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Obligation
April 2010
Please note that Tyndall working papers are "work in progress". Whilst they are commented on by Tyndall researchers, they have not been subject to a full peer review. The accuracy of this work and the conclusions reached are the responsibility of the author(s) alone and not the Tyndall Centre.
Dr Paul Upham, Manchester Institute for Innovation Research and Tyndall Centre Manchester, University of Manchester Ms Julia Tomei, UCL Energy Institute, University College London April 8th 2010
CONTACT
DETAILS
AND
ACKNOWLEDGEMENTS Many
thanks
to
the
interviewees
and
questionnaire
respondents
who
helped
us
to
build
a
picture
of
critical
and,
to
a
lesser
extent,
industry,
stakeholder
views
on
biofuels
as
of
late
2009.
Funding
for
this
work
is
by
EPSRC
Supergen
Biomass
and
Bioenergy
Consortium.
This
report
is
copyright
of
the
authors,
the
University
of
Manchester
and
University
College
London.
An
extended
version
will
be
publicly
available
on
the
website
of
the
EPSRC
Supergen
Biomass
and
Bioenergy
Consortium:
www.supergen-bioenergy.net/.
This
version
has
been
submitted
as
part
of
the
Tyndall
Working
Paper
series:
http://www.tyndall.ac.uk/publications/working-papers
.
For
further
information,
please
contact
the
authors:
Dr Paul Upham Research Fellow Tyndall Centre Manchester Pariser Building University of Manchester M60 1QD Paul.upham@manchester.ac.uk [t] 0161 306 3258 [f] 0161 306 3255
Ms Julia Tomei Research Associate / Doctoral Researcher UCL Energy Institute Central House 14 Upper Woburn Place London, WC1H 0HY j.tomei@ucl.ac.uk [t] 020 3108 5979 [f] 020 3108 5986
EXTENDED
ABSTRACT
This
working
paper
describes
investigation
of
selected
stakeholder
opinion
of
UK
biofuel
and
related
bioenergy
policy
over
the
period
September
2006
to
December
2009.
A
fuller
report
will
be
available
here:
http://www.supergen-bioenergy.net/?_id=339
and
a
more
condensed
journal
paper
will
follow.
A
review
of
the
sustainability
issues
associated
with
some
19
feedstocks
(Thornley
et
al.,
2008)
is
also
available
at
the
above
website.
In
this
working
paper,
we
describe
the
process
of
investigation,
our
findings
and
our
interpretation
of
them.
The
work
took
place
both
before
and
after
the
Gallagher
Report,
which
was
commissioned
by
the
UK
government
and
which
advocates
a
cautious
approach
to
biofuels.
The
working
paper
is
written
for
readers
without
a
social
science
background,
reflecting
the
EPSRC
funding.
Our
focus
is
on
environmental
and
social
sustainability
policy,
particularly
carbon
and
sustainability
reporting
under
the
Renewable
Transport
Fuels
Obligation
(RTFO).
The
opinions
examined
are
largely,
though
not
wholly,
of
those
stakeholders
whose
concerns
are
not
well-represented
in
existing
UK
biofuel
policy.
This
is
despite
increasing
evidence
that
the
bioenergy
and
biofuel
policy
arena
is
one
in
which
the
risks
of
perverse,
unintended
consequences
is
relatively
high.
As
our
study
progressed,
it
also
became
clear
that,
given
our
limited
resources,
one
of
the
more
distinctive
directions
that
we
could
take
would
be
to
highlight
this
particular
feature
of
UK
(and
EC)
bioenergy/biofuels
policy,
with
a
view
to
considering
the
prospects
for
a
more
inclusive
policy
process.
The
bioenergy
and
biofuels
policy
domain
is
substantially
different
from
other
technology-focussed
environmental
policy
domains,
in
that
it
has
strong
connections
across
agriculture,
international
development,
biodiversity
protection
and
climate
change
arenas.
Governance
and
institutional
capacity
are
also
important
in
this
context,
in
which
voluntary
environmental
and
social
standards
are
being
called
upon
to
perform
quasi-regulatory
tasks.
While
this
complexity
is
perhaps
increasingly
understood,
it
has
not
prevented
the
rapid
introduction
of
a
proactive
biofuel
policy
in
the
UK
and
Europe
that
many
consider
hasty.
Analysis
of
RTFO
consultation
responses
Here
we
refer
to
two
phases
of
our
investigation
into
stakeholder
opinion.
The
first
consists
of
analysis
of:
(i)
responses
to
the
UK
Department
for
Transport
(DfT)
consultation
on
the
design
of
the
RTFO
(DfT,
2007a
and
2008c)
and
(ii)
responses
to
the
DfT
consultation
on
RTFO
carbon
and
sustainability
reporting
requirements
(DfT,
2007b
and
2008b).
We
focused
on
sustainability
aspects
only
and
the
17
responses
examined
were
those
that
were
posted
on
the
internet,
readily
and
publicly
available
and
thus
function
as
public
position
statements.
We
firstly
sought
to
identify
issues
of
stakeholder
concern
in
relation
to
the
RTFO,
as
stated
in
the
consultation
responses.
These
were
highly
variable,
but
concern
over
food
prices,
land
theft
and
working
conditions
were
relatively
widely
shared.
Secondly,
we
observed
that
as
the
entire
stakeholder
response
set
expressed
support
for
greenhouse
gas
(GHG)
and
sustainability
reporting
by
biofuel
suppliers,
support
for
reporting
per
se
was
not
useful
for
distinguishing
positions.
Similarly,
the
objective
of
carbon/GHG
emissions
reduction
is
appealed
to
in
all
of
the
responses.
Given
this,
what
is
much
more
revealing,
in
terms
of
categorising
and
understanding
the
differing
priorities
of
stakeholders,
are
stakeholder
comments
relating
to
the
stringency
and
timing
of
the
introduction
of
reporting
conditions,
particularly
the
ability
of
suppliers
to
report
unknown
regarding
land
use
change,
as
well
as
the
other
concerns
and
issues
that
they
raise.
Stakeholder
interviews
The
second
phase
of
our
investigation
of
stakeholder
opinion,
considered
here,
consists
of
12
interviews
with
largely
non-commercial
actors,
given
that
our
comparison
of
the
RTFO
and
stakeholder
positions
3
available
suggests
that
NGO
voices
have
been
given
little
weight
in
the
design
of
the
RTFO.
One
interviewee
with
a
fuel
supply
affiliation
provides
a
contrast.
The
question
themes
are
those
that
we
found
to
be
central
issues
of
debate
and
concern
in
our
preceding
work.
Despite
these
being
largely
non-commercial
actors,
and
in
some
cases
non-UK
for
an
external
perspective,
strong
areas
of
divergence
continue
to
relate
to:
whether
a
large
scale
biofuels/bioenergy
trade
is
necessary
for
climate
change
mitigation;
necessary
for
UK
energy
security;
poses
a
GHG
emissions
risk
from
land
use
change;
poses
a
risk
in
terms
of
food
poverty;
whether
reducing
transport
energy
demand
should
be
a
higher
priority
than
increasing
biofuel
supply;
and
whether
use
of
land
for
bioenergy
should
prioritise
power
and
heat
as
end
uses,
rather
than
biofuel
for
transport.
There
was
no
divergence
among
the
environment
NGOs
on
these
points.
There
was
stronger
convergence
among
all
interviewed
stakeholders
on
two
points:
whether
a
large
scale
bioenergy/biofuel
trade
would
benefit
wealthier
farmers
(most
respondents
agreed);
and
the
level
of
confidence
that
interviewees
had
in
the
RTFO
carbon
and
sustainability
reporting
method
(most
respondents
considered
RTFO
reporting
to
be
weak).
Interpretation
We
bring
three
main
lines
of
discussion
to
bear
on
the
above,
both
to
help
characterise
our
findings
and
to
assist
in
making
recommendations
for
improving
the
situation.
The
first
is
an
analytic
rather
than
explanatory
concept,
namely
discourse.
At
the
most
general
level,
environmental
discourse
may
be
defined
as:
the
linguistic
devices
articulating
arguments
about
the
relationship
between
humans
and
their
environment
(Muhlhausler
and
Peace,
2006).
We
suggest,
specifically,
that
the
discourse
of
climate
mitigation
is
being
used
partly
as
a
persuasive
linguistic
device.
We
suggest
this
because
the
evidence
for
GHG
savings
from
biofuel
systems
is
rarely
conclusive,
requiring
the
demonstration
of
no
counter-balancing
direct
or
indirect
land
use
change,
and
requiring
the
demonstration
of
actualised
greenhouse
gas
(GHG)
displacement
benefits
from
the
use
of
co-products.
In
addition,
there
are
usually
other
uses
for
the
same
land
that
others
may
with
justification
consider
equally
valuable
(e.g.
maintenance
of
biodiversity,
cultivation
of
food
crops
or
energy
crops
for
heat
and
power),
the
latter
of
which
may
achieve
greater
GHG
displacement.
This
is
not
to
say
that
biofuels
cannot
achieve
GHG
reductions,
but
it
is
to
say
that
proving
this
to
be
the
case,
let
alone
an
optimal
case,
is
far
from
straightforward
and
is
partly
a
matter
of
opinion
(with
respect
to
what
one
considers
to
be
the
best
use
of
land).
In
short,
the
climate
mitigation
case
for
biofuels
is
frequently,
legitimately
contestable.
Secondly,
we
lightly
discuss
the
governance
aspects
of
biofuels
production,
particularly
the
use
of
non- state,
voluntary
standards
under
the
RTFO.
This
is
in
some
respects
concerning
and
indicative
of
the
limited
agency
and
powers
of
national
governments
in
this
context.
Very
few
of
the
non-commercial
stakeholders
interviewed
had
much
confidence
in
the
Roundtable
on
Sustainable
Palm
Oil
(RSPO),
Roundtable
on
Responsible
Soy
(RTRS)
or
Forest
Stewardship
Council
(FSC),
all
of
which
are
important
in
RTFO
sustainability
certification.
Non-state
actors,
particularly
corporations
and
non-governmental
organisations
with
environmental
and
social
missions,
are
increasingly
playing
significant
roles
in
the
formation
of
environmental
policy.
While
this
is
a
pragmatic
response
to
an
absence
of
institutional
capacity
in
supplier
countries,
it
is
not
an
effective
substitute
for
legally-enforceable
national
standards
in
supply
countries,
not
least
because
it
has
high
potential
for
leakage
in
the
sense
of
displacing
unwanted
activity
to
new
sites.
Thirdly,
we
use
concepts
of
regulatory
co-production
(Jasanoff,
1990)
and
post-normal
science
(e.g.
Funtowicz
and
Ravetz,
2008)
to
critique
the
process
by
which
the
RTFO
(and
it
would
appear
the
RED
also)
has
been
developed,
and
to
recommend
a
more
inclusive
approach
to
biofuel
and
bioenergy
policy
in
future.
Regulatory
co-production
refers
to
the
way
in
which
government
regulation
is
typically
influenced
and
shaped
by
stakeholders
during
its
development,
partly
to
ensure
that
it
is
practicable,
and
partly
4
because non-government actors have their own agendas that they seek to pursue. Post-normal science is an aspirational conception of how policy science in complex and contested arenas should be conducted: e.g. (Funtowicz and Ravetz, 1994, also 2008) argue that there is a need for science as applied in such contexts to recognise the multiplicity of legitimate perspectives and commitments, and to provide new norms of evidence and discourse. Our argument here, although arrived at independently, mirrors in a particular case that made by (Frame and Brown, 2008) at a more general level: namely that that co-production of the RTFO has been too narrow and needs to be broadened. Despite RTFO certification being dependent on non-state organisations for its functioning, the concerns of the environment and development non-government organisations (NGOs) who play a role in either directly monitoring environmental degradation, or in relaying others monitoring, have unjustifiably been given little credence in biofuel policy. We could go further than this and refer to political economy accounts of the way in which science is sometimes used in policy, specifically that private beneficiaries may sometimes dominate and even suppress scientific uncertainties (Collingridge and Reeve, 1986). The way in which biofuel policy has forged ahead in the face of increasingly obvious risks would add legitimacy to such an argument. We also lightly discuss the role of emerging Renewable Energy Directive (RED) certification and the potential role of the CEN standard (European Committee on Standardisation) on sustainable biomass production. We do not argue against a large scale international trade in biomass for bioenergy as a matter of principle, but a more stringent assessment of feedstocks would nonetheless greatly reduce the scale of that trade relative to its technical potential, perhaps particularly for biofuels. Finally, we note that the difficulties involved in characterising, anticipating and preventing indirect impacts are likely to remain a major obstacle to widespread consensus on biofuel policy.
CONTENTS
Extended
abstract......................................................................................................................................................3
Contents....................................................................................................................................................................6
1.
Context..................................................................................................................................................................7
1.1
Introduction.................................................................................................................................................................. 7
1.2
The
UK
RTFO ................................................................................................................................................................. 7
1.3
Carbon
and
sustainability
reporting
under
the
RTFO ................................................................................................... 8
1.4
Previous
studies
of
stakeholder
opinion
on
biofuels.................................................................................................... 9
2.
Research
Aims,
objectives
and
methods ..............................................................................................................10
2.1
Aims
and
objectives....................................................................................................................................................10
2.1.1
Epistemology ...........................................................................................................................................................10
2.2
Methods .....................................................................................................................................................................11
2.2.1
Review
of
feedstock
sustainability
literature ..........................................................................................................11
2.2.2
stakeholder
submissions
to
RTFO
consultations .....................................................................................................11
2.2.3
Stakeholder
interviews ............................................................................................................................................11
3
Interpretative
theory ............................................................................................................................................12
3.1
discourse
analysis .......................................................................................................................................................12
3.2
Co-production
of
regulatory
policy.............................................................................................................................13
4.
Results.................................................................................................................................................................15
4.1
Stakeholder
submissions
to
RTFO
consultations ........................................................................................................15
4.1
Position
differences ....................................................................................................................................................15
4.2
Discursive
differences.................................................................................................................................................24
4.3
Stakeholder
responses
to
biofuel
policy
interview
questions ....................................................................................27
5.
The
prospects
for
wider
co-production
of
biofuel
policy.......................................................................................36
5.1
Introduction................................................................................................................................................................36
5.2
post-normal
science
and
biofuel
policy ......................................................................................................................36
5.3
Future
prospects.........................................................................................................................................................37
6
Conclusions...........................................................................................................................................................42
Bibliography ............................................................................................................................................................43
Appendix
A
Interview
Questionnaire.........................................................................................................................52
6
1.
CONTEXT
1.1
INTRODUCTION
This
working
paper
describes
an
investigation
of
selected
stakeholder
opinion
of
UK
biofuel
and
related
bioenergy
policy
over
the
period
September
2006
to
December
2009.
We
describe
the
process
of
investigation,
our
findings
and
our
interpretation
of
them,
using
other
findings
and
concepts
drawn
from
the
social
sciences.
The
work
took
place
both
before
and
after
the
Gallagher
Report,
which
was
commissioned
by
the
UK
government
and
which
advocates
a
cautious
approach
to
biofuels.
The
working
paper
is
based
on
a
report
written
for
a
non-social
science
audience.
1.2
THE
UK
RTFO
In
November
2005,
the
UK
Government
announced
that
it
would
introduce
a
Renewable
Transport
Fuel
Obligation
(RTFO)
as
a
means
of
supporting
the
use
of
biofuels
and
other
renewable
fuels
in
the
transport
sector.
The
RTFO
began
in
April
2008
and
applies
to
any
road
transport
fuel
supplier
supplying
more
than
450,000
litres
of
fossil
fuel
per
year
to
the
UK
market.
The
obligation
requires
road
transport
fuel
suppliers
to
either
ensure
that
a
specified
percentage
of
their
fuel
sales
come
from
renewable
sources,
or
to
discharge
their
obligation
in
the
ways
described
below.
As
originally
formulated,
the
level
of
the
obligation
on
a
transport
fuels
supplier
was
equivalent
to
2.5%
of
their
total
road
transport
fuel
sales
in
2008/9,
rising
to
3.75%
in
2009/10
and
5%
in
2010-11
and
beyond.
However,
following
the
recommendations
made
by
the
Renewable
Fuels
Agency
to
the
Government
in
the
Gallagher
review
on
the
potential
indirect
land
use
effects
of
biofuels
policy,
the
RTFO
(Amendment)
Order
was
made
on
1
April
2009,
reducing
the
rate
of
increase
of
the
targets
for
biofuel
supply
by
volume
under
the
RTFO
to
3.25%
for
2009-10,
3.5%
for
2010- 11,
4%
for
2011-12,
4.5%
for
2012-13
and
5%
for
2013
onwards
(Renewable
Fuels
Agency,
2009a).
A
supplier
can
meet
up
to
25%
of
their
obligation
by
presenting
RTF
Certificates
as
evidence
of
the
supply
of
renewable
transport
fuel
(ibid).
These
certificates
may
be
awarded
directly
by
the
Renewable
Fuels
Agency,
or
to
other
suppliers
and
then
bought
by
the
obligated
supplier.
If
an
obligated
company
does
not
have
sufficient
RTF
certificates,
it
may
discharge
its
obligation
by
paying
a
buy-out
price
for
each
litre
of
renewable
road
transport
fuel
which
should
have
been
but
has
not
been
supplied.
RTF
Certificates
may
be
traded
amongst
suppliers
or
other
persons
who
have
an
RTF
account.
An
RTF
Certificate
will
also
entitle
a
fuel
supplier
to
a
share
of
any
buy-out
fund
that
may
be
recycled
(DfT,
2007a).
The
design
of
the
scheme
is
thus
similar
to
that
of
the
UK
Renewable
Obligation
Order
that
obliges
and
incentivises
the
generation
of
electricity
from
renewable
sources.
Legally,
UK
biofuels
policy
is
driven
by
the
Biofuels
Directive
(2003/30/EC),
which
requires
that
biofuels
or
other
renewable
fuels
constitute
5.75%
of
the
energy
content
of
petrol
and
diesel
sold
for
transport
in
member
states
by
2010.
An
EC
proposal
(COM(2007)18)
to
reduce
the
carbon
intensity
of
transport
fuels,
to
be
made
in
the
Fuel
Quality
Directive,
could
raise
the
role
of
biofuels
to
15%
of
transport
fuel
(by
energy)
by
2020,
depending
on
the
final
target
and
the
extent
to
which
other
renewable
fuels
are
used
(Renewable
Fuels
Agency,
2008).
In
September
2008,
the
European
Parliament's
Industry
and
Energy
Committee
voted
for
a
5%
share
for
renewable
fuels
by
2015
and
10%
by
2020.
This
support
was
conditional
on
at
least
20%
of
the
2015
target
and
40%
of
the
2020
goal
(i.e.
4%
of
total
2020
fuel
sales)
being
met
from
"non-food
and
7
feed-competing"
second-generation
biofuels
(echoing
the
Gallagher
report
above)
or
from
other
renewable
fuels
such
as
renewably-sourced
electricity
and
hydrogen.
This
would
effectively
reduce
the
interim
2015
target
for
the
share
of
EU
fuel
sales
that
must
be
from
biofuel
to
4%,
compared
to
the
target
of
5.75%
by
2010
set
in
the
2003
Biofuels
Directive
(EurActiv.com,
2008).
In
December
2008,
the
European
Parliament
agreed
that
in
order
to
count
toward
the
EU
target,
biofuels
must
deliver
life-cycle
CO2
savings
of
initially
35%,
then
50%
from
2017,
rising
to
60%
when
produced
from
new
refineries
that
come
on-stream
from
2017
onwards
(European
Parliament,
2008).
The
European
Parliament
has
also
repeatedly
referred
to
the
need
for
biofuels
supply
to
be
subject
to
effective
sustainability
criteria,
and
has
specified
environmental
criteria
(essentially
prohibitions
on
the
use
of
biodiverse,
high
carbon
stock
and
wooded
land)
for
this
purpose
(Article
17,
in
ibid).
1.3
CARBON
AND
SUSTAINABILITY
REPORTING
UNDER
THE
RTFO
To
receive
a
certificate
(and
hence
financial
reward),
a
supplier
operating
in
the
UK,
above
the
threshold
of
450,000
litres
of
biofuel/year,
must
report
monthly
on
their
performance
in
terms
of
the
extent
to
which
they
have
met
the
qualifying
standards
(discussed
below)
defined
in
RFA
guidance;
(2)
the
greenhouse
gas
(GHG)
intensity
of
the
biofuels
supplied;
(3)
land
use
on
Nov
30th
2005;
and
(4)
the
level
of
accuracy
of
the
data
supplied,
as
defined
on
five
levels
(RFA,
2009).
Qualifying
standards
are
defined
as
those
that
meet
a
specified
number
of
criteria
in
the
RTFO
sustainability
meta-standard,
which
is
a
set
of
aspirational
principles,
criteria
and
indicators
that
is
broader
and
in
some
cases
of
a
higher
standard
than
the
qualifying
standards.
The
RFA
takes
responsibility
for
reporting
indirect
effects
on
land
use
and
commodity
prices,
not
the
biofuels
supplier.
At
the
time
of
writing,
meeting
a
qualifying
standard
is
not
mandatory.
The
RFA
states
that
it
aims
for
this
to
be
mandatory
by
April
2011,
conditional
on
this
being
compatible
with
World
Trade
Organisation
rules
and
EU
Technical
Standards
requirements,
consistent
with
the
policy
framework
being
developed
by
the
European
Commission
as
part
of
the
review
of
the
Biofuels
Directive,
and
subject
to
consultation
on
its
environmental
and
economic
impacts
(RFA,
2009,
p.2).
As
of
the
end
of
2009,
qualifying
environmental
standards
were:
Linking
Environment
And
Farming
Marque
(LEAF);
Roundtable
on
Sustainable
Palm
Oil
(RSPO)
(also
a
qualifying
social
standard);
Sustainable
Agriculture
Network/Rainforest
Alliance
(SAN/RA)
(also
a
qualifying
social
standard);
Basel
criteria
for
soy
(Basel)
(also
a
qualifying
social
standard);
Forest
Stewardship
Council
(FSC);
Assured
Combinable
Crops
Scheme
(ACCS)
and
Genesis
Quality
Assurance
(QA)
(RFA,
2009).
There
are
several
other
standards
that
do
not
meet
the
RTFO
qualifying
standard
and
there
are
also
initiatives
that
seek
to
harmonize
national
and
other
initiatives;
Gnansounou
et
al
(2007)
provide
a
review
of
initiatives
as
of
2007,
but
the
number
has
proliferated
since
then
see
http://www.bioenergywiki.net/index.php/Sustainability_standards
for
an
on-going
list.
Also
notable
is
the
European
Committee
for
Standardisations
Sustainably
produced
biomass
for
energy
applications
(CEN/TC
383),
which,
although
voluntary,
will
apply
as
a
European
standard
across
the
EU.
Being
consensual,
this
may
come
to
function
as
a
lowest
common
denominator,
but
at
the
present
time
it
is
too
early
to
comment
with
any
certainty.
8
1.4 PREVIOUS STUDIES OF STAKEHOLDER OPINION ON BIOFUELS At the time of writing, there is little literature, academic or otherwise, on stakeholder opinion differences with respect to biofuels. One of the few examples is (van Dam et al., 2008), which includes a summary of selected NGO opinion on and involvement in biomass certification, based on documentary evidence. It would be fair to say that van Dam et al (ibid) does not reflect the state of UK environment and development NGO opinion on biofuels as of 2009, which is much more strongly doubtful of the way that UK and EC policy has developed and is developing. The concerns that we describe in this report capture much of that opinion and also add a degree of specificity with respect to the RTFO, as well as the implications for use of biofuel science in policy. This is not available elsewhere at the time of writing. Indeed the twin, key critiques of large scale bioenergy expansion remain under-addressed, namely whether the necessary institutional capacity can be installed and the extent and nature of indirect effects.
2.
RESEARCH
AIMS,
OBJECTIVES
AND
METHODS
2.1
AIMS
AND
OBJECTIVES
The
aim
of
the
study
is
to
gain
a
better
understanding
of
stakeholder
perceptions
of
UK
biofuel
and
related
bioenergy
policy
and
options.
As
the
study
proceeded,
the
research
objectives
were
refined
and
the
methods
of
investigation
adapted
accordingly.
The
initial
brief
in
the
EPSRC
proposal
was
to
develop
quantitative
and
qualitatively
informed
biofuel/bioenergy
scenarios
of
alternative
pathways
from
feedstock
production,
conversion
and
end
use,
and
to
use
these
as
part
of
an
MCA
process.
However,
it
became
apparent
that
focussing
more
specifically
on
the
sustainability
aspects
of
RTFO,
and
on
the
way
in
which
it
was
developed,
would
prove
a
more
readily
fruitful
means
of
documenting
existing
opinion
and
eliciting
opinion
that
is
not
already
documented.
In
terms
of
knowledge
gaps,
we
also
judged
that
this
approach
would
add
most
substantially
to
our
understanding,
given
that
other
scenario-oriented
work
into
stakeholder
perceptions
was
on-going
at
the
time
(e.g.
Elghali
et
al.,
2007).
A
further
refinement,
as
we
began
to
understand
that
the
RTFO
development
process
had
marginalised
most
of
the
environment
and
development
NGOs,
was
to
focus
particularly
on
those
stakeholders
who
were
likely
to
have
been
external
to
the
RTFO
development
process.
Question
checks
were
used
in
order
to
verify
this.
The
objectives
are
as
follows
and
selective
detail
on
methods
is
given
in
subsequent
sections:
1. To
review
the
sustainability-related
biofuel
and
bioenergy
policy
literature,
identifying
evidence,
debates
and
issues
of
concern
to
a
variety
of
stakeholders.
2. To
probe
in
further
detail
the
opinions
of
a
small
number
of
stakeholders
likely
to
hold
differing
perspectives,
in
order
to
further
understand
areas
of
opinion
difference.
3. To
analyse
publicly
available
stakeholder
responses
to
the
sustainability
aspects
of
the
RTFO,
in
order
to
identify
areas
of
commonality
and
difference
in
opinion.
4. To
undertake
interviews
with
largely
non-commercial
stakeholders,
focussing
on
detailed
perceptions
of
the
RTFO,
its
sustainability
aspects,
and
the
process
by
which
RTFO
policy
was
developed.
5. To
draw
inferences
in
terms
of
the
use
of
stakeholders
use
of
climate
discourse;
the
use
of
science
in
policy;
and
the
development
of
environmental
regulation
in
conditions
of
scientific
uncertainty.
2.1.1
EPISTEMOLOGY
Here,
we
consider
that
alternative
definitions
of
optimality
and
sustainability
are
legitimate
and
are
founded
upon
alternative
values.
This
does
not
mean
that
science
is
irrelevant
to
sustainability,
but
it
does
mean
that
applying
sustainability
concepts
to
a
sector
requires
definition
of
what
exactly
is
to
be
sustained
and
in
what
form
(Upham,
2001).
Although
sustainability
has
been
defined
from
many
different
perspectives,
the
search
for
a
single
or
objective
definition
of
sustainable
development
is
misleading
10
because the concept has a variety of political and scientific roots (Kidd, 1992). As stakeholders differ in their views on these issues and have different degrees of influence over policy, the meaning of sustainability in a given context is almost invariably contested. This is very much the case in biofuel and bioenergy policy, which cuts across many domains and thus provides ample opportunity for differing valuations of the same phenomena. Broadly, we take a critical realist view, in which we assume that objective actualities exist, but that these may be empirically perceived very differently by different people (e.g. Bhaskar, 1975; Archer et al., 1998). 2.2 METHODS 2.2.1 REVIEW OF FEEDSTOCK SUSTAINABILITY LITERATURE The first phase of our work consisted of a detailed and substantial (40,000 word) review of the sustainability aspects of a broad range of biofuel feedstocks, drawing on academic, NGO and other sources. At this point in time (late 2006 to mid-2007) there was relatively little related academic literature on the topic. The review informed Thornley et al (2009); Tomei and Upham (2009) and Upham et al (2009). 2.2.2 STAKEHOLDER SUBMISSIONS TO RTFO CONSULTATIONS A further phase of our investigation into stakeholder opinion consisted of analysis of: (i) responses to the DfT consultation on the design of the RTFO (DfT, 2007a and 2008c) and (ii) responses to the DfT consultation on RTFO carbon and sustainability reporting requirements (DfT, 2007b and 2008b). We focused on sustainability aspects only and the 17 responses examined were those that were posted on the internet, readily and publicly available and thus function as public position statements. We firstly sought to identify issues of stakeholder concern in relation to the RTFO, as stated in the consultation responses. Secondly, we took note of the discourses used. 2.2.3 STAKEHOLDER INTERVIEWS The third phase of our investigation into stakeholder opinion, as reported here, consisted of 12 structured interviews with non-commercial actors, following our finding that NGO voices have been given little weight in the design of the RTFO. One interviewee with a fuel supply affiliation provides a contrast. The question themes are those that we found to be central issues of debate and concern in our preceding work. The questions, notable responses and transcripts are appended.
11
3
INTERPRETATIVE
THEORY
This
section
introduces
the
social
science
literatures
that
we
have
referred
to
in
characterising
stakeholder
perceptions
the
RTFO
development
process.
We
apply
the
literature
in
section
5.
3.1
DISCOURSE
ANALYSIS
An
oft-used
approach
to
analysing
stakeholder
opinion
is
one
that
focuses
on
the
use
of
language,
namely
discourse
analysis.
Broadly
speaking,
discourse
analysts
propose
an
intuitively-acceptable
premise:
that
language
reveals
beliefs
and
values
and
that
it
is
used
purposively:
inter
alia
to
create
identities,
to
attribute
significance,
to
make
associations,
to
represent
political
perspectives,
and
to
privilege
particular
types
of
knowledge
and
language
(Gee,
2006).
At
the
most
general
level,
environmental
discourse
may
be
defined
as
the
linguistic
devices
articulating
arguments
about
the
relationship
between
humans
and
their
environment
(Muhlhausler
and
Peace,
2006).
Studies
of
environmental
policy
discourse
offer
considerable
potential
for
insight
in
a
wide
range
of
areas
and
examples
in
recent
years
include:
Frantzi
(2008)
on
regional
environmental
planning;
Bogelund
(2007)
on
motor
vehicle
taxation
policy;
Davies
(2006)
on
anti- incineration
and
environmental
justice;
Penning-Rowsell
et
al
(2006)
on
UK
flood
defence
policy;
Laine
(2005)
on
corporate
disclosures;
and
Reber
and
Berger
(2005)
on
NGO
campaigning.
At
the
meta-level,
Mhlhasler
and
Peace
(2006)
characterise,
from
Hymes
(1972)
socio-linguistic
perspective,
the
many
analytic
approaches
to
environmental
discourse,
and
the
large
body
of
environmental
discourse
literature.
Here
we
are
investigating
the
specific
case
of
biofuel
policy,
particularly
the
diversity
of
opinion
that
we
show
lies
behind
a
universal
appeal
to
carbon
and
greenhouse
gas
(GHG)
emissions
reduction.
In
terms
of
the
analytics
of
environmental
discourse,
Hajer
(1995)
and
Dryzek
(1997,
2005)
have
been
particularly
influential
and
are
relevant
here.
Considering
contemporary
environment
policy,
there
is
almost
ubiquitous
evidence
of
Hajers
thesis
(ibid)
that
the
dominant
environmental
policy
discourse
of
the
day
is
"ecological
modernization",
i.e.
a
discourse
that
emphasises
the
opportunities
of
environmental
policy
for
economic
development
and
technological
innovation.
This
discourse
makes
a
normative
appeal
to
environmental
protection
but
is
also
highly
instrumental,
aligning
itself
with
national
economic
and
financial
objectives,
practices
and
institutions.
Dryzek
(1990,
1997)
defines
nine
discourses
in
environmental
debate,
which
we
later
relate
to
stakeholder
statements
on
biofuels.
These
discourses
are:
survivalism,
which
emphasises
the
need
to
limit
consumption
and
population
in
order
to
avoid
global
environmental
catastrophe;
Promethean,
which
is
technologically
optimistic
and
views
global
environmental
limits
as
non-existent;
administrative
rationalism,
which
emphasises
the
role
of
the
expert,
manager
and
regulator
as
a
solution
to
environmental
problems;
democratic
pragmatism,
emphasising
the
citizen
as
the
key
agent
of
a
response
to
environmental
problems;
economic
rationalism,
emphasising
the
use
of
economic
instruments
in
solving
environmental
problems;
sustainable
development,
emphasising
the
need
to
balance
society,
ecology
and
economy;
ecological
modernisation,
emphasising
efficiency
and
technology
in
a
liberal
economy;
green
romanticism,
emphasising
the
need
for
passionate
and
intuitive
humans
to
co-exist
and
co-operate
with
other
forms
of
nature;
green
rationalism,
which
differs
from
green
romanticism
in
its
conception
of
nature
as
a
complex
system
that
interacts
with
rationally
analyzable
human
social,
economic,
and
political
structures.
12
Analogous to discourses, or a component of them, are conceptual frames: these are interpretive structures through which individuals organize and make sense of an ambiguous stream of events and issues (Goffman, 1974, in Reber and Berger, 2005). Master frames (Snow and Benford, 1992, in Reber and Berger, 2005) perform similar functions but on a larger scale. The over-arching nature of master frames strongly influence how those actors who may challenge them must interpret and present their own causes (Mooney and Hunt, 1996, in Reber and Berger, 2005). In the UK at least, it increasingly appears that the need to respond to climate change and achieve carbon emissions reduction are becoming akin to a master frame or dominant discourse in environmental policy. This is not a claim that we can fully evidence here (though it is one that could be examined empirically). Below, we focus on UK biofuels policy as an example of this tendency, in particular showing where the appeal to emissions reduction risks being rhetorical. While climate change does indeed merit an urgent response, and the urgency is much greater than is generally realised (Anderson and Bows, 2008), it would be a dubious strategy to subordinate the need to critically examine and inform environmentally policy to that sense of urgency. This is particularly so in the case of biofuels, where carbon emissions can be very significantly exacerbated by land use change (DfT, 2008a), alongside other adverse social consequences (Renewable Fuels Agency, 2008). 3.2 CO-PRODUCTION OF REGULATORY POLICY A more general way of describing the role of stakeholders in policy development is via the concept of co- production. That scientific knowledge is deployed in the development and implementation of environmental regulation is widely understood. However the relationship between science and policy (not to mention politics) is not at all a linear one, with science simply informing policy (Lovbrand, 2007). Seeking to characterise the relationship of science to policy more fully, in particular the relationship of science to regulation, Jasanoff identified three types of scientific activity in the regulatory arena (Jasanoff, 1990). First are studies commissioned by regulatory agencies to provide additional, policy-relevant knowledge; second are synthesising and reviewing activities; and third are assessments or forecasts of environmental risk. In order to increase the policy utility of this type of knowledge-generation, there is a significant element of interaction between scientists or academics and those commissioning the work an iterative activity termed co-production in the field of science and technology studies. Within the sphere of environmental regulation and its co-productive relationship to science and science advisors, our focus here is on the development of a particular environmental and social performance standard, namely the RTFO. Jasanoff (1998: 108) characterises this generic standard-setting process as: a superficially bureaucratic but actually deeply value-laden process; a measure of high performance, in an environmental context, often intended to protect vulnerable populations or to ensure reasonable levels of safety, health, and environmental quality for those most at risk; a powerful averaging instrument that requires conformity from everyone it affects, potentially and often unintentionally defining the de facto upper bounds of performance as well as the lower bounds (Jasanoff 1998). As Jasanoff further points out, it is often impossible to demonstrate in real time whether an environmental standard is meeting its intended purpose, due perhaps to background noise and the practicalities of monitoring; a substantial temporal separation of cause and effect; or difficulties in isolating specific causes (ibid). Consequently, the credibility of environmental standards may depend more on the methods by which they were generated and enforced than on their empirical validation (ibid: 108).
13
Whereas design standards target the components of a technological system, performance standards are intended to regulate the quality of the output of that system: in other words, to specify how the system as a whole should perform (ibid: 109-110). Performance standards are preferred by industry for their relative flexibility because they leave to industrial managers the choice of how to achieve the desired level of performance and at what cost (ibid). However, Jasanoff observes that data gaps are often endemic in standards setting, and that as the limited available information tends to support differing perceptions of risk, and because environmental standards can have far-reaching economic and social consequences, the interpretation of standards-related data can become highly political (ibid: 112). Given these uncertain and politicised circumstances, scientist advisors and regulators involved in establishing standards must make a number of judgments, which can be categorised as follows: Boundary setting - where to draw the line between science and policy; Equivalence and simplification - a standard is a unit of comparison and norm against which every instance of the product, process, or system governed by the standard has to be measured. Adopting a standard assumes that equivalence has been established within the class of objects to which the standard applies (i.e. that they are commensurate; e.g. via common indicators); Embedded social judgments - standards that appear to relate only to nature and technology often also incorporate assumptions about society (e.g. that institutional capacity exists). Adequacy of evidence the judgement that the available knowledge, assumptions and analytic methods exist or may need revision (ibid: 117).
Jasanoff observes (1995: 282), for example, that several detailed studies of expert opinion in the area of carcinogen risk assessment have confirmed that scientific and policy judgments do indeed intermingle.
14
4.
RESULTS
In
section
4
we
summarise
our
observations
of
stakeholder
positions,
discourses
and
opinions
in
a
relatively
descriptive
way.
Further
inference
and
discussion
follows
in
section
5.
4.1
STAKEHOLDER
SUBMISSIONS
TO
RTFO
CONSULTATIONS
4.1
POSITION
DIFFERENCES
For
this
analysis,
discourse
and
opinion
is
sourced
from:
(i)
responses
to
the
UK
DfT
consultation
on
the
design
of
the
RTFO
(DfT,
2007a
and
2008c)
and
(ii)
responses
to
the
DfT
consultation
on
RTFO
carbon
and
sustainability
reporting
requirements
(DfT,
2007b
and
2008b).
Responses
to
the
latter
consultation
are,
in
some
cases,
available
as
discrete
documents
issued
by
stakeholders
and
referenced
in
the
tables
below.
In
the
subsequent
section,
only
responses
relating
directly
to
the
sustainability
of
biofuels
are
considered.
The
premises
of
the
consultation
on
the
design
of
the
RTFO
(DfT,
2007a)
were
narrow,
in
the
sense
that
the
questions
presumed
that
the
RTFO
would
proceed
in
one
form
or
another.
Four
of
the
25
questions
directly
related
to
environmental
or
social
impacts
and
are
listed
in
Box
1
below.
Box
1
Sustainability-related
questions
in
the
2007
consultation
on
the
design
of
the
UK
RTFO
(DfT,
2007a)
Q8:
In
advance
of
internationally
agreed
standards,
is
there
more
that
can
be
done
to
help
ensure
that
biofuels
are
sustainably
sourced,
for
example
through
voluntary
standards
or
agreements?
Q13:
Should
the
Government
specify
that,
from
a
given
date,
credits
under
the
RTFO
should
be
linked
to
the
GHG-saving
of
the
fuel?
If
so,
what
arrangements
should
operate
and
how
quickly
should
this
requirement
be
introduced?
Q14:
Should
the
Government
specify
that,
from
a
given
date,
only
those
biofuels
meeting
certain
minimum
environmental
and
social
standards
should
qualify
for
credits
under
the
RTFO?
If
so,
what
standards
should
be
applied,
and
from
what
date?
Q20:
Is
the
Government
right
to
insist
that
robust
carbon-saving
and
sustainability
criteria
are
built
into
future
EU-wide
biofuel
targets
and
support
mechanisms?
Q24:
Will
rewarding
different
biofuels
on
the
basis
of
their
relative
carbon
saving
performance
be
sufficient
to
bring
these
fuels
onto
the
market?
If
not,
in
what
other
ways
might
the
Government
support
the
development
and
use
of
advanced
renewable
transport
fuels?
A
selective
summary
of
stakeholder
responses
to
DfTs
generic
RTFO
consultation
(DfT,
2008b)
is
given
in
Table
1.
Responses
are
selected
where
they
provide
an
insight
into
alternative,
specific
views
of
biofuel/bioenergy
options,
such
as
in
terms
of
feedstocks,
technologies,
scale
of
supply,
government
support
and
trade-offs
between
different
types
and
class
of
impact
or
benefit.
Similarly,
responses
to
DfTs
consultation
on
carbon
and
sustainability
reporting
of
biofuels
(DfT,
2008c)
are
selectively
listed
in
Table
2.
DfT
received
54
stakeholder
responses
to
the
latter
consultation,
which
was
not
aimed
at
the
public.
15
Tables 3a-c selectively summarise the sustainability-related issues referred to in the position statements of the organisations for which positions are readily publicly available. The tables are split (a-c) simply and only to accommodate the large number of sub-issues. Again, selection is on the basis of comments with potentially significant implications for sustainability. Only explicit reference to issues has been noted. The epistemological basis of the method is interpretative, in the sense of focussing on stakeholders meanings (Williams, 2000), and the column headings in Tables 3(a-c) are intended to be self-explanatory in their reference to those meanings. Tables 3a-c indicate the variety of opinion on biofuel policy as regards environmental and social sustainability. Most concerns are shared by few organisations, though concern over food prices, land theft and working conditions do stand out as relatively widely shared. The first point to note is that as all of the stakeholder responses express support for GHG and sustainability reporting by biofuel suppliers, support for reporting per se is clearly not useful for distinguishing positions. Similarly, the objective of carbon/GHG emissions reduction is appealed to in all of the responses. Table 4 provides a count of the number of times carbon/GHG emissions reduction is referred to in the response document of each stakeholder, summarily indicating that all of the responses refer to carbon/GHG emissions reduction as a key objective of biofuel policy. Given this, a deeper consideration of stakeholder views (i.e. as evidenced in the above tables) is necessary for an understanding of stakeholder differences. Given that GHG emissions reduction is taken for granted by stakeholders as an over-arching or framing discourse, what is much more revealing, in terms of categorising and understanding the differing priorities of stakeholders, are stakeholder comments relating to the stringency and timing of the introduction of reporting conditions, particularly the ability of suppliers to report unknown regarding land use change, as well as the other concerns and issues that they raise. Avoiding land use change (unless such change is remediatory via the use of degraded land, for which suppliers may receive specific credit under EC proposals (European Parliament, 2008)) is critical to realising the potential of bioenergy for emissions reduction. As such, a commitment to immediate and full reporting in terms of RTFO reporting categories can be taken as one test of whether an organisation is committed to an environmentally benign biofuels policy, in the sense of a willingness to forego some of the immediate economic benefits of biofuel development. In terms of concerns reported to and by DfT (2008c) on carbon and sustainability reporting under the RTFO, Table 2 shows that many are barely commensurate with early enforcement of mandatory reporting (note also that reporting is itself relatively weak as an environmental protection measure: reporting a potentially damaging activity is not preventative). For example, concerns reported by stakeholders to DfT included: that the imposition of reporting standards will favour one agricultural sector over another, that the UK should wait for EU standards, that the minimum GHG saving should be reduced to as low as 10% relative to fossil petroleum and that RTFO certificates should be awarded not simply on the basis of supplying certified biofuel, but also on a grandfathered basis (i.e. to existing firms partly in proportion to existing levels of supply). In addition, Table 2 also shows a split among respondents as to whether the RTFO approach to assessing land use change is appropriate, with many considering the proposed reporting requirements adequate.
16
Table
1
Selected
sustainability-related
responses
to
the
DfT
RTFO
order
consultation
(2008b)
Themes
and
Issues
in
Responses
(selected
from
DfT,
2008b)
Displacement
effects
(sustainable
sourcing)
Sustainability
What
standards
required?
sustainability
standards?
GHG
performance
Adverse
effects
Should
on
other
sectors
advanced
biofuel
technologies
receive
additional
Government
support?
-
Respondents
divided
and
uncertain
-
Sustainability
should
be
rewarded,
not
just
carbon
savings
-
Reward
high
performing
biofuels
whether
first
or
second
generation
- Concerns over - Mandatory their magnitude - Voluntary and reporting - Delay for 3-5 years - Use grandfathering of RTFO certificates to protect incumbents from consequences of standards
- Standards risk - Link to RTFO - One third of market distortion credits respondents uncertain and - Could act as an - Link to RTFO others divided illegal trade credits later barrier - Concern re - 30% saving effects on food - European minimum prices and standards first shortages, - 10% saving agricultural - Standards will acceptable diversity not be sufficiently stringent. - First need to agree: criteria for environmental performance; crop neutral targets to avoid WTO challenge; standards for palm oil agreed by the Roundtable for Sustainable Palm Oil
17
Table
2
Selective
summary
of
responses
to
the
DfT
(2008c)
consultation
on
RTFO
carbon
and
sustainability
reporting
requirements
Themes
and
Issues
in
Responses
(selected
from
DfT,
2008c)
Scope
of
RTFO
Are
the
RTFO
Are
the
sustainability
reporting
environmental
and
social
reduction
adequate?
principles
appropriate?
adequate?
-
Mostly
yes
-
Mostly
yes
RTFO
GHG
Is
the
RTFO
approach
to
targets
assessing
the
impact
of
land
1
use
change
appropriate?
- Large majority of - Respondents divided respondents think the GHG Of no: Of no: reduction targets are too - Stronger incentives to report on and avoid the GHG stringent - reporting unknown - displacement effects impacts of land use change should be and land use change - GHG targets can only be disallowed/phased out insufficiently met if co-products burned - No biofuel causing land use & default values change should be eligible for - Adverse land use change covered RTFO certificate recalculated (LUC) not discouraged - Add food security - GHG targets do not -Ex-post facto evaluation sufficiently take into of indirect LUC not - Add retention of important aspects of the account the impact of LUC sufficient local landscape - Food security should be reported on Note: the RTFO sets out default values for tonnes of CO2e emissions per hectare, assumed to arise from changing existing land types to biofuel cultivation. The values are to be reported as grams CO2e per MJ of biofuel, and are also to be taken account of in the reported carbon intensity of the biofuel, together with identification of the level of accuracy relating to the land use change, in terms of a fixed scale (DfT, 2007b: Annex G).
18
integrated into current farming wetlands, practices, grasslands, that do not GHG emissions, displace or biodiversity, compete soils, water, with food food crops security & human rights
African NGOs
Biofuelwatch
19
Greenpeace UK
Natural England
Oxfam
Total
Note: sources are all 2007 and are listed in the References by name of organisation.
20
General
21
Motors
Greenergy
Greenpeace UK LowCVP
NFU
Oxfam
Total
Note: sources are all 2007 and are listed in the References by name of organisation.
22
Natural England
NFU
Total
Note: sources are all 2007 and are listed in the References by name of organisation.
23
National Forum on Biomethane as a Road Transport 9 Fuel Natural England NFU Oxfam Renewable Energy Association 5 3 4 18
Five BarGate Consultants FoE England & Wales FoE Scotland Food and Drink Federation General Motors
1 30 2 2 4
4.2
DISCURSIVE
DIFFERENCES
Having
illustrated
the
highly
divergent
nature
of
opinion
on
UK
biofuels
policy
despite
a
ubiquitous
appeal
to
emissions
reduction,
this
section
considers
the
relationships
between
stakeholder
policy
positions
and
the
discourses
with
which
these
are
expressed.
These
reveal
differing
priorities,
as
one
would
expect.
In
Hajers
terms,
one
might
say
that
the
discourse
coalition
(Hajer,
1995)
around
carbon
emissions
reduction
is
only
surface
deep,
beneath
which
a
correspondence
to
some
of
Dryzeks
(1990
and
1997)
differentiated
environmental
discourses
is
evident.
Below,
a
variety
of
discourse
themes
are
identified
and
commented
on.
This
is
not
a
comprehensive
discussion,
but
an
illustration
of
some
of
the
discourses
evident
in
the
17
stakeholder
position
statements
on
the
RTFO.
Biofuelwatch,
a
campaigning
NGO
dedicated
to
opposing
the
biofuels
trade,
perceive
their
role
as
in
part
one
of
representing
the
views
of
those
potentially
adversely
affected
by
UK
biofuels
policy
in
the
near-term.
The
NGOs
tone
is
one
of
moral
indignation,
as
they
seek
to
defend
those
affected
and
highlight
the
environmental
risks
involved.
In
Dryzeks
terms
(ibid),
there
is
an
element
of
green
rationalism,
in
which
humans
with
a
range
of
motivations
are
conceived
of
as
dependent
on
nature
though
this
relationship
is
not
romanticised
(as
in
Dryzeks
green
romanticism,
ibid).
However,
24
stronger than this is the theme of eco-socialism (e.g. Pepper, 1993), evident in the concern for less advantaged peoples. Eco-socialism may be defined as the idea and belief that globalising, capitalist forces are responsible for environmental damage and social inequities, both within and between nations. Marxist concepts may be used to support eco-socialist reasoning, such as critiques of exchange value as the basis of the market economy (i.e. the proposition that goods are produced not only for their use value, but also for their exchange value, so leading to excess consumption and increasing commodification (marketisation) of society and nature) (Pepper, ibid). Thus Biofuelwatch state of the 2007-8 RTFO consultations: As usual conspicuous by their absence were the groups who represent the billions of citizens in the majority world where most biofuels will be produced and who will be adversely affected by your ill-advised policy: the landless movement in Brazil, the subsistence farmers in Indonesia, the indigenous people of Borneo, India & West Papua, the afro-Colombians of Colombia, poor farmers in Paraguay and Argentina. It is censorship by omission. (Lander, 2007). Greenergy, at the time of writing the major supplier of biofuel in the UK, take a highly pragmatic tone that corresponds most closely to a blend of Dryzeks ecological modernisation and administrative rationalism, the latter assuming that environmental problems can and will be solved by competent states (Dryzek, 1990, 1997). Specifically, not only do Greenergy view indirect land use change as someone elses problem and responsibility, namely national government, but they also implicitly assume that the problem can be managed: There needs to be a clear distinction between those effects which are the responsibility either of individual companies or the supply chains of individual sectors (e.g. biofuels) and those which are the responsibility of national Governments. Greenergy (2007) In contrast, the NGO positions express scepticism that these impacts can be managed through policy measures. For them, indirect impacts are a potential show-stopper for much of the international trade in biofuel feedstocks. Thus Friends of the Earth (FoE England and Wales, 2007) consider that minimising these impacts may require a policy of sourcing only relatively local feedstocks, for which administrative control could be relied upon. In this regard they doubt the premises of both ecological modernisation and administrative rationalism, with their technological and managerial optimism. Of course the RTFO carbon and sustainability reporting framework is by its nature an administrative and managerial response to a range of biofuels-related impacts. Emphasising this, Greenergy is keen to encourage a discourse of politically neutral carbon and sustainability reporting, despite the framework being explicitly underpinned by environmental and social norms that are themselves intrinsically political: The assessment of carbon savings within the RTFO needs to be based on a review of scientific evidence and not on a methodology or selected data that has been influenced by political considerations. (Greenergy, 2007).
25
Position
statements
on
the
RTFO
were
not
generally
available
for
the
oil
majors.
An
exception
was
BP,
which,
with
an
express
technological
optimism,
can
also
be
considered
aligned
with
an
ecological
modernist
position.
In
June
2007,
BP
plc
and
D1
Oils
plc
announced
that
they
would
form
a
50/50
joint
venture
(from
which
BP
later
disinvested),
to
be
called
D1-BP
Fuel
Crops
Limited,
to
accelerate
the
planting
of
Jatropha
curcas.
Jatropha
is
an
oil-
yielding
bush
that
can
be
grown
on
poor
soils
without
on-going
irrigation,
though
(anecdotally)
yield
is
much
improved
by
irrigation
under
water- poor
conditions,
making
it
a
potential
competitor
with
food
crops
for
water
in
dry
locations.
Under
the
terms
of
their
joint
venture
agreement,
BP
and
D1
Oils
stated
an
intention
to
invest
around
$160
million
over
five
years.
In
return
for
investment
capital,
D1
Oils
plc
would
contribute
(as
of
June
2007)
their
172,000
hectares
of
existing
plantations
in
India,
Southern
Africa
and
South
East
Asia
and
the
joint
venture
would
have
exclusive
access
to
the
Jatropha
seedlings
produced
through
D1
Oils
plant
science
programme
(BP,
2007).
D1
Oils
plant
science
is
the
exclusive
supplier
to
D1-BP
Fuel
Crops,
on
a
cost-plus
basis,
of
selected,
high-yielding
jatropha
seedlings.
BP
and
D1
emphasise
the
scientific,
particularly
plant-breeding
and
agronomic,
innovations
that
play
a
significant
role
in
their
biofuels
development
plans:
We
are
pioneering
the
science
and
planting
of
energy
crops
that
produce
inedible
vegetable
oils
to
make
biodiesel.
(D1
Oils,
2007)
The
BP/D1
response
is
supportive
of
the
RTFO
carbon
and
sustainability
reporting
framework
but
this
support
is
expressed
in
terms
conveying
an
implied
criticism
of
its
currently
limited
relationship
to
sustainability:
We
support
the
development
over
time
of
reporting
systems
that
deliver
genuine
carbon
savings
and
ensure
real
sustainability.
(D1
Oils,
2007).
A
further
feature
of
the
NGO
positions
is
their
wider
environmental
frame
of
reference,
which
hints
at
Dryzeks
(1990,
1997)
green
rationalism.
The
NGOs
are
more
concerned
with
the
wider
context
of
biofuel
development
than
with
the
commercial
opportunities
that
biofuels
afford.
Thus
Friends
of
the
Earth
emphasises
transport
demand
management
and
reduction
and
also
the
limited
efficacy
of
policy
incentives
for
the
use
of
biomass
for
heat
and
power:
Friends
of
the
Earth
is
deeply
concerned
that
the
UK
Government
is
failing
to
address
the
priority
issues
for
bringing
down
transport
emissionsThe
Government
has
also
failed
to
develop
the
sustainable
use
of
biomass
for
heat
and
electricity
generation
when
there
are
clearly
much
higher
emissions
savings
to
be
made
by
using
first
generation
biomass
in
this
way.
(FoE
England
and
Wales,
2007).
Few
vehicle
manufacturer
positions
were
publicly
available,
but
General
Motors
is
notable
for
its
expression
of
a
relatively
Promethean
(Dryzek,
1990,
1997)
sub-text
in
its
approach
to
biofuels
and
the
RTFO
carbon
and
sustainability
framework,
in
the
sense
of
a
bullish
confidence
in
the
ability
of
technology
and
the
market:
GM
is
concerned
that
the
need
for
a
carbon
accreditation
scheme
should
not
become
an
obstacle
to
further
progress
in
promoting
the
production
and
use
of
biofuels
in
the
UK,
the
26
encouragement
of
cars
equipped
to
run
on
high-blend
biofuels,
or
the
development
of
associated
refuelling
infrastructure.
Instead,
work
on
carbon
accreditation
should
continue
to
run
parallel
to
efforts
to
promote
the
take-up
of
biofuels.
(General
Motors,
2007).
The
National
Farmers
Union
(NFU)
also
expresses
confidence
in
market
dynamics,
using
an
economic
discourse
and
rationale
to
express
this:
The
NFU
believe
that
the
RTFO
will
not
have
any
major
adverse
impacts
on
other
sectors
in
the
medium
to
long
term.
As
commodity
prices
rise,
so
farmers
will
be
encouraged
to
plant
more
of
those
crops,
with
the
market
effectively
self-regulating
itself
to
a
large
degree.
There
is
a
significant
amount
of
under-utilised
agricultural
land
on
which
expansion
could
take
place
before
other
crops
or
activities
are
displaced.
(NFU,
2007).
The
Environment
Agency
argue
a
contrary
viewpoint,
namely
for
the
limited
land
available
in
the
UK
to
be
used
for
perennial
energy
crops
for
heat
and
power
rather
than
annual
crops
for
biofuels.
Interestingly,
this
argument
is
also
couched
in
economic
terms
(cost-effectiveness)
but
with
environment
as
an
integrated
factor:
the
estimate
for
the
cost
of
reducing
CO2
from
transport
fuels
such
as
biodiesel
is
137/tCO2
and
152/tCO2
from
bioethanol
(wheat).
On
the
other
hand,
using
biomass
for
heat
in
a
large
industrial
boiler
would
cost
76/tCO2,
and
for
a
small
commercial
boiler
78/tCO2
(Environment
Agency,
2007).
The
Environment
Agency
view
might
be
positioned
somewhere
between
green
rationalism
and
ecological
modernist:
in
practice
these
can
be
difficult
to
distinguish
in
terms
of
an
organisational
position,
given
that
their
key
differences
are
perhaps
less
in
terms
of
policy
and
more
in
terms
of
worldview,
philosophy
or
ideology.
In
short,
not
only
do
stakeholders
take
very
different
positions
on
UK
biofuel
policy,
but
the
language
and
tone
of
the
position
statements
echo
some
of
the
archetypal
environmental
discourses
that
others
have
previously
identified.
While
this
is
not
unexpected,
the
variety
is
notable
given
the
ubiquitous
appeal
to
the
objective
of
GHG
reductions
and
also
confirms
that
biofuel
policy
is
no
exception
in
terms
of
environmental
policy
contentions.
4.3
STAKEHOLDER
RESPONSES
TO
BIOFUEL
POLICY
INTERVIEW
QUESTIONS
Table
5
below
summarises
interviewee
Lickert
scale
responses,
which
required
the
respondent
to
express
a
degree
of
agreement,
disagreement
or
neutrality
with
statements
reflecting
key
issues
identified
in
the
preceding
work
(not
all
respondents
gave
numerical
answers
to
the
questions).
Questions
were
posed
on:
the
merits
of
biofuels
for
climate
change
mitigation
and
energy
security;
risks
in
terms
of
emissions
from
land
use
change
and
food
poverty;
who
the
rural
beneficiaries
are
expected
to
be;
degree
of
confidence
in
the
RTFO
carbon
and
sustainability
method;
whether
transport
demand
should
be
reduced
in
preference
to
an
expansion
of
biofuel
production;
whether
land
should
be
prioritised
for
bioenergy
crops
for
power
and
heat
rather
than
for
transport
fuel
(see
27
appendix
A
for
the
full
interview
questionnaire).
Respondents
were
also
asked
for
their
more
detailed
views
on
the
RTFO
carbon
and
sustainability
reporting
method
and
the
process
by
which
this
was
developed.
A
total
of
11
stakeholders
were
interviewed,
either
by
telephone
or
face-to- face,
during
November
and
December
2009.
Selection
was
partly
pragmatic,
i.e.
influenced
by
the
nature
of
those
who
responded,
but
primarily
targeted
at
critical
and
independent
commentators.
Overall,
respondents
in
NGOs
with
an
environmental
or
social
mission
tended
to
agree
in
their
responses
and
to
differ
in
their
opinions
from
the
other
respondents,
who
were
a
fuel
supplier,
bioenergy
standards
expert,
academic
expert,
renewable
energy
consultancy
and
UK
regulator.
However,
there
was
more
variation
in
the
opinion
of
these
latter
individuals
than
among
the
NGOs,
while
the
opinions
of
the
regulator
tended
to
be
in
between
the
two
groups.
Respondents
were
in
disagreement
about
whether
a
large-scale,
international
trade
in
bioenergy
was
essential
for
tackling
climate
change.
Some
strongly
agreed
with
the
statement,
arguing
that
this
proposition
was
self
evident
(Dutch
academic)
and
that
biofuels
represented
the
only
technology
we
have
today
for
decarbonising
our
transport
fuel
(fuel
supplier).
However,
other
respondents
were
less
certain
about
the
potential
GHG
benefits
of
bioenergy,
arguing
that
while
trade
could
have
a
positive
impact
on
both
producer
and
consumer
countries,
this
was
contingent
on
factors
such
as
indirect
land
use
change
(ILUC)
being
addressed
(WWF).
Several
interviewees
argued
that
more
research
into
the
carbon
implications
of
biofuels
was
required
and
that
while
likely
to
play
a
role
in
mitigating
climate
change
bioenergy
was
by
no
means
essential
(Practical
Action).
This
sentiment
was
echoed
by
RSPB
who
thought
that
while
bioenergy
would
have
to
make
a
contribution
to
delivering
the
UKs
renewable
energy
targets,
that
it
would
necessarily
be
good
for
the
climate.
RSPB
strongly
disagreed
with
the
statement
and
favoured
an
approach
that
prioritised
the
domestic
sourcing
of
bioenergy
feedstocks.
Opinion
was
again
divided
on
whether
bioenergy
was
essential
for
UK
energy
security.
The
majority
of
the
environmental
NGOs
strongly
disagreed
with
this
statement,
arguing
that
a
large-scale
international
trade
in
bioenergy
would
make
us
dependent
on
non-fossil
energy
from
countries
that
are
not
necessarily
politically
stable
(Friends
of
the
Earth).
RSPB
argued
that
much
more
research
and
further
analysis
was
required
into
the
contribution
that
bioenergy
could
make
towards
the
UK
renewable
energy
targets.
WWF
was
undecided,
opining
that
biofuels
mandates
were
not
about
energy
security
because
if
people
didnt
use
their
cars
we
wouldnt
need
10%
biofuels;
WWF
was
also
sceptical
about
the
contribution
that
bioenergy
could
make
to
energy
security
asking
if
bioenergy
supply
was
zero,
would
it
entail
significant
disruption?.
The
regulator
also
strongly
disagreed
arguing
that
while
the
sustainability
issues
remained
to
be
resolved,
the
focus
should
be
on
waste-derived
fuels:
If
energy
or
biomass
energy
was
the
way
forward
other
companies
would
have
jumped
on
the
bandwagon,
but
theyre
not
doing
that.
The
opposite
view
was
held
by
the
renewable
energy
consultant
who
held
that
UK
resources
arent
sufficient
to
provide
all
our
future
energy
needs,
hence
the
UK
will
be
dependent
on
fuel
imports
and
the
Dutch
academic
agreed,
stating
he
thought
this
statement
was
self-evident.
28
The NGOs were strongly concerned about the risk of an increase in GHG emissions via land use change. Only the fuel supplier and Dutch academic disagreed; the former strongly disagreeing that this was a risk, providing that RED-type conditions, such as avoiding peat lands, were adhered to. The Dutch academics position was more qualified: major preconditions have to be fulfilled to achieve strong GHG emissions reductions. The Dutch standards expert also saw this as a risk, saying that this issue needs to be dealt with very thoroughly and very conservatively. Other respondents agreed that controls were critical but expressed reservations that they would be possible: It depends how its [sustainability certification] done. It needs viable sustainability criteria and tools to enable proper carbon accounting and control over the worst kinds of conversion (Practical Action) This was echoed by the renewable energy consultant who argued that certification schemes need financial incentives that protect sensitive areas and that these incentives should outweigh the benefits of land conversion for biomass. The NGOs saw the potential for GHG emissions from land conversion as a major risk; for example, for RSPB: Bioenergy must be delivered in a way that helps to tackle climate change. One of the big problems with policy making in the area is the assumption that bioenergy will be good for the climate. It isnt a given that bioenergy is going to be good for the climate full stop. All of the NGOs were concerned that a large-scale international trade in bioenergy posed substantial risk in terms of food poverty. FoE argued that they could not see how the system could be managed in a way that avoided impacts on food poverty nor had they seen any proposals for such management. Practical Action argued that while there was a substantial risk, international agreements and policy should be able to manage and mitigate this risk; they also stressed that the potential for livelihood opportunities for people working in bioenergy should not be overlooked. WWF argued there was no question that bioenergy production had an impact on food poverty but thought that the real question was the extent to which it contributed and the issue was rather one of distribution. Of those who thought trade did not pose a risk to food poverty, the fuel supplier highlighted the potential for increased yields of foodstuffs, while the standards expert argued that: History has taught us that the food market is completely independent of the biofuels market. Food shortages in those countries in developing countries are not directly related to biofuels; there is a small risk but it is only small risk. It is the perception of traders that has a relationship to prices, so it has a small impact. The renewable energy consultant was undecided but thought that there neednt be an adverse effect, highlighting the availability of land unsuitable for food production, as well as residues from crops, waste products and food waste. The opportunities for waste-derived fuels were also stressed by the regulator.
29
All interviewees agreed or were undecided about whether large-scale, international trade would primarily benefit well capitalised land-owners. Of those who were neutral or undecided, the Dutch academic argued that who benefitted from international trade would be conditional on how biofuel production was organised: National policy frameworks are key governments control access to the land if it is a fully liberalised situation, then biofuels will be in competition with small-holders. On the other hand, if governments prioritise good investment and good governance, land zoning, then build capacity and infrastructure development, then small farmers will be the main beneficiaries. Of those who agreed or strongly agreed, the capacity for well-capitalised land owners (and corporations) to capitalise on these new markets was emphasised: [well-capitalised land owners] are better placed to scale up, probably already have land tenure, able to invest in mechanisation and the low cost, intensive agriculture thats probably going to give the lowest cost output for international trade (Practical Action). Biofuelwatch was highly critical of current government policy, which it was argued promoted large- scale production and therefore would largely benefit corporations including agribusiness, oil and energy companies. WWF also highlighted the lack of evidence that increasing commodity prices trickle down to smaller producers. There remained a high level of concern among the NGOs questioned, regarding the direction of UK biofuel policy and its tools. Perhaps most importantly, no respondent strongly agreed that they had a high degree of confidence in the RTFO carbon and sustainability reporting method as a model for managing bioenergy feedstock impacts. Even the fuel supplier considered it only a limited step forward from which progress could be made in future. Nonetheless, both the fuel supplier and the Dutch academic agreed that it was better to make a start on biofuel incentivisation than to wait until better management tools were in place. The UK regulator thought the RTFO represented a ground breaking methodology and was better than nothing, but argued that the obligation was dependent on industry playing game. RSPB was sceptical about the motivations behind the RTFO: I think because the RTFO and the RFA were brought in to deliver a target at all costs... The carbon and sustainability reporting methodology was brought in under quite a lot of pressure and quite a lot of lobbying [and] its a way of getting the better stuff [onto market], even though for biofuels theyve not made it mandatory, which makes it a bit meaningless... But the problem was that the principles arrived at in the beginning and the overall implementation of those principles has been flawed. GRR thought certification schemes were fundamentally flawed as they failed to take into account the institutional contexts within which they would be implemented, arguing: you cannot translate these systems into the South.
30
Most of the respondents indicated that they did consider reducing energy demand in developed countries to be as high, or a higher priority, than further developing an international bioenergy market. FoE strongly agreed arguing that the use of bioenergy to produce heat and power remained the most effective use of bioenergy feedstocks and that effort in the transport sector should focus on reducing demand and improving vehicle efficiency. For WWF questions about the potential emissions from some bioenergy pathways meant that reducing energy demand was the no risk solution. Support for demand reduction was also given by the renewable energy consultant who argued that we wont learn anything if we still leave the lights on, just because its green electricity doesnt mean its ok. The fuel supplier and Dutch academic took the view that bioenergy remains a necessity; the supplier on the grounds that denying developing countries the opportunity to benefit from bioenergy trade was unfair, while the Dutch academic argued that everything is a priority in the challenge to address climate change. The fuel supplier and Dutch academic were also relatively isolated in their view that land use for feedstocks for liquid transport fuel should be prioritised over land use for energy crops for heat and power. Both argued that limited options for decarbonising the transport sector, with oil the critical fossil fuel, meant that biomass for transport should be prioritised. The fuel supplier further argued that food crops should have priority over energy crops, and that this could be achieved by using the pricing mechanism to ensure that transport could never be able to out-compete food. The renewable energy consultant took a more pragmatic view, arguing that which sectors bioenergy was allocated to would ultimately depend on priorities: It will depend on who wants what and who will pay for what. Greater emission savings can be made with using biomass for heat, but we can get super efficient fuel boilers and insulate; we have few options for reducing emissions from transport. Those who thought biomass should be allocated primarily to heat and power argued that efforts should focus on the most efficient uses of land and on those feedstocks which had the highest GHG emissions reductions. The contribution that waste-derived fuels could contribute was emphasised by the UK regulator and the renewable energy consultant. Only the fuel supplier highly rated the effectiveness of the RTRS, RSPO and FSC standards for environmental and social protection (these being key standards within the RTFO meta-certification system). The FSC was seen as the best of the three, with WWF being the most approving of the NGOs. The NGOs and the Dutch academic emphasised the limitations of voluntary, as opposed to mandatory, certifications systems and also the problems associated with limited institutional capacity and instances of fraud in producer countries. Many of the NGOs were generally highly sceptical about the efficacy of certification schemes, emphasising their failure to stop deforestation and land use change in producer countries and their inability to take into account many of the more complex social issues.
31
Fundamental problems are that theyre about products made in countries where corruption, poor governance and a total lack of accountability and disregard for habitats and forests is the norm or certainly endemic (RSPB). The legitimacy of these certification schemes was questioned by the NGOs, who argued that their currency was very low amongst NGO circles as they had been unable to acquire the legitimacy it needed from enough stakeholders to be representative and effective. GRR was also sceptical about the motivations of those involved in certification schemes, and dismissed such schemes as greenwash: In the North such schemes are about consumer perceptions, its not about genuine environmental concerns for the South. The priority is to sell the commodity and avoid criticism: if a problem exists they can say but weve got certification so in a way its set up to ease consumer consciences. Regarding sustainability reporting under the RED, the NGOs (with the exception of WWF) generally considered the 2008 baseline to be problematic, arguing for example that every time a new standard is created they shift the baseline a bit later, which makes them meaningless (RSPB). However, the other respondents generally accepted the regulatory convention of not using a retrospective baseline. No respondent thought that biomass sustainability reporting under the RED would adequately indicate ILUC, there currently being no provisions for this. The need to develop a system to monitor ILUC was discussed by some respondents youve got to have something, you cant just pretend its not happening (UK regulator) although there was no agreement about how or indeed whether this could be achieved. Respondents were also asked to consider the ways in which their opinions of biofuels and/ or bioenergy had changed over the past couple of years. Only the fuel supplier felt more positive about the industry: I guess my view has been reinforced that we need to do it and that we need to do it properly [national] governments and not just Europe need to put in place the right rules so that we do it in the right way. Many of the NGOs expressed feeling greater concern about the way the bioenergy sector was developing; for many, the issue of ILUC had highlighted the potential dangers associated with increased use of biofuels/ bioenergy: Its no longer just a case of good and bad biofuels... even with certified biofuel this inevitably fuels an expansion of agriculture worldwide, which will impact on forests and habitats (FoE). This was echoed by RSPB who had become more cynical over the last couple of years, particularly with regards to the capacity to develop and implement a more sustainable bioenergy market:
32
The more Ive learnt about where [bioenergy] will come from, the various drivers and the scary assertions from industry, my awareness of the risks from biomass has increased, and the reality of commitment from policymakers and industry to really create a sustainable industry. The opinions of GRR had also not changed, although they felt heartened by increasing public awareness of the biofuels/ bioenergy debate. The change in the tone of the biofuels debate over the past couple of years was also mentioned by Practical Action, who argued that debate was still failing to recognise the potential contribution that bioenergy could make to livelihoods and energy access in the global South: Bioenergy is not just international markets and large-scale biofuels, its starting from the fact that 2.4 billion people use bioenergy every day, so from that perspective I think the opportunities and the threats are the same. We need to move beyond thinking only about large-scale trade in biofuels and recognise the contribution of bioenergy to energy access. Fewer respondents felt able to answer questions on the RTFO carbon and sustainability reporting method, which reflected the fact that few of those we spoke to had been involved in developing the method. Only the fuel supplier thought the RTFO adequately accounted for the breadth of scientific knowledge on biofuels. Of those who thought it did not, criticisms were that the method was too simplistic (Dutch academic) and that it failed to account for ILUC (FoE and Biofuelwatch). RSPB also criticised the whole meta-standard approach, arguing that while the RTFO had started with a true definition of sustainability the overall principles of which all stakeholders had agreed on that there was nothing on the market that met this agreed definition of sustainability and as a consequence: They [the RFA] realised that nothing fitted the meta-standards, so they cobbled together some poor excuse of something that approaches [it] but isnt. Similar opinions were expressed about the sustainability criteria of the RED, although the failure to include social standards in particular was criticised by some respondents. RSPB was again highly critical of the RED, which they maintained was the outcome of political comprise, an accusation also made by WWF. When asked about the guidance given by DfT on the scope and content of the RTFO, the fuel supplier was highly supportive of the process. He argued that: The way in which the RTFO was developed it took two years of government involvement with stakeholders to get it right they did an excellent job of consulting to get appropriate regulations. However, other NGOs criticised the ways in which consultation had happened, arguing all they knew about was what was in the public consultation (Biofuelwatch).
33
When asked how differences of opinion were handled, the disagreement over whether to mandate sustainability reporting was mentioned by all those who responded to this question. For the fuel supplier, mandatory reporting would have presented difficulties to suppliers due to the availability (and lack) of data, and he argued that with mandatory reporting very little biofuel would be on the market and that this was one issue where pragmatism won through. By contrast, some of the NGOs argued that the failure of Government to take a precautionary approach and mandate sustainability reporting demonstrated that the only criticisms that the RFA only listened to were those of industry. Respondents were again divided over the issue of rewarding GHG credits for co-products. The supplier thought the issue irrelevant as there is currently no value in knowing the GHG value of a biofuel in the current RTFO. He argued that as it currently stands, there is no obligation to meet certain GHG requirements only to report and the way co-products are managed is critical to reporting. The Dutch academic thought that co-products should be fully incorporated, but when prompted acknowledged that substitution would not be guaranteed in the short term. The NGOs were more critical about the issue of co-products, which they thought was being pushed by industry, and called for more research and independent scrutiny of the issues.
34
Organisation
WWF RSPB Friends of the Earth Biofuelwatch Practical Action Grupo de Reflexion Rural UK regulator Fuel supplier Renewable energy consultant Dutch academic Dutch standards expert
2 5 5 5 3 5 4 1 2 1 1
U 5 5 5 4 5 5 3 1 1 U
3 1 1 1 3 1 1 5 2 4 2
4 5 5 5 5 5 5 2 3 2 1
2 1 1 1 2 1 2 3 U 3 2
1 1 2 2 3 2 U 5 U 5 2
Strongly agree = 1, agree = 2, neither agree nor disagree = 3, disagree = 4, strongly disagree = 5. U = unsure/ dont know
35
5.
THE
PROSPECTS
FOR
WIDER
CO-PRODUCTION
OF
BIOFUEL
POLICY
5.1
INTRODUCTION
This
section
draws
on
the
preceding
theoretical
themes
and
findings
in
more
detail,
to
discuss
the
prospects
for
wider
co-production
of
UK
(and
EC)
biofuels
and
bioenergy
policy.
Although
somewhat
late
for
the
RTFO,
wider
co-production
is
still
relevant
to
the
RED
and
is
also
relevant
to
possible
future
bilateral
agreements
between
feedstock
producers
and
commercial
distributors
of
biofuel.
As
ever,
the
past
holds
lessons
for
the
future.
5.2
POST-NORMAL
SCIENCE
AND
BIOFUEL
POLICY
Where
environmental
and
social
sustainability
is
a
core
objective,
thinking
on
post-normal
science
provides
a
rationale
for
stakeholder
inclusivity
in
policy
development.
This
rationale
has
been
well
rehearsed
(e.g.
Frame
and
Brown,
2008).
Frame
and
Brown
(ibid)
describe
how
the
post-normal
science
concept
was
originally
developed
by
Jerry
Ravetz
and
Silvio
Funtowicz
in
the
mid-1980s
to
mid-1990s
(e.g.
Ravetz,
1987;
Funtowicz
and
Ravetz,
1990;
Funtowicz
and
Ravetz,
1993;
Funtowicz
and
Ravetz,
1994)
and
subsequently
by
other
authors.
The
main
arguments
supportive
of
post-normal
science,
as
reviewed
by
Frame
and
Brown
(ibid)
are,
firstly,
that
it
is
legitimate
to
view
the
world
in
more
than
one
way;
i.e.
that
there
is
an
irreducible
plurality
of
perspectives
and
modes
of
understanding
(Frame
and
Brown,
2008).
This
echoes
arguments
from
science
and
technology
studies
regarding
the
value
of
local
knowledge
and
the
contingency
of
scientific
knowledge
(e.g.
Wynne,
1996).
Accepting
this
plurality
does
not
imply
that
all
involved
need
to
subscribe
to
others
beliefs
or
ways
of
knowing,
but
it
does
imply
the
need
to
accept
that
alternative
views
need
to
be
acknowledged
and
taken
into
account.
One
of
the
questions
that
this
premise
begs,
of
course,
is:
to
what
extent
should
such
views
be
taken
into
account?
The
position
taken
here
is
(a)
ontologically
and
epistemologically
critical
realist
and
(b)
politically
and
epistemologically
inclusive.
That
is,
with
respect
to
(a)
we
assume
that
objective
actualities
exist,
but
that
these
may
be
perceived
empirically
very
differently
by
different
people
(e.g.
Bhaskar,
1975;
Archer
et
al.,
1998);
with
respect
to
(b)
we
assume
that
there
are
advantages
in
political
and
policy
terms
to
those
in
positions
of
power
over
policymaking
taking
substantive
differences
of
opinion
seriously.
Ultimately
there
may
be
areas
of
irreconcilability,
and
decisions
may
need
to
be
made
that
exclude
some
options,
but
doing
so
without
a
proper
dialogue
as
part
of
the
normal
policy
process
(one
might
justify
narrow
command
and
control
structures
in
extreme
or
particular
situations,
or
where
decisions
must
be
made
very
quickly)
-
is
unlikely
to
lead
to
good
decision-taking.
Indeed
the
latter
is
the
second
main
argument
referred
to
by
advocates
of
the
post-normal
science
concept:
namely
that
epistemological
inclusivity
is
likely
to
lead
to
better
decisions
with
wider
36
political
support
and
legitimacy,
particularly
in
contexts
that
have
been
described
as
wicked
(Rittel
and
Webber,
1973)
and
requiring
solutions
described
as
clumsy
(Shapiro,
1988;
Verweij
et
al.,
2006;
Rayner,
2006).
While
not
all
will
find
the
terms
wicked
and
clumsy
immediately
helpful,
Rittel
and
Webbers
abstract
summarises
the
argument
regarding
wicked
problems
thus:
The
search
for
scientific
bases
for
confronting
problems
of
social
policy
is
bound
to
fail,
because
of
the
nature
of
these
problems.
They
are
wicked
problems,
whereas
science
has
developed
to
deal
with
tame
problems.
Policy
problems
cannot
be
definitively
described.
Moreover,
in
a
pluralistic
society
there
is
nothing
like
the
undisputable
public
good;
there
is
no
objective
definition
of
equity;
policies
that
respond
to
social
problems
cannot
be
meaningfully
correct
or
false;
and
it
makes
no
sense
to
talk
about
optimal
solutions
to
social
problems
unless
severe
qualifications
are
imposed
first.
Even
worse,
there
are
no
solutions
in
the
sense
of
definitive
and
objective
answers.
Similarly
Verweij
et
al
(2006)
emphasise
that
clumsy
solutions
are
those
that
are,
and
that
work
because
they
are,
politically
and
psychologically
inclusive:
Successful
solutions
to
pressing
social
ills
tend
to
consist
of
innovative
combinations
of
a
limited
set
of
alternative
ways
of
perceiving
and
resolving
the
issues.
These
contending
policy
perspectives
justify,
represent
and
stem
from
four
different
ways
of
organizing
social
relations:
hierarchy,
individualism,
egalitarianism
and
fatalism.
Each
of
these
perspectives:
(1)
distils
certain
elements
of
experience
and
wisdom
that
are
missed
by
the
others;
(2)
provides
a
clear
expression
of
the
way
in
which
a
significant
portion
of
the
populace
feels
we
should
live
with
one
another
and
with
nature;
and
(3)
needs
all
of
the
others
in
order
to
be
sustainable.
`Clumsy
solutions'-
policies
that
creatively
combine
all
opposing
perspectives
on
what
the
problems
are
and
how
they
should
be
resolved
-
are
therefore
called
for.
Not
only
is
UK
biofuel
and
bioenergy
policy
being
pursued
in
part
for
its
contribution
to
mitigating
the
wicked
problem
of
climate
change,
but
the
way
in
which
it
crosses
multiple
policy
domains,
makes
use
of
policy
instruments
over
which
governments
have
little
control,
relies
on
the
co- operation
(rather
than
obligation)
of
actors
along
supply
chains,
involves
indirect
impacts
that
are
intrinsically
difficult
to
model
and
monitor,
is
entangled
with
national
and
international
agricultural
commodity
trading
and
food
supply,
all
of
which
is
subject
to
significant
contestation,
makes
this
policy
arena
difficult
itself
-
unless
the
objective
is
simply
to
stimulate
fuel
supply
regardless
of
other
consequences.
5.3
FUTURE
PROSPECTS
In
terms
of
institutions
and
procedures,
the
theory
of
post-normal
science
implies
deliberative
forms
of
science
engagement
that
can
accommodate
multiple
framings,
which
in
this
context
may
include
integrated
assessment
techniques,
scenario
and
futures-building
(Frame
and
Brown,
2008),
but
also
boundary
or
bridging
organisations
that
can
broker
relations
between
diverse
stakeholders
(ibid)
37
and move beyond the style of consultation often practiced in UK politics, in which key outcomes often appear pre-determined. Are such aspirations realisable and realistic at UK national and EC policy levels, in this context, or is it nave to expect large commercial interests to find common ground with NGOs implacably opposed to a large scale bioenergy trade? On the latter point we would have to concede that the prospects are slim; but in fact there are few if any NGOs who are opposed to a large scale trade per se. What most of the NGOs are opposed to is a large scale trade that brings social, economic and environmental damage to localities. It should come as no surprise that this (very real) possibility engenders absolute and antagonistic positions. Indeed one could ask whether UK environmental policy ever been framed as weakly as the RTFO, with environmental regulation reduced to a minimal reporting requirement. Reardon (2001), in a case study of what became the controversial human genome diversity project, describes how the project organisers only gradually came to realise the social dimension of their work. Just as Reardon describes the human genome project encountering and being caught up in pre-existing debates on human nature and the reasons for human differences (specifically in relation to ethnicity), so UK biofuel policy has quickly run into long-standing debates relating to land use, neo-colonialism, food access, livelihoods, climate change, biodiversity, economic development and so on. Rather than attempting a relatively consensual approach to biofuel policy development, the UK Dept for Transport pushed ahead with a policy that had to be reined back due to public and NGO pressure and supporting studies (Renewable Fuels Agency, 2008) within only one year. Importantly, this post-dated NGO concerns relayed to Government via its RTFO consultations. What makes this particularly odd and reflects the fact that the RTFO process has been driven by the Department for Transport is that non-state actors, particularly corporations and non- governmental organisations with environmental and social missions, are increasingly playing significant roles in the formation of environmental policy. From various perspectives, this phenomenon has been referred to as the development of private environmental governance (Pattberg, 2004), partnerships between governments, business and/or civil society (Visseren- Hamakers, 2007) and private rule making (Chan and Pattberg, 2008). These cross-sectoral governance initiatives are increasingly found in the establishment and governance of non-state standards organisations (Gulbrandsen, 2008a), particularly in the activity of product certification and labelling, coupled with third party auditing (Auld et al, 2008). Furthermore, this activity is fundamental to the design of carbon and sustainability reporting under the RTFO. As of the end of 2009, qualifying environmental standards for the RTFO were the Roundtable on Sustainable Palm Oil (RSPO); Roundtable on Responsible Soy (RTRS); Sustainable Agriculture Network/Rainforest Alliance (SAN/RA); Basel criteria for soy (Basel); Forest Stewardship Council (FSC); Linking Environment and Farming Marque (LEAF); Assured Combinable Crops Scheme (ACCS); Genesis Quality Assurance (QA). At least the first five of these have had substantial NGO involvement, though in general evidence on the effectiveness of such partnerships remains rather scant (Van Huijstee= et al., 2007).
38
Of particular relevance here is Cashores conceptualisation of legitimacy in the context of non-state, market-driven governance systems (Cashore, 2002). Drawing on the organisational sociology literature, particularly (Suchman, 1995), Cashore discusses the FSC in terms of three forms of legitimacy, from which the FSC draws its authority: pragmatic, moral and cognitive (Suchman, 1995, in Cashore, 2002). Considering these summarily in turn, pragmatic legitimacy relates to the self- interests of an organisations most direct and immediate stakeholders. In the case of the non-state organisation FSC, this would most notably consist of the financial interests of companies in the timber trade (ibid). Moral legitimacy is drawn from a positive, normal evaluation of the organisation, i.e. that it is doing the right thing. Stakeholders in this case are more distant from the organisation than those closely involved in the supply chain, and the focus is not on exchange or commercial interest, but ethics and values (ibid). Cognitive legitimacy is construed as relating to the logic, intellectual and sense-making aspects of an organisations actions. Cashore, citing Suchman, refers to comprehensibility and taken-for-grantedness and suggests an element of environmental manipulation or recruitment, such as the organisation modelling such part of its procedures on already-accepted norms (ibid). Applying this to carbon and sustainability reporting under the RTFO, we should firstly note that although RTFO certification rests on non-state standards for part of its legitimacy, the RTFO is itself a state-sponsored and statutory reporting standard (or meta-standard). Indeed, it is an instance of a combined state- and non-state standard. As such, it is a form of hybrid regulation: as noted by the WWF interviewee, governmental incorporation of non-governmental standards into statutory legislation is a novel situation that itself raises issues of legitimacy and durability: it assumes that the non-state standards can continue to be relied upon; that they will not change in such a way as to confound or complicate the purposes of the legislation into which they have been subsumed, despite the state having no direct control over those standards. Somewhat paradoxically, by recruiting the standards into law, the additional credence and legitimacy lent thereby may have the effect of supporting and stabilising those them so that they are indeed more likely to endure in the long term and form part of a self-fulfilling assumption. This should not distract, however, from the fact that the legislation rests intriguingly and somewhat unsatisfactorily - on a voluntary base. This acknowledged, to what extent might it be said that the RTFO carbon and sustainability standard has achieved, and can achieve in future, the three forms of legitimacy posited by Cashore (2002) and Suchman (1995)? Firstly, the scheme would appear to perform well in pragmatic terms. Designed with the close assistance of at least one pro-biofuel fuel supplier and similarly-minded organisations such as the LowCVP, although it would be difficult to determine whether or not RTFO carbon and sustainability reporting had held back the sector following its stimulation by mandatory blending requirements, there does not appear to be any evidence of this. Given the very weak reporting regime, this should not be surprising. At the time of writing, the RED appears to be developing similarly, with, for example, no social assessment criteria that might prove complicated for suppliers to manage though the longer term GHG thresholds may exclude feedstocks or require changes to agronomic practice. Suchman and thus Cashore refer to working with the self-interests of stakeholders in mind as conforming to external audiences.
39
In terms of Cashores second form of legitimacy, moral legitimacy, the RTFO carbon and sustainability standard is most definitely problematic. Very limited support by environmental and social NGOs, with the exception of WWF, is a key indicator of this. In terms of wider society, it is likely that few in the wider population are aware of the RTFO or its implications. Data on public awareness is limited, but a YouGov opinion survey of 2,183 UK adults in April 2008, just before the commencement of the RTFO, commissioned by Friends of the Earth, found that 33% of respondents responded yes to the question: "are you aware that the growth in biofuels is contributing to deforestation in countries like Indonesia?" and 89% did not know that biofuels must be added to their vehicle fuel from 15th April 2008. Of the 55% of respondents who knew what biofuels were, only 14% thought they were the best way to reduce emissions from road transport; 44% singled out improving public transport as the best option (FoE, 2008). Overall, this does not appear to indicate a social mandate for biofuel usage (though awareness of links to Indonesian deforestation does not necessarily indicate disapproval). In terms of cognitive legitimacy, the last of Cashores forms of legitimacy, again the RTFO performs relatively poorly, with the merits of large scale biofuel production being widely contested and the subject of on-going research e.g. see studies referenced in Upham et al. (2009) and Thornley (2008). Given this context, what are the prospects for a more inclusive and legitimate (in the above sense) co-production of UK, and indeed European, biofuel policy? It would be fair to say that, without a substantive policy change, the prospects appear slim at both levels (it is also unclear how the RTFO will interface with the RED). The relevant reporting requirements under the RED are due for imminent release and national systems will need to reflect these. For the UK, preliminary discussions suggest that this will entail a narrower reporting scope, with no requirement for reporting on the social consequences of biomass production (RFA, 2009). Rather, reporting is expected to be required on at least four aspects: GHG threshold (for which there will be a grandfathering clause); biodiversity (essentially no biofuels to be produced on high biodiversity value land); carbon stock (no biofuels produced on high carbon stock land, e.g. peatlands); and cross-compliance for EU producers, meaning that existing EC environmental regulations will need to be met. The baseline date under RED sustainability reporting (particularly relevant to land use change) looks likely to be January 2008, later than under the existing UK RTFO. However, in important contrast to the first years of the RTFO, suppliers will not be allowed to submit unknown with respect to land-use. In terms of chain of custody requirements, book and claim systems (in which certificates are decoupled from the commodity, as in RSPO Greenpalm) will not meet RED rules, although mass balance (where the commodity and the certificate remain coupled) will be acceptable. For the RTFO, RED-ready compliance will begin in the next reporting year i.e. April 2010. However, a now axiomatic concern of critical observers is that the environmental protection afforded by the above (and at the time of writing it looks like being only environmental, not social protection), together with the environmental benefit of GHG reduction, could be wholly or partly negated if biofuel production displaces other agricultural production to new sites. Unless there are signs of a genuine willingness to deal with this problem, and others - such as the concerns of NGOs regarding fuelling the displacement of agricultural livelihoods (Tomei and Upham 2009), it is difficult to imagine meaningful engagement of dissenting stakeholders in biofuel policy formation.
40
Although the sustainable biomass standard being developed by the CEN (CEN/TC 383 see e.g. Ortwin, 2009) does include indirect effects within its scope, it remains to be seen how it will address such inherently difficult issues; or rather, whether it can do so to the satisfaction of critical observers. Indeed the latter is the nub of the social problem here. Building a successful network requires what Callon (1995) described as translation: the ability to recruit or co-opt animate and inanimate objects (people, resources all of all types, organisations, standards, procedures, equipment etc) for the purpose of the network. Jasanoffs (1998) observation that standards involve establishing equivalence and commensurability across individual cases is a particular case of translation in this sense. Modelling or ex-ante assessment of the indirect impacts of supplying biomass for fuel is likely in many cases to be possible only with a narrow geographic scoping of the system boundary. Although coarse, high-level modelling of the effects of bioenergy/biofuel supply on global agricultural commodity supply and trade is possible (Searchinger, Heimlich et al. 2008), this is of limited value for certifying a specific quantity of biomass. It may well be that insights from such modelling could inform certification, and it may well be that analysis of existing and future remote sensing data could do likewise, but biofuel certification policy is not being pursued ahead of such studies. At present, indirect impacts are likely to remain one of the key obstacles to a wider consensus on biofuel policy though, as we show above, not the only one.
41
6
CONCLUSIONS
The
biofuels
debate
in
the
UK
and
EU
has
developed
rapidly
in
the
first
year
of
the
RTFOs
operation
and
early
concern
that
policy
was
moving
ahead
of
scientific
knowledge
in
the
area
are,
for
civil
society
observers,
proving
increasingly
founded.
The
Gallagher
Report
(Renewable
Fuels
Agency,
2008)
and
its
constituent
studies
represent
official
acknowledgement
of
the
problems
not
only
of
most
first
generation
biofuels
(a
term
generally
applied
to
current
agricultural
feedstocks
used
for
biofuel),
but
also
of
the
scale
of
the
additional
global
land-take
that
would
be
required
to
significantly
supply
vehicle
fleets
in
a
period
for
which
there
is
in
any
case
likely
to
be
a
substantial
increase
in
global
demand
for
agricultural
land
for
food
and
animal
feed
(ibid).
There
is
and
will
remain
strong
political
dimensions
to
transport
fuel
supply
at
all
levels:
indeed,
biofuels
add
a
new
dimension
to
geopolitical
tensions,
in
terms
of
trade,
land
acquisition
and
security
of
supply,
which
we
have
not
had
time
to
discuss
here.
Despite
a
dominant,
surface
discourse
of
carbon
and
GHG
emissions
reduction,
UK
stakeholder
opinion
differs
substantially
on
biofuel
policy.
In
consultation
on
the
design
of
the
RTFO
and
its
carbon
and
sustainability
reporting
framework,
commercial
and
transport
policy
stakeholders
have
wanted
to
see
biofuel
supply
driven
ahead
with
RTFO
regulation
in
its
initial
state,
or
even
weaker.
Their
appeal
to
emissions
reduction
overlies
commercial
and
economic
priorities,
in
particular
that
these
interests
should
not
be
adversely
affected
by
the
RTFO
carbon
and
sustainability
reporting
framework.
The
environmental
and
social
NGO
positions
are
similarly
predictable
in
terms
of
their
own
priorities.
We
have
described
positional
and
discourse
differences
on
biofuels
in
some
detail
and
have
discussed
both
the
desirability
and
the
prospects
for
a
more
inclusive
co-production
of
biofuel
policy
in
the
UK
and,
to
a
lesser
extent,
Europe.
Unfortunately,
we
have
had
to
conclude
that
the
prospects
for
bringing
a
wider
and
more
socially
legitimated
alliance
into
UK
and
quite
likely
European
biofuel
policy
making
are
slim,
while
policy
continues
to
stimulate
biofuel
production
ahead
of
an
understanding
of
its
consequences.
42
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APPENDIX A INTERVIEW QUESTIONNAIRE Please see overleaf. Questionnaire sent by email and administered by telephone during November and December 2009. The response rate was about 33%; no one from Government departments or the Renewable Fuels Agency replied to repeat requests for interview hence our primary focus on critical stakeholders.
52
Strongly agree 1
Reasons/comments: 2. A large-scale, international trade in bioenergy feedstocks is essential for UK energy security 2 3 4 5 Strongly disagree
Strongly agree 1
Reasons/comments: 3. A large-scale, international trade in bioenergy feedstocks risks a net increase in global GHG emissions from land conversion 2 3 4 5 Strongly disagree
Strongly agree 1
Reasons/comments: 4. A large-scale, international trade in bioenergy feedstocks poses little risk in terms of food poverty in developing countries 2 3 4 5 Strongly disagree
Strongly agree 1
Reasons/comments: 53
5. A large-scale, international trade in bioenergy feedstocks will primarily benefit well-capitalised land owners 2 3 4 5 Strongly disagree
Strongly agree 1
Reasons/comments: 6. I have confidence in the RTFO carbon and sustainability reporting methodology (current or near future) as a model for managing bioenergy feedstock impacts 2 3 4 5 Strongly disagree
Strongly agree 1
Reasons/comments: 7. Strongly agree 1 2 3 4 5 Strongly disagree Reducing energy demand in developed countries should be a higher priority than further developing an international bioenergy market
Reasons/comments: 8. Strongly agree 1 2 3 4 5 Strongly disagree Where land is scarce, cultivation of energy crops for power and heat should be prioritised over crops for transport fuel
Reasons/comments:
54
Round Table on Responsible Soy (RTRS) Highly effective 1 2 3 4 5 Not at all effective
Reasons/comments: Roundtable on Sustainable Palm Oil (RSPO) Highly effective 1 2 3 4 5 Not at all effective
Reasons/comments: Forest Stewardship Council (FSC) Highly effective 1 2 3 4 5 Not at all effective
Reasons/comments: 10. Is a January 2008 baseline date for land use change in biomass sustainability reporting agreeable to you? Yes No
Reasons/comments 11. Do you think that biomass sustainability reporting for the RED can adequately indicate indirect land use change? Yes No
55
Reasons/comments 12. In what ways, if at all, have your opinions on biofuels and/or bioenergy changed over the last two years?
Saynor, B., Bauen, A. and Leach, M. (2003) The Potential for Renewable Energy Sources in Aviation, ICCEPT, Imperial College, London. [Allocating energy and GHG credit to co-products makes the untestable assumption that substitution takes place. It ignores: (i) the net increase in production and (ii) effects external to the LCA system boundary]. 56
The Tyndall Centre working paper series presents results from research which are mature enough to be submitted to a refereed journal, to a sponsor, to a major conference or to the editor of a book. The intention is to enhance the early public availability of research undertaken by the Tyndall family of researchers, students and visitors. They can be downloaded from the Tyndall Website at: http://www.tyndall.ac.uk/publications/working_papers/working_papers.shtml The accuracy of working papers and the conclusions reached are the responsibility of the author(s) alone and not the Tyndall Centre.
Papers available in this series are: Seyfang, G., I. Lorenzoni, and M. Nye., (2009) Personal Carbon Trading: a critical examination of proposals for the UK. Tyndall Working Paper 136. HTompkins E. L, Boyd E., Nicholson-Cole S, Weatherhead EK, Arnell N. W., Adger W. N., (2009) An Inventory of Adaptation to climate change in the UK: challenges and findings: Tyndall Working Paper 135; Haxeltine A., Seyfang G., (2009) Transitions for the People: Theory and Practice of Transition and Resilience in the UKs Transition Movement: Tyndall Working Paper 134; Tomei J., Upham P., (2009) Argentinean soy based biodiesel: an introduction to production and impacts: Tyndall Working Paper 133; Whitmarsh L, O'Neill S, Seyfang G., Lorenzoni I., (2008) Carbon Capability: what does it mean, how prevalent is it, and how can we promote it?: Tyndall Working Paper 132; Huang Y., Barker T., (2009) Does Geography Matter for the Clean Development Mechanism? : Tyndall Working Paper 131;
Tyndall Working Papers
Huang Y., Barker T., (2009) The Clean Development Mechanism and Sustainable Development: A Panel Data Analysis: Tyndall Working Paper 130; Dawson R., Hall J, Barr S, Batty M., Bristow A, Carney S, Dagoumas, A., Evans S., Ford A, Harwatt H., Kohler J., Tight M, (2009) A blueprint for the integrated assessment of climate change in cities: Tyndall Working Paper 129; Carney S, Whitmarsh L, Nicholson-Cole S, Shackley S., (2009) A Dynamic Typology of Stakeholder Engagement within Climate Change Research: Tyndall Working paper 128; Goulden M, Conway D, Persechino A., (2008) Adaptation to climate change in international river basins in Africa: a review: Tyndall Working paper 127; Bows A., Anderson K., (2008) A bottom-up analysis of including aviation within the EUs Emissions Trading Scheme: Tyndall Working Paper 126; Al-Saleh Y., Upham P., Malik K., (2008)
2000 - 2010
Renewable Energy Scenarios for the Kingdom of Saudi Arabia: Tyndall Working Paper 125
Scrieciu S., Barker T., Smith V., (2008) World economic dynamics and technological change: projecting interactions between economic output and CO2 emissions :Tyndall Working Boyd E., Hultman N E., Roberts T., Paper 124 Corbera E., Ebeling J., Liverman D, Brown K, Tippmann R., Cole J., Mann P, Kaiser Bulkeley H, Schroeder H., (2008) M., Robbins M, (2007) The Clean Governing Climate Change Post-2012: Development Mechanism: An The Role of Global Cities - London: assessment of current practice and future approaches for policy: Tyndall Tyndall Working Paper 123 Centre Working Paper 114 Schroeder H., Bulkeley H, (2008) Governing Climate Change Post-2012: The Role of Global Cities, Case-Study: Hanson, S., Nicholls, R., Balson, P., Los Angeles: Tyndall Working Paper 122 Brown, I., French, J.R., Spencer, T., Sutherland, W.J. (2007) Capturing coastal morphological Wang T., Watson J, (2008) Carbon change within regional integrated Emissions Scenarios for China to assessment: an outcome-driven fuzzy 2100: Tyndall Working Paper 121 logic approach: Tyndall Working Paper No. 113 Bergman, N., Whitmarsh L, Kohler J., (2008) Transition to sustainable Okereke, C., Bulkeley, H. (2007) development in the UK housing Conceptualizing climate change sector: from case study to model implementation: Tyndall Working Paper governance beyond the international regime: A review of four theoretical 120 approaches: Tyndall Working Paper No. Conway D, Persechino A., Ardoin-Bardin 112 S., Hamandawana H., Dickson M, Dieulin Doulton, H., Brown, K. (2007) Ten C, Mahe G, (2008) RAINFALL AND WATER RESOURCES VARIABILITY IN years to prevent catastrophe? Discourses of climate change and SUB-SAHARAN AFRICA DURING THE 20TH CENTURY: Tyndall Centre Working international development in the UK press: Tyndall Working Paper No. 111 Paper 119 Dawson, R.J., et al (2007) Integrated Starkey R., (2008) Allocating analysis of risks of coastal flooding emissions rights: Are equal shares, fair shares? : Tyndall Working Paper 118 and cliff erosion under scenarios of long term change: Tyndall Working Paper No. 110 Barker T., (2008) The Economics of Avoiding Dangerous Climate Change: Okereke, C., (2007) A review of UK Tyndall Centre Working Paper 117 FTSE 100 climate strategy and a Estrada M, Corbera E., Brown K, (2008) framework for more in-depth analysis in the context of a post-2012 climate How do regulated and voluntary regime: Tyndall Centre Working Paper carbon-offset schemes compare?: 109 Tyndall Centre Working Paper 116
Tyndall Working Papers 2000 - 2010
Estrada Porrua M, Corbera E., Brown K, (2007) REDUCING GREENHOUSE GAS EMISSIONS FROM DEFORESTATION IN DEVELOPING COUNTRIES: REVISITING THE ASSUMPTIONS: Tyndall Centre Working Paper 115
Gardiner S., Hanson S., Nicholls R., Zhang Z., Jude S., Jones A.P., et al (2007) The Habitats Directive, Coastal Habitats and Climate Change Case Studies from the South Coast of the UK: Tyndall Centre Working Paper 108
Kirk K., (2007) Potential for storage of carbon dioxide in the rocks beneath the East Irish Sea: Tyndall Centre Working Paper 100 Arnell N.W., (2006) Global impacts of abrupt climate change: an initial assessment: Tyndall Centre Working Paper 99
Schipper E. Lisa, (2007) Climate Change Adaptation and Development: Exploring the Linkages: Tyndall Centre Lowe T.,(2006) Is this climate porn? Working Paper 107 How does climate change communication affect our perceptions Okereke C., Mann P, Osbahr H, (2007) and behaviour?, Tyndall Centre Working Assessment of key negotiating issues Paper 98 at Nairobi climate COP/MOP and what it means for the future of the climate Walkden M, Stansby P,(2006) The regime: Tyndall Centre Working Paper effect of dredging off Great Yarmouth No. 106 on the wave conditions and erosion of the North Norfolk coast. Tyndall Centre Walkden M, Dickson M, (2006) The Working Paper 97 response of soft rock shore profiles to increased sea-level rise. : Tyndall Anthoff, D., Nicholls R., Tol R S J, Centre Working Paper 105 Vafeidis, A., (2006) Global and regional exposure to large rises in sea-level: a Dawson R., Hall J, Barr S, Batty M., sensitivity analysis. This work was Bristow A, Carney S, Evans E.P., Kohler J., prepared for the Stern Review on the Tight M, Walsh C, Ford A, (2007) A Economics of Climate Change: blueprint for the integrated Tyndall Centre Working Paper 96 assessment of climate change in cities. : Tyndall Centre Working Paper Few R., Brown K, Tompkins E. L, 104 (2006) Public participation and climate change adaptation, Tyndall Centre Dickson M., Walkden M., Hall J., (2007) Working Paper 95 Modelling the impacts of climate change on an eroding coast over the Corbera E., Kosoy N, Martinez Tuna M, 21st Century: Tyndall Centre Working (2006) Marketing ecosystem services Paper 103 through protected areas and rural communities in Meso-America: Klein R.J.T, Erickson S.E.H, Nss L.O, Implications for economic efficiency, Hammill A., Tanner T.M., Robledo, C., equity and political legitimacy, Tyndall OBrien K.L.,(2007) Portfolio screening Centre Working Paper 94 to support the mainstreaming of adaptation to climatic change into Schipper E. Lisa, (2006) Climate development assistance: Tyndall Centre Risk, Perceptions and Development in Working Paper 102 El Salvador, Tyndall Centre Working Agnolucci P., (2007) Is it going to happen? Regulatory Change and Renewable Electricity: Tyndall Centre Working Paper 101 Paper 93 Tompkins E. L, Amundsen H, (2005) Perceptions of the effectiveness of the United Nations Framework Convention on Climate Change in prompting
2000 - 2010
Anderson K., Bows A., Upham P., Centre (2006) Growth scenarios for EU & UK aviation: contradictions with climate Warren R., Hope C, Mastrandrea M, policy, Tyndall Centre Working Paper 84 Tol R S J, Adger W. N., Lorenzoni I., Williamson M., Lenton T., Shepherd (2006) Spotlighting the impacts functions in integrated assessments. J., Edwards N, (2006) An efficient Research Report Prepared for the numerical terrestrial scheme (ENTS) Stern Review on the Economics of for fast earth system modelling, Climate Change, Tyndall Centre Working Tyndall Centre Working Paper 83 Paper 91 Bows, A., and Anderson, K. (2005) Warren R., Arnell A, Nicholls R., Levy An analysis of a post-Kyoto climate P E, Price J, (2006) Understanding the policy model, Tyndall Centre Working regional impacts of climate change: Paper 82 Research Report Prepared for the Sorrell, S., (2005) The economics of Stern Review on the Economics of service contracts, Tyndall Climate Change, Tyndall Centre Working energy Centre Working Paper 81 Paper 90 behavioural change, Working Paper 92 Tyndall Barker T., Qureshi M, Kohler J., (2006) The Costs of Greenhouse Gas Mitigation with Induced Technological Change: A Meta-Analysis of Estimates in the Literature, Tyndall Centre Working Paper 89 Kuang C, Stansby P, (2006) Sandbanks for coastal protection: implications of sea-level rise. Part 3: wave modelling, Tyndall Centre Working Paper 88 Wittneben, B., Haxeltine, A., Kjellen, B., Khler, J., Turnpenny, J., and Warren, R., (2005) A framework for assessing the political economy of post-2012 global climate regime, Tyndall Centre Working Paper 80 Ingham, I., Ma, J., and Ulph, A. M. (2005) Can adaptation and mitigation be complements?, Tyndall Centre Working Paper 79
Agnolucci,. P (2005) Opportunism Kuang C, Stansby P, (2006) and competition in the non-fossil fuel market, Tyndall Centre Sandbanks for coastal protection: obligation implications of sea-level rise. Part 2: Working Paper 78 current and morphological modelling, Barker, T., Pan, H., Khler, J., Tyndall Centre Working Paper 87 Warren., R and Winne, S. (2005) Stansby P, Kuang C, Laurence D, Avoiding dangerous climate change by technological progress: Launder B, (2006) Sandbanks for inducing using a large-scale coastal protection: implications of scenarios sea-level rise. Part 1: application to econometric model, Tyndall Centre East Anglia, Tyndall Centre Working Working Paper 77 Paper 86 Agnolucci,. P (2005) The role of Bentham M, (2006) An assessment political uncertainty in the Danish of carbon sequestration potential in renewable energy market, Tyndall the UK Southern North Sea case Centre Working Paper 76 study: Tyndall Centre Working Paper 85
Tyndall Working Papers 2000 - 2010
Fu, G., Hall, J. W. and Lawry, J. (2005) Beyond probability: new methods for representing uncertainty in projections of future climate, Tyndall Centre Working Paper 75 Ingham, I., Ma, J., and Ulph, A. M. (2005) How do the costs of adaptation affect optimal mitigation when there is uncertainty, irreversibility and learning?, Tyndall Centre Working Paper 74
regional and local scenarios for climate change mitigation and adaptation: Part 2: Scenario creation, Tyndall Centre Working Paper 67 Turnpenny, J., Haxeltine, A., Lorenzoni, I., ORiordan, T., and Jones, M., (2005) Mapping actors involved in climate change policy networks in the UK, Tyndall Centre Working Paper 66
Adger, W. N., Brown, K. and Tompkins, E. L. (2004) Why do Walkden, M. (2005) Coastal resource managers make links to process simulator scoping study, stakeholders at other scales?, Tyndall Centre Working Paper 65 Tyndall Centre Working Paper 73 Lowe, T., Brown, K., Suraje Dessai, S., Doria, M., Haynes, K. and Vincent., K (2005) Does tomorrow ever come? Disaster narrative and public perceptions of climate change, Tyndall Centre Working Paper 72 Peters, M.D. and Powell, J.C. (2004) Fuel Cells for a Sustainable Future II, Tyndall Centre Working Paper 64
Few, R., Ahern, M., Matthies, F. and Kovats, S. (2004) Floods, health and climate change: a strategic review, Boyd, E. Gutierrez, M. and Chang, Tyndall Centre Working Paper 63 M. (2005) Adapting small-scale CDM Barker, T. (2004) Economic theory sinks projects to low-income communities, Tyndall Centre Working and the transition to sustainability: a comparison of Paper 71 approaches, Tyndall Centre Working Abu-Sharkh, S., Li, R., Markvart, T., Paper 62 Ross, N., Wilson, P., Yao, R., Steemers, Brooks, N. (2004) Drought in the K., Kohler, J. and Arnold, R. (2005) Can Migrogrids Make a Major Contribution African Sahel: long term perspectives to UK Energy Supply?, Tyndall Centre and future prospects, Tyndall Centre Working Paper 61 Working Paper 70 Tompkins, E. L. and Hurlston, L. A. (2005) Natural hazards and climate change: what knowledge is transferable?, Tyndall Centre Working Paper 69 Bleda, M. and Shackley, S. (2005) The formation of belief in climate change in business organisations: a dynamic simulation model, Tyndall Centre Working Paper 68 Few, R., Brown, K. and Tompkins, E.L. (2004) Scaling adaptation: climate change response and coastal management in the UK, Tyndall Centre Working Paper 60 Anderson, D and Winne, S. (2004) Modelling Innovation and Threshold Effects In Climate Change Mitigation, Tyndall Centre Working Paper 59
Bray, D and Shackley, S. Turnpenny, J., Haxeltine, A. and ORiordan, T., (2005) Developing (2004) The Social Simulation of The
2000 - 2010
Powell, J.C., Peters, M.D., Ruddell, Public Perceptions of Weather Events and their Effect upon the A. and Halliday, J. (2004) Fuel Cells for a Development of Belief in Sustainable Future? Tyndall Centre Anthropogenic Climate Change, Tyndall Working Paper 50 Centre Working Paper 58 Awerbuch, S. (2004) Restructuring Shackley, S., Reiche, A. and our electricity networks to promote Mander, S (2004) The Public decarbonisation, Tyndall Centre Working Perceptions of Underground Coal Paper 49 Gasification (UCG): A Pilot Study, Pan, H. (2004) The evolution of Tyndall Centre Working Paper 57 economic structure under Vincent, K. (2004) Creating an technological development, Tyndall index of social vulnerability to climate Centre Working Paper 48 change for Africa, Tyndall Centre Berkhout, F., Hertin, J. and Gann, Working Paper 56 D. M., (2004) Learning to adapt: Organisational adaptation to climate Mitchell, T.D. Carter, T.R., Jones, change impacts, Tyndall Centre Working .P.D, Hulme, M. and New, M. (2004) A Paper 47 comprehensive set of high-resolution Watson, J., Tetteh, A., Dutton, G., grids of monthly climate for Europe and the globe: the observed record Bristow, A., Kelly, C., Page, M. and (1901-2000) and 16 scenarios (2001- Pridmore, A., (2004) UK Hydrogen 2100), Tyndall Centre Working Paper 55 Futures to 2050, Tyndall Centre Working Paper 46 Turnpenny, J., Carney, S., Purdy, R and Macrory, R. (2004) Haxeltine, A., and ORiordan, T. (2004) carbon sequestration: Developing regional and local Geological scenarios for climate change critical legal issues, Tyndall Centre mitigation and adaptation Part 1: A Working Paper 45 framing of the East of England Tyndall Centre Working Paper 54 Shackley, S., McLachlan, C. and C. (2004) The Public Agnolucci, P. and Ekins, P. (2004) Gough, The Announcement Effect And Perceptions of Carbon Capture and Environmental Taxation Tyndall Centre Storage, Tyndall Centre Working Paper 44 Working Paper 53 Anderson, D. and Winne, S. (2003) Agnolucci, P. (2004) Ex Post Innovation and Threshold Effects in Evaluations of CO2 Based Taxes: A Technology Responses to Climate Survey Tyndall Centre Working Paper 52 Change, Tyndall Centre Working Paper 43 Agnolucci, P., Barker, T. and Ekins, P. (2004) Hysteresis and Energy Demand: the Announcement Effects and the effects of the UK Climate Change Levy Tyndall Centre Working Paper 51 Kim, J. (2003) Sustainable Development and the CDM: A South African Case Study, Tyndall Centre Working Paper 42 Watson, J. (2003), UK Electricity Scenarios for 2050, Tyndall Centre Working Paper 41
2000 - 2010
Electricity System: Investigation of Klein, R.J.T., Lisa Schipper, E. and the impact of network faults on the Dessai, S. (2003), Integrating stability of large offshore wind farms, mitigation and adaptation into climate Tyndall Centre Working Paper 32 and development policy: three Turnpenny, J., Haxeltine A. and research questions, Tyndall Centre ORiordan, T. (2003). A scoping study of Working Paper 40 UK user needs for managing climate Tompkins, E. and Adger, W.N. futures. Part 1 of the pilot-phase integrated assessment (2003). Defining response capacity to interactive (Aurion Project), Tyndall enhance climate change policy, Tyndall process Centre Working Paper 31 Centre Working Paper 39 Hulme, M. (2003). Abrupt climate Brooks, N. (2003). Vulnerability, risk and adaptation: a conceptual change: can society cope?, Tyndall framework, Tyndall Centre Working Centre Working Paper 30 Paper 38 Brown, K. and Corbera, E. (2003). A Ingham, A. and Ulph, A. (2003) Multi-Criteria Assessment Framework Carbon-Mitigation Projects: Uncertainty, Irreversibility, for Precaution and the Social Cost of Putting development in the centre Carbon, Tyndall Centre Working Paper 37 of decision-making, Tyndall Centre Working Paper 29 Krger, K. Fergusson, M. and Dessai, S., Adger, W.N., Hulme, M., Skinner, I. (2003). Critical Issues in Decarbonising Transport: The Role of Khler, J.H., Turnpenny, J. and Warren, R. Technologies, Tyndall Centre Working (2003). Defining and experiencing dangerous climate change, Tyndall Paper 36 Centre Working Paper 28 Tompkins E. L and Hurlston, L. Tompkins, E.L. and Adger, W.N. (2003). Report to the Cayman Islands Government. Adaptation lessons (2003). Building resilience to climate through adaptive learned from responding to tropical change cyclones by the Cayman Islands management of natural resources, Government, 1988 2002, Tyndall Tyndall Centre Working Paper 27 Centre Working Paper 35 Brooks, N. and Adger W.N. (2003). Dessai, S., Hulme, M (2003). Does Country level risk measures of climate policy need probabilities?, climate-related natural disasters and implications for adaptation to climate Tyndall Centre Working Paper 34 change, Tyndall Centre Working Paper 26 Pridmore, A., Bristow, A.L., May, A. Xueguang Wu, Mutale, J., Jenkins, D. and Tight, M.R. (2003). Climate and Strbac, G. (2003). An Change, Impacts, Future Scenarios N. and the Role of Transport, Tyndall investigation of Network Splitting for Fault Level Reduction, Tyndall Centre Centre Working Paper 33 Working Paper 25 Xueguang Wu, Jenkins, N. and Xueguang Wu, Jenkins, N. and G. (2002). Impact of Strbac, G. (2003). Integrating Strbac, Renewables and CHP into the UK Integrating Renewables and CHP into
Tyndall Working Papers 2000 - 2010
Analysis Perspective, the UK Transmission Network, Tyndall Institutional Tyndall Centre Working Paper 14 Centre Working Paper 24 Dewick, P., Green K., Miozzo, M., Paavola, J. and Adger, W.N. (2002). Technological Change, Justice and adaptation to climate (2002). Structure and the change, Tyndall Centre Working Paper 23 Industry Environment, Tyndall Centre Working Watson, W.J., Hertin, J., Randall, T., Paper 13 Gough, C. (2002). Renewable Energy Dessai, S., (2001). The climate and Combined Heat and Power Resources in the UK, Tyndall Centre regime from The Hague to Marrakech: Saving or sinking the Kyoto Protocol?, Working Paper 22 Tyndall Centre Working Paper 12 Watson, W. J. (2002). Renewables Barker, T. (2001). Representing and CHP Deployment in the UK to the Integrated Assessment of Climate 2020, Tyndall Centre Working Paper 21 Change, Adaptation and Mitigation, Turnpenny, J. (2002). Reviewing Tyndall Centre Working Paper 11 organisational use of scenarios: Case Gough, C., Taylor, I. and Shackley, study - evaluating UK energy policy options, Tyndall Centre Working Paper 20 S. (2001). Burying Carbon under the Sea: An Initial Exploration of Public Pridmore, A. and Bristow, A., Opinions, Tyndall Centre Working Paper (2002). The role of hydrogen in 10 powering road transport, Tyndall Barnett, J. and Adger, W. N. (2001). Centre Working Paper 19 Climate Dangers and Atoll Countries, Watson, J. (2002). The Tyndall Centre Working Paper 9 development of large technical Adger, W. N. (2001). Social Capital systems: implications for hydrogen, and Climate Change, Tyndall Centre Tyndall Centre Working Paper 18 Working Paper 8 Barnett, J. (2001). Security and Dutton, G., (2002). Hydrogen Energy Technology, Tyndall Centre Climate Change, Tyndall Centre Working Paper 7 Working Paper 17 Adger, W.N., Huq, S., Brown, K., Conway, D. and Hulme, M. (2002). Adaptation to climate change: Setting the Agenda for Development Policy and Research, Tyndall Centre Working Paper 16 Khler, J.H., (2002). Long run technical change in an energyenvironment-economy (E3) model for an IA system: A model of Kondratiev waves, Tyndall Centre Working Paper 15 Goodess, C.M., Hulme, M. and Osborn, T. (2001). The identification and evaluation of suitable scenario development methods for the estimation of future probabilities of extreme weather events, Tyndall Centre Working Paper 6 Barnett, J. (2001). The issue of 'Adverse Effects and the Impacts of Response Measures' in the UNFCCC, Tyndall Centre Working Paper 5
Barker, T. and Ekins, P. (2001). Shackley, S. and Gough, C., (2002). The Use of Integrated Assessment: An How High are the Costs of Kyoto for
Tyndall Working Papers 2000 - 2010
Centre Hulme, M. (2001). Integrated Assessment Models, Tyndall Centre Working Paper 2 Berkhout, F, Hertin, J. and Jordan, A. J. (2001). Socio-economic futures in Mitchell, T. and Hulme, M. (2000). A climate change impact assessment: Country-by-Country Analysis of Past using scenarios as 'learning and Future Warming Rates, Tyndall machines', Tyndall Centre Working Paper Centre Working Paper 1 3
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