Memorandum submitted by the Environment
Agency (Bio 17)
SUMMARY
1. The Environment Agency welcomes this
opportunity to provide written evidence on some of the issues
surrounding renewable energy and the role of bioenergy. The Environment
Agency is the Government's principal adviser on the environment.
2. We support bioenergy as a renewable source
of energy that contributes to limiting climate change and as a
part of sustainable development. However, adequate safeguards
must be in place to minimise environmental impacts.
3. In considering the role of bioenergy
we offer the following comments:
— Whole life-cycle impacts of bioenergy
should be assessed including net greenhouse gas emissions, environmental
and biodiversity impacts and wider sustainable development contributions.
The Environment Agency has developed a tool to enable environmental
assessment of different biofuels.
— Incentives such as grants, reduced
excise duties or supplier obligations should be focussed on those
technologies and fuels with low environmental impact.
— A certification and labelling scheme
would enable consumers to choose biofuels with the lowest environmental
impact and for any market support to be commensurate with environmental
impact.
— A long-term biofuels strategy would
clarify what role biofuels can play in a low carbon transport
strategy and send important investment signals to fuel suppliers
and vehicle manufacturers.
— A Renewable Heat Obligation or a
targeted capital grants scheme would encourage wider uptake of
bioenergy, beyond the transport sector, and would create a more
consistent approach to supporting renewable energy outside the
electricity sector.
— Energy from waste has a role in sustainable
waste management, provided it does not undermine the prevention,
minimisation or recycling of waste. At present most of the waste
strategy incentives favour diversion from landfill, but not necessarily
towards the higher end of the waste hierarchy, for example, waste
minimisation and resource efficiency.
— Co-firing is an efficient form of
biomass use, but any support for co-firing should avoid creating
perverse incentives, for example to switch from gas to coal generation.
— There is a good case for support
for small-scale use of wood fuels meeting the needs of local communities
in particular in areas where there are homes off the gas grid
or concentrations of fuel poverty.
INTRODUCTION
4. Bioenergy is usually produced from combustion
of plant material or organic wastes in the form of biomass or
biofuels, such as biodiesel or ethanol. Bioenergy use can reduce
fossil fuel pollution and is a form of renewable energy. Whenever
fossil fuel is substituted by bioenergy, overall emissions are
commonly reduced as each growth cycle, driven by solar energy,
takes up most of the equivalent carbon dioxide (CO2)
that is released in combustion and processing.
5. Making bioenergy from waste can avoid
the disposal of this waste through landfill or direct incineration.
In addition, using waste vegetable oil and fats as fuels is important
now that these can no longer be mixed in with animal feed. This
can contribute to sustainable waste management, and reduces our
dependence on non-renewable energy.
THE ENVIRONMENT
AGENCY ROLE
IN BIOENERGY
6. Our role in biomass includes regulation
of waste and aspects of agriculture, pollution permitting for
large biomass plants and as a statutory consultee in the planning
system. The permits and consents required for developing a new
plant vary depending on the proposal.
7. Producing bioenergy (whether from crops
or wastes) requires a range of permits, such as pollution control,
and we require developers to work with us to ensure statutory
arrangements and planning permission are all in place.
ENVIRONMENTAL IMPACTS
OF BIOCROPS
8. Different forms of bioenergy have varying
degrees of environmental impact. Our concerns range from large
scale changes to land use for energy crops, impacts on water resources,
soils, and biodiversity, the handling and reuse of wastes as fuel,
and emissions from power stations. Carbon savings are undermined
if rainforests are cleared to grow biocrops, fertilisers are used
extensively, fuels are transported excessive distances, or if
processing plants are powered by inefficient use of fossil fuels.
9. Impacts depend on a variety of factors
such as the type of crop, its location and how it is managed.
For example, sugar beet and miscanthus are late harvesting crops,
which can lead to soil erosion problems that one would see less
of with oilseed rape. However, oilseed rape causes problems with
nitrate leaching (with losses of approximately 77kg of nitrogen
per hectare) that are more serious than for these other crops.
10. The European Commission promotes the
use of set-aside land for the growth of bioenergy crops. Taking
land out of production and increasing the amount of organic matter
contained in soils acts to decrease levels of atmospheric greenhouse
gases. Such use could lead to negative environmental impacts.
Soils, wildlife and water would need to be suitably protected.
It may also increase emissions of carbon. For example, practice
has shown that SRC willow grown on set-aside land leads to an
increase in CO2 emissions. In contrast, when SRC willow
is grown in place of arable production carbon emissions are shown
to decrease.
11. Even where good practice is followed,
some areas may not be suited to certain crops. For example, SRC
willow is likely to have serious implications for water resources
in drought prone areas, but could help prevent flooding by reducing
the level of extreme flows. Software is currently being developed
by the Centre for Ecology and Hydrology, which should provide
information to allow biomass crop impacts on water resources to
be modelled more accurately.
12. Ultimately the question of which crops
are most suited to which circumstances should be dependent on
a full life cycle assessment of the various potential options.
This should be supported by growers' code of practice, perhaps
based on the guidelines adopted as part of the Energy Crops Scheme.
13. As part of our commitment towards developing
sustainable new bioenergy capacity, we have developed the Biomass
Environmental Assessment Tool (BEAT). It was developed within
our science programme to ensure the wider impacts of biomass facilities
can be assessed to minimise overall environmental impacts (from
areas such as crop production methods and transport) and to maximise
sustainable development benefits. BEAT has recently been deployed
to all our staff dealing with biomass facility proposals.
BIOFUELS FOR
TRANSPORT
14. Road transport accounts for a growing
proportion of UK CO2 emissions, currently around 22%.
Using liquid biofuels in vehicles can cut overall carbon dioxide
emissions by replacing fossil fuels.
15. The EU Biofuels directive (2003/30/EC)
promotes bioethanol and biodiesel for use in transport. The directive
requires each member state to have a suggested target of 5.75%
of all petrol and diesel sold by 2010, measured by energy content.
Current policy allows for blends of up to 5% by volume (equating
to a lower share by energy content because biofuels have lower
energy density than fossil fuels). In November 2005 the UK government
announced its intention to introduce a Renewable Transport Fuels
Obligation (RTFO) which would require 5% of all UK fuel sold on
UK forecourts to come from a renewable source by 2010.
16. In the short term there may be enough
organic resources to make biofuels even with an expansion in biomass
energy at the same time. In terms of energy yield the RCEP[40]
argues that heat and power are a better use of the same resource
if there has to be a choice. In the long term biofuels will be
based on woody biomass with more efficient technologies, so the
likely competition for land and crops will have to be assessed
and a balance set.
17. Biofuels may be used instead of conventional
vehicle fuels or blended with them. In the short-term, blends
that work in current vehicle engines are the most practical option,
such as bioethanol (5-20%, with petrol).
18. Several hundred thousand vehicles running
on biodiesel from 100% vegetable oils and animal fats are already
in use in Europe. The UK is a long way behind other EU member
states—for example, in 2004 the UK produced 9,000 tonnes
of biodiesel compared to Germany's 1,035,000 tonnes and France's
348,000 tonnes[41].
Although fossil fuel energy may still be used in production, there
is an overall net carbon saving of between 40% and 57% compared
to fossil diesel (depending on how the product is produced and
shipped). Biodiesel from waste oils is the only biofuel currently
in production in this country. Vehicles running on biofuels from
waste should not require individual waste permits. However, a
long-term biofuels strategy must make clear the regulatory requirements
that apply to biofuel production plants.
19. The recent announcement of the government's
intention to develop a Renewable Transport Fuel's Obligation should
provide a significant boost to the UK biofuel's market. However,
a long-term biofuels strategy is needed and should be part of
an integrated transport, fuel and energy strategy in the context
of climate change. It should also link with rural strategy.
20. For the RTFO and the biofuels strategy
we stress the need for sustainability checks being built into
the system. We recommend the government:
— protect natural resources affected
by expanding the cultivation of biofuel crops at home and abroad
by focusing grants and concessions on low impact options.
— introduce a labelling certification
scheme that enables buyers at the point of sale confidently to
choose biofuels with the lowest overall environmental impact across
the whole life-cycle. This must be independent, credible and transparent.
BIOMASS
21. Despite promotion of both energy crops
and recovery of energy from wastes, and incentives to mix biomass
with coal, UK progress has been slow. Including wastes, crops,
and landfill gas, biomass amounts to 80% of the UK's current renewable
energy (including refuse combustion) used as either heat or power.
Austria and Scandinavian countries have made most progress with
modern biomass energy.
22. A wider life-cycle study of the potential
for use of land for the growth of different biomass crops should
be undertaken, including the consideration of more complex alternative
strategies, such as leaving fields to lie fallow, or using digested
sewage sludge to increase the yield of wood crops. We would be
happy to design such a study.
23. The permits and consents required for
developing new biomass plants vary depending on the proposal.
We support small-scale generation where proportionate and risk
based environmental standards can be maintained. We would like
to see support for small-scale use of wood fuels meeting the needs
of local communities, in particular in areas where there are homes
off the gas grid or concentrations of fuel poverty.
24. Given the RCEP recommendation that it
is better to use biomass resources for heat and electricity we
would like to see Government support for biomass heat at least
comparable with the RTFO. We urge the government to either follow
the RCEP's recommendation to introduce a Renewable Heat Obligation,
or the Biomass Taskforce Report's suggestion for a targeted capital
grants scheme.
ENERGY FROM
WASTE BIOMASS
25. It is clear that energy recovery from
waste is preferable to incineration without energy recovery. All
incinerators regulated by us (those burning over 1 tonne waste/hour)
and burning municipal waste, or sewage sludge now recover energy.
However, policy on energy recovery from waste must not undermine
waste management options that are economically achievable and
more environmentally beneficial. The forthcoming update of the
waste strategy should secure the potential benefits of energy
from waste but only as part of a properly considered integrated
waste management strategy, based on life cycle assessment. Any
such policy should reflect the relative environmental benefits
of waste minimisation, reuse and recycling. At present, the economic
incentives to manage waste at these higher levels of the waste
hierarchy are weak compared to the incentive to divert from landfill
to incineration.
26. Many organic wastes, for example from
food processing, are a potential source of energy and we would
welcome further research and actions to deliver this potential.
Upcoming regulations concerning nutrient additions from spreading
manure on fields may restrict the traditional land application
recovery route for many nutrient rich organic wastes in the future.
We are working with Defra to look for successful and safe ways
to spread organics to land in the medium term. Central to this
will be agreeing a standard which waste derived organic materials
can meet. Other important solutions will be to carefully separate
waste at the point of disposal and designing harmful materials
out of the organic waste streams.
27. There is an environmental case that
burning certain biomass wastes is much cleaner and produces lower
emissions of carbon dioxide than burning fossil fuels. However,
biomass wastes, like fuels, vary in their threat to the environment.
This creates a need for stringent emissions standards and biomass
wastes must meet the requirements of the Waste Framework Directive
and, in some cases, the Waste Incineration Directive (WID). This
is especially so when there is a risk of contamination in the
materials used and a consequential potential for environmental
pollution (eg municipal waste, clinical waste, sewage sludge and
waste wood that has been treated with heavy metals and/or halogenated
chemicals). On the other hand, cleaner biomass wastes such as
vegetable waste from forestry, agriculture and food processing
industry, clean wood, animal carcasses and waste from paper making
are not subject to the controls of the WID. We have produced a
list of 30 such clean wastes that are exempt from the WID. In
order to help the developers of biomass energy, we are planning
to produce a simple guidance on the requirements of environmental
regulations and how to apply for relevant permissions.
CO -FIRING
28. Current indications are that the Renewables
Obligation is supporting increased interest and investment in
the co-firing of biomass in conventional power stations, which
promises to provide a significant proportion of the growth in
the biomass sector. The main problem from co-firing would arise
if it caused coal generation to become more competitive through
the RO. This could cause coal with biomass co-firing to displace
gas-fired CCGT generation—thereby potentially creating a
net carbon emission increase, though that would depend
on how allowances are allocated in the EU emissions trading regime
in future. A large scale uptake of biomass co-firing may also
reduce Renewables Obligation Certificates prices and stall investment
in other renewables. This would only be acceptable if there was
high confidence in the carbon savings arising from biomass co-firing
and the award of ROCs for biomass co-firing was commensurate with
carbon reductions.
CONCLUSIONS
29. The Environment Agency recognises that
bioenergy could make a significant contribution to delivering
UK and global emissions reductions. However, environmental gains
risk being seriously undermined, unless the government introduces
measures to ensure low environmental impacts.
Environment Agency
February 2006
40 RCEP: Biomass as a renewable energy source, 2004. Back
41
European Commission: Biofuel Barometer. EurObserv/ER -EEB 2005. Back
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