Memorandum submitted by the Woodland Trust
1. The Woodland Trust welcomes the opportunity
to respond to this inquiry. The Trust is the UK's leading woodland
conservation charity. We have four main aims: no further loss
of ancient woodland, restoring and improving woodland biodiversity,
increasing new native woodland and increasing people's understanding
and enjoyment of woodland. We own over 1,000 sites across the
UK, covering around 20,000 hectares (50,000 acres) and we have
300,000 members and supporters.
EXECUTIVE SUMMARY
— The biofuels industry is expanding
rapidly. The Woodland Trust is concerned that policy, particularly
with respect to environmental impacts, is not keeping pace with
this development.
— Within the UK, where land is already
subject to a number of conflicting pressures, there is a danger
that expansion in biofuel crops to meet existing and future targets
could compete with land-use for food production, recreation and
nature conservation. The Trust is particularly concerned that
important wildlife areas could be lost or managed inappropriately
and there could be further intensification across the whole landscape.
— Developing technologies for production
of "second-generation" biofuels offer more postive opportunities,
since they could utilise woody material rather than traditional
arable crops. This could create a market for low-grade timber,
stimulating restoration of semi-natural habitats planted with
conifers (including ancient woodland), and planting of new woodland
and trees that could help to buffer and expand semi-natural habitats.
Production of second-generation biofuels is also potentially more
carbon efficient than production of fuels like bio-ethanol from
conventional crops.
— Production of biofuels must be subject
to minimum standards and certification, to ensure that it occurs
sustainably ie creating genuine greenhouse gas savings, without
negative environmental impacts, and where possible, providing
positive environmental benefits.
— A more strategic approach is needed,
including an assessment of the role of biofuels and other bioenergy
in the UK's total energy mix, taking account of environmental
constraints and the capacity of other renewables.
— Last, but most importantly, development
of biofuels should take place within an over-arching strategy
that recognises the need to reduce consumption and implement energy-saving
measures.
2. SUMMARY OF
THE WOODLAND
TRUST'S
VIEW ON
BIOFUELS
2.1 The Woodland Trust believes climate
change is the single biggest threat to biodiversity, including
woodland biodiversity. Urgent measures are needed to mitigate
the effects of climate change, reducing greenhouse gas emissions
by curbing energy consumption, increasing energy efficiency, and
the use of renewable sources that provide real carbon savings.
2.2 The bioenergy industry, including production
of biofuels, is growing rapidly. As well as potentially contributing
to reducing greenhouse gases, bioenergy offers some positive opportunities
to enhance biodiversity, could contribute towards measures to
help adaptation of wildlife to climate change, and may also offer
wider environmental benefits, for example, through provision of
"ecosystem services" such as flood prevention. However,
there is also a risk that, if not subject to the correct controls,
the development of bioenergy could have a negative effect on biodiversity
and the environment.
2.3 The Woodland Trust supports the development
of bioenergy, including biofuels, where it offers genuine greenhouse
gas savings, where it does not negatively impact on biodiversity,
and, if possible, it delivers positive biodiversity benefits.
3. ANSWERS TO
SPECIFIC QUESTIONS
3.1 Question 1: What are the possible
positive and negative social, environmental and economic consequences
of biofuels? How might trade-offs between climate benefits and
environmental and social impacts be made? Is there a need to develop
a new biofuel strategy for the UK or EU, to balance the environmental,
social, economic and climate impacts of biofuels?
3.1.1 Globally, there is increasing concern
about the effects of the expanding biofuels industry, particularly
felling of tropical rainforest, displacement of poor farmers,
and replacement of food crops with plantations of soya, sugar
cane and other crops for biofuel production. While the Woodland
Trust recognises that these issues are a major concern, our comments
in this response will be largely confined to the potential effects
in the UK, particularly the environmental impacts of biofuels.
3.1.2 Earlier this year, Wildlife and Countryside
Link, a coalition of environmental non-governmental organisations
(NGOs), including the Woodland Trust, launched "Bioenergy
in the UK: Turning green promises into environmental reality,"
a policy paper that set out six priorities for Government action
to ensure that growth in UK bioenergy production would maximise
greenhouse gas savings and minimise damaging environmental impacts.
Many of the issues raised in this consultation response are dealt
with in more detail in the policy paper, and we would recommend
that the Environmental Audit Committee refer to it. A copy is
attached.
3.1.3 Bioenergy crops currently account
for only a small percentage of land use in the UK but this is
likely to increase rapidly over the next couple of decades to
help meet national targets on use of bioenergy. For example, to
meet the 5% by 2010 target on biofuels would require between 1.2m
and 1.9m ha of additional wheat and oilseed rape1. At the same
time, there is also pressure to increase the area of energy crops
to provide heat and power; to meet just one-third of the government's
2010 target for electricity from renewables would require 1.2m
ha of short rotation coppice (SRC) and Miscanthus (elephant grass)2.
This is equivalent to about 20% of the UK's arable land.
3.1.4 The specific environmental effects
of particular biofuel crops depends on a number of factors:
— The land use it displaces.
— The management techniques employed
in growing and harvesting.
— The scale and location of bioenergy
development.
3.1.5 Currently, most developments in biofuels
in the UK require the use of traditional agricultural crops such
as sugar beet, wheat or oilseed rape. However, in the future,
emerging technologies will enable the use of more woody feedstocks:
timber from existing woods, short rotation coppice and forestry,
and energy grasses such as Miscanthus to produce "second-generation
biofuels." Research3 indicates that such fuels are more efficient
in delivering greenhouse gas savings than those produced from
traditional arable crops, and the estimated yield per hectare
from second generation feedstock is much higher, since the whole
crop can be used.
3.1.6 Within the UK, such developments could
offer some really positive opportunities for woodland and its
wildlife. The stimulation of markets for wood products (low grade
timber and forest residues, SRC and short rotation forestry (SRF)
could lead to improvements in woodland biodiversity through:
— Restoration of Plantations on Ancient
Woodland Sites (PAWS).
— Bringing woods into sensitive and
appropriate management, where it can be demonstrated that this
will have biodiversity and/or social benefits.
— Expansion of native woodland, and
buffering of sensitive woodland eg ancient woods with low-intensity
new planting, including SRC.
— Renewing public and political appreciation
for the value of woodland to society.
3.1.7 It could also lead to additional "ecosystem
services" benefits—for instance, replacing traditional
arable crops with SRC could lead to improved soil and water quality
because if done correctly it requires lower inputs of fertilisers
and pesticides. SRC and SRF can also absorb pollutants, and could
therefore be used to buffer sensitive habitats such as ancient
semi-natural woodland from the effects of nearby intensive land-use.
SRC can also help to ameliorate major downstream flooding events
in floodplains by reducing flow rates and planting tree species
can help to reduce soil erosion. Even perennial grasses, or conventional
arable crops planted for biofuels, might lead to reduced intensity
of land-use, depending on where they are planted, the land-use
they replace, and how they are managed, contributing to a landscape
that is more permeable to wildlife enabling adaptation in the
face of climate change.
3.1.8 However, biofuel crops also pose some
real threats. Planting of semi-natural or other valuable unprotected
wildlife (UKBAP) sites with energy crops is a risk if demand for
bioenergy continues to rise in the UK, and begins to compete with
the other services we demand of our land; for example, land with
semi-natural characteristics, such as permanent pasture, semi-improved
grassland and wet grassland, could be at risk, and in particular,
set-aside land that has been left fallow and has developed biodiversity
value.
3.1.9 Maximising greenhouse gas savings
requires minimising the use of artificial nitrogen inputs, but
unless producers are required to deliver higher greenhouse gas
savings, a growing market for conventional agricultural crops
for biofuels could cause intensification of production.
3.1.10 The need to cluster crops near to
processing plants in order to reduce transport emissions and costs
could lead to large concentrations of monoculture, which would
threaten both biodiversity and landscape character.
3.1.11 The effects of non-native species
that are currently relatively unknown in the UK (eg Miscanthus)
have not been adequately researched, and the use of genetically
modified organisms could pose a further threat to biodiversity.
3.1.12 Current evidence is that the greatest
potential greenhouse gas savings can be achieved through burning
of woodchip to generate heat, gasification of biomass to produce
electricity and the use of second generation biofuels produced
from biomass4. The Woodland Trust would therefore like to see
bioenergy policies place greater emphasis on the use of woody
biomass crops for these purposes, rather than on agricultural
crops such as sugar beet and wheat for the production of biofuels.
3.1.13 There is a need for the growing,
harvesting and processing of all biofuel crops to be subject to
minimum standards and certification of greenhouse gas savings
and environmental impacts. Greenhouse gas certification should
be based on the work already conducted for the greenhouse gas
reporting mechanism that will form part of the Renewable Transport
Fuels Obligation (RTFO). For forestry crops, sustainability certification
should be basedon existing independent standards: the UK Woodland
Assurance Standard and the Forest Stewardship Council's certification
scheme.
3.1.14 There is a real need to assess the
biodiversity, landscape, and wider environmental effects of the
developing market for biofuels in the UK and develop a coordinated
strategy for the future development of biofuels that takes these
into account. The policy statement recently published by Wildlife
and Countryside Link, of which the Trust is a member5 sets out
a number of recommendations to Government for the sustainable
development of bioenergy. This could inform a future strategy
for biofuels and includes the following key points:
— Undertake a strategic assessment
of the role of bioenergy in the UK's energy mix, seeking to identify
the level and type of bioenergy production that should be encouraged,
taking account of environmental constrains.
— Introduce minimum standards and certification
of greenhouse gas savings and environmental impacts.
— Ensure the planning system is equipped
to respond to the pressures on land use of bioenergy projects
and provides appropriate policy and guidance.
— Identify the opportunities for bioenergy
to contribute to the achievement of other environmental goals
eg flood defence, improvement of biodiversity—and ensure
these are acted upon.
— Actively promote small scale local
uses of bioenergy.
— Undertake further research to ensure
bioenergy policy is based on a thorough understanding of environmental
threats and opportunities.
3.2 Question 2: Should biofuels be regulated
to minimise the negative environmental and social impacts and
in what way? How might regulation fit in with international trade
agreements and rules? Should there be regulation of the entire
carbon cycle of biofuels?
3.2.1 Production of biofuels should be subject
to minimum standards of greenhouse gas savings and environmental
impacts. A certification system should be developed, linked to
financial incentives and credits, as soon as possible, and that
this must apply internationally, and should regulate the entire
carbon cycle of biofuels. (see 3.1.13 above).
3.3 Question 4: At what stage is biofuel
technology? Is there enough support for the development of biofuel
technology? A UN report found that the climate change benefits
of solid biomass fuels outweigh those of liquid biofuels. Are
current policies promoting the development and deployment of a
range of biofuel technologies? How successful have EU strategies
and Directives been in stimulating biofuel usage? Will the 2010
biofuel target be reached? How effective are the Government's
fiscal arrangements for biofuels?
3.3.1 The Woodland Trust supports the use
of woody biomass for the production of heat, power, and second-generation
biofuels, where such biomass is produced without negative environmental
impacts, and, if possible, delivers positive biodiversity and
wider environmental gains, as described above. However, there
are many barriers to the use of such products for second generation
biofuels, including the cost of harvesting in woods with poor
access, lack of infrastructure required for mobilisation of the
timber, and the cost of the processes required to produce second-generation
biofuels. Investment is needed in development of infrastructure
and markets, and further research into the production processes.
3.4 Question 5: The EU Strategy for Biofuels
claims that biofuels "are a direct substitute for fossil
fuels in transport and can readily be integrated into fuel supply
systems". What proportion of UK domestic transport and energy
generation could be fuelled by UK-produced biofuels? Is it possible
for biofuels to entirely replace oil for transport purposes? Is
there a role for public procurement or public transport? Will
biofuels improve fuel security? How secure are biofuel crops from
unexpectedevents such as drought or disease?
3.4.1 Given the many conflicting pressures
on land use in the UK, it is unlikely that domestically produced
biofuels alone will replace oil for transport purposes. The use
of biofuels from the UK or overseas should only be promoted if
it can be demonstrated that they are, truly, produced sustainably.
However, we would also urge that over-arching all policies on
bioenergy must be a recognition by Government and others of the
need to reduce consumption through energy-saving measures, and
to work towards "one-planet living".
3.5 Question 6: What impact would an expansion
of UK production of biofuels have on the ability of the UK to
produce its own food? How might this impact on greenhouse gas
emissions from international trade patterns? What impact might
the expansion of biofuels have on international food security
and prices?
3.5.1 The expansion of biofuels is already
impacting on world food prices, as demonstrated recently by rising
prices of maize and wheat. Incentives for growing biofuel crops
could lead to competition between use of land for food and fuel
within the UK, as well as elsewhere in the world. This underlines
the need for a coordinated strategy which assesses the available
resource for production of biofuels, and other bioenergy, taking
into account the many other pressures on land in the UK.
September 2007
REFERENCES
1. NFU (2006) UK biofuels—land required
to meet RTFO 2010. www.nfuonling.com/x9763.xml
2. Land Use Consultants (2007) Bioenergy:
Environmental Impact and Best Practice (report prepared for Wildlife
and Countryside Link) p 30
3. Carbon and energy balances for a range
of biofuels options, Sheffield Hallam University (2003) and
WTW evaluation for production of ethanol from wheat, Low
Carbon Vehicle Partnership (2004). Contained within House of Commons
EFRA Committee (2006) Climate change: the role of bionergy
4. Carbon and energy balances for a range
of biofuels options, Sheffield Hallam University (2003) and
WTW evaluation for production of ethanol from wheat, Low
Carbon Vehicle Partnership (2004). Contained within House of Commons
EFRA Committee (2006) Climate change: the role of bionergy
5. Bioenergy in the UK: Turning green promises
into environmental reality, Wildlife and Countryside Link
(2007)
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