Biomass action plan for Scotland

9. ENVIRONMENTAL IMPACTS

INTRODUCTION

9.1 Maintaining the high quality of our environment is an important element in the development of a sustainable biomass industry. There are a number of potential environmental impacts associated with the development of the raw materials and use of biomass for energy. How significant these impacts are will depend on a number of factors, which can be mitigated against in many cases through the use of best practice in land management and adherence to air quality standards and planning regulations. Some of the general principles are touched on below. Those issues relating to natural heritage are also developed in more detail in Scottish Natural Heritage's "Biomass Energy & The Natural Heritage" Policy Statement, due to be published shortly.

PRODUCTION OF THE RAW MATERIALS

9.2 The impacts on the environment from the development of a biomass feedstock will depend on the land use the biomass crop is replacing, the choice of crop and the way it is managed. However all public incentives supporting the establishment of such crops must follow general consultative arrangements provided for under the relevant grant scheme and this process will help to address environmental considerations. For woody biomass, the UK Forestry Standard covers the sustainable basis of all forestry practice in the UK.

Soil & Water Quality

9.3 Potential impacts on the soil quality from the growth and harvesting of wood biomass feedstocks are largely addressed through compliance with the UK Forestry Standard and associated guidance such as the Forestry Commission's Forest and Soil Conservation Guidelines (1998). These are currently under revision and are due to go to consultation in 2007/08. Under CAP reform, to receive the Single Farm Payment, farmers must comply with the requirements of the Good Agricultural Environmental Conditions ( GAEC) covering soil erosion, maintenance of soil organic matter levels, maintenance of soil structure, minimum levels of maintenance and avoidance of deterioration of habitats.

9.4 Potential impacts on water quality are closely linked to effects on the soil and are covered by the Forest Water Guidelines and the Water Environment (Controlled Activities Scotland) Regulations 2005 and General Binding Rules for Controlling Diffuse Pollution due for publication in Spring 2007. Certain biomass feedstocks, particularly willow SRC, have high water demands and care should be taken to avoid depletion of the water table in areas with low water availability. However, compliance with the UK Forestry Standard should mitigate against any potential problems. The UK Woodland Assurance Standard additionally provides a voluntary certification process for forest owners. Furthermore, compliance with Forest Nature Conservation Guidelines (1990) and the revision due out in 2007 will ensure plantations are not established in areas of conservation value. It is worth noting that taking land out of agricultural use and into forestry in nitrate vulnerable zones ( NVZs) will have beneficial implications for water quality in these areas. For agricultural crops, farmers within NVZs must comply with the requirements in the Action Programme for Nitrate Vulnerable Zones (Scotland) Regulations 2003.

Waste

9.5 By using residual waste from the waste management stream which would otherwise go to landfill, thermal treatment facilities have the potential to reduce risks of leachate and soil and water contamination. It also avoids the production in landfill sites of methane which is powerful climate change gas.

Biodiversity

9.6 In the development of domestic biomass feedstocks, it is likely that set aside will be extensively used for the growth of energy crops. This has the potential to have a significant positive impact on biodiversity, the nature and extent of which will depend on the environmental quality of the set aside and the type of crop it is replaced by. On marginal land with low biodiversity SRC could benefit biodiversity, and could also have a role as a corridor between isolated habitats, though buffer zones may be required to preserve edge habitats and open spaces in some areas to allow for species movements.

9.7 To prevent any significant environmental impacts, all woodland creation, including SRC, falls within the potential scope of the Environmental Impact Assessment Regulations. Any public support for woodland creation requires adherence to the UK Forestry Standard and associated guidelines, and is subject to statutory consultation. This ensures that priority open habitats are protected, and that woodland creation proposals take full account of biodiversity considerations.

9.8 Growing demand for woody biomass could encourage active management of neglected woodland which can bring environmental and amenity benefits, for example through encouragement of woodland regeneration. The UK Forestry Standard, and associated Forests and Nature Conservation Guidelines, lay out appropriate standards for in-forest retention of deadwood and old trees as part of the woodland ecosystem.

9.9 Soil biodiversity and freshwater ecosystems could be negatively affected by an increase in fertiliser application. Conversion to forestry is unlikely to increase fertiliser use compared to agricultural practice and compliance with the Forestry Commission's Forest and Soil Conservation Guidelines (1998) should mitigate any potential problem. The application of sewage sludge, where considered, is controlled by the Waste Management Licensing Amendment (Scotland) Acts 2003, 2004 and must conform to current guidance which will prevent toxic build-up and bio-hazards (see Forestry Commission's Information Note: "Use of sewage sludges and composts in forestry" published 2006). The current Controlled Activities Regulations and the imminent Diffuse Pollution General Binding Rules (see Water Environment and Water Services (Scotland) Act 2005) provide further statutory regulation.

9.10 The current and growing demand for biofuels is also leading to a global market for biofuels feedstock. The Executive will consider how imports of biofuels or their raw materials can be quality assured to guarantee they are derived from sustainable sources.

Landscape

9.11 For woody biomass, the Scottish Forestry Strategy recognises the importance of forestry in the landscape. Although SRC is usually managed on 3 to 5 years rotations, it has some physical characteristics of woodland and grows tall enough to create a three dimensional mass in the landscape. Establishing and managing SRC in currently open arable landscapes will result in potential impacts on landscape character and visual amenity, which requires careful consideration. These impacts can be mitigated through adherence to guidance in the Forestry Commission Guideline Note: Short rotation coppice in the landscape (2001), which is an expansion of the essential forest and woodland design advice for such arable landscapes contained in the Lowland Landscape Design Guidelines (1992).

Greenhouse Gas balances

9.12 Greenhouse Gas ( GHG) emissions can depend on a variety of factors such as crop choice and variety; soil type; how it is managed; distance of processing plant from source and others. It is important that the net GHG emissions reductions from all stages in feedstock production, from land management to biomass use for energy are considered. For example carbon savings from fossil-fuel substitution, or the carbon sequestration functions of forests, should not be lost through inappropriate forestry practices disturbing organic soils. This is addressed through sustainable forest management principles set out in the UK Forestry Standard. A comprehensive study of the factors affecting GHG balance of biomass feedstocks, Review of Greenhouse Gas Life Cycle Emissions, Air Pollution Impacts and Economics of Biomass Production and Consumption in Scotland, has been published by SEERAD. This highlights that the greatest carbon savings are likely to be derived from wood for heat. Combined heat and power ( CHP) generation offers particular opportunities for maximising the energy generation capacity of biomass. Although carbon savings from biofuels are typically much lower, they replace fossil fuels where few alternatives currently exist.

Mitigation

9.13 The development of good management practices has the potential to address many of these possible impacts. This can include thinning practices to promote biodiversity, appropriate management of native broadleaved woodlands as a biomass resource, correct choice of felling and extraction systems and the sequencing of harvesting, multi-species coppicing to enhance biodiversity, improving long term soil fertility and providing biological resistance to pests. The application of the UK Forestry Standard and its associated guidelines, coupled with the expansion of certification schemes, would ensure that good practice is widely adopted, and this should apply to domestic feedstocks and imports.

USE OF BIOMASS FOR ENERGY

Air Quality

9.14 All local authorities, under the Environment Act 1995, are required to review and assess air quality in their area against a set of health based objectives for certain pollutants. These objectives are outlined in the Air Quality Strategy ( AQS) for England, Scotland, Wales and Northern Ireland. If this work suggests that any objective will not be achieved by the required date, the local authority concerned must declare an Air Quality Management Area and produce an action plan outlining how it intends to tackle the issues identified.

9.15 Most of the air quality problems identified to date have been in large urban areas and are caused by vehicle emissions. Industrial emissions are less of an issue than in the past helped by the fact that SEPA regulates large industrial installations in line with the requirements of the relevant legislation.

9.16 Any moves towards increased emissions from industrial or domestic actives involving biomass will be looked at cautiously by both SEPA and local authorities.

9.17 First impressions are that the effects will be minimal in the short term, given that any initiatives are probably going to be small scale, and any larger ones will be regulated by SEPA as described above.

9.18 Government approved biomass technology is listed on the Energy Technology List ( www.eca.gov.uk), which meets the minimum emissions standards. In Smoke Control Areas, installation must also comply with the exempt appliance list ( www.smokecontrolareas.co.uk). The number of appliances is currently limited and equipment suppliers should be encouraged to register their equipment.

9.19 Existing measures to ensure the continued high quality of our environment include the Air Quality Strategy, the Smoke Control Regime and regulation by SEPA of plants over 0.4 MW or which plan to utilise waste as a feedstock. Future measures include regular reviews of the Air Quality Strategy and Smoke Control Regimes, including lists of approved appliances.

ACTION TABLE

Lead Department	Action	Timing	Indicators/Outputs
Forestry Commission Scotland	Implementation of the relevant Forest Guidelines & UK Forestry Standard	ongoing	SFS Implementation Plan
Forestry Commission Scotland	Encourage the forestry sector to take part in the Scottish Executive's National Waste Plan	ongoing	SFS Implementation Plan
ERAD - Biodiversity	Continue to implement the Scottish Biodiversity Strategy	ongoing	Growth of biomass industry is developed in a sustainable way
ERAD - Climate Change	Examine ways to secure compliance with environmental legislation without imposing undue costs or constraints on farm businesses	ongoing	Growth of biomass industry is developed in a sustainable way
ERAD - Climate Change	Ensure grant conditions for the Scottish Biomass Support Scheme promote best environmental practice	ongoing	Growth of biomass industry is developed in a sustainable way
ERAD - Climate Change	Regularly review AQS and Smoke Control regime, including list of approved appliances	ongoing	List of approved appliances