Dear Sir/Madam, I Wish to Respond to the Call for Evidence on Contracts for Difference

Dear Sir/Madam,
I wish to respond to the Call for Evidence on Contracts for Difference (CfDs). I strongly believe that no CfD subsidy should be available for coal-to-biomass conversions, dedicated biomass combined heat and power (CHP) or any other biomass electricity technology.
Biomass electricity is not truly renewable energy and as such, it should not be supported by the UK Government, nor promoted as one of the technologies with which to combat climate change. Available evidence suggests the climate impacts of biomass electricity are severely underestimated and are generally no better than those of the fossil fuels they are meant to replace [1]. Additionally, large-scale biomass electricity has significant and growing negative effects on forests, contributing to deforestation and forest degradation, and thereby loss of biodiversity.
There are multiple studies refuting the assumption that emissions from burning woody biomass can be ignored as the process is inherently ‘carbon neutral’ [2]. Burning whole trees to produce electricity produces a ‘carbon debt’ which will not be repaid for decades, if not centuries [3] [4].
This is incompatible with the time scale for tackling climate change: emissions reductions must be steep in the next 30 years in order to have a reasonable chance of avoiding warming of 2 degrees, let alone 1.5 degrees [5] [6], and they must include greatly reduced emissions from deforestation and land use change as well as fossil fuel burning. Replacing fossil fuel burning with biomass will not achieve emissions reductions on a large scale, no matter how it is accounted for.
Wood waste and residues are often cited as ‘sustainable’ biomass sources, but there are not sufficient volumes to meet growing biomass electricity demand [7]. Furthermore, study published by DECC found that in some cases, burning residues produces greater emissions than those from natural gas [1].
UK demand for green wood for electricity was 15.1 million tonnes in 2014/15, and this is expected to rise [8]. This demand is putting growing pressure on natural forests worldwide. The UK is now the world’s largest importer of wood pellets, and a large portion are sourced from the forests of the South-East USA, a region within a biodiversity hotspot [8] which is experiencing very high levels of forest loss [9] and has weak forest protections due to high private ownership [11]. 6.1 million tonnes of wood pellets were exported from this region last year and NGO investigations have revealed US pellet suppliers Enviva clearcutting wetland forests [12]. Enviva supplies Drax and has agreed to supply Lynemouth and the the MGT Power Teesside plant in future.
The currently high levels of subsidy should be diverted from biomass to low-carbon wind and solar instead. Wind and solar out-perform biomass on almost every metric:
Their life-cycle greenhouse gas emissions are far below those of biomass electricity [13], and they require far less land than biomass [14]. Solar and wind are also far cheaper than biomass electricity: a study published last month by the Natural Resources Defense Council [15] found that even without full accounting for the emissions from biomass, total economic costs for onshore wind and large-scale solar are less than or equivalent to those for biomass (they are far less if full carbon accounting is used). The costs of wind and solar continue to fall to 2025, whereas biomass remains at much the same level.
Finally, biomass power stations emit a similar range and volume of pollutants to coal power stations [16], whereas wind turbines and solar panels operate without causing any pollution.
Please ensure CfDs are given to genuine renewables only, and not coal-to-biomass conversions, biomass CHP, or ‘advanced conversion’ of biomass or waste.

References

1. Stephenson, A. L. & MacKay D. J. C (2014) “Life cycle impacts of biomass in 2020” Department of Energy and Climate Change https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/349024/BEAC_Report_290814.pdf
2. E.g. Joshua Clark et al., “Impacts of Thinning on Carbon Stores in the PNW: A Plot Level Analysis”, Oregon State University, May, 2011; Stephen R. Mitchell et al., “Carbon Debt and Carbon Sequestration Parity in Forest Bioenergy Production”, Duke University and Oregon State University, May 2012. Andrea Colnes, David Saah, et al., “Biomass Supply091 and Carbon Accounting for Southeastern Forests”, The Biomass Energy Resource Center, Forest Guild, and Spatial Informatics Group, February 2012; Thomas Buchho, “Mineral soil carbon fluxes in forests and implications for carbon balance assessments”
3. Thomas Walker et al., “Biomass Sustainability and Carbon Policy Study”, Manomet Center for Conservation Sciences, June 2010 Available at
4. Mckechnie et al. (2011) “Forest Bioenergy or Forest Carbon? Assessing Trade-Offs in Greenhouse Gas Mitigation with Wood-Based Fuels” Environ. Sci. Technol., 2011, 45 (2), pp789–795 from
5. Raupach, M.R. et al., (2014) calculated that for a 50%/66% chance of remaining within 2 degrees warming requires global emissions reductions of 5.5%/7.9% every year since 2015 (it would be steeper now).
   (“Sharing a quota on cumulative carbon emissions.” Nature Climate Change, 4(10), pp.873–879. Available at:
   Friedlingstein et. al. (2014) calculated that the carbon budget for a 66% chance of remaining below 2 degrees would be used up in 30 years at current global emissions rates. (“Persistent growth of CO2 emissions and implications for reaching climate targets.” Nature Geoscience, 7(10), pp.709–715. Available at:
6. Anderson, K., 2015. Duality in climate science. Nature Geoscience, 8(12), pp.898–900. Available at:
7. USDA “Forest Resources of the United States, 2012.” http://srs.fs.usda.gov/pubs/gtr/gtr_wo091.pdf. 59.3 million dry tonnes of wood residues arose at timber-processing facilities in the US, but less than 1% of those were not used for other purposes and thus available for pellet production
8. https://www.ofgem.gov.uk/publications-and-updates/biomass-sustainability-dataset-2014-15
9. A hotpsot is defined here : The North American Coastal Plain was designated a hotpsot in 2015
10. 61 US scientists wrote a letter to DECC in 2014 titled “ Problems with burning wood from Southern US forests to generate electricity in the UK”
11. The US-based NRDC have multiple reports highlighting the threat of the wood pellet industry to Southern Forests including an investigation into clearcutting by Enviva
12. Median values. Taken from IPCC Working Group III “Mitigation of Climate Change, Annex II: Technology - specific cost and performance parameters". IPCC. 2014. p. 10. (NB Other evidence suggests biomass emissions can be far higher than this depending on the source of biomass).
13. Solar and biomass from Searchinger, T. & Heimlich R. (2015) “Avoiding Bioenergy competition for food crops and land” World Resources Institute. p14, Wind from
14. NRDC (October 2016) “Money to Burn? The UK needs to dump biomass and replace its coal plants with truly clean energy”