Memorandum submitted by Natural England
CLIMATE CHANGE
AND ENERGY
POLICY
1. Natural England recognises that climate
change poses the most serious long-term threat to our natural
environment and welcome measures that can help tackle its causes.
We are also of the view that the agriculture, forestry and land
management sector can make an important contribution to climate
change adaptation and mitigation.
2. There is a growing global demand for
biofuels, driven by both a need in some parts of the world to
increase energy security and to contribute towards efforts to
reduce greenhouse pollution and mitigate climate change. In England
it is expected that as a result of the EU Biofuels Directive and
the implementation of the Renewable Transport Fuels Obligation,
5% of transport fuels will be required to come from biomass or
other clean sources by 2010. Natural England notes that it does
not, though, require that production needs to be sourced domestically.
3. The focus for Natural England's energy
mitigation work will be to facilitate the development of clean
energy infrastructure in appropriate locations and to facilitate
the role of land managers as contributors to the UK's clean energy
and carbon reduction targets.
4. Natural England's position on the development
of a sustainable biofuel industry is that it should:
— minimise the impact on the natural
environment; whilst also
— optimising the contribution of biofuel
production to reducing greenhouse gas pollution.
5. Natural England's view is that urgent
action is required to establish agreed standards and method's
of accreditation for sustainable biofuel production, both domestically
and overseas. We feel that the contribution of biofuels to fuel
security should not come at the expense of the natural environment.
6. One of our key strategic targets is to
facilitate investment in the generation of clean energy. As part
of this target we are working towards providing a clear framework
for assessing the environmental impacts of bioenergy crops, against
the varied potential in terms of carbon saving, wildlife value,
fuel security and socio-economic impacts of different feedstocks.
7. Natural England will work to ensure that
our evidence base for biofuel policy and programme development
is sound and helps to guide government policy and delivery.
MAIN ISSUES
FOR NATURAL
ENGLAND
8. The following are the key issues relating
to biofuels production that Natural England would wish to see
considered and consolidated, within European and UK biofuels strategy,
policy and delivery.
8.1 The development of a biofuel sector that
ensures that biofuels are produced sustainably with no significant
adverse impacts on the natural environment and with demonstrable
carbon savings.
8.2 The development, introduction and monitoring
of an internationally agreed accreditation/standards for sustainably
produced biofuels. The introduction of robust and certifiable
minimum sustainability standards is the best way of bolstering
consumer confidence and providing a clears reporting framework
for the biofuels industry.
8.3 An increased understanding of the potential
impacts on the natural environment of increasing biofuel crop
production in the UK and how these might be avoided or minimised.
In particular there is need for an increased understanding of
the potential future growth trend for biofuel crop production
in England. We feel there is also need for careful monitoring
of the environmental impacts of the production of biofuel crops
in England and the consequences of competition for land use with
food production, development and nature conservation.
8.4 Given the benefits of "second generation"
biofuels over current "first generation" biofuels (greater
carbon savings, less land-take, less waste) we would welcome any
action that can facilitate their earlier commercial viability
and use.
8.5 Government recognition that over-emphasis
on enhancing the market for biofuels could be at the expense of
energy demand management and alternative uses of biomass for heat
and electricity generation, that may deliver better environmental
outcomes.
9. Whilst Natural England's reason for engagement
in this area is to ensure that increasing biofuels production
will not result in significant adverse impacts for England's natural
environment. It should be noted that a focus on accreditation
and standards for sustainably produced biofuels will contribute
to efforts to ensure that adverse environmental impacts are minimised
elsewhere in the world.
ENVIRONMENTAL IMPACT
OF BIOFUEL
CROP PRODUCTION
10. Natural England recognises that the
increasing production of biofuel crops in England has the potential
to impact upon biodiversity, soils, water resources and landscape
diversity. To avoid any adverse impacts, biofuel crops need to
be the right type of crop, grown in the right places using the
right techniques. We would also note the following environmental
impacts:
10.1 Biofuel crops grown in existing arable
areas that merely substitute for existing arable crops are likely
to have limited impact on the natural environment. In some cases,
where for instance oil seed rape replaces wheat, there is potential
for a positive impact on biodiversity.
10.2 Crops grown in areas which are currently
natural or semi natural or replace beneficial land uses such as
set-aside, are likely to have the greatest negative impact on
biodiversity, geodiversity, landscape diversity and could damage
important carbon stores.
10.3 Growth of this sector is likely to increase
competition for land between food, non food and conservation purposes,
potentially impacting upon agri-environment scheme uptake, particularly
in arable areas.
10.4 An overall expansion in the area of
intensive monoculture may also increase the barriers to the adaptation
of England's natural environment in the face of climate change.
11. The global nature of the transport biofuels
market means that there is real potential for rising demand in
the UK and EU to contribute to negative environmental impacts
elsewhere, particularly in Latin America and South East Asia.
As well as the direct impacts on biodiversity and soils, the conversion
of these natural areas can release large quantities of greenhouse
gases and risk undermining the potential contribution of biofuels
to tackling climate change.
SUSTAINABILITY REPORTING
AND CERTIFICATION
12. Natural England recognises that as yet
there is no international agreement on what constitutes a sustainably
produced biofuel. We are supportive of the planned introduction
of a certification system with mandatory, robust minimum environmental
standards under the Renewable Transport Fuel Obligation in 2011.
We would recommend that the Government works to promote the adoption
of these standards across the EU and globally, as swiftly as possible.
13. As well as certification of the environmental
sustainability of biofuel production through the Renewable Transport
Fuel Obligation, fuels sold in the UK should be labelled according
to the environmental standards that they meet, so that consumers
can make informed choices.
14. The majority of feedstocks for biofuels
contributing to the 5% Renewable Transport Fuel Obligation target
are likely to be grown outside of the UK, where they are less
expensive to produce and where, in some cases, significant adverse
impacts on the natural environment have been reported. Government
must, through the EU, work closely with the industry and countries
exporting biofuels and feedstocks, to address the risk of significant
environmental impacts being promulgated by a weak worldwide reporting
and certification framework.
DEVELOPMENT OF
THE EVIDENCE
BASE
15. There is much speculation about the
extent to which the increased global demand for biofuels will
lead to significant changes in land use in England. Simple extrapolations
of the amount of land that may be required to meet for example
the EU Directive on biofuels, do not take into account the fact
that the biofuels market will be global and that production will
come from countries and regions which have the most suitable conditions
and can produce the fuel at the lowest cost. These areas, however,
may also have the greatest overall impact on the natural environment.
Natural England stresses that there is a need for further evidence
of the economic viability of biofuel production in England, relative
to the rest of the world and the consequences for current land
use.
16. The introduction of the Renewable Transport
Fuel Obligation could have impacts on the agricultural and food
sectors if increased competition for land and other factors contribute
to higher land values and higher values for dual-purpose crops
such as oil seed rape and wheat. Defra must closely monitor these
impacts and refine regulation of the sector accordingly.
8 October 2007
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