Memorandum submitted by The Royal Society
for the Protection of Birds (Bio 10)
SUMMARY
1. The RSPB believes that bioenergy could
play an important role in helping meet the UK's greenhouse gas
emissions as part of a mix of renewable energy sources. This potential
can only be realised sustainably, however, if a strategic framework
is in place to ensure genuine emissions savings are made and that
this is not at the expense of biodiversity and the wider environment.
INTRODUCTION
2. The RSPB considers that human-induced
climate change poses the biggest long-term threat to global biodiversity.
We therefore support policies and measures that reduce the anthropogenic
greenhouse gas emissions that cause climate change. The RSPB endorses
the UK Government's aim to cut emissions by 60% by 2050, a target
that we should try hard to surpass. The RSPB is a founder member
of Stop Climate Chaos, a coalition of environment, development,
faith-based and other organisations campaigning to limit climate
change. Global CO2 pollution needs to peak by 2015
and decline steeply thereafter to stay within the 2C average
global temperature increase widely held to be the limit of "safe"
global warming. To be reasonably sure of staying below the 2oC
target, absolute emission reduction rates of 3% per annum are
likely to be required.
3. Climate change and the alarming rate
of biodiversity decline worldwide are the most critical environmental
challenges society faces today; a point that was recently voiced
by former Government Chief Scientist, Lord May. Policy should
therefore strive to address both. As a minimum, tackling one must
not unnecessarily exacerbate the other. Government is committed
to addressing biodiversity loss through a number of targets, including
the EU commitment to halt biodiversity loss and the Public Service
Agreement to reverse the decline in farmland birds.
4. The RSPB supports the use of bioenergy
as part of a wider climate change mitigation strategy and believe
that bioenergy could play an important role in the UK's mix of
renewable energy sources. However, this support is contingent
on a strategic framework designed to ensure the industry's development
has minimal negative impacts upon biodiversity, locally and globally,
and offers genuine and proven reductions in greenhouse gas emissions.
This framework should include:
(i) A spatial plan for bioenergy development
based on a comprehensive understanding of the social and environmental
implications of growing biomass at a large scale.
(ii) Provision for the incremental development
of bioenergy with ongoing monitoring and scheduled review points,
similar to that seen in the second round of offshore wind power
development.
(iii) A robust strategic environmental assessment
and the application of Environmental Impact Assessments of bioenergy
developments at the local level.
(iv) Accreditation for all bioenergy, covering
greenhouse gas emissions throughout the full life-cycle of the
product and minimum environmental standards.
5. We believe it is critical that these
concerns are at the heart of a policy framework designed to encourage
bioenergy, and that the industry's credibility will be dependant
on this. This means that environmental impacts must be factored
in to bioenergy's development from an early stage—a lesson
learnt from the development of other renewable energies, such
as onshore wind. If a well designed framework is in place, integrated
solutions and win-wins are possible. If it is badly designed,
we can see bioenergy further exacerbating biodiversity losses.
Question 1: What is the real scope for biomass
and biofuels to contribute to tackling climate change? What proportion
of the UK's energy and transport supply could they provide?
6. Bioenergy is not a silver bullet, able
to solve climate change while reversing the fortunes of struggling
farmers, and we are deeply concerned that it is being portrayed
in this way. In reality, there is already considerable demand
for land, and the use of land to produce biomass and biofuels
may carry a significant opportunity cost as it competes with the
use of that land for producing food, other non-food crops and
conservation.
7. The real question is therefore not what
proportion could they supply, but what proportion should
they supply. The answer should be guided by the public benefit
generated from each use, and the demands of the market. In particular,
land should not be used for bioenergy at a scale where it would
either endanger the supply and cost of food, particularly to developing
countries, or damage biodiversity through displacing other, important
land-uses.
Question 4: Not all biomass is equal—potential
carbon savings depend on, for instance, farming practice. What
can be done to ensure energy crops are sustainably produced?
8. As part of a strategic framework for
sustainable bioenergy development, Strategic Environmental Assessment
should be applied to bioenergy before production is taken up to
a significant level, and this should guide future developments.
Environmental Impact Assessments will be necessary at the local
level to steer development of biomass away from environmental
conflict. This will need to be supported by clear guidance at
a national level to encourage solutions that recognise the need
to conserve the environment and biodiversity when planning for
biomass developments.
9. As part of a spatial plan for bioenergy,
the land use implications of high-level policies to encourage
bioenergy need to be assessed. Impacts should be monitored and
regularly reviewed in order to identify and react to unforeseen
environmental impacts. For example, excessive demand for wood
and short rotation coppice could place massive pressure for restocking
and new planting of fast growing conifers with potential adverse
impact on high biodiversity value areas of open ground habitat.
10. Accreditation for bioenergy will be
required to ensure genuine lifecycle greenhouse gas emission savings
are made and minimum sustainability standards are adhered to,
so that biofuel development does not undermine Government's wider
commitments, including reversing the decline in farmland birds
by 2020.
11. Accreditation for bioenergy is necessary
as the greenhouse gas emissions savings and wider environmental
impacts vary widely according to life cycles. This is particularly
true for bioenergy from energy crops, as shown in the divergent
results that emerged from the three major well-to-wheel studies
that contributed to the Government's recent analysis of biofuels.
Their studies found, for example, that the emissions savings from
replacing petrol with bioethanol from sugar beet ranged from 63%
to -11% (ie an increase in emissions of 11%). A similarly diverse
impact on biodiversity can be seen (see Question 7).
12. As a result, the RSPB believes it to
be imperative that an accreditation scheme is developed alongside
a Renewable Fuels Obligation.
13. We envisage this scheme accrediting
those biofuels that offer life cycles emissions savings over single
or multiple threshold values, or in direct proportion to the emission
savings compared to traditional fossil fuel equivalents. Only
accredited fuels should count towards meeting Renewable Fuels
Obligation commitments. Accreditation should encourage carbon
optimal input management, ie management designed to maximise the
emissions savings through efficient use of energy inputs. This
requires, among other things, achieving the optimal balance between
fertiliser input and yield, as fertiliser use is usually the single
largest contributor to greenhouse gas emissions in the life-cycle
of a biofuel.
14. Much technical work on accreditation
has been conducted through the fuels subgroup of the Low-carbon
Vehicles Partnership, a stakeholder group established by Defra,
which we hope will feed into the development of an accreditation
scheme.
15. Environmental standards are needed as
part of an assurance scheme to ensure that in meeting the primary
objective of reducing greenhouse gases, sustainability is not
undermined by unnecessary damage to the wider environment. These
standards should be designed to safeguard biofuel development
from adversely impacting upon biodiversity, soil and water. Some
of the standards that would need to be included are:
— The protection of important habitats
from conversion into bioenergy production, including, for example,
set-aside, semi-natural grasslands and peat bogs;
— Ensuring appropriate scale and spatial
distribution of bioenergy crops to avoid damaging monocultures
and consequent loss in landscape heterogeneity;
16. The fuels subgroup of the Low-carbon
Vehicles Partnership have commissioned a study to develop possible
criteria that would meet these requirements, but the results were
not available in time for this Enquiry.
17. Environmental accreditation for forestry
and short rotation coppice (SRC) is well developed, providing
a good basis for the environmental standards that would be required
for accreditation of bioenergy from forestry and SRC. Carbon accreditation
for this sector is yet to be developed.
18. We recommend that the UK Woodland Assurance
Scheme is used to certify the sustainable management of forestry
and woodland management for biomass objectives, including agricultural
short rotation coppice, with linked use of Forest Stewardship
Council Chain-of-Custody traceable certification of the resultant
wood/timber products.
Question 6: What level of financial and policy
support for bioenergy technologies require in order to achieve
the Government's targets for renewable energy?
19. The RSPB believes that a policy framework
based on a combination of incentives and regulation needs to be
in place to support the development of a sustainable bioenergy
sector.
20. Policy support for bioenergy should
be demand based, with the aim of building a thriving energy market
that rewards low carbon fuels. This means that the focus should
be on providing incentives for renewable, sustainable technologies,
through grants and differential taxation. Supply based support,
such as direct subsidies for energy crop production, should not
be used. Our experience with the Common Agricultural Policy has
shown that the use of similar subsidies for food production has
had a detrimental impact on biodiversity and the wider environment,
and that building a supply base without securing a market is an
ineffective long-term strategy for the development of a self-sustaining
industry.
Question 7: What impact might an increase in energy
crops in the UK and the rest of the EU have on biodiversity, production
of food crops and land use and the environment more generally?
21. The overall impact of large-scale bioenergy
crop production on farmland biodiversity will depend largely on
the crops in question and the land-use type they replace. As part
of a strategic plan for bioenergy development, we recommend a
spatial plan is developed to identify possible areas for bioenergy
developments and that this is accompanied with best practice guidance.
The aim of this plan should be to deliver multiple public benefits,
including, for example, biodiversity, water quality, landscape
and access, and minimise any adverse impacts.
A. Previous land-use
22. Where bioenergy crops are grown on intensively
managed farmland, research shows overall bird species diversity
and breeding density in the local area may be either little affected
or increased as a result.
23. Loss of high wildlife value habitats
such as wetlands, wet meadows, extensively managed semi-natural
grassland and scrub through conversion to bioenergy crops will
have negative impacts on some bird species and other components
of farmland biodiversity. Marginal farmland habitats such as hedgerows
and small areas of unmanaged grassland also provide valuable wildlife
habitats and any net loss of these due to bioenergy crop planting
is likely to have negative effects.
24. The most immediate threat posed to biodiversity
is the loss of set-aside to bioenergy crops. This is of particular
concern as set-aside land is known to provide important feeding
and nesting resources for many farmland birds. In the breeding
season, set-aside holds relatively high densities of many bird
species, compared to other arable land-use types and provides
important nesting opportunities for species of high conservation
concern. 80% of the wintering population of linnets East Anglia
spend winter on set-aside, compared to only 1% on winter cereals.
The UK linnet population has already declined by 48% since 1970.
25. We accept that set-aside is an illogical
anomaly in the new decoupled, market-oriented system. The RSPB
believes that it should be phased out and the benefits it provides
should be brought into the Stewardship scheme so that farmers
are rewarded appropriately. Currently, the Government's farmland
bird Quality of Life indicator is levelling off, although the
overall decline in farmland bird populations has not yet been
reversed. Factors which are likely to have contributed to the
levelling off of the Index include milder winters, agri-environment
schemes, and set-aside. The impacts of the new Entry Level Scheme
are not yet apparent in the Index, as the data pre-date the launch
in spring 2005. It is clear that the rapid loss of set-aside to
bioenergy crops without a parallel process of putting an equivalent
amount of land into wildlife management is likely to put populations
back into decline.
26. A spatial plan for bioenergy production
should consider the future biodiversity potential of land as well
as assess its current value. Unregulated coppicing of willow may
lead to the loss of land with high potential to deliver public
benefit through wetland habitat creation. The wetland vision being
produced by the Environment Agency, English Nature, the RSPB and
the Wildlife Trusts should provide guidance here.
B. Bioenergy crops
27. While an increased production of conventional
crops, such as oilseed rape, sugar beet and wheat, is unlikely
to have a significant impact on biodiversity in itself, the large
scale cultivation of new crops, including woody crops and perennial
grasses, represents a considerable ecological shift from conventional
farmland habitats. The RSPB carried out a review of the known
and potential effect on biodiversity of energy crops in the UK
in 2003 the results of the study are summarised below.
28. Short rotation coppice (SRC) has been
found to host a generally higher density and variety of bird species
than is usually seen on arable land or improved grasslands. Types
of bird species depend on the age of the plantation. Young crops
attract birds that prefer open landscapes, including a number
of species that are of medium or high conservation concern in
the UK such as the lapwing, skylark, meadow pipit, wagtail and
corn bunting. Mature plantations generally host more common species
that are currently of low-medium conservation concern, such as
the pheasant, robin and blackbird. SRC plantations also support
higher invertebrate populations than conventional crop types and
as input requirements are low, there is the potential for diverse
plant communities to be supported. These results come almost entirely
from studies of relatively small pre-commercial SRC plantations,
larger commercial plantations may have different advantages and
disadvantages.
29. Little is known of the potential impact
that perennial grasses, such as Miscanthus, canary grass and switchgrass,
could have in the UK and Europe. They are unlikely to provide
seed food, and are not suitable habitats for open ground species.
However, they may prove suitable habitats for species characteristic
of reedbeds and dense herbaceous vegetation or scrub, eg reed
warbler and reed bunting. Plantations are likely to host a diversity
of invertebrates unless widespread cultivation leads to known
pests causing problems and results in increased pesticide use.
30. It is the management regime of the bioenergy
crop that will ultimately determine their impact on biodiversity
and the wider environment. For example, increases in the area
of spring-sown crops are likely to have major benefits for farmland
birds, such as skylarks and yellow wagtails. Currently, guidelines
are best developed for conventional crops. Of the novel crops,
only SRC has recognised guidelines. These have the specific aim
of increasing the biodiversity value of the crop by including
features such as rides, headlands and stands of different age-class
to increase habitat heterogeneity.
31. In the medium to long term, Genetically
Modified (GM) bioenergy crops may enter the market. We are already
aware of GM drought tolerant, salt tolerant and frost tolerant
bioenergy crops being developed. As with all GM crops, the RSPB
believes it is imperative that these are assessed on a case-by-case
basis to determine impacts on biodiversity, using a methodology
based on the recent Farm Scale Evaluations. These varieties pose
further risk as they are likely to be grown in areas that are
not currently intensively cropped and are of high biodiversity
value.
C. Scale and spatial distribution of bioenergy
crops
32. As with all crops, the scale and spatial
distribution of energy crops will greatly determine their impact
on birds and the wider environment. The level at which bioenergy
is produced will determine these factors. Generation could either
be:
— Large-scale and based on a national
transmission network fuelled by large generating units; or,
— At the local-level and based on small
production units that form part of a distributed generation network.
33. Current infrastructure and policy strongly
favour the first option. Economies of scale, transport costs and
other practical factors encourage crops to be grown (or imported)
in close proximity to where they are processed, as is seen in
the sugar industry. This is reflected by UK grant funding for
bioenergy crops, which specifies that they should be grown as
close as possible to the end user, usually within 25 miles. Large-scale
generation is therefore likely to result in significant simplification
of the landscape in terms of habitats and vegetation structure
as large uniform areas of bioenergy crop are produced in the area
surrounding the processing facility. It is likely that this spatial
arrangement of bioenergy crops will reduce the biodiversity benefits
of the crops themselves, making small-scale generation preferable
from this perspective.
D. Biomass from forestry
34. While not an "energy crop"
per se, the environmental impact of biomass production
in forestry is potentially wide ranging and thus important to
highlight here. It includes damage to existing habitats and species
through increased felling activity, planting in inappropriate
areas, restocking areas with trees in areas which would be better
restored to important non- wooded UK Biodiversity Action Plan
priority habitats. On the other hand, increased markets for wood
and timber products could encourage beneficial woodland management
in neglected and under managed woods where biodiversity is in
decline.
35. Carefully managed, smaller scale rural
development projects that use coniferous plantation forest residues
and existing coppice wood chipped or pelleted for local heating,
could support the restoration of coppice management in lowland
woods and native woodland management. This is an example of a
"win-win" bioenergy development that would be positive
nature conservation measure while also aiding rural development
and climate change mitigation.
36. The strategic planning of forestry biomass
should recognise the potential for very large wood/timber demand
from power generating stations. This could have serious implications
on transport infrastructure and on carbon emissions from increased
haulage. It may also result in the retention of remote "timber"
plantations on restorable open-ground habitats, or short rotation
coppice of low biodiversity value on important agricultural habitats.
37. It is also important to address the
potential import of significant quantities of timber and timber
products, in line with the UK Government's commitments in the
UK Forest Partnership for Action, to ensure that procurement from
abroad is environmentally sustainable.
Question 8: Does bioenergy production constitute
the best use of UK land for non-food crops? Should UK and EU policy
focus on increasing domestic production of energy crops and biomass,
or are there merits in importing biomass for energy production,
or raw feedstock or refined biofuel, from outside the EU?
38. A certain amount of bioenergy and bioenergy
feedstocks, particularly biofuels, will inevitably come from abroad.
This is not inherently negative, though the costs of transport
to the environment must be accounted for. Indeed, imported bioenergy
may make a valuable contribution to sustainable development, but
only if there is an international accreditation scheme in place
to ensure imports meet the same standards as domestically produced
feedstocks and bioenergy products.
39. The most significant risks posed by
bioenergy production from outside the EU arise from the production
of sugar cane for conversion into bioethanol and palm oil and
soy into biodiesel. Sugar cane has very little biodiversity value
and continues to expand at the expense of globally important natural
habitats. Our BirdLife International partner in Brazil has identified
sugar cane expansion as a key driver of the destruction of the
Cerrado, a savannah-like habitat that is home to the fourth highest
level of bird diversity in the world. Similarly, Soy expansion
is driving the destruction of rainforest in South America, and
palm oil in Asia. The establishment of oil palm plantations in
Indonesia and Malaysia, for example, is a major driver of lowland
forest lost, one of the most important habitats for biodiversity
in the world.
40. The very real risks posed by bioenergy
development internationally means that the RSPB could not support
bioenergy unless international accreditation was in place. Until
it is, UK and EU policy should focus entirely on domestic production
as it is traceable and the carbon emission savings and sustainability
of the product can be traced and accounted for.
RSPB
February 2006
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