Chatham House's Duncan Brack on the huge emissions from burning US wood overseas

"In 2019, the use of United States sourced wood pellets in the UK was accountable for 16 million to 19 million tonnes of carbon dioxide, mostly burned by Drax. That is roughly equivalent to a quarter of all the emissions from the UK power sector."

Edward speaks to Duncan Brack, Associate Fellow at Chatham House and author of numerous reports into industrial-scale biomass  and forestry policy.

Read the report here. 

Find all our latest investigations, features and interviews at www.landclimate.org

Transcript

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Ed: 0:06

Hello and welcome to the Economy, Land and Climate podcast. I'm Edward and this week I spoke to Duncan BracK, Associate Fellow at Chatham House and author of numerous reports into biomass at industrial scale and forestry policy.

Duncan Brack: 0:19

We reckoned that in 2019, the use of United States sourced wood pellets in the UK was accountable or resulted in 16 million to 19 million tonnes of carbon dioxide mostly burned at Drax. And just to give you a comparison there, that is roughly equivalent to a quarter of all the emissions from the UK power sector. As I'm sure your listeners will be aware, the power sector is quite rapidly decarbonizing.

Ed: 0:48

This is a really important time for all those concerned about the increasing use of forests wood as a substitute for coal. MEPs in Brussels are looking again at the renewable energy directive and the UK is preparing an updated biomass strategy. I started by asking Duncan to outline his previous work in this area including his stint as an advisor on energy policy to the UK.

Duncan Brack: 1:10

Yeah, I worked in government. I was a special advisor to the Department of Energy and Climate Change for the first two years of the coalition government from 2010 to 2012. And it was just about when biomass energy was really taking off. And I think at the time, nobody really knew which renewable source of energy, particularly of power, was going to be the one to bet on, and governments, the UK and other EU member state governments as well, were putting money behind

all of them: 1:37

solar, wind, tidal, biomass, whatever, because they were under pressure from the renewable energy targets which each country adopted under the renewable energy directive. And they had to boost their renewable energy output. And that's particularly true from the UK, which had a really very poor record, indeed, on renewables, just a little bit of hydro power and very little else until the turn of the century. So government was subsidising pretty much everything. And we were seeing quite rapid growth in the use of biomass. So burning basically wood feedstocks for heat and power, and we were seeing biomass used in old coal plants, sometimes co-fired with coal in the same burners, sometimes as conversion from old coal plants. You know, it's a very simple technology, you didn't really need to develop anything incredibly new for that, because it's the same kind of thing. You chuck the fuel into a furnace into a boiler and you burn it and it heats up turbines, which generate electricity. What we've seen since then, of course, is that actually, the costs of solar and wind have collapsed in quite dramatic fashion. So now these are far more cost effective renewable energy technologies than biomass. Biomass has come down in cost a bit as the technology has matured, but not very much because it was largely mature technology already. But of course, nobody knew that at the time. And when I worked at DEC, government was getting a bit concerned about the expansion of biomass energy. And in the end, in fact, the government ended up putting a cap on the total it was prepared to subsidise in the UK. Of course, you have to remember that all these forms of renewables only exist at the scale they do because they're subsidised by regulatory requirements on electricity suppliers, and they're paid for by levies on the electricity bills. Having said that, the cost of new wind is now actually cheaper than even new gas plants. So the situation changed quite a lot. Of course, that wasn't clear then. So I left government in 2012, and went back to being a policy analyst, policy researcher, working mainly on forests and the impact of many consumer countries like the UK and the EU, on forests. There's a whole debate there around the association of forest of agricultural production for crops like soy and palm oil and cocoa with deforestation. But also people begin to get concerned about the impact of this sourcing for biomass energy on forests. And the EU is now the biggest user of wood for bioenergy in the world. But actually, it doesn't produce as much as it consumes. So increasingly the EU is importing more and more from outside. But then in addition to that, quite apart from the impact on just forests, there's the question of the impact on the global climate. And that's what we started looking at in Chatham House in around about 2014 2015. And in the end, we published a report in 2017, which focused just on that latter issue, the question mark about whether if you use biomass for energy, you're really having a positive impact on the climate or not. And that was the kind of first, not the first report that had been published on that, but I think one of the first from an organisation like Chatham House, a kind of Think Tank, a research institute, rather than a campaigning NGO. So we got quite a bit of coverage. And then since then, we've looked in a bit more detail at patterns of demand and supply for biomass within particular EU member states. And then this latest report, which was trying to calculate in quite some level of detail, the emissions of carbon dioxide and therefore the impact on the climate, of the use of wood pellets sourced from the United States, which is one of the world's biggest producers in the use of those wood pellets in the UK and the EU 27. And trying to look ahead about 10 years and seeing what was likely to happen to markets for US wood pellets.

Ed: 5:09

That's fascinating. Thank you very much that background. And as I remember your 2017 report was indeed on the front page of several national newspapers.

Duncan Brack: 5:17

Yeah, well, I was a special advisor, as I said, working for Chris Hughes, Secretary State for Energy and Climate Change at the time, Liberal Democrat minister. And then later on, after he left government, he ended up working part time for a US wood pellet company. So when I published my report, The Times thought it'd be quite amusing to use it to have a go at him. They didn't state that he was responsible for establishing government subsidies, you know, because that would have been obvious that he sets up this industry and then goes to work for it later as a minister. I mean, he didn't he wasn't responsible for it, we inherited that framework from the Labour government before that, but they kind of sort of implied or try to imply that he was, and then Channel Four thought it would be very amusing to put both him and me on an interview on Channel For News to have a sort of debate with each other, which was very civilised I have to say. But because it was on the front page of The Times, The Sun and The Mail picked up on it as well. And I think Chatham House Press Office, they had gone through the publications that were going to come out that week and the head of the Energy and Environment Department said well- a report on woody biomass implications for the global climate. They were saying,'yeah, specialist stuff won't get any coverage in the mainstream media at all', suddenly it gets splashed across the three major papers. And the BBC and the New Scientist.

Ed: 6:32

And one of the major reasons as well as this that we've got such interest in UK is, obviously the UK is a major importer and burner of wood pellets for energy. And this report is actually taking it another level. And I think a lot of the work on Bioenergy and often in biomass as well, is often looked at quite a theoretical level in the sense that there's sort of models that are done, they generate results, it's to do with the growth of the forest stock and the time between when the forest the wood is burned and combusted, and etc, and emissions go up, and then when the forest stock could recover those emissions in growth. But you've actually - I want to just talk a little bit about the methodology for this report to cover I think chapter, I can't remember it's Chapter Two or something in the report report, but you've actually looked in extreme detail at specific pellet mills and tried to draw the emissions out there. So if you could just say a bit about that methodology, and what this report was doing, that'd be great.

Duncan Brack: 7:34

Yes, that's right. So we partnered with the colleagues from the United States based Woodwell Research Center. Woodwell Climate Research Center, I think is its proper name, who did the detail work on US wood pellet sourcing, and it was a very good partnership, we work together very well. So you're quite right about the UK as a major source of demand for pellets. Now wood pellets are not the only type of feedstock that's burnt in biomass power stations. And certainly the smaller ones will tend to use all kinds of things; wood chips, residues from harvesting operations, agricultural residues possibly. But they're really very, very small and their impact on the climate and on forests is much lower. What we've seen in the UK and the EU is the development of really big power stations, generally speaking old coal stations which have been converted, though a few new dedicated ones have been built and are being built. And mostly they use wood pellets. Because if you pelletise the material from harvesting or from a sawmill, the wood pellets are much easier to transport and to store and they're kind of more resistant to moisture and degradation and so on. You can't store them indefinitely, but they're easier commodity to ship. So they become the main type of wood fuel that's transported, particularly transported internationally. And in 2018, the UK consumed about 8.3 million tonnes of wood pellets, which represents 21% of all the wood pellets produced worldwide. So yeah, we're burning about well, it used to be more than that, used to be a quarter to a fifth of all the wood pellets produced everywhere. And most of that goes to Drax, which is a big coal station originally with six units. Now they're converted four of their units to burning wood pellets. So they burned alone 7 million tonnes in that year. The biggest source of supply is the US but they also import from Canada, and from within the EU, mostly from the Baltic states, places like Estonia and a few other places. UK production of wood pellets is tiny. It's about 300,000 tonnes. So you see, you know, we don't have very big forests, we don't have a very big wood processing industry. So there is very little feedstock available for really big power stations like Drax, so we're always - the UK is always - going to be an importer. So what we wanted to do was to get a picture of the emissions that are associated with the use of wood pellets and we analyse them in three categories. The biggest proportion obviously is the emissions from combustion, from burning the wood pellets themselves. Now, these are, as you said in your introduction, these are not reported these are not included in countries greenhouse gas targets, greenhouse gas emission totals, which they judge against their targets, but they are reported, happily, to the United Nations Framework Convention on Climate Change, that's part of the national reporting structure. And they're reported as what's called the memo item. So we have the data on that. We just looked at the UK reports to the UNCCC to get a total and also, in fact, Drax reports, actually on their own carbon emissions per tonne of wood pellets burned. And they report on the total of tonnes of wood pellets burn. So we've using Drax as a proxy for basically the whole of the UK and the EU, which isn't going to be precisely accurate. I mean, Drax is actually relatively efficient, and many of the other biomass industry, biomass power stations, sorry, may be less efficient. So we may if anything have underestimated the total of emissions. But Drax is such a big user, it seemed is that a sensible thing to do. So we get emissions from combustion, there's also emissions from the supply chain. So that's emissions from energy use when the feedstock is sourced. So when the trees are harvested, or the residues are collected, there's an energy hit when you process them, when you turn them into pellets, you need to dry them, and you need to press them, compress them, into the pellet size. There's energy used in shipping the pellets while transporting them by rail or truck, and then shipping them across the Atlantic. Obviously, we're talking about US pellets here. And then transporting them to Drax or other power stations, and Drax happily publishes detail on that as well. So we know the emissions associated with the supply chain. And then the third thing I mean, they're relatively easy calculations. The third area, which is new, I think about the reports, I've not seen anybody else do it. And this is what our colleagues in Woodwell did, was they looked at the impact of using wood pellets on the forests from which they were sourced in the southeastern US. And there's quite a lot of detail on the methodology we followed in the report for people who want to look at it, but just briefly, we looked at the emissions of the carbon dioxide that the trees, the feedstock that Drax and other biomass stations uses is a mixture of whole trees harvested for bioenergy, and residues and stuff. But when you take out whole trees, obviously, you're losing all the carbon they would have sequestered from the atmosphere if they had continued to grow. So we looked at the proportion of Drax feedstock that was whole trees, and Woodwell reached a calculation on the emissions of carbon dioxide, that they would have sequestered if they had been allowed to grow. And we allow to regrowth as well. So that was all taken into account. Because obviously, the forests also carry on growing then and stop. We also looked at the emissions from the decay of roots and unused logging residues. So a portion of the trees when they're logged are always left in the forest. And actually, that's to a certain extent, the good thing was you want the nutrients to go back into the soil, and some of the carbon is captured by the soil as well. But some of the carbon is just decays and goes into the atmosphere. And you get that, particularly from roots. So it's quite detailed calculations in all of that. So that's the new bit, the impact on the amount of forest carbon stored in the forest from which the feedstock is sourced. And it's quite difficult to do those calculations, we ended up actually with a range. So we had an upper bound and the lower bound, and we think that you know, somewhere in between is probably the accurate figure. But putting those three categories together, we reckon that in 2019, the use of United States sourced wood pellets in the UK was accountable or resulted in 16 million to 19 million tonnes of carbon dioxide, mostly burned at Drax. And just to give you a comparison there, that is roughly equivalent to a quarter of all the emissions from the UK power sector. Because, as I'm sure your listeners will be aware the power sector is quite rapidly decarbonising. And about roughly 3% of total UK greenhouse gas emissions in 2019, or to put it another way, the equivalent to the emissions produced from 6 million to 7 million cars, passenger vehicles.

Ed: 13:47

Yeah, I mean, it's a stunning finding. Because just for the sheer scale, and to be very clear, you've explained that very well. But I still think people, they're still shocked at the fact that if you burn coal, your emissions from coal are counted. And in some cases, if you're in the EU, you're subject to the European emissions trading system, so you're paying for permits to burn that. But if you burn wood, you're considered to be burning a carbon neutral, zero carbon fuel, and therefore you're only actually paying for the supply chain emissions that you've outlined. So there are two huge parts that are not being accounted for though, as you said, they are being reported. And then of course, the other argument is, you know, all the forests will regrow. And the argument that lots of NGOs and others and foresters and people that are interested in nature and biodiversity have always made is that, yes, they do regrow, but over a very long period of time, and you're also losing a large amount of benefit at that very moment while they're regrowing. No one, as much as many people look at the literature, has done this level of analysis where they've actually looked at a specific feedstock area, in this case in the US and looked at that catchment area and then tried to trace the emissions through the whole system and come up with the figure and I think it's fair to say I mean, you know, we have been very concerned about bioenergy for a long time, but I had never imagined the figures would be quite as high as that. And that's your mid range point.

Duncan Brack: 15:06

Yes, that's right. And projecting it forward, I mean, Drax won't convert any more units. They're probably at maximum consumption at the moment. But there is a new dedicated biomass power station still under construction in the UK at Teesside. So if you add in consumption of pellets there, and also from the other, the third relatively big biomass power station at Lynemouth and project forward to the mid 20s, we reckon that emissions would rise to somewhere between 17 to 20 million tonnes of CO2 a year. And of course, this is against the background of a falling amount of emissions from the rest of the UK economy. So over the fourth carbon budget period, so that the climate targets that the UK has to hit under the Climate Change Act, we reckon biomass emissions would be adding around about 5% per year to the UK's target. And remember, the government's plans aren't actually on track to meet that target even now. So and then, you know, if you find my submissions to account, it adds another 5% of emissions on top. So it means we missed the target by even more.

Ed: 16:05

These are just colossal figures. Yeah, as you say, 7 million passenger vehicles, it's about the size of the - just that thing alone on fibers iis around about the size of UK aviation. So you're talking about everybody's flights.

Duncan Brack: 16:16

And this is just this is just US sourced biomass burnt in the UK. The UK also burns other volumes of biomass. And the EU burns quite a lot of other biomass from other sources, mostly from within the EU. Some European countries import quite a lot from the US as well as Belgium, Denmark, Netherlands, but actually most of them either generate their own biomass or they import it from other sources like Russia or Balkan states. So yeah, this is just looking at the US sourced biomass, just in the UK, though we've produced figures, projections for the EU 27 as well. So I think you're right. I mean, there are two things going on here. I mean, one is the basic problem here. One is the time period, and you're right. I mean this is one of the reasons why biomass emissions are treated as carbon neutral, because the assumption that the forest from which you're sourcing them will carry on growing or regrow or possibly even grow faster, as a result of thinning, and therefore all the carbon emissions will be captured in the long term. But that's the problem, it's the long term. And there is quite a big argument about how long the long term is. And then it depends very critically on the type of feedstock you're using. So if you're using, I've never argued that all kinds of biomass feedstock are wrong - if you're using feedstock that would otherwise be burnt as waste, and that does happen in some places, or left to decay and decay very rapidly, and it also has no other possible use, that's actually probably quite a sensible thing to do. And there are some types of feedstock like black liqueur, which is again, a waste product from the pulp and paper industry that you have to dispose off. And actually, it makes sense to get rid of that with energy recovery. And that happens in pulp and paper mills anyway. So there are two things going on here. So one is, as you mentioned, it's the time delay before which the carbon emissions are reabsorbed. So one of the reasons why biomass is treated as zero carbon at the point of combustion in greenhouse gas reports and policy frameworks, is because on the assumption that the carbon that you emit when you burn biomass is reabsorbed by forest growth in the future. And maybe even if you thin forests, you take out debris and so on, you may even get faster forest growth. But the problem with that is that it does take quite a long time for whole trees to regrow. And they won't absorb any significant amounts of carbon, probably for at least the first 10 years of the growth. So there is going to be a time delay until the emissions in the atmosphere or levels in the atmosphere return to what they were before or even fall below. So the type of feedstock you use is critical here. I've never argued that all biomass burning should be banned. There are some types of feedstock it probably does make sense to use for energy. And they are really the kind of wastes and residues that have no other use, that might otherwise just be burnt as waste and release all their carbon to the atmosphere or be left to decay and release their carbon really fast. The trouble is there probably aren't very many very large volumes of that kind of waste and residues. There are some definitely, but some of them have other uses, I mean a lot of sawmill waste and residues are used to make engineered wood products like MDF, some of forest residues from forest harvesting operations will be left to decay in the forest and some of the nutrients and carbon will go into the soil and so on. But I think if you really tightly control the type of feedstock you use, you can end up with some from the more useful things. But that's a much, much smaller scale that's being used at the moment. The other reason why people tend to think that we'll treat biomass as zero carbon is because emissions from biomass are supposed to be recorded and reported in the land use sector of greenhouse gas accounts, national accounts, and not in the energy use sector. So the idea is you record them when you take them out of the forest, rather than when you burn them. And if you recorded them, if you reported them when they were burnt as well, you get double counting. And that's a kind of a reasonable sort of convention for reporting. But when you start to ignore the impact of emissions from combustion, it means you're setting up policy frameworks that create an incentive to burn them, because it looks like you're getting a good result, you're not getting any carbon emissions. And there's no corresponding incentive in the country of origin to do anything to compensate for that. And that's particularly true under the Paris Agreement, there was an attempt under the Kyoto Protocol, to have a kind of global framework to try and balance those out. But it's really difficult to do that, partly because, of course, forests grow at different speeds all the time. And not just for human reasons, for just climatic reasons, from wildfires, and all sorts of things. So it was really difficult to make it work. And the Paris Agreement, it's up to countries themselves to decide whether or not they'll put forests in their NDCs and their climate action plans, and whether or not to account for emissions from forests. And actually, what we know from looking at various countries' reports, including the United States, is that they make no effort to estimate the amount of forest feedstock that's taken out for bioenergy in any case. And in fact, actually, it's a pretty difficult thing to do. Because, you know, you often don't know when a piece of wood is taken out of the forest, what it is going to be used for. So actually, there is no way in which the current policy framework can compensate in terms of land use reporting, for emissions reduced in the energy sector. So you have a policy framework now that is basically incentivising the growth of the use of biomass, pretending it's zero carbon, when actually it isn't, at least certainly not over the short or medium term. And there's no compensatory action taken in the countries of origin.

Ed: 21:21

So you've done all this work. And you've got figures for the UK. And you've also got figures for the EU and I will come on briefly to the EU situation as well, because that's really important as well, just to be clear the context here is an announcement recently from Drax, which has now become one of the biggest wood pellet producers in the world as well as one of the biggest burners if not the biggest burner of wood pellets, but it's now become because it's bought lots of pellet mills, a lot of which are in the US, a lot of which are in the areas you've been looking at. It now wants to double its pellet production. So it's looking to really ramp up its business there. And the EU numbers, which you've got in your report are fairly stark as well. And of course, the EU'S land use side of things, the land use change and forestry directive, that is actually talking about forestry and biomass domestically in the EU 27. But it's actually foreseeingforseeing a decrease in the sink driven by harvesting for many things, but some of which will potentially be bioenergy. So, yeah, we are looking at a potential very serious situation that EU 27 as well, I mean, I saw the German coalition agreement includes ambition to come off coal, you know, many years before the previous government or the current government is envisioning so by 2030 is the ideal scenario. But the think tank Ember, I know, you know, and we work with a bit in the UK, they've done a piece of analysis in 2019, saying there's a very high threat of another something like four or five potentially direct style power plants coming online in the EU. And the Europe renewable energy directive is putting up the renewable target to something like 38 to 40%. And so if you don't change the definition of carbon neutral in that you could potentially see this absolutely exploding as a renewable fuel. So could you say a little bit about the EU numbers, the numbers you got for the EU, and that was just on the imports in the US. And then a little bit about projected growth, which you tackle in chapter four?

Duncan Brack: 23:17

Yes, that's right. EU member states are not huge, mostly not huge importers of wood pellets from the US. It's important for Belgium, Netherlands and Denmark at the moment, all countries a bit like the UK with quite limited forest resources of their own and very small wood product industries producing wastes and residues which you can use. And some of those countries import from somewhere else, like Denmark, imports from Scandinavia, within the EU and also from Russia. So nevertheless, we thought that projections are that this would still increase consumption of US wood pellets in the EU 27, around about 1.3 million tonnes in 2019, we thought it'd be all the way up to about 3.5 million tonnes in 2025, but then falling to 2 million tonnes in 2030. Like the UK, most of these countries are actually reducing support for biomass as other renewables become more viable. So this is just looking at US wood pellets. But those figures may well prove to be underestimates, as you were saying if other things happen, in particular, there is pressure for more coal to biomass conversions in quite a few member states, particularly Germany, who are trying to phase out coal and also of course, having issues with nuclear power. So they really need new sources of electricity. But other countries as well, Czech Republic, Poland and other countries are talking about coal to biomass conversions and such converted stations. I think this is an Ember analysis, they would have the potential almost triple EU27 wood pellet consumption from 2018 levels. Now, I say it's not necessarily the case they're getting it from the United States, but equally if suppliers from domestic sources, or other countries like Russia are going to be constrained, actually, they could well end up sourcing them from the United States, which is one of the main global suppliers. And looking further ahead, you're right the commission on the impact assessment the European Commission produced for the climate target plan, they're talking about projected 50% increase in bioenergy by 2050. Now they talked about most of the feedstock expecting to be sourced from within the EU. But they included a huge increase, projected increase in energy crops. So fast growing energy crops like miscanthus, switchgrass or fast spring, willow, things like that. And by and large, the policy frameworks to encourage that don't exist at the moment. And in any case, it's not always the case that you can burn the same kind of feedstock in the same kind of power plants, you might have to convert them to optimise them for different types of feedstock, because the quality of the feedstock is quite different. So I think, first of all, it's not at all clear that that level of increase in energy crops will happen. Secondly, I'm sure the existing industry will want to stick with the feedstock they know and they already source which is forest feedstock. So I think the possibility, the potential for continued growth in the use of forests feedstock, whether from within the EU or from the US or from anywhere else is pretty high. And we haven't even talked about BECCS yet, if we're going to get on to bioenergy with carbon capture and storage, that adds another sort of slab of potential demand on top of that, both in the UK and the EU.

Ed: 26:10

Yes, it definitely does. And we were speaking a bit to Dan Quiggin. And I know you and one of your colleagues wrote a paper on BECCS was it January 2020.

Duncan Brack: 26:20

Yeah, that's right. Richard King.

Ed: 26:21

Richard King. Yes. And you came up with, and that was looking at a global picture, I think for BECCS, and you came up with a fairly stark number on the amount of land, I can't remember, you'll have to remind me but there was a very stark number on the amount of land that will be needed for feedstock in,

Duncan Brack: 26:35

there are all sorts of projections out there. Some of the big ones are like, you know, when you're talking about deforestation, people often talk about the number of Waleses or the number of Costa Ricas, well, for BECCS, it tends to be the number of Indias you need for land. I think some of the biggest, biggest projections, which I mean, really are completely ridiculous, there just isn't that much land available. It's like two and a half times the land area of India, which is absurd. And I think for energy crops for BECCS yeah, I think people are now really beginning to reevaluate that. But it is worrying because a lot of the projections forward for how you reach net zero emissions in 2050, or whenever, place quite a lot of reliance on BECCS. And what Richard and I were arguing really is this: policymakers are kind of sleepwalking into BECCS because it features so heavily in the models. But that's not really based on any rational sensible evaluation of the real potential for it and the impacts that it would have on other aspects of the global forests and global food system.

Ed: 27:34

I think that's why this report, which is not on BECCS, this one you published last October, just a month, a couple of weeks ago, is important because it's not theoretical. The policymakers are looking at models projecting into 2050, about what you could potentially do. And they're looking at, they're keen to get understandably big numbers, emission reductions out of the hardest to abate sectors, industry, etc. But this report is saying this is not a theory, this is about going to a place where this is happening now, looking at the impacts of that, looking at the real supply chain and real emissions from stack. And then coming back and saying this is amounts of this amount, it's a very tough message for the bioenergy sector because I do not know how this can be challenged in the sense. I mean, you do hear that from people in Brussels and also in London as well, saying that, well, you know, as long as forest growth overall outstrips forest removals, then things should be okay. But you know, this report is challenging that in the sense that it's saying in those areas in which the bioenergy is coming from i.e. not bits of the forest that have got nothing to do with bioenergy which you could use as an offset, but the ones where the areas in which there is an active bioenergy, and a growing bioenergy industry that is connected to very, very high emissions.

Duncan Brack: 28:55

Yes, I think that's absolutely right. And it's worrying that policymakers don't really seem to be responding to this at the moment. I mean, it's not entirely true to say they're not responding. The UK is I think they have said they will not provide support for any more biomass plants apart from BECCS so BECCS is the sort of big unanswered question. And the European Commission in the fit for 55 package, introduced in July, introduced a number of proposals to tighten up the sustainability criteria, which define the categories of feedstock that are eligible for support. Now, the changes they've made, they're not huge, but they are in the right direction. So I think there is kind of at least a bit of acknowledgement that there is a problem here. But it's true to say, I mean, in particular, we don't know what kind of framework will govern feedstocks for BECCS, just nobody's talked about that yet. And it's quite urgent. I think that both the UK and the EU governments [need to] begin to put in place proper policy frameworks to control BECCS if it's going to be used and to minimise the impact on the climate. As I said before, I think some categories of feedstock probably would make sense, but I think the volumes are very, very limited, much, much smaller than a lot of the models are assuming. And therefore, of course, then the consequential decision is, well, what do you do about reaching net zero? Because we know there are some sectors where it's really difficult to reduce emissions, some industrial uses food and agriculture, aviation. So we have to have some form of negative emissions technologies. Growing forests is a good solution. But it's not going to be big enough by itself. And if you can't use BECCS, which is what a lot of policymakers assume you can do. If you don't use BECCS, what are you going to do? And that's the real question that needs to be addressed.

Ed: 30:32

Policymakers, I think are, as you say, they are taking an interest there is a sense in which both in the UK and in Brussels and I think Lord Goldsmith who's in DEFRA is now saying off the back of COP, where there was a lot of focus on deforestation, and there was also a bit of focus on greenwash and things like that, you know, they would be looking quite carefully at the sources of UK wood pellets. And I have no doubt that he's looking through this report as we speak. And that's the one of the most one of the most clear signals publicly they've made that they're really taking an interest in and digging around in this. At the same time, they are being quite heavily lobbied I think for very large financial commitments to Drax for BECCS, I think it will be in the 10s of billions, I'm sure. And in Brussels, with the renewable energy directive being looked at as part of, as you said, the fit 55 package. You have a lot of MEPs now gathering to sort of see where they sit on this. I mean, that's, that's in the environment committee, and in the Energy Committee, where views do range, you know, but I suppose my final question would be, I mean, is there an easy way out of this in terms of policy? Is there something some people suggested, for example, expose bioenergy to the ETS, move it from the land use sector, which as you say, there's absolutely no incentive and it's very opaque, where it's supposed to be counted, to just make power plants that are burning wood pellets, count the emissions, which they report. Count, and pay for those emissions on the emissions trading system. Or do you think that that wouldn't work? Or is there a recommendation and you sort of make a couple of recommendations towards the end of the report that you think people should be adopting in Brussels now, you know,

Duncan Brack: 32:10

yeah, yeah, we do for both the UK and the EU. Both legislations - can't call the EU a country, I was about to say both countries. But yeah, you know what I mean, both of them, use sustainability criteria to limit the feedstocks, which are eligible for support. And at the moment, they're fairly loose categories. And they're designed to avoid just entire forests being cut down and used for energy. So direct land use changes and so on. I think you can tighten up the sustainability criteria very significantly. And what we argued for is only those categories of feedstock with the lowest carbon payback periods. In other words, the shortest period until emissions are reabsorbed should be eligible for support. And we think that means sawmill and small forest residues and wastes with no other commercial use, whose consumption for energy does not inhibit forest ecosystem health and vitality. And I think there are supply chain control mechanisms in place that could be developed that will enable you to distinguish that type of feedstock from others. It's not straightforward, but I think it could be done. And you need a number of other things. I mean, the regulator's definitions of different categories of feedstock are not very tightly drawn at the moment, they need to be more tightly defined to make sure you're using stuff. And you need periodic monitoring of that to make sure that all those criteria are being held to, and that would still permit a bit of subsidy to go into fairly small scale uses of biomass. I think that's okay. What we said is that any other type of biomass shouldn't be eligible for subsidy and any emissions from it should be counted in the energy sector. And in both the consuming countries accounts, greenhouse gas accounts, and also in policy instruments, like emissions trading schemes, and so on. And I think that would really limit the use of biomass to areas where the kind of uses where it does make sense. And also, quite importantly, you have the same kind of policy framework governing use in BECCS plants, because as I said we don't know at all what that's going to be in any of these countries yet. I mean, there are no operating BECCS plants. But I think it's quite urgent that government gives signals about the type of feedstock they're prepared to support and prepared to subsidise.

Ed: 34:11

Well, that's really useful Duncan, I think that's going to be helpful for people working on these files right now. So thank you very much. That's a real, a very efficient and speedy jog through what is it actually an incredibly detailed report, which is available on the Chatham House website, and it would definitely be worth anyone working on this subject checking out because the methodology, which we've gone over very quickly today, is very, very comprehensively laid out in that report and in an annex accompanying it. So it's really worth reading, and it is one of the most detailed studies that's done been done on the subject.

Duncan Brack: 34:44

And if I might just add that clearly, the biomass industry didn't like the report at all and quite widespread criticised it. They have produced no criticisms, or no critiques at all that I've seen of the methodology we used, which leads me and basically we were using Drax reported figures most of the time as well. So I think our calculations are entirely robust, and they haven't been able to challenge those at all.

Ed: 35:04

My thanks to Duncan for those important insights, do check out our website where there's a great deal more about biomass and energy policy in our campaign section and that's www.elc-insight.org. You'll also find podcasts and interviews with Dan Quiggin, Duncan's colleague at Chatham House, talking about bioenergy with carbon capture and storage and the problems associated with that. Also Phil MacDonald talking about the costs of biomass energy policy. Next week, my colleague Lauren is going to be speaking to Mark Bould, about his book, the Anthropocene Unconscious, climate catastrophe culture. Tune in then for that, that should be very interesting. Thank you very much.