- What is a bioenergy strategy useful for?
- What does the process of devising and agreeing a bioenergy strategy achieve?
How a bioenergy strategy is used
A completed bioenergy strategy is a tool used by people constructing new policies. A bioenergy strategy rules out some bioenergy technologies and declares different priorities for different feedstocks. This is extremely useful as there is a much reduced range of possibilities to be examined for each new policy and many prior arguments can be treated as settled. This speeds up policy making immensely.
If the bioenergy strategy proposals are clear and are widely agreed, then the public, local authorities and commercial organisations can make outline plans in advance of detailed legislation. This speeds up adoption of the policies when they arrive and may even make some legislation entirely unnecessary.
Bioenergy issues always cross government departmental boundaries, so a strategy which allocates responsibilities clearly between departments is vital to prevent sterile and interminable disagreements between officials. These disagreements are hidden from public view and can never be resolved quickly, however unimportant they really are.
Creating and agreeing a bioenergy strategy
The UK has three bioenergy strategy documents:
and the first two are now severely out of date. Each of these was published alongside technical papers, models and annexes which described the issues in substantially more depth and breadth. Since 2012 there has been a quite extraordinary amount of work globally and in the UK, and special mention must be made of the ETI bioenergy report repository which is now public.
These are two different types of strategy: the CCC reports are open reviews which propose specific policy options but are somewhat in the style of an academic consolidated review paper. The government strategy is a “closing down” rather than an “opening up” document, because that is what is necessary for an authoritative statement about choices and departmental responsibilities. Government strategies will generally also include ad hoc rules because of interactions with non-energy and non-climate policies. A common example (since 2012) is forbidding the use of human food crops for energy (whilst still allowing the use of livestock feed crops).
The later 2018 CCC report does have a few “closing down” elements, e.g. section 3.7 on sub-optimal uses of biomass: “These end-uses should not be supported by Government”.
Counterfactuals
Any bioenergy strategy has to cover much more than bioenergy. This becomes obvious as soon as one looks at the key decision options to be decided but this means that any group attempting to produce such a strategy can run into the difficulty of being accused of extending its work beyond its remit. So any body preparing to produce a bioenergy strategy would be well advised to prepare for this in advance.
A strategy recommendation that some bio-resource is to be used for energy can only be made if all the alternative non-energy uses for that same feedstock (and their climate implications) are understood. Thus the methane emissions from the farming practice of using open ponds for farmyard slurries become relevant, because those emissions would be reduced if the slurry was instead carefully used for anaerobic digestion and biogas production.
A strategy recommendation must also consider what alternative fuel is being displaced by the bioenergy. Thus the case for using biomethane to fuel trucks can be very different if the fuel being displaced is (fossil) diesel rather than compressed (fossil) natural gas. Since 2016 we have a government policy of removing all coal-fired electricity generation so one can no longer propose that biomass burned after 2025 replaces coal. [Sometimes the displacement is explicit: in the recent contract for difference auction, offshore wind was competition for the same budget as biomass-CHP. But one suspects that the cost-benefit analysis for the proposed biomass-CHP plants did not envisage wind as the “fuel” being displaced, even though that was the case.]
In those examples of slurries and trucks there is clear encroachment on the area normally considered to be entirely within the purvey of the ministries of agriculture (slurries) or transport (trucks). This is especially contentious when the climate benefit of using that resource for bioenergy can be significantly undermined by non-energy changes in the practice of the alternative use: thus covering slurry ponds is a good thing, but would reduce the optimal subsidy to be paid for biogas.
Discussion and agreement
The activities involved in creating a review-type bioenergy strategy require a wide-ranging survey of technical and academic knowledge and can be carried out largely in public. This public discussion tests and verifies the assumptions and models thus improving their quality and helping to understand the limits of their applicability. Whereas creating a government strategy requires negotiation between representatives of distinct policy authorities: private negotiations which require access to previously-agreed data and assumptions, but where it is more important that those assumptions and models are agreed than that they are correct. [New measurements and technologies will revise the data and assumptions, thus undermining the negotiated agreements, which is an incentive to keep those agreed models and data private. But the UK government actually published as much as it could in 2012 in a technical annex, but the proprietary AUB model itself was published only in report form.]
Pitfalls
The 2012 Bioenergy Strategy defined four basic principles which are almost unarguably useful (at least the first three are, the fourth is just an admission that the world changes and any strategy has a finite life):
- Policies that support bioenergy should deliver genuine carbon reductions that help meet UK carbon emissions objectives to 2050 and beyond…
- Support for bioenergy should make a cost effective contribution to UK carbon emission objectives in the context of overall energy goals…
- Support for bioenergy should aim to maximise the overall benefits and minimise costs (quantifiable and non-quantifiable) across the economy…
- At regular intervals and when policies promote significant additional demand for bioenergy in the UK, beyond that envisaged by current use, policy makers should assess and respond to the impacts of this increased deployment…
But then almost all the specific recommendations in the strategy were based on the results of one proprietary model: the Appropriate Uses of Bioenergy (AUB) model by Redpoint. The model was commissioned (I believe) by government but copyright remained with Redpoint who declined to publish it (or to publish the specific tables of cost and performance data on which it depended). Thus no one in the public domain could tell when any new published report invalidated the assumptions behind an important strategy recommendation or not. Thus the strategy recommendations were almost instantly out of date as they could not be supported or challenged.
It is particularly frustrating that the strategy did not make the logical deductions from principles 2 and 3, deductions which would have been useful – if they had been made explicit – when new data and new applications arose. This would have helped future-proof it to some extent and to improve its coverage to those areas on which it was silent:
The combination of cost-effectiveness with a “whole economy” scope means that for any use of bioenergy, it is the cost of the alternative way of supplying that demand in a similarly low carbon way which needs to be considered.
- Thus when using biomethane to power trucks, the comparative lowest cost would be using biodiesel instead.
- But when using biomethane injected into gas mains to heat poorly-insulated houses, the comparative lowest cost would be insulation plus heat-pumps (or possibly mass conversion to hydrogen).
Thus the subsidy level for each use of biomethane should be scaled according to the alternative (and not the fuel displaced, which is irrelevant according to the principles). Since biodiesel is fairly cheap, the strategic decision should be to put all biomethane into the gas grid, and not to put it into trucks. But if biodiesel is ruled to be a bad thing because of land-use change effects, then all biomethane should go into trucks as there is no sensible alternative for heavy goods vehicles.
But that example illustrates a systemic failure of the 2012 bioenergy strategy principles: although it projected economy changes to 2050, it did not suggest that the appropriate uses of bioenergy should vary with the date. As we know from recent modelling for Carbon Budget 5, it is actually cheaper for the economy averaged over time if conversion of heavy goods transport is left until much later, and that all bioenergy (including biomethane) is used with carbon-capture and storage (CCS) to buy time. We now know that CCS changes everything in that bioenergy strategies with- and without-CCS are radically different (as illustrated by the ETI BVCM work).
[Addendum: The AUB model is very impressive: it is a model of the whole UK energy system including transport (but not agriculture or forestry) and uses the AIMMS underlying software (as does ESME from ETI). Creating it was no doubt a very significant piece of work and it is a great shame that the dataset on which it was based has not been made public. See here for a list of models of this type.]
[Addendum: This post updated 4 December 2021 to include a reference to the later 2018 CCC report “Biomass in a low carbon economy” and supporting research.]
A footnote on regulation
The emphasis on the utility of a bioenergy strategy as a tool to help “regulation construction” may seem bizarre to many people. But for anyone who has had to develop a specific policy to support a policy goal it will seem entirely natural.
Suppose that there is a policy goal to help the “ice-cream poor” and a minister has made a public statement that we must eliminate “ice-cream poverty”. Those charged with constructing policy options have to look at the following options:
- Should this be an obligation on ice-cream producers? An obligation to give away a proportion of their production (perhaps controlled by some kind of certificate trading like the renewables obligation)?
- Or should this be an incentive to voluntary action by subsidy, either an incentive to produce (similar to a feed-in tariff), or an incentive to consume (similar to a boiler replacement subsidy), or an incentive to both produce and consume (similar to the renewable heat incentive)?
- whatever is chosen, it should not increase the price of ice-cream generally as that will create more “ice-cream poor”: which is usually an argument that the cost should come from general taxation and not just by moving funds within the ice-cream industry.
- also any policy must not be easily “gamed” by anyone who can obey the letter but not the intent, it will not be liable to any fraud, and it will not accidentally support another industry which is intended to be phased out by another policy;
- in an ideal world, the policy will reward the virtuous and penalise the unworthy (though the reality is that while political speeches always claim this, the reality is that effective policies mostly work by bribing the unworthy, and any payments to people who “would have done it anyway” are termed “deadweight”),
- the policy will induce society or technical changes which will lead to its own obsolescence and will not create a new industry entirely dependent on subsidy which will then lobby loudly and determinedly for its own continued existence.
Thus the earmarking of all bioliquids to be primarily for transport in a bioenergy strategy has the effect that there will be no policy to subsidise adding a small percentage of bio-oils to heating oil: a market which is very dispersed across the UK, is hard to police, which has a history of fraud, and where fossil oil-fired heating is intended to be replaced by heat-pumps, solar-thermal and biomass boilers supported by the renewable heat incentive. [Unfortunately this is very hard luck for any companies valiantly trying to produce non-transport liquid biofuels, but at least the situation is (eventually) clear and unambiguous. Any bioenergy strategy will not be perfect. There will always be useful and valuable special cases which are pointlessly and unfairly eliminated.]