Memorandum submitted by the Royal Society
for the Protection of Birds
1. SUMMARY
1.1 The RSPB welcomes the Committee's inquiry
into this issue. Our vision is for energy crops to be a commercially
profitable and environmentally sustainable mainstream option for
farmers, which will contribute to UK renewable energy targets
and benefit biodiversity. We believe that energy crops should
be managed in a way which supports the environmental ethics behind
their usage.
1.2 In order to achieve this vision we believe
that the Department for Environment Food and Rural Affairs (Defra)
should draw up a non-food crop strategy, based on a Strategic
Environmental Assessment that takes into account the needs of
biodiversity, energy security and the farming industry. The strategy
must dovetail with the recent energy white paper. It should facilitate
the evolution of a sustainable bioenergy industry, which is both
commercially profitable and environmentally responsible.
1.3 In order to inform such a strategy it
is essential that the UK invests in research into the wider environmental
and social implications of biofuel production. We must learn the
lessons of the biodiversity declines that have occurred over the
last few decades due to agricultural intensification and driven
by the market distortions of the Common Agricultural Policy (CAP).
If we are to use our agricultural resources to help reduce our
influence on the global climate, we must ensure that we do not
damage our local environment in doing so.
2. BACKGROUND
2.1 The RSPB is Europe's largest wildlife
charity with over one million members. We manage one of the largest
conservation estates in the UK, covering more than 100,000 hectares.
60 of our reserves are farmed, with around 170 tenant farmers,
200 employees and a total estate turnover of between £4-6
million. A number of our reserves are exploring the possibility
of renewable energy projects including a feasibility study into
biomass heating from harvested reed beds.
3. BIOENERGY
3.1 The RSPB strongly supports initiatives
that aim to increase the proportion of UK fuel sourced from renewable
materials. We also support opportunities for farmers to diversify
their markets, as our farmland biodiversity depends on a healthy
farming industry. Bioenergy, derived from a variety of sources,
would help the UK meet its emission targets and provide a source
of rural employment. However, there are potential negative impacts
that must be avoided.
3.2 We are concerned that the expansion
of energy crop cultivation without a strategic impact assessment
could cause considerable damage to our biodiversity. The transformation
of large areas of land into energy crop plantations could destroy
or severely reduce the biodiversity value of existing habitats
that support farmland bird species of high conservation concern.
For example, the replacement of species-rich semi-natural or wet
grasslands with short rotation coppice could destroy the habitat
of breeding wader populations (lapwing, snipe, curlew) or other
birds requiring a more open landscape (skylark, yellow wagtail,
corn bunting).
3.3 In addition to habitat loss, increased
block cropping, which could result from large scale production,
could further reduce the diversity of our countryside, exacerbating
recent declines in biodiversity in the farmed landscape. This
could compromise Defra's ability to deliver its Public Service
Agreement to reverse the decline in farmland bird populations.
Also, under current rules, increased biofuel production could
result in the loss of more set-aside land, which currently provides
a haven for our wildlife.
4. SET-ASIDE
AND CAP REFORM
4.1 Set-aside land currently provides important
benefits for UK biodiversity, particularly for wintering and breeding
birds. Growth of industrial crops on set-aside, as currently permitted,
would result in a reduction of these beneficial sites. An expansion
in the area of set-aside land being lost to bioenergy crops, such
as autumn-sown industrial oilseed rape, is likely further to exacerbate
the major population declines experienced by birds such as skylark,
lapwing, finches and buntings in recent decades.
4.2 Under the reform proposals for the CAP,
non-food crops would no longer be eligible to be grown on set-aside
but would be supported by a carbon credit payment of
45/ha. Even before these proposals were made, the
EU intended to phase out set-aside by 2006. Therefore, if bioenergy
is to become a significant crop, set-aside is unlikely to provide
a long-term growing opportunity, and supporting the crop within
mainstream rotations will be necessary.
4.3 Currently, bioenergy crops have to compete
for land with other agricultural products and under the present
economic climate they are less profitable. However, CAP reform
proposals, which include a decoupled single income payment, could
change the balance of profitability between crops, making bioenergy
more economically attractive.
5. CROP MANAGEMENT
5.1 By minimising the inputs used to produce
energy crops, ie by using appropriate levels of fertiliser and
only applying pesticide when pest threshold levels are exceeded,
improvements could be made not only to the carbon mitigation benefits
of the biofuel and the economic viability of the crop, but also
to farmland biodiversity, much of which is currently in decline.
This will ensure that biofuel can be said to be truly sustainable.
5.2 Although the interactions between conventional
crops and biodiversity are fairly well researched, very little
research has been carried out into the impact of large scale energy
crop plantations of crops, such as short rotation coppice replacing
annual crops. The research that has been done has studied pre-commercial
trials, which have been mainly small scale. The results from large,
intensively managed plantations may well be very different. Further
research, assessment and appropriate planning policies are needed
to ensure that this potential energy source can be exploited without
adverse effects on biodiversity and damage to the environment.
6. RECOMMENDATIONS
6.1 In order to capitalise on bioenergy
as a tool in the race against climate change, whilst ensuring
that UK biodiversity is not damaged, the RSPB recommends that
the Government should:
(i) implement the recommendation of the Curry
Commission and produce a long-term strategy for Non Food Crops
based on a Strategic Environmental Assessment. This should include
an appraisal of areas suitable for bioenergy developments and
areas where, for environmental reasons, such developments should
be prohibited. The strategy should take into account the recent
energy white paper, "Creating a low carbon economy";
(ii) develop a support framework, which
ensures that energy crops are supported by a buoyant renewable
energy market, rather than by production subsidies, and encourages
local sourcing and use;
(iii) develop guidelines, which producers
must follow, for growing energy crops to high conservation standards
and in a manner compatible with the "green" ethics behind
their industrial usage (eg: mixed age stands, use of native species
and integrated crop management techniques);
(iv) ensure that an effective farm advisory
system is in place to supply conservation advice and training
to all bioenergy producers;
(v) ensure that the Environmental Impact
Assessment carried out before the creation of new plantations
takes into account the impact the change in land use may have
on species in the current habitat, particularly the farmland birds
of conservation concern which are included in Defra's Public Service
Agreement target; and
(vi) recognise the potential biodiversity
value of set-aside land, and ensure that this valuable resource
is not damaged by cultivation of energy crops. Within current
rules for set-aside, we believe 50% should be managed for conservation,
with energy crops encouraged to the same extent as other arable
crops, until an equivalent area of land can be managed environmentally
through the second pillar of the CAP.
SWOT ANALYSIS OF
BIODIESEL, BIOETHANOL
AND SHORT
ROTATION COPPICE
BIOETHANOL
Strengths
— Can be derived from a variety of
feedstocks: including wheat, sugar beet and woody crops.
— Spring sown crops provide valuable
winter stubble, which benefits stone curlews, lapwings, finches,
buntings and skylarks.
— Tailpipe emission improvements.
— Particulate emission reductions.
Weaknesses
— Would require large areas of arable
land and therefore have to compete with food crops.
— Requires further cut in fuel tax
to be economically viable.
— Requires some improvements to fuel
network infrastructure.
Opportunities
— If crops managed under low input
regime could benefit biodiversity.
— There is currently a four million
tonne surplus of wheat, which could be used.
— CAP reforms could produce a surplus
of beet, which could also be used.
— Provide new opportunities for local
economic development and employment.
Threats
— Could be grown on set-aside.
— Could be derived from woody crops
on pastoral land, which would destroy the habitat of wading birds.
— Potential for GM crop use with less
public resistance which could threaten biodiversity if not well
researched.
BIODIESEL
Strengths
— Can be derived from conventional
crops.
— Already being sold on UK forecourts.
— Tailpipe emission improvements.
— Particulate emission reductions.
— Rapidly biodegradable compared to
conventional diesel.
Weaknesses
— Require large area of arable land
and therefore have to compete with food crops.
— Requires further tax incentives to
improve uptake.
— Possible adverse health effects in
terms of increased allergenic reactions.
Opportunities
— If managed under low input regime
could benefit biodiversity.
— Provide new opportunities for local
economic development and employment.
— Well managed oilseed rape provides
feeding and nesting resources for a number of farmland birds.
Threats
— Could increase oilseed rape in rotations,
reducing crop diversity.
— Could be grown on set -aside.
— Potential for GM crop use with less
public resistance which could threaten biodiversity if not well
researched.
SHORT ROTATION
COPPICE/MISCANTHUS
Strengths
— Can be grown on low quality land.
— Tailpipe emission improvements.
— Particulate emission reductions.
Weaknesses
— Increased demand on the local water
table.
— Damage to archaeological sites.
— Cost of specialist machinery.
Opportunities
— If technology is proven has the potential
to be the most energy efficient source of bioethanol.
— Biofilters—crop used to absorb
nutrients and contamination from sewage and other sludges.
— Provide new opportunities for local
economic development and employment.
Threats
— Decreased biodiversity—inappropriate
location could destroy important habitats crucial for nesting
and feeding for open field species.
— Visual impact, undesirable change
in landscape characteristics.
— Potential for GM crop use with less
public resistance which could threaten biodiversity if not well
researched.
March 2003
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