Drax Group                            DEF0044

Written evidence submitted by Drax Group plc
 

Drax Group plc (Drax) owns and operates a portfolio of flexible, low carbon and renewable electricity generation assets, including Drax Power Station, based at Selby, North Yorkshire, which is the country’s single largest source of renewable electricity in the UK. Following the conversion of most of the power station to operate using sustainably sourced biomass, we have been trialling Bioenergy with Carbon Capture and Storage (BECCS) which will enable us to deliver 8MtCO2 of negative emissions in the 2020s, which would play a significant role in meeting the UK’s ambitious decarbonisation goals.

We welcome the opportunity to help inform the Environmental Audit Committee’s Inquiry into sustainable timber and deforestation.

Drax sources the majority of fuel or “feedstock” from countries with vast working forests which are managed to ensure sustained growth and harvest, within the confines of strict laws and regulations. Robust and well governed active forest management activity, the existence of demand for long-lived, solid wood products and economic market forces makes the regions from where we source good for biomass. In our response to the Committee, Drax is keen to raise awareness of the fundamental principles and critical parameters within which the biomass sector operates, chief of which includes clear and strict legal structures[1] which ensure deforestation does not take place as a result of biomass sourcing for bioenergy. Drax is legally required to prove deforestation has not taken place as a result of our sourcing. This is also a central component of our own sourcing policy[2].

There are several cross-cutting issues which should be acknowledged and addressed by the Committee to ensure the outcomes are fit for purpose and accurate.

  1. The main driver of deforestation globally is from land conversion to agriculture, not biomass. According to NGO Fern[3], as of March 2022 80% of global forest loss is due to converting forests to farmland to produce agricultural commodities such as beef, palm oil and rubber. According to the FAO[4], agricultural expansion drives almost 90% of global deforestation. Other causes include urban development, illegal logging, mining and poor forest management. Deforestation has not taken place in any of the regions from which Drax sources feedstock. In the US (our main sourcing region), the USDA and other organisations have observed stable forest area and an increase in overall inventory stock and improved carbon sequestration and storage across the landscape. These outcomes are the result of active forest management activities (widely known as being beneficial for the climate and nature), strong forest regulation and a healthy demand for solid wood[5] and other wood products. Independent academic research on this subject can be found in the annex below.
     
  2. Definitions are important when talking about deforestation and degradation. The FAO definition[6] of deforestation is “the conversion of forest to other land use independently whether human-induced or not”. Whereas, for instance, the Accountability Framework defines[7] deforestation as “loss of natural forest as a result of: i) conversion to agriculture to other non-forest land-use, ii) conversion to tree plantation; or iii) severe and sustained degradation”. We must use a shared definition which works for all if we are to tackle deforestation globally. Importantly, we are of the view that the Committee should acknowledge that harvesting (by clear cutting or other regime) of areas or “tracts” of forests to meet demand for timber, and where restocking of that area is carried out, is not the same as deforestation. We source from areas where a successor tree crop is established after harvest, which the FAO deems “temporary unplanted”.

 

  1. The term “forestry product” is a potentially misleading term to use when referring to biomass. It is very rare for the production of biomass for energy to be the main objective of a forest owner, or the main driver behind decisions to fell. There are no forest regions where biomass for pellets is the main determinant of forest activity. Rather, our feedstocks are a co-product or by-product (and sometimes a ‘residual’) of forest-based activity and demand for solid wood products. Our fuel or feedstock is most commonly incidental to the primary demand i.e., if the biomass sector did not exist, forests would still be managed and utilised to meet demand for high quality wood (sawlogs) from high-paying sectors such as furniture and construction. However particularly in the US South, our largest sourcing area, the availability of markets for low grade roundwood is assistive for forest owners growing sawtimber. Such markets both facilitate thinning, an important activity to achieve a final crop of sawtimber trees and get some revenue earlier in the rotation, and also help sawmills remain profitable by providing an additional market for sawmill residuals. Having a market for low grade material at time of final harvest can improve revenues and assist in preparing an area for replanting.

 

  1. Importing products from abroad, in this case wood-based products, does not mean those products are less easy to govern or are less sustainable. Drax disagrees with the assumption that governance and sustainability are much less assured when feedstocks are imported (compared to being sourced in the UK). This is not necessarily the case for several reasons. Biomass is the most heavily regulated of all timber imports and the UK has some of the strictest biomass sustainability requirements in the world. If Drax sees weakness in any region’s sustainability or forestry laws or regulations, UK criteria are applied to ensure only biomass with UK-levels of sustainability and assurance are imported. Whilst sourcing from these regions may initially appear counterintuitive, it is quite the opposite:
    1. Often it is much more sustainable sourcing from places with robust safeguards, regulation, and transparency requirements (and plenty of available material) such as North America and Europe, than anywhere else. It is wrong to assume sourcing from such regions means there are no safeguards in place. Not only must we meet UK law, but we must operate within US State law and National law, Canadian Provincial law and National Law, EU Member State law and European Union law. On top, we demonstrate our compliance with multiple Chain-of-Custody certifications (FSC, PEFC, SFI), SFI Fibre Sourcing certification, and SBP certification. Drax refuses biomass which does not meet every requirement. We also source from multiple, trusted, democratic geographies, reducing dependence on one fuel source from one region.
    2. Regarding supply chain emissions, it is inaccurate (but common) to assume transporting pellets is where the majority of emissions come from. To provide context, shipping wood pellets from the south US to the port in the UK represents around 20% of the supply chain emissions whereas drying and pelleting accounts for 50% (the latter being mainly dependent on the electricity grid mix of the sourcing country). Shipping in large bulk vessels can be a highly carbon-efficient way of moving wood pellets across large distances. To provide more context, 1 kWh of coal-electricity would release around 1000g of new CO2 emissions, whereas fossil emissions of shipping pellets to provide that 1 kWh is just 50g.  It is simply not true that shipping pellets from overseas cancels the carbon benefits.
    3. Other studies[8] found similar conclusions, that the GHG intensity of a unit of electricity generated in European countries using imported wood pellets from the US and Canada is about 65–80% lower than the GHG intensity of a unit of grid electricity.
       
  2. Safety of the pellets we use. It is untrue to assume that, because some of the material used in our feedstock is dead or diseased, that the infected components make their way to UK shores. This is false. Pellets are very low moisture content compressed particles of wood. The combination of the comminution, drying and the pelleting process combines physical disaggregation and very high temperatures and pressures that kill any pests and pathogens. Drax takes its phytosanitary responsibilities very seriously, and there is no evidence that imported pellets have ever been associated with spreading any tree diseases. It is therefore possible to conclude that an advantage of our fuel/feedstock is that it brings zero risk to UK tree health.  
  3. Finally, accuracy. As is widely agreed in scientific literature (summarised well by Cowie et al[9] and Favero, Daigneault and Sohngen[10]), the climate effects of bioenergy must be accurately assessed in order to best inform policy decision making. But this is a complex arena to work in. It is not as simple as assuming biomass for energy generation here leads to widespread inherent and total negative nature and climate outcomes there. There are critical nuances, local and regional specificities, economic contexts, existing land and energy system considerations and more all coming into play. In particular, temporal and spatial system boundaries and counterfactual scenarios are key methodology choices that strongly influence analysis and results around whether biomass for energy has positive or negative impacts on the climate. Importantly, we would like the Committee to understand that narratives focusing on carbon balances of individual forest stands and comparisons of emissions at the point of combustion critically disregard system-level interactions that actually have an impact on the climate effects of forest bioenergy. As summarised well by Cowie et al “Narrow perspectives obscure the significant role that bioenergy can play by displacing fossil fuels now and supporting energy system transition”.

Responses to several questions posed by the Committee are answered below. We would be happy to answer any questions the Committee may have in follow up to our response.

 

Yours Sincerely,
 

Via Email
 

Tanisha Beebee

Government Policy Senior Manager

Drax Group plc

 

Responses to questions

Growing the UK timber industry

  1. Does the UK Government have an adequate understanding of the future demand for timber, including what tree species should be grown?

 

  1. Does the UK government, working with the devolved administrations, have an effective, joined-up plan with appropriate incentives to increase the production and use of sustainable, domestically grown timber in the UK to reduce its reliance on imports?
  1. 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?
  1. How well is the UK Government managing its plans for the domestic timber industry in tandem with meeting its woodland creation targets and related climate change, biodiversity and other environmental goals?
     
  2. How effectively is the UK strengthening the resilience of its tree stock to ensure it is resilient to the future impacts of climate change, as well as to pests and diseases?

 

The effectiveness of UK efforts to reduce global deforestation

  1. In what ways and to what extent are UK value chains (in the form of public procurement, goods, services, or the private sector) contributing to global deforestation?
  1. 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?
  1. How effective are the measures to improve due diligence and ban imported products of illegal deforestation in the Environment Act 2021? Do these measures target the right sectors? Given that they do not extend to all products of deforestation, are they adequate?
     
  2. To what extent have the Global Resource Initiative (GRI) Taskforce’s recommendations on deforestation and land conversion been met by the Government?
     
  3. 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?

 

Working with international partners to tackle deforestation

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

 

Annex

Research by North Carolina State University and Duke University[20] found within their analysis of restricted and non-restricted pellet sourcing scenarios, increased removals, an increase in forest area, and little change in forest inventory. The research also found annual gains in forest carbon across the following few decades. These findings collectively suggest that the market is responding positively to pellet demand, but not so much that inventory is substantially reduced (thus driving net carbon storage down).
 

In addition, despite there being an increased demand for woody biomass, this has not depleted forests in the US South (Drax’s largest sourcing location). Instead, markets have encouraged landowners to invest in productivity improvements that dramatically increase the amount of wood fibre, and therefore the amount of carbon, contained in the US South’s forests. Analysis already quoted in our response by Forest2Market[21] found that the number of timberland acres has remained stable in the US South, increasing by 4%. At the same time, total inventory has doubled (+108%, from 142.1 to 296.1 billion cubic feet) because growth has outpaced removals. Further statistical analyses has shown that increased demand is associated with more acres, better growth, and larger inventories. 

In the US a recent synthesis of almost 20,000 articles concerning the effect of forest management techniques on biodiversity in South-eastern US, the research team found that the majority of studies report no negative impacts of forestry practices on biodiversity, concluding that “claims of large-scale damage to biodiversity of woody bioenergy in South-eastern US are not supported,” and that “adverse impacts are mostly from studies of short duration conducted soon after extraction[22] .

This data and research is evidence to the fact that the UK’s current sustainability criteria is effective in ensuring the sourcing locations of biomass are sustainably managed and that habitats/biodiversity therein are protected.

September 2022

 

 


[1] RO2015

[2] https://www.drax.com/sustainable-bioenergy/responsible-sourcing/#chapter-2

[3] https://www.fern.org/publications-insight/what-are-the-causes-of-deforestation-1975/

[4] https://www.fao.org/newsroom/detail/cop26-agricultural-expansion-drives-almost-90-percent-of-global-deforestation/en

[5] https://www.drax.com/sustainable-bioenergy/the-us-souths-biomass-sourcing-areas-analysed/#chapter-1

[6] https://www.fao.org/3/I8661EN/i8661en.pdf

[7] https://accountability-framework.org/the-framework/contents/definitions/

[8] https://iopscience.iop.org/article/10.1088/1748-9326/9/2/024007#back-to-top-target

[9] https://onlinelibrary.wiley.com/doi/epdf/10.1111/gcbb.12844

[10] https://www.researchgate.net/publication/340182053_Forests_Carbon_sequestration_biomass_energy_or_both

[11] https://www2.gov.bc.ca/gov/content/industry/forestry/managing-our-forest-resources/forest-health/forest-pests/bark-beetles/mountain-pine-beetle/responding-to-the-1999-2015-outbreak

[12] https://sbp-cert.org/

[13] https://sbp-cert.org/documents/standards-documents/standards/

[14] https://www.drax.com/sustainability/sustainable-bioenergy/catchment-area-analyses/

[15] https://www.drax.com/sustainability/sustainable-bioenergy/catchment-area-analyses/

[16] https://www.sciencedirect.com/science/article/pii/S0928765517302968?via%3Dihub

[17] https://www.researchgate.net/publication/340182053_Forests_Carbon_sequestration_biomass_energy_or_both

[18] https://www.drax.com/sustainable-bioenergy/the-us-souths-biomass-sourcing-areas-analysed/#chapter-1

[19] https://sbp-cert.org/wp-content/uploads/2021/03/SBP_AnnualReview_2020_FINAL.pdf

[20] https://onlinelibrary.wiley.com/doi/epdf/10.1111/gcbb.12273

[21] https://www.forest2market.com/hubfs/2016_Website/Documents/20170726_Forest2Market_Historical_Perspective_US_South.pdf

[22] https://doi.org/10.1016/j.foreco.2020.118773