Letter by Dogwood Alliance and Biofuelwatch
We are writing to you on behalf of Dogwood Alliance (dogwoodalliance.org), an NGO working to protect forests across the southern USA, and Biofuelwatch (biofuelwatch.net), an organisation that carries out research, advocacy and campaigning in relation to the impacts of large-scale bioenergy.
Dogwood Alliance and Biofuelwatch wish to object to ESB’s planning application “Continued operation of peat-fuelled power station to facilitate the phased transition to exclusive firing with biomass and associated development works” (Reference PL19 .303108). We believe that West Offaly Power Station must be closed down once the current planning consent expires at the end of 2020.
We enclose an Open Letter signed by 33 environmental NGOs representing millions of people in the USA who share our view that: “closing down peat power stations is vital for meeting the goals of the Paris Climate Agreement. Burning peat and burning biomass for electricity are both clearly incompatible with the goal of the Paris Climate Agreement to keep global warming to 1.5C. Ireland’s three remaining peat power stations must be shut down, with the capacity being replaced by genuine low–carbon renewable energy and greater energy efficiency and conservation”.
We are objecting to the planning proposal on two grounds:
1) We believe that it is not compatible with Ireland’s climate change commitments and with the goal of the Paris Agreement to restrict warming to 1.5 degrees;
2) We believe that ESB’s claims regarding their future ability to source domestic biomass are not credible and that all or most of the biomass would have to be imported, most likely in the form of pellets from the world’s main pellet producing regions, the largest of which is the southern US.
1) Climate impacts:
ESB claims in its planning application that the proposed gradual conversion of West Offaly Power Station from peat to biomass will help achieve the “vision for transforming Ireland’s fossil fuel-based energy sector into a clean, low carbon system by 2050” contained in the White Paper Ireland’s Transition to a Low Carbon Energy Future. We believe that those claims must be dismissed:
Firstly, ESB seeks to continue burning peat at West Offaly for a further seven years beyond what is currently permitted. The International Panel on Climate Change report on limiting warming to 1.5 degrees shows that rapid emissions reductions within the next 12 years are required. Given this clear instruction, permitting the burning of such a high-carbon fuel like peat for another seven years flies in the face of such instruction.
Secondly, electricity from burning forest biomass (as shown below the only credible source of biomass for this plant) is also a very high carbon form of energy. As the enclosed Open Letter states:
“The upfront carbon emissions of burning wood for electricity are even greater than those of burning peat or coal. Biomass advocates argue that those emissions can be ignored because new trees will recapture the CO2 emitted. However, this claim has been exposed as dangerously misleading by a large number of scientific studies.[i] In January 2018, 800 scientists wrote to the European Union, warning: “Even if forests are allowed to regrow, using wood deliberately harvested for burning will increase carbon in the atmosphere and warming for decades to centuries – as many studies have shown – even when wood replaces coal, oil or natural gas. The reasons are fundamental and occur regardless of whether forest management is ‘sustainable’.”[ii]
Note that in the UK, which has so far been a world leader in coal-to-biomass conversions, the Committee on Climate Change has called for an end to support for new large-scale biomass power developments without carbon capture and storage.[iii] Note that the feasibility of using CCS with biomass has so far not been demonstrated at any scale. In response, the UK Government has announced that it will “consult on making coal to biomass conversions ineligible for future allocation rounds of the contracts for difference scheme”.[iv] In 2018, the UK Government already tightened greenhouse gas standards for biomass electricity such that we believe they cannot be met from imported wood pellets, i.e. from the type of biomass most likely to be burned at West Offaly. This sends a further strong signal that biomass electricity should not be treated as low-carbon energy.
2) Biomass sourcing:
ESB states in the planning document that the power station would burn both imported and indigenous biomass, but that supplies of indigenous biomass – both forest wood and energy crops – would rapidly increase from the 2020s. According to the planning documents it is “expected that the agricultural sector will seek government support…for the development of short rotation energy crops, e.g. willow“, and that from 2025, “there will be a marked increase in the availability of indigenous biomass from the forestry sector (public and private). This will occur as maturing forests reach thinning and harvestable age”.
This is contradicted by evidence presented by Bord na Móna to the Joint Committee on Climate Action in November 2018.[v] Bord na Móna seeks to supply biomass to West Offaly power station. According to its evidence in November 2018:
● “We have increased that [domestic biomass supplies] to approximately 400,000 tonnes this year. We think we are at a limit…There needs to be serious planting and land use change to do that”;
● “Volume of wood in Ireland to increase from the mid-2020s, however planting rates have dropped in the past decade”;
● “[It is] very difficult to persuade Irish farmers or landowners to change land use [to willow and other short-rotation energy crops].” The evidence given confirmed that attempts to develop a domestic supply chain of biomass from willow have been unsuccessful. Miscanthus and other grasses are ruled out as a feedstock because burning them would cause boiler corrosion.
Bord na Móna seeks to continue burning the maximum 400,000 tonnes of domestic biomass in its Edenderry power station, which means that this would not be available for the West Offaly Power Station.
ESB argues that domestic forest wood supplies will increase in the mid-2020s “as maturing forests reach thinning and harvestable age”, although, as is pointed out in Bord na Móna’s evidence, tree planting rates have declined. Higher domestic wood arisings will thus be very temporary. In reality, Ireland is heavily dependent on net imports of wood and wood products,[vi] especially panelboard, pulp and paper products. In 2017, Ireland’s net imports of wood and wood products amounted to €185 million. This means that a temporary increase in wood arisings cannot be expected to be available for bioenergy. Furthermore, using domestic forest wood for electricity generation would still result in carbon emissions comparable to or higher than those from coal burning for a period of several decades.
As the enclosed Open Letter states:
“Given that domestic biomass sourcing is not a realistic option on the scale required for the proposed power station conversions or large-scale cofiring, pellet imports would be inevitable. Bord na Móna has already stated in public that US wood pellets are to be the ‘initial’ biomass source. The southern US is the world’s largest pellet producing region. Pellet production heavily targets coastal hardwood forests which lie at the heart of a global biodiversity hotspot, called the North Atlantic Coastal Plain region. The region is home to hundreds of species of plants, amphibians and reptiles found nowhere else in the world[vii] and a large percentage of those depend on hardwood forests for their survival. Only a small percentage of the original forests remain. Those are now being increasingly clearcut for pellet production for export to Europe, often followed by conversion to monoculture pine plantations bereft of wildlife. The largest pellet producer in the region, Enviva, primarily sources wood from hardwood forests.[viii] On the other hand, if pellets were sourced from pine plantations, this would still accelerate forest conversions to such plantations and thus contribute to biodiversity losses”.
We therefore hope that the planning application will be refused and that West Offaly Power Station will be required to close at the end of 2020.
[i] See biofuelwatch.org.uk/biomass-resources/resources-on-biomass/ for a list of relevant studies