Shrewsbury friends of the earth

E.ON. Change of fuel from coal to wood at Ironbridge Power Station

Update November 2013

Shropshire Council did not refuse planning permission. Nor did it require E.ON to report annually on the type of fuel it was using, its source etc.

So E.ON is now burning wood pellets from the US. 

Biofuel Watch UK has recently produced a report on the sources of E.ON’s wood pellets, which shows that, as feared,  Enviva, E.On’s supplier of pellets, is clearcutting natural, slow-growing native forests in a region in the USA with highly biodiverse and fragmented wetland.*

The problem is essentially one of scale. If we, as individuals, burn wood pellets in home boilers or use logs on wood-burning stoves , it is possible to use wood from managed woodlands. The CO2 emitted from burning can be absorbed by the remaining trees. Large-scale burning leads to huge quantities of CO2 being emitted. This puts a heavy burden on the forests of the world, but if those forests are being felled to create the pellets – then the carbon sink is being destroyed. It’s not an immediate answer to plant more trees.  Trees planted now will take 20-30 years to become effective CO2 sinks.

We’re being encouraged at the moment to switch our energy suppliers for financial reasons. Here’s another good reason to move from E.ON.

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* The  detailed report by Dogwood Alliance and NRDC about the impacts of Enviva’s largest existing pellet plant, the Ahoskie pellet mill in North Carolina, can be downloaded from http://www.dogwoodalliance.org/2013/08/press-release-new-maps-reveal-envivas-ahoskie-wood-pellet-facility-threatens-southern-wetland-forests-surrounding-ecosystems-and-wildlife

Comment in November 2012

The campaign continues

What’s the problem?

1. higher efficiencies are achieved in generating heat rather than electricity
2. over-reliance on biomass to generate electricity could undermine the development of more efficient electricity generating technologies
3. too great a use of biomass is setting up economic pressures, leading to the transformation of existing old growth forests into monoculture tree plantations which undermine biodiversity

What we asked Shropshire Council to do

1. all quantities and types of feedstock being used
2. all the sources of the feedstock
3. all appropriate certification together with details as to the significance of the certification eg the standards used in the certification, suppliers credentials, fuel renewal policies etc
4. the fuel supply chain: transport of fuels from source to user, with a calculation of cost and environmental impact
5. stack emissions data, an air quality assessment based on those emissions and information as to probable and possible effects.

E.ON planning application to erect a wood pellet fuel store at Ironbridge power station

Comment from Shrewsbury Friends of the Earth

1    E.ON planning application

We are writing to make comment on the planning application by E ON in relation to Ironbridge power station. They are seeking permission to construct a wood pellet fuel store.

2    Wildlife: grounds for refusal

We are not in a position to undertake a survey of the wildlife or to note potential disruption to wildlife as a result of the construction of the store. But we have read the comment on the planning application by Shropshire Council’s ecologist and wish to support her in her concern for the badgers and great crested newts and believe that the wood store should be rejected on these grounds.  

3    Wood burning: grounds for refusal

The construction of the fuel store is to enable E.ON to undertake a major change in practice - from burning coal sourced in Russia to burning virgin wood pellets probably from N America in the first instance. This gives us great cause for concern. We believe that E.ON will be contributing to worldwide environmental damage that is currently taking place on a wide scale.

We understand that E. ON is not restricted under its current licence with the Environment Agency to the burning of a particular feedstock. It is therefore not required to seek planning permission for a change of feedstock to virgin wood/biomass.

We propose that Shropshire Council reject the application on environmental grounds because of the intended use of the building.  As a different agency from the Environment Agency, and on whose land the wood burning will take place, SC could argue that the wood pellet store is a key crucial component of a system which when used as intended will cause heavy pollution and environmental damage. (An analogy might be selling a gun to a man who is known to be intending to kill his neighbour) The wood pellet store as a building in itself is benign and if E.ON simply filled it with wood and left it there, this would also be benign. But E.ON is intending to use it for an activity which evidence shows will cause great damage to the environment.  While the EA is locked into a permit and is not in a position to challenge this, Shropshire Council is.

4    Intended use of the wood store – and environmental damage

    Sustainability

We estimate that to generate 270 MW of electricity from biomass, E.ON would be required to burn more than 2 million tonnes of wood a year. The UK produces less than 10 million tonnes of wood annually. Across the UK, companies have already announced plans to burn around 60 million tonnes annually in other biomass power stations.

FoE nationally opposes the use of biomass in large scale thermal electricity generation for reasons which include:
higher efficiencies are achieved in generating heat rather than electricity
over-reliance on biomass to generate electricity could undermine the development of more efficient electricity generating technologies
too great a use of biomass is setting up economic pressures, leading to the transformation of existing old growth forests into monoculture tree plantations which undermine biodiversity (1).

Environmental and conservation organisations in the US are warning about the devastating impact which Europe's and especially the UK's biomass demand will have on forests in North America, including in the southern US.

Certification of sustainable wood sources is notoriously difficult to police. Most suppliers of wood that have certification under internationally recognised sustainable forest management schemes are in Europe and N America. However, these may be using dubious practices. E.On have entered into an agreement with Enviva for purchasing very large quantities of wood pellets from the southern US, almost certainly with a view to supplying Ironbridge.    E.On will be easily able to supply “sustainability certification”: the certification used by Enviva and thus to be used by E.On is the 'Sustainable Forestry Initiative' or SFI.  Dubbed 'Selling False Information' by North American NGOs such as Forest Ethics in Canada (2). Greenpeace comments: "SFI-certified companies continue to log old-growth and endangered forests, destroy the habitat of rare and endangered species and replace natural forest with plantations." (3)  The Dogwood Alliance works to protect forests in the southern US. They warn that the large new bioenergy demand could spell the end for what remains of the southern US native forests and their biodiversity (4). Yet those very practices are already SFI certified.

E.ON indicates that it will be open to the use of biomass generally: their wood is “likely to be sourced primarily from N America…(and later) it is likely that other locations for sourcing similar sustainable fuels will become available” (our italics p 3 Main Supporting Document). This opens up the possibility of their using other fuels – frequently sourced from land which has been changed from growing food to growing energy crops with consequent increases in food prices and poverty.

    Climate impacts
E.ON states that “virgin wood pellets offer a significant improvement in environmental performance over non-renewable fossil fuels” (p2 Main Supporting Document). The evidence is very different.
Just this month, a study called "Biomass Supply and Carbon Accounting for Southeastern Forests" was published (5).  This suggests that the carbon impact of electricity from wood taken from SE US forests will be worse than that of fossil fuel alternatives for 35-50 years.  We know that emissions must come down fast; we cannot afford to further increase them for that length of time. Biomass power stations emit up to 50% more carbon dioxide than coal power stations (for the same amount of electricity) – even if new trees are planted, they will not be able to absorb this quantity of CO2.  There are many warnings that rapid warming is already leading to forest die-back and much more intense and frequent droughts, including in the southern US, so the carbon debt may in fact never be repaid.  
As the European Environment Agency’s Scientific Committee and many other scientists have warned, ignoring this carbon debt and the indirect climate impacts of biomass energy means that it is being wrongly viewed as helping tackle climate change.
CO2 aside, biomass and coal burning appear to be similarly polluting overall, with biomass emitting more of some pollutants and less of others. We are uncertain about E.ON’s claim that “there will be a reduction in the emissions of oxides of nitrogen and sulphur” (P2 Main Supporting Document ); we note Biofuelwatch’s advice that wood fuel combustion increases nitrogen oxide emissions.
    Future developments
We believe that E.ON is looking for ways of keeping Ironbridge running well beyond 2015.  They said in 2008 that biomass may be the future for Ironbridge after that date.  They will require a new planning permit, almost certainly from the Department of Energy and Climate Change. This will probably not be problematic: DECC have so far approved every single biomass power station application, regardless of size, efficiency, sourcing or air quality, etc.  If E.ON can demonstrate between now and 2015 that biomass conversion technically 'works', it will be extremely difficult to then stop them from extending the life-time of this inefficient, polluting power station probably for decades to come, very likely still burning lots of coal together with wood.  

E.ON is interested in (partial) biomass conversion

1. because of the subsidies (Renewable Obligation Certificates)
2. because biomass contains less sulphur than coal so they hope they can keep Ironbridge open without installing expensive flue-gas desulphuration. They chose to opt out of the Large Combustion Plant Directive requirements to undertake expensive upgrades to their flue gas cleaning systems.
3. E.ON is entering into long-term supply agreements in the US and new pellet factories are being built by Enviva as a direct result of what is planned for Ironbridge.  (Once that infrastructure is in place and more forests in the US have been clearcut and turned into new tree plantations for wood pellets, the impacts will be pretty much irreversible).  

5    Damage limitation – a legally binding commitment to report

If neither of the above grounds for rejection is feasible, and because of the scale of the potential damage E.ON’s actions may cause, we propose very strongly that SC takes all steps possible now to ensure that in future it will have much greater influence over any planning applications made by E.ON.  We believe that this could be done by requiring E.ON at this stage to enter into a legally binding agreement to report on all aspects of its biomass use until 2015 and by establishing a Scrutiny Group to consider, interpret and comment on these reports for Shropshire Council and Shropshire residents.

E.ON sees the use of biomass as an opportunity to learn:  “The shift to the new base fuel enables E.ON to develop an informed understanding of wood pellet consumption on a large scale and its fuel supply chain” (p2 Main Supporting Document) and “The conversion to a renewable base fuel at a large scale coal-fired power plant will help develop the long-term UK renewable fuel supply chain, potentially making a significant contribution towards the development of a low carbon environment” (p9 same document).

SC can also learn from the project. A legally binding document would require E.ON to:

 
a)    Report annually on

1. all quantities and types of feedstock being used
2. all the sources of the feedstock
3. all appropriate certification together with details as to the significance of the certification eg the standards used in the certification, suppliers credentials, fuel renewal policies etc
4. the fuel supply chain: transport of fuels from source to user, with a calculation of cost and environmental impact
5. stack emissions data, an air quality assessment based on those emissions and information as to probable and possible effects.

Each report would be required to show

To what extent (and giving specifics) the data demonstrates that burning of biomass

(a) has desirable local effects

(b) has desirable global effects

(c) has undesirable local effects

(d) has undesirable global effects

b)    Respond in writing and orally to questions from a Scrutiny Group which would be set up by Shropshire Council and would consist of local, regional and national individuals and organisations well placed to interpret the details in the reports

c)     Make available a sum of money to be determined by SC to cover all
the costs associated with this Scrutiny Group such as meetings, expenses, publication of scrutiny reports for Shropshire Council and Shropshire residents etc


This approach may place SC in a better position to
take an informed decision regarding Ironbridge power station’s future in 2015 should they seek to continue energy production
inform government and other authorities in the UK as to the effects of large scale wood/biomass burning.

(1)   www.foe.co.uk/resource/briefing_notes/biomass_summary_position.pdf .
(2)   http://forestethics.org/stop-sustainable-forestry-initiative-greenwash
(3)   http://www.greenpeace.org.uk/forests/sfi
(4)  http://www.dogwoodalliance.org/campaigns/bioenergy/: "Many forests stand on the brink of disaster — and they are facing an energy industry that sees our forests as fuel rather than as the important communities that make up our biological and cultural heritage. This could push them over the edge. Imagine if the already unsustainable level of forest management for the pulp and paper industry is combined with large-scale consumption for producing biomass and biofuel. Clear-cutting will increase well beyond current levels, threatening more of our already endangered forests. A greater level of conversion will occur, as natural forests are destroyed to create fast growing tree plantations. More chemicals will be used, harming human health and critical wildlife habitat." Yet these very practices are already SFI certified.
(5)  www.southernenvironment.org/uploads/fck/file/biomass/biomass-carbon-study-021412-FINAL.pdf .


Frank Oldaker
Barbara Phillips
Joint Co-ordinators, Shrewsbury Friends of the Earth