11 April 2023

NGO Joint Statement

Co-firing of Biomass in Coal Plants or Conversion of Coal Power Plants toDedicated Biomass Power Plants is Greenwashing

Biomass accelerates climate change and destroys forest ecosystems

In Japan, the co-firing of biomass in coal power plants and conversion of coal-fired power
plants to biomass are currently taking place at a rapid pace. Already 31 coal-fired units, orabout half of the coal-fired power plants of major power utilities, are co-firing withbiomass.1 At least 40 of the renewable energy feed-in-tariff (FIT) approved biomass power
projects are at coal power plants, and 35 of these plants are designated as “inefficient”(sub-critical or super-critical).2 Biomass co-firing for industrial self-generation at in-housecoal-fired power plants and other power plants is also part of Japanʼs “GreenTransformation” (GX) policy.3

Wood pellets are one of the primary biomass fuels used for biomass co-firing at coal plants.
With the increase in biomass power generation under the FIT program, imports of woodpellets have increased 61-fold over the past decade to approximately 4.41 million tons in
2022.4 As the power generation capacity of coal-fired power plants is generally much larger
than that of dedicated biomass power plants, further increases in wood pellet imports are
expected as biomass co-firing is promoted at coal-fired power plants.5 This increase indemand for wood pellets is nothing short of an additional burden on forests, whether
directly or indirectly.

The undersigned environmental NGOs working on climate change and forest issues,
oppose biomass co-firing and the conversion of coal power plants to dedicated biomasspower plants for the following reasons:1. Accelerates climate change1) Burning biomass emits CO2
Biomass power generation is thermal power generation, and the combustion of biomass
fuels emits large amounts of CO2 into the atmosphere. Even though the carbon emission
coefficient of wood is greater than that of coal,6 the Japanese government considers it
to be “carbon neutral” and does not account for CO2 emissions from combustion. 7
Moreover, when forests are cleared to produce biomass fuels, the carbon that theforests have stored in the trees and soil over a long period of time is released into theatmosphere. There is no guarantee that cleared forests will recover to their originalstate, and even if they do, it will take decades to centuries to completely restore theCO2 released into the atmosphere. In addition to this, CO2 derived from fossil fuel use
is generated at each stage of harvesting, processing, and transportation. Japan relies
on imports for most of its wood pellets,8 which emits large amounts of GHGs duringtransportation. To regard biomass power generation as “carbon neutral,” ignoring theCO2 emissions throughout its lifecycle, the years required for forests recovery and thepossibility that forests will not recover, is a great risk that will accelerate climate change.

2) Prolonging the life of coal-fired power stations
In order to meet the Paris Agreementʼs 1.5 ℃ target, OECD countries need to phase out
coal-fired power by 2030. However, Japanʼs Ministry of Economy, Trade and Industry(METI) uses a formula that deducts the biomass inputs for co-firing from coal inputs,
which enables inefficient coal power plants to appear efficient and thereby extend theirlives.9An expert has estimated that the CO2 emission coefficient for a coal-fired power plant
without biomass co-firing is 0.84kg-CO2/kWh, while it increases to 0.85kg-CO2/kWh
when a coal-fired plant with 38% power generation efficiency co-fires 5% biomass.10 In
addition, the conversion or retrofitting of coal-fired power plants to dedicated biomass
combustion is being considered,11 in which case the CO2 emission coefficient would be
1.03 kg-CO2/kWh.

2. Destroys forest ecosystems
Most of the woody biomass fuel used for large-scale biomass power generation as wellas biomass co-firing coal-fired power generation is imported from Southeast Asia andNorth America. 12 Future attempts to supply large quantities of biomass fuels will
increase pressure for deforestation. The impacts caused by biomass fuels production
on ecosystems, such as deforestation, forest degradation, and biodiversity loss, isimmeasurable. Cases have been reported of natural forests, including primary forests
in North America, being cleared to produce woody biomass fuels. It is not easy for
destroyed forest ecosystems to restore their function, and it is impossible for them torecover to a qualitatively equivalent ecosystem. The guidelines for developing projectplans under the FIT subsidy program do not have clear standards for the sustainabilityof woody biomass fuels, and any such standards are not applied to non-FIT biomass
power generation. Biomass power generation threatens ecosystems and biodiversity,and undermines the very concept of renewable energy, which is intended to reduce theburden on the environment.

Hereby, we urge the Japanese government to take following measures:• Achieve a coal exit as soon as possible, regardless of biomass co-firing.
• Do not support biomass co-firing or dedicated biomass power plants.
• Exclude biomass power generation that uses fuels other than waste from thedefinition of renewable energy. and do not provide subsidies or other support.
• Require that CO2 emissions from biomass combustion be accounted for at thepower plant level.
• Count CO2 emissions from biomass combustion by the consuming country andincorporate this into their carbon accounting.

Signatories (90 organizations)
Friends of the Earth JapanJapanGreenpeace JapanJapan

HUTAN GroupJapanKiko NetworkJapan

Global Environmental Forum

Japan

Japan Tropical Forest Action NetworkJapan

Istitute for Sustainable Energy Policies

Japan

Japan Center for a Sustainable Environment and Society

Japan

Climate Action Network Japan（CAN-Japan）

Japan

Citizens Alliance for Saving the Atmosphere and the Earth (CASA)Japan

A SEED JAPANJapan

350.org Japan

Japan

Fridays For Future Sendai

Japan

Forests, Climate and Biomass Working Group - Environmental Paper Network International
Mighty EarthUSA

350 Eugene

USA

350 Triangle

USA

AbibiNsroma Foundation

Ghana

Australian Forests and Climate Alliance

Australia

Biofuelwatch

UK/USABlue Dalian

China

Castlemaine Residents Against Biomass

Australia

Center for Biological DiversityUSACentral California Environmental Justice NetworkUSA

Coast Range Association

USA

Coastal Plain Conservation Group

USA

Comite Schone Lucht | Clean Air Committee NLNetherlands

Community Partners Across the South

USA

Conservation North

CanadaConsumers' Association of Penang

Malaysia

De Bomenbond

Netherlands

De Klimaatcoalitie

Netherlands

Doctors and Scientists Against Wood Smoke Pollution (DSAWSP)

USA

Dogwood Alliance

USA

Earth Action, Inc.

USA

Earth Neighborhood Productions

USA

EARTHDAY.ORG

USA

EDSP ECO

Netherlands

Endangered Species Coalition

USA

Environment East Gippsland inc

Australia

EPIC- Environmental Protection Information Center

USA

Federatie tegen Biomassacentrales

Netherlands

FernEUFIAN Sri Lanka

Sri Lanka

Forest Watch Indonesia

Indonesia

Forum Ökologie & Papier

Germany

Friends of the Clearwater

USA

Friends of the Earth USUSAGippsland Environment GroupAustralia

Global Justice Ecology ProjectUSA

Great Old Broads for Wilderness, Cascade-Volcanoes Chapter

United States

Green Cove Defense Committee

USA

Green Longjiang

China

Green Snohomish

USA

Himalaya Niti Abhiyan

India

Hunter Knitting Nannas

Australia

Independent Forestry Monitoring Network (JPIK)

Indonesia

John Muir Project

USA

Kaoem TelapakIndonesia

Kitsap Environmental Coalition

USA

Landelijk Netwerk Bossen- en Bomenbescherming

Netherlands

Leefmilieu

Netherlands

Maíra Institute

BrazilNatural Resources Defense Council

USA

Nature Nova Scotia

CanadaNC Climate Solutions Coalition

United States

No Electricity from Forests

Australia

Ole Siosiomaga Society Incorporated (OLSSI)

Samoa

PakaidPakistan

Partnership for Policy Integrity

USA

Pivot Point

USAProfundo

Netherlands

River coalition

Czech Republic

Sahabat Alam Malaysia (Friends of the Earth)

Malaysia

Save Estonia's Forests (Päästame Eesti Metsad)

Estonia

Scholar Tree Alliance

China

Snow Alliance

China

Solutions for Our ClimateSouth Korea

South East Region Conservation Alliance (SERCA)

Australia

Southern Environmental Law Center

USA

Spruill Farm Conservation ProjectUSASouthern Forests Conservation Coalition

USAStand.earth

CanadaStanding Trees

USA

Sunflower Alliance

USAThe Corner House

UKThurston Climate Action TeamUSA

Trend AsiaIndonesia

Utah Physicians for a Healthy Environment

USA

Wild Nature InstituteUSA

WOLF Forest protection movement

Slovakia

1

The Ministry of Economy, Trade and Industry (METI), Outline of Interim Report of the Working
Group to Study Coal-fired Power Plants, p.27,<https://www.meti.go.jp/shingikai/enecho/denryoku_gas/denryoku_gas/sekitan_karyoku_wg/20210423_report.html>
2Prepared by FoE Japan based on the data from the website of the Agency for Natural Resources
and Energy and the database of Japan Beyond Coal (See Appendix 1)
3
METI, ʻEmbodiment of Policy Initiatives to Realise GXʼ, p.29, p.31, p.33,<https://www.meti.go.jp/shingikai/sankoshin/sangyo_gijutsu/green_transformation/pdf/011_01_00.pdf>
4

The Ministry of Finance, ʻTrade Statisticsʼ (See Appendix 2)
J-Power, a major Japanese coal-fired power utility company, and Enviva, a world leading woodpellets manufacturing company in the U.S., signed a memorandum of understanding to jointly
establish a system producing and supplying 5 million tons of wood pellets annually.
<https://www.jpower.co.jp/english/news_release/pdf/news211117e.pdf>
6Center for Global Environmental Research, National Greenhouse Gas Inventory Report of JAPAN2022, p.3-16,<https://www.nies.go.jp/gio/archive/nir/jqjm10000017uzyw-att/NIR-JPN-2022v3.0_GIOweb.pdf>
7
The GHG Protocol and SBTi, which are the global standard for corporate GHG emissions
calculation and reporting methods, require that CO2 emissions from biomass used for energy tobe reported as corporate emissions.
i) World Business Council for Sustainable Development, World Resources Institute, ʻ The
Greenhouse Gas Protocol -A Corporate Accounting and Reporting Standard, Revised Editionʼ ,p.63, <https://ghgprotocol.org/sites/default/files/standards/ghg-protocol-revised.pdf>ii) Science Based Targets Initiative, SBTI corporate net zero standards, p.24,
5<https://www.env.go.jp/earth/ondanka/supply_chain/gvc/files/tools/Net-Zero-Standard_v1.0_jp.pdf>
8

The Ministry of Finance, ʻTrade Statisticsʼ and the Ministry of Agriculture, Forestry and Fisheries,
ʻSurvey of Production Statistics on Special Forest Productsʼ (See Appendix 3)
9METI, Outline of Interim Report of the Working Group to Study Coal-fired Power Plants, p.1,
<https://www.meti.go.jp/shingikai/enecho/denryoku_gas/denryoku_gas/sekitan_karyoku_wg/20210423_report.html>
10

Global Environmental Forum, Reference ʻCO2 emissions from biomass power plantsʼ provided atthe webinar ʻIn the shadow of “Carbon Neutral” -CO2 emissions from biomass power generationand coal co-firingʼ, p.6,
<https://www.gef.or.jp/wpcontent/uploads/2022/12/bbd4731754105f73e348ee35cca7119c.pdf>
11
METI, Reference 4 ʻSecuring Investment in Power Sourcesʼ, p.28,<https://www.meti.go.jp/shingikai/enecho/denryoku_gas/denryoku_gas/seido_kento/061.html>
12
The amount of waste biomass in Japan is limited and most of it has already been used.