Memorandum submitted by the Royal Society
for the Protection of Birds
SUMMARY
1. The expansion of biofuels poses a significant
risk to biodiversity worldwide and their production and use does
not guarantee greenhouse gas emissions savings. Significant emissions
savings can be made from transport, however, through a combination
of efficiencies and encouraging behaviour change. The RSPB is
therefore calling on priority to be given to reducing emissions
in transport through efficiencies and encouraging behavioural
change, and for a moratorium on all new targets and support instruments
for biofuels until their sustainability can be proven and GHG
emission savings guaranteed.
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 (GHG) emissions that cause climate change. 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.
3. Global CO2 pollution needs to peak by
2015 and decline steeply thereafter to stay within the 2O°C
average global temperature increase widely held to be the limit
of "safe" global warming. To be reasonably sure of staying
below the 2°C target, current scientific consensus suggests
that the UK, with other developed countries, must make cuts of
no less than 80% in emissions of CO2 by 2050.
4. Climate change and the alarming rate
of biodiversity loss worldwide are the most critical environmental
challenges society faces today. Policy must therefore seek to
deliver for both. As a minimum, tackling one must not exacerbate
the other. This is critical for all Government policy, but in
particular for biofuels.
5. The RSPB believes that although biofuels
may play a role in helping reduce the UK's greenhouse gas (GHG)
emissions from transport, this can only be very limited as they
require large areas of land for feedstock cultivation, which poses
significant risk to the natural environment and competes with
our ability to produce food.
6. We are deeply concerned that current
biofuels policy in the UK, and particularly in the EU, is not
based on robust evidence regarding the direct and indirect impacts
of promoting biofuels on agricultural markets, domestic and international
land use, climate change and the wider environment. There is a
growing body of evidence suggesting that promoting biofuels is
already having a profound and negative influence on all of these.
The RSPB is therefore calling for:
a. A moratorium on all new biofuel targets,
including the EU's proposed binding target of replacing 10% of
transport fuels with biofuels, and other promotional policies.
b. The development of strict sustainability
and greenhouse gas standards for all biofuels that benefit from
existing public policy support mechanisms, such as grant schemes,
obligations and tax incentives.
c. The establishment of a global monitoring
programme on the effects of biofuels and bioenergy on the global
environment and climate change.
7. Furthermore, biofuels should be seen
and presented by Government as a small part of a wider strategy
for reducing GHG emissions from transport. This strategy should
prioritise the mechanisms listed below over biofuels as they guarantee
GHG savings and carry a lower environmental risk:
a. Reducing the public's need to travel through
effective planning policies and by encouraging the use of appropriate
information technology.
b. Encouraging the use of more sustainable
modes of transport through fiscal measures, such as well-to-wheel
fuel taxes and road-user charging, as well as softer measures
such as car clubs and travel plans.
c. Encouraging responsible, efficient methods
of driving.
d. Increasing vehicle efficiency through
establishing mandatory efficiency targets, appropriate fiscal
regimes, consumer grants, and the provision of information to
consumers that would allow informed vehicle purchase choices to
be made.
8. The Government hopes that the RTFO will
deliver GHG savings equivalent to 1 million tonnes of CO2. This
is a relatively small saving compared to what can be achieved
through these alternative methods. For example, an equal amount
of savings could be gained through enforcing the 70mph speed limit
on motorways, whilst increasing the average vehicle efficiency
to 100gCO2/km would save 2.4mn tonnes of CO[2].
9. In addition to the risk of not meeting
its objective of delivering GHG emission reductions, a biofuels
policy that fails to ensure the sustainability of the sector poses
significant risks to biodiversity, including:
a. Accelerating agricultural expansion in
the tropics at the expense of natural habitats with global importance,
such as rainforests and savannah. This is already the primary
driver of biodiversity loss worldwide.
b. Replacing important habitats and land-uses
in the EU and UK, such as grasslands, spring-sown crops, scrub
land, marginal areas and set aside.
c. Simplifying the agricultural landscape
through encouraging monocultures of biofuel crops, causing a loss
in landscape heterogeneity and a reduction in the wildlife value
of agricultural habitats.
d. Increasing the signal to farmers to produce,
something that the decoupling of direct subsidies in 2005 had
sought to reduce, and thus accelerating further agricultural intensification.
10. It is essential that biofuels and biofuel
policy do not accelerate the destruction of globally important
natural habitats. Rainforest destruction is not only a prime cause
of extinctions, but is responsible for 20% of global GHG emissions.
Equally important are grasslands, which are also at risk of conversion
for biofuel production. The Brazilian Cerrado, for example, is
one of the richest biodiversity areas in the world.
Question 1. The environmental and climate
impacts of biofuels
11. The principle potential positive environmental
impact of biofuels are emissions savings, although these are not
guaranteed. The risks, particularly to wildlife and biodiversity,
are globally significant and potentially extremely serious. We
do not believe that potential benefits in GHG emissions from biofuels
justify unacceptable damage to biodiversity and the wider environment,
particularly given the lack of guarantee for these gains. Policy
to reduce emissions from transport should not seek to trade off
environmental harm against benefit, but to make savings in the
lowest impact way.
The potential of biofuels to provide environmental
benefits
12. The only legitimate reason to promote
biofuels is as a delivery mechanism for GHG savings. Biofuels
are often referred to as "carbon neutral" because they
are made from organic matter that has absorbed carbon from the
atmosphere during their growth, but, in reality, they release
GHGs throughout their production. There are a large number of
life-cycle analysis studies of the GHG savings from biofuels.
The RSPB has collated the data from a number of review studies
from these analyses in Figure 1.
Figure 1
% GREENHOUSE GAS SAVINGS FROM BIOFUELS COMPARED
TO FOSSIL FUEL EQUIVALENTS, NOT ACCOUNTING FOR LAND USE CHANGE
Source: LowCVP (2006), E4Tech (2006), Concawe,
EUCar & JRC (2006)
13. Figure 1 demonstrates that savings are
highly variable according to production pathways, ranging from
significant savings to a net increase in emissions. These studies
do not, however, account for the GHG impact of land use change,
which has the potential to negate any savings even for biofuels
produced within Europe. For example:
a. Conversion of grassland in Europe to biofuel
production has been calculated to have a GHG payback time from
17-111 years. This is the time required for the production and
use of biofuels off this land to render the original land conversion
"carbon neutral".
b. Tropical deforestation is already responsible
for 20% of global GHG emissions.
14. A recently published study indicates
that life cycle analyses to date, including those outlined above,
have significantly underestimated the emissions of nitrous oxide
from the production of some biofuel crops that arise from the
application of nitrogen fertilisers[3].
The study concludes that crops that require high nitrogen inputs
such as maize and oilseed rape are likely to result in an increase
in emissions compared to conventional fuels.
15. Second generation ligno-cellulosic based
biofuels generally have higher emission savings and may offer
some benefits to biodiversity in the UK if their expansion is
managed in a way that avoids the displacement of important habitats,
such as wet grassland and marginal areas, and is sympathetic to
biodiversity and the wider environment. Conventional biofuels
crops such as wheat and oilseed rape will not be much different
in terms of their habitat value to food crops, but the biodiversity
value of the two most likely sources of biomass for second generation
biofuels differ significantly and are summarised below.
16. Short Rotation Coppice (SRC) has been
found to host a generally higher density and variety of bird species
than is usually seen on intensively-farmed arable land or improved
grasslands, but it tends to attract a different suite of birds
than open farmland as it is essentially a woodland habitat. Species
of conservation concern such as skylark, lapwing and corn bunting
will not do well in SRC field, but common woodland species, such
as the pheasant, robin and blackbird could benefit. However, there
have been no studies to date to establish the impacts of SRC plantations
on bird breeding success, which may be reduced by, for example,
the lack of dead wood in plantations. 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. This information mostly comes
from studies of relatively small pre-commercial SRC plantations;
the impacts of a larger, commercial-scale plantations are likely
to be very different.
17. Little is known of the potential impact
that perennial grasses, including miscanthus, reed canary grass
and switchgrass, could have in the UK and Europe. These are not
native species, and are unlikely to be suitable habitats for open
ground species, but may prove beneficial for species characteristic
of reedbeds and dense herbaceous vegetation or scrub, eg reed
warbler and reed bunting.
Negative environmental impacts
18. The negative environmental impacts of
biofuels arise from their land requirements and can be grouped
into the following categories: previous land use, management of
crops, and scale and spatial distribution at the landscape scale.
19. Where biofuel demand results in biofuel
feedstock production that replaces a habitat with greater wildlife
value than the crop itself there will be a negative environmental
impact. In the UK, valuable areas of set aside are already being
lost to biofuel production. Also at risk are unimproved and wet
grasslands, particularly in the Central and Eastern European Member
States, which are important for a wide range of biodiversity.
20. 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. Recent research by Natural England and the RSPB has found
that when the set-aside area was halved in the 1990s, the numbers
of farmland birds also showed a serious decline[4].
In spite of this, set-aside has been reduced to 0% this year and
will be phased out permanently in the CAP health check, partly
driven by land demand for biofuels, with an expected negative
impact on farmland biodiversity unless environmental safeguards
are put in place.
21. The most significant natural habitats
that risk being lost to biofuel production exist in tropical producer
countries, particularly rainforest in Indonesia, Brazil and other
South American countries, and the cerrado in Brazil. These habitats
are of global importance for biodiversity and their destruction
not only damages this local biodiversity, but also means a loss
of ecosystem services from that land, including clean water, flood
alleviation, firewood, and food for local people. They are being
lost rapidly, primarily as a result of agricultural expansion.
This is an increasing trend that biofuels can only exacerbate
both directly, through the establishment of new plantations that
replace these habitats, and indirectly through displacing other
agricultural production onto these habitats.
22. Biofuel production also risks damaging
biodiversity through further simplifying the agricultural landscape
as a result of encouraging monocultures of biofuel crops, causing
a loss in landscape heterogeneity, and a reduction in the wildlife
value of agricultural habitats. Anecdotal evidence already suggests
that oilseed rape is replacing other break crops, including beans
and sugar beet. This is also likely to be of particular concern
in the future for new perennial biomass crops that may be used
for second-generation fuels, such as miscanthus and short rotation
coppice willow. The logistics of transporting biomass will encourage
block cropping within the vicinity of processing plants, creating
perennial monocultures at the local or even landscape scale.
23. The use of land for biofuel production
is also in direct competition with the use of land for biomass
for heat and electricity production. Both of these offer far greater
and less variable GHG emissions savings. A large uptake of land
for biofuels as a result of supportive public policies could therefore
mean a forfeit of emissions savings in the heat and electricity
sectors.
Question 2. The regulation of biofuels to
minimise negative environmental impacts
24. The negative impacts of biofuels can
be minimised through ensuring that the industry does not grow
beyond sustainable limits and through robust and appropriate regulation,
in particular through the implementation and monitoring of minimum
environmental standards for all biofuels eligible for public support,
including the RTFO and the 20 pence per litre tax incentive on
biofuels.
25. The cost of reducing GHG emissions via
biofuels is relatively high relative to other ways of reducing
emissions in transport. Their cost of production is also high
in real terms: the OECD estimates that in most cases it is approximately
double that of conventional fuels, with costs increasing with
the growing cost of feedstock. The biofuels market is therefore
entirely created by Government through the use of a variety of
incentives and at the cost of the taxpayer and consumer. The RTFO,
for example, would cost £500mn/yr at the current rate of
5% substitution, and at current tax rates. We believe that this
public investment justifies requirements that biofuels meet certain
standards of production that ensure that significant and proven
GHG emissions are delivered and that they are produced sustainably.
26. Government must also ensure that the
level of biofuels produced and thus paid for by the public is
sustainable. This means that targets for biofuels should be based
on robust evidence that demonstrates they can be met sustainably.
This evidence has not yet been produced and there is increasing
evidence that even at relatively low levels of production biofuels
are causing serious environmental damage. The RSPB is therefore
calling on a moratorium on new biofuel targets and believes that
the proposal by the European Council to adopt a 10% biofuel target
for the EU should not be adopted.
27. Standards must cover the entire life-cycle
of biofuels to ensure that they are effective, but should prioritise
those stages where the risks are highest: the production and processing
phases, which is where most environmental and biodiversity impacts
are felt and where a significant proportion of GHG emissions from
biofuel production are emitted.
28. The RSPB has been advocating minimum
environmental and GHG standards for biofuels throughout the development
of the RTFO. We are an active member of the Low Carbon Vehicle
Partnership, and are represented on DfT's RTFO sustainability
advisory group. We have worked with industry and Government to
develop and promote standards but have been deeply disappointed
by their failure to introduce these standards from the beginning
of the RTFO (April 2008). Instead, Government have announced that
companies will be required to report on sustainability and GHG
emission savings with the view of introducing standards in 2011
and 2010 respectively. However, Government also announced a number
of conditions that must be met before these are introduced, including
compliance with World Trade Organisation (WTO) rules.
29. We do not believe that WTO rules will
prohibit linking the RTFO to GHG emission saving requirements
given that:
a. Climate change and the need to reduce
GHG emissions is recognised in the United Nations Framework Convention
on Climate Change and the Kyoto Protocol.
b. Standards would not be discriminatory
toward non EU production.
c. GHG emissions savings are the explicit
aim of the RTFO and the 20ppl tax incentive on biofuels. It is
not suggested that failing to meet these standards would prevent
trade, only that it should be a precondition to benefitting from
these policy mechanisms.
30. This conclusion was also reached in
the Government's own advice on these matters[5].
The situation is more complex with regards to sustainability standards
but we remain convinced that it is possible under current WTO
rules. We strongly recommend that Government takes a more proactive
approach to promoting this approach within the WTO and with trading
partners to ensure that we are able to introduce these standards
in 2011 as promised.
31. Minimum standards for biofuels are technically
possible now. The failure to introduce minimum standards for biofuels
from the beginning of the RTFO reflects a political decision that
will result in approximately 2.5 billion litres of biofuel on
UK forecourts with no assurance it is not causing environmental
damage.
Question 3. International assurance of biofuels
32. The RSPB believes that the commodity
assurance schemes, including the Roundtable on Sustainable Palm
Oil, the Better Sugar Cane Initiative and the Roundtable on Sustainable
Soy, as well as general assurance schemes, such as organic and
Rainforest Alliance, could offer a means of delivering higher
standards and accountability throughout the supply chain. We believe
that the current approach used by the RTFO sustainability reporting
requirement of depending on these schemes is appropriate as they
have been developed by the industry and NGOs, and are practical
and relevant.
33. We are, however, concerned that these
schemes may not be able to guarantee enforcement of standards
and chain-of-custody control, particularly as most of these schemes
are at a very early stage of development and rely on self-regulation
and monitoring.
34. It is also important to note that these
schemes can only deal with particular farms or plantations, and
that they cannot deal with the indirect environmental impacts
of biofuels. There is considerable risk that certified commodities
will be bought by the UK and EU, whilst uncertified and less sustainable
commodities will be bought by other markets. This makes international
cooperation and agreement over biofuels extremely important.
Question 4. Biofuel technology and competition
with biomass
35. There is a strong expectation that second
generation biofuel technology will greatly increase the efficiency
of biofuel production, thereby increasing the GHG savings and
decreasing the land requirement. The EU's impact analysis for
the proposed EU 10% biofuel target depends on second generation
fuels supplying 30% of biofuels in 2020. However, there is no
consensus as to how close to market second generation is. This
is of great concern because ambitious targets are being announced
that will be well beyond what can be produced sustainably without
it being available. In their recent report[6],
the OECD noted that second generation fuels are still in the demonstration
phase and a long way from the market, claiming that they are still
a "distant possibility". Furthermore, there remain doubts
over the feasibility of biomass-based biofuels, given the logistics
of producing and transporting large amounts of biomass. We therefore
believe it is irresponsible to set targets and current biofuel
policy based on a technology that is not yet available, especially
given the risks are so high.
36. In spite of variations according to
production pathways, there is broad consensus that biomass derived
electricity and heat offers very significant emission reductions.
The emissions advantages offered by electricity from biomass are
shown in Table 2.
Table 2
THE CO2 EMISSIONS OF TWO ELECTRICITY PATHWAYS
COMPARED TO CONVENTIONAL ELECTRICITY GENERATION
|
| Electricity source | CO2 emissions
in g/kWhe
|
|
| Modern coal | 1,054
|
| Natural gas (combined cycle) | 411
|
| Electricity from forest residues | 12
|
| Electricity from SRC | 84
|
|
| Source: Bauen, Woods and Hailes (2003)
|
37. It is clear that biomass for heat and electricity
offer greater and more reliable GHG emission savings than biofuels.
However, it is usually argued that there are fewer options for
reducing emissions in transport than there are in other sectors.
A recent study[7] by the
Government's advisor on transport, the Commission for Integrated
Transport, has, however, found that emissions from transport could
be reduced by 14% from 1990 levels through a combination of vehicle
efficiency savings, eco-driving, changes in travel behaviour,
efficiencies in freight transport, and including aviation in the
European Emissions Trading Scheme. We do not, therefore, believe
this argument to be valid, and there should be a review of the
role of biofuels and biomass for heat and power given the restrictions
in land availability and the GHG abatement potential of these
technologies.
Questions 5 and 6. The potential role of biofuels
38. The contribution biofuels can make to the UK's transport
fuel needs is restricted by the availability of feedstock and,
consequently, of agricultural land. The NFU estimate that 1.2
million hectares would be required to meet the 5% RTFO target
from domestically grown crop, whilst another study[8]
found that approximately 1.9 million hectares—or 32%—of
our arable land would be needed for the EU's 5.75% target, which
is likely to be increased to 10% by 2020. This must also be seen
in addition to demand for biomass for heat and power production.
If biomass were to provide a third of the 10% renewable electricity
by 2010 target, 1.2 million ha of short rotation coppice willow
and miscanthus would be required[9].
39. Even with set-aside coming into production and the
current surplus in wheat production, it is clear that a large
proportion of biofuels consumed in the UK will therefore be imported.
Imported biofuels can deliver greater GHG savings but also greatly
increase the risk of serious environmental damage:
a. The largest biofuel exporters internationally are tropical
countries where agricultural expansion, primarily for the export
market, is the principal driver of loss of globally important
habitats, including rainforest and grasslands.
b. International commodity chains are long and complicated,
making traceability and responsibility throughout the chain more
difficult to achieve.
40. Furthermore, as the UK capacity to produce biofuels
is severely limited in comparison to its consumption of transport
fuels, and so is global production capacity. For example, the
global production of vegetable oils is 146mn tonnes, compared
to global use of crude oil of 4252mn tonnes. We understand, however,
that there may be land that is not currently in production and
could be used for biofuels without adverse environmental impact.
This land is sometimes referred to as "idle land", however
we are concerned that targeting biofuel development at idle land
outside the UK and EU will not be possible given traceability
issues in the international commodity market, and are also concerned
that land-uses often referred to as idle can have exceptional
biodiversity value.
41. Biofuels are clearly already having an impact on
the market as they increase demand and compete with food. In addition
to this increased demand, poor harvests in Canada, Europe and
Australia this year have meant that wheat prices have jumped 110%
in the past 12 months and have risen threefold since 2000. The
estimate for the 2007-08 global wheat crop is 607m tonnes, but
demand is forecast at 614m tonnes[10].
Global wheat inventories were at their lowest since 1979. Climate
change will increase the occurrence of these extreme weather events,
making future production levels more unpredictable.
42. A European Commission sponsored study has found that
replacing 5.75% of our diesel requirements in the EU would require
192% of current production. The Commission estimate this will
result in an increase in price by 8-18%. The OECD concur, concluding
that "the rapid growth of the biofuels industry is likely
to keep prices high and rising".
43. These impacts of biofuels on the food market, the
restricted land available for their production and thus commodity
availability globally, suggests that biofuel policy needs urgent
review.
44. We believe that the fuel security benefits of biofuels
are exaggerated for the following reasons:
a. Given the limited availability of feedstocks that could
be grown in the UK and the EU relative to demand, much of the
feedstock for biofuel production will have to be imported.
b. Biofuel feedstock production is heavily reliant on
artificial nitrogen fertiliser, an energy-intensive product that
is in turn is reliant on natural gas for its production.
45. Given the risks described in this consultation response,
and with reference to the questions posed by the Committee, we
do not believe it appropriate to encourage public procurement
of biofuels.
1 October 2007
2
Commission for Integrated Transport (2007) Transport and climate
change Back
3
Crutzen et al (2007) N20 release from agro-biofuel production
negates global warming reduction by replacing fossil fuels Back
4
RSPB & Natural England(2007), unpublished data Back
5
E4tech (2005) Feasibility study on certification for a Renewable
Transport Fuel Obligation Report for the DfT Back
6
OECD (2007) Biofuels: is the cure worse than the disease? Back
7
Commission for Integrated Transport (2007) Transport and climate
change Back
8
Turley (2006) Environmental impacts of cereal and oilseed cropping
and potential for biofuel production Report for the HGCA Back
9
Land Use Consultants (2007) Bioenergy in the UK Back
10
FT (2007) Wheat prices jump to record high Back
| 
