BRIEFING NOTES FOR MPS

Briefing Notes for MPs Under the current consultation on the Renewables Obligation Banding Review (closing on 12th January 2012), DECC proposes to continue to finance biomass electricity on an unlimited scale, and also to provide finance for up to 400,000 tonnes of bioliquids to be burnt in each year in power stations, despite the evidence that biomass, bioliquids, and waste incineration are highly damaging for both people and the planet. The questions in the consultation focus on economic factors alone and ignore all sustainability impacts.

Why ROCs for Biofuels must stop.
The Committee on Climate Change has expressed concern that the large scale use of biomass electricity would hinder rather than help the UK’s transition to a low carbon economy and that there is no place for it after 2020 due to concerns about high carbon emissions, low conversion efficiency and security of feedstock due to lack of global land.
 The UK must, in law, comply with the European Renewable Energy Directive (RED). However, the figures for carbon accounting used in the RED are dangerously wrong, so the government must urgently stop subsidies to fuels that further damage the climate.

RED Error No 1 is to assume that ‘tailpipe’ emissions of CO2 from biofuels are zero.
The European Environment Agency’s Scientific Committee stated in September 2011:
Important international and European efforts are under way to account for and reduce greenhouse gas (GHG) emissions and to increase the use of renewable energy. Several European Union energy directives encourage a switch from fossil fuels to renewable energy derived from plant biomass based on the premise that biomass combustion, regardless of the source of the biomass, would not result in carbon accumulation in the atmosphere. This mistaken assumption results in a serious accounting error.http://www.eea.europa.eu/about-us/governance/scientific-committee/sc-opinions/opinions-on-scientific-issues/sc-opinion-on-greenhouse-gas <http://www.eea.europa.eu/about-us/governance/scientific-committee/sc-opinions/opinions-on-scientific-issues/sc-opinion-on-greenhouse-gas>
RED Error No 2. The RED does not include the effects of Land Use Change and Indirect Land Use change.168 scientists from the Union of Concerned Scientists
Have called on the European Commission to recognize and account for indirect land use change (ILUC) impacts as a part of the lifecycle analyses of greenhouse gas emissions from biofuels.When land used for food or feed production is turned over to growing biofuel crops, agriculture has to expand elsewhere. This often results in new deforestation and destruction of other ecosystems, particularly in tropical regions in the developing world.
The resulting heat-trapping emissions from clearing new land can be significant and may outweigh any emissions savings from the use of biofuels.
RED Error No 3. The figures in the RED appendix for carbon-release from palm plantations are a gross under-estimate.Geographers at the University of Leicester have recently shown that Greenhouse Gas emissions from palm oil plantations are 50 percent worse than previously thought, because of the release of carbon from peat.  Previous estimates gave 50 tonnes of CO2 per hectare per year, but using the new data, the emissions figure, using the RED approved period of 20 years rises to 106 tonnes. http://www.theicct.org/2011/10/ghg-emissions-from-oil-palm-plantations/#more-2664
Following a comprehensive literature review the authors claim,
These results show that biofuels causing any significant expansion of palm on tropical peat will actually increase emissions relative to petroleum fuels. When produced in this way, biofuels do not represent a sustainable fuel source.
. . . If these improved estimates are applied to recent International Food Policy Research Institute modelling of the European biofuel market they imply that, on average, biofuels in Europe will be as carbon intensive as petrol and worse than fossil diesel.The RED requires, in the “default” levels (35% for palm oil) a minimum saving of greenhouse gas emissions by biofuel use in place of fossil fuels.
 This is impossible because of the scientific facts above.
The consequences of EU RED subsidies are a massive destruction of tropical forest with release of carbon. Dr Sue Page, University of Leicester’s head of the physical geography department, highlights the danger of palm-oil expansion on peat:
Projections indicate an increase in oil palm plantations on peat to a total area of 2.5Mha by the year 2020 in western Indonesia alone — an area equivalent in size to the land area of the United Kingdom. The Indonesian government is currently planning to double its palm-oil production to provide 12% of aviation fuel. They are now spending €5.5 million to deny campaigners’ facts  on the problems of palm-oil.
DoT Minister’s doubts over ‘sustainability’
Norman Baker, Secretary of State at the Department for Transport has admitted the risks and uncertainties of biofuel use, and has limited their adoption under the EU Renewable Transport Fuel Obligation. He states:

It is crucial that we do all we can to ensure that biofuels both deliver real greenhouse gas emission reductions and do not cause unacceptable environmental and social side effects in the process. There is much work being undertaken, nationally and internationally, to understand better the indirect effects related to biofuels and to investigate how the negative indirect effects can be reduced.

Until we have a more robust evidence base, we cannot confidently set biofuel targets beyond those established under the current RTFO…. When we have this evidence we will set biofuel targets beyond those set out to 2014 under the current Renewable Transport Fuel Obligation <http://en.wikipedia.org/wiki/Renewable_Transport_Fuel_Obligation>  (RTFO <http://en.wikipedia.org/wiki/RTFO> ).http://www.theyworkforyou.com/wms/?id=2011-11-07a.7WS.1&s=biofuel#g7WS.2 <http://www.theyworkforyou.com/wms/?id=2011-11-07a.7WS.1&amp;s=biofuel#g7WS.2>
The Department for Transport’s own recent Impact Assessment also accepts the difficulty in satisfying sustainability criteria published by DfT in connection with the (RTFO) states on page 7/8:
10. The implications of the requirement that biofuels are not sourced from areas of high carbon stock or high biodiversity areas are particularly uncertain and difficult to evaluate.
<http://assets.dft.gov.uk/consultations/dft-2011-05/overarching-ia.pdf <http://assets.dft.gov.uk/consultations/dft-2011-05/overarching-ia.pdf> >

Biofuels do not comply with environmental standardsThe Renewable Fuels Agency (the independent sustainable fuels regulator), before it was abolished last March, reported that less than one-third of the biofuel used on UK roads met government environmental standards intended to protect water supplies, soil quality and carbon stocks.

Biofuels raise global food prices – afflicting the poor
Diverting land from food to energy crops e.g. for Jatropha plantations, maize for ethanol, etc. has already caused food prices to rise and the poor to starve.

The world’s largest food companies (Nestlé, Olayan Group, Pepsico, Unilever) in November urged the G-20 to take action on Biofuel subsidies“Expert opinion, including from the intergovernmental agency report to the G20, the High Level Panel of Experts' report on food price volatility and the IFPRI Global Hunger Index, is converging on the view that market distorting biofuel policies are significant drivers of high and volatile food prices. The growing demand for biofuels has contributed to food shortages and competition for land and scarce water, disproportionately affecting the most vulnerable people, while often having a negative greenhouse gas balance.”
www.nestle.com/.../Statements/G20_letter_nestle_biofuels%20(2).pdf
Human Rights Abuses by the biofuel industry In southeast Asia, Central and South America and West Africa: including forced eviction of populations, rape and murder. The RED takes no account of these illegal actions.
Disposession of indigenous forest-dwellers by plantation developers continues in Indonesia.
http://news.mongabay.com/2011/1101-muara_tae.html <http://news.mongabay.com/2011/1101-muara_tae.html>

No valid certification system for so-called ‘sustainable’ palm-oil exists. It is impossible scientifically, and impractical to deliver ‘sustainable’ palm-oil because of the bulk shipping methods used for the product. Paper certification is already corrupt.
ISCC/SGS certification, already accepted in Finland and Germany, is supplied by a company already suspended for other bad practises.

OFGEM is unqualified and unable to verify the validity of certificates produced by consultants.  OFGEM certification for subsidies will be annual and retrospective – after the damage is done, and thus much harder to stop. Lack of secure ‘policing’ by OFGEM will thus allow abuse to increase.

Conclusion
In view of all the errors and omissions in current legislation, and the prevalence of corrupt practice in certification and production, the only moral option is to apply the precautionary principle and stop ROC subsidies for biofuels NOW.  Voters’ money (ROCs come from their electricity bills) should be used to promote renewable energy industries that deliver a guaranteed saving of greenhouse gas emissions, such as solar, tidal and wind.