Memorandum submitted by English Nature
(Bio 09)
EXECUTIVE SUMMARY
1. If Government policy is used to promote
production and consumption of biomass or biofuels in the UK without
any additional safeguards on where those biofuels come from and
how they have been produced, English Nature believes this
would risk an increase in agricultural intensification, particularly
if combined with high prices, that would contribute to loss of
biodiversity both in England and globally, while delivering only
small cuts in GHG emissions. We recommend the following measures
to prevent this from happening:
Strategic policy
(a) Government's top priority in terms
of climate change should be to improve energy efficiency and demand
management. This is where the greatest reductions in GHG emissions
can be achieved in the short and medium term.
(b) Government bioenergy policy should
prioritise use of existing sources of biomass, to reduce the
need for large areas of land to grow energy crops.
(c) Government should ensure that policies
put in place to deliver climate change targets will not reduce
our ability to meet other important environmental targets, such
as the UK Biodiversity Action Plan, the Water Framework Directive
and the Soils Directive.
Policy initiatives
(d) In designing and implementing the
RTFO, the government should link allocation of certificates to
the amount of GHG emissions saved by the production of biofuels.
It is already proposed that the RTFO should include mandatory
reporting on the life cycle carbon balance (including all GHG
emissions from crop production, harvest, transport and processing
of biofuels). This data could be used in the allocation of certificates—for
example, the government could choose to withhold RTFO certificates
from biofuels that deliver less than, say, 50% GHG savings compared
to fossil fuels.
(e) Incentives for producing biofuels
should be linked to the sustainability of their production system.
A certification scheme should be established that will provide
assurance that the crops used to grow biofuels have been managed
according to good environmental standards. We understand that
this may be difficult because of WTO rules but the Government
should make every effort to resolve this.
(f) Encourage best land management practice
in growing energy crops to maximise greenhouse gas savings
in terms of kgCO2 eq/£ while protecting and enhancing
biodiversity, water quality and soils.
(g) Investigate ways of mitigating the
possible adverse effects of converting uncropped land into energy
crop production. These could include additional Entry Level
Scheme prescriptions for biofuel or biomass crops grown on set-aside
(not allowed under current set-aside rules), and for maintaining
fallow land on the farm.
(h) Increase funding for R&D on new
crop varieties and management practices that can deliver both
reductions in GHG emissions and improve environmental sustainability
of agricultural management.
(i) Monitor changes in area of uncropped
set-aside land, and the total area of land used for growing energy
crops, to provide information on trends in crop diversity and
aid in development of mitigation measures if necessary.
(j) Promote small-scale, local uses of
biomass energy, which can connect people more closely with
their energy sources and so have additional benefits such as reduced
pressure for industrialisation of agricultural landscapes and
need for long-distance transportation, improved public acceptability
and educational opportunities.
2. English Nature is committed to providing
support and advice to Government and other stakeholders involved
in the bioenergy sector, in order to maximise the contribution
of this rapidly developing sector to targets on climate change,
biodiversity and agricultural sustainability. Achieving these
outcomes is likely to prove a significant challenge so we are
pleased that the EFRA Committee is holding this inquiry, which
we hope will make an important contribution to continuing policy
development in this area.
INTRODUCTION
3. A new organisation—Natural England—is
being created with responsibility to conserve and enhance the
value and beauty of England's natural environment and promote
access, recreation and public well-being for the benefit of today's
and future generations.
4. The creation of the new organisation,
Natural England, is well under way, with English Nature
(EN), the Landscape, Access and Recreation division of the Countryside
Agency (LAR), and the Rural Development Service (RDS) working
together as partners. This natural partnership is delivering joint
outcomes and paving the way for Natural England, whilst
continuing to deliver their separate and respective statutory
duties:
— English Nature is the independent
Government agency that champions the conservation of wildlife
and geology throughout England.
— The Rural Development Service
is the largest deliverer of the England Rural Development Programme
and a range of advisory and regulatory rural services.
— The aim of Countryside Agency's Landscape,
Access and Recreation division is to help everyone respect,
protect and enjoy the countryside.
This consultation response has been produced
by English Nature. English Nature is working with the Rural Development
Service and the Countryside Agency's Landscape, Access and Recreation
division to create Natural England, a new agency for people,
places and nature.
BACKGROUND
5. English Nature wishes to see an objective
assessment of the likely impacts of all major proposed changes
in technology deployment in the countryside so that decisions,
particularly about public financial support, can be made from
a good evidence base. In our view some deployments of bioenergy
technology, particularly where they are small-scale and introduce
heterogeneity into otherwise homogeneous intensive agricultural
landscapes have the potential to be beneficial. Conversely the
large-scale industrial production of bioenergy is likely, in many
cases, to have a severe environmental downside.
6. Our current energy demand is now so great
that providing even a proportion of it from bioenergy is likely
to result in significant impacts on biodiversity, either directly
(eg crop production) or indirectly (eg opportunity costs of removing
farmland, funding etc from other potential end uses). There is
a danger that by over-reliance on `renewables' such as biofuels
to deliver climate change targets, attention may be distracted
from the wider issues of energy efficiency and demand management.
7. While Government policy clearly states
that the main justification for public support for bioenergy is
its potential for climate change mitigation, we recognise that
various forms of bioenergy may also have other benefits, such
as energy security, rural development, employment in rural areas,
biodiversity and reduction of waste going to landfill. However,
there are potential dangers in confusing policy objectives—for
example, attempting to tackle both climate change and rural development
using the same funding stream may result in the inefficient delivery
of both objectives.
UK POTENTIAL FOR
PRODUCING BIOENERGY
8. Most forms of bioenergy are not carbon-neutral
because of the energy inputs needed to grow biomass and convert
it into useful fuel. For example, producing biodiesel from oilseed
rape still results in around 40% of the greenhouse gas (GHG) emissions
produced by fossil diesel (Mortimer et al 2003). However,
some forms of bioenergy can be carbon-neutral or even carbon-negative—for
example anaerobic digestion of organic wastes may approach or
even exceed 100% GHG saving due to avoided landfill emissions
of methane, a GHG 21 times more potent than CO2 (HM
Revenue & Customs/HM Treasury 2005).
9. Various assessments have been made of
the potential for UK bioenergy production and its contribution
to climate change abatement. Agronomically speaking, domestically-grown
arable crops (oilseed rape, wheat and sugar beet) could probably
produce up to 5% of our current terrestrial transport fuel requirements
without impacting significantly on domestic food production, by
using existing food crops that would otherwise be exported and
by growing biofuel crops on set-aside land. This could represent
a total area of around 1 million ha—one-sixth of the UK
arable area. To put this into context, we calculate that oilseed
rape grown for biodiesel could mitigate around 1.7 tonnes of GHG
emissions (measured as CO2 equivalents) per hectare
per year, wheat for bioethanol 2.8 tCO2eq/ha/yr and
sugar beet for bioethanol 4.0 tCO2eq/ha/yr (based on
figures from Elsayed et al 2003). Growing a mixture of
these crops over 1 million ha could potentially reduce UK GHG
emissions by around 2.5 million tonnes per year. This is equivalent
to 0.37% of total UK greenhouse gas emissions for 2004 (672 million
tonnes CO2 eq, Defra 2004). In our view this represents
a relatively small GHG benefit for a large area of land.
10. Perennial energy crops (short rotation
coppice (SRC) willow and Miscanthus and short rotation forestry
(SRF) using either native or exotic species) could save significantly
more GHG emissions per hectare than arable biofuels. SRC willow
or Miscanthus grown on set-aside and used in small-scale CHP can
potentially save around 10 tCO2eq/ha/year in comparison
to leaving the set-aside fallow and using natural gas CHP (Elsayed
et al 2003). An area of 0.5 million ha of SRC willow might
be agronomically feasible and if used for this purpose could abate
around 5 million tonnes of CO2 per year, or 0.75% of
total UK emissions.
11. Although growing up to 1.5 million ha
of bioenergy crops may be agronomically feasible, there
may be both direct and indirect environmental impacts. These are
addressed later on in the submission.
ALTERNATIVES TO
INCREASING CROPPING
12. Dedicated biomass crop production is
just one route for producing bioenergy. However, there are already
significant biomass resources in England that can be used to generate
heat, power, gas and liquid fuels, without needing to increase
crop production. Turley et al (2003) estimated that 100,000
tonnes of biodiesel could be produced by processing waste oils
from the food industry—effectively substituting for 90,000
ha of oilseed rape. Forestry thinnings, arboricultural arisings,
woodland coppicing and other waste wood products (sawdust, pallets
etc), can provide wood chips or pellets for electricity and/or
heat production from domestic to industrial scale. Some biomass
sources have additional environmental benefits: woodland coppicing
is important in improving conservation status of woodlands, while
anaerobic digestion of animal manures and other organic wastes
can help prevent emissions of methane into the atmosphere and
reduce nutrient pollution and landfill volumes. Other organisations
are better placed to estimate availability of these resources,
but in our view a high priority should be placed on using existing
sources of biomass, to reduce the need to dedicate large areas
of land to growing biomass.
RELATIVE COST
EFFECTIVENESS
13. Mortimer et al (2003) found that installing
glass fibre loft insulation in domestic dwellings (506 kg CO2eq
saved per £) was over 100 times more cost-effective than
biodiesel production from oilseed rape at a fuel duty derogation
rate of 20p/l (4.5 kg CO2eq saved per £). Heat
or electricity from woodchips could save four times more greenhouse
gas emissions per £ than biodiesel (18 kg/£). This reinforces
English Nature's view that the Government's top priority for climate
change policy should be to reduce energy demand, as this is where
the greatest reductions in GHG emissions can be achieved in the
short and medium term.
ROLE OF
AGRICULTURE IN
REDUCING GREENHOUSE
GAS EMISSIONS
14. Agriculture was responsible for 7% of
total UK greenhouse gas emissions in 2003 (National Statistics
2005). On the other hand, agricultural land management can also
contribute to carbon sequestration in soils and vegetation. The
Government's Climate Change Programme Review (not yet published)
has included an assessment of how GHG emissions from agriculture
can be reduced. Methods include reducing use of artificial fertilisers
and use of no-till systems, organic farming, clover or other legumes
to fix atmospheric nitrogen, crops with lower nutrient requirements,
woodland regeneration, anaerobic digestion of animal manures and
use of biomass energy/biofuels on farms.
15. To maximise abatement of GHG emissions
these practices should be used on all farms, not just those growing
energy crops. However, we should be particularly conscious of
the GHG balance of energy crop production, because emissions savings
are the main justification for Government support. By encouraging
best practice in growing energy crops Government can therefore
maximise GHG savings in terms of kgCO2eq/£.
16. However, some farming practices that
cut GHG emissions could result in other kinds of environmental
harm. For example, one study suggested that growing genetically
modified herbicide tolerant sugar beet could result in reduced
GHG emissions because it needed fewer machinery passes (Bennett
et al 2004). But evidence from the Farm Scale Evaluations programme
shows clearly that growing these crops with the associated herbicide
regime would result in a significant loss of biodiversity (Firbank
et al 2003). Government should be very careful to avoid
putting in place policies to deliver climate change targets that
are likely to harm our ability to meet other important environmental
targets.
ENVIRONMENTAL IMPACTS
OF EXPANDING
UK AND EU AREAS
OF ENERGY
CROPS
17. There have been a number of studies
assessing likely impacts of expanding areas of energy crops in
the UK. Turley et al (2003) concluded that arable biofuels
(wheat, sugar beet and oilseed rape) are unlikely to expand outside
of existing production areas but could be grown more intensively
within these areas. Some farmers are already growing rotations
of wheat/rape/wheat/rape, although this can prove an agronomic
challenge due to increased pest and disease pressure in the rape.
Agronomists advise increasing the range of seed treatments and
fungicide sprays on oilseed rape in these rotations (Monsanto
2004). This suggests that biofuels could accelerate a trend towards
less diverse rotations with a greater reliance on chemical inputs
to tackle pests and diseases—a trend that is unlikely to
offer benefits for the environment.
18. There is evidence that uncropped set-aside
generally supports more biodiversity than land under intensively-grown
arable crops (e.g. Buckingham et al 1999). Compulsory set-aside
in England is currently 8% of the arable area, although this varies
from year to year. A switch to growing biofuels on set-aside land
could cause the loss of around 400,000 ha of uncropped land to
winter wheat and winter oilseed rape, which would result in loss
of biodiversity, especially seed-eating farmland birds. This could
lead to slippage on targets for the Farmland Birds PSA and UK
Biodiversity Action Plan. The newly-launched Environmental Stewardship
scheme aims to help deliver these targets but was not designed
to cope with the impacts of an increasing area of arable crops
or widespread loss of set-aside in England. This means that additional
measures may be required to mitigate impacts on biodiversity,
water resources and soils.
19. However, perennial crops such as SRC
willow and Miscanthus could add structural diversity to some landscapes.
A recent study apparently showed higher levels of biodiversity
in SRC willow compared to intensive arable and grassland crops
(Sage et al unpublished). These benefits seem to depend
on a number of factors such as maintaining a mixed age structure,
leaving areas of bare ground and breaking up plantations into
smaller segments, as these are all important in increasing habitat
diversity. Willow and Miscanthus are generally grown with a relatively
low input regime, with likely benefits for biodiversity, soils
and water quality, but this could change if pest problems start
to build up and/or there is economic pressure to increase productivity.
20. The Forestry Commission recently funded
a study on the potential impacts of short rotation forestry (Forestry
Commission, unpublished), which suggested that SRF could be compatible
with protection of biodiversity, soils and hydrology provided
that care was taken to select the right species and design the
plantations to fit in with existing habitats and features. However,
it cautioned that the highest-yielding, most profitable species
(eg Eucalyptus spp) were associated with negative environmental
impacts, emphasising the need for public funds to support species
choice and management practices that deliver wider public goods.
21. Low-intensity, high-biodiversity land
uses need to be protected from replacement with energy crops.
Currently this is achieved through the Forestry EIA Regulations
and the Uncultivated Land EIA Regulations, and it is vital that
this system continues to be effective in the face of rising numbers
of applications to ensure protection of biodiversity, soils and
water resources.
22. Elsewhere in the EU, it has been suggested
that the Central and Eastern European countries have greatest
potential for expansion of the biomass sector and these could
produce enough excess biomass to export to Western Europe (preliminary
report of the VIEWLS project, unpublished). In our view this could
cause massive biodiversity loss through the intensification of
agriculture in these areas, where small-scale low intensity farming
currently dominates. It would be a dangerous strategy for the
UK to rely on imports from these countries to make up any biomass
shortfall.
SUSTAINABILITY ISSUES
RELATED TO
GLOBAL TRADE
IN BIOMASS
AND BIOFUELS
23. The UK is a net importer of food and
there is relatively little spare capacity within our agricultural
land to produce biofuels or biomass crops without displacing some
production abroad. In fact, importing processed biofuels such
as bioethanol from Brazil could potentially deliver substantially
greater GHG savings than producing ethanol domestically from wheat
and sugar beet, because sugar cane requires far lower energy inputs
to grow and process.
24. However, climate change is only one
consideration. Much potential for expanding production of liquid
biofuels is assumed to exist in tropical regions which still contain
significant areas of important natural habitat. Experience from
past and current trends in expansion of soyabeans, sugar cane
and oil palm indicates that there is a real danger that increasing
production in these areas will lead directly to further losses
of natural habitats like tropical rainforests and savannas. In
addition to the potential massive impacts on biodiversity and
ecosystem services, clearing rainforests for cultivation leads
to immediate and massive losses of carbon dioxide and other GHG
into the atmosphere: several decades of continuous energy crop
production would be needed to recover the GHG released by cutting
down tropical forests.
25. In our view, a crucial instrument to
help avoid damage to biodiversity both in the UK and abroad will
be a robust carbon and environmental sustainability certification
scheme. Some work is currently being carried out by the Low Carbon
Vehicle Partnership (LowCVP) to develop an industry certification
scheme, aiming to create a standard that all companies producing
biofuels could sign up to. There is currently pressure for a certification
to be only a voluntary measure, but English Nature has a strong
preference for linking certification to receiving certificates
through the Renewable Transport Fuel Obligation (RTFO). Government
should send a strong message that imports of unsustainably produced
biofuels are unacceptable and should not receive public funding.
English Nature
February 2006
REFERENCES
Bennett R, Phipps R, Strange A and Grey P (2004).
Environmental and human health impacts of growing genetically
modified herbicide-tolerant sugar beet: a life-cycle assessment.
Plant Biotechnology Journal 2 (4), 273.
Buckingham, DL, Evans, AD, Morris, AJ, Orsman,
CJ & Yaxley, R (1999) Use of set-aside land in winter by declining
farmland bird species in the UK. Bird Study 46: 157-169.
Elsayed MA, Matthews R, and Mortimer ND (2003).
Carbon and energy balances for a range of biofuels options.
Resources Research Unit, School of Environment, Sheffield Hallam
University.
Firbank, LG, Perry, JN, Squire, GR, Bohan, DA,
Brooks, DR, Champion, GT, Clark, SJ, Daniels, RE, Dewar, AM, Haughton,
AJ, Hawes, C, Heard, MS, Hill, MO, May, MJ, Osborne, JL, Rothery,
P, Scott, RJ & Woiwod, IP (2003) The implications of spring-sown
genetically modified herbicide-tolerant crops for farmland biodiversity:
A commentary on the Farm Scale Evaluations of Spring Sown Crops.
ISBN 0-85521-036-2. Published on the Defra website:
http://www.defra.gov.uk/environment/gm/fse/index.htm
Revenue & Customs/HM Treasury (2005). Partial
regulatory impact assessment on an enhanced capital allowance
for biofuels production.
Monsanto (2004). Tightening rape rotations demand
new management approach. http://www.monsanto-ag.co.uk/layout/resources/news/oilseed/2004/08-04.asp
Mortimer ND, Cormack P, Elsayed MA and Horne
RE (2003). Evaluation of the comparative energy, global warming
and socio-economic costs and benefits of biodiesel. Report
No 20/1 for the Department for Environment, Food and Rural Affairs,
Resources Research Unit, Sheffield Hallam University, Sheffield,
United Kingdom, January 2003.
National Statistics (2005).
http://www.statistics.gov.uk/downloads/theme—environment/EANov05.pdf
Turley, DB, Boatman, ND, Ceddia, G, Barker,
D, and Watola, G (2003). Liquid biofuels—prospects and
potential impacts on UK agriculture, the farmed environment, landscape
and rural economy. Defra report.
Sage R et al (unpublished).
See press release at http://www.gct.org.uk/article.asp?PageId=78&ArticleId=160
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