Draft Bioenergy Policy Statement: Consultation

I am answering this consultation principally from a biomass crops industry standpoint. The issue that makes it difficult to develop a biomass crops industry is that power stations require large volumes of cheap biomass whereas farmers need to gain a high return from their land. 30 years of trying to get farmers to plant biomass crops en masse has failed. There are more lucrative ways that farmers can make money and so they have taken those choices. In order for biomass crops to play a major part in the Net Zero challenge the income potential for farmers planting these crops must significantly increase. It needs to be an easy decision for farmers to make - for instance planting grants, interim payments, environmental payments for value added services (e.g. flood mitigation, water quality buffer strips, biodiversity etc), subsidised harvesting and transport and a good price for the biomass product. There is lots of competition for land from food crops/livestock production and environmental incentives. Growing biomass crops ties up land for 20+ years so for farmers to take this up as an option they will need to be persuaded by very big carrots.

The potential uses proposed are predominantly bioenergy based. As per my answer in Q1, this has not been achieved despite over 30 years of efforts. Either the incentives offered farmers need to increase or any new policy will just lead to cheap imports from other countries. It is very important to recognise this. Otherwise, the Scottish Government will be following a very well trodden path that doesn't lead to a biomass crops industry. Redacted text

There are many other potentially more lucrative markets for biomass crops. For instance Short Rotation Coppice willow can be used for compost and mulch, fodder for livestock and zoo animals (it can reduce GHG emissions compared to grass and cereal feeds), bioactive bedding for livestock, horses, zoo animals and pets, bio-packaging and pharmaceuticals. A biorefinery approach as researched by the EU Interreg funded project BioWill is an obvious way forward which would potentially allow farmers to make income from several revenue streams.Redacted text

In addition, the consultation document fails to recognise the many environmental protection measures that could be achieved by planting biomass crops. These crops could have a multi functional role whilst they are growing and
• Provide environmental protection measures (water quality improvement, a means of flood mitigation, soil erosion control).
• Enhance biodiversity benefits and ecosystem services (SRC willow in particular provides habitats and feeding opportunities for insects and birds, pollination services through provision of nectar and pollen from willow catkins, encourages predatory arthropods that can help control food crop pests).
• Help reduce a farms net greenhouse gas emissions (GHG) and potentially increase soil carbon sequestration. Also, reduce the life cycle GHG emissions from other processes such as effluent disposal and water treatment.

The issue here is that if the housing stock in Scotland was completely overhauled and retrofitted with high levels of insulation, draught proofing and other energy efficient measures then heat pumps would be the most obvious way forward. However, the housing stock in Scotland is still very poor from an energy efficiency point of view. This makes many properties and businesses hard to heat and expensive to heat. Furthermore, heat pumps are wholly unsuitable for these properties unless insulation levels are increased and heat loss reduced. If heat pumps are installed in houses that don't have sufficient insulation then they will actually be more expensive and require more energy. This is untenable. As such biomass boiler systems and pellet stoves offer an option for these sorts of properties. I would love to see the phasing out of biomass for heating but I think for the forseeable future biomass for heating is an essential way of decarbonising heating.
Producing biomass crops for heating purposes is more lucrative to farmers (especially self-supply or local provision) than selling in volume to power stations. The biomass heat sector also enables jobs in rural areas in different parts of the supply chain.

This is just 2% of Scottish farmland and is therefore considered to be an achievable threshold and in line with that suggested in the consultation and by ClimateXChange.

Our view is that if all things were equal farmers would have the following preferences for their land:
Food crops and animal husbandry > annual non-food crops > perennial biomass crops > short rotation forestry > regenerative agriculture > woodland creation
However, government incentives skew this by making some land use options more advantageous. At the present time we feel that this changes the preferences to
Food crops and animal husbandry > regenerative agriculture > annual non-food crops > woodland creation > short rotation forestry > perennial biomass crops
The lack of incentives for biomass crops means that they are not even on the radar of most farmers. As a result, the potential for rapid environmental protection interventions is not being exploited.

Biomass crops offer farmers a chance to keep their land as farmland. By contrast a conversion to woodland is a permenent land use change. The former is advantageous and should be seen as such by policy makers. If incentives were made available, potentially more landowners would get on board and plant biomass crops - this could make an immediate difference to the environment at a reduced cost to the tax payer. Incentives for woodland planting are very expensive and the environmental protection benefits (flood mitigation, water quality improvements) are realised in a much slower fashion. We need climate change adaptation measures now, not in 20-30 years. Biomass crops provide this immediacy.

We believe there is a £50 per tonne funding gap that needs to be filled by incentives in order to create a thriving biomass crops sector in Scotland. This could be achieved through incentives based on the maxim “public money for public goods”. This would enable rapid environmental protection interventions to be implemented whilst enabling farmers to produce biomass feedstock to help meet Net Zero targets. Please see answer to Q2.

Please refer to answers to Q1 and Q8. Farmers are unlikely to plant biomass crops whilst there is no support whatsoever. It simply does not stack up financially. Until, a tipping point is reached no industry can be created and there is no chance that it will ever be possible to be self sustaining.

However, if the Scottish Government can see the oportunities that exist to harness benefits to biodiversity, flood mitigation and water quality then farmers could be rewarded for the role that these crops can play whilst growing. Research at AFBI in Northern Ireland shows that willow buffer strips can reduce phosphate run off from agriculural fields by 35%. Very few crops offer so much in the potential to meet Net Zero targets and fight climate change. We would like to share with you some ideas for large scale projects that roll out the environmental protection measures offered by SRC willow. These could potentially deliver environmental benefits whilst providing valuable data. We cannot afford to wait for small scale plot trials. Where data (like that produced in NI) suggests an obvious environmental benefit we need to roll out solutions now. Checks and balances can be put in place but there is no excuse for inactivity when science indicates that there are low cost, green solutions available.

In Q2 we mention the many opportunities for using a biomass crop like SRC willow to help decarbonise. For instance as the UK phases out peat in compost there is a huge opportunity to meet this demand for peat free compost with composted SRC willow. This is a huge market that already exists. The alternatives (imported coir or green waste) are no where near as environmentally friendly, carbon lean or produce a consistent enough product.

Research at Queens University Belfast suggets that feeding cows with willow fodder can reduce methane emissions from livestock burping by around 20%.

Both these opportunities would enable beneficial products that work with the actual crop. Combusting willow requires the woodchip to be dry whereas these products do not. In addition, achieving the best fuel from willow would require harvesting in the winter dormant period. This is simply not possible with our mild, wet winters. Again, the alternative products enable and benefit from harvesting at other times of the year.

After 50 years of research and a recent investment of £37 million from the Biomass Feedstocks Innovation Programme we have all the necessary knowledge on best practice, varieties and innovative technology to create a world leading biomass crops industry.

The BFI programme will afford high class technological solutions than can increase efficiency, improve the window of opportunity to plant and harvest, varieties that will achieve higher yields and knowledge transfer facilities that will enable farmers to make informed decisions on crop choise for their land.

All of this will reduce costs, ensure that the right crop is planted in the right place and improve potential returns to the farmer. It is still not enough.

In order to achieve an industry that is capable of meeting the Net Zero challenge we need the Scottish Government to provide a suite of incentives that will make the decision for farmers to plant almost impossible to resist. One has to remember that farmers (like anyone) do not like making a risky 20 year decision. They are hardly likely to take this plunge without a very strong safety net. The risk needs to be removed or considerably reduced. It also needs to be remembered that biomass crops are not the first choice for land use for most farmers (see Q8 response). In order for this to change incentives need to be introduced that make it an attractive propostion to farmers. Parity with food crops is not enough. As has been shown with recent environmental incentives, the remuneration level needs to be set high in order to gain momentum. My view is that a package that would enable a farmer to achieve a 20% increase in income compared to the average food crop/livestock option on their land could persuade farmers to convert a prportion of their farm to biomass crops. Checks and balances could and should be put in place in order to avoid a financially unsustainable mad rush.

In addition, the Scottish Government needs to assist with market development, helping small businesses invest in kit and infrastructure so there is a market pull. This would probvide a framework for success. Within 5-10 years the biomass crops sector would be able to stand alone without additional support.

There are several projects funded under the UK Government's Biomass Feedstocks Innovation Programme that could make a difference to delivering a biomass crops industry. Here are some examples:

Net Zero Willow
The UKs maritime climate makes it very difficult to plant and harvest willow plantations at the correct time. Most machinery developed for willow cultivation was produced in countries with drier soils and harsher winters. These machines have been used in the UK for 30 years. However, the changing climate means that these inefficient machines are no longer suitable. The Net Zero Willow project is developing the most significant step forward in the history of willow cultivation technology. The project seeks to benefit from marginal gains achieved at every step of the pathway. This will help increase yields, reduce costs, increase the window of activity for field working, reduce inputs and labour requirements, reduce lifecycle greenhouse gas emissions and reduce the impact on the soil. An autonomous robotic machine is being developed that will (initially) comprise two modular attachments to harvest propagation material and plant willow cuttings. A separate innovation is a tracked forage harvester with an integrated bunker.
This project was instigated in 2020 and is nearing the end of phase 2 funding. This project is led by Willow Energy.

Envirocrops
The idea behind the Envirocrops is to create a digital consultant for biomass crops such as Short Rotation Coppice (SRC) willow and Miscanthus. Over 20 years, Crops for Energy (C4E) has produced hundreds of feasibility studies and created many dissemination tools. Envirocrops aims to assemble all this information into a single web app allowing users to follow the same steps as those set out in a consultant’s report. However, whereas a report is relevant on the day of publication, users of the Envirocrops web app will be able to return to the information as and when circumstances change e.g. markets evolve, prices increase, incentives are made available, world events unfold etc. If humanity is to combat climate change and move towards net zero then farmers, policy makers, academics and students will need tools like Envirocrops (and its offshoot, the game Cropper) to help growers understand the economics, logistics and best practice cultivation techniques for biomass crops.
This project was instigated in 2020 and is nearing the end of phase 2 funding. The project is led by the Agri Food and Biosciences Institute.

Biomass Connect
This project is designed to provide farmers and other interested parties with all the information they need to be able to plant the right biomass crop in the right place. It works alongside Envirocrops to provide a suite of knowledge transfer activities that include a network of 8 accessible trial sites across the UK that include 11 different biomass crop types planted together. Biomass Connect also provides a huge website resource with written articles, cases studies, webinar library and what’s on guide.
This project was instigated in 2020 and is nearing the end of phase 2 funding. The project is led by the UK Centre of Ecology and Hydrology.

As part of the third year of Biomass Connect there is an intention to draw together scientific knowledge into recommendations for biodiversity standards (gold, silver and bronze). These will be shared with policy makers across the UK.

Already some farmers are integrating some of these measures in their plantations. One of our clients is planting an SRC willow plantation this spring. This will include additional buffer strips to maximise edge effect and the plamting of native, male willows around the periphery of the plantation. This will attract more pollinators to the crop (as most improved biomass varieties are female and therfore only provide nectar, whereas male willows also provide pollen which is a food source for pollinators and birds).

The Biomass Connect project has produced several outputs that educate on the potential benefits of biomass crops to biodiversity. Redacted text

Planting biomass crops (particularly SRC willow) as agroforestry strips coudl have numerous benefits for farm biodiversity and environmnetal protection by
- Providing maximum edge effect and wildlife corrdors
- Enabling food sources for birds and attracing polinators
- Providing habitats for predatory arthropods which are useful in biological control of pest species
- Providing erosion control
- Reducing pollution entering watercourses by intercepting agricultural run off (particularly useful in nitrate vulnerable zones and catchments with phosphate pollution issues)
- Enabling increased hydraulic roughness to reduce flow of water and debris during flood events.