Willow for Wales Helyg i Gymru

Thank you for the opportunity to comment on this document. I am replying in my role at the Institute of Grassland and Environmental Research as Head of Non-Forage Crops Team and co-ordinator of the ERDF Objective 1 project on ‘The development of sustainable heat and power fuelled by biomass from short rotation coppice in Wales’ (Helyg I Gymru – Willow for Wales) funded by the European Regional Development Fund (ERDF) Objective 1 through the Welsh European Funding Office on behalf of the Welsh Assembly Government and by the Welsh Development Agency. The project also involves Cardiff University, the Forestry Commission, and EGNI, Mid-Wales Energy Agency, RWE npower, Renewable Energy Ltd, SW Seed Ltd and Agrobransle.

The project co-ordinator and project personel interact with farmers and others such as medium and large power generators and are therefore well placed to understand the use of renewable energy from biomass in Wales.

It should also be noted that apart from the project mentioned above, I am also responsible for Defra’s investment of over £220K per annum in IGER and Plant Research International, Netherlands, to make necessary genetic improvements in Miscanthus, a productive energy grass that can be harvested annually.

I only wish to comment on the section of the TAN 8 document headed ‘Woodfuel’. I have separately contributed to responses co-ordinated by the Ceredigion Energy Forum and by workshops organised as part of the Mid-Wales Energy Agency official launch event.

The points that I wish to make are as follows:

1. There is over-emphasis on woodfuel as compared with dedicated energy crops. Both should be considered under the heading of Biomass (the more generic and widely used term). Woodfuel and dedicated energy crops are complementary in that both will be needed to fulfil continuous demand and be competitive rather than have a single source of supply. Wales needs to develop its own distinctive policies rather than copying the Upper Austrian model. Upper Austria is a heavily forested area in which log fuel has been traditional; the step from logs to community-based wood pellet burners is a rather easier one to make compared with the barriers that need to be (and can be) overcome in Wales.

2. Growing energy crops will bring benefits to rural development as well as reducing carbon emissions. Wales needs to encourage and support a range of renewable energy technologies to support its renewable energy targets. The brief and not very clear reference to SRC in the draft TAN 8 does not offer a very clear or accurate description of the viability or SRC, and appears to write it off.

The statement in para 49 that short-rotation coppice of willow and poplar has long been mooted but has suffered unfortunate set-backs should be deleted. If it refers to the closure of the Arbre project in Yorkshire, this was a good example of how not to develop a fuel supply chain i.e. farmers should not be expected to grow energy crop commercially for one plant in which the technology (in terms of the technical specification of woodchips and large scale gasification) was unproven. In fact the SRC planted for that project is now being used in co-firing at the Drax Power Station. Drax Power are now advertising for producers of SRC, forestry, Miscanthus and rape grown within 50 miles of Drax power station to supply them through long term contracts. There are similar demands for biomass in the RWE npower plant at Aberthaw.

These facts would be useful background that could be included in TAN 8.

3. It should be borne in mind that biomass, whether from wood wastes or from energy crops) is not a fully developed supply chain. There are opportunities for improving the economics by decreasing costs (through lower establishment costs, higher yielding cultivars), adding value (through pre-extractions and using the ash in building blocks or in silica production), or through hydrothermal or other processing. Short rotation coppice is an extremely useful means of using treated sewage sludge in Wales (estimated 3.76m t per annum in Wales).

It is clear that for energy crops in Wales, raising the Woodland Grant (which is administered by the Forestry Commission in Wales on behalf of WAG) to the level paid by Defra in England is essential to start-up SRC and the growing of energy grasses such as Miscanthus until the economies of scale and local supply within competitive markets bring the costs of machinery and establishment down (eg through cheaper willow cuttings).

Helyg i Gymru – Willow for Wales is taking a stepwise approach to the development of heat and power from short rotation coppice in Wales. It will help bring about change through education and by allowing farmers to ‘see with their own eyes’.

It is complementary to WEBS (the Woodland Energy Business) mentioned in TAN 8, as one deals with the supply and the other the utilisation of biomass. It is important that all those involved in the development of the biomass industry (participants of the project, those in the supply chain, planners and public bodies, and the Welsh Assembly Government) all play their part in supporting biomass crops. WAG is urged to adopt such positive approaches as part of TAN 8.

C. THE SUSTAINABLE DEVELOPMENT ACTION PLAN OF THE WELSH ASSEMBLY GOVERNMENT 2004-2007 MARCH 2004

IGER submission
We applaud the wide and inclusive definition of sustainable development in terms of being about wealth creation and tackling poverty and injustice as much as being an environmental issue. The document quite rightly, places sustainable development in Wales in an international context. We wish to comment specifically on Wales’ contribution, through substantially increasing renewable energy, to reducing greenhouse gas emissions that are driving climate change. As the document indicates, while we have led the way in wind energy in the 1990s, our recent record on increasing renewable energy generation is modest. The section ‘Living Differently’ emphasises Wales’ tremendous natural potential for renewable and alternative energy and proposes to take this forward by driving our clean energy policies through a clean energy action plan. Previous studies (eg AEAT report 2001) have shown that this will doubtless require a mix of technologies including biomass.

Our specific comments relate to the role of biomass and to what needs to be done in order to ensure good progress.

The Farm Woodland Development of Biomass Action Plan, to which IGER contributed and which has been adopted in plenary by the Welsh Assembly, identified that biomass is one of the main sources of renewable energy identified as having the potential to contribute towards national targets. Wales could source 100 MW of electricity from biomass by 2010 (AEAT report 2001). This would have major benefits for Welsh farm incomes and safeguarding jobs and health communities. Employment opportunities will be created inside and outside agriculture – for instance, in the harvesting machinery, planting material suppliers, haulage, plumbing and equipment sectors.

There has been limited development of the biomass industry in Wales compared to many European countries.

IGER, Cardiff University, Forest Research, Innogy, EGNI, Powys Energy Agency, SW Seed Ltd and Agrobransle (via Renewable Fuels Ltd) have received funding from EU structural funds, the Welsh Assembly Government and the Welsh Development Agency to conduct a demonstration project on ‘The Development of Sustainable Heat and Power fuelled by Biomass from Short Rotation Coppice in Wales’. This will complement the Woodland Business Energy Scheme. In locating farms for growing 5ha demonstration blocks, the project has identified a number of barriers affecting the willingness of farmers to participate.

1. A major concern of farmers has been whether growing short-rotation coppice will affect cross-compliance and the single farm payment. A number of farms have dropped out because of uncertainty about this issue. A clear statement is needed that SRC will not affect the single farm payment and cross-compliance. Specifically the Single Farm Payment is conditional upon cross-compliance with environmental, food safety, animal health and welfare, as well as maintenance of the farm in good agricultural and environmental condition.

Since the planting of SRC is regulated by the Forestry Commission, farmers are concerned that it would decrease the land eligible for payment or worse still, affect the whole farm payment.

There are a number of indications that this is not an issue. For instance, the relevant EC regulation laying down basic rules that must be followed by member states (EC No 1782/2003 of 9 September, 2003) indicates that support is given to energy crops as defined by their products and fast-growing species cultivated in the short-term but that support is not given to permanent crops. Good agricultural and environmental condition issues would seem to favour the maintenance of pasture and other features, but one would think that if arable crops are allowed, so must SRC.

A clear statement is needed to indicate that short-rotation coppice will affect cross-compliance and the single farm payment.

2. Grant aids which are needed to kick-start the growing of SRC are less than those available in England. A grant of £600 per hectare compared to £1000 per hectare in England for SRC and £920 per hectare for Miscanthus is a major limitation to uptake in Wales. These grants should be reviewable and of finite life – in due course, the cost of planting will fall dramatically as planting machinery and cuttings become available locally. Noting that the Wood Energy Business scheme supports infrastructure and equipment, it is important that we support all parts of the supply chain if SRC is to be successful. Biomass from energy crops complements that from forestry.

3. We must overcome production inertia and unwillingness to recognise change. Farmers and others currently compare the returns from SRC to the returns from subsidised sheep without recognising that subsidies will in due course diminish and that the demand for raw materials to produce renewable energy is likely to increase, as it has done in Germany and Sweden, with positive effects on price.

The demonstration project will help bring about change through education and allowing farmers to ‘see with their own eyes’. But it is important that all those involved in the development of the biomass industry (participants of the project, those on the supply chain, public bodies, and the Welsh Assembly Government) all play their parts in making the supply chain work.