Background

Climate change is progressing at an alarming pace. Every day there are new facts emerging: Hottest June (in the UK) on record, hottest year on record, wettest July (in many places in the UK) on record, hottest ocean temperature, wild fires in southern Europe and North America.

Various organisations including the Intergovernmental Panel on Climate Change (IPCC) and the Climate Change Committee (CCC) have stated the importance of biomass crops in meeting Net Zero targets and combatting climate change. The CCC has suggested that for the UK to meet Net Zero targets there needs to be 700,000 hectares of biomass crops by 2050[1].

Despite over 50 years of research into biomass crops, no country in the world has managed to progress a policy framework that has led to a significant scaling up of a biomass crops industry[2]. Policy and schemes have usually been short term and ill thought through leading to boom and bust[3].

The market price for biomass and need for economies of scale by large bioenergy end users often squeezes out the potential for more sustainable, locally produced biomass crops in favour of less sustainable, imported fuels.

Despite many environmental potentialities (e.g., increasing farm biodiversity, option for flood mitigation and water quality protection, erosion control, carbon sequestration etc) biomass crops are not and never have been part of any environmental schemes. This is a serious omission which fails to capitalise on the major environmental benefits of biomass crops.

Environmental NGOs tend to be concerned about biomass and its use in combustion schemes. Their opposition to large scale, imported biomass tends to cast a large shadow over locally produced biomass crops. As a result, organisations that should be an obvious natural ally to the biomass crops sector (because of the environmental benefits that they offer) are more likely to lobby against any measures that promote biomass crops.

The UK Biomass Strategy was published on 10 August 2023. The initial announcement was made in November 2020 and the call for evidence was made in April 2021[4]. There were several delays before the final publication was released. Despite significant engagement from biomass crops sector participants, the Strategy does not present the necessary action plan to stimulate planting. As a result, there remains a policy vacuum and no incentives or schemes that include these crops.

The UK Government has supported many programmes and projects which are augmenting the evidence base and enabling new innovations to be developed to meet the upscale challenge, such as: the Biomass Feedstocks Innovation Programme (which includes the Biomass Connect and Envirocrops projects)[5], The Centre for High Carbon Capture Cropping (CHCx3)[6], Perennial Biomass Crops for Greenhouse Gas Removal (PBC4GGR)[7] and the forthcoming Land Use and Net Zero Hub (LUNZ)[8].

This paper suggests that in the UK there is:

• A distinct and obvious need for biomass crops to meet Net Zero and other environmental requirements.
• A network of world class academic organisations and researchers currently deployed in the biomass crops field.
• A thorough scientific evidence base demonstrating that biomass crops can be deployed to provide ecosystem services and biodiversity net gain.
• A small but highly committed and experienced group of SMEs working in the biomass crops sector.
• A number of world class innovations being created that will revolutionize the biomass crops sector and make it possible to upscale towards anticipated land use levels.

The one thing that is missing is a World Leading policy framework that will bring all of this together and enable biomass crops to fulfil their potential.

The current approach – and an alternative

The current approach to dealing with biomass crops policy does not work. It involves Government Departments releasing a call for evidence, doing fact finding visits, listening to information and then after a period of time putting together a Strategy. At this point the industry and other interested parties are invited to respond, and revisions may (or may not) be made. More time passes and this initial framework may lead to the design of schemes and incentives. Usually, this involves another period of consultation, and more time is lost.

As we are dealing with a climate emergency, this traditional approach is simply not a viable option.

Forestry schemes have the advantage in that the forestry bodies in each of the devolved regions are part of the fabric of Government.

• In England, the Forestry Commission sits alongside DEFRA, Natural England and the Environment Agency.
• In Scotland, Scottish Forestry is the government agency responsible for forestry policy, support and regulations.
• In Wales, Natural Resources Wales are responsible for creating, protecting, and managing woodlands.
• In Northern Ireland, the Forest Service is part of the Department of Agriculture, Environment and Rural Affairs (DAERA).

This means that people who understand forestry and woodlands are involved in designing the schemes for forestry and woodland creation and are able to communicate these with Government departments and agencies at the very top level.

Similarly, the official forestry bodies produce their own action plans and strategies:

• Scottish Forestry Strategy 2019[9]
• England Tree Strategy and England Trees Action Plan 2021-2024[10]
• Wales Sustainable Farming Scheme 10% Tree target[11]

There is as yet no Biomass Crops Commission or a similar entity. There is also, and never has been a Biomass Crops Strategy and Action Plan. This is a big problem as getting to 700,000 hectares is an extremely challenging target[12]. Also, there are many biomass crop options, all with different pros and cons. This means that designing long term, affordable, workable schemes and policy instruments is very complicated. There either needs to be an integrated body that speaks for biomass crops in devolved Governments, or the sector needs to be creative and combine the talents from all sectors: Government officials, industry participants, academic experts and conservationists.

It is highly unlikely that a Biomass Crops Commission will be borne in a short time. Therefore, a collegiate approach involving key stakeholders has to be the way forward.

We are not proposing to start this process from scratch but to build on and align with the foundation of work carried out as part of the Biomass Strategy and Land Use Policy Framework as well as with policy makers in the devolved regions.

This would enable the design of schemes that:

• Meet Government targets.
• Enables farmer buy in.
• Translates research findings into practice.
• Maximises environmental benefits and minimises trade-offs.

This surely is a pragmatic approach allowing all parties to agree on a way forward that enables and rewards productivity whilst enabling ecosystem services and biodiversity net gain.

Enabling Productivity and Ensuring Environmental Net Gain – a tiered approach

A pragmatic approach to incentives and schemes would provide opportunities for farmers to make a viable income whilst also enabling environmental benefits. A tiered approach could be managed as follows:

• Tier 1 – Environmental Gold standard – biomass crops planted in a way that maximises environmental benefits (ecosystem services and biodiversity net gain). This would limit productivity due to increase of open land/edge effect but would provide the greatest subsidy (public money for public goods). This option could perhaps be considered for more sensitive (but not the most sensitive) land.
• Tier 2 – Payments for other environmental considerations e.g., flood mitigation and water quality protection. This tier would not prohibit productivity as that might impact on the environmental purpose.
• Tier 3 – No payments over and above those payments to which a permanent arable crop

grown on eligible land would qualify. Limited to non-sensitive land. Productivity would be the main purpose of the plantation.

Placating environmental trade-offs – Checks and Balances

Particular concerns with biomass crops from conservation bodies are “what ifs” and the implications of these. For instance, there is a worry of replacing one monoculture with another monoculture. Also, there is the concern at the untapped growth of the biomass industry so that there is natural capital loss due to over planting of a particular type of crop. A further worry involves using non-native plants.

700,000 hectares is a large area, but it won’t be achieved overnight. It will take decades. We should look to bring in checks and balances to make sure that environmental trade-offs are minimised. These could be carried out through ongoing academic studies which report regularly, say every 5 years. If certain crops do have detrimental effects on the countryside, then further planting should be restricted. Similarly, if there are few or no environmental limitations then the crops should be allowed to be planted without restriction until the next review window.

What we need to avoid is putting in barriers at the start and “make the best the enemy of the good”. That will stop possible improvements being achieved soonest and only preserve a status quo which is not helping the natural environment.

Gaps in knowledge – Twin track approach

Despite 50 years of research into some biomass crops (e.g., Short Rotation Coppice willow) there are newer crop options that have knowledge gaps. We can ill afford to wait to plant until we know all the research outcomes. That could waste years which we don’t have in the fight against climate change.

Where knowledge gaps exist, the research work should be carried out alongside a small to medium scale commercial roll out. An example is Eucalyptus plantations. There is enough knowledge to know that these tree crops (as Short Rotation Forestry) produce high yields and achieve excellent land resource efficiency. The knowledge gaps include biodiversity implications and effects of the UK maritime climate on establishment and survivability. Research work could be carried out on existing commercial plantations and feed into the 5-year report on environmental checks and balances.

Holistic schemes – Levelling up

It is very important that there is parity and fairness across crops. At the moment there are payments for woodland creation that can help in flood mitigation schemes but there are no payments for biomass crops. There is evidence that the higher hydraulic roughness of SRC willow and miscanthus can provide much quicker, more effective and cheaper solutions. This is in terms of stemming the flow of water, giving people downstream more time to react and reducing the movement of dangerous objects blocking bridges and culverts. Going forward, schemes that target flood mitigation efforts should be holistic and include biomass crops.

In addition, if biomass crops are considered to be an important part of meeting Net Zero targets, then a Biomass Crops Action Plan is necessary. We would welcome the opportunity for funding to be made available for this from the Nature for Climate Fund (in the same way it was for the (England Trees Action Plan).

Scheduling the roll out – Maintaining momentum

The Biomass Feedstocks Innovation Programme will conclude in March 2025. All of the projects funded under this scheme are required to have a commercialisation strategy in place to take their innovations to market. It is very difficult to devise a plan of activities to realise this without some clarity on the future policy framework. In order to maintain momentum in market development and avoid a period of inertia that will impact the upscale challenge, we propose that there is an urgency to design a scheme in readiness for a trial launch in the spring of 2025. To make this achievable for Government departments, agencies and the biomass crops industry we suggest that any scheme or schemes are rolled out on staggered basis, i.e.:

• A trial basis in 2025 (limited numbers of growers or land area) perhaps targeted at a particular region with a particular need.
• An increased capacity for 2026 planting (subject to initial satisfactory results).
• Full launch for Spring 2027 planting.

These timescales are considered to be realistic and will provide the assurance required by biomass crops companies to invest and scale up capacity with confidence. A staggered launch will also mean that many results from other projects (CHCx3, PBC4GGR, LUNZ etc) will be available to feed into the scheme eligibility and rules.

There are clear opportunities for this activity to progress alongside the Land Use Policy Framework being developed by DEFRA in England. We will also seek opportunities to liaise with policy makers in Scotland, Wales and Northern Ireland.

To kick start this approach we suggest a round table event in the autumn of 2023 with relevant stakeholders and policy makers. As an industry we will present our ideas for schemes and incentives, and we hope that this will serve as a starting point for constructive dialogue.

The future – Beyond Bioenergy

Biomass crops are multi-functional and ambidextrous. On one hand, they produce a great deal of useful material, in a short time with a high land resource efficiency. On the other hand, whilst growing they provide ecosystem services and biodiversity net gain.

For the last 30 years the focus of getting an industry up and running has all been about bioenergy. As a result, biomass crops are synonymous with bioenergy. This market placement has largely been a failure. There are still possibilities for bioenergy to serve as an enabler to help upscale the biomass crops sector. However, this is probably a transitionary use for what is a much more valuable commodity.

Biomass crops policy should look Beyond Bioenergy. Much academic work is focussing on the biorefinery approach where different aspects of the biomass produced are harnessed with the potential of several revenue streams for the farmer. Of course, bioenergy could be one of the products, but very likely the lowest value one.

Current and planned R&D projects are looking at biomass crops for use as pharmaceuticals, biopolymers, bio-packaging, insulation, cement replacements, biochar, mulches and composts and animal fodders. All these are potentially more lucrative for a farmer than selling into large scale bioenergy facilities.

Conclusion

We the undersigned believe that this document presents a pragmatic and achievable approach to developing long term biomass crops policy. We very much welcome the opportunity of engaging and working with and alongside Government officials in all of the four devolved regions, academic researchers, environmental organisations and any other relevant stakeholders to achieve synergistic benefits for landowners, the environment and a significant contribution towards our net zero targets.

Signatories

• Kevin Lindegaard, Crops for Energy
• Murray Carter, EWBP
• Paul Carver, New Energy Farms
• Mike Cooper, Miscanthus Nursery
• Richard Edwards, Sida Agroforestry
• Bryan Elliott, Eucalyptus Renewables
• John Hawkins, Bagber Farms
• Matt Hunt, Bio Global Industries
• Will Jackson, Poplar Tree Company
• Jamie Rickerby, Willow Energy
• Alex Robinson, Terravesta
• David Watson, Energy Crops Consultancy

References

[1] Land use: Policies for a Net Zero UK. Committee on Climate Change (CCC) (2020) https://www.theccc.org.uk/publication/land-use-policies-for-a-net-zero-uk/#:~:text=The%20report%20sets%20out%20a,and%20conifer%20woodland%20each%20year.

[2] A critical appraisal of the effectiveness of UK perennial energy crops policy since 1990. Adams and Lindegaard (2016) Renewable and Sustainable Energy Reviews https://www.crops4energy.co.uk/wp-content/uploads/2022/11/Adams-Lindegaard-2016-final-formatted-version.pdf

[3] Short rotation plantations policy history in Europe: lessons from the past and recommendations for the future. Lindegaard et al (2016) Food and Energy Security. https://onlinelibrary.wiley.com/doi/pdf/10.1002/fes3.86

[4] Role of biomass in achieving net zero: call for evidence https://www.gov.uk/government/consultations/role-of-biomass-in-achieving-net-zero-call-for-evidence

[5] Biomass Feedstocks Innovation Programme: successful projects https://www.gov.uk/government/publications/biomass-feedstocks-innovation-programme-successful-projects

[6] Centre for High Carbon Capture Cropping https://www.niab.com/research/agronomy-and-farming-systems/centre-high-carbon-capture-cropping

[7] Perennial Biomass Crops for Greenhouse Gas Removal (PBC4GGR) https://pbc4ggr.org.uk/

[8] Land use for net zero – research (LUNZ-Research) https://www.ukri.org/opportunity/land-use-for-net-zero-research-lunz-research/

[9] https://forestry.gov.scot/forestry-strategy

[10] https://consult.defra.gov.uk/forestry/england-tree-strategy/

[11] https://www.gov.wales/sustainable-farming-scheme-outline-proposals-2025-frequently-asked-questions-html

[12] In 1919, the UK faced a similar need to increase woodland cover. Following World War I, UK woodland cover had fallen to 5% and the aim was to increase this to a more sustainable figure. The Forestry Commission (FC), a non-ministerial government department was established, and land was requisitioned for afforestation and reforestation. At its height, and prior to devolution, the FC managed 700,000 hectares of forestry across the UK! It is a big coincidence that these area figures are the same. It does however illustrate clearly – that to achieve such a large area we will need a big body to help realise the change.