning in the Global North.” NRDC Expert Blog, https://www.nrdc.org/experts/jennifer-skene/glasgow-declaration-requires-reckoning-northern-forests.

[68] CCNF. (2021). The Impacts of UK Biomass on Our Planet’s Birdlife, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/03/impacts-uk-biomass-birdlife-fs.pdf.

[69] CCNF. (2021). UK Biomass Imports Threaten Global Biodiversity, https://www.cutcarbonnotforests.org/wp-content/uploads/2021/03/uk-biomass-threatens-global-biodiversity-fs.pdf.

[70] Id.

[71] Letter from prominent health organisations to U.S. Congress about the health harms of biomass, September 13, 2016. Available at: https://www.lung.org/assets/documents/advocacy-archive/health-organizations-letterbiomass.pdf

[72] UK Defra, “Clean Air Strategy 2019,” January 14, 2019, https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/770715/ clean-air-strategy-2019.pdf. 

[73] EU Biomass Legal Case, “Drax (UK): 1,000 tonnes of deadly particulate pollution a year, a 400% increase since they switched from coal to biomass,” http://eubiomasscase.org/2019/03/08/drax-uk-1000-tonnes-of-deadly-particulate-pollution-a-year-a-400-increase-since-they-switched-from-coal-to-biomass/.

[74] Environmental Integrity Project. Apr. 26, 2018. Dirty Deception: How the Wood Biomass Industry Skirts the Clean Air Act, https://www.environmentalintegrity.org/wp-content/uploads/2017/02/Biomass-Report.pdf; SELC. Feb. 13, 2019. Press Release. Clean Air Carolina Challenges Air Permit for Enviva Hamlet Expansion in Richmond County, https://www.southernenvironment.org/press-release/clean-air-carolina-challenges-air-permit-for-enviva-hamlet-expansion-in-ric/.

[75] Stefan Koester & Sam Davis. Apr. 1, 2018. Siting of Wood Pellet Production Facilities in Environmental Justice Communities in the Southeastern United States. Environmental Justice 64-70,  https://www.liebertpub.com/doi/10.1089/env.2017.0025; Buchholz, T., Gunn, J.S. & Sharma, B. (2021). Biomass Electricity Demand Prompts Thinnings in Southern US Pine Plantations: A Forest Sector Greenhouse Gas Emissions Case Study. Front. For. Glob. Change, https://doi.org/10.3389/ffgc.2021.642569; see also SELC Fact Sheet: New Report Shows Wood Pellets from Drax’s U.S. Mills Increase Carbon Emissions During the Timeframe Necessary to Address Climate Change, http://www.southernenvironment.org/wp-content/uploads/legacy/publications/Biomass_Factsheet_0719_F_Pgs.pdf.

[76] Id.

[77] DIRTY DECEPTION: How the Wood Biomass Industry Skirts the Clean Air Act, Environmental Integrity Project (2018). https://www.sec.gov/rules/petitions/2019/ptn4-741-exc.pdf.

[78] Northampton County Health Department. 2019 COMMUNITY HEALTH ASSESSMENT, https://schs.dph.ncdhhs.gov/units/ldas/cha2018/Northampton%20CHA%202018.pdf; Danielle Purofoy. Oct. 5, 2020. How Europe’s wood pellet appetite worsens environmental racism in the US South,

https://www.ehn.org/wood-pellet-energy-environmental-racism-2647890088.html.

[79] National Association for the Advancement of Colored People (NAACP). “Just Energy Policies: Reducing Pollution and Creating Jobs,” Cleveland, Ohio, (2013): 5.

[80] Ronnie Greene. Apr. 26, 2011. ‘Green’ Biomass Isn’t Always So Clean. The Center for Public Integrity, https://publicintegrity.org/environment/green-biomass-isnt-always-so-clean/.

[81] Majlie de Puy Kamp. July 9, 2021. “How marginalized communities in the South are paying the price for ‘green energy’ in Europe.” CNN, https://www.cnn.com/interactive/2021/07/us/american-south-biomass-energy-invs/.

[82] Environmental Integrity Project (2018).

[83] Sara Sneath. Feb. 25, 2021. Mississippi biomass facility fined for emitting three times more air pollution than permitted, https://southerlymag.org/2021/02/25/mississippi-biomass-facility-fined-for-emitting-three-times-more-air-pollution-than-permitted/.

[84] Good Jobs First. Violation Tracker, https://violationtracker.goodjobsfirst.org/prog.php?parent=&major_industry_sum=&offense_group_sum=&primary_offense_sum=&agency_sum=&agency_sum_st=&hq_id_sum=&company_op=starts&company=Enviva&major_industry%5B%5D=&case_category=&offense_group=&all_offense%5B%5D=&penalty_op=%3E&penalty=&govt_level=&agency_code%5B%5D=&agency_code_st%5B%5D=&pen_year%5B%5D=&pres_term=&free_text=&case_type=&ownership%5B%5D=&hq_id=&naics%5B%5D=&state=&city=.

[85] Lisa Sorg. Aug. 18, 2022. Half-truths and sometimes no truths at all: Public debates pollution limits at Enviva’s wood pellet plant in Hamlet. NC Policy Watch, https://ncpolicywatch.com/2018/11/09/half-truths-and-sometimes-no-truth-at-all-public-debates-pollution-limits-at-envivas-wood-pellet-plant-in-hamlet/.

[86] Id.

[87] Majilie de Puy Kamp (2021); Xiangyu Feng, et al. June 2022. (Abstract) Location, Location, Location: Manufacturing and House Price Growth, https://people.bu.edu/stephent/files/HousingPaper.pdf.

[88] Nataly Perez Manrique. Jan. 11, 2022. Fires at Wood Pellet Facilities: What You Need to Know. Dogwood Alliance, https://www.dogwoodalliance.org/2022/01/fires-at-wood-pellet-facilities-what-you-need-to-know/

[89]  Id.

[90] Environmental Integrity Project (2018).