The GHG criteria in the Renewable Energy Directive (RED) are expressed as the percentage reduction in fossil fuel CO2 emissions from Harvesting, Producing and Transporting biomass (we can call these “HPT emissions”), compared to a fossil fuel grid comparison value, generally taken to be 183 grams CO2 per megajoule of produced electricity (183 g CO2 MJ-1). The RED proposal calls for these HPT emissions to be 70% or 80% lower than the comparison value.

The RED claims to “ensure” that burning biomass reduces emissions compared to fossil fuels, but of course this  is completely false, because by only counting HPT CO2 emissions, the GHG criteria drastically underestimate emissions by ignoring the biggest, most important and most direct source of emissions – CO2 from actually burning the wood.  It’s a complete fraud, especially considering that burning biomass emits more CO2 than fossil fuels.

Regarding the proposal for a 70% or 80% reduction of HPT emissions compared to the grid average value, wood pellet producers are already achieving these values, so the RED proposal is simply designed to allow the wood pellet industry to operate with no impediments. This will ensure forest destruction continues.

To show this, see data that the Drax power plant reports to the UK government. Drax purchases pellets from all over the world, but the majority come from the US and Canada (where Drax itself owns several pellet plants, that were the subject of that BBC documentary).

Here are the data that Drax reports to the government (original source here).

The RED proposal calls for a 70% or 80% reduction in emissions compared to the grid value of 183 g CO2 MJ-1

A 70% reduction is (1 – 0.7) x 183 = 54.9 g CO2 MJ-1

An 80% reduction is (1 – 0.8) x 183 = 36.6 g CO2 MJ-1

The data file is filtered to show the Drax data, and the first tab is and highlighted the last two columns of data, which show the emissions rate. You can see that Drax is routinely reporting GHG emission rates for its HPT emissions that are already lower than the above levels of 54.9 and 36.6, including from their Canadian and US pellet suppliers. Drax’s values range from 12.5 to 38.18, with the majority being lower than the 36.6 level that the RED criteria would (eventually) impose (and then only on new plants – which is ridiculous – as this will never bring about any change in the pellet industry if it doesn’t apply to fuel burned in plants of all vintages).

If policymakers believe that the new levels proposed in the RED for GHG “HPT” emissions are rigorous, these data should convince them otherwise.  
The RED provides lucrative rewards for biomass – these should be reserved for best practices, not business-as-usual. 

It’s just another piece of evidence concerning the extraordinary role the biomass and wood-pellet industry played in writing these weak standards.

The so-called GHG criteria for biomass are an industry-written fraud