Foodrise’s response to the Financial Conduct Authority’s consultation.

Scientists urge governments to act aggressively over the next decade to keep global warming to 1.5°C and avert the worst consequences of climate change. Pivotal to that effort are policies to quickly end reliance on dirty energy; support a rapid transition to genuinely non-emitting and renewable energy; and protect forests and other intact ecosystems as critical carbon sinks. Industrial scale biomass-burning in the power sector threatens all three pillars of climate action and should not be subsidised.

Anaerobic Digestion (AD) of biomass feedstocks such as wastes and bioenergy crops is often a suboptimal use of land and resources, and must therefore be kept within its sustainable niche as a last-resort waste management option1. Any support for the growth of AD must be designed in a manner which does not undermine waste prevention efforts or divert land from environmentally preferable uses.

The Paris agreement targets are unlikely to be met by mitigation alone and based on current trajectories, 1.5°C warming is likely to be exceeded between 2030 and 2052. It is therefore clear that the UK will also need to use Greenhouse Gas Removal methods to reach net zero by 2050. However, it is imperative that Greenhouse Gas Removal is in addition to maximising the mitigation potential of all sectors.

The government wishes to “increase the proportion of green gas in the grid” and to “provide targeted support to heat pumps”. The summary of evidence presented in our response shows that “green gas” from Anaerobic Digestion (AD) is often a suboptimal use of land and resources, except for a limited sustainable niche. Foodrise therefore recommends that greater subsidies are dedicated to electrifying the heat supply as quickly as possible through technologies such as heat pumps, rather than locking in expensive and suboptimal “green gas” infrastructure. Foodrise recommends increased taxes on landfill and incineration of waste feedstocks so that AD becomes attractive as a last resort only, with the revenue raised used to subsidise more cost-effective and more sustainable alternatives to AD, such as food waste prevention, afforestation, a just transition to more plant-based diets, and scaling up more efficient renewables such as solar and wind

The government wishes to “ensure that the CFD scheme continues to support low carbon electricity generation at the lowest possible cost to consumers”. The summary of evidence presented here shows that Anaerobic Digestion rarely delivers this desired outcome. Therefore, Contracts for Difference should not give support to Anaerobic Digestion (AD) plants of any size. Moreover, Feedback strongly recommends against creating a bespoke version of CfD to subsidise smaller scale AD plants than are currently covered by CfD.

Foodrise welcome the CCC’s modelling of a 50% reduction in food waste by 2030. We recommend that the CCC use the following means of measuring the 50% per capita food waste reduction target, as a more ambitious scenario:
• 50% reduction of edible and inedible food waste (in practice mainly achieved through a
greater than 50% reduction in edible food waste)
• 50% reduction by 2030 against a 2015 baseline (there is a strong rationale for 2015 as
the baseline year, as the founding year of the SDGs, including SDG 12.3, which sets the
food waste reduction target)
• 50% reduction of food waste from farm to fork
• Additional prevention of edible surplus food currently sent to animal feed

The current Covid-19 pandemic is exposing many aspects of our food system which pose major challenges to both ensuring that the public’s nutritional needs are fulfilled fairly and equitably and to producing food without exacting a dangerous environmental toll. Our response to the enquiry is founded on our belief that true food system productivity should be measured as the greatest nutritional value consumed (with the least waste) for the least environmental harm or the greatest environmental enhancement. The Government’s response to the impact of the Covid-19 crisis on our food supply chain needs to go beyond measures to relieve immediate scarcity – though these are of course important and vital – to encompass action that will help to build a food system that is more resilient to future shocks, especially those posed by the ongoing climate emergency.

Foodrise responds to the Government’s consultation on the new National Food Strategy, led by Henry Dimbleby. We argue that to achieve the best health and environmental outcomes, the government will need to redefine agricultural productivity, to prioritise high quality, nutritious food, low waste, and minimal environmental impact – and that implementing this approach will require a new land use strategy. We also urge the Food Strategy team to take another look at existing land uses – such as sugar beet production and feedstock crops for bio-energy – which do not contribute to human or planetary health.