Scotland: No to biofuel and biomass electricity subsidies

The Scottish government believes it can reduce greenhouse gas emissions by providing finance to renewable energy technologies through subsidies called Renewable Obligation Certificates (ROCs).

As well as providing support for clean technologies like wind farms, ROCs also finance electricity from biomass and bioliquids, which have been shown to

Using biomass on an industrial scale means more imports from overseas where forests are already dwindling. Picture courtesy of Greenpeace.

increase greenhouse gas emissions
cause deforestation
worsen air quality locally
result in human rights abuses with forced evictions, inhumane treatement of workers, and increased food prices commonplace

The Renewables Obligation also subsidises the incineration of waste, which can be derived from fossil fuels, thus worsening air quality and discouraging recycling.

The Renewable Obligation Scheme is financed through money from our fuel bills. If things stay as they are, it will carry on being OUR MONEY funding this dirty, false solution at the expense of people and the planet.

The Scottish Government is consulting on the level of support to be given all types of electricity classed as renewable, including from biomass and bioliquids, and they want your views.

Tell the Scottish Government that renewable energy support should go to clean, sustainable real renewables, such as sustainably sited wind, solar and tidal energy, and not to destructive biomass and bioliquid electricity.

We have prepared a template below – feel free to customize it, and if you need any more information, see our guide to the consultation. If you would like to read the Government’s consultation document, please click here.

Take Action - Send an Email

To:Neal.Rafferty@scotland.gsi.gov.uk

Renewable Energy The Renewables Obligation (Scotland) Order 2011

Scottish Government Review of ROC Banding October 2011 – Consultation Response

I am responding to the Consultation on the Renewables Obligation Banding Review. I call on the Scottish Government to remove ROCs for biomass, bioliquids, and waste incineration.

Unlike the other renewables under review, the use of bioliquids and biomass on a subsidized, industrial scale has devastating impacts. I do not believe that the impacts are adequately addressed through the sustainability criteria for biomass. The use of biomass and bioliquids on an industrial scale:

(1)        Increases carbon emissions rather than reducing them, undermining the policy reasons behind their use. Certain types of biomass electricity produce 50% more carbon emissions than coal. Bioliquids produce more GHG emissions than fossil fuels. Note that the European Environment Agency has criticised legislation which encourages the use of bioenergy on the premise that it is ‘carbon neutral,’ as this is often not the case.

(2)        Leads to deforestation and other ecosystem destruction releasing further carbon emissions. Note that proposed sustainability criteria for biomass only addresses the impacts of direct land use change and not indirect land use change and there are no credible proposals for enforcing them.

(3)        Is implicated with human rights abuses overseas, including land grabs, the inhumane treatment of workers, and increased food prices. Note that the sustainability criteria for biomass completely ignores the human rights impacts associated with using bioenergy.

(4)        Threatens to undermine Scotland’s air quality obligations: Biomass burning produces similar levels of air pollution as coal burning, with even higher levels of nitrogen dioxide and small particulates.

My representations are as follows:

1.    I welcome proposals not to incentivise new large scale dedicated biomass electricity, but those will be meaningless if the proposed, possibly 10MW cap does not apply to power stations currently defined as CHP.  Furthermore, the Government must go much further and remove subsidies for all biomass altogether, irrespective of the scale of individual power stations. This is because, if subsidies remain available for dedicated biomass power stations falling under the set threshold, it is highly likely that Scottish biomass power stations will still depend on imported wood, putting pressure on the world’s forests.

Moreover, electricity-only biomass power stations are highly inefficient, with 25-30% efficiencies. The European Union recommends that Member States encourage biomass power stations which can achieve a minimum of 70% efficiencies and so subsidizing electricity-only biomass power stations would be in breach of EU recommended standards, on top of being in breach of the Scottish Government’s own policy on biomass.

2. Under the Renewables Obligation in Scotland, biomass power stations attract even higher levels of subsidies as ‘CHP’ even if they only capture a very small amount of process heat and reach a mere 50% of the efficiency required for them to qualify under the EU Cogeneration Directive (35% rather than 70%).  Secondly, efficiency of CHP plants depends directly on the amount of heat that is captured and used and biomass heat from CHP is already eligible for subsidies under the Renewable Heat Incentive.  And finally, efficiency alone does not address other serious environmental and human rights concerns related to the large-scale use of biomass, including greenhouse gas emissions, deforestation, human rights abuses, and air pollution locally.

3.    Incentives under the ROS in Scotland should not mirror the UK Government’s proposals on enhanced co-firing and conversion: This would see new subsidies for coal-fired power stations that supply at least 15% biomass. Effectively, this entirely undermines the Scottish Government’s stated commitment to using biomass on an appropriate scale: For example, if Cockenzie Power Station and Longannet were to supply 15% biomass, they would effectively be generating 540MW from biomass, which would require over 5 million tonnes of wood per year – a scale that would rely heavily on imported wood putting pressure on the world’s forests. Again, the Government would be in breach of the EU recommended standards for efficiency remain, as biomass-only plants would remain subsidized.

4.    Continued subsidies for bioliquids would enable biofuels such as palm oil to be burned in Scotland, with devastating consequences for rainforests, forest-dependent peoples and the climate.  DECC has proposed a cap for overall subsidies (ROCs) for electricity from bioliquids, but it is set so high that over 110,000 new oil palm plantations would be required to meet the additional demand.  Palm oil is by far the cheapest vegetable oil and experience in Germany and Italy shows that developers consistently rely on this rather than other biofuels to supply power plants.  It is not clear from the Scottish Government proposals whether the proposed overall cap would apply to Scotland, too – if it didn’t then we could expect developers with ambitious biofuel power station plans to move those plans from England and Wales to Scotland.  There must be no subsidies for electricity from bioliquids in Scotland, given their serious effects on forests, climate and communities in the global South.

5.    The Scottish Government should also stop subsidising energy from waste: Waste incineration, including through gasification and pyrolysis, causes a particularly large range of dangerous toxins being emitted, undermines recycling and increases overall resource use, and, in the case of fossil-fuel derived waste, cannot be defined as renewable under EU legislation.

In a time of austerity measures and cuts to public services it is unacceptable in my view to make it possible for tens of millions of pounds of the electricity users’ money to fund bioelectricity when this will exacerbate climate change, and deprive truly low-carbon renewable energy in need of additional support. Instead, I would like to see the Government put more money into solutions which do not threaten the people and planet, such as sustainable wind, solar and tidal power.

Yours sincerely,

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