Scottish Natural Heritage Bioenergy and the natural heritage · ii Bioenergy and the natural heritage Issues ... be based on a full energy product life cycle and reflect ... 22 Changes

Scottish Natural Heritage

Bioenergyand the natural heritage

ii Bioenergy and the natural heritage

Issues and Revisions

SNH’s Approach and Summary

Background and Context

Implementation Guidance

First issued June 2009 June 2009 June 2009

Revised

Document Status

(at June 2009) Green - current

Contact

Jane ClarkSNH Sustainable Land UseSilvan House231 Corstorphine RoadEdinburghEH12 7AT

e: [email protected]

tel: 0131 316 2640

Document History

Section Page

Summary 1

Our aproach 3

Background and context 9

Implementation guidance 27

Contents

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Bioenergyand the natural heritageSummary

Policy 2009/1

Issued June 2009

Last revised

Introduction

SNH supports the development of bioenergy for the contribution it can make to mitigate against climate change. SNH recognises that bioenergy offers opportunities to use land in a way that could be beneficial to the natural heritage and support rural development in Scotland. However, there is a risk that the development of bioenergy could affect land use with adverse effects on biodiversity, landscapes, soil and water quality. Moreover, insufficient local resources, particularly for transport biofuels, may lead to significant pressure on the environment globally.

SNH recommends that in pursuing bioenergy development, the following principles should be adhered to:

• Support for bioenergy should be set within a policy framework that seeks as a priority to reduce energy demand and improve energy efficiency.

• Bioenergy policy should incentivise types and uses of biomass that represent the most efficient use of land with regards to greenhouse gas savings while safeguarding or enhancing natural heritage interests.

• Use of waste biomass should be encouraged so as to limit the pressure for dedicated feedstocks production, provided the waste management hierarchy is being adhered to.

� Bioenergy and the natural heritage

• The production of bioenergy feedstocks must be carried out in a sustainable way, which includes protecting the natural heritage.

• Demand for bioenergy in Scotland should not create additional pressures on ecosystems overseas. The development of bioenergy must be consistent with international environmental commitments, including the global 2010 target on biodiversity loss.

• Mandatory greenhouse gas savings and sustainability standards must be applied to all transport biofuels production and trade to ensure biofuels are sustainably produced and effectively contribute to climate change objectives.

• The assessment of net greenhouse gas emissions for bioenergy products must be based on a full energy product life cycle and reflect emissions resulting from change in land use. A life cycle assessment of all bioenergy options is needed to allow an informed choice to be made to ensure maximum climate change benefits.

• Bioenergy plants should be appropriately located and scaled to avoid adverse off-site impacts, minimise energy losses and maximise greenhouse gas savings.

• Bioenergy should be developed in a way that provides net benefits for the rural economy and contributes to a sustainable and dynamic economy for Scotland.

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Bioenergyand the natural heritageSNH’s approach

Policy 2009/1

Issued June 2009

Last revised

Introduction

1 Bioenergy is a form of renewable energy produced from biomass, with applications in the heat, electricity and transport sectors. There are three main types of biomass materials, or feedstocks, including forest resources, energy crops and waste residues. Seaweeds and microalgae are other resources which are currently being investigated for bioenergy applications.

2 SNH strongly supports the development of renewable energy, including bioenergy, as a part of the Government’s action on climate change. This support is dependent on a high priority being placed on securing emissions reduction through energy efficiency and reduction in energy demand, and on ensuring that impacts on the natural heritage are minimised. The important role that renewables should play in any long term energy mix is set out in our Policy Statement Energy and the Natural Heritage[1] (06/02). SNH’s general Renewable Policy Statement, SNH’s Policy on Renewable Energy[2] (01/02), sets out our support for all types of renewables provided a mix of technologies are developed and these are located in areas with minimum natural heritage impacts.

3 The development of bioenergy in Scotland offers the opportunity to utilise land for forestry and energy crops in a way which could benefit both landscapes and wildlife and which can be accommodated alongside existing land management practices. The bioenergy industry provides opportunities for enhanced rural employment and can contribute to a sustainable and dynamic economy for Scotland.


4 However, if care is not taken in the production of feedstocks, the development of bioenergy could have adverse impacts on biodiversity, landscapes, soil and water quality. The nature of impacts will depend on the land use being replaced, the feedstocks used, the management practices and the scale and spatial distribution of developments. At the global level, there is a risk that bioenergy feedstocks could be derived from unsustainable production systems. In particular, the development of the transport biofuel industry is creating new pressures on the environment globally.

5 Bioenergy should be developed within a wider sustainable development framework, such as to ensure that bioenergy feedstocks are only produced according to sustainable management practices. Targets should only be set at levels that can be reached in a fully sustainable way.

SNH’s policy approach

Transport biofuels

6 SNH supports the overall development of transport biofuels as one part of a strategy to address emissions from the transport sector. This should be set within a policy framework that seeks as a priority to reduce demand and improve energy efficiency.

7 The greenhouse gas savings delivered by many first generation transport biofuels are modest, even when best practice is used in crop management. SNH supports the work currently underway to develop processing technologies for the use of second and third generation biofuels, which will allow the exploitation of a greater range of feedstocks with the potential to yield greater reductions in life cycle greenhouse gas emissions and reduce competition for land between food, non-food and nature conservation uses.

8 Measures to support transport biofuels must be consistent with climate change objectives and compatible with EU and global objectives to halt biodiversity loss by 2010 and beyond.

9 SNH supports the EU requirement that mandatory sustainability criteria and minimum greenhouse gas savings be applied to all transport biofuels. Transport biofuels that meet minimum sustainability and greenhouse gas savings requirements should then be rewarded according to the carbon savings they offer. SNH encourages the development of voluntary certification and accreditation schemes that guarantee a higher level of sustainability.

10 In assessing the carbon saving potential of biofuels, all greenhouse gas emissions should be taken into account through life cycle analysis, including those resulting from change in land use, and the assessment should be based on emission and resource use performance over a full energy product life cycle.

11 Policy decision-making must be based on robust evidence of the environmental risks and benefits of biofuels, including any indirect impacts resulting from the production of biofuel feedstocks.

12 SNH’s position on transport biofuels is also outlined in the Joint Nature Conservation Committee (JNCC)1 Position Statement on Transport Biofuels and Biodiversity[3]. SNH supports the EU requirement that biofuels deliver at least 35% greenhouse gas savings and believes that this threshold should increase over time, as technology improves and the market develops. SNH support is currently not limited to biofuels meeting at least a 50% greenhouse gas savings threshold as recommended in the JNCC Position Statement.

� The JNCC delivers the UK and international responsibilities of the Council for Nature Conservation and the Countryside, the Countryside Council for Wales, Natural England and Scottish Natural Heritage.

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Biomass for electricity and heating

13 Use of biomass for heating or in Combined Heat and Power plants should be encouraged in preference to its use for electricity production, as it leads to substantially greater greenhouse gas savings. Any incentive scheme should ensure that the financial rewards available from different bioenergy options reflect their relative potential to reduce greenhouse gas emissions.

14 Widespread use of biomass for domestic or small business heating should be encouraged, including small-scale district heating schemes, particularly through the use of woodfuel in rural Scotland, and should be used to promote energy awareness. However there is a need for clearer regulations to control emissions from domestic woodfuel boilers to reduce impacts on local air quality.

15 SNH supports the development of sustainable supply chains to ensure significant greenhouse gas savings are delivered and natural heritage interests are safeguarded. We welcome the EU’s proposed analysis on the potential for a sustainability scheme for bioenergy other than biofuels. This should inform on the feasibility of agreeing EU-wide minimum sustainability criteria for the electricity and heat sectors.

Production of bioenergy feedstocks

16 Most impacts on the natural heritage will arise in the production of bioenergy feedstocks (forestry and agriculture). SNH’s support for bioenergy is dependent upon good practice being followed in feedstocks production.

17 Planting for bioenergy feedstocks should not be undertaken on areas designated under the Habitats or Birds Directives, or within habitats or affecting species identified as of special importance within the Scottish Biodiversity Strategy. This includes some habitats within forestry and farmland.

18 SNH encourages the use of certification schemes, such as the UK Woodland Assurance Standard, to ensure high standards in sustainable woodland management are followed. Use of existing forestry guidelines as they relate to forest harvesting and replanting and management of new plantings should be standard practice. SNH supports the revision of standards to reflect climate change objectives and promote best practice in woodfuel production.

19 Sustainability criteria for transport biofuels must be robust so as to provide assurance that natural heritage and wider sustainable development interests are adequately safeguarded in the production of feedstocks.

20 There is a need for more research to identify the impacts of energy crops on the natural heritage and develop technologies and management practices that enhance environmental sustainability while minimising greenhouse gas emissions.

21 Comprehensive and accessible environmental guidelines should be made available to help ensure that only a good environmental standard of feedstocks production is pursued. These should ensure practices that maximise biodiversity and landscape benefits without significant detrimental impacts on soil and water quality or any increase in harmful emissions.

22 Changes in woodland structure and overall land use should be carefully designed to maintain and enhance connectivity of woodland and open ground habitats to assist biodiversity in adapting to the effects of climate change.

23 The development of the bioenergy industry has diverse and potentially significant implications for land use, landscapes and habitats. There is a need for ongoing review of the drivers stimulating the growth of the bioenergy sector and the scale of changes in rural land use in response to the demand for bioenergy feedstocks. Regulations and incentives should be reviewed and adapted so that changes in land use are managed and do not result in conflicts between food, non-food and nature


conservation interests. The development of bioenergy reinforces the need to consider strategically how to guide future land use in Scotland.

24 Provided the use of organic waste to energy fits within the waste management hierarchy, with highest priority being placed on waste reduction, reuse and recycling, there are no significant natural heritage impacts associated with energy from waste. We recommend that high priority be given to the use of such residual organic waste for energy, and also to making use of residues from agriculture and forestry provided their removal does not have adverse environmental impacts. Dedicated production of bioenergy feedstocks should generally take a lower priority. SNH supports energy from waste that conforms to the Sustainable Development Commission Scotland’s advice to government contained in A burning issue – Energy from waste in Scotland[4].

Bioenergy infrastructure

25 Bioenergy plants should be appropriately located and scaled to avoid adverse off-site impacts and minimise greenhouse gas emissions and energy losses.

26 Regional spatial guidance should be developed to identify constraints and opportunities for bioenergy developments. This should consider the existing land uses and bioenergy resource, factors affecting supply and demand and identify environmental sensitivities. This would help planners fulfil the objectives of Scottish Planning Policy 6: Renewable energy (or the section on renewable energy within the consolidated Scottish Planning Policy once published) and guide developers towards the most appropriate locations for plants, and provide guidance to land managers and other stakeholders on suitable areas for growing bioenergy feedstocks.

27 Where practical, plants should preferably be located in brownfield sites or co-located with other wood processing industries to minimise transport requirements; and locations should be close to the point of demand and adjacent to transport corridors to avoid the need for new roads.

SNH’s role

28 In delivering its policy on bioenergy, SNH will:

• advise the Scottish Government, the UK Government and the European Union decision-making bodies on the implications of bioenergy for the natural heritage and solutions for the development of a sustainable bioenergy sector.

• encourage a strategic approach towards land use, as embodied in the Indicative Forestry Strategies, to be extended to rural land use in general.

• advise, as required, on local initiatives for the development of bioenergy and seek to promote best environmental practice in the extraction/ production of bioenergy feedstocks.

• advise, as required, under the Scotland Rural Development Programme on applications for grants for the production of bioenergy feedstocks or installation of bioenergy capacity, and the implication of proposed activities on features of natural heritage importance.

• advise, as required, under the Environmental Impact Assessment (Agriculture) (Scotland) Regulations 2006 and Environmental Impact Assessment (Forestry) (Scotland) Regulations 1999, on the implications of land use change to accommodate feedstocks production on features of natural heritage importance.

• assess applications for consent under the Nature Conservation (Scotland) Act 2004 for the extraction / production of bioenergy feedstocks on designated sites where this qualifies as an operation requiring consent.

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• support the general guidance set out in planning policies (currently being reviewed, updated and condensed) and provide advice to local authorities and developers on bioenergy infrastructure within that context.

• work with other stakeholders and seek joint approaches to areas of common interest to ensure the development of an economically and environmentally sustainable bioenergy sector.

• support research into the development of sustainable practices for the production of bioenergy feedstocks.

Notes

1 Scottish Natural Heritage (2006) Energy and the natural heritage policy statement, Policy Statement No. 06/02, Inverness, SNH.http://www.snh.org.uk/pdfs/polstat/EnergyPolStat.pdf

2 Scottish Natural Heritage (2001) SNH’s policy on renewable energy, Policy Statement No. 01/02, Inverness, SNH.http://www.snh.org.uk/pdfs/polstat/renewenergy.pdf

3 Joint Nature Conservation Committee (2007) Transport biofuels and biodiversity: JNCC position statement, Peterborough, JNCC.http://www.jncc.gov.uk/pdf/2007_positionstatement_Biofuel_nov07.pdf

4 Sustainable Development Commission Scotland (2008) A burning issue – Energy from waste in Scotland, Edinburgh, SDC.


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Bioenergyand the natural heritageBackground and context

Policy 2009/1

Issued June 2009

Last revised

Introduction

1 Bioenergy is produced whenever organic non-fossil material of biological origin is converted into energy. There are several potential types of biomass material including forest resources, energy crops, algae and waste residues. Peat used to be a traditional form of biomass for energy, especially in some areas of Scotland, but the very slow rate of accumulation makes this a non-renewable resource and unsuitable for extensive use as a biomass resource.

2 Biomass has the advantage of providing a renewable source of energy (referred to as bioenergy) and can help mitigate against climate change. It has the potential to be carbon neutral depending on the way it is produced and in principle can reduce carbon dioxide emissions across all the energy sectors (electricity, transport and heat). Bioenergy is a type of renewable energy which remains under-exploited in Scotland and which does not have the disadvantage of intermittency associated with some other types of renewable energy. Interest in bioenergy is also being driven by concerns for energy security, and the desire for diversification in farming and forestry, and rural development.

3 Biomass can be used directly to generate heat or electricity - domestically in stoves or woodfuel boilers or at a community/ regional level through biomass power plants and Combined Heat and Power (CHP). Biomass materials (or feedstocks) can also be used on a larger scale through co-firing in existing fossil fuel power stations and through the

�0 Bioenergy and the natural heritage

use of liquid biofuels in the transport sector. Waste to energy schemes are available, either through thermal processes or anaerobic digestion, though the potential mixed nature of some wastes used (which can for example include plastics) means that this cannot always be classed as renewable.

Policy context

4 Climate change is increasingly acting as a driver to change energy generation and consumption patterns in Europe and around the globe. A central aim is to reduce greenhouse gas (GHG) emissions, especially carbon dioxide from the burning of fossil fuels. The UK Climate Change Act 2008 has introduced a legally binding target of at least an 80% cut in greenhouse gas emissions by 2050, to be achieved through action in the UK and abroad. The Climate Change (Scotland) Bill 2009 sets a statutory target of reducing emissions by 80 per cent by 2050. It also sets an interim target for a 42 per cent cut in emissions by 2020. Within this context, renewables have a key role to play in providing an alternative energy source. The UK Energy White Paper 2007 acknowledged the importance of renewables for meeting future energy needs, with bioenergy considered a key part of the renewables portfolio.

5 The European Environment Agency suggested that significant amounts of biomass could be produced within Europe, even if strict environmental constraints were applied[1]. The UK Environment, Food & Rural Affairs Committee produced a report[2] in 2006, calling on the UK Government to show more commitment to the promotion and use of biomass, particularly in relation to renewable heat and on developing biofuels for transport from cellulosic materials like wood. This followed up earlier calls for a greater focus on renewable heat from the Royal Commission for Environmental Pollution[3], which called for the phasing in of energy crops, and a report from the Sustainable Development Commission highlighting the significant potential of woodfuels[4] in Scotland to address carbon dioxide emissions. The latter report recommended that any woodfuel development would be most effective at a small scale in rural areas, potentially meeting 5-11% of domestic space and heating requirements.

6 A report[5] by the Scottish Executive’s Forum for Renewable Energy Development Scotland group advised that a Scottish biomass industry based on woodfuel resources could supply up to 450MW of electricity. A separate study predicted that biomass from short rotation coppice (SRC) and forest residues could provide up to 1 GW of electricity, based on land suitability and an assumption of 5% take up of SRC by farmers, and about 1.9 GW generation capacity if used for CHP[6]. Galbraith[7] also provided a range of values for the potential of bioenergy feedstocks in Scotland, based on forestry, agricultural and waste sources. This report estimated that there might be about 500MW of electricity potential and 1265 MW for heat and CHP. The Sustainable Development Commission Scotland advised the Scottish Government that there is a role for energy from waste within an integrated strategy for waste minimisation, reuse and recycling[8].

7 A number of measures have been implemented to support the development of a bioenergy industry in Scotland. The Scottish Executive produced a Scottish Biomass Action Plan in 2007. The Scottish Government has set a target to achieve 50% of electricity from renewables by 2020. The Renewables Obligation Scotland (ROS), which is the main driver behind renewable electricity development in Scotland, supports the development of dedicated bioenergy plants and co-firing of biomass alongside fossil fuels. The banding of the ROS should stimulate the bioenergy sector further. Recommendations to the Scottish Government from the Forum for Renewable Energy Development Scotland highlighted in 2008 the currently untapped potential for renewable heat in Scotland[9]. The Renewable Energy Action Plan published in 2009 introduces a framework for the promotion of renewable heat to reach a 11% target of heat demand to be met from renewable sources by 2020.

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8 Grants to support the production of some bioenergy feedstocks are available under Rural Development Contracts. Capital grants schemes are available to support the establishment of infrastructure and supply chains. The Scottish Government introduced a Biomass Support Scheme, now closed, and a Biomass Heat Scheme (2009-2011) to help promote the installation of biomass heating systems.

9 At the EU level, the Directive on the promotion of the use of energy from renewable sources requires that renewable fuels (including but not limited to biofuels) represent a 10% share of transport fuels (by energy content) by 2020. The Directive proposes that only biofuels that fulfil sustainability criteria and meet a minimum 35% GHG emissions reduction threshold are taken into account for compliance with the target. It also proposes that a sustainability scheme be considered for other types of bioenergy. The amended Fuel Quality Directive, which requires suppliers of fuels to reduce life cycle GHG emissions per unit of energy to at least 6% by 2020 (from 2010), will also drive demand for biofuels. In the UK, the Department for Transport has introduced a Renewables Transport Fuel Obligation (RTFO). Under the RTFO, suppliers claiming certificates are required to submit reports on both the net GHG savings and sustainability of the biofuels they supply.

Types of bioenergy feedstocks and uses

10 The main types of bioenergy feedstocks can be divided into forestry materials, energy crops (including perennial crops e.g. short rotation coppice, grasses and arable crops), and residues or waste products. Seaweeds and microalgae are other resources which are currently being investigated for bioenergy applications.

11 The Forum for Renewable Energy Development Scotland’s report[10] highlighted that there will be an increase in forestry supplies in the next decade or so, as a result of many plantations reaching maturity. Thus there is already an established resource in place that can be used for the generation of heat and electricity. The Scottish Forestry Strategy[11] has outlined commitment to the development of a bioenergy industry through the continued development of commercial forestry, including short rotation forestry (SRF), and the utilisation of secondary materials including residues and co-products from other wood processing industries. A Woodfuel Task Force, which was set up with the aim of increasing the supply of wood for renewable energy production, developed recommendations to stimulate the development of wood for energy in Scotland[12].

12 On agricultural land, there are options to diversify into SRC such as willow or poplar or perennial grasses such as Miscanthus, switch grass or reed canary grass. This may involve a change of cropping practice, predominantly on good quality agricultural land. Business barriers such as the 3-year delay before the first crop and the greater margins offered by arable crops on good quality land have resulted in a limited uptake of SRC[13]. Interest in perennial grasses has remained limited in Scotland. Farmers could also diversify into SRF, which could make use of poorer quality land. SRF involves the cultivation of fast growing tree species such as alder, ash, birch or eucalyptus.

13 Traditional arable crops, including oilseed crops (e.g. oilseed rape), sugar crops and starch crops (e.g. wheat), can be grown for the transport biofuel market. In Scotland, oilseed rape is the arable crop with the best potential for biofuel production[14]. Estimates have suggested that to meet a 5% transport biofuel target for the UK alone, between 1.2 and 1.9 million hectares of arable land would need to be devoted to oilseed rape, wheat and sugar beet (there is approximately 6 million hectares of land in arable production in the UK)[15, 16, 17]. Such estimates are largely theoretical but provide an indication of the land requirement for biofuel production. The majority of transport biofuels sold in the UK are actually produced from imported feedstocks[18]

14 Internationally, a large amount of research is underway to develop second generation transport biofuels, though these are yet to be commercially available. This involves

�� Bioenergy and the natural heritage

breaking down lignocellulosic material (e.g. woody biomass) through a process of biological or thermochemical conversion to produce biofuels. Second generation biofuels should be more efficient and have the potential to offer greater energy yields and GHG savings per hectare than conventional crops[19]. The ability to grow and use a greater range of plant materials will extend the land suitable for growing transport biofuel feedstocks beyond high grade agricultural land and stimulate a shift away from the competitive use of traditional food crops.

15 There is increasing interest in microalgae which can be farmed in open ponds or closed systems to produce biodiesel. Microalgae production systems are efficient and significantly less land intensive than energy crops[20, 21]. Seaweed biomass is another potential source of energy. Seaweeds could be harvested or farmed to produce biogas or turned into ethanol[22]. Commercial applications of algae for energy generation are yet to be deployed.

16 Waste and residues may also be used as bioenergy feedstocks, with applications in heat, electricity and transport. Feedstocks can include untreated wood from sawmills, sludge from paper or pulp mills, agricultural crop residues and manures, and other organic wastes such as the waste biomass content of residual municipal, commercial or industrial waste.

17 Biomass for heat and power can offer considerable GHG savings relative to fossil fuel based systems (up to 90% depending on the systems being compared)[23]. In the current stage of technological development, the Carbon Trust report, Biomass Sector Review for the Carbon Trust[24], concluded that the development of a biomass heat sector had the greatest potential to deliver cost-effective carbon savings. The GHG balances from feedstocks production being all equal, biomass heat and CHP will deliver higher GHG savings than electricity[25, 26]. Assuming no land use change, savings in GHG emissions from current transport biofuel technologies can vary between -20% and 80% for bioethanol and 40-50% for biodiesel[27]. Land use change for feedstocks production is a very important variable to consider in calculating the GHG balance of bioenergy over a full life cycle.1

18 Bioenergy developments offer new markets for agricultural and forestry products and provide farmers and land managers with diversification opportunities. Local economic benefits should also be realised from installation, maintenance, and electricity and/or heat sales. The demand for feedstocks should enable the bioenergy sector to provide ongoing employment opportunities in rural areas.

Impacts of bioenergy upon the natural heritage

19 The development of bioenergy could have a significant impact on the way the rural environment is managed, and there is a need to ensure that any land use changes are monitored to ensure that food, non-food and nature conservation objectives are achieved sustainably. Care is needed to avoid affecting local soil and water quality while consideration must be given to ensuring benefits to biodiversity and the landscape.

20 There are various potential impacts associated with the development of bioenergy, from source to plant. The nature of the impacts depends on the type of feedstock used, cultivation practices, the siting and scale of energy production plants. Whether such impacts represent a net benefit or an adverse impact will also crucially depend on the land use which bioenergy feedstocks production is replacing.

21 On a global scale, it is necessary to consider the impact demand for transport biofuels will have on the international market. Insufficient resources in the UK or the EU will increase demand for imports (e.g. for biodiesel from palm oil grown in Southeast Asia), which can result in large volumes of carbon dioxide emissions and the loss of biodiversity.

1 For details on life cycle analysis, activity data and emission factors see, e.g. Guide to PAS 2050: How to assess the carbon footprint of goods and services (2008) published by Defra, The Carbon Trust and BSi British Standards. http;//www.bsigroup.com/upload/Standards%20&20Publications/Energy/PAS2050%20Guide.pdf (15 May 2009)


22 Increased demand can lead to the loss of habitats and species of international importance to make way for energy crops. Carbon losses following vegetation clearing in tropical ecosystems can be very significant and negate any subsequent savings from biofuel use. Research showed that, over a thirty-year period, restoring natural forests was more efficient at reducing carbon emissions than biofuels produced on an equivalent land area[28]. Change in land use from habitats with high above and below-ground carbon stocks, such as rainforest or peatland habitats, results in large amounts of carbon emissions that will offset any carbon savings delivered by biofuels and could in fact lead to greater carbon dioxide emissions than using an equivalent amount of fossil fuel (per energy content) for decades or even centuries[29, 30].

23 The clearing of vegetation can also lead to soil erosion and sedimentation build-up in the water systems, and in many cases the biofuel crop will require extensive irrigation and fertiliser applications. There is also the risk of conflict between food and non-food agricultural land use, which might displace food production, affect food security, and result in encroachment on valuable habitats and GHG emissions from indirect land use change[31].

24 Use of bioenergy feedstocks from unsustainable sources must be strongly discouraged. It is essential that biofuels be subject to rigorous appraisal to ensure that production practices are fully sustainable and mechanisms are developed to assess and prevent indirect land use change.

25 Algal production systems are not discussed below as commercial applications of microalgae and seaweeds for bioenergy are yet to be deployed.

Production and extraction of bioenergy feedstocks in Scotland

Forestry sources

26 Forestry products are a readily available bioenergy feedstock, with the potential to enhance the economics of forestry and lead to long-term improvements in forest management. With the right precautions, the extraction of forestry residues and thinnings from managed forests is unlikely to have any impact on the natural heritage, and will offer an opportunity to utilise material previously considered unusable, with additional extraction of roundwood also possible up to a sustainable yield. Currently extensive thinning is not a viable option in some plantations due to landform or access constraints but if a new bioenergy market develops this could allow otherwise uneconomic thinning to take place. Thinning also increases instability, which is often the reason why forests are not thinned. Climate modelling indicates Scotland should experience stormier and wetter winters in the future[32], which suggests that climate change might reduce opportunities for thinning.

27 Longer term, there may be a demand for more forestry plantations. Some large historic plantations, which are of value in natural heritage terms, may hitherto have been overlooked as uneconomic, and extraction may become commercially viable if bioenergy creates a more favourable market. There may be natural heritage implications if replanting is on semi-natural land or if reinvestment in forest plantations moves away from the current policy of establishing more mixed native woodlands.

28 There is no commercial SRF in Scotland but the development of a bioenergy industry could be a driver for expansion. The environmental implications of large scale SRF in Scotland are not fully understood. Potential impacts are likely to depend on the type of species used, the site and management[33]. Research is currently being undertaken into the impacts of SRF.

29 Compliance with the UK Forestry Standard[34] and associated guidelines will help mitigate against potential adverse impacts on soil quality and the water environment, and ensure that woodland creation proposals take account of biodiversity considerations. The UK Forestry Standard is to be revised with a view to promote carbon friendly forestry practices amongst other things. Any public support for


woodland creation requires adherence to the UK Forestry Standard and is subject to statutory consultation. The UK Woodland Assurance Standard[35] provides a voluntary certification process for forest owners and promotes high standards in sustainable woodland management.

Impacts on soil and water quality

30 Not all forestry material should be extracted. The propensity for damage will depend on the sensitivity of the site[36]. While brash and undergrowth can provide a valuable biomass resource, its extraction can disturb local ecosystems, and affect nutrient levels. A significant loss of undergrowth can also affect forest regeneration by removing seedlings, though it is expected that managed forests will be re-planted cyclically. The removal of top branches can affect nutrient cycling; coniferous material should be given the opportunity to drop needles before removal. The length of time to leave material on site to ensure nutrients are released into the soil is being considered. The proportion of brash that needs to be left on the soil in order to maintain soil quality will be dependent on the local soil type and climatic conditions.

31 Some forest floor residue material should be retained to protect against soil erosion and it is important to avoid soil compaction through the use of heavy extraction equipment e.g. for chipping on site. Brash mats fulfill an essential function in forest harvesting by helping to prevent compaction. Compaction is particularly likely in wet or peaty soils, which are common in Scotland. Opportunities for forest residue extraction on upland soils may be significantly limited by the risks of compaction or acidification[37].

32 The loss of large amounts of residues can increase the likelihood of soil acidification. Fertilisation through the application of wood ash may help to compensate for increased soil acidity[38]. However recycling of wood ash must be properly monitored, with controls on contaminants, to ensure there is no build-up of pollutants in the soil or adjacent watercourses. Potential impacts on water quality are closely linked to effects on the soil and are controlled by the Water Environment (Controlled Activities Scotland) Regulations 2005 and General Binding Rules for Controlling Diffuse Pollution.

33 Whole tree harvesting (WTH) is an intensive harvest technique[39 40], as it involves the removal of all materials above ground and sometimes stumps. This practice might result in nutrient losses and soil compaction. Impacts are dependent on site-specific characteristics.

34 Changes in access can affect the type and use of biomass resources. The wider use of forestry products or residues is likely to lead to a need for new forest tracks, and this can have natural heritage impacts associated with construction and ongoing use. Changes in access may open up new forest areas, previously remote and uneconomic. In some cases, harvesting of these unmanaged forests should be avoided, on account of their natural heritage value.

Impacts on biodiversity

35 The biodiversity value of forests varies, and not all are suitable for biomass extraction. Native woodlands of high biodiversity value, such as SSSI2/ Natura woodlands, and ancient or historic woodlands (which tend to be limited or fragmented) are not considered suitable for biomass extraction. They are of significant natural heritage value, and minimal intervention is to be encouraged. Currently many native woodland sites have insufficient amounts of deadwood, and even extraction of this should be avoided, as the deadwood provides a valuable ecosystem function.

36 Provided good woodland practice is followed, there are unlikely to be any significant adverse impacts on biodiversity from the use of roundwood from managed forestry[41].

2 Sites of Specific Scientific Interest


Some thinning and felling practices could help to encourage the development of a ground cover ecosystem on the forest floor, with better regeneration and an increase in biodiversity. An irregular thinning pattern is preferable to encourage structural diversity. Some residues should be retained on the site to provide microhabitats. The deadwood resource should not be depleted or prevented from building up. As a minimum requirement, it is recommended that deadwood (both standing and lying) should amount to a minimum of 5% of the stand volume or 20m3 3 (whichever is the least)[42]. Where managed woodland provides a habitat for key species, such as capercaillie, use should be restricted to maintain the habitat. Some managed native woodlands may have ‘plantation’ aspects that are better suited for exploitation for bioenergy, though this should not compromise objectives to encourage natural regeneration.

37 Overall, where managed forestry is of limited natural heritage value, there is scope for biomass exploitation to deliver net associated benefits for biodiversity. This could help promote one of the Scottish Forestry Strategy’s priorities, which is to encourage the restructuring of woodlands to increase structural and species diversity.

38 New planting on semi-natural habitats could have impacts on biodiversity. Woodland planting proposals on semi-natural habitats will fall under the scope of the Environmental Impact Assessment (Forestry) (Scotland) Regulations 1999 and will require compliance with the Nature Conservation (Scotland) Act 2004 if on a SSSI.

39 Edge woodland within managed agricultural land can also be a biomass source, which may offer an economic incentive to managing this resource. Management should not be detrimental to biodiversity interests. Any felling licenses issued by the Forestry Commission on private land have to comply with the Nature Conservation (Scotland) Act 2004.

40 Change in woodland structure, land use and infrastructure (e.g. tracks) could affect the connectivity of woodland and open ground habitats. Woodfuel should not be produced and extracted in a way that would limit the ability of forest biodiversity to adapt to climate change.

Impacts on climate change

41 The extraction and planting of trees cause soil disturbance which results in emissions of carbon dioxide. Conversely carbon will be sequestered by tree growth. Hence the carbon balance of the system will depend on the relative rate of absorption and emissions post afforestation[43].

42 Whether biomass growth and extraction effectively mitigate against climate changes will depend on the carbon payback time. Soil type is one factor that will influence carbon payback time. In Scotland, soils have a high carbon content, accounting for over 50% of total UK carbon soil content[44].

43 New planting on carbon-rich soils is not recommended as it can change the soil from a carbon sink to a carbon source. Though soil carbon losses will eventually be compensated by carbon uptake by trees[45], the carbon payback time is too long. Afforestation on mineral soils should provide better opportunities for carbon sequestration.

44 Destumping can cause significant soil disturbance; in soils with a high carbon content, this will result in carbon dioxide emissions that could offset part of the carbon savings achieved by replacing fossil fuels with woodfuel. More research is needed to understand the carbon impacts of destumping.

45 Removing forestry as part of a peatland habitat restoration programme could be beneficial by providing long term carbon storage benefits that would outweigh short term losses. The impact of reversal of afforestation and peatland restoration on soil carbon budgets is not fully understood and is still being investigated.

3 20m3 amounts to a lorry load per ha; the most valuable deadwood is in larger pieces at least 100 mm in diameter.


46 Thinning operations for use as woodfuel should improve the overall carbon benefits of managed plantations. While the removal of brash can cause net emissions of carbon dioxide from the soil, this should be short term[46].

47 Old-growth woodlands can offer a valuable function as a carbon store (both below and above ground) whilst continuing to capture carbon[47]. Habitats that offer a valuable function as a carbon sink will make an immediate contribution to mitigation against climate change and as such need to be protected and enhanced.

Impacts on landscape and visual amenity

48 Provided existing forest management practices continues, such as shielding of felled sites and a move away from monoculture plantations, there should be no significant landscape impacts from the extraction of biomass material from managed forests. There is potential for a loss of landscape diversity and amenity if areas of native woodland are felled or heavily managed for biomass use. The Scottish Forestry Strategy recognises the importance of forestry in the landscape, which is delivered through mechanisms such as Landscape Character Assessments, Indicative Forestry Strategies, Local Forestry Frameworks, landscape designations such National Scenic Areas and the UK Forestry Standard and associated guidelines.

Energy crops

49 The potential impacts on the natural heritage from energy crops will depend on what land use is being replaced and how they are managed. In general, energy crops should be planted in cultivated agricultural areas, primarily those currently managed intensively for arable crops, or managed grasslands of low natural heritage value. SRC, as a woody crop, falls within the scope of the Environmental Impact Assessment (Forestry) (Scotland) Regulations 1999.

50 There may be interest in using genetically modified (GM) crops, in pursuit of greater energy yields without the public concerns associated with GM crops for food. Under the current EU regulatory framework, GM crops are assessed on a case-by-case basis for risks to human health and the environment before being authorised for placing on the market or released into the environment. SNH’s position on GMOs is outlined in the JNCC Position Statement on Genetically Modified Organisms and the Environment[48].


Perennial crops

51 If harvested cyclically, SRC willow can reduce the risk of soil erosion by providing better wind protection than that offered by arable crops. There is however a risk that SRC willow could lead to deterioration in soil quality. Harvest normally takes place in winter when wet weather and high soil water contents are more likely. Under these conditions, harvesting machinery can cause soil compaction[49].

52 SRC could cause nutrient depletion and deterioration in long-term fertility[50]. Nutrient removal will vary with the genotype used[51]. The use of a mix of varieties should help limit nutrient depletion, in comparison with the use of a single variety.

53 Willow coppice has a particularly high water requirement, and needs to be located in regions with high water availability, through a combination of good rainfall patterns and soil type/ depth, to avoid depletion of the water table and effects on existing water supplies and drainage patterns[52]. Willow plantations should not be located in or adjacent to areas of wetlands or wet meadows of conservation value.

54 Willow offers the advantage of tolerating high levels of heavy metals, and can have a role in bioremediation of contaminated land or waste treatment[53, 54]. When used in this way for bioremediation, the ash from the combustion of willow would need to be


disposed of in a way that prevents soil or water contamination from any accumulated heavy metal content.

55 Changes in the end use of the crop can affect management practices. If the crop is not to be used as food, there will be fewer restrictions imposed as a result of health concerns. This may lead to an increase in the use of sewage sludge (biosolids) as a fertiliser, with associated risks of soil contamination. If agricultural land is planted with energy crops and fertilised with sewage sludge, the farmer might not be able to convert the land to agriculture for human consumption for a period of years. The application of sewage sludge to agricultural land is controlled by SEPA under the terms of the Sewage Sludge (Use in Agriculture) Regulations 1989 (as amended).

Arable crops

56 Oilseed rape leaves relatively high levels of soil nitrogen compared to cereals.[55] Nitrate Vulnerable Zones (NVZs) in Scotland, which were designated to reduce water pollution caused by nitrates from agricultural sources, relate to intensively farmed areas where oilseed rape is grown[56]. Recommendations for nitrogen application in NVZs are based on crop requirements and restricted application timing applies[57]. This reduces the risk of loss of nitrogen to the environment. Risk of severe soil erosion is low[58]. Farmers must implement soil protection measures as part of the Good Agricultural and Environmental Conditions requirements.


Perennial crops

57 Planting of SRC within arable agricultural land could provide biodiversity benefits by increasing habitat heterogeneity[59]. It has been shown that SRC willow plantations can support a diverse invertebrate community in the canopy[60] and tend to contain a higher diversity of plants than intensively managed grasslands though plant communities will vary with the age of the stand, previous land use and management[61]. There is some evidence that commercial SRC willow in the UK can benefit bird species characteristic of scrub and woodland edge-type habitats and is used by a range of farmland bird species. However as the crop matures, the interior of large plots holds fewer birds than the edges or cut SRC. Some open ground specialists such as grey partridge do not seem to use SRC[62]. It has therefore been suggested that open farmland birds might be displaced by SRC particularly as the crop height and density increases[63]. Harvesting of SRC should avoid the nesting season. Ensuring a wide range of stand ages and thus some degree of cyclical harvesting should enhance benefits for farmland biodiversity.

58 Mixtures of different species and hybrids will enhance structural and functional diversity. By ensuring a mix of varieties within the coppice, a greater range of wildlife can be supported than with a single variety. Mixtures will also help to limit damage from pests and diseases[64].

59 Willow coppice has a high water demand and hence there is a need to ensure that willow plantations are not located in or adjacent to areas of wetland, which offer important habitats for birds. There is an obligation to protect many of these habitats under the EU Habitats & Birds Directives.

60 Perennial grasses also offer a very different habitat from open farmland. The understanding of the impacts of energy grasses on biodiversity is still limited. It has been suggested that Miscanthus within the first years of establishment may benefit birds in intensively managed lowland landscapes[65]. Miscanthus seems to offer more biodiversity benefits than reed canary grass[66].

61 It is important to consider the potential for contamination of areas of high conservation value through proximity to an energy crop site. There are risks to the pre-existing vegetation on these conservation areas associated with competition, shading, seed dispersal, vegetative colonisation of the protected site or through hybridisation of


native species (e.g. willow). Good practice precautions may need to be adopted such as biological screening or the use of non-reproducing varieties. Any introduction of non-native biomass-efficient varieties should be controlled to ensure they are non-invasive so that there are no long-term impacts on the biodiversity of the surrounding area.

62 There is need to understand ecological impacts at different spatial scales. Research is ongoing on the implications of land conversion to energy crops.

Arable crops

63 Oilseed rape is preferred by some birds to other crops. Spring-sown oilseed rape will be more beneficial than autumn-sown, as it will ensure the availability of stubble from the previous crop over winter for seed-eating birds. Results from the Farm Scale Evaluation trials showed that conventional (i.e. non GM) spring oilseed rape typically contained higher numbers of invertebrates and dicotyledon plants than conventional maize and beet, highlighting the value of this crop for farmland biodiversity[67, [68]. Overwintering oilseed rape stubbles support higher densities of seed-eating passerines than other crops[69].


64 There are significant differences in total GHG emissions from energy crops depending on a variety of factors such as crop choice and variety, crop management, and distance between the processing plant and the crop.[70] SRC would offer advantages over annual crops for carbon sequestration due to a more extensive root system and a longer growth cycle. The greatest potential for carbon sequestration under SRC will be on previously arable soils[71].

65 When producing transport biofuels from arable crops, fossil fuels are used throughout the process, from cultivation, transportation to processing. Nitrous oxide is a potent greenhouse gas, which is emitted from soils following fertiliser application. The use of nitrogen fertiliser accounts for most of the GHG emissions in the production of oilseed rape in Scotland[72]. It has been suggested that emissions of nitrous oxide from fertilised crops are higher than previously thought[73], which has implications for the calculation of GHG savings. The carbon footprint of transport biofuels should improve if the crop residues and co-products are utilised as a further energy source or feed for animals.

66 Depending on the previous land use, emissions resulting from land use change can also significantly affect GHG balances.


67 New coppice woodland, if well sited and managed in accordance with Forestry Commission guidance[74], can add to landscape diversity and compensate for past woodland and hedgerow losses within agricultural landscapes. However, care is needed in harvesting, as the timescales involved for crop growth and clearance are much longer than the annual cycle required for arable crops, hence changes in the landscape resulting from harvesting can be more dramatic, with potential adverse effects on amenity. This can be mitigated in most areas by harvesting cyclically, so that extensive areas are not harvested at once but are sectionally harvested in rotation. A complete change of land use from arable to SRC over extensive areas should be avoided due to the loss of both landscape and habitat diversity.

Impacts on access and recreation

68 It is important to ensure that any changes in land use do not restrict recreation or access opportunities. Establishment of corridors through SRC plantations should be designed to maintain access.


Waste by-products

69 The agricultural, manufacturing, commerce and domestic sectors all generate large quantities of organic wastes. Using this material to produce energy can reduce the amount of waste going to landfill thus further contributing to offset GHG emissions. Energy from waste should fit within the waste management hierarchy, with highest priority being placed on waste reduction, reuse and recycling (as applicable to the particular type of organic waste). Wastes may have existing applications. The indirect impacts of a switch from existing uses to bioenergy need to be understood.


70 Reducing the amount of waste going to landfill will lower the likelihood of soil and water contamination by leachates.

71 When organic waste is processed through anaerobic digestion to produce biogas, the organic by-products may then be returned to the soil as fertiliser and soil conditioner. Different types of organic waste can be used in anaerobic digestion, including food processing waste, abattoir waste, animal slurry, sewage sludge and segregated waste biomass from the domestic waste stream. Some of these may carry pollutants or present biosecurity risks. Application on land of digestates must be controlled to prevent contamination of soils. Spread of organic materials on land has already significant regulatory controls in place. However there is a need for more information on the characteristics and suitability of digestates for land application and their broad environmental impacts. Work has been ongoing to establish specifications for digestates.[75]

72 While there are advantages in using waste as a bioenergy feedstock, it is important that current uses of the waste are not neglected. In many cases agricultural wastes, such as crop residues, are mulched back into the soil as a natural fertiliser (or used as animal feed or for bedding). While replacement of mulching practice with higher fertiliser application could have a negative impact on soil and water quality, research suggests that up to 50% of agricultural residues could be removed from the site without any immediate loss of soil fertility[76].


73 Energy from waste should not have direct impacts on biodiversity.


74 Using organic waste to produce energy reduces the amount of methane released into the atmosphere through natural degradation in anaerobic conditions in a landfill site. Anaerobic digestion of livestock manures enables to reduce methane emissions from slurry storage on farms[77]. Methane is a potent greenhouse gas so tapping this resource to produce energy is a significant help in tackling climate change.


75 By reducing the amount of waste going to landfill, there might be visual and landscape benefits for traditional landfill sites.

Processing and energy production

76 The most common conversion processes are thermo-chemical processing, which converts the biomass material to heat or electricity; or biochemical processing, which can produce biofuels and biogas[78]. Feedstocks can be used wet (e.g. anaerobic digestion) or will have to be dried and processed in advance.


77 All forms of biomass will need transporting from source to processing plant and then on to the final point of use. There is a need to ensure that the distances involved are not so great that carbon dioxide emissions from transportation significantly reduce any carbon benefit derived from the use of biomass.

78 Biomass feedstocks used in heat and power plants can be converted into energy at different efficiency levels. There are minimum standards for a variety of energy conversion technologies. Using the heat generated in electricity production can significantly raise the energy conversion efficiency[79]. Using biomass in ‘electricity only’ plants where the capacity for producing significant heat exists does not represent good practice.

79 Depending on the scale of the plant, many of the impacts will be similar to those of any industrial development. Impacts on the natural heritage could result from loss of green space if sited in a greenbelt area, or through road expansion to accommodate greater transport pressures. There may also be some visual intrusion depending on where the plant is located. Care should be taken not to intrude on existing areas of amenity value such as public open space or green space or on areas of nature conservation value. There is also a need to assess any planned road widening necessary for the transport of material as this could result in changes in run-off and drainage patterns. Sensitive land uses should be avoided e.g. routes through or alongside areas of natural heritage value that are used by the public for recreation.

80 Bioenergy plants can generate off-site impacts through their demand for raw materials. Some bioenergy feedstocks can be bulky and expensive to transport, hence production will tend to take place close to the plants in which they are used. Therefore the establishment of plants has the potential to affect local land use, and depending on their size, location and spatial distribution, may have cumulative impacts on biodiversity, soil, water and landscape character. The extent of new planting likely to be required to meet the fuel needs of the plant should be assessed in the initial site planning, with consideration of potential cumulative impacts. While applications for bioenergy plants can entail an Environmental Impact Assessment, provision of information on the source of fuels is not a requirement. Scottish Planning Policy 6: Renewable energy (SPP6) requires planners to identify opportunities for bioenergy plants where there is an existing or potential resource, taking into account impacts on the natural and built heritage.

81 Emissions from bioenergy plants (>3MW) are controlled by SEPA under the Pollution Prevention and Control Regulations. Emissions that are potentially greater from bioenergy than from conventional power plants (e.g. oil & gas) include nitrogen oxides (NOX), ammonia (NH3) and particulate matter (PM). Emissions of sulphur dioxide (SO2) tend to be lower.[80] The levels of emissions will depend on the type of feedstock, the environment it was grown in and the presence of contaminants[81].

82 Any waste products, including ash, must be disposed of and this will involve additional transport emissions. Ash may be used in a number of applications, including as a possible fertiliser source. It is not suitable for application on clear-fell sites, as it would be exposed to wind blow and could cause contamination of water systems through erosion and run-off. The composition of the ash and the environmental implications arising from its application will depend on the type of feedstock, the site conditions and the conversion process[82]. Waste ash arising from biomass incinerators, which is used as a fertiliser, is regulated by SEPA under the terms of the Waste Management Licensing Regulations 1994 (as amended).

83 Smaller plants have the potential to be integrated into existing industrial and commercial developments for use as heat or electricity or into areas designated for future industrial, commercial, amenity or housing development without any significant impacts on the natural heritage. There may be opportunities to co-locate bioenergy plants with wood processing industries.


84 The development of small-scale bioenergy schemes to supply community energy needs could be of benefit by reducing domestic carbon dioxide emissions and encouraging energy self-sufficiency. There will be planning restrictions in ‘smoke controlled areas’, which will affect the siting of boilers for domestic or district heating schemes. Local emissions are regulated in these areas and domestic users are only allowed to use authorised fuels or exempt appliances that enable to burn smoky fuels without producing smoke. However the current regulations do not test for small particulates for which objectives and targets have been set under The Air Quality Strategy for England, Scotland, Wales and Northern Ireland[83, 84].

85 There are emissions from the end use of transport biofuels. Compared to conventional fuels, biodiesel will produce less carbon monoxide (CO), hydrocarbons (HC) and particulate matter (PM), but more nitrogen oxides (NOx)[85]. Bioethanol will release the same levels of NOx and HC as petrol and less PM, but more acetaldehyde (CH3CHO). With regard to vehicle performance, fuel economy impacts are variable, from slightly worse to better, depending on the type of biofuel and other factors such as the drive cycle[86, 87].

Conclusions

86 The development of bioenergy in Scotland offers the opportunity to utilise land in a way which could benefit both landscapes and wildlife and which can be accommodated alongside existing land management practices. The bioenergy industry also offers opportunities for enhanced rural employment along the supply chain. However, depending on the land use being replaced, the feedstocks used, production practices, and the scale and spatial distribution of developments, there are potentially adverse impacts on biodiversity, landscape, soil and water quality.

87 Good management practices can address many of the potential adverse impacts. Comprehensive and accessible environmental guidelines and best practice guidance should be made available to help ensure that only a good environmental standard of bioenergy production is pursued. These should ensure practices that maximise biodiversity and landscape benefits without significant detrimental impacts on soil and water quality or any increase in harmful emissions.

88 At the global level, there is a risk that bioenergy feedstocks could be derived from unsustainable production systems. Bioenergy should be developed within a wider sustainable development framework, such as to ensure that bioenergy feedstocks are only produced according to sustainable management practices.

89 A life cycle assessment of all bioenergy options is needed to allow an informed choice to be made to ensure maximum climate change benefits. The aim should be to develop a portfolio of source materials and uses that maximise GHG emission savings, and is balanced against other food or non-food demands (including nature conservation) requiring to be met from the available land resource.

Notes

1 European Environment Agency (2006) How much bioenergy can Europe produce without harming the environment, EEA Report 7/2006, Copenhagen, EEA.

2 Environment, Food & Rural Affairs Committee (2006) Climate change: the role of bioenergy, London, House of Commons.

3 Royal Commission for Environmental Pollution (2004) Biomass as a renewable Energy Source, London, RECP.

4 Sustainable Development Commission Scotland (2005). Woodfuel for warmth. A report on the issues surrounding the use of wood fuel for heat in Scotland, Edinburgh, SDC.


5 FREDS Biomass Energy Group (2005) Promoting and accelerating the market penetration of biomass technology in Scotland, Edinburgh, Scottish Executive.

6 Andersen, R.S., W. Towers, P. Smith (2005) ‘Assessing the potential for biomass energy to contribute to Scotland’s renewable energy needs’, Biomass & Bioenergy, Vol 29, 73-82.

7 Galbraith, D., Smith, P., Mortimer, N., Stewart, R., Hobson, M., McPherson, G., Matthews, R., Mitchell, P., Nijnik, M., Norris, J., Skiba, U., Smith, J. and Towers, W. (2006) Review of greenhouse gas life cycle emissions, air pollution impacts and economics of biomass production and consumption in Scotland, Environmental Research Report 2006/02, Edinburgh, Scottish Executive.

8 Sustainable Development Commission Scotland (2008) A burning issue – Energy from waste in Scotland, Edinburgh, SDC.

9 FREDS (2008) Scotland’s Renewable Heat Strategy: Recommendations to Scottish Ministers, Edinburgh, Scottish Government.

10 See FREDS Biomass Energy Group in note 5.

11 Forestry Commission Scotland (2006) The Scottish Forestry Strategy, Edinburgh, FCS.

12 Woodfuel Task Force (2008) Increasing the supply of wood for renewable energy production in Scotland, Edinburgh, Forestry Commission Scoland.

13 See Woodfuel Task Force in note 12.

14 Booth, E., Booth, J., Cook, P., Ferguson, B. and Walker, K. (2005) Economic evaluation of biodiesel production from oilseed rape grown in North and East Scotland, Edinburgh, Scottish Agricultural College.

15 Turley, D., McKay, H. and Boatman, N. (2004) Environmental impacts of cereal and oilseed rape cropping in the UK and assessment of the potential impacts arising from cultivation for liquid biofuel production, HGCA Project No. 3014 Final Report, London, Home Grown Cereals Authority.

16 National Farmers Union (2007) “Land required to meet RTFO 2010”, http://www.nfuonline.com/x33931.xml (October 2007).

17 English Nature & RSPB (2003) Assessing the impacts of bioenergy crops for transport biofuels on biodiversity and other natural resources, FWG-P-03-007, Briefing for the Low CVP transport fuels working group.

18 Renewable Fuels Agency (2009) RFA Quarterly Report 3, St Leonards-on-Sea, RFA.

19 Royal Society (2008) Sustainable biofuels: prospects and challenges, London, Royal Society.

20 Benemann, J. and Oswald, W. (1996) Systems and economic analysis of microalgae ponds for conversion of CO2 to biomass, US Department of Energy.

21 University of New Hampshire (2004) “Widescale biodiesel production from algae”, http://www.unh.edu/p2/biodiesel/article_alge.html (March 31 2009).

22 Kelly, M. and Dowrjanyn, S. (2008) The potential of marine biomass for anaerobic biogas digestion, Scottish Association of Marine Science & The Crown Estate.

23 See Galbraith, D. et al in note 7.

24 Carbon Trust (2005) Biomass sector review for the Carbon Trust, London, Carbon Trust.

25 Bates, J., Edberg, O. and Nuttall, C. (2009) Minimising greenhouse gas emissions from biomass energy generation, Bristol, Environment Agency.

26 Elsayed, M.A., Matthews, R. and Mortimer, N.D. (2003) Carbon and energy balances for a range of biofuels options, London, DTI.

27 Renewables Fuels Agency (2008) The Gallagher Review of the indirect effects of biofuels production, St Leonards-on-Sea, RFA.

28 Righelato, R. and Spracklen, D.V. (2007) ‘Carbon mitigation by biofuels or saving and restoring forests?’, Science, Vol 317 (Issue 5840), 902.


29 Danielsen, F., Beukema, H., Burgess, N.D., Parish, F., Brühl, C.A., Donald, P.F., Murdiyarso, D., Phalan, B., Reijnders, L., Struebig, M. and Fitzherbert, E.B. (2009) ‘Biofuel plantations on forested lands: double jeopardy for biodiversity and climate’, Conservation Biology, Vol 23 (Issue 2), 348-358.

30 Fargione, J., Hill, J., Tilman, D., Polasky, S. and Hawthorne, P. (2008) ‘Land clearing and the biofuel carbon debt’, Science, Vol 319, 1235-1238.

31 See Renewable Fuels Agency in note 27.

32 European Environment Agency (2008) Impacts of Europe’s changing climate - 2008 indicator-based assessment, EEA Report No 4/2008, Copenhagen, EEA.

33 Land Use Consultants (2007) Bioenergy: environmental impacts and best practice, Wildlife and Countryside Link.

34 Forestry Commission (2004) The UK Forestry Standard, Edinburgh, FC.

35 The UKWAS (2008), The UK Woodland Assurance Standard (amended edition), Edinburgh, UKWAS.

36 Nisbet, T. (2007) Guidance on site selection for brash removal, Farnham, Forest Research.

37 Gates, D., Beck, C., McPhie, F. and Hilton, G. and Hall, A. (2008) Local Environmental impacts of forest woodfuel harvesting in Scotland, Guidance Note, Munlochy, Highland Birchwoods.

38 See Gates, D. et al in note 37.

39 Nisbet, T., Dutch, J. and Moffat, A. (1997) Whole-Tree Harvesting: a guide to good practice, Edinburgh, Forestry Commission.



42 Forestry Commission (2009) Forest and biodiversity guidelines consultation, Edinburgh, FC.

43 Brainard, J., Lovett, A. and Bateman, I. (2003) Carbon sequestration benefits of woodland, Edinburgh, Forestry Commission.

44 Scottish Executive (2007) ECOSSE: Estimating carbon in organic soils – Sequestration and emissions: Final report, Edinburgh, Scottish Executive.

45 Hargreaves, K.J., Milne, R. and Cannell, M.G.R. (2003) ‘Carbon balance of afforested peatland in Scotland’, Forestry, Vol 76 (Issue 3), 299-317.


47 Luyssaert, S., Detlef Schulze, E., Börner, A., Knohl, A., Hessenmöller, D., Law, B.E., Ciais, P. and Grace, J. (2008) ‘Old-growth forests as global carbon sinks’, Nature, Vol 455, 213-215.

48 Joint Nature Conservation Committee (2003) Position statement on genetically modified organisms in the environment, Peterborough, JNCC. http://www.jncc.gov.uk/page-2992

49 Souch, C.A., Martin, P.J., Stephens, W. and Spoor, G. (2004) ‘Effects of soil compaction and mechanical damage at harvest on growth and biomass production of short rotation coppice willow’, Plant and Soil, Vol 263, 173–182.

50 Guo, L.B., Sims, R.E.H. and Horne, D.J. (2006) ‘Biomass production and nutrient cycling in Eucalyptus short rotation energy forests in New Zealand: II. Litter fall and nutrient return’, Biomass and Bioenergy, Vol 30 (Issue 5), 393-404.

51 Adegbidi, H.G., Volk, T.A., White, E.H., Abrahamson, Briggs, R.D. and Donald H. Bickelhaupt, D.H. (2001) ‘Biomass and nutrient removal by willow clones in experimental bioenergy plantations in New York State’, Biomass and Bioenergy, Vol 20 (Issue 6), 399-411.

52 Hall, R.L. (2003) Short rotation coppice for energy production: hydrological guidelines, CEH Report B/CR/00783/Guidelines/SRC, London, Dti.

53 Kuzovkina, Y.A., Quigley, M.F. (2005) ‘Willows beyond wetlands: Uses of Salix L. species for environmental projects’, Water Air and Soil Pollution, Vol 162 (Issue 1-4), 183-204.


54 Dimitriou, I., Eriksson, J., Adler, A., Aronsson, P. and Verwijst, I. (2006) ‘Fate of heavy metals after application of sewage sludge and wood-ash mixtures to short-rotation willow coppice’, Environmental Pollution, Vol 142 (Issue 1), 160-169.

55 Home Grown Cereals Authority (2005) Oilseed rape – a grower’s guide, London, HGCA.

56 Scottish Executive (2003) “NVZ Maps”, http;//www.scotland.gov.uk/Topics/Agriculture/Environment/NVZintro/NVZmap1(October 2007).

57 Scottish Government (2008) Guidelines for farmers in Nitrate Vulnerable Zones, Edinburgh, Scottish Government.

58 See Turley, D., McKay, H. and Boatman, N. in note 15.

59 Benton, T.G., Vickery, J.A. and Wilson, J.D (2003) ‘Farmland biodiversity: is habitat heterogeneity the key?’, Trends in Ecology and Evolution, Vol 18 (Issue 4), 182-188.

60 Cunningham, M., Bishop, J.D., McKay, H.V. and Sage, R.B. (2004) The ecology of short rotation coppice – ARBRE monitoring crops, NES: B/U1/00727/00/REP, London, DTI.

61 DTI (2006) The effects on flora and fauna of converting grassland to short rotation coppice, London, DTI.

62 Sage, R., Cunningham, M. and Boatman, N. (2006) ‘Birds in willow short-rotationcoppice compared to other arable crops in central England and a review of bird census data from energy crops in the UK’, Ibis, Vol 148, 184-197.

63 Anderson. Q.A., Haskins, L.R. and Nelson, L.H. (2004) ‘The effects of bioenergy crops on farmland birds in the UK: a review of current knowledge and future predictions’ in Parris, K. and Poincet T. (eds) Biomass and Agriculture: sustainability, Markets and Policies, 199-218, Paris, OECD.

64 Volk, T.A., Verwijst, T., Tharakan, P.J., Abrahamson, L.P., and White, E.H. (2004) ‘Growing fuel: a sustainability assessment of willow biomass crops’, Front. Ecol. Environ., Vol 2 (Issue 8), 411-418.

65 Bellamy, P.E., Croxton, P.J., Heard, M.S., Hinsley, S.A., Hulmes, L., Hulmes, S. Nuttal, P., Pywell, R.F. and Rothery, P. (2009) ‘The impact of growing miscanthus for biomass on farmland bird populations’, Biomass & Bioenergy, Vol 33 (Issue 2), 191-199.

66 Semere, T. and Slater, F. (2004) The effects of energy grass plantations on biodiversity, Cardiff University Report B/CR/00782/00/00, London, Dti.

67 See Turley, D., McKay, H. and Boatman, N. in note 15.

68 Hawes, C., Haughton, A.J., Osborne, J.L., Roy, D.B., Clarke, S.J., Perry, J.N., Rothery, P., Bohan, D.A., Brooks, D.R., Champion, G.T., Dewar, A.M., Heard, M.S., Woiwod, I.P., Daniels, R.E., Young, M.W., Parish, A.M., Scott, R.J., Firbank, L.G. and Squire, G.R. (2003) ‘Responses of plants and invertebrate trophic groups to contrasting herbicide regimes in the Farm Scale Evaluations of genetically modified herbicide-tolerant crops’, Phil. Trans. R. Soc. Lon B, Vol 358, 1899-1913.

69 Hancock, M.H. and Wilson, J.D. (2003) ‘Winter habitat associations of seed eating passerines on Scottish farmland’, Bird study, Vol 50, 116-130.


71 Matthews, R.B. and Grogan, P. (2002) ‘A modelling analysis of the potential for soil carbon sequestration under short rotation coppice willow bioenergy plantations’, Soil Use and Management, Vol 18, 175-183.

72 Jones, K. (2007) Biofuels in Scotland: climate change, biodiversity and economics, MSc Environment and Sustainable Development, University of Glasgow.

73 Crutzen, P.J., Mosier, A.R., Smith, K.A. and Winiwarter, W. (2008) ‘N20 release from agro-biofuel production negates global warming reduction by replacing fossil fuels’, Atmospheric Chemistry and Physics, Vol 8, 389-395.

74 Bell, S. and McIntosh, E. (2001) Short rotation coppice in the landscape, Edinburgh, Forestry Commission.

75 British Standards (2008) (Draft) Specification for whole digestate, separated liquor and separated fibre derived from the anaerobic digestion of source-segregated biodegradable materials, London, BSI.


76 International Energy Agency (2004) Biofuel for transport: international perspective, Paris, IEA.

77 Pollock, C. (2008) ‘Options for greenhouse gas mitigation in UK farming’, The Nuffield Carbon Farming Conference Proceedings, Frank Arden Memorial Study.

78 IEA Bioenergy (2005) Benefits of bioenergy, Rotorua, IEA Bioenergy.

79 See Bates, J., Edberg, O. and Nuttall, C. in note 25.


81 Biomass Energy Centre (2008) “Emissions”, http;//www.biomassenergycentre.org.uk/portal/page?_pageid=77,103200&_dad=portal&_schema=PORTAL (February 2008).

82 Pitman, R.M. (2006) ‘Wood ash use in forestry – a review of the environmental impacts’, Forestry, Vol 79 (Issue 5), 563-588.

83 DEFRA (2007) The air quality strategy for England, Scotland, Wales and Northern Ireland, DEFRA/SE/DOENI/WAG, London, DEFRA.

84 Abbot, J., Stewart, R., Fleming, S., Stevenson, K. Green, J. and Coleman, P. (2008) Measurement and modelling of fine particulate emissions (PM10 & PM2.5) from wood-burning biomass boilers, AEA Energy & Environment Report CR/2007/38, Edinburgh, Scottish Government.


86 See International Energy Agency in note 76.

87 Ropkins, K. Quinn, R., Beebe, J., Li, H., Daham, B., Tate, J., Bell, M. and Andrews, G. (2007) ‘Real-world comparison of probe vehicle emissions and fuel consumption using diesel and 5% biodiesel (B5) blend’, Science of the Total Environment, Vol 76 (Issue 1-3), 267-284.




Bioenergyand the natural heritageImplementation guidance

Policy 2009/1

Issued June 2009

Last revised

1 This implementation guidance has been developed for SNH’s staff and aims to explain how staff should use the Bioenergy and the Natural Heritage Policy Statement.

Use of this policy

2 The Bioenergy and the Natural Heritage Policy Statement No 2009/1 outlines SNH’s supportive stance towards bioenergy, subject to due care for the natural heritage being taken in developing bioenergy capacity.

3 This Bioenergy and the Natural Heritage Policy Statement is one of several which relate to energy and renewable energy. Our Energy and the Natural Heritage Policy Statement (06/02) and Renewable Energy Policy Statement (01/02) (under revision) outline our wider approach to energy issues and renewable energy. We also have policy statements on particular renewable energy technologies:

Strategic Locational Guidance for Onshore Windfarms (02/02);

Marine Renewable Energy and the Natural Heritage: an Overview and Policy Statement (04/01)

All these are available on the SNH’s intranet and website.


4 SNH staff responding to consultations or undertaking any other policy development activity concerned with bioenergy at Scottish, UK and EU level must use the Bioenergy and the Natural Heritage Policy Statement as a reference in conjunction with, as appropriate, these other policy statements. Regard should also be paid to any JNCC policy statements relating to energy to which SNH subscribes

5 Area staff, and their advisers, should be guided by the Bioenergy and the Natural Heritage Policy Statement when:

• contributing to any regional initiative which is concerned with the promotion of bioenergy;

• formulating a response to a land use change proposal under the Environmental Impact Assessment (Agriculture) (Scotland) Regulations 2006 and Environmental Impact Assessment (Forestry) (Scotland) Regulations 1999 to accommodate bioenergy feedstocks production;

• assessing an application for consent under the Nature Conservation (Scotland) Act 2004 involving the extraction / production of bioenergy feedstocks1;

• assessing applications for grants for the production of bioenergy feedstocks under the Scotland Rural Development Programme;

• inputting to a developer's bioenergy installation proposal or formulating a planning response for a bioenergy installation;

• assessing applications for grants for bioenergy installations under the Scotland Rural Development Programme.

In particular, staff should be aware of SNH’s policy approach on the production of bioenergy feedstocks and the development of bioenergy infrastructure and energy uses of biomass, and staff should refer to the review of the impacts on the natural heritage in the Background and Context; a list summarising key points of good practice can also be found below.

Staff should be guided by relevant technical guidance published by SNH (also available on the SNH’s intranet and website) and the Forestry Commission, and responses should be consistent with Scottish Planning Policy 6: Renewable energy (SPP6) (or the section on renewable energy within the consolidated Scottish Planning Policy once published). The statement should be used in conjunction with the Renewable Energy Service Level Statement when assessing bioenergy installations proposals. SNH’s technical guidance on microrenewables is about to be made available, which will be of particular relevance to applications for grants under the Scotland Rural Development Programme.

6 Staff representing SNH at relevant Public Local Inquiries must be familiar with the full text of the Bioenergy and the Natural Heritage Policy Statement.

7 All communications with the media and Government as well as any campaign or event concerned with bioenergy must be guided by the principles outlined in the Bioenergy and the Natural Heritage Policy Statement. Policy & Advice staff dealing with bioenergy should brief External Relations Unit staff (Strategy & Communications) accordingly.

8 Staff should be aware of other SNH’s policies where there is an interface between bioenergy and other policy topics, and liaise with relevant staff, to ensure consistency in approach across the organisation.

1 If a proposed operation on a SSSI is statutorily regulated by a designated regulatory authority (most likely Scottish Ministers/ RPID for agricultural operations; Forestry Commission Scotland for woodland/ forestry operations) and provided the regulatory authority consulted had regard to SNH’s advice in determining the application, the applicant does not need SNH’ SSSI consent for the same operation.


Dissemination

9 The Bioenergy and the Natural Heritage Policy Statement will be made available on SNH’s website and the intranet.

10 Policy & Advice staff working on bioenergy should circulate the updated policy statement to relevant contacts in national organisations, including central government (e.g. the Scottish Government, Forestry Commission Scotland, SEPA), country agencies (NE, CCW, JNCC), trade associations (e.g. Scottish Renewables, NFUS), environmental NGOs (e.g. RSPB), as well as major developers.

11 Area staff should circulate the updated policy statement to local authorities, land managers as well as individual developers they have worked or are still working with.

Principles of good practice

12 The principles of good practice listed below provide a summary of key points of good practice for feedstocks production in Scotland which should be exercised to minimise adverse natural heritage impacts and maximise benefits. For further information, practitioners need to refer to more detailed published guidance and/or seek expert advice.

Forestry

• The UK Forestry Standard and associated guidelines should be complied with.

• Extraction of biomass materials from SSSI/ Natura woodlands, ancient/ historic woodlands and limited/ fragmented areas of native woodland, should be avoided, to minimise biodiversity loss.

• Changes in woodland structure should be carefully designed to maintain and enhance connectivity of woodland and open ground habitats.

• Areas of plantation forestry should be favoured for exploitation; for natural/ semi-natural woodlands, the level of extraction or coppicing should be such as to maintain the diversity and naturalness of the woodland.

• Thinning should be carried out in a way that maximises the potential for forest floor biodiversity.

• Clear-felling should be avoided where practical.

• Some residues and deadwood should be left on site as per guidelines.

• The use of unusually heavy equipment such as chippers off tracks on site, should be avoided, due to the increased risks of soil compaction.

• In remote forested areas, extraction should be avoided if the area has developed as an area of high biodiversity value by virtue of its neglect to date.

• Any forest replanting, should be carefully managed, ensuring that planting is not extended to areas of land with high natural heritage value including but not limited to land that is designated.

• Planting or harvesting on carbon-rich soils should be avoided, unless extraction is part of a habitat restoration programme.

• In building new upland tracks, SNH’s guidance “Constructed tracks in the Scottish uplands” should be followed.


Short rotation coppice

• The UK Forestry Standard and associated guidelines should be complied with.

• Planting multi-varieties coppice, should enhance visual amenity, improve pest resistance, and could minimise fertiliser requirements.

• Cyclical harvesting should help ensure continuous cover for birds and avoid a changing visual landscape.

• Landscape impacts of new planting should be considered; Landscape Character Assessments will help in understanding the characteristics of the landscape, and Forestry Commission guidelines are available on locating and designing short rotation coppice.

• Simplification of cropping systems should be avoided, as this results in a narrower range of habitat and food sources for farmland wildlife.

• Planting should not be carried out in areas where it may create wider semi-natural habitat network fragmentation.

• Opportunities for new planting to contribute to habitat networks should be explored.

• Marginal land of high nature conservation value should not be planted with short rotation coppice.

• Planting on carbon-rich soils should be avoided.

• Willow plantations should not be located in or adjacent to wetlands or wet meadows of conservation value.

Arable crops

• Management should comply with Good Agricultural and Environmental Condition (GAEC) requirements, agricultural standards and available good practice guidance.

• Spring-sown oilseed rape will be more beneficial for farmland biodiversity than autumn-sown.

• Using disease-tolerant varieties or blends of varieties will help reduce fungicide inputs.

• Efficient nitrogen fertiliser use is important to minimise emissions of nitrous oxide.

• Precision farming and spray application technologies2 that improve the targeting of inputs will help reduce water and air pollution.

• Tools that improve decision-making will help reduce unnecessary applications of fertiliser and pesticides, saving energy and helping to reduce air and water pollution.

• Sufficient residues should be retained on the soil to maintain soil stability and nutrients.

• Undertaking carbon footprinting or energy auditing and implementing energy efficiency measures should help reduce GHG emissions of all operations of the production cycle.

2 Information on technologies that help optimise the use of inputs can be found in SNH’s TIBRE Arable Handbook http://www.snh.org.uk/tibre

www.snh.org.uk

© Scottish Natural Heritage June 2009

Photography: Cover image by Neil McIntyreAll other images by Lorne Gill/SNH

ISBN: 978-1-85397-589-9Print Code: WOP1000609

Further copies available from:Publications DistributionScottish Natural HeritageBattlebyRedgortonPerth PH1 3EW

T: 01738 458530 F: 01738 458613 E: [email protected]

www.snh.org.uk

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