amarilis et al, 2011, a comparative study of the approaches taken to perennial biomess crop planting...

8/13/2019 Amarilis et al, 2011, A comparative study of the approaches taken to perennial biomess crop planting in So Paul

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Investigating the effectiveness of environmental assessment

of land use change: A comparative study of the approaches

taken to perennial biomass crop planting in Sao Paulo and

England

Amarilis Lucia Casteli Figueiredo Gallardo a,*, Alan Bond b

a Institute for Technological Research, Center of Environmental and Energetic Technologies, Av. Prof. Almeida Prado, 532, Cidade

Universitaria, Sao Pauloe

SP, CEP 05508-901, Brazilb InteREAM (Interdisciplinary Research in Environmental Assessment and Management), School of Environmental Sciences, University of East

Anglia, Norwich, NR4 7TJ, UK

a r t i c l e i n f o

Article history:

Received 23 August 2010

Received in revised form

25 February 2011

Accepted 26 February 2011

Available online 22 March 2011

Keywords:

Environmental assessment

Brazil

England

Perennial bioenergy crops

Sugarcane (Saccharumspp.)

Miscanthus (Miscanthus spp.) grass

a b s t r a c t

There is a move towards large-scale planting of perennial bioenergy crops in many

countries to help reduce Green House Gas emissions, whilst still meeting energy demand.

However, the implications of such wholesale land use change have yet to be fully under-

stood which raises some concerns over the strategy. This paper identifies, through litera-

ture review, that significant social, economic and environmental impacts might be

expected from land use change in two different parts of the world, Sao Paulo, Brazil, where

sugarcane is the predominant perennial biomass crop, and England wheremiscanthusandshort rotation coppice are likely to predominate. In order to examine the extent to which

these impacts can be addressed in decision-making, the paper develops a framework for

testing the effectiveness of environmental assessment practice in these two regions, and

applies it to both. The conclusion is that, whilst tools which can address sustainability

impacts in decision-making exist, the legal framework in England precludes their appli-

cation for the majority of land use change, and in Brazil there is incomplete consideration

of social and economic impacts at the strategic level.

2011 Elsevier Ltd. All rights reserved.

1. Introduction

In recent years, in order to tackle climate change and to

promote energy security, renewable energy (biomass, wind,

solar, small-scale hydropower, tidalpower, geothermal energy

and waste) has been advocated as a means of enhancing

diversity in energy supply markets whilst achieving sustain-

able development. Biomass can be defined as any biological

material, derived from plant or animal matter,which can be used

for producing heat and/or power, fuels including transport

fuels, or as a substitute for fossil fuel-based materials and

products ([1], p.11).Biofuelscan be defined as liquid transport

fuels derived frombiomass, whereasbioenergyis the heat and

power derived from biomass (including from derived biofuels)

[2].

Given that motivation of Governments to reduce Green

House Gas (GHG) emissions is driven by international agree-

ments like the Kyoto Protocol, and the fact that bioenergy

crops are regarded as having significant GHG reduction

potential across the complete life cycle [3], the use of

* Corresponding author. Tel.: 55 11 37674611; fax: 55 11 37674938.E-mail addresses:[email protected](A.L. Casteli Figueiredo Gallardo),[email protected](A. Bond).

A v a i l a b l e a t w w w . s c i e n c e d i r e c t . c o m

h t t p : / / w w w . e l s e v i e r . c o m / l o c a t e / b i o m b i o e

b i o m a s s a n d b i o e n e r g y 3 5 ( 2 0 1 1 ) 2 2 8 5e2 2 9 7

0961-9534/$ e see front matter 2011 Elsevier Ltd. All rights reserved.

doi:10.1016/j.biombioe.2011.02.050
mailto:[email protected]:[email protected]://www.sciencedirect.com/http://www.elsevier.com/locate/biombioehttp://dx.doi.org/10.1016/j.biombioe.2011.02.050http://dx.doi.org/10.1016/j.biombioe.2011.02.050http://dx.doi.org/10.1016/j.biombioe.2011.02.050http://dx.doi.org/10.1016/j.biombioe.2011.02.050http://dx.doi.org/10.1016/j.biombioe.2011.02.050http://dx.doi.org/10.1016/j.biombioe.2011.02.050http://www.elsevier.com/locate/biombioehttp://www.sciencedirect.com/mailto:[email protected]:[email protected]


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bioenergy from biomass crops is expected to play an impor-

tant role as an energy source in partially replacing the energy

obtained from fossil resources. In 2004, an estimated

140,000 km2, worldwide, were being used to produce biofuels

and their by-products, representing approximately 1% of

global cropland [4]. Currently, the evidence suggests that

a change from annual crops to perennial (bioenergy) crops is

likely to have more positive environmental implications,particularly in relation to GHG emissions and energy balance

[5,6]. However, there have been growing concerns that the full

implications of large-scale land conversion to bioenergy crops

have not yet been entirely considered and there are particular

fears over the indirect consequences in relation to food

security, biodiversity impacts, water security and climate

change[7e11].

Most countries have adopted some form of environmental

assessment legislation applying either at the project level

(Environmental Impact Assessment e EIA) or at the strategic

level for policies, plans and programmes (Strategic Environ-

mental Assessment e SEA) in order to determine the impli-

cations of actions in advance[12]. The extent to which suchassessment processes apply to bioenergy crops, or work as

intended where they do apply is, thus, an important research

question. In particular, there is a need to know the extent to

which current decision-making practice can identify impacts

of land use change (towards increased planting of perennial

bioenergy crops) and influence the planting to minimise

negative impacts and accentuate positive impacts.

In Europe, bioenergy crops are currently replacing annual

crops [6] although European regulations prevent Member

States from reducing the area of permanent pasture [13].

Despite this, the future situation in Europe is less clear: pro-

jected long-term, contrasting scenarios accommodating both

different socio-economic conditions climate scenarios indi-cate that a number of different outcomes are possible as soon

as 2035[14]. In Brazil, however, increased planting of sugar-

cane (Saccharumspp.) is argued to be replacing pasture land

(i.e. grass which is perennial) [15]. Thus, a comparative study

of Sao Paulo and England is undertaken in order to determine

how the statutory authorities currently appraise the potential

impacts from land use change related to bioenergy crops and

the extent to which their appraisals properly inform decision

makers of the consequences.

Both regions are expected to increase the area of land

under bioenergy crops, however, the majority of the expan-

sion in the State of Sao Paulo will be through an increase in

planting of sugarcane (it currently accounts for 83% of theStates renewable energy contribution [16]), and so this biofuel

crop will provide the focus for this region. In England, signif-

icant expansion is expected both for biofuels (from wheat and

oilseedrape) and biomass crops for Combined Heat and Power

(CHP) (Short Rotation Coppice Willow e Salixspp.e SRC and

miscanthus grass e Miscanthus spp.). Whilst the land area

covered by the former is anticipated to be twice that of the

latter [1], our focus will be on increased planting of the

biomass crops SRC and miscanthus because this represents

a significant change in land use from annual crops to peren-

nial crops. England and Sao Paulo have similar populations,

42,736,000 (2007) and 41,779,000 (2008), respectively, although

the latter is 80% larger in land area, 130,439 km2 and

248,209 km2, respectively. Otherwise there are many differ-

ences, such as each countrys geography, distinct kinds of

feedstock, policies, economic context and level of use of bio-

energy in their grid.

In order to answer the research question, the research is

broken down into specific objectives:

To identify the significant impacts (positive and negative)from land use change associated with perennial biomass

crops in both regions to demonstrate a need for some form

of pre-decision assessment;

To determine a method for measuring the effectiveness of

any assessment conducted; and

To apply this method to the current systems of assessment

in the two regions.

The next section will briefly describe crop production and

outline the main drivers for its expansion and associated

expectations for future perennial biomass crop planting in the

two regions. This is followed by an explanation of the meth-

odological approach used in order to, firstly, identify thetypical impacts associated with expected land use change in

each region and, secondly, the procedure used to evaluate the

effectiveness of the assessment systems. The results will then

highlight the most important impacts of biomass production

in (the state of) Sao Paulo and England to demonstrate the

importance of effective evaluation. This will be followed by

the environmental assessment system evaluation itself.

Finally, the learning the systems in Sao Paulo and England can

take from each other, and from the evaluation of effective-

ness, will be presented.

1.1. Brief description of the ethanol sector in Sao Paulo

and the biomass sector in England

Sao Paulo is the Brazilian leader in renewable energy

producing almost 51% of its internal needs for energy (30%

sugarcane; 17% hydraulic power, 2% charcoal and firewood

and 2% other renewable sources[16]).

For England, statistics are available only at the national

(UK) level where renewables and waste accounted for almost

2% of the total production of primary fuels[17]. With regard to

renewable sources, in 2008, biomass represented 81% of the

amount of renewables (26.7% landfill gas, 4.1% sewage gas,

6.1% domestic wood, 1.8% industrial wood, 9.1% waste

combustion, 9.0% co-firing, 5.0% animal biomass, 5.3% plant

biomass and 14.0% liquid biofuels). Of the 247 PJ of primaryenergy use accounted for by renewables, energy crops

answered for only 0.3% by weight of the feedstock burned to

produce electricity and/or heat[1].

1.2. The ethanol market in Sao Paulo and the biomass

market in England

The use of ethanol on a large-scale was launched in 1975 with

a Brazilian Federal Government Programme, termed Proal-

cool, in order to encourage the redirection of some sugarcane

production to generate fuel thus decreasing petrol imports. In

Brazil in 2003, the flex-fuel vehicle was introduced which

operates with any percentage of ethanol-gasoline blend and

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even with pure (hydrated) ethanol[18]. In 2008 in Brazil, for

the first time in twenty years, the ethanol volume used as fuel

in light vehicles exceeded the gasoline volume [7]; the pre-

dicted increased use of flex-fuel cars would suggest that

demand for ethanol will double in the 10 years from 2008 to

2018[16].

In Sao Paulo ethanol is provided exclusively by sugarcane

crops. In the harvest of 2008/2009 27.5 hm3 of sugarcaneethanol was produced in Brazilof which Sao Paulocontributed

16.7 hm3 [19]. In 2006 the sugarcane crop in Sao Paulo repre-

sented almost 60% of the total cultivated area of the state[20].

Brazil uses 85% of its production domestically, while 15% is

exported to the US, Caribbean Basin Initiative (CBI), EU and

others. Brazilian ethanol production is likely to double from

2006 levels (17.8 hm3) by 2012/2013 to 36 hm3 per year,

replacing approximately 50% of the gasoline that otherwise

would be used in the country. In order to meet this demand

49,000 km2 (in 2006 62,000 km2 was cropped to produce sugar

of which only 29,000 km2 was used to produce ethanol) of

sugarcane crops will be needed.

In the European Union, the Renewable Energy Directive [21]and Fuel Quality Directive[22]have placed strict obligations

on all member states to achieve targets which are likely to

have implications beyond their borders. The Fuel Quality

Directive requires that GHG emissions from transport are

reduced by at least 6% in all member states by 2020, whilst the

Renewable Energy Directive requires that each member state

shall ensure that the share of energy from renewable sources in

all forms of transport in 2020 is at least 10% of the final consumption

of energy in transport in that Member State ([21], Article 3,

paragraph 4). In March 2007, the European Council agreed to,

amongst other things, a binding target of a 20% share of

renewable energies in overall EU consumption by 2020. This

target applies to transport and heating as well as the genera-tion of electricity[23]and biomass will have a central role to

play in meeting this requirement[1].

The UK Governments strategy for biomass[1] is intended

to realise a major expansion in the supply and use of biomass

in the UK. The additional area of perennial energy crops

required in the UK in order to meet the strategy is almost

3500 km2 by 2020, rising from just 150 km2 grown in 2008[2].

With regard to bioenergy crop expansion in England, as

a feedstock, short rotation coppice (SRC) and miscanthus are

expected to play an important role due to the financial

incentives available through the Energy Crops Scheme [24]

that provides support for these crops at a rate of 50% of

actual (verifiable) costs.

2. Methods

To recognize the environmental, social and economic impacts

related to ethanol production in Sao Paulo and the forecasts

for biomass from non-food crops in England, the approach

taken drew on a methodological approach which emphasised,

in the context of measuring the achievement of sustainable

development, the importance of appropriately balancing the

social, economic and environmental criteria [25]. A large

number of potential impacts related to land use change

associated with energy crops have been identified and

reduced to a manageable list of impact areas of concern based

on their frequency of occurrence in the literature. The eleven

key issues of concern were: water resources; water and soil

pollution; residues; soil erosion; land use change, deforesta-

tion and biodiversity; air emissions; energy balance and GHG;

waste management; food security; labour conditions and

workers rights; social responsibility and benefits; jobs, wages,

income distribution and land ownership[26].In order to evaluate effectiveness of the environmental

assessment systems in place, we must first define what we

mean by effective. With reference to the literature, effec-

tiveness can be categorised into 4 types: procedural,

substantive, transactive, and normative effectiveness [27].

Procedural effectiveness expresses that the assessment

complies with acceptable standards and principles, substan-

tive effectiveness indicates the achievement of expected

objectives, and transactive effectiveness denotes that the

outcomes have been obtained with the least cost in the

minimum timeframe [28]. In addition, normative effective-

ness has been defined as the extent to which the process

achieves its normative goals, that is, sustainable development[29]. We assume in this research that all these categories have

some influence in determining overall effectiveness.

In order to compare the assessment systems in Sao Paulo

and England a setof criteria have been developed based on the

literature. Such an approach has been successfully applied in

comparative reviews of assessment systems[30,31], although

criteria are typicallyrelated specifically to proceduralstages of

the assessment processes under review whereas we have

added criteria for substantive, transactive and normative

effectiveness.Table 1sets out the criteria identified from the

literature to be used in this study.

3. Results and discussion

3.1. Typical impacts associated with land use change to

accommodate bioenergy crops

Results are presented in a tabular format for both Sao Pau-

lo and England, drawing on the literature to highlight the

potential impacts which might be caused by land use

change to bioenergy crops. The specific nature of impacts

will depend on both the local geographical context and the

existing land use prior to change, soTable 2, which identifies

the main issues related to sugarcane expansion in Sao Paulo,

and Table 3 to bioenergy crop planting in England, areintended to do no more that accredit the possibility for

adverse impacts. It should be recognized that the purpose of

the tables is not to cross-reference, to compare or to qualify

these impacts.

With regard to English bioenergy crops, the ecological

implications are complex, because the impacts vary between

scales, in that the conversion of large areas of land to mono-

cultures of bioenergy crops may have locally damaging

consequences, but could contribute to the global reduction of

GHG production. There are substantial uncertainties over

these potential impacts and strong dependencies on the

management of the bioenergy projects across their whole

life cycle[56]. In general, for environmental impacts, less is

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known about the consequences of large-scale deployment of

miscanthus, compared to SRC willow, including effects on

biodiversity and hydrology and this requires further research

[6].Table 3sets out the current state of knowledge over the

implications of planting these crops.

3.2. Current appraisal system in Sao Paulo and England

3.2.1. Sao Paulo

The current appraisal system in Brazil is supported by the

Environmental Impact Assessment (EIA) tool. The institu-

tional framework for EIA in Brazil is highly centralized and

shows considerable variations in implementation amongdifferent states, with some examples of good practice, espe-

cially in the southern and southeastern states[57], where Sao

Paulo is situated.

EIA was introduced in Brazil in 1981 with Federal Law 6.938

which required the production of an Environmental Impact

Statement (EIS) for certain projects. Subsequent decrees have

set out the specific details of how the EIA process must

operate. In Sao Paulo, Resolution SMA (the Sao Paulo Secre-

tariat for the Environment) 42/94, seeking to improve

screening in the EIA process, created a lower level of assess-

ment through the submission of a Preliminary Environmental

Report (PER), for undertakings whose potential impacts are

deemed to be less significant. Resolution SMA 54/04 retainsthe PER and provides a new kind of environmental study, the

Simplified Environmental Study (for enterprises deemed not

to create significant impacts).

Authors cite a number of problems in relation to the

practice of EIA in Brazil prior to the year 2000 (for example

[57,58]). Since 2000, a great deal of improvement and experi-

ence has been gained in Brazil[59]mainly in Sao Paulo, that

has highly trained and skilled technical staff and experience

of practical EIA follow up[60,61]. Research also highlights that

the projectEIA processis quite robust in the State, based on 20

years of continuous experience, although the absence of

Strategic Environmental Assessment is considered to be

a significant weakness[62].

Every new sugarcane enterprise or the expansion of

existing undertakings to produce ethanol that involves

sugarcane crops has to submit an environmental study (EIS or

PER), and must comply with the existing legal and Govern-

mental requirements and laws for this sector (both the agri-

cultural and the industrial sector from the sugarcane

industry) to obtain approval. Resolution SMA 42/06 stipulates

that: i) new sugarcane plants with a crushing capacity of less

than 50 kt a1 or expanding production with a crushing

capacity of less than 200 kt a1 do not need an environmental

study presentation; ii) new industries with a crushing capacity

of more than 50 kt a1; expanding production with a crushing

capacity of more than 200 kt a1; total or partial replacementof sugarcane production for ethanol production; and

expanding of sugarcane cropping which affects fragile envi-

ronmental areas need a PER; iii) new industries with a crush-

ing capacity of equal to or more than 1.5 Mt a1 in accordance

with Agri-environmental Zoning need an EIS.

Agri-environmental Zoning was introduced by Resolution

SMA/SAA 4/08 (Sao Paulo Secretariat for the Environmental and

Sao Paulo Secretariat for the Agriculture) (and subsequently

amended) and is an initiative to tackle the shortcomings of the

EIA approach which is primarily reactive in assessing the

implications of sugarcane planting proposals developed in

locations specifiedby the proponent and in isolation from other

proposals. It introduces zoning guidelines specificallyapplied tonew ethanol projects, as shown inFig. 1. It is a zoning proposal

for sugarcane cropsbased on thefollowing factors that relateto

the whole of Sao Paulo: soil and climate conditions; slope and

aptitude for mechanical harvesting; current air quality as

compared to quality standards; aquifer vulnerability; surface

water availability; existing protected areas or restricted use

areas and buffer zones; areas considered as a priority for

biodiversity protection. Table 4 presentsthe mainrequirements

for the approval of new projects.

3.2.2. England

The current appraisal system in the majority of development

initiatives in England is focused on the spatial (land use)

Table 1e Criteria for evaluating current appraisal systems for biomass crops.

Criteria (effectiveness category) Description Source

1. Legal basis (procedural) Clear legal mandate for conducting environmental assessment at strategic

and project levels

[28, 30, 31]

2. Guidance (procedural) Does guidance exist which sets out how to conduct appraisal of biomass

crop planting?

[28, 30]

3. Level of assessment(procedural) Is the level/scale of assessment appropriate for the biomass crop planting? [28, 32]

4. Sustainable Development

(normative)

Is the concept of sustainable development integral to the assessment

process(es)?

[30, 32, 33]

5. Socio-ecological system integrity

(normative)

Does the assessment consider the integrity of the socio-biophysical system? [34]

6. Consultation and public

participation (substantive)

Does consultation and public participation take place within the assessment

system leading to action?

[28, 30-33]

7. Intergenerational equity

(normative)

Does the assessment consider future generations and act in their interests? [34]

8. Decision-making (substantive) Does the assessment have any discernible effect on the decisions taken? [28, 30, 31]

9. Timeliness (transactive) Information is available in a timely manner (so assessment isex ante and

notpost hoc)

[27, 28, 32, 33]

10. Credibility (substantive) Robustness and consistency of assessments (reducing bias) [33]



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planning system for which the principal act is the Town and

Country Planning Act 1990 as amended.

This Act controls development through the preparation

of spatial plans. There is a very well developed environmental

assessment system associated with planning, which requires

both SEA and EIA under legislation implemented to meet the

obligations of European Union Directives[63,64]. In addition,

the Planning and Compulsory Purchase Act 2004 [65], which

amended the Town and CountryPlanning Act 1990 introduced

a specific requirement in England for spatial plans to be sub-

jected to Sustainability Appraisal (SA); this has a broader

scope than SEA and, therefore, the Government published

guidance on how SA might be conducted to meet the

requirements of the SEA Directive[66].

Despite the existence of a well developed environmental

assessment system, agricultural planting is largely excluded.

Such activity is not incorporated within the definition of

development and, notwithstanding the inclusion of the

Table 2e Main issues identified in the literature related to sugarcane expansion to produce sugarcaneethanol in Sao Paulo[26].

Issue Description

Environmental Water resources The process to convert cane into ethanol requires large amounts of water both in the agricultural and

industrial processes; however the water re-use level has been increasing and other techniques to

reduce the consumption of water and rates have been strongly decreasing in recent year [35e37].

Water and soilpollution During the process of cropping sugarcane and producing ethanol there are pollutants that can causewater and soil pollution. For example, organic pollutants, of which the major wastewater flow is

vinasse, and inorganic substances that can cause damage to soil and water similar to pesticides and

fertilizers.

Residues Many types of residues are produced by the sugarcane industry, such as bagasse and straw which are

generated in enormous quantities, and filter cake. Part of these residues is used for example for co-

generation.

Soil erosion Soil erosion in sugarcane crops is generally limited compared to conventional agricultural harvests,

however soil losses for sugarcane may vary dramatically from 10 t km2 a1 to 10.9 kt km2 a1,

depending on many factors such as the angle of slope, the annual rainfall, the management and

harvesting system[11].

Land use change,

deforestation and

biodiversity

The occurrence of direct impacts on biodiversity is limited. In recent years the expansion of the

sugarcane sector has mainly replaced pastures and/or food crops and sugarcane production operates

farfromthe majorbiomes in Brazil.This expansionis argued notto lead to replacement of nativeforest

by this crop, except in very specific situations; however some conflicts are identified where crops are

grown in biodiversity conservation hotspots[15].Air emissions The impacts associated with air emissions caused by sugarcane burning will be enormously reduced

due to legislation, established in 2003, that forbids this practice for areas that use mechanical

harvesting from 2021, and for areas that use non-mechanical harvesting from 2031. There are impacts

associatedwith the co-generation ofheat and electricity.The levelsof NOxand particulate material are

near to the limits allowed and in some situations exceed them [38].

Energy balance and

GHG

Despite some doubts about addressing indirect land-use change in the analysis of energy balance and

GHG (Renewable Fuels Agency, 2008), the ethanol from sugarcane is recognized as one of the best

options to reduce emissions of GHG compared to petrol fuel [39]. The energy balance is highly positive

if compared to the petrol industry[40, 41].

Waste Management Only part of vinasse and wastewater is used in fertirrigation. For economic reasons waste disposal

takes place within 15e30 km of the ethanol plant. This practice causes risks to groundwater recharge

areas by nitrate contamination. Non-sealed tanks are potential hotspots of pollution. Washed

packages usually are disposed of in landfills. However it is difficult to control inappropriate practices

that can cause environmental liabilities[42].

Social Food security This is a very controversial issue related to Brazilian sugarcane crops. Some researchers believe thatsugarcane crops directly influence and impose restrictions upon the production of food crops, in both

Sao Paulo and surrounding Brazilian states[41]. However, during the period 2002-2006, sugarcane

expansion is argued to have occurred in Sao Paulo mainly on land previously used for cattle ranching,

thus not pressuring food crops[37].

Labour conditions

and workers rights

The main problem with respect to labour conditions is related to manual cane harvesting[11].

Mechanical harvesting is presently used as a standard for productivity. Owing to the targets for cane

cutting, only a small number of women work in sugarcane cutting and there are problems for migrant

and temporary workers. Some workers rights violations have been reported[37]. In contrast to this, in

2003 the rate of regular jobs in sugarcane production (agriculture) represented 88% of all agricultural

jobs in Sao Paulo[11].

Social Responsibility

and Benefits

The ethanol production sector maintains more than 600 schools, 200 nursery centres and 300 day care

units and other kinds of benefits butthere is a scarcity of information about the absolute life conditions

of the workers in the sugarcane and ethanol industry [11].

Economic Jobs, wages, income

distribution and landownership

For every 300 Mt of sugarcane produced, approximately 700,000 jobs are estimated to be created [37].

The workers receive, on average, wages that are 80% higher than those of workers holding otheragricultural jobs[40]. About 25% of sugarcane is produced by independent, relatively small farmers

who sell their production to the mills. The remaining part is produced on lands either owned or rented

by the mills owners[11, 40].



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Table 3e Main issues identified in the literature related to perennial crops in England.

Issue Description

Environmental Water resources It is generally expected thatmiscanthusand SRC will have higher water demands than arable crops

due to a combination of higher growth rates, elevated transpiration rates, longer seasonal growth

and increased rooting depth and complexity[6]. For the same rainfall and soils, the water use of the

energy grasses is likely tobe less or comparable to that of the existing land cover where it is grass or

tilledland andless if the existing land cover is woodland or heathland;and the results forSRC showa very high water use[43].

Water and soil

pollution

The extended growing season, high evapotranspiration rates and extensive root systems of SRC

andmiscanthusplantations has lead to much interest in the effect these plantations may have on

nitrogen cycling, leaching and related changes in water quality [6]. Research has shown that both

miscanthus and SRC require fewer inputs of fertilizer and pesticides than conventional crops [e.g.

44]. It has been shown that nitrate leaching from land under miscanthuswas closer in value to rates

recorded under extensively managed grassland rather than arable land [44].

Residues The economic implications of ash disposal for electricity generation from biomass has been

calculated, with the amount of ash being dependent on feedstock[45]. The assumption is made the

ash needs to be landfilled, although this presupposes contamination which would be the case

where biomass was co-fired. However, where wood ash is created, a portion can be used as forestry

fertiliser, though the extent to which this is possible depends on combustion technology and

settings[46].

Soil erosion Miscanthusand SRC have a potential for improved physical soil properties due to the role these

compounds play in soil aggregate formation and stability and lead to reduced run-off and thusdecrease the erosion process[6].

Land use change,

deforestation

and biodiversity

While SRC can increase avian diversity compared to arable crops, it represents a poorer habitat

than many natural and semi-natural habitats such as ancient woodland, wet meadows and

unimproved grassland.Miscanthusplantations may not support as many species as SRC

plantations. Although both plantations could be generally regarded as beneficial for biodiversity in

an agricultural setting, they are not a substitute for natural and semi-natural habitats[6]. Using one

butterfly biodiversity indicator, researchers have produced a study that suggests that dedicated

biomass crops placed in arable farmland could be used to provide habitat for intrinsically

interesting butterflies, whilst not providing a source of economically harmful pest species[47].

Air emissions Most emissions from biomass have been found to be associated with combustion end use[48]. A

comparison of CO2, CH4, N2O emissions for a range of biofuels with that of conventional sources of

energy found that total GHG requirements (in kg equivalent of CO 2/MJ) were less for biofuels and

biomass, but that the major savings related to CO2as, depending on the technology, N20 and CH4emissions associated with bioenergy crops could be higher than conventional sources[49]. A key

variable is life cycle emissions related to the quantity of nitrogen fertiliser needed as its productiondemands considerable energy use[50].

Energy balance

and GHG

There is a generalconsensus thatthe conversion of arableland to SRCor miscanthuswill resultin an

increase in carbon sequestration, while the conversion of grassland may not be as beneficial. In

addition the extensive roots systems characteristic of SRC and miscanthusresult in large below

ground biomass storage, further improving the carbon mitigation potential of these plantations in

addition to improving soil texture[6]. There have been a limited number of models constructed in

relation tomiscanthus, one of them concluded that inputs of pesticides, fertiliser and harvesting

have the strongest negative impact on GHG emission and energy balance for this crop, while the

energy ratio is most sensitive to changes in yield. The same study also suggested that energy

grasses have a higher energy ratio and lower GHG emission than SRC, although other models refute

this point[6].

Waste

Management

For perennial biomass crops, the entire crop is harvested and so residual wastes are not

a significant issue. However, it has been suggested that these (non-food) crops can be used to

dispose of waste, including sewage sludge. For SRC, evidence suggests NePeK rich effluent can be

spread on the crop without threatening groundwater quality[51]. Advice to farmers recommendsspreading of sewage sludge on SRC[52]and miscanthus[53].

Social Food security First of all, they are non-food crops. According to some projected scenarios[8], if strategic land use

and economic planning are taken into account, the non-crop food expansion in arable land would

not necessarily greatly impact on UK food security. However, this conclusion is based on expansion

to meet UK Biomass Strategy targets only.

Labour

conditions and

workers rights

No information is available on labour conditions and workers rights.

Social

Responsibility

and Benefits

The current small-scale of planting hasnot ledto any academic interest over thepotentialfor social

responsibility and benefits. However, social benefits can accrue where biomass crops are used as

a means of remediating contaminated land[54], although contaminants would be present in the

ash after combustion.



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agricultural sector within the scope of the SEA and EIA Direc-

tives, no SEAs are conducted because there is no formal plan-

system for agriculture. At the project level, specific regulations

to implement EIA apply only to uncultivated land or semi-

naturalareas (which tend to be largely grassland and,therefore,

perennial)[67]. As such, they are unlikely to apply to bioenergy

cropplanting as thesetend to replace existingarablecrops. This

means that expansion of bioenergy crops even on a large-scale

basis is currently undertaken without appraisal in the UK [47].

The only exception would be where planting might affect a sitedesignated as a Special Protection Area under the EU Birds

Directive[68], or a Special Area of Conservation under the EU

Habitats Directive [69] (collectively these sites are known as

Natura 2000 sites). Planting would not be allowed to proceed if

these sites were adversely affected unless it could be demon-

strated (through an Appropriate Assessment) that there were

Imperative Reasons of Overriding Public Interest (IROPI). One

potential exception where EIA might have some influence is

where the end use, for example a new biomass electricity

generating plant, is itself subject to EIA through the need for

planning permission. One particular proposal for an advanced

gasifierusingmiscanthus feedstockhasbeensubjectedtotheEIA

process. Some of the relevant concerns, mainly environmental,were identified using survey questionnaires distributed to local

people and are reported elsewhere[70e73].

There is some experience of trying to appraise the impli-

cations of significantly increasing the planting of bioenergy

crops through a Research Councils UK funded project, termed

Relu-Biomass, that performed a holistic assessment of the

potential impacts of increasing rural land use ofmiscanthus

and SRC, focusing on two study regions e the South-West and

the East Midlands both in England. This project has brought

together experts from the fields of crop science, biodiversity

and ecology, hydrology, social science and geography and

rural economics, and has provided an integrated, interdisci-plinary scientific evaluation of the implications of land

conversion to energy crops.

There are some available results based on the Relu-

Biomass project. Researchers used an empirical model with

GIS to produce a yield map of the UK potential and

a constraints map identifying the land areas where biomass

crops should be planted to minimise impacts whilst still

obtaining viable yields [8]. A biomass-planting-specific

Sustainability Appraisal Framework was then introduced to

recognize the implications for social, economic and environ-

mental indicators of planting in the unconstrained areas[74].

This approach was taken as dialogue with stakeholders had

expressed a concern that SA might lead to trade off decisionswhich allowed bioenergy crops to be planted on sensitive

habitats. Thus, the constraints mapping excludes these

Table 3 (continued).

Issue Description

Economic Jobs, wages,

income

distribution and

land ownership

Miscanthusrequires 25% more direct agricultural jobs than does SRC[55], however, SRC employs

a tenth the number of agricultural workers as the equivalent area of arable crops. They further

calculate that 1.27 man years/GWh of electricity are created in power plants associated with either

crop when producing electricity only. Currently only 150 km2 of land is growing biomass crops[47],

with individual farmers choosing to enter into contracts with end users or through dedicatedbiomass crop companies.

Fig. 1e

Agri-environmental Zoning: (modified from[20]).



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habitats and the SA provides evidence on where best to plant

in the remaining land area.

The remaining issue is how such an SA, which has no

statutory basis in England, can influence decision-making.

Ultimately, farmers make their own decisions on which crops

to plant and where they will plant them. The only significant

influence that can be brought to bear is through financial

incentives. For example, Natural England (which is a non-department public body of the UK Government) manage an

Energy Crops Scheme whereby farmers can claim back

some of the costs of planting energy crops. Thus, there is the

potential for Natural England to be influenced in terms of

which areas of land they will agree to finance under this

scheme.

3.2.3. Evaluation of the effectiveness of the assessment

systems

Table 5 sets out the evaluation of the effectiveness of

the assessment systems in Sao Paulo and England based

on the criteria developed for this purpose presented in

Table 1.

It is clear from the analysis that neither system can be

considered to be effective against all of the criteria. A partic-

ular failing is the lack of strategic assessment in either region.

The limitations of projectlevel EIA, where it does take place, in

terms of managing cumulative impacts and considering

alternatives is well documented (see, for example[76e78]). In

addition, the real influence of EIA in decision-making can be

very limited because it occurs in the latter stages of develop-ment proposals where important decisions related to a land

use plan are already agreed.

In England, the main shortcoming is related to the lack of

legal requirement for any form of assessment, apart from

limited cases where a Natura 2000 site may be affected or

where the proposal is to plant energy crops on previously

uncultivated land (which is considered to be unlikely). The

critical issue appears to be the lack of any legal framework

for decision-making in the agricultural sector because

planting of specific crops is not considered to be development

as defined by planning legislation. Whilst the potential need

for an appropriate assessment does help to protect the

Natura 2000 network against inadvertent damage by farmers,it does not cover any other land use change, for example

from pasture land to arable, or arable to energy crops, irre-

spective of the scale of the change. The decision to change

a crop is entirely down to the individual land owners and

farmers. In this context, it might be argued that the

Environmental Assessment Directive has failed to envisage

the potential significance of impacts associated with land

use change on a scale not envisaged when the Directive

was adopted in 1985, or subsequently amended. The

1985 Directive failed to require EIA for golf courses, for

example, an omission which was rectified in subsequent

amendments[79].

The Sao Paulo assessment system at the project level isfocused on environmental impacts and their mitigation.

However, with regard to the full consideration of environ-

mental impacts (Table 2), the environmental assessment

process has been found to have a restricted scope [26]. In

addition, the focus is very much directed at new ethanol

plants and captures the impacts of land use change through

increased sugarcane planting as an indirect consequence. On

these lines, it could be argued that EIA does take place for

energy crop planting in England, where it is to be associated

with a new biomass power plant. However, planting

currently takes place to feed co-firing in existing power

plants (which therefore bypasses EIA), or where new power

plants are proposed for power plants to use energy crops asthe primary feedstock, off-site impacts (i.e. those caused by

land use change) are not typically considered beyond the

transport implications of transporting the feedstock to the

power plant.

The constraints maps (Agri-environmental Zoning) used as

a land use planning tool in Sao Paulo (and in England the

studies conducted under the Relu-biomass project) have

demonstrated approaches for managing land use change

associated with bioenergy crop planting, although it is only in

Sao Paulo that this approach has a formal status. In both

regions, formal strategic assessment of the land use change

implications would be beneficial to the future sustainability of

agricultural practice.

Table 4e Requirements for the approval of new projectsin Sao Paulo.

Type of zoning Main requirements

In suitable areas appropriate environmental

study (PER or EIS) in accordance

with Resolution SMA 42/2006

Maximum water consumption1 m3 t1 of processed

sugarcane

Rehabilitation of riparian

vegetation

In areas considered

as suitable with

environmental

limitations

EIS

Continuous air emissions moni

toring (particulate matter and NOx)

Detailed study of aquifer

vulnerability

Underground water monitoring

and target of maximum nitrate

concentration of 5 mg m3

Maximum water consumption

1 m3 t1 of processed

sugarcane Full protection of remaining

natural vegetation stands and

wetlands

Landscape ecology studies to

support any request to fell

isolated remaining trees

In areas considered

as suitable with

environmental

constraints

As above and

Establishment of ecological

corridors

Fauna monitoring during

operation

Maximum water consumption

0.7 m3 t1 of processed

sugarcane

Detailed landscape ecology andecological studies

In unsuitable areas New projects are forbidden

Source[20].



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4. Conclusions and recommendations

The main world drivers supporting the expansion of bio-

energy crops are primarily related to climate change and

energy security. Accordingly, Sao Paulo and England have

been experimenting at different levels in the development of

their bioenergy industries. The former has a huge internalmarket that consolidates the sugarcane industry andthere are

forecasts of a massive increase in land use for the purpose of

satisfying the demand from flex-fuel vehicles. With respect to

the latter the forecast is of exponential growth in miscanthus

and SRC in order to fulfil national strategic targets and inter-

national obligations. There are clear and tangible benefits of

biomass crops regarding different aspects discussed in detail

by some authors [6,7,11,16,39,40,47,80e82], however the

concerns arising have to be appropriately understood.

There are many potential impacts related to sugarcane

crop expansion in Sao Paulo and to perennial crop expansion

in England and, in order to determine the effectiveness of the

assessment systems to identify the potential impacts fromland use change, a set of criteria was developed and applied.

We recognise that the understanding of the term effective-

ness is heavily contested[74,83]and we would caution that

our approach is unlikely to be universally accepted as an

appropriate definition. However, we have encompassed all

recognised categories of effectiveness in our approach which,

in combination, does make some attempt to acknowledge and

accommodate a variety of theoretical perspectives on the

effectiveness of EIA[84].

The Sao Paulo assessment system is focused on the project

level, although a more strategic approach, through Agri-

environmental Zoning, exists for protecting some environ-

mental aspects. In England, there is no legal mandate forconducting assessment at different levels for land use change

to bioenergy crops except in some (unlikely) situations where

protected areas are threatened, or uncultivated land is

developed. Thus in both regions, there is considerable

opportunity for significant land use change in a context where

the decision-making powers of the Government are limited,

and so the opportunities to avoid or mitigate significant

impacts are absent.

In Sao Paulo there is evidence of procedural effectiveness

for individual projects, but the research suggests that more

engagement with citizens and stakeholders early in the deci-

sion-making process, along with a broader scope encom-

passing all three pillars of sustainability (social, economic andenvironmental) in line with the anticipated implications is

needed (see also[26]). In England, there is limited scope for

any effectiveness because, as it stands, there is no decision-

making structure in place for the majority of agricultural land

use change. Thus, EIA is unlikely to be required for perennial

biomass crops. To overcome this omission, some consider-

ation should be given to the scale of planting which is

considered significant enough to trigger EIA.

Previous research has identified a mismatch between the

geographical scale at which assessment tends to be applied

and the scale at which impacts occur[74]. Our analysis had

identified a similar problem in relation to assessment practice

for land use change involving perennial bioenergy crops. The

scale of planting is suchthat a strategic overview is required to

fully acknowledge the impacts. For example, development on

the scale of individual farms is not likely to demonstrate

significant implications for GHG emissions, whereas on

a regional scale, it might. This suggests that some form of SEA

is required that, in line with the findings for EIA, has a broader

sustainability scope. Agri-environmental Zoning used in Sao

Paulo is a step in the right direction, and a similar approachhas been taken in the UK [8]. However, these constraints

mapping approaches need to feed into a broader consider-

ation of sustainability implications. This, of course, has

financial implications and imposes obligations on the state,

rather than on developers (the typical EIA model follows the

polluter pays philosophy), however, it is more likely to lead to

better planned land use change, and has the potential to

reduce the need for EIAs written for inappropriate project

proposals.

Acknowledgements

This paper draws on evidence gathered in the RELU-Biomass

project (http://www.relu-biomass.org.uk) funded under the

Rural Economy and Land Use programme of the ESRC, BBSRC

and NERC.

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