The Renewables Obligation Banding Review presents an opportunity for the government to get this right, by remove the existing financial incentives for unsustainably produced biomass electricity generation and redirecting this support towards genuinely sustainable renewable energy technologies and measures to dramatically reduce energy demand.   

Sustainable biomass is a limited resource and should therefore be used in the most efficient way possible. This means local production of biomass to minimise transport emissions and costs, and the incentivisation of combined heat and power plant.

Subsiding existing or planned large-scale biomass electricity power stations or co-firing of coal and biomass by large power stations without utilisation of heat is not a good use of taxpayers’ money.

These are inefficient and wasteful of fuel, typically having a conversion efficiency of 30 to 35 per cent compared to the EU Renewable Energy Directive's aspiration for biomass energy use to be at least 70 per cent efficient.

Mandatory sustainability standards must also be introduced to prevent production or extraction of energy biomass from land otherwise used for food production, pristine forests, lands with high carbon stocks and high nature conservation value such as wetlands and peat lands.

The current EU standards do not go far enough and must be improved through the addition of rules to mitigate indirect land use change and mandatory standards for water, soil and air protection  as well as social criteria. Compliance mechanisms must be robust and must not rely on self-reporting by fuel suppliers.

The Scientific Committee of the European Environment Agency’s advice[iii] underlines the crucial importance of strong safeguards to guarantee sustainability and genuine carbon savings, stating:  “legislation that encourages substitution of fossil fuels by bio energy, irrespective of the biomass source, may even result in increased carbon emissions – thereby accelerating global warming”.  

Given the particular reputation of palm oil as the epitome of environmentally destructive bioenergy, I would ask that you commit publicly to ruling out any subsidy for palm oil energy generation through the Renewables Obligation. 

Hard-pressed householders will not take kindly to hearing that even a small proportion of their energy bills could be contributing to the destruction of tropical forests and endangering the very existence of iconic species such as the orang-utan.

The public need to be confident that the Renewables Obligation will only support biomass that meets the highest sustainability standards in both production and use, in order to prevent environmental and social harm and secure genuine carbon reductions.

A number of my constituents have raised additional concerns regarding bioenergy and I enclose a summary of these. I would be grateful for your response to these points, as well as those set out in the body of this letter.

Thank you in advance for your ongoing consideration of these crucial issues.  I am copying this letter to Chloe Smith and I look forward to receiving a reply from both of your departments and to the imminent publication of the Government’s response to the Renewables Obligation Banding Review.

Yours sincerely,

Caroline Lucas, MP Brighton Pavilion