“The REA welcomes the fact that 3Keel’s report – ‘Biomass for energy: A framework for assessing the sustainability of domestic feedstocks’ – recognises the ongoing role for biomass in decarbonisation energy and the importance of developing domestic feedstock supplies. The Climate Change Committee (CCC), within their 2020 land use report, has made clear that we will need to be planting up to 23,000 Ha of bioenergy crops by 2035 to sustainably meet our low carbon energy needs.

“However, the report is selective in its representation of some innovative bioenergy feedstocks, such as perennial energy crops and short rotation forestry, which they wrongly label as of ‘high risk’.

“The report focuses on land and resource competition risk, while omitting consideration of existing sustainable agricultural practices that mitigates these risks by focusing growth on marginal land. The report also omits to look at the sizable amount of research that demonstrates the environmental benefits these crops provide when they are done correctly. This includes biodiversity, carbon fixing in soils, flood mitigation and pollination services.

“Rather than moving to restrict use of these crops, the Government should be developing a pathfinder program aligned to delivering the quantity of crops the CCC suggest are needed. This programme can be regionally specific to ensure the right crops are being grown on the right land and the environmental benefits are being optimised. This will both ensure bioenergy crops are done correctly, mitigate any risks and deliver rural jobs by creating a viable business model for landowners and farmers.

“The REA would welcome the opportunity for RSPB and 3Keel to talk directly with the industry to understand existing agricultural practices, so that their framework better reflects the reality of these energy crops.”