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Kenneth Richter Consultancy

Self-employed consultant working for environmental NGOs.

Lobbying Activity

Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

Please accept this feedback on the implementing regulation for the forest biomass sustainability criteria from the Natural Resources Defense Council (NRDC). The current so called “sustainability criteria” for forest biomass in the RED do not ensure that bioenergy from forest wood results in net emissions reduction over climate relevant time scales, nor do they ensure that sourcing practices that harm forest biodiversity are no longer supported through billions of Euros of member states' subsidies. The majority of the wood being burnt in the EU is sourced in countries which have all the laws required in Article 3 and 5 and few have infringements proceedings against them, since these are a last resort for the EU and happen very rarely. Therefore, the vast majority of wood that is currently being burnt in the EU would automatically be considered compliant with these “sustainability criteria.” Destructive harvesting practices to feed bioenergy plants would continue according to these criteria, because unfortunately, these destructive practices—such as clear-cutting a forest for biomass fuel—are considered legal in the country where they take place. For this reason, compliance under Article 29(6) and (7) does not ensure that the forest biomass is sustainable. The criteria do not prevent sourcing forest biomass from lands with high carbon stock or put any types of forests off-limits for harvesting except “protected” forests, which does not include, for instance, the EU’s Natura2000 forests where logging is permitted. Whereas the criteria for agricultural biomass contain some moderate protections, the forest biomass criteria barely address the issue. A discussion of what forests should be classified as “biodiverse”—and therefore essentially off-limits—is restricted by the definition in Recital 97 to only those areas protected by national nature protection law and to “primary” (essentially undisturbed) forests. This definition excludes nearly all forests where harvesting for biomass occurs. The RED promotes use of biomass by treating it as “zero” emissions. However, as European Commission scientists and the Joint Research Centre have affirmed, we know that burning biomass emits more CO2 than fossil fuels per unit of final energy, and net emissions continue to exceed those from fossil fuels for decades to centuries. As the RED II GHG criteria exclude emissions from burning the biomass itself, they cannot help in assessing the actual atmospheric CO2 impact of burning forest biomass. Nor do the LULUCF criteria help ensure climate change mitigation. The LULUCF criteria broadly seek to ensure that forest harvesting does not exceed growth. This relies mostly on the concept of “sustainable” forest management and the idea that despite a forest stand having been degraded by logging for fuel, forests somewhere else are still growing and sequestering carbon, and this carbon uptake is assumed to instantaneously offset emissions from burning the biomass. But, treating sustainable harvesting as a proxy for carbon neutrality is misleading: it credits ongoing forest growth to offset emissions which does not constitute “increased” carbon uptake as the IPCC warns. The approach ignores the multiple decades required for forests to regrow after logging to offset emissions and to re-capture carbon to the level before harvesting. The RED II “sustainability” criteria do not deliver on the RED’s promise of “ensuring” that burning forest biomass reduces GHG emissions compared to fossil fuels. Accordingly, removing eligibility for forest biomass under the revision of the RED (RED III) would be the easiest and most efficient way to remove the incentives that are driving accelerated logging for fuel. This would help redirect billions of euros spent in member states subsidies on forest bioenergy toward real clean, green solutions, such as geothermal, wind and solar energy.
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Response to EU Forest Strategy

4 Dec 2020

The Natural Resources Defense Council (NRDC) welcomes the EU’s commitment to a policy framework that will protect forests as a critical part of its plans to mitigate both the climate and biodiversity crises. Natural and near-natural forests are vital for biodiversity, society and in our strategy to combat climate change. Experts agree that large-scale conservation of natural ecosystems, particularly forests, is an essential mitigation strategy in our effort to combat the twin threats of climate change and ecosystem collapse. Countries can both immediately reduce CO2 emissions by conserving and increasing carbon stores in terrestrial systems otherwise slated for destruction and protect ecosystems critical for safeguarding biodiversity. Unfortunately, forests are increasingly threatened by overexploitation in the EU and beyond. National Energy and Climate plans reveal that around a third of the 2005 EU carbon sink could be lost by 2030 - lost primarily from forests. An analysis by the Joint Research Centre (JRC) recently found that the total area of forests 'clear-cut' harvested in the EU in 2016-18 was 49% higher than in 2011-15, an increase that is partly blamed on the increase in demand for bioenergy (1), one of the fastest growing demands for wood from natural forests. European bioenergy consumption has already doubled since 2005 and a report by Sandbag predicts a large increase in the use of wood for electricity production, particularly in current and former coal power plants.(2) To meet this growing demand, the European Union is increasingly importing biomass in the form of wood pellets from overseas, in particular from North America. Independent media reporting has exposed the unsustainable logging practices used to source wood for pellets exported to Europe, including sourcing from clearcuts of mature hardwood forests in the Southeastern U.S. NGO investigations likewise spotlight the vast quantities of the most carbon-intensive types of biomass (whole trees and other large-diameter wood) entering the pellet industry’s supply chain. These sourcing practices not only liquidate carbon stocks, but damage biodiversity in a the North American coastal plain—a region designated as a global biodiversity hotspot. Similar sourcing practices are now also becoming common-place in EU countries such as the Baltic states, that are rapidly becoming major exporters of wood pellets to the rest of the European Union and where the last remaining old-growth forests, rich in rare species, are in notable decline.(3) This demand has been primarily driven by EU policies—in particular the Renewable Energy Directive and the resulting subsidies legislated by EU member states— that falsely assume all biomass is carbon neutral. This assumption has now been debunked by leading scientists, including the European Academies Science Advisory Council (EASAC). In line with the EU Green Deal and the EU Biodiversity Strategy for 2030, the post-2020 EU Forest Strategy must: • End support for the burning of forest-biomass for energy. • Recognise that the biodiversity extinction crisis and the climate breakdown are inseparable features and that forest protection offers a solution to both. • Emphasize more strictly protected forests, and better management of existing protected areas. • Recognize conservation/strict protection of forests as a legitimate management choice. • Guarantee stronger coordination between national legislation on all relevant fields including climate and biodiversity. • Reduce impacts from forestry in managed forests and re-naturalize production forests wherever possible. • Call for regular monitoring of the real impact of forestry on forest carbon and habitats across Europe. (1) https://ec.europa.eu/jrc/en/news/recent-surge-eu-forest-harvesting-according-jrc-study (2) EMBER, Playing with Fire, https://ember-climate.org/project/playing-with-fire/ (3) Hidden inside a wood pellet: Intensive logging https://elfond.ee/biomassreport
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

In the context of the European Union’s climate ambitions it is vital to ensure that policy measures actually lead to positive outcomes for the climate and money spent on such measures is used in the most efficient way. Raising the EU’s renewable energy targets will only result in climate benefits if the types of energy supported lead to significant GHG reductions. This is not the case for energy generated from burning forest biomass. Currently the emissions from burning biomass for bioenergy are assumed to be zero in the Renewable Energy Directive’s methodology. But recent science has shown that this is wrong. Per unit of energy, biomass-burning plants emit more carbon dioxide (CO2) from their smokestacks than coal-burning plants. And, in each wooded area, cutting older trees and replacing them with saplings reduces how much carbon is stored in that forest, even if trees are replanted right away. Together, this means it takes decades to more than a century for bioenergy to deliver any climate benefit. This is incompatible with the speed at which countries must cut emissions to meet Paris Agreement targets or limit global warming to 1.5o Celsius. The European Academies of Science (ESAC) recently warned that the carbon neutrality concept for bioenergy is a “gross misrepresentation of the atmosphere's CO2 balance” and that “current policies risk achieving the reverse of that intended – initially exacerbating rather than mitigating climate change” . In an open letter to the EU Parliament, more than 800 leading scientists called for urgent action to restrict support for forest bioenergy. The EU Commission’s own report titled, “Carbon impacts of biomass consumed in the EU,” also showed that EU energy scenarios that backed away from the use of bioenergy resulted in the lowest carbon emissions. In their report, “Abrupt increase in harvested forest area over Europe after 2015” , scientists from the EU’s Joint Research Centre (JRC) warned that the “increase in harvesting might endanger EU climate targets and might require additional emission reductions in other sectors.” Continued state-support for biomass energy can no longer be justified on climate or environmental grounds. However, a recent assessment of government subsidies and other forms of financial support offered to biomass energy producers in the European Union found that in 2017, the 15 member states most heavily reliant on bioenergy spent more than €6.5 billion to subsidise its production . The approach in the 2018 RED recast of amending “sustainability criteria” for bioenergy has not led to any substantial changes and high-carbon energy from forest biomass still accounts for large percentages of many EU countries’ renewable energy totals. As the UK’s Committee for Climate Change pointed out in their report “Biomass in a low-carbon economy” sustainable forest management criteria do “not guarantee bioenergy supply chains reduce carbon emissions when used in place of fossil fuels.” It is vital that the European Commission fundamentally revises the Renewable Energy Directive in regards to the support for different types of energy. Energy from burning forest biomass must be excluded from eligibility for counting toward renewable targets and from eligibility for member state support schemes for renewable energy. In light of these points, we urge the Commission to broaden the scope of the review beyond Article 29 and include Articles 2, 4, 7, 23 and 25 (support to RES-E and role of biomass in H&C and biofuels for transport) and Annex IX. A further tinkering with “sustainability criteria” is not sufficient. The rules for calculating greenhouse gas impacts of bioenergy must revised so that they account for the full stack emissions, rather than assuming the burning emissions from biomass to be zero.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

23 Jul 2020

NRDC submission to the consultation “EU emissions trading system – updated rules on monitoring and reporting (2021-30)” The Implementing Regulation (EU) 2018/2066 on the monitoring and reporting of greenhouse gas (GHG) emissions pursuant to Directive 2003/87/EC of the European Parliament and of the Council stipulates that in calculating GHG emissions for bioenergy production “The emission factor of biomass shall be zero,” provided that the biomass complies with the sustainability criteria of the Renewable Energy Directive (REDII). This, however, is scientifically wrong and results from an misapplication of the original guidance provided for national level GHG counting under the United Nations Framework Convention on Climate Change (UNFCCC). This error has been pointed out by - amongst many others - the European Environment Agency Scientific Committee as far back as 2011 . Per unit of energy, biomass-burning plants emit more carbon dioxide (CO2) from their smokestacks than fossil fuel plants. And, in each wooded area, cutting older trees and replacing them with saplings reduces how much carbon is stored in that forest, even if trees are replanted right away. Together, this means it takes decades to more than a century for bioenergy to deliver any climate benefit—and then only if forests are allowed to regrow and not converted to plantations or re-cut for energy.. Peer-reviewed scientific studies now show that even when power stations burn forestry residues—the leftovers from logging operations—the result is more CO2 in the atmosphere over several decades . Under UNFCCC accounting rules, countries separately report their emissions from energy use and from land-use change. To avoid double-counting, the rules allow countries to ignore carbon that is released from a smokestack when biomass is burned for energy production— not because it assumes that biomass is carbon neutral, but rather, because it assumes that biogenic emissions are being reported in the land-use sector (LULUCF). Thus, when countries import biomass as fuel for energy production, they effectively export these combustion emissions to the biomass supplier countries. Where these countries do not account properly for LULUCF, the emissions disappear from the international accounting system entirely . Further, the UNFCCC accounting guidance does not apply to any regulations, such as the European Trading Scheme (ETS), that seek to limit emissions from energy use but do not limit emissions from land-use, and that do not apply worldwide. Since the ETS does not count bioenergy smoke-stack emissions, and does not address LULUCF emissions, it effectively allows energy companies that burn wood to avoid responsibility for these emissions and, by extension, the carbon costs associated with their operations. Instead, it allows them to operate on the assumption that the EU country of origin of their biomass fuel will take on this liability. This violates the EU’s polluter-pays principle, laid down in Article 191 TFEU, which stipulates that the cost of preventing, reducing or repairing environmental impairment should be borne by the polluter and not by the taxpayer. The ETS bioenergy accounting framework must be fundamentally reformed - as part of the European Green Deal’s review of current climate legislation - so that operators are fully liable for smokestack GHG emissions from bioenergy, in the same way they are for fossil fuel emissions. Without this reform the ETS threatens to fail on its two primary objectives: To reduce GHG emissions efficiently and to promote corporate investment in genuine low carbon technologies.
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Response to 2030 Climate Target Plan

15 Apr 2020

The Natural Resources Defense Council’s response focuses on ensuring that 2030 EU climate protection measures deliver the best possible outcomes for climate and nature, whilst ensuring the highest cost-effectiveness. In particular, we urge you to end billions of Euros in subsidies for replacing fossil fuels with biomass from forests, which are counterproductive to these aims. Burning forest biomass releases large amounts of climate-warming pollution into the atmosphere and destroys crucial carbon-capturing ecosystems, setting us back decades in the fight against climate change. As such, continued EU support for this form of bioenergy directly threatens the tightened GHG reduction targets proposed in the 2030 EU Climate Target Plan. In an open letter to the EU Parliament, more than 800 leading scientists have called for urgent action to restrict forest bioenergy schemes, as has the European Academies Science Advisory Council (EASAC). Forest biomass also diverts scarce investment resources from low-cost, low-risk and readily available clean energy alternatives, such as solar and wind, and is incompatible with the EU’s ‘do no harm’ principle. A key problem of EU flagship climate policies to date has been their failure to distinguish between forms of energy generation that do not rely on combustion and therefore, are genuinely free of GHG emissions (e.g. wind, solar, wave, tidal), and forms of energy generation that are based on the combustion of raw materials, which result in significant GHG emissions and subsequently rely on theoretical re-sequestration of CO2 by plants to offset their emissions (e.g. various forms of bioenergy). This has led to the perverse situation where the majority (approximately 60%) of the EU’s Renewable Energy Target is now met by forms of combustion energy, which emit significant GHG emissions. Burning wood in power stations to produce electricity worsens climate change just like coal and other fossil fuels. Per unit of electricity, biomass power plants emit more CO2 from their smokestacks than coal plants do. Forest regrowth takes decades, during which atmospheric CO2 is higher than it would be otherwise. The EU Commission’s own report titled “Carbon impacts of biomass consumed in the EU” showed that EU energy scenarios that reduce the use of bioenergy, instead relying more on solar and wind, result in the lowest carbon emissions. Additionally, EU incentives to harvest wood for electricity production undermine local efforts to protect biodiversity in the regions where forests are being cut to supply biomass. Independent media reporting has exposed the unsustainable logging practices used to source wood for pellets exported to Europe, including sourcing from clearcuts of mature hardwood forests in the Southeastern U.S., damaging biodiversity in the North American coastal plain—a region designated as a global biodiversity hotspot. Continued state-support for biomass energy can no longer be justified on climate or environmental grounds. However, a recent assessment of government subsidies and other forms of financial support offered to biomass energy producers in the European Union found that in 2017, the 15 member states most heavily reliant on bioenergy spent more than €6.5 billion to subsidise its production. [Trionomics - Financial support for electricity generation & CHP from solid Biomass- attchd]. Some countries have already started to change course: e.g. the UK government has announced that coal-to-biomass will be excluded from future Contracts for Difference (CFD) auctions, and stated that “all support for biomass conversions ends in 2027”. Given the significant financial expenditures now required to mitigate the economic impacts of the COVID19 pandemic, it is more important than ever that the EU’s Climate Target Plan to 2030 puts an end to billions in wasteful bioenergy subsidies and instead redirects this investment toward truly clean and renewable energy sources like solar and wind.
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Response to Climate Law

4 Feb 2020

The Natural Resources Defense Council appreciates the opportunity to input into the Commission’s 2050 climate law roadmap. We agree with leading European NGOs that the target of reaching net-zero ghg emissions by 2050 is an insufficient contribution to preventing warming greater than 1.5°C, and that far more ambitious year-on-year reductions in greenhouse gas (ghg) emissions are required. However, we focus our response on the role of bioenergy and the importance of properly accounting for its emissions if the EU is to achieve real carbon-neutrality. Flagship EU climate policies—in particular the Renewable Energy Directive (RED) and the resulting subsidies legislated by EU member states—falsely assume all bioenergy to be carbon neutral at the point of combustion. This assumption has now been debunked by leading scientists, including the European Academies Science Advisory Council, which warns about serious mismatches between science and policy in the EU RED. In an open letter to the EU Parliament, more than 800 leading scientists called for urgent action to restrict forest bioenergy schemes. Burning trees to produce electricity worsens climate change just like coal and other fossil fuels. The EU Commission’s own report titled, “Carbon impacts of biomass consumed in the EU,” showed that EU energy scenarios that reduce the use of bioenergy, instead relying more on solar and wind resulted in the lowest carbon emissions. Additionally, EU incentives to harvest wood for large-scale electricity production undermines local efforts to protect biodiversity in the regions where forests are being cut to supply biomass. Unfortunately, the 2018 RED recast failed to introduce meaningful restrictions or safeguards for bioenergy. Closely related to the issue of bioenergy is bioenergy with carbon capture and storage (BECCS). The EU’s main 2050 pathway scenarios rely on BECCS to deliver large ‘negative emissions.’ But BECCS remains a speculative technology and has never been demonstrated at any scale with biomass plants. The energy needed to operate a BECCS plant could well outstrip the energy it produces because of its low efficiency in combination with the potentially high energy demand of the biomass supply chain as a recent Imperial College report warned. The assumption that BECCS creates a ‘carbon negative’ power station relies on the same discredited myth of biomass carbon neutrality underlying EU bioenergy policy writ large, as a recent Chatham House report warned. Carbon capture technology only captures smokestack emissions; it cannot make up for the resulting loss in the ability of forests to continue to absorb and store CO2 when trees are harvested for large-scale energy production. Experts agree that large-scale conservation of natural ecosystems, such as forests, is an essential mitigation strategy in our effort to combat the twin threats of climate change and ecosystem collapse. Policies that incentivize the use of forest biomass for bioenergy production work directly against these objectives and must be scrapped. To fulfill its promise the Climate Law roadmap must: 1. Have as its explicit aim an end to the EU’s reliance on forest biomass for large-scale bioenergy schemes in the power and heat sectors. 2. Press for the urgent review and ultimate removal of the ‘carbon neutrality’ assumption for bioenergy, both in EU legislation and international treaties, ending the EU legal basis for member state subsidies. 3. Discourage member states from including forest bioenergy in their national climate and energy plans, and instead prioritize investment in energy efficiency and genuinely clean and renewable energy sources like solar and wind. 4. Avoid reliance on BECCS to deliver negative emissions in 2050 energy pathways and immediately move to reduce emissions from the electricity grid, in transport and in homes, and invest in expanding terrestrial carbon sinks in natural forests and other ecosystems.
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Response to EU 2030 Biodiversity Strategy

20 Jan 2020

Together with climate change, biodiversity loss is one of the most pressing global environmental catastrophes of our time. The Natural Resources Defense Council (NRDC) welcomes the EU’s commitment to tackle global biodiversity loss with its 2030 biodiversity strategy. To succeed, the strategy must address the man-made drivers of global biodiversity loss, including the consumption of natural resources for products, food and energy. As the second largest consumer market in the world, Europe bears significant responsibility for the ecological impacts of its consumption across countries of origin. One of the fasted growing new demands for natural resources is wood from natural forests to meet the rapidly increasing demand for biomass for bioenergy. To meet this demand, the European Union is increasingly importing biomass in the form of wood pellets from overseas, in particular from North America. Independent media reporting has exposed the unsustainable logging practices used to source wood for pellets exported to Europe, including sourcing from clearcuts of mature hardwood forests in the Southeastern U.S. These sourcing practices not only liquidate carbon stocks, but damage biodiversity in the North American coastal plain—a region designated as a global biodiversity hotspot. This demand has been primarily driven by EU policies—in particular the Renewable Energy Directive and, to a lesser extent, by other climate-related legislation and the resulting subsidies legislated by EU member states— that falsely assume all biomass is carbon neutral. This assumption has now been debunked by leading scientists, including the European Academies Science Advisory Council (EASAC). In an open letter to the EU Parliament, more than 800 leading scientists called for urgent action to restrict forest bioenergy schemes. The EU Commission’s own report titled, “Carbon impacts of biomass consumed in the EU,” also showed that EU energy scenarios that backed away from the use of bioenergy resulted in the lowest carbon emissions. Per unit of energy, biomass-burning plants emit more carbon dioxide (CO2) from their smokestacks than coal-burning plants. And, in each wooded area, cutting older trees and replacing them with saplings reduces how much carbon is stored in that forest, even if trees are replanted right away. Together, this means it takes decades to more than a century for bioenergy to deliver any climate benefit. This is incompatible with the speed at which countries must cut emissions to meet Paris Agreement targets or limit global warming to 1.5o Celsius. In its resolution from the 16th of January 2020, the EU Parliament called on the Commission to lead the way globally in addressing the main drivers of biodiversity loss. This must include improving environmental policy coherence in all internal and external policies of the EU. The biodiversity strategy (together with the European Green Deal) presents a major opportunity to align past legislation with current EU goals , as it strives to fully integrate biodiversity considerations into other EU policies and address EU impacts on global biodiversity. To fulfil its promise the biodiversity strategy must: 1. Have as its explicit aim an to end the EU’s reliance on forest biomass for large-scale bioenergy schemes in the power and heat sectors” 2. Press for the urgent review and ultimate removal of the carbon neutrality assumption for bioenergy, both in EU legislation as well as in International treaties, ending the EU legal basis for Member state subsidies. 3. Call for the end of other support mechanisms for forest bioenergy, such as under the Common Agriculture Policy (CAP). 4. Discourage member states from including forest bioenergy in their national climate and energy plans, and instead prioritize investment in energy efficiency and genuinely clean and renewable energy sources, such as solar and wind.
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Response to Stepping up EU Action against Deforestation and Forest Degradation

15 Jan 2019

NRDC welcomes the EU’s initiative to tackle global deforestation and forest degradation. The world must take urgent action to halt the devastation of the world’s forest, which are vital for biodiversity, and are our best tool for removing heat-trapping carbon dioxide from the atmosphere. The roadmap correctly identifies the expansion of agriculture as one key driver of global deforestation and forest degradation. However, a second important driver is rapidly accelerating demand for wood as a fuel for energy production across multiple sectors (bioenergy). Unfortunately, EU policies intended to promote renewable energy contribute significantly to this relatively new driver. This is because they promote the mistaken assumption that all biomass is carbon neutral As a result, multiple EU members states have put in place large subsidies that encourage biomass-burning for electricity production. This is a policy error enshrined in EU policies and addressing it is directly in the power of European institutions. While member states are accounting for peripheral fossil fuel emissions from sourcing and transporting biomass, they are failing to account for the smokestack emissions from burning wood, as well as forest carbon losses on the landscapes from which biomass is sourced. Scientists have shown that many forms of biomass—especially from forests—produce higher carbon emissions compared to fossil fuels. A growing body of peer-reviewed scientific studies shows that burning wood from whole trees and other large-diameter wood for electricity can increase carbon emissions relative to fossil fuels for many decades—anywhere from 35 to 100 years. Bioenergy already represents about two-thirds of the EU’s renewable energy use. The resulting policy-driven growth in biomass demand comes on top of existing pressures on global forests from other sectors. Member states are increasingly importing wood from outside the EU, often from countries with lower levels of forest stewardship, and/or flawed methods for accounting for forest carbon losses. Today, the EU imports more than 8 million tons of wood pellets per year, making it world’s largest importer. The U.S. Southeast is the top region supplying wood to the EU bioenergy market. U.S. pellet manufacturers often claim to only use timber residues in pellet production. However, NGOs, including NRDC, Dogwood Alliance, and the Southern Environmental Law Center, have shown in multi-year investigations that wood entering EU biomass supply chains is sourced from whole trees from bottomland hardwood wetland forests. Sustainability standards for bioenergy, such as those in place in the UK and other major bioenergy markets in the EU, have failed to prevent large-scale clear-cutting in ecologically high-value forests. The RED recast has failed to introduce meaningful safeguards for biomass electricity. In particular, the RED continues to count wood burning as carbon neutral and missed the opportunity to exclude the highest emitting forms of forest biomass, such as roundwood and stumps, from eligibility for subsidies. The EU roadmap against deforestation and forest degradation must address EU bioenergy demand as a key driver for global deforestation and forest degradation. It must recommend a rapid review of the bioenergy provisions in the RED and it must encourage member states to go beyond the minimum requirements of the Directive (as the legislation explicitly allows) and introduce further restrictions on the use of forest biomass. These should include, at minimum: 1. Ruling out subsidies for the highest carbon sources of biomass (i.e. roundwood). 2. Ruling out all subsidies for the least efficient uses of biomass (i.e. electricity only power stations not generating a combination of heat and power), including for existing installations. 3. Setting stricter peripheral emissions carbon intensity limits for biomass than the RED, such as the 29 g CO2/MWh recently adopted by the UK.
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