The Whitehead report on carbon dioxide removals (CDR) was published in October 2025 and overall, it’s bad news for Drax. The report concludes it’s important to minimize import of wood pellets, which are a risky and expensive way to deliver “removals” of CO₂ from the atmosphere.  Unfortunately, however, the report doesn’t acknowledge the obvious: that storing tree carbon belowground using CCS does not contemporaneously remove CO₂ from the atmosphere, no matter where the trees come from.

We anticipated that the report would not be truly science-based or “independent” (despite its announcement as such). Our concerns were justified: the report has the government’s fingerprints all over it, and even thanks DESNZ for inputs. Nonetheless, the report does make one novel and important conclusion concerning greenhouse gas removals (GGR): that if the government wants to offshore its removals, there are probably better ways to do it than by importing biomass (e.g. at page 134: “It is not obvious that GGRs based on imported feedstocks is an inherently more desirable GGR solution for the UK than paying for deployment overseas of, for example, DACCS in a country with abundant low-cost solar energy”).

Overall, while there is a conspicuous Drax-shaped hole in this report (the company is mentioned only once, in a tiny footnote), the report makes it clear almost anything else than Drax would be preferable, setting out a list of “no regrets” strategies that conspicuously omits burning imported biomass (p. 132).

Given that the government has just agreed to grant new subsidies to Drax, the report is clearly was clearly not considered relevant for policymaking in the near term. But since Drax is nowhere near deploying BECCS at scale, perhaps the report will strengthen the hand of those in government who understand that claims of future BECCS are essentially just a scheme to keep subsidies flowing.

However, the credulousness of the report regarding “removals” means it probably does more harm than good.  It assesses a number of GHG strategies against a variety of metrics (Fig. 1), but omits to ask the most important question: Will the technology actually remove net CO₂ from the atmosphere?

Fig. 1. Overview table from Whitehead report

In fact the report promotes a number of technologies that don’t remove CO₂ but simply move carbon from one pool (usually forest aboveground biomass) to another. For BECCS, the final pool is  belowground storage; for biochar and timber in construction, the end-products remain aboveground.

The IPCC itself has clarified in 2019 that such uses don’t remove CO₂ from the atmosphere. For example, in the case of timber for construction (harvested wood products, HWP), the IPCC GHG reporting Guidelines state,  “In the context of HWP, when referring to CO₂ removals, it may be noted that HWP do not directly sequester carbon from the atmosphere. …carbon retained in HWP constitutes a pool of carbon that was sequestered originally by the above ground biomass carbon pool of forests and other wood producing land categories”

This same logic applies to storing wood carbon belowground using CCS. It’s not a new “removal” and shouldn’t be counted as such. Any hypothetical removal of CO₂ from the atmosphere occurs during forest regrowth, and as regrowth is slow and uncertain, BECCS as a mitigation strategy should be seen as fundamentally incompatible with need for timeliness, certainty and permanence of CO₂ removals from the atmosphere.

It’s interesting to contrast how the report describes the process for allegedly delivering removals with three main technologies: direct air carbon capture and storage (DACCS);  waste energy with carbon capture and storage (WECCS); and biomass energy with carbon capture and storage (BECCS).

Regarding direct air capture, the report correctly states (p. 54) that “DACCS plants remove CO₂ from ambient air for permanent storage.”  Whether there is net removal given the energy and carbon costs of doing DACCS is another question, but at least in theory, that technology does actually pull CO₂ from the air.

For WECCS, the report explains (p. 47) that “removals” actually consists of preventing the re-entry of biogenic CO₂ back into the atmosphere (presumably via decomposition):

Around 50% of the unrecyclable MSW produced by society is biogenic: in other words, it derives from plant matter rather than from petrochemicals. This biogenic waste, including food waste, plants and paper, therefore contains carbon that was removed from the atmosphere as plants grew, rather than carbon that was previously stored geologically. Installing CCS technology at an EfW facility enables this CO2 to be permanently captured and stored rather than released back into the atmosphere, resulting in a net carbon removal from the atmosphere.

Whether preventing biogenic emissions from entering the atmosphere is functionally the same as removing CO₂ from the atmosphere requires more discussion than we have space for here.  The important thing to recognize is that they appropriately create a framework for assessing the effect of WECCS by comparing CO₂ flux using WECCS versus a counterfactual where biogenic waste decomposes and the carbon enters the atmosphere. Under this framework, capturing and storing the CO₂ belowground is claimed to provide a climate benefit.

In contrast, the explanation for why BECCS provides removals doesn’t use a counterfactual and isn’t as explicit. At page 42 the report states:

The general principle behind BECCS technologies is that the CO₂  captured and stored in the biogenic feedstock during plant growth is released during whichever biomass conversion technology is being utilised and is then captured and permanently stored (Figure 2.3). This process leads to the permanent removal of CO2 from the atmosphere.

At page 108, the order that events occur is notable: “Biomass-based GGRs include all solutions and strategies that use plants to remove carbon dioxide from the atmosphere through photosynthesis, then durably store that carbon in long-lived products or underground. This includes BECCS and the conversion of biomass into products like biochar for permanent sequestration.”

Their unsubstantiated claim that BECCS leads to permanent removal of CO₂ from the atmosphere reminds us of one of the world’s great cartoons:

Fig. 2.  Applies to several technologies listed in Fig. 1.

Simply storing carbon belowground (which can be done with fossil fuel-derived CO₂) doesn’t constitute a removal.  There’s no new “removal” if the biomass carbon was (as they admit) already sequestered, which in the case of trees, could have occurred decades or even centuries previously. The BECCS explanation doesn’t use a counterfactual, but if it did, one scenario is that instead of being cut and burned in a powerplant, the trees could continue to grow and pull CO₂ out of the atmosphere, providing actual “removals” – and their continued presence on the landscape itself locks up vast stores of carbon.  If  pulling carbon from the atmosphere and storing carbon is what you’re after, then it’s hard to beat a forest – a fact the report itself acknowledges (“afforestation, reforestation and forest management” – along with “peatland restoration” – beat out all other approaches in the table shown in Figure 1, including regarding costs and “technology readiness level”, TRL).

The report promotes other marginal technologies that are likely have severe negative environmental effects, such as enhanced rock weathering (“ERW” in Fig. 1) , or widescale spreading of biochar, which is likely to affect air quality, as well as potentially contribute to black carbon loading, an important driver of climate warming.

Fig. 3. Image of biochar from report at page 65. Anyone fancy a nice cup of black carbon?

The report displays a hopeless techno-optimism and naivete regarding the plausibility of some scenarios (e.g. see page 173 where they envision a Rube Goldberg-esque process for optimal use of biomethane). There is little acknowledgement that some of the UK’s renewable energy gravy trains have led to absurdist disasters, which in addition to Drax logging irreplaceable primary forests in Canada (a process that is still occurring), include incentives for anaerobic digestion that has led to some unpleasant outcomes, and the “Cash for Ash” wood-heating scandal.

Overall, the report was about as bad as we predicted in some respects, and worse in others. Importantly, though, it does make a feeble stand against Drax and imported wood pellets. Drax should not be feeling very happy about this outcome. But in their rush to continue sending cash to Drax, will the government listen?