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BIOENERGY:A BURNINGISSUE

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SUMMARY

The UK is currently witnessing a major rush to build large-scale electricity-onlybiomass plants as well as seeing an increase in biomass used in co-firing. The scaleof proposed power plant development dwarfs the planned use of domestic fuel

resource. Instead, many of these new plants are expected to be dependent on importedbiomass. They are generally being built on the UK coast near port facilities with expectedsources of feedstock from Canada, the US, Russia and the Baltic States, among others.Furthermore, new plants are often being sited in locations where it is either not possible ornot economic to capture the substantial quantities of heat produced, significantly reducingtheir efficiency and therefore their ability to deliver greenhouse gas emissions reductions.

The RSPB has conducted analysisto understand the scale of theexpected reliance on imports ofbiomass. This analysis shows thatcurrent planning proposals in theUK indicate a substantial shiftfrom primarily domestic supply(74%) to a bioenergy industrybased largely on imports (81%).Wood imports in particular willincrease substantially from 13%to 68%, resulting in wood beingthe most significant feedstocktype for UK biomass plants. Thiswill be in addition to the alreadyhigh level of wood imports fornon-biomass use. Althoughabsolute levels of waste used forbioenergy will increase, inrelative terms the waste sector isexpected to play a much morelimited role, providing just 15%of overall feedstock.

With the bioenergy sector on theverge of rapid growth, the UKfaces an urgent choice about itsfuture development. Withoutintervention, it will be dominatedby large-scale production ofelectricity from biomass, lockingus into massive andunsustainable demand for woodthat will be needed to keep theseplants running for decades tocome. The UK has rightlyembraced the need for renewableenergy, which is essential in thefight against dangerous climatechange. However, it is imperativethat the renewable energyindustry develops sustainablyand environmental impacts arenot ignored. An unsustainablebioenergy industry risks seriousdamage to wildlife and theclimate by driving substantial

additional logging overseas. We need to avoid the mistakesthat were made in the liquidbiofuels industry where policiesled to large-scale unintendedenvironmental and socialconsequences. The RSPBbelieves, however, that asustainable bioenergy sectorbased on wastes and domesticfeedstocks is possible – if the UKGovernment acts now toencourage more sustainabletechnologies at appropriatescales, rules out subsidies forlarge-scale electricity productiondependent on imported wood,improves sustainabilitystandards, and fully accounts forall emissions from bioenergy.

Bioenergy: a burning issue

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INTRODUCTION

This report reveals thefindings of RSPBresearch and analysis

into the future of the UK’srapidly expanding bioenergyindustry, provides anassessment of the size andnature of the environmentalthreat this expansion riskscreating, and proposespolicy solutions that wouldlead to an alternative futurefor the sector whichdelivers for the climate andthe wider environment.

Our analysis is based on thelatest available data for the UK’scurrent and proposed bioenergyplants and the expected sourcesof feedstock required to fuelthese plants. We use data madepublicly available by power

companies and local authoritiestogether with data collated by theENDS Report and biofuelwatch.For a full list of data sources andassumptions please turn to theback page of this report.

Bioenergy is the catch-all term for heat and power fromorganic materials. The terms biomass and feedstocks

refer to material fuelling a bioenergy plant, which includeswood from forestry and woody energy crops as well asagricultural residues and wastes. Co-firing is thecombustion of biomass with coal in existing plant.Imported virgin wood refers to all imported woodymaterial intended for use as a bioenergy feedstock thathas been removed from existing natural or semi-naturalforests and fast growing forestry plantations.


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THE UK’SBIOENERGY PLANS

Under the Renewable Energy Directive, the UK has agreed a target to generate 15% of its energy from renewables by 20201. This target has been critical in drivingrenewables investment in the UK and across the continent, and the RSPB

therefore strongly supports it. All EU Member States, including the UK, produced aNational Renewable Energy Action Plan (NREAP) in 2010. This document detailsgovernments’ plans for meeting their targets, and the role they envisage for eachtechnology, including bioenergy2. These plans were further developed in the UK’s recentlypublished Renewable Energy Roadmap.

The Roadmap shows that in 2010there was 2.5 GW of biomasselectricity installed in the UK4,much of which was producedfrom landfill gas. This capacity isexpected to increase up to 6 GWin 2020, principally from solidbiomass. This would require an

equivalent of around 36 millionoven dried tonnes (odt) of woodin 2020 compared to the demandin 2010 of 15 million odt5.Dependent on the feedstock, thisreflects at least a doubling in theamount of biomass needed forelectricity production. However,

it is not the whole picture as anadditional 10 million odt wouldalso be needed to meet thedemands from the biomass heatsector in 2020.


1 Directive 2009/28/EC on the promotion of the use of energy from renewable sources 2 http://ec.europa.eu/energy/renewables/transparency_platform/action_plan_en.htm3 http://www.decc.gov.uk/assets/decc/11/meeting-energy-demand/renewable-energy/2167-uk-renewable-energy-roadmap.pdf4 Includes 0.4 GW of co-firing capacity 5 Calculated using figures in the UK NREAP (as cited in footnote 3) and a conversion factor of 6,000,000 odt/GW (SQWenergy: Renewable and Low-carbon Energy Capacity Methodology, Jan 2010)

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CURRENTDEVELOPMENTS INTHE UK’S BIOENERGYSECTOR

The RSPB has analysedthe latest data onproposals for biomass

power plant and co-firingacross the country toestablish how the sector isdeveloping to meet thetargets set out in the UKAction Plan and to assess thescale of the environmentalrisks this may pose. Table 1shows current and futurepower plant developments.

These plants will each havesignificant demands for biomassas shown in the map overleaf. Alloperating and projected plantswith a yearly biomass demand ofmore than 50,000 tonnes areshown as circles. The coloursshow the proportion of importscompared to domestic supply,while the size of each circle reflectsthe expected biomass demand in

tonnes of biomass delivered peryear. The average demand perplant is 840,000 tonnes ofbiomass, but ranges from smallerplants such as Longannet(number 23 on the map), whichco-fired 56,621 tonnes of biomassin 2010, to the largest, Tilbury B(number 49 on the map), expectedto need 7.5 million tonnes ofbiomass per year.6

Electricity-only or combined heat and power (CHP)?

Table 2 shows the different types of bioenergy plants that are operating or are projected tobe operating in the UK. It highlights a huge growth in electricity-only generation with newplants often being sited in locations where it is either not possible or not economic to capturethe substantial quantities of heat produced. In electricity-only plants, however, a largeproportion of the energy is wasted. In fact, emissions from a CHP plant in terms ofkgCO2/MWh of useful energy generated are four times lower7. The less efficient the plant,the greater the quantity of feedstock needed to fuel it for the same output.

Table 1: Number of solid biomass plants operating or planned in the UK


6Some plant are clustered in one area, lines indicate their actual location.7Environment Agency (2009) Carbon sink or carbon sinner.

Operating Approved In planning ProposedNo. of plants 31 14 16 9

6


Table 2: Types of energy plants identified in this report8

Type

No. of plants

Operating Total projected

co-firing13

electricity12

CHP6

co-firing13

electricity44

CHP12

7


If all plants currently proposedwere to be built, a total of 48.3million tonnes of biomass wouldbe needed to fuel UK biomassplants. This is 9.3 times thecurrent levels of biomass usedannually (see Figure 1) .

It can also be seen that by 2020, if all current and projected plantswere operating, the biomassmarket would be dominated byimports. Domestic sources wouldmake up only 19% of the biomassused by the sector. Thissubstantial increase in biomassimports would require a total of39.1 million tonnes of biomass ayear – approximately 29 timeshigher than total importedbiomass in 2010.

BIOMASSFEEDSTOCKSSo what type of feedstocks canwe expect to meet this hugeincrease in demand? Figure 2shows the current and projectedfeedstock sources for thebioenergy sector.

Our analysis shows that most ofthe additional domestic supplywould be sourced from waste,with the remainder coming fromforestry. The highest increase,however, is expected to comefrom imported wood,contributing 68% of the totalbiomass supply. Plans alsoindicate companies intend toincrease imports of bioenergycrops. Some companies, whileleaving their options open forbiomass supply, intend to locatetheir plants near port facilities in

order to import biomassfeedstocks. A small fraction ofbiomass will be agriculturalwaste imported from palm oilplantations in South East Asia.

This massive increase inimported wood suggests therewill be a substantial shift in thecomposition of biomass used in

the UK; the fraction of biomasscoming from wood is expected toincrease from 50% to 73%, anadditional 32.3 million tonnes13.This figure is comparable withanalysis by Confor, whichprojected 2020 wood imports of27 million tonnes. This should beconsidered in the context of

Figure 1: Annual biomass requirement for UK solid biomass plants

Figure 2: UK biomass supply for operating solid biomass plants versus

projected total solid biomass plants12

8 Tilbury B (RWE) operates as a co-firing plant but the application to convert it into a biomass-only electricity plant is also approved. 9 Comparing findings for UK biomass plants with their current biomass consumption and the projected demand.10 Note that not all proposed plant may be built and that tonnes of biomass received will always be a higher quantity than oven dried

tonnes of wood because of the lower energy content of mixed biomass sources.11 The projected requirement includes solid biomass demands of operating, approved, in the planning system and proposed plants.12 Projected total biomass supply and total future plant include operating, approved, in the planning system and proposed plant.

Total of 5.2 million tonnes of biomasss Total of 48.3 million tonnes of biomass

ProjectedOperating

8

substantial existing UK importsof wood-based products such assawn wood and wood-basedpanels, and pulp and paper, thelatter alone contributing 8.5million tonnes14.

Based on our analysis, the totalamounts of waste imports forbioenergy generation are alsoexpected to rise, with plansshowing an additional demandof 400,000 tonnes per year.However, the proportion ofwaste used as biomass isexpected to decrease from 42% to15%, as a result of the substantialincrease in the use of wood.


13 http://www.confor.org.uk/Upload/Documents/37_WoodFibreAvailabilityDemandReportfinal.pdf 14 http://www.forestry.gov.uk/pdf/trprod10.pdf/$FILE/trprod10.pdf

Graham

e Madge (rspb-im

ages.com)

12 electricity-only biomass plants have been built

in the UK with a further 32 proposed.

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ENVIRONMENTALRISKS OF RELIANCEON LARGE-SCALEWOOD IMPORTS


15 http://www.wwf.org.uk/filelibrary/pdf/logging_full_report01.pdf

Locking into a biomass electricity sector reliant on massive imports of wood posessignificant risks. Large-scale logging in countries such as Canada, Russia, the UnitedStates and South Africa to meet demand in the UK could have substantial impacts on

the climate and wildlife. Mitigating these will be challenging, if not impossible. The UK hasonly recently started to bring under control imports of timber for non-bioenergy use, havingbeen the world’s third largest importer of illegal timber in 200715.

A heavy reliance on imports alsomarginalises domestic supplywhere environmental impactscan be more easily addressed and controlled. It missesopportunities to securesubstantial wider environmentalbenefits by sensitively bringingthe UK’s native woodlands intogood biodiversity condition andit ignores significant domesticwaste streams and opportunities.

CLIMATE RISKS OFIMPORTSOne of the key reasons the UKGovernment is supporting

bioenergy, and why UK energyconsumers are paying subsidiesto the sector through theirelectricity bills, is becausebioenergy is considered to be alow carbon energy source. This isby no means certain, however,particularly if it is fuelled largelyby imported wood. This is inspite of the fact that Governmenthas proposed a greenhouse gasemissions standard for biomass.Particular problems include thebiological issue of carbon debtfrom wood combustion, thepolitical issue of flawedinternational accounting rules

and the logistical issue ofadditional transport emissionsattached to biomass imports.

1Carbon debt Our analysisshows an expected increasein the consumption of

imported wood to meet UKbioenergy needs. When woodand other biomass is burnt in apower station, it releases carbondioxide, just like fossil fuels.These emissions are ignored inGovernment’s proposedgreenhouse gas emissionsstandard on the grounds thatemissions from combusting

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16 Eg Walker, T. (ed.). 2010. Massachusetts Biomass Sustainability and Carbon Policy Study: Report to the Commonwealth ofMassachusetts Department of Energy Resources. Manomet Centre for Conservation Sciences and Zanchi, G., Pena, N., Bird, N.2010. The upfront carbon debt of bioenergy. Joanneum Research.

17 IPCC Guidelines for National Greenhouse Gas Inventories: http://www.ipcc-nggip.iges.or.jp/public/2006gl/index.html18 http://www.environment-agency.gov.uk/static/documents/Leisure/Biomass__carbon_sink_or_carbon_sinner_summary_report.pdf

wood are compensated for whenforests regrow after harvesting.Yet studies16 show that trees takedecades or even centuries toreabsorb the initial carbon lost tothe atmosphere and thereforerepay the “carbon debt” fromtheir combustion.

2Flawed carbon

accounting rules

International guidance17

requires emissions frombioenergy to be accounted for inthe land use, land-use changeand forestry (LULUCF) sector.This means that the carbonreleased is recorded when andwhere wood is harvested, notwhen it is combusted. It istherefore counted as zero carbonin the energy sector as theemissions have theoreticallyalready been accounted for.However, new accounting rulescurrently being negotiated underthe United Nations FrameworkConvention on Climate Change(UNFCCC) will allow asignificant proportion ofemissions from forestry andagriculture to go unaccounted.What’s more, developingcountries, and countries thathave not signed the KyotoProtocol, like the US, will notaccount for these emissions at all.This means millions of tonnes ofcarbon emissions arising fromburning biomass imported from

these countries will be entirelyunaccounted for. For example,the 7.5 million tonnes of biomassexpected to be imported annuallyto feed the Tilbury biomass plant,partly sourced from the US, willfalsely be accounted as zero-carbon, despite massiveemissions from this combustionbeing released.

3Higher life-cycle

emissions from imports

It is essential thatemissions arising from bioenergythroughout its life cycle are takeninto account, minimised andshown to be substantially lowerthan the fossil-fuel equivalent.Feedstocks transported overlarge distances, for example fromRussia, South America, the USand Canada will see a higher

contribution from transportemissions to life-cyclegreenhouse gas emissions,undermining the climate benefitsof these feedstocks18.

WILDLIFE ANDECOSYSTEM RISKSOF IMPORTSWood demand to fuel UKbiomass plants will be fulfilledeither through logging existingforests or establishing plantationson new land. Both can potentiallylead to serious harm to wildlifeand ecosystems.

Logging of old growth or semi-natural forests for biomass can bevery damaging to wildlife as vitalhabitat is destroyed. Equally,over-extraction from managedforests by, for example, removing

Canadian Parks and W

ilderness Society

Clearance of land to meet bioenergy

demand in Nova Scotia, Canada.

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19 http://cpaws.org/uploads/pubs/facts_woody-bioenergy.pdf 20 http://www.forthenergy.co.uk/sustainability-statements.asp21 US Forest Service Southern Forest Research Assessment as cited in http://www.foe-scotland.org.uk/biomass-us-objection

dead wood and extractingstumps, can also have significantimpacts on biodiversity,hydrology and soils. Data showthat imports of wood into the UKfrom Canada are expected toincrease significantly. BritishColumbia has seen increasedextraction of woody biomass thatwould previously have been leftbehind after traditional loggingpractices in response to demandfor wood for bioenergy19. Whenleft in the forest, this woodybiomass provides habitat andshelter for birds, such aswoodpeckers and owls, andmammals, such as the pinemarten. It supports a widediversity of smaller organismsfrom insects to fungi, as well asmicro-organisms which supportthe nutrient cycle. Finally, itprotects the soil from erosion into

streams and serves as a source ofnutrients and moisture for thegrowth of new trees. Removal ofdead wood therefore hassignificant detrimental impactson this ecosystem.

In Florida, the scale of impacts isalso expected to be verysignificant. There are currently anumber of proposals, which maysource biomass feedstock fromFlorida. For example, ForthEnergy has submittedapplications to construct andoperate four biomass powerstations in Scotland, which ifconsented, could lead tosubstantial imports of wood. Theapplication suggests that up totwo-thirds of the imported woodmay initially be sourced fromFlorida20. Our calculations showthis could be equivalent to up to

3.3 million tonnes of biomassannually. This area contains someof the most biodiversity-richecosystems in North Americaand has already experiencedhuge losses, with the conversionof natural forest to industrial pineplantations. According to the USForest Service Southern ForestsResearch Assessment, only about182 million acres of the original356 million acres of natural foreststill remain21. New demand forwood production from theseforests will only put increasingpressure on this resource.

Plantations, if poorly sited, canalso risk the destruction of otherimportant habitats for wildlife.Areas at risk include semi-natural grassland, heathland,partially drained peat andbogland, and scrubland. Withoutsignificant improvements inresource efficiency, whendedicated biomass crops such aseucalyptus or short rotationcoppice are grown on land thatpreviously produced food (orother products for which there isan established market), thedemand for land to produce foodwill increase and inevitablyproduction will be shiftedelsewhere. As well as impactingon the greenhouse gas savingsassociated with bioenergy, thisindirect land use change can leadto negative impacts on

Mike B

eedell

Over-extraction of woody biomass for bioenergy removes

the habitat of the great grey owl in Canada.

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biodiversity, resource availabilityand other ecosystem services.

WHYSUSTAINABILITYSTANDARDS AREINADEQUATE In response to concerns alreadyraised by the RSPB and otherenvironmental organisations, theUK Government has recentlyproposed sustainability criteriafor solid biomass based on thosedeveloped for biofuels andbioliquids in the RenewableEnergy Directive. Thesestandards are often used byindustry and Government as thejustification for their plans forlarge-scale expansion of thesector, yet they arefundamentally flawed for fourprinciple reasons:

1Biodiversity protection is

limited They provide limitedprotection for certain highbiodiversity and high carbonstock areas from conversion forbioenergy. However, they do notdeal with the bulk of biomassproduction likely to arise fromexisting forestry resource wherethe key issue outside the UK isover-exploitation andunsustainable harvesting.Government’s proposals to dealwith this are currently unclear.

2Significant greenhouse gas

emissions will be permitted

The Government is proposing a60% threshold for emissions

savings from bioenergycompared to fossil fuels.However, bioenergy could easilydeliver much higher savings andindeed should be incentivised todo so through a higher emissionsstandard. Furthermore, theemissions from combustingbiomass will be largelyunaccounted for as a result offlawed greenhouse gas rulesunder the international carbonaccounting system for land use,land-use change and forestry(LULUCF) under the KyotoProtocol.

3The scale of demand will be

overwhelming The sheerscale of demand will result inindirect impacts, which cannot beaddressed through sustainabilitystandards. Such impacts includethe displacement by energy cropsof other land uses into valuablehabitats for biodiversity whichare also often important carbonstores. Indirect impacts cansignificantly alter the carbonprofile of a particular feedstock.

4Enforcement outside the

UK is not guaranteed

Sustainability standards forbiofuels, which form a basis forthose used for biomass, are notworking in countries with poorenvironmental laws and/orenforcement. For example,European companies havepermission to convert woodlandareas in Dakatcha, North Kenya,for jatropha plantations.

FORESTMANAGEMENTSTANDARDSThe UK Forestry Standard(UKFS) has been developed forforestry in the UK. At themoment, this does not entirelyguarantee sustainability for UKgrown forestry biomass. TheRSPB has concerns regarding theagricultural and planning systemexemptions from UKFScompliance, the rigour andquality of auditing for UKFScompliance, and the continuedrestocking of priority openground habitats, such as lowlandheathland and blanket bog.Nevertheless, the UKFS ismandatory and sets standards forgood practice and, alongside thevoluntary UK WoodlandAssurance Standard (UKWAS),provides a framework underwhich it is possible to bringdomestic woodlands back intomanagement for bioenergyproduction in a way that benefitsrather than harms wildlife.

Many countries do not have anequivalent standard and forestlaws vary widely. Indeed, thereare no EU-wide or globalstandards for bioenergy, orproposed EU legislation toharmonise forest management orfelling laws. The UK Governmentand the devolvedadministrations are notproposing to apply the Forest

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Stewardship Council (FSC)requirements to imports. FSC hasrobust environmentalrequirements combined with aneffective chain of custody fortraceability of wood productsfrom the forest through to the enduse. Without the use of robuststandards, it will be impossible tocontrol or limit the damage towildlife and ecosystems expectedfrom reliance on bioenergyimports.

We note the work done by the UKGovernment and devolvedadministrations on procurementguidance for their own timberand wood product purchasing.This needs wider adoptionoutside government, ensuringcredible assessment ofenvironmental sustainability. The RSPB does, however, haveconcerns about how the UKGovernment and devolvedadministrations define“sustainable” timber sourcing viaguidance from its Central Point ofExpertise on Timber. Theinternational standards itrecommends must have crediblesite level auditing and equitablerepresentation fromenvironmental and socialinterests in addition to economicconcerns, as well as have stronggovernance, be transparent andcontain robust biodiversityrequirements.

Chris G

omersall (rspb-im

ages.com)

Forest management must be

carried out in a sustainable way.

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WHAT IS THESOLUTION?

The RSPB believes that bioenergy can play a significant and environmentallysustainable part of the UK’s low carbon energy mix, making a genuine contributionto mitigating climate change. This will require prioritising the most carbon-effective

and sustainable means of bioenergy production and use, in a way that limits damage toand preferably benefits biodiversity.

So how can the UK achieve thisvision in the context ofsubstantial additional demandfor biomass, while avoiding theclimate and wildlife risks fromhigh levels of importshighlighted above?

The European EnvironmentAgency (EEA) investigated thepotential of all EU-25 States togenerate biomass in a sustainableway in 202022 utilising feedstocksfrom agriculture (bioenergycrops), forestry (wood) andwaste. The EEA suggestedcriteria for each sector to ensure amore sustainable approach23.

For agriculture, the criteriainclude:• meeting EU targets of 30%

of agricultural land being

devoted to “environmentally-orientated farming” by 2030;

• establishing ecologicalcompensation zones;

• choosing low environmentalimpact bioenergy crops.

For forestry, the criteria involve:• respecting existing protected

forest areas;• leaving foliage and roots on site

post-harvesting;• limiting the extraction rate of

residues from stem andbranches;

• reducing the area available forwood supply by 5% in eachMember State to allow anincrease in protected woodland;

• setting aside 5% of dead woodand large diameter trees by volume.

Finally for waste, the criteriainclude:• an overall target to reduce the

amount of waste produced andto ensure that no wastecurrently reused or recycled isused for energy production;

• household waste currentlydestined for landfill or compostcan be utilised for bioenergyproduction, alongside somewaste products from theagricultural sector.

Based on these criteria, the EEAcalculated the potentialenvironmentally compatiblecontribution of different biomassfeedstocks for the UK in 2020 (see Figure 3).

According to the EEA’s criteria,the contribution from thedomestic forestry sector could be


22 European Environment Agency (2006):How much bioenergy can Europe produce without harming the environment?, No 7, 67 pp.,ISBN 92-9167-849-X, ISSN 1725-9177

23 For full details see EEA report 7/2006 as cited above, p. 12

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1.5 mega tonnes of oil equivalent(Mtoe). This compares to the 6.9 Mtoe of biomass that wouldbe required to meet the UK’scurrent 2020 plans. Therefore ifthe UK bioenergy targets were tobe met through forestry productsalone, the UK would need toimport nearly four-fifths of itsbioenergy supply. However theanalysis also demonstrates thatlarge-scale imports of forestryfeedstocks are not necessary: theUK’s 2020 ambitions for thesector could instead be satisfiedby solely relying on waste, whichhas the potential to deliver 8.7 Mtoe. This suggests that therush to develop a sector based onlarge-scale wood imports isunnecessary. It even suggests thatno bioenergy crops would beneeded from agriculture in the

timeframe to 2020, reducingdirect pressure on land andeliminating indirect impacts on food prices and land usechange overseas.

While these criteria may notentirely represent the RSPB’sideal criteria for sustainableagriculture and forestry, theynevertheless represent a credibleattempt to understand andquantify bioenergy productionthat can take place in anenvironmentally compatible way.The EEA’s findings are supportedby a separate review ofindependent assessments ofdomestic bioenergy resource25.This review found that wastewood and paper productsrepresent a potentiallysubstantial resource of up to

13.6 million odt, with anadditional, potential resource of16.8 million tonnes of driedbiomass from food, municipal,garden and plant wastes.Agricultural products, such asstraw and livestock manure foranaerobic digestion, were alsofound to be significant. The hugepotential for bioenergy based onwaste is echoed by the UK’sNREAP26. This highlights thatwaste biomass is under-used andcould provide a significantcontribution to our renewableenergy targets and reduce theamount of waste land filled in theUK. It notes that in 2009,approximately 6 million tonnes ofwaste wood and 9 million tonnesof waste food were land filled.

The UK’s NREAP furthersuggests there could be sufficientbiomass resource potential in theUK to meet demand for heat andpower in 2020, if the supplypotential is fully developed. Thisassessment assumes that wecould rapidly increase theproduction of energy crops in theUK, increase wood fuel supplyfrom sustainable forestry, makebetter use of agricultural residuesand fully exploit waste biomasscurrently going to landfill.

While waste will be a substantialresource, utilising domesticallyproduced feedstocks from UK

Figure 3: Potential environmental-compatible biomass supply [Mtoe]

compared to expected UK biomass requirement in 202024

24 Graphic based on data from the EEA Report 7/2006 and the DECC Renewable Energy Roadmap(http://www.decc.gov.uk/assets/decc/11/meeting-energy-demand/renewable-energy/2167-uk-renewable-energy-roadmap.pdf)

25 Gove et al. 2010 A review of environmental consequences of biomass production for UK energy consumption26 http://www.decc.gov.uk/assets/decc/what%20we%20do/uk%20energy%20supply/energy%20mix/renewable%20energy/ored/25-

nat-ren-energy-action-plan.pdf

16

woodlands provides importantopportunities to control directlyand improve managementpractices, and to bringunmanaged woodlands back intomanagement, which can havewildlife benefits. The decline inmanagement of our woodlandshas led to an increasingproportion of high forest areasand a lack of structuralcomplexity and diversity that is

crucial for woodland specialistspecies. With evidence-basedtargeting, appropriate safeguardsin place and the provision ofappropriate managementsupport and guidance, a viableand successful woodfuel sectorcould see major gains for thewildlife associated with nativewoodland. This could helpreverse some of the major speciesdeclines, such as woodland bird

populations which have declined32% since 197027 and woodlandbutterflies which have declined74% since 199028. Policies areneeded to ensure woodfueldelivers maximum benefit fordeclining woodland wildlifeassociated with coppice and openhabitats and avoids damagingthe rare and fragile wildlifeassociated with dead wood richand mature woodland.


27 Defra Woodland Birds Indicator 200928 Defra Woodland Butterflies Indicator 2009

Andy H

ay (rspb-images.com

)

The spotted flycatcher is one of 12 declining woodland bird species

that could benefit from bringing woodlands back into management.

17

CONCLUSION –POLICYRECOMMENDATIONS

The UK has the potential to meet its 2020 targets from sustainable sources, butcurrent plans will instead lock us into heavy reliance on imported wood, with all theattendant risks to wildlife, the climate and the environment. Urgent action is needed

to correct this at the UK and devolved Government levels.

Bioenergy policies of the UKGovernment and devolvedadministrations should bedirected towards supporting anindustry that relies on utilisingwaste feedstocks and sustainabledomestic forestry rather thanlarge-scale imports. This meansdirecting support to waste-basedtechnologies and themanagement of woodlands toincrease the supply of domesticbioenergy forestry products inways that protect and enhancebiodiversity.

The RSPB therefore calls on theUK Government to put in placethe following policy measures:

1Remove public subsidies

from unsustainable

supplies of bioenergy

UK consumers are paying forgenerous subsidies to thebioenergy industry, much ofwhich will ultimately bank-rolllarge-scale electricity generatorsusing huge amounts of importedwood. As well as causing anenvironmental disaster in its ownright, this threatens to underminesupport for renewable energymore generally. The RSPB istherefore calling for an urgentreview of subsidies delivered tothe industry, and specifically forlarge-scale bioenergy that usesimported feedstocks from virginwood and non-waste bioliquidsto be removed from eligibility forthe Renewables Obligation.

2Enhance support for

sustainable bioenergy

generated from wastes

and domestic feedstocks,

ensuring heat capture

Provide the highest levels ofsupport to wastes such as post-consumer wood and thebiodegradable fraction ofmunicipal and industrial waste(providing there are not moreefficient uses of these wastestreams) as well as the use ofresidues such as cereal straw andnut shells. The RenewablesObligation and the RenewableHeat Incentive should notsubsidise residues from crops,such as kernels from palm oils,which have significantsustainability impacts, if it isshown that use of these is an


18

additional market driver. In addition, support should beredirected towards small-scalelocal supply of feedstocks,ensuring efficiency is maximisedthrough heat capture. Wewelcome the statement by theScottish Government that itprefers to see biomass deployedin heat-only or combined heatand power schemes, off gas-grid,at a scale appropriate to makebest use of both the availableheat, and of local supply29.

3Revise sustainability

standards for bioenergy

Sustainability standards dohave an important role to play,but this report shows that currentproposals are deeply flawed andneed urgent revision if they areto offer genuine climate andbiodiversity protection. Inparticular, they should includegreater protection for wildlifefrom unsustainable landconversion and harvestingpractices, a strengthenedgreenhouse gas emissionsstandard and full accounting for indirect impacts.

4Fully account for

emissions

Both the international accountingrules for LULUCF and the UK’sgreenhouse gas emissionsstandard have to fully account

for emissions. Where bioenergyemissions are not captured in theLULUCF accounting system,these must be counted in theenergy sector or imports must beruled out from countries that falloutside this accounting system.Where imports are fromcountries with partial LULUCFaccounting, a factor should beapplied to reflect the proportionof emissions unaccounted. Thegreenhouse gas standard shouldinclude a carbon debt factorwhere bioenergy is derived froman existing forestry resource. Thiscan be calculated by assessing theemissions at combustiondiscounted for the rate ofregrowth that will take place inmanaged forest systems over a 20-year period.


29 http://www.scotland.gov.uk/Publications/2010/11/17094217/8

And

y H

ay (r

spb-

imag

es.c

om)

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REFERENCESANNEX 1: BIBLIOGRAPHYBeurskens L.W.M., Hekkenberg M. (2011): Renewable Energy Projections as Published inthe National Renewable Energy Action Plans of the European Member States, Energyresearch Centre of the Netherlands (ECN-E--10-069)Department of Energy & Climate Change (2009): National Renewable Energy Action Planfor the United Kingdom, Article 4 of the Renewable Energy Directive 2009/28/ECDepartment of Energy & Climate Change (2011): Digest of United Kingdom EnergyStatistics (DUKES)European Environment Agency (2006): How much bioenergy can Europe produce withoutharming the environment?, No 7, 67 pp., ISBN 92-9167-849-X, ISSN 1725-9177

ADDITIONAL BIOMASS PLANTS AND FEEDSTOCK DATA WASSOURCED FROM THE FOLLOWING:ENDS Report (2011): Biomass plants bypassing UK supply chain, No 437, June 2011, pp.6-7(reproduced with permission of the ENDS Report, www.endsreport.com, the journal andwebsite for UK environment policy and business data)Hogan G. (2011): UK biomass power stations, Forestry Commission and BIOMASS EnergyCentre (Version 1.0 Jan 2011)Biofuelwatch: personal communication, July 2011 &http://www.biofuelwatch.org.uk/biomass_map/http://infrastructure.independent.gov.uk/projects/north-east/port-blyth-new-biomass-plant/http://infrastructure.independent.gov.uk/projects/north-east/tyne-biomass-power-plant/http://infrastructure.independent.gov.uk/projects/north-west/port-of-liverpool/http://infrastructure.independent.gov.uk/projects/south-east/port-of-southampton-biomass-energy-plant/http://maps.google.co.uk/maps/ms?msid=203549520660292289646.0004a6c1dd1b870ba8dd2&msa=0http://maps.google.co.uk/maps/ms?msid=203549520660292289646.0004a6c527015c097f0a0&msa=0&ll=54.622978,-1.757812&spn=11.62092,28.256836http://opencorporates.com/companies/gb/06269884http://roseenergy.webbelief.com/newsDetail.aspx?uid=45http://sites.google.com/site/foodnotfuelorg/newporthttp://www.ablehumberport.com/pdfs/Able%20Marine%20Energy%20Park%20-%20Informal%20pre-application%20consultation%20document%208%20July%202010.pdfhttp://www.alexandradockproject.co.uk/about-the-project/fuel-supply.aspxhttp://www.boxedpaper.com/mills/view/19/upm_caledonian_paper_millhttp://www.briggrep.co.uk/http://www.developmentcontrol.stockton.gov.uk/PublicAccess/tdc/DcApplication/application_detailview.aspx?caseno=KUSSKCPK0Bhttp://www.draxpower.com/biomass/renewable_energy_plants/ouse_plant/http://www.eco2uk.com/en/our_projects/project_detail.asp?project_id=12http://www.eco2uk.com/en/our_projects/project_detail.asp?project_id=9http://www.eon-uk.com/downloads/1_EON_Blackburn_Meadows_Renewable_Energy_Plant_Other_Material_-_Design_and_Access_Statement.pdfhttp://www.eprl.co.uk/pdfs/press_release_jan_2011_vfinal.pdf

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http://www.forthenergy.co.uk/sustainability-statements.asphttp://www.gaiapower.co.uk/feedstock.phphttp://www.gb-bio.com/http://www.graingersawmills.com/residues.htmhttp://www.heliusenergy.com/rns_viewer.php?id=4174177http://www.mgtpower.com/files/2009-09-10%20Tyne%20REP%20Press%20Release.pdfhttp://www.middlesbrough.gov.uk/ccm/content/environment/1planning-services/1development-control/1-planning-application-search-content/planning-application-search.enhttp://www.northamptonshire.gov.uk/en/councilservices/Environ/planning/planapps/Documents/PDF%20Documents/Minerals%20and%20Waste%20Apps/Chelveston%20-%20Application%20Forms%20(PDF%20Format%2048.9KB).pdfhttp://www.northlincs.gov.uk/NR/rdonlyres/C2C2BC20-A6F4-4DF2-9A65-3A26A8C7B530/39850/2009_1269.pdfhttp://www.pdm-group.co.uk/renewable_energy/energy_generation.htmlhttp://www.peelenergy.co.uk/cbep/http://www.planningwam.stockton.gov.uk/WAM133/doc/Report-1458715.pdf?extension=.pdf&id=1458715&location=VOLUME1&contentType=application/pdf&pageCount=16http://www.power-technology.com/projects/beiteesidepowerplant/http://www.power-technology.com/projects/western-wood-energy/http://www.r-e-a.net/installations/goosey-lodge-power-planthttp://www.risiinfo.com/timber/news/Suzanos-Brazilian-pellet-mills-UK-biomass-power-MGT.htmlhttp://www.rwe.com/web/cms/en/97594/rwe-npower/about-us/our-businesses/power-generation/aberthaw/http://www.sleafordrep.co.uk/info1.htmlhttp://www.sse.com/Ferrybridge/ProjectInformation/http://www.thetfordrenewableenergyplant.co.uk/links-downloads-planning-application.asphttp://www.thurrocktgdc.org.uk/data/Planning/Planning%20Committee/2011/03%20-%20March%20Planning%20Committee%20Meeting/Documents%20-%20No%20Port/Item%2009%20-%20Planning%20Application%20-%2010-%2050259%20-TTGFUL%20-%20Tilbury%20Power%20Station.pdfhttp://www.yorkshirepost.co.uk/news/around-yorkshire/local-stories/biomass_power_station_is_threat_to_primary_school_claims_head_1_2579086https://www.og.decc.gov.uk/EIP/pages/projects/PeterboroughDecision.pdfhttps://www.og.decc.gov.uk/EIP/pages/projects/TilburyConsent.pdf

ANNEX 2: CALCULATIONSA conversion from GWh to GW data was achieved by applying a load factor of 57.6% forelectricity from biomass (DUKES) and assuming a constant run time {8,760 hours a year).

Conversion Unit Source

factor

11630 Mtoe/GWh http://www.onlineconversion.com/energy.htm6000 odt/MW

biomass electricity http://www.sqw.co.uk/file_download/34141.87 GJ/toe biomass heat http://www.decc.gov.uk/assets/decc/statistics

/source/renewables/60-renewable-statistics-methodology.pdf

18 GJ biomass heat/odt http://www.sqw.co.uk/file_download/343

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72% of the assessed plant provided full information for the RSPB’s analysis. For theremaining 28%, calculations had to be based on the following assumptions:1. When generalised terms such as “mainly imports”, “primarily waste” or “most likely...”

were given, all tonnes of biomass for that plant were accounted to the major or most likelycategory (even if further feedstock was listed but without its contribution being specifiedor if other supply was also seen as possible in the future).

2. From application forms, which did not explicitly name a geographic origin of the biomassbut showed plans how local traffic will be affected, it was assumed that biomass supplywill be from domestic sources.

3. Plant that are or intend to use imports initially with the possibility or intention of usingdomestic biomass in the future were categorised as using imports (no company provideda timeline for when domestic supply might be expected to be introduced).

4. For five plants (Grainger Sawmill, Widnes PDM, Rothes Distillers, Tansterne Hull andWetwang), no information on tonnes of required biomass a year could be found. Theirbiomass requirement was calculated using their capacity and a conversion factor of 6,000 tonnes/MW.

5. For nine plants, which use biomass for co-firing, no electricity capacity of the biomassfraction was available. A conversion factor of 6,000 tonnes/MW was used to calculate theplants’ capacities.

6. The plant’s energy capacity available to the grid system was chosen over a maximumcapacity value.

Written by Melanie Coath and Sandra Pape

The Royal Society for the Protection of Birds (RSPB) is a registered charity:England and Wales no. 207076, Scotland no. SC037654. 272-0777-11-12

The RSPB speaks out for birds and wildlife, tackling the problems that threaten our environment.Nature is amazing – help us keep it that way.