MCS Charitable Foundation, Royal Society for the Protection of Birds, Soil Association, Wildlife and Countryside Link                            DEF0038

Written evidence submitted by RSPB, Soil Association, MCS Charitable Foundation, Wildlife and Countryside Link


Are there sustainable sources of biomass for UK energy generation either from imported or domestically grown wood for pellet or woodchip? And how can future demand be met from sustainable sources? 

Any incentives to burn forest biomass for energy carry an intolerable level of sustainability risk and should be removed. Our organisations jointly urge you to ensure that new sustainability standards for biomass (i.e. the Land and Greenhouse Gas criteria under the Renewables Obligation Order and any existing or new contracts for biomass electricity or BECCS generators[1]) exclude wood sourced directly from forests from eligibility for subsidy.

There are only very limited ‘sustainable’ sources of woody biomass available, and financial incentives have generated a vast discrepancy between availability and usage. A report by 3Keel for the RSPB identified that the only moderate and low risk sources of biomass for the UK are wastes and residues and that these could provide 4% of primary energy supply.[2] The European Commission’s Joint Research Centre analysed a range of woody biomass feedstocks to identify risks posed to biodiversity and ecosystems as well as carbon emissions. Out of 24 sourcing practices, the only scenario identified as presenting a short term carbon risk and low risk for biodiversity is burning fine woody debris (twigs and low diameter branches) if some are also left in the forest to maintain soil health and biodiversity.[3] This is only a small fraction of the biomass currently used by the UK.

The UK currently uses large amounts of thinnings (trees removed from the forest to make space for the remaining ones) for bioenergy. We recognise that UK Woodland Assurance Scheme accredited thinning practices in the UK are beneficial for silvicultural reasons and may have biodiversity benefits, however, however the evidence shows that we cannot separate these from the carbon and nature risk of incentivising excessive harvesting for wood burning. Incentives for truly sustainable forest management, either of plantations or semi-natural woodland that would benefit from conservation management, should be developed separately from the energy market. Woody arisings from such management may be suitable for small-scale bioenergy use, however the market should not be distorted by subsidy to encourage this end use over other options which may be more beneficial for climate and nature.

Evidence suggests that the creation of a market for wood pellets can stimulate excessive thinnings or clearcuts, removal of beneficial debris, or cause indirect impacts by displacing other markets like pulp or paper elsewhere.[4] As our current woody biomass supply chain is almost totally reliant on imports, challenges of international governance can also prove to be insurmountable, as discussed below.

It is imperative that future targets for biomass use are scaled down in order to facilitate this reduction in feedstock availability.

Forest biomass emissions

Burning forest biomass for large-scale electricity generation worsens climate change in real terms and in real time, and the harm it causes can persist for decades or even centuries.[5] For the purpose of international accounting under the Paris Agreement, these emissions are supposed to be counted in countries’ land use sectors at the point of harvest. Imported biomass is therefore counted as zero emissions in the UK energy sector. This has created perverse incentives, whereby renewable energy and zero carbon subsidies are awarded to large-scale biomass plants, despite the real carbon emissions associated with burning wood. Soaring demand for imported wood pellets, led by the UK,[6] also puts unsustainable pressure on globally important ecosystems.[7]

Proponents of bioenergy argue carbon neutrality can be achieved after wood is combusted when an equal amount of carbon is sequestered by regrowing trees. However, this premise of carbon neutrality is false.[8]

It can take decades for new trees to sequester equivalent carbon to that released, and this generates a ‘carbon debt’ in the atmosphere that will not be repaid on timescales relevant to achieving net zero.[9],[10]

Other significant woody biomass lifecycle emissions (that are not always properly accounted for) include:

  1. Emissions from processing and transporting wood pellets;
  2. Carbon released from the soil during biomass harvest in forests;[11]
  3. Forgone sequestration as a result of cutting down older trees and replacing them with saplings after harvest, where the forest’s overall carbon storage and sequestration capacity declines for decades compared to a scenario where the trees are left standing.[12],[13]

Large-scale reliance on burning forest biomass therefore sets back climate efforts. Evidence indicates that protecting forests is more valuable for climate change mitigation than harvesting trees for bioenergy.[14], [15]

As the government considers further billions of pounds in subsidy for bioenergy with carbon capture and storage (BECCS), UK greenhouse gas emissions accounting and GGR policy must reflect the real and total effects of BECCS on the atmosphere as well as other environmental impacts. A UK-focussed approach based on sustainability criteria that include ruling out specific feedstocks would close this loophole and end the subsidy of those types of wood that have the greatest carbon and biodiversity impact.

Forest biomass impacts on biodiversity and habitats

Under existing sustainability standards, wood sourced using damaging logging practices, including clear-felling of mature and highly biodiverse hardwood forests, routinely enters the UK energy market.[16] This biomass is high-carbon and its sourcing contributes to forest degradation, yet it takes place under government and corporate sustainability standards.[17] Recent Channel 4 News[18] and CNN[19] investigations both found wood sourced from clearcuts of old and biodiverse forests supply the wood pellet industry, and in turn the UK bioenergy industry, under current sustainability regimes. In Estonia, which supplies the UK, recent investigations found that logging on land owned by wood pellet companies was occurring in Natura 2000 sites and Woodland Key Habitats,[20] likely violating UK sustainability standards.[21]

Domestic energy crops

Regarding the potential expansion of domestic bioenergy crop production, including dedicated energy forestry and coppice, impacts will depend on both the existing and potential (‘opportunity cost’) value of land to carbon and wildlife. The scale of impact could be very large, with the Climate Change Committee estimating that BECCS could require up to 1.4 million hectares of land, and that BECCS will be needed to offset up to 35.4 million tonnes of CO2e per year by 2050.

Policy to expand production should be considered in light of a robust land use framework which accounts for meeting the whole range of land use challenges for food, nature and climate. New monitoring, reporting and verification above and beyond current regimes will also be required, as the Government is staking legally binding carbon budgets on the promise of BECCS delivering true ‘negative emissions’, which will rely, amongst other assumptions, on rapid crop regrowth and carbon stock permanence.

The ability to successfully manage bioenergy crops for biodiversity benefit will depend on  variables including density, choice of native tree species, diversity of species and structure, proximity to and linkages with woodland habitats and hedgerows, and preventing displacement of agri-environmental areas on farmland. The production of energy crops in itself does not represent a public good and should not be an option under future ELM or the Nature for Climate fund, except where the primary focus is on habitat provision, for example reinstatement of coppice management of native woodlands to benefit priority species populations.


Due to intolerable impacts on nature and climate of stimulating international wood pellet markets via subsidies for bioenergy, new sustainability standards for biomass sources should exclude wood sourced directly from forests.

Incentives for truly sustainable forest management, either of plantations or semi-natural woodland that would benefit from conservation management, should be developed separately from the energy market, with the goal of optimising climate and nature benefit.

Pathways should be developed which tightly limit the amount of biomass available to BECCS at a much lower level than currently projected, removing subsidies for energy from forest biomass entirely.

September 2022


[2] 3Keel, Biomass for Energy: A framework for assessing the sustainability of domestic feedstocks, May 2022,

[3] European Commission, Joint Research Centre, Camia, A., Giuntoli, J., Jonsson, R., et al., The use of woody biomass for energy production in the EU, Publications Office, 2021,

[4] ‘Managers at Plum Creek. […] agreed that the market provided by Drax was accelerating this intensified forestry regime’ Fern (2016) Up in Flames: How biomass burning wrecks Europe’s Forests. Online.

[5] Michael Norton et al., “Serious Mismatches Continue Between Science and Policy in Forest Bioenergy,” Global Change Biology Bioenergy 11, no. 11 (November 2019): 1256-1263,


[7] “UK Biomass Imports Threaten Global Biodiversity,” Cut Carbon Not Forests, March 2021,

[8] Scientist letter regarding use of forests for bioenergy. Online.

[9] European Academies’ Science Advisory Council, “Commentary by the European Academies’ Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality,” June 15, 2018, online.

[10] Brack, D. (2017). Woody biomass for power and heat: Impacts on the global climate. Environment, Energy and Resources Department, The Royal Institute of International Affairs, Chatham House, London.

[11] D. L. Achat et al., (2015) “Forest Soil Carbon Is Threatened by Intensive Biomass Harvesting,” Scientific Reports 5, art. 15991 (online); S. P. Hamburg et al., (2019) “Losses of Mineral Soil Carbon Largely Offset Biomass Accumulation 15 Years After Whole-Tree Harvest in a Northern Hardwood Forest,” Biogeochemistry 144, no. 1. Online.

[12] N. L. Stephenson et al., (2014) “Rate of Tree Carbon Accumulation Increases Continuously With Tree Size,” Nature. Online.

[13] Mitchell, S.R., Harmon, M.E. and O'Connell, K.E.B. (2012), Carbon debt and carbon sequestration parity in forest bioenergy production. Glob. Change Biol. Bioenergy, 4: 818-827.

[14] Ter-Mikaelian, M. T., Colombo, S. J. & Chen, J. The Burning Question: Does Forest Bioenergy Reduce Carbon Emissions? A Review of Common Misconceptions about Forest Carbon Accounting. J. For. 113, 57–68 (2015).

[15] Moomaw, W. R., Masino, S. A., & Faison, E. K. (2019). Intact forests in the United States: Proforestation mitigates climate change and serves the greatest good. Frontiers in Forests and Global Change, 2, 27.

[16] NRDC, Dogwood Alliance, and the Southern Environmental Law Center (2019) Global markets for biomass energy are devastating US forests.

[17] Van der Wal (2021) Wood pellet damage: How Dutch government subsidies for Estonian biomass aggravate the biodiversity and climate crisis. SOMO for Greenpeace Netherlands. Online.

[18] Fear Biomass green revolution could be fuelling habitat loss. Alex Thomson, Channel 4, 5 July 2021.

[19] ‘It’s like we don’t matter’: Green energy loophole has devastating impact. CNN 2021.

[20] Estonian Fund for Nature and Latvian Ornithological Society (2020) Hidden inside a wood pellet: intensive logging impacts in Estonian and Latvian forests. Online.

[21] Cut Carbon Not Forests (2022) Biomass Sourcing in Estonia May Violate UK Sustainability Standards for Biomass. Online.