Written evidence submitted by the Southern Environmental Law Center (CCU0387)

  1. Introduction

              The Southern Environmental Law Center (“SELC”) is a nonprofit organization located in the Southeastern United States. SELC has used the power of the law to champion the environment of the Southeastern U.S. for more than 30 years. SELC is widely recognized as the Southeast’s foremost environmental organization and regional leader. SELC works on a full range of environmental issues to protect our natural resources and the health and well-being of all the people in our region. www.SouthernEnvironment.org 

              SELC is submitting this evidence as part of our ongoing efforts to seek reform of energy policies in Europe and the UK that are escalating demand for wood pellets harvested from the Southeastern U.S. to fuel European power plants. SELC is particularly concerned with the implications of the Government’s CCUS inquiry on a technology referred to as BECCS—bioenergy with carbon capture and storage.

  1. Executive Summary

              SELC is concerned with the use of CCUS—and BECCS in particular—as a means to meet the UK government’s carbon reduction targets under the UK Climate Change Act or the Paris Agreement. CCUS technology is currently untested and infeasible at the scale contemplated by many of the 2° scenarios reviewed in the IPCC AR5. BECCS, in particular, has not been proven to result in negative emissions after accounting for direct and indirect life-cycle emissions. SELC’s submission will therefore focus on the following main points:

For these reasons, discussed more fully below, SELC recommends that the government support proven, low-carbon renewable energy sources—such as wind and solar—in order to meet its carbon reduction targets. CCUS technology, BECCS, and biomass electricity are not necessary to meet the UK’s carbon reduction goals, and continued support for biomass and BECCS will undermine these goals by increasing short- and medium-term carbon emissions over coal and gas.

  1. Responses to Inquiry

Question 1: How essential is CCUS for the UK to meet its carbon emission reduction targets to 2050?

1.              Implementation of CCUS is not essential for the United Kingdom to meet its carbon emission reduction targets to 2050. A recent report by Vivid Economics (the “Vivid report”), working with the Imperial College, tested a future energy scenario in the UK that utilizes solar and wind energy, phases out biomass electricity generation, and still meets year-round electricity demand by 2030 without deploying any CCUS. Specifically, the “High Renewables Scenario” tested by the Vivid report achieves reliable year-round electricity and produces a carbon emissions intensity of 100 gCO2/kWh, which is in line with the UK Committee on Climate Change’s recommendations in the Fifth Carbon Budget.

2.              Under the High Renewables Scenario the UK can achieve a reliable, low-carbon electricity system by 2030 by utilizing high levels of variable renewables and low levels of thermal generation capacity. This scenario includes divesting biomass from the UK energy portfolio while increasing wind, solar, and smart resources for reliable renewable energy that limits carbon emissions. Additionally, this scenario requires no new nuclear beyond Hinkley Point C and no CCUS deployment. Instead, over 60 percent of electricity generation in 2030 will come from wind (37 GW offshore and 18 GW onshore) and solar (41 GW) capacity.               

3.              The Vivid report addressed the UK’s goal of system reliability while also seeking to ensure electricity supply, decarbonization, and affordability. It designed tests to confirm the reliability of an electricity system by testing the adequacy, reserve, inertia, and frequency response of the system.[1] The High Renewables Scenario passed all four tests, demonstrating the UK’s ability to maintain a reliable electricity system while employing a high level of renewables and no CCUS. Specifically, under this scenario the electricity system was able to:

Notably, all four requirements for reliability—adequacy, reserve, inertia, and frequency response—can be met without CCUS by utilizing and expanding technology that is already close to the current UK market. Thus, according to the Vivid report, the UK can operate with a reliable, low-carbon electricity system by 2030 without deploying CCUS and without biomass energy generation.

4.               Furthermore, there are many technical challenges to incorporating CCUS technology to power stations. According to the European Academies Science Advisory Council, CCUS for power stations remains in an unproven and largely demonstrative phase, with little evidence to suggest that reliable solutions have been found to reduce the upfront energy costs that result from integrating CCUS technology into power stations. In fact, integrating CCUS into power stations has proven extremely difficult for each stage of CCUS—capture, transport, and storage. As a result, many proposed projects are withdrawing CCUS efforts altogether.

5.              Moreover, the barriers to deployment expand and become harder to overcome when CCUS is combined with biomass-generated energy. Bioenergy with carbon capture and storage (“BECCS”) is erroneously relied upon by climate modelers as a “negative emissions technology” (“NET”) to achieve the Paris Agreement’s targets. BECCS is also erroneously assumed to be a net producer of electricity. However, the energy intensity of the biomass supply chain coupled with inefficient power generation could result in BECCS being an “energy negative technology.” For example, Fajardy and Mac Dowell (2018) found that a UK-based BECCS facility that utilized imported willow wood pellets from Louisiana, U.S., was an energy negative BECCS system. Even if a specific BECCS facility is a net producer of energy, it is unlikely to also deliver emissions reductions. Instead, these two goals are inversely related, with more efficient power plants actually removing less CO2 than less efficient plants. Accordingly, Fajardy and Mac Dowell (2018) suggest that a BECCS facility must prioritize one function over the other in order to be successful—either energy production or carbon dioxide removal.

6.              Additionally, there is no scientific basis for assuming that BECCS can deliver negative emissions after accounting for all direct and indirect life-cycle emissions of biomass. The success of BECCS power plants is dependent, in part, on the biomass fuel source being used, including its cultivation, transportation, and energy content, the sum of which creates a carbon debt that must be incorporated into carbon accounting for the BECCS facility. The actual carbon debt of BECCS facilities, particularly when those facilities utilize woody biomass as fuel, cannot be made up for within the next 10 to 20 years, as is necessary to meaningfully respond to climate change. See Carbon Evidence (Section V).

7.              Multiple studies have also demonstrated that implementation of BECCS is an unsustainable drain on natural resources, specifically as it relates to land and water availability. According to Fajardy and Mac Dowell (2018), a UK-based BECCS fleet, at a scale designed to remove 50 MtCO2 per year, could require up to 22 million hectares of land and up to 175 billion m3 of water per year.

8.              Specifically, deploying BECCS at a scale necessary for major climate mitigation would require significant areas of land, which would compete or overlap with land availability for food production, urban growth, reforestation / afforestation efforts, and maintaining biodiversity. In fact, some studies estimate that BECCS at this level would require utilizing 1/3 of all arable land on Earth. For example, Fajardy and Mac Dowell (2018) concluded that the UK-BECCS fleet reliant on imported pellets from Louisiana would require 22 million hectares of land. In comparison, Louisiana’s total land area is only around 13.5 million hectares, with much of that land already being used for other purposes.

9.              Natural resources and technical challenges are not the only barriers to BECCS—it is also financially unsustainable. Land and biomass fuel supply limitations significantly increase the cost of BECCS once the project’s carbon removal rate reaches large-scale deployment. With limited resources on the horizon, BECCS does not have the necessary investor confidence to reach large-scale deployment.

10.              In sum, more often than not, BECCS will produce a carbon debt due to land conversion for biomass production which cannot be offset within the power plant’s operational lifetime. Additionally, large-scale implementation of BECCS could result in depletion of other important natural resources, like land and water. When combined with the technological obstacles associated with CCUS generally, CCUS and BECCS are not feasible or sustainable paths forward for the UK to achieve its carbon reduction targets.

Question 2: How should the Government set targets for cost reduction in CCUS?

11.               We are not responding to this question.

Question 3: How could CCUS costs be usefully benchmarked?

12.               We are not responding to this question.

Question 4: What would be a realistic level of cost reduction to aim for—and by when?

13.               We are not responding to this question.

Question 5: If CCUS costs do not come down “sufficiently,” what alternatives should the Government consider to meet the UK’s climate change targets?

14              As discussed above, the UK can meet its 2050 carbon emission reduction goals without the use of CCUS and additionally without the use of biomass energy. Biomass, therefore, is not a necessary alternative for the UK to meet its carbon reduction targets. Instead, the government should support genuine, low-carbon renewables such as wind and solar. Additionally, continued support for large-scale biomass electricity generation will undermine the UK’s broader climate and clean energy goals. As explained more fully in a letter to Secretary Greg Clark, dated 25 October 2017, from SELC and other environmental NGOs, biomass power plants emit more CO2 at the stack than coal or gas plants, with any hypothetical carbon “benefit” not occurring for decades or longer; the wood pellet industry in the Southeastern U.S., which supplies much of the UK’s biomass, contributes to the destruction of some of the world’s most ecologically valuable forest ecosystems; and air pollution from wood pellet mills and biomass power stations degrade air quality and health in local communities. See Appendix. Thus, the UK should not use biomass as an alternative path to achieving its carbon reduction goals.

Question 6: How might the cost of these [alternatives] compare with CCUS?

15.               We are not responding to this question, but would refer the government to a 2017 report by Vivid Economics demonstrating that solar and wind energy can reliably supply the UK’s electricity needs as it phases out coal more cost effectively than biomass conversions. Natural Resources Defense Council, Fact Sheet, Money to Burn II: Solar and Wind Can Reliably Supply the United Kingdom’s New Electricity Needs More Cost-Effectively than Biomass (2017), https://www.nrdc.org/sites/default/files/money-to-burn-ii-uk-biomass-ib.pdf.

  1. Evidence

 

August 2018

The following is a list of resources specifically relied on in the above responses:

The following is a list of additional resources for consideration during the government’s consultation:

  1. Carbon Evidence

 

The follow is a list of evidence demonstrating that burning biomass for electricity is not carbon neutral.

 

 


 

 

 

 

 

 

 

 

APPENDIX

 

NGO Letter to Secretary Clark (Oct. 25, 2017)


Description: NRDC_Logo_FullName.jpg                             Description: Letterhead logo.jpg              Description: BFWlogo (002).png                           

 

 

25th October 2017

 

 

Dear Secretary of State,

 

We, a coalition of environmental NGOs based in the United Kingdom and United States, are writing to share our concerns regarding the impacts of ongoing UK Government support for biomass electricity generation in UK power stations. We would like to thank the Prime Minister and the Government for re-committing to phase out coal by 2025. However, we believe that UK Government support for switching to biomass as a coal abatement strategy, whether via co-firing or coal-to- biomass conversions, will not only undermine the climate change mitigation aims of this phaseout, but the country’s broader climate and clean energy goals.

 

In the Government’s response to BEIS oral questions on Tuesday 12th September, the Minister for Climate Change and Industry, Claire Perry, stated the UK's imported biomass was ‘both sustainable and carbon beneficial,’ thanks to the UK’s ‘strict sustainability criteria.’ The Minister had no comment on the question posed about the significant level of subsidy awarded to the biomass industry. There is, however, an abundance of compelling evidence that the UK’s large-scale use of biomass for electricity harms the environment, increases the UK’s carbon emissions impact, and wastes public funds. We have summarised this evidence in the attached explanatory note and annotated bibliography.

 

We note instances where UK Government statements do not reflect accurately the results of UK- commissioned reports and current science. Specifically, the ‘follow-on report’ cited by the Minister, completed by Ricardo-AEA for BEIS on high-carbon biomass scenarios, shows that hardwood trees— one of the highest-carbon sources of biomass—are being used for electricity in the UK, contrary to assertions made by the Minister.

 

Additionally, the Government’s Clean Growth Strategy (CGS) envisages a 36% increase in the use of bioenergy by 2023, particularly for the heat, heavy industry, and transport sectors. However, current levels of demand are already unsustainable, and many types of woody biomass have a significant impact on the climate and environment.

 

Of significant concern is the CGS’s discussion of the role of woody Bioenergy with Carbon Capture and Storage (BECCS). The CGS looks for BECCS to deliver “negative emissions”; however, CCS in conjunction with forest biomass suffers from the same major environmental shortcomings associated with standalone electricity production from forest biomass, and the carbon costs of harvesting forests for fuel make this scenario unlikely. In a current consultation investigating bioenergy subsidies, BEIS acknowledges that, "[compared to other renewable technologies]…carbon savings from biomass conversion or co-firing are low or non-existent, and the cost of any savings is high."

 

The information provided herein covers the following risks posed by burning biomass for electricity:

 

 

Your Department could take three important steps today to minimise these risks:

 

  1. Rule out biomass co-firing or conversion as an abatement option in the coal phaseout.
  2. Rule out any new subsidy for biomass electricity generation, including for biomass conversion, under the Contracts for Difference regime, and use the current consultation to immediately ramp down Renewables Obligation subsidies for biomass co-firing and conversion.
  3. Remove biomass as a generating technology eligible to bid for capacity agreements in the Capacity Market.

 

In addition, we urge the Government to review policies that sit beneath the UK’s Bioenergy Strategy. The EU is currently determining accounting rules for land use, land use change and forestry (LULUCF) for the post-2020 period. The EU’s decision will have international significance. It is crucial that the UK and EU’s accounting rules account honestly for any decrease in forest sinks.

 

Attached to this letter is a more detailed explanation of the evidence on the risks posed by biomass electricity, as well as an annotated bibliography of supporting studies from government, NGOs, and academics. We hope that these materials can serve as a resource to you and your staff. We are aware that Drax had a meeting with Ministers on Monday 9 October and respectfully request a meeting with you at your earliest convenience to discuss these issues.

 

 

 

[1] The Vivid report defines “adequacy” as the ability to meet demand at all times during normal operations of the system. “Reserve” is the availability of spare generating capacity to address unexpected reductions in output or increases in demand. “Inertia” considers whether there is enough synchronous capacity generating electricity at all times to maintain inertia above a given threshold. “Frequency response” considers whether there is enough spare generating capacity at all times to correct the frequency deviation that would occur in the event of the largest possible loss of supply, such as losing a generator or interconnector.