Written evidence submitted by Cut Carbon Not Forests coalition (PEG0107)



We, the Cut Carbon Not Forest coalition, consisting of Natural Resources Defense Council (NRDC), Dogwood Alliance, Biofuelwatch and Southern Environmental Law Center (SELC), welcome the opportunity to input into the Business, Energy and Industrial Strategy Committee’s post-pandemic economic growth inquiry.


We are submitting evidence to this as we believe that the UK Government post-pandemic economic response presents a major opportunity to set the economy on a sustainable path to deliver emission reductions that are vital to combat climate change. But in doing so, the Government must avoid investing in failed technologies and false solutions, such as the billions wasted on subsidies for the burning of wood for power.


What core/guiding principles should the Government adopt/prioritise in its recovery package, and why?

In a post-pandemic environment of scare government resources and the urgent need to reduce greenhouse-gas emissions it is vital that the Government’s recovery package adopts a core principle to only support climate solutions that are effective, deliver value-for money and do not harm the environment. In other words, “we must stop investing in failure”, as Anna McMorrin MP put it in the debate on the finance bill.


While solar and wind energy are reliable, readily available and have a proven track record of delivering low-carbon energy at continuously falling prices, power stations that burn biomass are a long-existing combustion technology without much scope for further capital cost reductions, while operating costs may well increase in future given the fast rising demand for forest biomass worldwide.


For any climate solution to receive government pay-outs, carbon benefits must be realized within short timeframes relevant to climate policy and action (i.e. a decade or less). However, established science shows that burning biomass derived from forests increases emissions for many decades or more.[1] Forest biomass of this type is a high-carbon fuel for two key reasons:



First, just like coal, when trees are burned in power plants, the carbon they have accumulated over long periods of time is released into the atmosphere. However, wood is a less energy dense fuel than coal, making biomass facilities far less efficient than fossil fuel plants per ton of carbon emitted. Lower efficiency means more wood must be burned to generate the same amount of electricity, increasing carbon emissions from the smokestack.


For example, according to Drax, in 2019 its power station emitted nearly 13 million tonnes of CO2 solely from the combustion of biomass. This is almost 3 million tonnes more than what the UK’s Committee on Climate Change has recommended is needed in carbon reductions to meet the UK’s 4th and 5th Carbon Budgets (10 million tonnes/year reduction).[2]


Second, if left alone, trees will continue to absorb carbon. Logging and burning trees for energy thus not only emits a lot of carbon dioxide, it also depletes vital carbon sinks and impedes ongoing forest carbon sequestration. From the perspective of the atmosphere, destroying a carbon sink is the same as building an equivalent sized smokestack. Even if replanted immediately, trees take decades to reach maturity. Young trees may grow at a faster rate relative to their small existing stock of carbon than older trees, but older trees have been found to sequester more carbon from the atmosphere.[3] 


Together, this means it takes decades to more than a century for bioenergy to deliver any climate benefit—and then only if forests are allowed to regrow and not converted to plantations or re-cut for energy.[4] Even when power stations burn forestry residues—the leftovers from logging operations—the result is more CO2 in the atmosphere over several decades.[5] This is incompatible with the speed at which countries must cut emissions to meet Paris Agreement targets or limit global warming to 1.5 degrees Celsius.


To a limited degree, the risk of biomass emissions has been reflected in some UK Government safeguards, such as overall emissions limits on biomass. To date, however, biomass is still considered a “carbon neutral” fuel by the government’s calculations. UK policy only requires biomass-burning utilities, whether co-firing biomass or burning biomass in dedicated plant conversions, to account for the lifecycle fossil fuel greenhouse gas (GHG) emissions associated with the logging, processing, and transport of wood pellets—not the emissions produced when biomass is combusted at power plants nor the foregone carbon sequestration in the forest from the additional logging of trees for energy production.  This fundamental loophole in UK policy means emissions from burning biomass for electricity are being significantly undercounted. These GHG emissions are, effectively, “missing.


In 2018, the UK government tightened supply chain emissions and efficiency requirements for new biomass plants seeking renewable electricity subsidies. In 2019 it pledged to consult on closing subsidies to biomass conversions due to harmful local air pollution, and none were made available in the 2019 Contracts for Difference auction. But in both cases, plants with existing subsidies are exempt.


Without further reform, UK energy billpayers will spend £13 billion in direct support to large biomass power plants through 2027 when most subsidies are due to end, including £10 billion for Drax alone, according to a new report by climate think tank Ember.[6]


The Government should adopt as a principle in its recovery package to only support genuine clean and renewable energy that results in immediate carbon emissions reductions. 
As the UK works to get the country back on track, the Government must invest in a true clean-energy economy and end wasteful subsidies paid to companies that burn trees for electricity. The Government should redirect biomass subsidies, under the Renewables Obligation Certificate (ROCs) scheme, to real clean and renewable energy like wind and solar power.



Whether the government should give a higher priority to environmental goals in future support?


The Government should give higher priority to environmental goals in future support. However, the Government must also make sure we are not paying for failure. The UK spent roughly £1.67 billion in 2019 subsidising burning trees for electricity, of which £1.26

billion was distributed via ROCs. We understand that if ROCs for biomass were withdrawn, the money saved would, via the Levy Control Framework, become automatically available to new Contracts for Difference for renewable energy, in which case (given the much stricter standards for new biomass subsidies) they would almost certainly benefit wind and solar power. Much of the wood burned as fuel in UK power stations was cut down and shipped in from precious forests overseas. The UK’s massive demand for wood-fuelled electricity is accelerating climate change, destroying forest habitats and endangering wildlife. The UK must stop pretending that burning forests for fuel is “green” energy.


Burning forest biomass for electricity 1) exacerbates climate change; 2) degrades forests and threatens wildlife; 3) emits deadly air pollution; and 4) cannot compete with solar and wind on cost and is unnecessary for UK grid reliability.



1)      Burning biomass for electricity worsens climate change and is not a low-carbon alternative to coal

Alarmed that biomass burning is accelerating climate change, scientists have called for urgent action to restrict forest bioenergy schemes.[7] That’s because per unit of energy, biomass-burning plants emit more carbon dioxide (CO2) from their smokestacks than coal-burning plants. And, in each wooded area, cutting older trees and replacing them with saplings reduces how much carbon is stored in that forest, even if trees are replanted right away.[8]


Together, this means it takes decades to more than a century for bioenergy to deliver any climate benefit—and then only if forests are allowed to regrow and not converted to plantations or re-cut for energy.[9] Even when power stations burn forestry residues—the leftovers from logging operations—the result is more CO2 in the atmosphere over several decades.[10] This is incompatible with the speed at which countries must cut emissions to meet Paris Agreement targets or limit global warming to 1.5° Celsius.


2)      Burning biomass for electricity degrades forests and threatens wildlife

Independent reporting by Channel 4 News, TV2, the Washington Post, Wall Street Journal and others has exposed the unsustainable logging practices used to source wood for pellets exported by Enviva, a top supplier to Drax, including sourcing from clearcuts of mature hardwood forests in the Southeastern U.S.[11] NGO investigations likewise spotlight the vast quantities of the most carbon-intensive types of biomass (whole trees and other large-diameter wood) entering the industry’s supply chain.[12] These sourcing practices not only liquidate carbon stocks, but damage biodiversity in a region where the North American coastal plain is designated a global biodiversity hotspot.[13],[14]



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


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 emergency room visits, hospitalizations and premature deaths.[15] 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.[16] Yet it exempts existing biomass plants—a source of today’s emissions.[17] 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.[18],[19] Drax has been cited for serious air quality violations at all three of its own U.S. pellet mills.


Biomass industry claims about “sustainable forestry” are greenwashing. The facts about biomass don’t change when industry proponents call it “sustainable.” When Drax’s pellets come from so-called “sustainably managed” forests, burning those pellets for electricity increases CO2 pollution for over 40 years.[20] And the main certifier of “sustainable” wood pellet imports into the UK, the Sustainable Biomass Program (SBP), is built using an industry self-policing approach and does little more than rubber stamp the damaging sourcing practices of pellet producers.



4)      Coal-to-biomass conversions are uneconomic and unnecessary for UK grid reliability

A 2017 study found that by 2025, the UK’s existing biomass conversions will be more expensive to run than building completely new solar and wind capacity, including grid integration costs.[21] A 2018 study demonstrates that the UK can decarbonise its electricity system by 2030 and meet year-round electricity needs even during the darkest, coldest, most windless days by relying almost entirely on new investments in wind, solar and smart resources and without any expensive and controversial biomass.[22]




What opportunities does this provide to reset the economy to drive forward progress on broader Government priorities, including (but not limited to) Net Zero, the UK outside of the EU and the ‘levelling up’ agenda? What should the Government do to ensure that delivering on these priorities does not exacerbate the vulnerability of businesses, consumers and communities/workers that have been impacted by COVID-19?



Building back better after the coronavirus means prioritizing the clean, low-cost and abundant climate solutions the UK already has, such as wind and solar. As the UK rebuilds its economy, the Government must consider where money is being spent and ensure public investment goes towards clean and climate-friendly growth. One area where reform can make an immediate difference is redirecting hundreds of millions in ROCs renewable energy subsidies for power stations that burn biomass to solar, wind and other true clean and renewable energy sources. With household budgets under pressure, there is absolutely no justification for the UK continuing to waste over £4.5 million a day subsidising fake solutions to climate change and increasing electricity costs for people in Britain when true renewables are already cheap and getting cheaper.


Biomass does not meet any of the Government’s tests for renewable energy investment:

The government of the United Kingdom has a three-pronged objective of grid reliability, affordability, and decarbonisation for its electricity supply. One way it endeavours to achieve this is by giving large subsidies to Drax Power and others for coal-to-biomass conversions— at a government cost to support Drax alone of nearly £2 million per day. Yet, scientists neither see largescale use of biomass for electricity as the preferred decarbonisation approach nor as the most cost-effective approach. A ground-breaking study in 2018 also showed that as soon as 2021, the UK could zero out biomass generation and meet year-round electricity demand, even under the most challenging conditions.[23]


Biomass is not ‘low carbon’:

A growing body of peer-reviewed, scientific studies show that burning wood from forests in power plants to produce electricity can increase carbon emissions relative to fossil fuels for many decades—anywhere from 35 to 100 years. This time period is significant: climate policy imperatives require dramatic short-term reductions in greenhouse gases, and these emissions will persist in the atmosphere well past the time when significant reductions are needed.


Science now tells us that burning biomass taken from forests, whether in the form of whole trees or residues, increases CO2 levels in the atmosphere over relevant timeframes for meeting Paris Climate Agreement commitments.


A report from the United Kingdom’s own previous Department of Energy and Climate Change[24] supports these findings, concluding that burning forest-derived biomass from whole trees and other large-diameter wood increases carbon emissions relative to coal and natural gas for decades.



Biomass will not lead to a phase-out of coal:

The government has also signalled its willingness to keep coal plants open if they are “abated,” either via biomass co-firing or conversion, under the same flawed assumption that all biomass is “carbon neutral” at the smokestack. Thus, continued investment in biomass threatens to erode the climate gains of a coal phase-out and wastes additional resources to extend the life of old coal plants that would otherwise shutter their doors.



What opportunities exist for the UK economy post Brexit and the pandemic for export growth?


In a post-Brexit and post-pandemic UK, opportunities exist for export growth for the UK economy. For example, with its world-class wind resources, the UK has an overwhelming competitive advantage in offshore wind and the industry offers significant export opportunities. Storage technology for electricity from genuinely low carbon renewables is another sector where the UK has the potential to become a world leader with significant export opportunities. By comparison, biomass offers no similar prospects for driving economic growth. Instead burning wood for bioenergy requires continued imports of costly pellets from overseas. The UK is the world’s biggest pellet importer.


July 2020

[1] Colnes, A., et al., Biomass Supply and Carbon Accounting for Southeastern Forests, The Biomass Energy Resource Center, Forest Guild, and Spatial Informatics Group, February 2012;   Harmon, M., Impacts of Thinning on Carbon Stores in the PNW: A Plot Level Analysis, Oregon State University, May, 2011;  Mitchell, S., Harmon, M., and O’Connell, K., Carbon Debt and Carbon Sequestration Parity in Forest Bioenergy Production, GCB Bioenergy, May, 2012;  Repo, A., et al., Sustainability of Forest Bioenergy in Europe: Land-use-related Carbon Dioxide Emissions of Forest Harvest Residues, GCB Bioenergy, March 2014;  Stephenson, A. L., and MacKay, D., Life Cycle Impacts of Biomass Electricity in 2020: Scenarios for Assessing the Greenhouse Gas Impacts and Energy Input Requirements of Using North American Woody Biomass for Electricity Generation in the UK, UK Department of Energy and Climate Change, July 2014;  Ter-Mikaelian, M., et al., Carbon Debt Repayment or Carbon Sequestration Parity? Lessons from a Forest Bioenergy Case Study in Ontario, Canada, GCB Bioenergy, May 2014;  Walker, T., et al., Biomass Sustainability and Carbon Policy Study, The Manomet Center for Conservation Sciences, June 2010.

[2] https://www.drax.com/wp-content/uploads/2020/03/Drax_AR2019_Web.pdf

[3] Stephenson, N. L., et al., “Rate of Tree Carbon Accumulation Increases Continuously with Tree Size,” Nature, March 6, 2014, http://www.nature.com/nature/journal/v507/n7490/full/nature12914.html

[4] EASAC, “Commentary by EASAC on Forest Bioenergy and Carbon Neutrality,” June 15, 2018, https://easac.eu/fileadmin/PDF_s/reports_statements/Carbon_Neutrality/EASAC_commentary_on_Carbon_Neutrality_15_Jun e_2018.pdf; Duncan Brack, “Woody Biomass for Power and Heat: Impacts on the Global Climate,” Chatham House, February 23, 2017, https://www.chathamhouse.org/publication/woody-biomass-power-and-heat-impacts-global-climate; Sami Yassa, “Think Wood Pellets Are Green? Think Again,” NRDC, May 2015, https://www.nrdc.org/sites/default/files/bioenergy-modelling-IB.pdf.

[5] Mary Booth, “Not carbon neutral: Assessing the net emissions impact of residues burned for bioenergy,” Environmental Research Letters, February 21, 2018, iopscience.iop.org/article/10.1088/1748-9326/aaac88

[6] Ember (previously Sandbag), Playing with Fire - An assessment of company plans to burn biomass in EU coal power stations https://ember-climate.org/wp-content/uploads/2019/12/2019-SB-Biomass-report-1.7b_DIGI.pdf

[7] EASAC, “EASAC’s Environmental Experts call for international action to restrict climate-damaging forest bioenergy schemes,” October 9, 2019, https://easac.eu/press-releases/details/easac-s-environmental-experts-call-for-international-action-to-restrict-climate-damaging-forest-bioe/; Beddington, J. et al. Letter from scientists to the EU parliament regarding forest biomass. Available at: http://empowerplants.files.wordpress.com/2018/01/scientist-letter-on-eu-forest-biomass-796-signatories-as-of-january-16-2018.pdf (2018). http://empowerplants.files.wordpress.com/2018/01/scientist-letter-on-eu-forest-biomass-796-signatories-as-of-january-16-2018.pdf (2018).

[8] Anderson, M.G. 2019. Wild Carbon: A synthesis of recent findings. Northeast Wilderness Trust. Montpelier, VT USA., https://rewilding.org/wild-carbon-a-synthesis-of-recent-findings/

[9] EASAC, “Commentary by EASAC on Forest Bioenergy and Carbon Neutrality,” June 15, 2018, https://easac.eu/fileadmin/PDF_s/reports_statements/Carbon_Neutrality/EASAC_commentary_on_Carbon_Neutrality_15_June_2018.pdf; Duncan Brack, “Woody Biomass for Power and Heat: Impacts on the Global Climate,” Chatham House, February 23, 2017, https://www.chathamhouse.org/publication/woody-biomass-power-and-heat-impacts-global-climate; Sami Yassa, “Think Wood Pellets Are Green? Think Again,” NRDC, May 2015, https://www.nrdc.org/sites/default/files/bioenergy-modelling-IB.pdf

[10] Mary Booth, “Not carbon neutral: Assessing the net emissions impact of residues burned for bioenergy,” Environmental Research Letters, February 21, 2018, iopscience.iop.org/article/10.1088/1748-9326/aaac88

[11] TV2, “TV2 reveals climate control errors,” September 10, 2019, https://nyheder.tv2.dk/samfund/2019-09-09-tv-2-afsloerer-fejl-i-klimakontrol-helt-sort-siger-ekspert; Channel 4 News Dispatches, “The True Cost of Green Energy,” aired Monday, April 16 2018; Joby Warrick, “How Europe’s climate policies led to more U.S. trees being cut down,” Washington Post, June 2, 2015, https://www.washingtonpost.com/national/health-science/how-europes-climate-policies-have-led-to-more-trees-cut-down-in-the-us/2015/06/01/ab1a2d9e-060e-11e5-bc72-f3e16bf50bb6_story.html; Justin Scheck, “Europe’s Green-Fuel Search Turns to America’s Forests,” WSJ, May 27, 2013, https://www.wsj.com/articles/SB10001424127887324082604578485491298208114;

[12] European Imports of Wood Pellets for “Green Energy” Devastating US Forests, NRDC, Dogwood Alliance and SELC, June 2019, https://www.nrdc.org/sites/default/files/european-imports-wood-pellets-greenenergy-devastating-us-forests.pdf

[13] Critical Ecosystem Partnership Fund, “Announcing the World’s 36th Biodiversity Hotspot: The North American Coastal Plain,” February 18, 2016, https://www.cepf.net/stories/announcing-worlds-36th-biodiversity-hotspot-north-american-coastal-plain

[14] Southern Environmental Law Center, “Southeast U.S. Wood Pellet Plants Exporting to Europe,” https://www.southernenvironment.org/uploads/maps/SELC_WoodPelletExportMap_2019_1126_map+table.pdf

[15] Letter from prominent health organizations 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-letter-biomass.pdf

[16] 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

[17] 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: 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/

[18] https://www.environmentalintegrity.org/wp-content/uploads/2017/02/Biomass-Report.pdf

[19] https://www.southernenvironment.org/news-and-press/press-releases/clean-air-carolina-challenges-air-permit-for-enviva-hamlet-expansion-in-ric

[20] SELC, “New Report Shows Wood Pellets From Drax’s U.S. Mills Increase Carbon Emissions During the Timeframe Necessary to Address Climate Change,” https://www.southernenvironment.org/uploads/publications/Biomass_Factsheet_0719_F_Pgs.pdf

[21] Sasha Stashwick, “Money to Burn II: Solar and Wind Can Reliably Supply the United Kingdom’s New Electricity Needs More Cost-Effectively Than Biomass,” NRDC, September 2017, https://assets.nrdc.org/sites/default/files/money-to-burn-ii-uk-biomass-ib.pdf?_ga=2.165636671.1426806616.1526490771-%20%201380781386.1517278009

[22] “Thermal Generation and Electricity System Reliability,” Vivid Economics, June 2018, https://www.vivideconomics.com/casestudy/thermal-generation-and-electricity-system-reliability/

[23] Sasha Stashwick, “Reality Check: Biomass is Unnecessary for the Reliability of UK Electricity Supply—and So Are Continued Subsidies to Drax Power,” NRDC, June 2018, https://www.nrdc.org/sites/default/files/reality-check-biomass-uk-electricity-ib.pdf

[24] Dr Anna L Stephenson, Professor David J C MacKay FRS, Life Cycle Impacts of Biomass Electricityin 2020 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/349024/BEAC_Report_290814.pdf