7th July 2020 – I am responding to this consultation on behalf of Biofuelwatch. Biofuelwatch has been researching the impacts of large-scale bioenergy since 2006, and advocating for reforms to our energy system would see support shift from high carbon, dirty forms of energy to energy conservation, efficiency and low-carbon renewable energy.
Before answering the consultation questions, we would like to comment on the relationship between minimising heat loss from buildings on the one hand, and low-carbon heat on the other hand. By far the most effective ways of reducing greenhouse gas emissions from the heat sector is to retrofit buildings with insulation and to strengthen building standards so that they require maximum energy efficiency ratings.
As a recent report by the Energy Efficiency Infrastructure Group[1] confirms, investment in home insulation is also particularly effective at creating large numbers of jobs.
Energy conservation therefore needs to be the first priority for reducing ghg emissions from the heat sector, and funding for low-carbon heat must no longer be allowed to subsidise wasteful energy use, i.e. to needlessly help heat the air above buildings.
Question 7: Do you have further suggestions, beyond those mentioned in this consultation, which would help the Green Gas Support Scheme to deliver the best possible value for money? Please provide evidence to support your response. AND Question 9: What are your views on increasing the minimum percentage of waste feedstocks above 50%, now or in the future? What could be a suitable new threshold? Please provide evidence to support your response.
We believe that subsidising biomethane from energy crops is not compatible with the aim of decarbonising heat due to direct and especially indirect land use change emissions, soil carbon losses through intensive farming (especially of maize), and the use of nitrogen fertiliser, a cause of nitrous oxide emissions.
Furthermore, the large-scale use of maize, rye grass and sugar beet for biogas and biomethane production takes fertile agricultural land out of food production, thus reducing the UK’s food security. Energy crops also compete for land with the need to restore forest cover in the UK.
In 2016, DECC acknowledged that the large-scale use of energy crops for biogas was not desirable, and introduced the 50% minimum percentage of waste feedstocks. This temporarily halted the expansion of maize production for biogas, however, subsequent increases in the subsidy rate for biogas reversed this positive trend. In 2017, according to Defra statistics, 31% of all maize in England was used for anaerobic digestion, an increase from 17% in 2015. Clearly, renewable energy subsidies continue to incentivise farmers to convert land away from food production.
We fear that the proposed Green Gas Support Scheme could cause further expansion of maize, rye and beet production for anaerobic digestion across the UK, even with a 50% minimum waste requirement. We believe that support must be confined entirely to the use of genuine waste feedstock, which, in turn, must be used in accordance with the waste hierarchy principle.
In the case of food waste, there is a strong argument for using a proportion of such waste for livestock feed. We support food waste that cannot be used in that way being converted to biomethane, provided that food waste minimisation is prioritised.
Question 10: In light of recent amendments to sustainability criteria in the RED II, do you have any views on whether the UK should look to take into account similar changes for the Green Gas Support Scheme?
The sustainability criteria in the REDII are not relevant to UK biomethane feedstock. REDII contains limits to the amount of biofuels and biogas/biomethane produced from food crops that can count towards renewable energy targets, as well as incentives for so-called advanced biofuel and biogas feedstocks. However, those apply only to the transport sector, not to biomethane used for heat. Sustainability criteria which do apply to biogas and biomethane for heat and power aim to prevent deforestation, destruction of highly biodiverse grasslands and draining of wetlands for feedstock production. We are not aware of those being risks with regards to biomethane production in the UK. REDII criteria do not address indirect land use change, soil degradation and compaction, agrochemical run-off or other adverse impacts associated with energy crop, such as silage maize, production.
Question 22: Do you agree with targeting support at domestic and non-domestic installations with a capacity up to and including 45kW? Yes/No. Please provide evidence to support your response.
We do not agree with such a cap in relation to larger, including district heat pumps. The consultation paper says: “The evidence received reaffirmed our view that heat pumps offer the greatest heat decarbonisation potential for the majority of buildings off the gas grid”. We agree that heat pumps can and should play a significant role in reducing ghg emissions from the heat sector, after greatly improving building efficiency. District heat pumps are particularly efficient and other countries, such as Denmark, are investing in them as a key solution for reducing ghg emissions. We believe that they must benefit from future support in the UK.
[1] https://www.theeeig.co.uk/media/1096/eeig_report_rebuilding_for_resilience_pages_01.pdf