Common biomass sustainability framework: consultation

Delivery of the government’s clean energy mission risks being undermined by the continued use of biomass in the power sector, due to its high emissions, import reliance and cost. The proposed common biomass sustainability framework does not sufficiently address these concerns. 

Recommendation 1

Biomass generation is incompatible with UK carbon budgets. The role of large-scale biomass power in the UK should be limited, building on existing plans to cap generation at Drax and Lynemouth between 2027-31. Ember recommends that additional measures be introduced when the agreed Heads of Terms for these plants conclude in March 2031, to cap the annual load factor eligible for subsidy and reduce biomass generation further. 

Recommendation 2

Imported biomass is a risk to UK energy independence and exposes households to price volatility. The government should require a shift to domestic sourcing for large-scale biomass power stations, with capped generation making it more realistic for sourcing requirements to be met with UK-sourced feedstock. This will also ensure biomass feedstock meets sustainability standards, in line with recommendations from the Climate Change Committee and Dr Alan Whitehead on the role of large-scale biomass in the power sector. 

Recommendation 3

The government should continue to pursue and scale-up alternative low-carbon forms of dispatchable and flexible power – such as wind, solar and batteries – to prevent an increase in biomass generation post-2031. This is the surest way to ensure UK power is genuinely homegrown and low-carbon.

Summary

The common biomass sustainability framework consultation explains that biomass is currently expected to play an important role in delivering net zero in the UK. However, burning biomass for power generation releases more carbon than burning coal, making it incompatible with carbon budgets. This fundamental carbon accounting issue will remain, regardless of sustainability sourcing requirements. Ember’s key recommendation is to minimise the future role of large-scale biomass power in the UK, building on existing plans to cap generation at Drax and Lynemouth.

Biomass for power generation is incompatible with carbon budgets

Biomass power generation is currently “zero-rated” in the energy sector due to a United Nations Framework Convention on Climate Change (UNFCCC) accounting convention designed to avoid double counting emissions between the energy and land use sectors. The UK’s sustainability framework assumes that if standards are met, biomass power can be assumed to be carbon neutral, as sourced feedstock is replaced by new growth. This means that the annual emissions of Drax (12.7MtCO2 between 2020-2024, on average) and Lynemouth are not accounted for in UK carbon budgets, and the generators are eligible for low carbon subsidies.

However, the scientific debate increasingly suggests that burning biomass could actually be contributing to climate change, since burning woody biomass emits more carbon than coal. The carbon payback period for woody biomass can also be significant, as it can take decades or even centuries for regrowth to sequester the same volume of carbon originally stored. Bodies including the European Academies Science Advisory Council have cautioned against using woody biomass for power for this reason.

Biomass power generators are among the UK’s biggest emitters

Ember analysis has found that Drax power station has been the UK’s single biggest emitter since 2016. Drax emitted more carbon than the six largest gas power plants combined in 2024. Lynemouth was also the twelfth-biggest emitter in the same year. Drax is likely to remain the UK’s largest emitter out to 2030, despite a confirmed generation cap that will come into effect from 2027.

The underlying fundamentals of the carbon released from burning wood mean that large-scale biomass power stations will remain high emitters, regardless of the new sustainability sourcing requirements. It is therefore essential to limit the role of biomass power in the UK and invest in scaling up genuinely low-carbon alternatives, such as wind, solar and batteries, as well as clean technologies that provide grid stability services.

Biomass sourcing risks ecological harm

Furthermore, BBC investigations have shown examples of rare old growth forests being cut down and turned into wood pellets for Drax power station, increasing the potential ecological harm inflicted. While ecological sustainability and individual company conduct are outside the remit of this consultation response, existing voluntary monitoring and verification schemes may be inadequate to address the climate and environmental risks associated with forest harvesting, especially outside of the UK.

Summary

The UK Government has a mission to deliver a clean power system by 2030. However, continued use of biomass in the power sector risks undermining this mission. This is because large-scale biomass power generation is highly dependent on imports, risking energy independence and future price volatility. The new common biomass sustainability framework and recently negotiated Contracts for Difference for Drax and Lynemouth are missed opportunities to tackle import-reliance for biomass power, by requiring a managed switch to domestic sourcing.

Power biomass risks UK energy independence

Efforts to reduce imports through the clean power mission risk being undermined. This is due to bioenergy’s high dependence on imported feedstock for power – including among government-supported schemes. 

The two largest biomass power stations in the UK – Drax and Lynemouth – are both highly dependent on imported woody biomass feedstock. The majority of their feedstock is currently sourced in the US and Canada, where Drax operates 17 pellet mills. Just 0.6% of the 9 million tonnes of fibre sourced by Drax in 2024 were sourced within the UK. While the UK government is investing in homegrown energy with wind and solar, biomass is likely to remain highly dependent on imported fuel in the near- to medium-term.

Imported biomass is linked to price volatility

This dependence on imported biomass risks UK energy security and price volatility because biomass generators are exposed to knock-on price volatility from other markets. As the price of gas jumped during the 2021-23 energy crisis, other imported fuels (including wood pellets) also saw price shocks. As long as the UK is reliant on imported fuel for unabated biomass power generation, the risk of price shocks remains high.

Sustainability monitoring is more challenging for imported feedstock

The Climate Change Committee has been explicit that, ‘the UK should also shift from relying primarily on imported biomass for power generation to developing domestic supplies as much as possible.’ This is because it will be challenging to ensure imported biomass meets sustainability standards, due to differences in regulatory oversight around land use and forest management in other countries. Dr Alan Whitehead’s Independent Review of Greenhouse Gas Removals reached the same conclusion and recommendation with regards to large-scale biomass power plants fitted with carbon capture and storage technology (BECCS).

New biomass framework and CfD contracts are missed opportunities to require switch to domestic fuel

The new common biomass sustainability framework and the recently agreed Heads of Terms for CfD support for Drax and Lynemouth are missed opportunities to require a switch to domestic feedstock in biomass power generation. 

It is not currently a realistic proposal to use sustainably-sourced UK feedstock for biomass power without large reductions in consumption. In 2024, Drax biomass power station generated 14.9 TWh and sourced 9 million tonnes of fibre, of which 97% was woody biomass. This is close to the total volume of roundwood removals (i.e. harvested) in the UK in the same year, of 10.7 million tonnes. This means that roundwood removals in the UK would need to near-double to absorb a domestic woody biomass feedstock supply chain that meets Drax’s 2024 sourcing level. 

However, between 2027 and 2031, Drax and Lynemouth will enter new government support agreements that cap the annual load factor eligible for subsidy at 27%. Ember analysis estimates this will see Drax’s annual generation fall from 15.4 TWh in 2025 to around 5.1-6.3 TWh – unless it chooses to sell power outside of the new Contract for Difference. This will also reduce the total volume of biomass feedstock needed for power generation. 

The new Heads of Terms, along with the new common biomass sustainability framework, could therefore have been used as a mechanism to require a staggered increase in domestic sourcing for biomass power in line with a demand level that could be more realistically sourced within the UK. Future revisions to the framework alongside any agreed government-support for large-scale biomass generation or power-BECCS project beyond 2031 should include a requirement that accelerates this sourcing shift.

Supporting materials

Downloads