Memorandum submitted by Friends of the
Earth Ltd (Bio 23)
SUMMARY
0.1 Friends of the Earth believes that bio-energy
can make a significant and important contribution to tackling
climate change. A sustainable supply could include both domestic
production and some imports. This could bring economic benefits
and jobs and reduce greenhouse gas emissions whilst protecting
and even enhancing biodiversity and environmental quality.
0.2 However, biomass production can cause
a range of adverse environmental and social effects. These impacts,
and the benefits of bio-energy for emissions reduction, depend
very much on the biomass used and where and how it is produced.
It is therefore essential that all policy measures to support
bio-energy are accompanied by strong certification schemes to
ensure emissions reductions are achieved and adverse effects minimised.
Given that the sustainable supply is limited, it makes sense for
policy to encourage biomass to be used as efficiently as possible.
Q1. What is the real scope for biomass and
biofuels to contribute to tackling climate change? What proportion
of the UK's energy and transport fuel needs could they provide?
1.1 Friends of the Earth, for the last ten
years, has championed the environmental space approach to ensure
a fair allocation of natural resources and a respect for environmental
limits, so that natural resources are preserved for the future.
This approach is useful in determining the scope for biomass and
biofuels to contribute to tackling climate change.
1.2 The Committee is hopefully familiar
with the per capita approach to the allocation of emissions permits
for carbon emissions—whereby a country's fair share of the
sustainable level of global emissions is considered to be proportional
to the country's share of global population. A similar approach
can be adopted for bio-energy. In this case, the operative limit
for the consumption of bio-energy is the amount of land that can
be allocated to the production of biomass, once sufficient land
has been given over to food production, the preservation of biodiversity
and other essential uses. Measures of output using sustainable
techniques can then be combined with the assessment of land availability
to estimate the sustainable level of biomass production. Extra
biomass can be added from waste arising from forestry, municipal
trees and some crops to give an overall total. Assessments of
this kind have been carried out globally by the German Advisory
Council on Global Change (WBGU)[44]
and for Europe by the European Environment Agency.[45]
1.3 Friends of the Earth has carried out
rough calculations of the sustainable UK consumption, based on
the assumption that we could ethically import biomass up to the
level at which we consume a share of global or European production
equivalent to our share of global or European population minus
an allowance for the energy consumed in producing and transporting
the biomass. This allowance we set, somewhat arbitrarily, at a
third. These calculations suggest to us that the UK may be able
to consume between 132-182 terawatthours (TWh) of energy from
biomass every year. For comparison purposes, the UK currently
uses about 400 TWh of electricity alone (and more than 700 TWh
for heat). Use of this biomass for energy would make a significant
and important contribution to our energy needs. In order to maximise
its impact, policy measures must ensure that it is used as efficiently
as possible.
1.4 We do not make any special claims for
the accuracy of these calculations and would not be surprised
if more sophisticated variants of them doubled the sustainable
supply. However, we believe the principles behind them are right
and that more sophisticated calculations based on these principles
should be an important input into Government policy-making. However,
none of the assessments we have seen of the UK's biomass potential,
including that of the Royal Commission on Environmental Pollution,
do this. There is an urgent need for the calculations to be done.
Q2. How cost-effective are biomass and biofuels
in comparison with other sources of renewable energy? How do biofuels
compare to other renewables, and with conventional fossil-fuels,
in terms of carbon savings over their full life-cycle? 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?
2.1 The key point we would emphasise in
answering these questions is the wide variation in costs, carbon
savings and ancillary impacts between different sources of biomass
and between different uses of biomass and biofuel.
2.2 This variation represents both an opportunity
and a threat. On the one hand, the complex variation in costs
suggests that Government policy should allow market mechanisms
to determine which sources of biomass are used and to what ends
they are put. On the other hand, the wide variation in carbon
savings (and in other environmental and social impacts) suggests
that market mechanisms alone will not be capable of ensuring maximum
carbon savings and minimal adverse social and environmental impact.
2.3 We therefore believe that mechanisms
to promote the use of biomass (eg the Renewables Obligation, the
Renewable Transport Fuel Obligation) should:
— directly target, in so far as is
possible, reductions in greenhouse gas emissions, calculated on
a whole life-cycle basis;
— be accompanied by a strong and mandatory
accreditation scheme to minimise adverse social and environmental
impact.
2.4 A key concern is WTO-compatibility.
We understand WTO rules prohibit the use of controls or incentives
to regulate how imports are produced. However, such controls would
be inherent in any scheme to target incentives toward reductions
in life-cycle emissions and in any strong and mandatory accreditation
scheme.
2.5 The success or failure of attempts to
ensure energy crops are sustainably produced therefore depends
on the extent to which life-cycle incentives and the accreditation
scheme can be made WTO-compatible or on the extent to which WTO
rules can be ignored.
Q3. 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?
3.1 Measures currently planned by the UK
Government, if modified to directly incentivise reductions in
life-cycle greenhouse gas emissions and accompanied by a strong
and mandatory accreditation scheme, could lead to the development
of a sustainable biomass and biofuels industry.
3.2 Much of that industry is likely to be
located inside the European Union, although there may be some
imports. This will bring economic benefits and jobs and reduce
greenhouse gas emissions whilst protecting and even enhancing
biodiversity and environmental quality. The land take required
is not likely to have a detrimental effect on food production.
More measures could also be introduced to increase use of waste
biomass (eg from forestry) and promote the growth of energy crops,
especially to generate heat, without adverse consequences for
biodiversity or the environment more generally.
3.3 However, in the absence of direct incentives
to cut emissions and a strong and mandatory accreditation scheme,
UK Government and EU actions are likely merely to encourage supply
from the cheapest sources. This is likely to lead to production
from intensively farmed rape and grain in the European Union,
using energy-intensive fertilisers that pollute water courses
and add to nitrous oxide emissions. It is likely also to lead
to imports of soy and palm oil from tropical countries, causing
deforestation which in turn would damage biodiversity, increase
carbon emissions and undermine livelihoods of local people who
depend on the forest.
Q4. 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?
4.1 Climate change is the most pressing
environmental issue facing humanity. Hundreds of millions of people,
including many of the poorest people in the world, could lose
their lives or livelihoods if average temperatures rise as forecast.
Up to one million species of animal and plant could be committed
to extinction. Action to prevent climate change is an economic,
social and environmental imperative.
4.2 Bio-energy production has a significant
and important contribution to make, alongside other policies,
in ensuring UK emissions fall by 3% per year and by 60-80% by
2050.
4.3 The analyses we have done suggest that
while the UK and the EU should focus primarily on increasing domestic
production of energy groups and biomass, there is scope for importing
biomass from outside the EU. These could include imports from
elsewhere in the developed world (eg Russia, Canada) and from
developing countries. There is nothing inherently wrong with this.
4.4 If incentives are designed to reduce
greenhouse gas emissions throughout the life-cycle and accompanied
by a strong and mandatory accreditation scheme, these imports
could help facilitate sustainable development in the producer
countries.
4.5 However, in the absence of incentives
designed to reduce greenhouse gas emissions throughout the life-cycle
and strong and mandatory accreditation scheme, there are serious
risks in promoting imports, especially from developing countries:
— developing countries do not have
targets under the Kyoto Protocol. There is no incentive on them
to ensure that biomass production doesn't lead to increased carbon
emissions as a result of deforestation or inefficient energy use.
— developing countries are home to
hundreds of millions of people on very low incomes who depend
on forests and other natural habitats, but who have no secure
title to the lands on which they depend. There is a very real
risk that land might be appropriated from them for biomass production.
— many developing countries contain
hotspots of global significance for biodiversity that could be
damaged for biomass production.
4.6 The experience we have seen already
with palm oil production in South East Asia and soy production
in South America strongly bears out these risks. It emphasises
the need for incentives to be based on life-cycle emissions and
for a strong and mandatory accreditation scheme.
Friends of the Earth Ltd
February 2006
pp 56-62 http://www.wbgu.de/wbgu_jg2003_engl.html
44 German Advisory Council on Global Change (WBGU),
2003 "World in Transition: towards sustainable energy systems" Back
45
European Environment Agency, 2005 "How much biomass can
Europe use without harming the environment" EEA Briefing
02 http://reports.eea.eu.int/briefing_2005_2/en/briefing_2_2005.pdf Back
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