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Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Reduce and Cap Carbon Dioxide from Fossil Fuel Fired Electric Power Generating Facilities (Rev. C17)
Stage Proposed
Comment Period Ends 3/6/2019
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3/6/19  10:29 am
Commenter: Max Broad, National Wildlife Federation

Biomass Blowback: How Virginia Can Avoid Duplicating the Fallout from the UK’s Climate Policies

Biomass Blowback:

How Virginia Can Avoid Duplicating the Fallout from the UK’s Climate Policies


The Virginia Conservation Network and National Wildlife Federation strongly support Virginia’s proposed regulation for emissions trading. To promote the successful implementation of this policy, we seek to demonstrate that Virginia should regulate all greenhouse gas emissions, not just those from fossil fuels. In doing so, Virginia can obviate a series of problems associated with the types of biomass are most problematic for the climate.

  • Environmental: Substituting biomass for fossil energy often does not mitigate climate change, and actually increases near-term pollution.
  • Political: Carbon pollution and biodiversity impacts from biomass have drawn the ire of the public, media, and NGO sector, particularly in the UK which is driving many of the problems.
  • Economic: Biomass requires immense subsidies to be competitive, whereas clean renewables are already economical.

By taking a page out of the UK’s book of how to address climate change, Virginia can prevent recreating the same problems. Britain established climate policies nearly a decade ago that sent strong market signals to transition away from fossil fuels. Because this regulation was about phasing off of fossil fuels and not about reducing greenhouse gas emissions, it had an unintended yet severe consequence: it became a major driver of biomass, which is resulting in increased emissions.

The UK has muddied its climate progress by allowing all types of biomass, regardless of emissions footprint. Their policy was developed when the carbon accounting science for biomass was nascent, so the UK erroneously classified biogenic emissions as carbon neutral. Consequently, this policy has had tremendous environmental ramifications. Since its implementation, the UK rapidly scaled up to be the top consumer of biomass in the world. In parallel with this boom, the science has come out to resoundingly assert that biogenic carbon emissions most often have a payback period that is decades in the future. The time needed to resequester the emissions from burning biomass usually takes so long that it is not compatible with the urgency of climate change. Last year the European Academies of Science Advisory Council assertively removed ambiguity on the climate cost of bioenergy:  

The concept of all bioenergy being carbon-neutral is too simplistic...Carbon neutrality

involves a ‘payback’ period (the time taken for forests to reabsorb the carbon dioxide

emitted during biomass combustion), which ranges from decades to hundreds of years[1]


Although the UK policy errantly deemed biomass carbon neutral, it is actually driving carbon emissions that are exacerbating the pace with which we approach irreversible climate impacts.

Socially, this policy had major political blowback. The UK public, alarmed at the environmentally consequential use of biomass, has become activated on this issue. Congruently, the media picked up on the destructive practices and climate impacts, publishing several major articles on biomass. The British TV program Dispatches even made an exposé documentary on the wood pellet trade. Major think tanks wrote papers that created embarrassment over the policy[2] [3] and environmental groups mobilized their members to apply pressure on politicians. Realizing the gravity of the mistake, the government is now walking back their policy on biomass. Last August, they reworked the major subsidy scheme for renewables to only permit the most efficient uses of biomass.[4] In December, the UK Committee on Climate Change released a report that advised a transition away from large-scale biomass power plants and declared “the production of some biomass feedstocks could lead to larger net GHG emissions than fossil fuel alternatives.”[5] The Department for Environment, Food and Rural Affairs is issuing a consultation to help them make a formal decision on biomass “We will consult on making coal to biomass conversions ineligible for future allocation rounds of the contracts for difference scheme.[6]

Moreover, there is a strong case that most biomass is not economically competitive. In the UK, Vivid Economics found that new solar and wind have a lower total economic cost than new biomass. As a result, taxpayers are subsidizing biomass at the rate of roughly £2 million per day![7] Similarly, the Georgia Institute of Technology found that Dominion’s forest biomass investments in Virginia are extraordinarily expensive compared with clean energy alternatives.[8]

Virginia can avoid these pitfalls by simply returning to the original language in the draft regulation that included emissions from biomass. Indeed, Virginia’s draft policy explicitly states that it will regulate CO2 emissions—this effort should not be limited to fossil fuels. Not all types of biomass pose a threat to the climate—wastes and residues that would have otherwise been burned or decayed on their own have a sound climate performance compared to fossil fuels. Yet, by allowing unrestricted uses of biomass, a policy will inevitably allow and even encourage biomass sources that have the highest carbon emissions. This is the source most commonly used in the UK. Not setting safeguards that qualify climate-friendly biomass is tantamount to cherry picking technology winners. The Virginia Conservation Network and National Wildlife Federation advise that Virginia heeds the science—biomass can make problems worse for the climate. We urge you to regulate biomass emissions unless the source genuinely helps address the threat of climate change.


Mary Rafferty

Executive Director

Virginia Conservation Network


Julie Sibbing

Associate Vice President of Land Stewardship

National Wildlife Federation


The Virginia Conservation Network (VCN) is an environmental non-profit organization with over 100 Network Partners across the Commonwealth. Founded in 1969, VCN is committed to building a powerful, diverse, and highly-coordinated conservation movement focused on protecting our Commonwealth’s natural resources.

The National Wildlife Federation (NWF) is America’s largest advocacy-based conservation organization, with nearly six million members and supporters. Founded in 1936, we have 51 affiliates across the United States. NWF is dedicated to protecting wildlife and habitat, and to inspiring the next generation of conservationists.


[1] EASAC, 2018. Commentary by the European Academies’ Science Advisory Council (EASAC) on Forest Bioenergy and Carbon Neutrality.

[2] Brack, D. 2017. Woody Biomass for Power and Heat: Impacts on the Global Climate. Chatham House.

[3] Brack, D. 2017. The Impacts of the Demand for Woody Biomass for Power and Heat on Climate and Forests. Chatham House.

[4] BEIS. 2018. Contracts for Difference Scheme for Renewable Electricity Generation

[5] The Committee on Climate Change. 2018. Biomass in a low-carbon economy.

[6] DEFRA, 2019. UK Clean Air Strategy.

[7] NRDC. 2018. Reality Check.

[8] Georgia Institute of Technology. 2018. The Economics of Four Virginia Biomass Plants.