Memorandum submitted by the Environment
Whilst recognising the importance of developing
more sustainable transport fuels, the Environment Agency is concerned
that ambitious biofuel use targets have been established at European
Union level in advance of a proper understanding of the implications
in terms of carbon emissions, sustainable development and land-use.
Specifically, our submission highlights that:
There is a risk of significant environmental
impacts from biofuel production in the UK related to competition
for land use, water use, water quality, and waste management.
In addition, there will be negative impacts on biodiversity and
deforestation associated with the import of tropical biofuels
such as palm oil. There is a real danger that with biofuels, trying
to solve one environmental problem (ie climate change) will create
Greenhouse gas (GHG) emission reductions
from biofuels are not guaranteed, as some fuels have high life
cycle ("well to wheel") emissions. There needs to be
a minimum threshold of carbon saving for fuels to qualify for
measures such as the Renewable Transport Fuels Obligation (RTFO),
as well as robust sustainability standards.
The emphasis in the UK and at EU
level on biofuels, as opposed to other bioenergy options, needs
to be questioned. Biofuels are the most land-intensive and least
cost-effective carbon mitigation alternatives. More policy measures
are needed to promote options at the top of the Government's biomass
hierarchy (eg biomass heating).
The government also needs to give
more priority to other policy measures for the transport sector,
in particular a substantial tightening of fuel efficiency standards
and measures to promote modal switch (eg road pricing).
Notwithstanding these concerns, the Environment
Agency believes that there is a role for a continued careful development
of transport biofuels, especially in view of prospects for improvements
in technology and the emergence of newer advanced biofuels which
promise significantly higher carbon savings.
The Environment Agency welcomes the opportunity
to submit evidence to the Environmental Audit Committee's inquiry
into the sustainability of biofuels.
Our role in biofuels includes the regulation
of waste, pollution prevention permitting for large biofuel plants,
and as a statutory consultee in the planning system. We have a
range of statutory responsibilities for protecting resources (soil,
air and water), and limiting and adapting to climate change in
England and Wales.
There is much interest in the use of biofuels
to replace fossil fuels, driven by a number of concerns, such
as climate change, benefits to the rural economy and energy security.
However, increasingly questions are being asked about the environmental
and broader sustainability impacts that a large and sustained
expansion in biofuel production might have, both in the UK and
in the developing world.
The Environment Agency believes that biofuels
can play a role in reducing transport's greenhouse gases (GHGs)
but we are sceptical that they represent a good environmental
or economic deal, unless there are major advances with production
from so-called second generation biofuels.
We focus our comments on the environmental impacts
of biofuels (question 1) but also provide some answers to questions
2, 4, 6 and 7.
2.0 KEY INQUIRY
Question 1 (i): What are the possible positive
and negative social, environmental and economic consequences of
The environmental issues surrounding biofuels
are wide-ranging. They include:
A large variation in GHG emissions
according to feedstock and process.
Large-scale changes to land use for
Effects on water resources, soils
The handling and reuse of wastes
Emissions from some combustion processes.
We explore some key issues in more detail below.
a) GHG emissions
From an environmental point of view, the major
promise of biofuels is a reduction in GHG emissions. Road transport
accounts for 21.6% of UK CO2 emissions, with an increase of about
10% since 1990. The biggest increase has come from heavy goods
vehicles (+30%). Transport emissions are still on an upward trend
which is one of the reasons why the UK is unlikely to achieve
its domestic emissions target of a 20% CO2 reduction by 2010.
Measures to reduce transport emissions are thus of crucial importance
for the achievement of the UK's climate change targets.
However, GHG emission reductions from biofuels
are not guaranteed, as the carbon footprint of different biofuels
varies enormously (see graph 1). While some reduce emissions by
up to 100% (eg recycled vegetable oil), others (eg palm oil grown
on plantations where virgin rainforest has been cut and peat swamps
drained, US maize grown very intensively) actually result in emissions
increases over regular fuels. Even for the same feedstock (eg
wheat), GHG emissions savings can vary from 20 to 80%, depending
on the manufacturing process used for refining the fuel and on
the use of by-products.
BIOFUEL GHG EMISSIONS
Source: Joint Research Centre, Well to Wheels
Report, Version 2c, March 07 http://ies.jrc.cec.eu.int/wtw.html
Higher CO2 emission reductions per hectare can
be achieved by restoring cropland to forest. For example, converting
cropland back to tropical forest can sequester 20-30 tonnes CO2/hectare
per year, three to four-fold higher than the emissions avoided
by using bioethanol from a hectare of sugar cane.
In the future, some of these secondary forests could be used for
producing second-generation (lignocellulosic) biofuels.
To ensure biofuels deliver real GHG emission
reductions, a minimum threshold of carbon saving (at least 50%)
needs to be introduced for measures such as the RTFO. The Agency
also supports a banding of the RTFO, with a larger number of certificates
on offer for higher carbon savings (eg 3 certificates for 90%
In terms of UK-grown fuels, concerns about biodiversity
relate mainly to the use of set-aside land. According to the RSPB,
the loss of set-aside to bioenergy crops is the most immediate
threat posed to biodiversity in Europe. It is likely further to
exacerbate the major bird population declines experienced in recent
With set-aside being phased out anyway in 2008,
the issue is not necessarily biofuel specific. An effective agri-environment
scheme that affords support for the most biodiverse sites currently
under set-aside is thus important. However, higher commodity values
will decrease the value of agri-environment payments that offset
environmental degradation. Biofuel policies are thus putting environmental
objectives under great pressure.
As concerns imported biofuels, attention has
focused on deforestation for palm oil plantations. Most palm oil
is used in the food industry but as the oil is considered the
most productive source of biodiesel,
demand for biofuels is causing more deforestation in highly biodiverse
areas of Malaysia and Indonesia. 20% of the EU's biofuels market
is expected to be supplied from these two countries.
The problem is not only direct palm oil use as a biofuel. EU palm
oil imports doubled during the 2000-06 period, mostly to substitute
for rapeseed oil diverted from food to fuel uses.
c) Water resources and soil impacts
The production of biofuels can also impact on
water use and water quality. Increased commodity prices will allow
irrigation to be cost effective, and a large expansion in maize
or sugar beet will stretch water resources in a large part of
the UK that is already identified as water stressed. Bringing
new land into arable production will put pressure on Water Framework
Directive objectives. It will increase nitrate leaching and there
is evidence to suggest water companies are already having to treat
drinking water for oilseed rape herbicides such as carbetamide.
An increase in the land use for late harvested
crops such as maize and sugar beet for biofuels will inevitably
result in more soil compaction, especially in wetter autumns and
will increase water run-off and potential flooding in sensitive
Question 1 (ii): How might trade-offs between
climate benefits and environmental and social impacts be made?
Trade-offs are never easy to make but can be
achieved through effective carbon, environment and sustainability
standards. Under such standards, a number of different criteria
will be assessed and an overall rating given. Such standards could
also include definite "no-go" options, eg fuel from
plantations which have resulted in the destruction of highly biodiverse
Question 2 (i): Should biofuels be regulated
to minimise the negative environmental and social impacts, and
in what way?
Regulation is crucial to ensure the environmental
concerns raised above are addressed. If the choice of biofuel
is simply left to the market, price considerations will determine
choice, potentially at the expense of sustainability. In the case
of support measures such as the RTFO, permissible biofuels should
be required to meet certain carbon and sustainability standards.
The standards should cover key criteria including: carbon in soil
and above ground, biodiversity, water use, water quality, waste
management, soil fertility, and good agricultural practice.
The Environment Agency supports the work on
standards for the RTFO currently underway. Ideally, standards
should be developed at international level, with one set of standards
applying globally. However, in the short term, this is probably
not feasible, with UK/EU standards more likely. It is important
that the Government works with the EU to resolve real or perceived
WTO constraints to the application of carbon and sustainability
Question 4 (iii): Are current policies promoting
the development and deployment of a range of biofuel technologies?
Policies in the UK and the EU appear to give
undue attention to transport biofuels compared to other bioenergy
options. According to the Government's biomass hierarchy,
transport biofuels offer the least cost-effective approach for
reducing carbon from biomass. For example, CO2 abatement cost
from biodiesel (£137/tCO2) and bioethanol (£152/tCO2
for wheat) are up to twice those for biomass for heat (£76/tCO2
for a large industrial boiler).
The biomas hierarchyin order of cost effectiveness
Biomas combined heat and power (CHP).
Co-fired electricity in large fossil
Dedicated biomas power plant.
Additionally, biofuels (especially those based
on wheat and oil seed rape) have the highest land requirements
per tonne of CO2 avoided. Perennial biomass energy crops such
as short-rotation coppice are also generally more beneficial from
a biodiversity point of view compared to annual biofuel crops
such as oil seed rape. Furthermore, they require few inputs once
planted, hence they generate little pollution (eg nitrogen run-off)
compared to biofuel crops and can act as a nutrient sink.
Within the next decade or so, it is expected that biomass crops
will be turned into so-called "second generation" transport
biofuels at a relatively low cost (£30-50/tCO2),
but currently the technologies are still at the development stage.
Concern about the focus on biofuels has recently
also been raised by Jacques Diouf, the Director General of the
Food and Agriculture Organisation of the United Nations (FAO).
In his view, more attention needs to be given to providing electricity
to the two billion people who have no access to modern energy
services. Biomass could make a direct contribution to poverty
reduction whereas the benefits of biofuels are less clear.
The Environment Agency believes that there is
a compelling case to use biomass at the higher end of the biomass
hierarchy (for heating) and not the lower end (for transport).
Furthermore, there is a range of options for reducing transport
sector emissions and more emphasis should be put on other measures,
such as mandatory fuel efficiency standards, road pricing and
speed control measures.
Question 5 (i): What proportion of UK domestic
transport and energy generation could be fuelled by UK-produced
Land is a limited resource and biofuel crops
are land intensive. According to NFU figures, the RTFO target
of 5% biofuel could be achieved through growing biofuel crops
(mainly wheat and oil seed rape) on land currently in set-aside
and by turning wheat currently exported into bioethanol. Overall,
this would amount to 16% of the UK arable land (almost one million
Even if all of the UK's arable land was used
for growing biofuel crops, at best only about 30% of current transport
fuel requirements could be met. Even assuming that these crops
would also produce substantial amounts of animal feed as a by-product,
it is unlikely that using all our arable land for fuel production
is desirable from a food security point of view. Other estimates
suggest even higher land requirements.
In the Environment Agency's view, the UK could
only meet a substantial amount of its energy requirements from
biofuels by first investing in a major energy and fuel efficiency
drive to reduce overall demand.
Question 5 (iii): Is there a role for public
Public procurement's role should focus on demonstrating
that biofuels can meet high carbon and sustainability standards.
The Environment Agency is currently running its own biodiesel
trial, using recycled vegetable oil. The trial runs from April
2007 for two years and involves 100 Agency vehicles. We will independently
evaluate the GHG savings.
Questions 6 (iii) & 7 (ii): What impacts
might the expansion of biofuels have on international food security
and prices? What implications are there for poverty in developing
The increasing demand for biofuels is already
having an impact on global food prices. According to the latest
OECD/FAO Agricultural Outlook, the growing use of cereals, sugar,
oilseed and vegetable oils (mainly in the EU and US) to produce
fossil fuel substitutes are underpinning both crop prices and,
indirectly, livestock product prices due to higher animal feed
During August 2007, both corn (maize) and wheat reached their
highest price in 11 years.
While this news will be welcomed by many farmers
who have struggled under low prices for more than a decade, higher
commodity prices are problematic for net food importing developing
countries as well as the poor in urban populations. Furthermore,
while higher prices for biofuel feedstocks support the incomes
of producers of these products, they imply higher costs and lower
incomes for producers that use the same crops for animal feed.
A fundamental issue is that the demand for biofuels
is putting substantial pressure on land and water resources at
the same time as demand for food and forest products is also rising
Furthermore, climate change will increasingly impact on agricultural
production. For example, it has been reported that China's grain
harvest will fall by 5-10% by 2030 due to climate change,
at a time when population growth and changing dietary habits mean
demand for grain is increasing rapidly.
Second generation biofuels or crops such as
jatropha which can grow on more marginal land should help avoid
many of these issues. Small scale jatropha plantations can successfully
be intercropped with agricultural, horticultural, herb, and pastoral
land. Sustainability standards can insure that biofuel production
favours these options.
As we have shown in this submission, there are
real and valid concerns about the sustainability of biofuels.
Our key policy recommendations are:
Government policy should deliver
the maximum GHG emission reductions from bioenergy in a cost-effective
way, based on its own biomass hierarchy. There is a compelling
case to use biomass at the higher end of the biomass hierarchy
(for heating) and not the lower end (for transport).
Government should assess other policy
instruments for reducing GHG emissions from the road transport
sector and compare the environmental and financial cost implications
with those involved in the use of biofuels for road transport.
This analysis should shape any future EU and UK targets for biofuels.
Economic instruments to encourage
the uptake of low carbon energy should be designed to limit adverse
environmental impacts. For example, the RTFO should include environmental
safeguards, and certificates should be awarded only to fuels that
meet environmental standards that cover soil, air quality, biodiversity,
water use and quality, and waste management.
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RSPB Memorandum to the Select Committee on Environment, Food and
Rural Affairs. http://www.publications.parliament.uk/pa/cm200203/cmselect/cmenvfru/929/929we15.htm Back
Palm oil yields are 6000+ litres per hectare, compared to 1188
litres for rapeseed oil in the UK. Back
Thoenes, P (2006) Biofuels and Commodity Markets-Palm Oil Focus
DEFRA, UK Biomass Strategy, May 2007 Back
DEFRA, UK Biomass Strategy, May 2007 Back
"Biofuels should benefit the poor", Jacques Diof, Financial
Times, 14/8/07. Back
United Nations (2007) Sustainable bioenergy: a framework for decision-makers. Back
Planet Ark, 24.8.07 Back