Joint submission to the Environmental Audit Committee’s inquiry into biodiversity and ecosystems by NRDC, Dogwood Alliance, Biofuelwatch, SELC and FERN


The above mentioned organisations are submitting a joint response the Environmental Audit Committee’s call for evidence into biodiversity and ecosystems because we believe urgent action is needed to end the burning of forest wood for energy which contributes to the destruction of ecologically valuable forest ecosystems




The state of biodiversity:

       How has the Government performed against the Aichi Biodiversity Targets and what further progress is needed?

Despite the Government’s commitment under the Convention on Biological Diversity, an international legally-binding treaty on the conservation and sustainable use of biodiversity, which requires the elimination of subsidies that are harmful to global biodiversity, the United Kingdom continues to subsidise biomass without considering the potential for perverse environmental outcomes.

Target 3 of the Aichi Biodiversity Targets states: “By 2020, at the latest, incentives, including subsidies, harmful to biodiversity are eliminated, phased out or reformed in order to minimize or avoid negative impacts, and positive incentives for the conservation and sustainable use of biodiversity are developed and applied, consistent and in harmony with the Convention and other relevant international obligations, taking into account national socio economic conditions.”

Consistent with Target 3, the UK Government’s 25 Year Environment Plan states that the UK will establish “appropriate mechanisms to screen policies and strategies for potential negative environmental effects overseas.”

In contradiction to all of this, the UK provides subsidies for wood pellets sourced in the U.S., which contribute to the destruction of ecologically valuable forest ecosystems and harm the communities and wildlife that depend on them. For this exact reason, a wide array of voices, including environmental NGOs and other public interest organizations, esteemed scientific and research bodies, as well as public policy think tanks, such as Bright Blue, have all called for an end to biomass subsidies.[1]

The bulk of biomass subsidies are paid out under the Renewables Obligation Certificates scheme and can be redirected immediately at the Government’s discretion. Under the Levy Control Framework, reduced spending on biomass electricity subsidies should automatically free up increased funding for new subsidies for different and cleaner renewable electricity. Wherever possible, we recommend that the UK Government immediately phase out all subsidies for large-scale biomass use for electricity production and redirect the savings to genuinely clean and renewable energy sources like solar and wind, as well as the conservation of natural forests and restoration of peatlands and wetlands.



       How effective are other policies for conservation and enhancement of existing natural habitats, such as the Woodland Grant Schemes?


Unfortunately, the UK government’s forest conservation efforts are dwarfed each year by the scale of the harmful subsidies it continues to provide energy companies that burn trees for electricity under the guise of generating renewable energy. Most of the wood that’s burnt as fuel in biomass power stations is imported from overseas forests. This is not only wasteful financially, but counterproductive to conservative and climate goals.

For example, in the 2020 Budget Statement, the government announced a £640m “nature for climate fund” for England, which had previously been set out in the Conservative party’s manifesto. According to the announcement, this would mean an additional 30,000 hectares of trees (roughly 300 square kilometers), “a forest larger than Birmingham,” over the next five years.

At the same time, in 2019, wood pellet sourcing for Drax’s coal-to-biomass conversions at Drax Power Station alone required sourcing of over 7 million tonnes of wood pellet, roughly 4.6 million tonnes of which were sourced from forests in the southern United States.[2] Supplying this demand required the harvesting of approximately 340 square kilometers of forests in the region,[3] where the North American Coastal Plain has been designated as a global biodiversity hotspot.[4] At this level, five years of wood fuel supply thus requires harvesting 1,700 square kilometers, equal to six times the area the UK intends to plant via the “nature for climate fund.” And again, Drax imported more than 1.5 times that much forest biomass from all sources in 2019, so the total forest harvest impact is actually much greater.


In financial terms, the UK’s tree-planting efforts are also outstripped manifold by spending on biomass subsidies. According to BEIS, biomass subsidies totaled approximately £1.46 billion in 2018-19.[5] Thus, the £640 million “nature for climate fund” (over 5 years) totals just 9% of what the UK Government will spend on biomass subsidies over the same period (if we assume biomass subsidies continue at the same level).

Transformative change, including putting an end to spending billions of pounds of billpayer subsidies to burn trees for electricity, is needed to help reverse the biodiversity crisis and must be at the core of how the UK bolsters its conservation policies.


Co-ordination of UK environmental policy:

       How can policy be better integrated to address biodiversity, climate change and sustainable development?


The twin crises of climate change and biodiversity loss are inextricably linked, so keeping biodiverse and carbon rich natural forests standing must be a priority of the UK government. Biomass subsidies are counterproductive to addressing both challenges.


Because of its policies on biomass energy, the UK is degrading precious forests around the world to meet its electricity needs, threatening the habitats of many at-risk animals. The UK and Europe's forests are often highly regulated, so power companies have had to look abroad to source wood fuel, turning to the largely unregulated forests of the American South for fresh supplies. In the U.S. Southeast, where much of the wood pellets for UK and EU biomass plants are sourced, it is legal to clear-cut biodiverse and carbon rich natural forests. The trees that might be planted in replacement (e.g. monoculture pine) are forests in name only; they support just a fraction of the biodiversity found in natural forests.[6] This practice eliminates the hardwood ecosystem and associated biodiversity and causes permanent carbon loss, including loss of soil carbon.


Yet, wood pellet manufacturing in the southern U.S. is expected to continue skyrocketing.[7] Demand for biomass from the UK and other EU countries is so large that it has resulted in the proliferation of wood pellet manufacturing facilities across the region to produce wood fuel for export. Last year alone, wood pellet exports from Southern ports increased 70 percent.

The UK is currently the largest user of biomass electricity in Europe, and much of the wood in question is cut down and shipped in from ecologically sensitive forests overseas, particularly North America, destroying habitats and wildlife.[8] Claims that wood shipped into the UK for electricity production is sourced “sustainably” are misleading. Years of on-the-ground investigations show that wood entering the UK bioenergy market is routinely sourced from clearcuts of mature, biodiverse hardwood forests in the US Southeast.[9] Photographic evidence also shows vast quantities of whole trees and other large-diameter wood—biomass feedstocks known to be high-carbon—entering the supply chain destined for UK power stations, including Drax. This practice degrades the habitats of a number of at-risk native species, including salamanders, the Louisiana black bear, the Venus flytrap and multiple songbird species. And all of this takes place under existing governmental and corporate “sustainable sourcing” standards, demonstrating their inadequacy.


Further, the assumption of carbon neutrality for “sustainably sourced” biomass falsely counts biomass emissions as zero.[10] Nonetheless, the assumed equivalence of sustainability and carbon neutrality continues to underpin the UK’s policy of providing billions more in subsidies to existing biomass plants (despite having pledged to end subsidies for new biomass plants on the basis of climate and air pollution).


Established science now calls into question the effectiveness of the massive public subsidies given to biomass energy. Just like coal, burning trees to produce electricity fuels more – not less – climate change. Burning biomass emits more CO2 per unit of energy than fossil fuels. And even accounting for regrowth, net CO2 emissions persist in the atmosphere for decades to centuries—well outside Paris Agreement-relevant timeframes for addressing the climate emergency or timeframes associated with the UK’s statutory climate targets. Scientists now state plainly that, “labelling forest biomass as renewable has a perverse impact on the climate,” andmuch more would be achieved in tackling climate change if the huge subsidies currently given to biomass could be diverted to technologies that really helped the climate.[11]


The Intergovernmental Panel on Climate Change has also made it clear that climate mitigation requires not only drastically reducing emissions but finding ways to take carbon dioxide (CO2) out of the air. Large-scale burning of wood sacrifices opportunities to remove CO2 from the atmosphere because it requires harvesting trees, whereas maximal CO2 removal is achieved by letting forests grow. Rather than subsidising biomass energy, rotecting and restoring forests is amongst the most cost-effective CO2 removal strategies and provides a host of co-benefits, such as biodiversity protection and increased community and ecosystem climate resilience.

Last but not least, public opinion polling shows that the British public is deeply concerned about the impacts of the biomass industry and supports change. Data from a July 2020 YouGov poll shows that 85% of respondents worried about the impact on wildlife if trees in forests are being cut down to generate electricity. Fewer than one in four Britons (23%) think electricity generated by burning wood from forests should be classified as ‘renewable energy.’ Additionally, 55% also disagreed with the Government’s continued subsidies for this dirty source of energy as part of the UK’s renewable energy strategy.[12]

Better integrating UK policy to address biodiversity, climate change and sustainable development - particularly in the wake of the coronavirus pandemic - cannot mean a return to business as usual where the UK Government continues to prop up dirty energy sources from the past like burning trees for electricity. Cutting down trees, shipping them from forests overseas and burning them in power plants was never clean or cost-effective; that’s even clearer today. The government must immediately direct public funds away from false climate solutions like biomass and towards low-cost and truly clean and renewable energy like wind and solar, as well as forest conservation. 

We must also safeguard our environment and biologically important habitats by protecting our natural forests and the wildlife that inhabits them. Transformative change, including putting an end to billions in subsidies for burning trees for electricity, is needed to help reverse the biodiversity crisis and must be at the core of UK environment and energy policy, and how the country rebuilds after the coronavirus pandemic.

       How can biodiversity and ecosystems help achieve the air, soil and water quality objectives in the 25 Year Environment Plan?

       How well is the UK addressing biodiversity loss in its Overseas Territories and in international development partnerships with other countries?

Sadly, just like the UK’s domestic tree planting efforts, the UK’s effort to address biodiversity loss via forest conservation efforts around the world is significantly diminished by billions in biomass energy subsidies, which prop up degradation of sensitive forests, threatening communities and the wildlife that depend on them. This renders the UK’s policies on forest conservation incoherent and hypocritical.

In September 2019, the UK Government unveiled £1.2bn fund for climate and endangered species.[13] This level of spending is outstripped in just a single year by subsidies to Drax and other biomass-burning power stations, which contribute to forest degradation and exacerbate climate change.[14]

Similarly, DFID reports that it has invested £57.2 million (2017-18), £53.1 million (2018-19) and £50.8 million (2019-20) in bilateral forest programmes over the past three years.[15] This means the UK’s annual overseas forest conservation funding is less than 4% of what it spends to subsidise importing wood from overseas forests to be burnt for energy each year.


According to BEIS, biomass subsidies totaled approximately £1.46 billion for the period 2018-2019.[16] Of this, nearly £1.1 billion was paid out under the Renewables Obligation Certificates scheme and can – and must - be redirected immediately.


       What outcomes and protections should the UK Government be pushing for at the forthcoming UN negotiations on the post-2020 global biodiversity framework at the Convention on Biological Diversity COP 15?



First and foremost, global leadership on protecting biodiversity requires that, wherever possible, the UK Government immediately phases out subsidies for large-scale biomass use for electricity production. As described, the bulk of biomass subsidies are paid out under the Renewables Obligation Certificates scheme and can be redirected immediately at the Government’s discretion.


Additionally, no further public funds in the UK should be used to support bioenergy with carbon capture and storage (BECCS) at Drax Power Station. Drax’s long experiment with burning wood for electricity has shown that it exacerbates climate change just like fossil fuels, threatens forests, and diverts scarce public resources from low-cost, low-risk alternatives like solar and wind. Now is the time to end subsidies for large scale bioenergy and significantly increase support to real climate and clean energy solutions, not waste time or more money on the latest Drax experiment.


BECCS only exists as an idea and is a wholly unproven technology. CCS has never been demonstrated at any scale with biomass plants. And except for Drax’s pilot project to capture CO2 from burning trees, no proposals exist anywhere in the world to try and capture carbon from biomass burning. The biggest of the experiments at Drax aims – but currently fails – to capture 365 tonnes per year out of 13 million tonnes of CO2 emitted in 2019. All of the captured CO2 has been released back to the air.


BECCS is also the wrong and most risky place to start when it comes to carbon dioxide removal.[17] Because most bioenergy use for electricity generation results in increased carbon emissions, adding carbon capture use and storage to these plants, including Drax’s pilot project in North Yorkshire, does not result in net carbon dioxide removal from the atmosphere. Large-scale reliance on forest biomass for BECCS also risks untenable ecosystem impacts.[18]


Of the four illustrative pathways for reducing emissions and increasing carbon storage featured in the Intergovernmental Panel on Climate Change’s Special Report on Global Warming of 1.5°C, there is only one scenario that envisions low or no overshoot of climate targets and does not count on biomass electricity generation as renewable energy; in fact, the scenario envisions a decrease in bioenergy usage and no reliance on BECCS. This is because this scenario prioritizes maximizing carbon storage by forests, not burning them for energy – and it is not possible to do both.[19]


Instead of wasting money on BECCS, the UK Government should invest in energy efficiency, solar and wind, as well as innovative technologies that help manage demand for electricity and battery storage. Restoring forest ecosystems, as well as peatlands and wetlands, protecting intact forests, and improved agricultural practices are more effective carbon dioxide removal investments than BECCS. In addition to pulling CO2 out of the air and storing it in organic materials, these approaches can secure food supplies, improve the resilience of ecosystems, and enhance biodiversity. Any programme to subsidise BECCS will be ineffective in tackling the climate emergency and waste public resources that are better invested elsewhere. 



Economics and biodiversity:

       What are the possible approaches to balancing economic growth and conservation of nature and its contributions? Is there evidence these approaches work and can be implemented?

As part of its plan for building back after the COVID-19 pandemic, we urge the UK Government to act immediately to end wasteful biomass subsidies. Doing so would free up significant resources which could be more productively invested in truly clean and renewable energy sources like solar and wind, as well as other innovative solutions to address climate change and create new green jobs in support of a genuinely green recovery.


In 2015, the UK adopted a programme to retire all coal plants by 2025. Since then, the costs of clean energy technologies like solar and wind have fallen dramatically, according to the Government’s own figures.[20] As the UK rebuilds its economy, the Government must consider where money is being spent and ensure public investment goes towards real clean and climate-friendly energy sources and the most cost-effective climate solutions. With household budgets under pressure, there is absolutely no justification for continuing to waste over £2 million a day subsidising fake solutions to climate change and increasing electricity costs for British households when true renewables are already a more affordable option - and getting cheaper.

Indeed, analysis shows that biomass electricity is simply unnecessary. It is not needed to secure the reliability of the UK power system and raises serious sustainability concerns while offering limited value in achieving deep decarbonisation of the electricity system. Instead, the UK can decarbonise emissions from its electricity system by relying almost entirely on new investments in wind, solar, and smart resources. Delivering these new investments is both technically and economically low-risk, but it does require further UK Government action to create a supportive policy environment. A first step towards this goal would be an immediate reinvestment of billions in biomass electricity subsidies towards these genuinely low-carbon technologies.[21]


As discussed, in 2018-19, the UK spent approximately £1.46 billion subsidising burning trees for electricity, of which nearly £1.1 billion was distributed via the Renewables Obligation Certificates scheme and could thus be redirected at the Government’s discretion. We urge the UK Government to do so immediately and reinvest the savings towards real climate solutions.


       What does the UK Government need to do to maximise human prosperity – in terms of health, economic, and social wellbeing—within the ecological and resource constraints of a finite planet? What alternative models and measures of economic welfare can feasibly help achieve this?

Burning biomass for electricity pollutes the air and is not “clean” energy. Burning biomass from forests releases dangerous air pollution like particulate matter, in addition to climate pollution. The latest data from the European Environment Agency indicates 456,000 premature deaths in the E-28 from air pollution, with 82% attributable to particulate matter (PM2.5).[22]

Indeed, the UK Government’s own Clean Air Strategy pledged to close future auction rounds for Contracts for Difference to new coal-to-biomass conversions on the basis of serious air quality impacts, and in particular to help reduce deadly emissions of PM2.5.[23] Yet, it exempted existing biomass plants, which are obviously the source of today’s emissions, and continues to heavily subsidise their operation and thus their air pollution.

As the COVID-19 lockdown is eased, the British public believes the UK’s recovery phase must prioritise true clean energy sources, such as wind and solar power. 82% of respondents in a July 2020 YouGov poll agree that the UK should aim to preserve improvements in air quality by switching to energy sources with no associated air pollution emissions. Ending subsidies for existing biomass-burning power stations would be a win for biodiversity, climate and clean air in the UK.


Pairing nature-based solutions to climate change with biodiversity:

       Which nature-based solutions are most effective in achieving both climate and biodiversity goals?


According to the International Panel on Climate Change, CO2 removal of up to 20 GtCO2 per year or more will be needed to limit warming to 1.5ºC, an amount equivalent to half of today’s global emissions. It will be essential to make maximum use of “natural climate solutions”—i.e. the deliberate enhancement of CO2 removal by natural systems, such as the conservation and restoration of soils, forests, peat bogs, and coastal ecosystems. Of these natural pathways, forests hold the greatest potential, in addition to providing significant biodiversity co-benefits. It is essential to achieve maximal forest regrowth by letting forests grow rather than harvesting them for energy.


Bioenergy with carbon capture and storage (BECCS), often advertised as a means of delivering “negative emissions,” is in fact unproven and counterproductive to this goal. The UK’s Committee on Climate Change rightly acknowledges that BECCS can “have negative impacts on biodiversity, soil health, water quality and invasive species”. A recent Chatham House report warned that the assumption that BECCS creates ‘carbon negative’ power is not valid as it relies on the discredited carbon-neutrality assumption for biomass, also citing uncertainty about its feasibility and its predicted impacts on a global scale, recommending that it should be evaluated on an equivalent basis to nature-based solutions.[24]

The European Academies Science Advisory Council (EASAC) has also identified that BECCS may not remove carbon efficiently from the atmosphere due to ‘leakage’ and that “significant risks exist of perverse outcomes where the net effect is to increase emissions”. The UK Government should thus not rely on BECCS as being a dependable source of negative emissions in models of carbon budgets for future decades while these issues remain unresolved.[25]

Now is the time to end subsidies for large-scale bioenergy and significantly increase support to real climate and clean energy solutions, including efforts to protect and restore forests and expand native tree planting, not waste time or more money on the combination of bioenergy with carbon capture storage.



September 2020


[1] Bright Blue, “Global Green Giant? A Policy Story,” 2020,

[2] Drax, “Enabling a Zero Carbon, Lower Cost Energy Future,” 2020,

[3] Calculation based on equation at note 9 in:SELC, “Burning Trees for Power: The Truth about Woody Biomass, Energy & Wildlife,” January 2018,

[4] SELC, “Southeast U.S. Wood Pellet Plants Exporting to Europe,” August 18, 2020,; Critical Ecosystem Partnership Fund, “Announcing the World’s 36th Biodiversity Hotspot: The North American Coastal Plain,” 2016,;

[5] See response from Kwasi Kwarteng to questions related to biomass subsidies, July 6, 2020,

[6] SELC, “Burning Trees for Power: The Truth about Woody Biomass, Energy & Wildlife,” January 2018,

[7] SELC, “Southeast U.S. Wood Pellet Plants Exporting to Europe,” August 18, 2020,

[8] NRDC, “Bioenergy Threatens the Heart of North American Wetland Forests, 2015,

[9] Dogwood Alliance, NRDC, and SELC, “Global Markets for Biomass Energy are Devastating U.S. Forests,” 2019,

[10] Michael Ter-Mikaelian, et al., “The Burning Question: Does Forest Bioenergy Reduce Carbon Emissions? A Review of Common Misconceptions About Forest Accounting,” Journal of Forestry, November, 2014; John Gunn, et al., “Scientific Evidence Does Not Support the Carbon Neutrality of Woody Biomass Energy: A Review of Existing Literature,” Spatial Informatics Group Report 2018-01, October, 2018,


[11] EASAC, “Emissions Trading System: Stop Perverse Climate Impact of Biomass by Radically Reforming CO2 Accounting Rules,” August 26, 2020,

[12] NRDC Press Release, “YOUGOV Poll: Just 23% of Britons Believe Burning Wood for Electricity should be Classified as ‘Renewable Energy,’” July 21, 2020,

[13] Peter Walker at The Guardian, “Boris Johnson Unveils £1.2bn for Climate and Endangered Species,” September 22, 2019,

[14] See response from Kwasi Kwarteng to questions related to biomass subsidies, July 6, 2020,

[15] See response from James Duddridge to questions related to tree planting, July 6, 2020,

[16] See response from Kwasi Kwarteng to questions related to biomass subsidies, July 6, 2020,

[17] Chatham House, “Net Zero and Beyond: What Role for Bioenergy with Carbon Capture and Storage,” January 29, 2020,

[18] EASAC, “Forest Bioenergy, Carbon Capture and Storage, and Carbon Dioxide Removal: An Update,” February 2019,

[19] Partnership for Policy Integrity, “The IPCC’s Recipe for a Livable Planet: Grow Trees, Don’t Burn Them, October 7, 2018,

[20] Simon Evans at Carbon Brief, “Wind and Solar are 30-50% Cheaper than Thought, Admits UK Government,” August 27, 2020,

[21] NRDC, “Reality Check: Biomass is Unnecessary for the Reliability of UK Electricity Supply—and so are Continued Subsidies to Drax Power,” June 2018,

[22] 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,” available at:

[23] DEFRA, “Clean Air Strategy,” 2019,

[24] Chatham House, “Net Zero and Beyond: What Role for Bioenergy with Carbon Capture and Storage,” January 29, 2020,

[25] EASAC, “Forest Bioenergy, Carbon Capture and Storage, and Carbon Dioxide Removal: An Update,” February 2019,