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Investigating the effectiveness of environmental assessment of land use change

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Investigating the effectiveness of environmental assessment of land use change: A comparative study of the approaches taken to perennial biomass crop planting in Sao Paulo and ? England
Amarilis Lucia Casteli Figueiredo Gallardo a,*, Alan Bond b
Institute for Technological Research, Center of Environmental and Energetic Technologies, Av. Prof. Almeida Prado, 532, Cidade ?ria, Sa Paulo e SP, CEP 05508-901, Brazil Universita ?o b InteREAM (Interdisciplinary Research in Environmental Assessment and Management), School of Environmental Sciences, University of East Anglia, Norwich, NR4 7TJ, UK

article info
Article history: Received 23 August 2010 Received in revised form 25 February 2011 Accepted 26 February 2011 Available online 22 March 2011 Keywords: Environmental assessment Brazil England Perennial bioenergy crops Sugarcane (Saccharum spp.) Miscanthus (Miscanthus spp.) grass

There is a move towards large-scale planting of perennial bioenergy crops in many countries to help reduce Green House Gas emissions, whilst still meeting energy demand. However, the implications of such wholesale land use change have yet to be fully understood which raises some concerns over the strategy. This paper identi?es, through literature review, that signi?cant social, economic and environmental impacts might be expected from land use change in two different parts of the world, Sao Paulo, Brazil, where ? sugarcane is the predominant perennial biomass crop, and England where miscanthus and short rotation coppice are likely to predominate. In order to examine the extent to which these impacts can be addressed in decision-making, the paper develops a framework for testing the effectiveness of environmental assessment practice in these two regions, and applies it to both. The conclusion is that, whilst tools which can address sustainability impacts in decision-making exist, the legal framework in England precludes their application for the majority of land use change, and in Brazil there is incomplete consideration of social and economic impacts at the strategic level. ? 2011 Elsevier Ltd. All rights reserved.



In recent years, in order to tackle climate change and to promote energy security, renewable energy (biomass, wind, solar, small-scale hydropower, tidal power, geothermal energy and waste) has been advocated as a means of enhancing diversity in energy supply markets whilst achieving sustainable development. Biomass can be de?ned as “any biological material, derived from plant or animal matter, which can be used for producing heat and/or power, fuels including transport

fuels, or as a substitute for fossil fuel-based materials and products” ([1], p.11). Biofuels can be de?ned as liquid transport fuels derived from biomass, whereas bioenergy is the heat and power derived from biomass (including from derived biofuels) [2]. Given that motivation of Governments to reduce Green House Gas (GHG) emissions is driven by international agreements like the Kyoto Protocol, and the fact that bioenergy crops are regarded as having signi?cant GHG reduction potential across the complete life cycle [3], the use of

* Corresponding author. Tel.: ?55 11 37674611; fax: ?55 11 37674938. E-mail addresses: amaca?@ipt.br (A.L. Casteli Figueiredo Gallardo), alan.bond@uea.ac.uk (A. Bond). 0961-9534/$ e see front matter ? 2011 Elsevier Ltd. All rights reserved. doi:10.1016/j.biombioe.2011.02.050


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bioenergy from biomass crops is expected to play an important role as an energy source in partially replacing the energy obtained from fossil resources. In 2004, an estimated 140,000 km2, worldwide, were being used to produce biofuels and their by-products, representing approximately 1% of global cropland [4]. Currently, the evidence suggests that a change from annual crops to perennial (bioenergy) crops is likely to have more positive environmental implications, particularly in relation to GHG emissions and energy balance [5,6]. However, there have been growing concerns that the full implications of large-scale land conversion to bioenergy crops have not yet been entirely considered and there are particular fears over the indirect consequences in relation to food security, biodiversity impacts, water security and climate change [7e11]. Most countries have adopted some form of environmental assessment legislation applying either at the project level (Environmental Impact Assessment e EIA) or at the strategic level for policies, plans and programmes (Strategic Environmental Assessment e SEA) in order to determine the implications of actions in advance [12]. The extent to which such assessment processes apply to bioenergy crops, or work as intended where they do apply is, thus, an important research question. In particular, there is a need to know the extent to which current decision-making practice can identify impacts of land use change (towards increased planting of perennial bioenergy crops) and in?uence the planting to minimise negative impacts and accentuate positive impacts. In Europe, bioenergy crops are currently replacing annual crops [6] although European regulations prevent Member States from reducing the area of permanent pasture [13]. Despite this, the future situation in Europe is less clear: projected long-term, contrasting scenarios accommodating both different socio-economic conditions climate scenarios indicate that a number of different outcomes are possible as soon as 2035 [14]. In Brazil, however, increased planting of sugarcane (Saccharum spp.) is argued to be replacing pasture land (i.e. grass which is perennial) [15]. Thus, a comparative study of Sao Paulo and England is undertaken in order to determine ? how the statutory authorities currently appraise the potential impacts from land use change related to bioenergy crops and the extent to which their appraisals properly inform decision makers of the consequences. Both regions are expected to increase the area of land under bioenergy crops, however, the majority of the expansion in the State of Sao Paulo will be through an increase in ? planting of sugarcane (it currently accounts for 83% of the State’s renewable energy contribution [16]), and so this biofuel crop will provide the focus for this region. In England, significant expansion is expected both for biofuels (from wheat and oilseed rape) and biomass crops for Combined Heat and Power (CHP) (Short Rotation Coppice Willow e Salix spp. e SRC and miscanthus grass e Miscanthus spp.). Whilst the land area covered by the former is anticipated to be twice that of the latter [1], our focus will be on increased planting of the biomass crops SRC and miscanthus because this represents a signi?cant change in land use from annual crops to perennial crops. England and Sao Paulo have similar populations, ? 42,736,000 (2007) and 41,779,000 (2008), respectively, although the latter is 80% larger in land area, 130,439 km2 and

248,209 km2, respectively. Otherwise there are many differences, such as each country’s geography, distinct kinds of feedstock, policies, economic context and level of use of bioenergy in their grid. In order to answer the research question, the research is broken down into speci?c objectives:  To identify the signi?cant impacts (positive and negative) from land use change associated with perennial biomass crops in both regions to demonstrate a need for some form of pre-decision assessment;  To determine a method for measuring the effectiveness of any assessment conducted; and  To apply this method to the current systems of assessment in the two regions. The next section will brie?y describe crop production and outline the main drivers for its expansion and associated expectations for future perennial biomass crop planting in the two regions. This is followed by an explanation of the methodological approach used in order to, ?rstly, identify the typical impacts associated with expected land use change in each region and, secondly, the procedure used to evaluate the effectiveness of the assessment systems. The results will then highlight the most important impacts of biomass production in (the state of) Sao Paulo and England to demonstrate the ? importance of effective evaluation. This will be followed by the environmental assessment system evaluation itself. Finally, the learning the systems in Sao Paulo and England can ? take from each other, and from the evaluation of effectiveness, will be presented.

1.1. Brief description of the ethanol sector in Sao Paulo ? and the biomass sector in England
Sao Paulo is the Brazilian leader in renewable energy ? producing almost 51% of its internal needs for energy (30% sugarcane; 17% hydraulic power, 2% charcoal and ?rewood and 2% other renewable sources [16]). For England, statistics are available only at the national (UK) level where renewables and waste accounted for almost 2% of the total production of primary fuels [17]. With regard to renewable sources, in 2008, biomass represented 81% of the amount of renewables (26.7% land?ll gas, 4.1% sewage gas, 6.1% domestic wood, 1.8% industrial wood, 9.1% waste combustion, 9.0% co-?ring, 5.0% animal biomass, 5.3% plant biomass and 14.0% liquid biofuels). Of the 247 PJ of primary energy use accounted for by renewables, energy crops answered for only 0.3% by weight of the feedstock burned to produce electricity and/or heat [1].

1.2. The ethanol market in Sao Paulo and the biomass ? market in England
The use of ethanol on a large-scale was launched in 1975 with a Brazilian Federal Government Programme, termed ‘Proalcool’, in order to encourage the redirection of some sugarcane production to generate fuel thus decreasing petrol imports. In Brazil in 2003, the ?ex-fuel vehicle was introduced which operates with any percentage of ethanol-gasoline blend and

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even with pure (hydrated) ethanol [18]. In 2008 in Brazil, for the ?rst time in twenty years, the ethanol volume used as fuel in light vehicles exceeded the gasoline volume [7]; the predicted increased use of ?ex-fuel cars would suggest that demand for ethanol will double in the 10 years from 2008 to 2018 [16]. In Sao Paulo ethanol is provided exclusively by sugarcane ? crops. In the harvest of 2008/2009 27.5 hm3 of sugarcane ethanol was produced in Brazil of which Sao Paulo contributed ? 16.7 hm3 [19]. In 2006 the sugarcane crop in Sao Paulo repre? sented almost 60% of the total cultivated area of the state [20]. Brazil uses 85% of its production domestically, while 15% is exported to the US, Caribbean Basin Initiative (CBI), EU and others. Brazilian ethanol production is likely to double from 2006 levels (17.8 hm3) by 2012/2013 to 36 hm3 per year, replacing approximately 50% of the gasoline that otherwise would be used in the country. In order to meet this demand 49,000 km2 (in 2006 62,000 km2 was cropped to produce sugar of which only 29,000 km2 was used to produce ethanol) of sugarcane crops will be needed. In the European Union, the Renewable Energy Directive [21] and Fuel Quality Directive [22] have placed strict obligations on all member states to achieve targets which are likely to have implications beyond their borders. The Fuel Quality Directive requires that GHG emissions from transport are reduced by at least 6% in all member states by 2020, whilst the Renewable Energy Directive requires that each member state shall ensure that the “share of energy from renewable sources in all forms of transport in 2020 is at least 10% of the ?nal consumption of energy in transport in that Member State” ([21], Article 3, paragraph 4). In March 2007, the European Council agreed to, amongst other things, a binding target of a 20% share of renewable energies in overall EU consumption by 2020. This target applies to transport and heating as well as the generation of electricity [23] and biomass will have a central role to play in meeting this requirement [1]. The UK Government’s strategy for biomass [1] is intended to realise a major expansion in the supply and use of biomass in the UK. The additional area of perennial energy crops required in the UK in order to meet the strategy is almost 3500 km2 by 2020, rising from just 150 km2 grown in 2008 [2]. With regard to bioenergy crop expansion in England, as a feedstock, short rotation coppice (SRC) and miscanthus are expected to play an important role due to the ?nancial incentives available through the Energy Crops Scheme [24] that provides support for these crops at a rate of 50% of actual (veri?able) costs.

reduced to a manageable list of impact areas of concern based on their frequency of occurrence in the literature. The eleven key issues of concern were: water resources; water and soil pollution; residues; soil erosion; land use change, deforestation and biodiversity; air emissions; energy balance and GHG; waste management; food security; labour conditions and workers rights; social responsibility and bene?ts; jobs, wages, income distribution and land ownership [26]. In order to evaluate effectiveness of the environmental assessment systems in place, we must ?rst de?ne what we mean by ‘effective’. With reference to the literature, effectiveness can be categorised into 4 types: procedural, substantive, transactive, and normative effectiveness [27]. Procedural effectiveness expresses that the assessment complies with acceptable standards and principles, substantive effectiveness indicates the achievement of expected objectives, and transactive effectiveness denotes that the outcomes have been obtained with the least cost in the minimum timeframe [28]. In addition, normative effectiveness has been de?ned as the extent to which the process achieves its normative goals, that is, sustainable development [29]. We assume in this research that all these categories have some in?uence in determining overall effectiveness. In order to compare the assessment systems in Sao Paulo ? and England a set of criteria have been developed based on the literature. Such an approach has been successfully applied in comparative reviews of assessment systems [30,31], although criteria are typically related speci?cally to procedural stages of the assessment processes under review whereas we have added criteria for substantive, transactive and normative effectiveness. Table 1 sets out the criteria identi?ed from the literature to be used in this study.


Results and discussion

3.1. Typical impacts associated with land use change to accommodate bioenergy crops
Results are presented in a tabular format for both Sao Pau? lo and England, drawing on the literature to highlight the potential impacts which might be caused by land use change to bioenergy crops. The speci?c nature of impacts will depend on both the local geographical context and the existing land use prior to change, so Table 2, which identi?es the main issues related to sugarcane expansion in Sao Paulo, ? and Table 3 to bioenergy crop planting in England, are intended to do no more that accredit the possibility for adverse impacts. It should be recognized that the purpose of the tables is not to cross-reference, to compare or to qualify these impacts. With regard to English bioenergy crops, the ecological implications are complex, because the impacts vary between scales, in that the conversion of large areas of land to monocultures of bioenergy crops may have locally damaging consequences, but could contribute to the global reduction of GHG production. There are substantial uncertainties over these potential impacts and strong dependencies on the management of the bioenergy projects across their whole life cycle [56]. In general, for environmental impacts, less is



To recognize the environmental, social and economic impacts related to ethanol production in Sao Paulo and the forecasts ? for biomass from non-food crops in England, the approach taken drew on a methodological approach which emphasised, in the context of measuring the achievement of sustainable development, the importance of appropriately balancing the social, economic and environmental criteria [25]. A large number of potential impacts related to land use change associated with energy crops have been identi?ed and


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Table 1 e Criteria for evaluating current appraisal systems for biomass crops. Criteria (effectiveness category)
1. Legal basis (procedural) 2. Guidance (procedural) 3. Level of assessment (procedural) 4. Sustainable Development (normative) 5. Socio-ecological system integrity (normative) 6. Consultation and public participation (substantive) 7. Intergenerational equity (normative) 8. Decision-making (substantive) 9. Timeliness (transactive) 10. Credibility (substantive)

Clear legal mandate for conducting environmental assessment at strategic and project levels Does guidance exist which sets out how to conduct appraisal of biomass crop planting? Is the level/scale of assessment appropriate for the biomass crop planting? Is the concept of sustainable development integral to the assessment process(es)? Does the assessment consider the integrity of the socio-biophysical system? Does consultation and public participation take place within the assessment system leading to action? Does the assessment consider future generations and act in their interests? Does the assessment have any discernible effect on the decisions taken? Information is available in a timely manner (so assessment is ex ante and not post hoc) Robustness and consistency of assessments (reducing bias)

[28, 30, 31] [28, 30] [28, 32] [30, 32, 33] [34] [28, 30-33] [34] [28, 30, 31] [27, 28, 32, 33] [33]

known about the consequences of large-scale deployment of miscanthus, compared to SRC willow, including effects on biodiversity and hydrology and this requires further research [6]. Table 3 sets out the current state of knowledge over the implications of planting these crops.

3.2. 3.2.1.

Current appraisal system in Sao Paulo and England ? Sa Paulo ?o

The current appraisal system in Brazil is supported by the Environmental Impact Assessment (EIA) tool. The institutional framework for EIA in Brazil is highly centralized and shows considerable variations in implementation among different states, with some examples of good practice, especially in the southern and southeastern states [57], where Sao ? Paulo is situated. EIA was introduced in Brazil in 1981 with Federal Law 6.938 which required the production of an Environmental Impact Statement (EIS) for certain projects. Subsequent decrees have set out the speci?c details of how the EIA process must operate. In Sao Paulo, Resolution SMA (the Sao Paulo Secre? ? tariat for the Environment) 42/94, seeking to improve screening in the EIA process, created a lower level of assessment through the submission of a Preliminary Environmental Report (PER), for undertakings whose potential impacts are deemed to be less signi?cant. Resolution SMA 54/04 retains the PER and provides a new kind of environmental study, the Simpli?ed Environmental Study (for enterprises deemed not to create signi?cant impacts). Authors cite a number of problems in relation to the practice of EIA in Brazil prior to the year 2000 (for example [57,58]). Since 2000, a great deal of improvement and experience has been gained in Brazil [59] mainly in Sao Paulo, that ? has highly trained and skilled technical staff and experience of practical EIA follow up [60,61]. Research also highlights that the project EIA process is quite robust in the State, based on 20 years of continuous experience, although the absence of Strategic Environmental Assessment is considered to be a signi?cant weakness [62].

Every new sugarcane enterprise or the expansion of existing undertakings to produce ethanol that involves sugarcane crops has to submit an environmental study (EIS or PER), and must comply with the existing legal and Governmental requirements and laws for this sector (both the agricultural and the industrial sector from the sugarcane industry) to obtain approval. Resolution SMA 42/06 stipulates that: i) new sugarcane plants with a crushing capacity of less than 50 kt a?1 or expanding production with a crushing capacity of less than 200 kt a?1 do not need an environmental study presentation; ii) new industries with a crushing capacity of more than 50 kt a?1; expanding production with a crushing capacity of more than 200 kt a?1; total or partial replacement of sugarcane production for ethanol production; and expanding of sugarcane cropping which affects fragile environmental areas need a PER; iii) new industries with a crushing capacity of equal to or more than 1.5 Mt a?1 in accordance with Agri-environmental Zoning need an EIS. Agri-environmental Zoning was introduced by Resolution SMA/SAA 4/08 (Sao Paulo Secretariat for the Environmental and ? Sao Paulo Secretariat for the Agriculture) (and subsequently ? amended) and is an initiative to tackle the shortcomings of the EIA approach which is primarily reactive in assessing the implications of sugarcane planting proposals developed in locations speci?ed by the proponent and in isolation from other proposals. It introduces zoning guidelines speci?cally applied to new ethanol projects, as shown in Fig. 1. It is a zoning proposal for sugarcane crops based on the following factors that relate to the whole of Sao Paulo: soil and climate conditions; slope and ? aptitude for mechanical harvesting; current air quality as compared to quality standards; aquifer vulnerability; surface water availability; existing protected areas or restricted use areas and buffer zones; areas considered as a priority for biodiversity protection. Table 4 presents the main requirements for the approval of new projects.



The current appraisal system in the majority of development initiatives in England is focused on the spatial (land use)

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Table 2 e Main issues identi?ed in the literature related to sugarcane expansion to produce sugarcane ethanol in Sao Paulo ? [26]. Issue
Environmental Water resources

The process to convert cane into ethanol requires large amounts of water both in the agricultural and industrial processes; however the water re-use level has been increasing and other techniques to reduce the consumption of water and rates have been strongly decreasing in recent year [35e37]. During the process of cropping sugarcane and producing ethanol there are pollutants that can cause water and soil pollution. For example, organic pollutants, of which the major wastewater ?ow is ‘vinasse’, and inorganic substances that can cause damage to soil and water similar to pesticides and fertilizers. Many types of residues are produced by the sugarcane industry, such as ‘bagasse’ and straw which are generated in enormous quantities, and ?lter cake. Part of these residues is used for example for cogeneration. Soil erosion in sugarcane crops is generally limited compared to conventional agricultural harvests, however soil losses for sugarcane may vary dramatically from 10 t km?2 a?1 to 10.9 kt km?2 a?1, depending on many factors such as the angle of slope, the annual rainfall, the management and harvesting system [11]. The occurrence of direct impacts on biodiversity is limited. In recent years the expansion of the sugarcane sector has mainly replaced pastures and/or food crops and sugarcane production operates far from the major biomes in Brazil. This expansion is argued not to lead to replacement of native forest by this crop, except in very speci?c situations; however some con?icts are identi?ed where crops are grown in biodiversity conservation hotspots [15]. The impacts associated with air emissions caused by sugarcane burning will be enormously reduced due to legislation, established in 2003, that forbids this practice for areas that use mechanical harvesting from 2021, and for areas that use non-mechanical harvesting from 2031. There are impacts associated with the co-generation of heat and electricity. The levels of NOx and particulate material are near to the limits allowed and in some situations exceed them [38]. Despite some doubts about addressing indirect land-use change in the analysis of energy balance and GHG (Renewable Fuels Agency, 2008), the ethanol from sugarcane is recognized as one of the best options to reduce emissions of GHG compared to petrol fuel [39]. The energy balance is highly positive if compared to the petrol industry [40, 41]. Only part of vinasse and wastewater is used in fertirrigation. For economic reasons waste disposal takes place within 15e30 km of the ethanol plant. This practice causes risks to groundwater recharge areas by nitrate contamination. Non-sealed tanks are potential hotspots of pollution. Washed packages usually are disposed of in land?lls. However it is dif?cult to control inappropriate practices that can cause environmental liabilities [42]. This is a very controversial issue related to Brazilian sugarcane crops. Some researchers believe that sugarcane crops directly in?uence and impose restrictions upon the production of food crops, in both Sao Paulo and surrounding Brazilian states [41]. However, during the period 2002-2006, sugarcane ? expansion is argued to have occurred in Sao Paulo mainly on land previously used for cattle ranching, ? thus not pressuring food crops [37]. The main problem with respect to labour conditions is related to manual cane harvesting [11]. Mechanical harvesting is presently used as a standard for productivity. Owing to the targets for cane cutting, only a small number of women work in sugarcane cutting and there are problems for migrant and temporary workers. Some workers rights violations have been reported [37]. In contrast to this, in 2003 the rate of regular jobs in sugarcane production (agriculture) represented 88% of all agricultural jobs in Sao Paulo [11]. ? The ethanol production sector maintains more than 600 schools, 200 nursery centres and 300 day care units and other kinds of bene?ts but there is a scarcity of information about the absolute life conditions of the workers in the sugarcane and ethanol industry [11]. For every 300 Mt of sugarcane produced, approximately 700,000 jobs are estimated to be created [37]. The workers receive, on average, wages that are 80% higher than those of workers holding other agricultural jobs [40]. About 25% of sugarcane is produced by independent, relatively small farmers who sell their production to the mills. The remaining part is produced on lands either owned or rented by the mills’ owners [11, 40].

Water and soil pollution


Soil erosion

Land use change, deforestation and biodiversity

Air emissions

Energy balance and GHG

Waste Management


Food security

Labour conditions and workers rights

Social Responsibility and Bene?ts Economic Jobs, wages, income distribution and land ownership

planning system for which the principal act is the Town and Country Planning Act 1990 as amended. This Act controls “development” through the preparation of spatial plans. There is a very well developed environmental assessment system associated with planning, which requires both SEA and EIA under legislation implemented to meet the obligations of European Union Directives [63,64]. In addition, the Planning and Compulsory Purchase Act 2004 [65], which amended the Town and Country Planning Act 1990 introduced

a speci?c requirement in England for spatial plans to be subjected to Sustainability Appraisal (SA); this has a broader scope than SEA and, therefore, the Government published guidance on how SA might be conducted to meet the requirements of the SEA Directive [66]. Despite the existence of a well developed environmental assessment system, agricultural planting is largely excluded. Such activity is not incorporated within the de?nition of “development” and, notwithstanding the inclusion of the


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Table 3 e Main issues identi?ed in the literature related to perennial crops in England. Issue
Environmental Water resources

It is generally expected that miscanthus and SRC will have higher water demands than arable crops due to a combination of higher growth rates, elevated transpiration rates, longer seasonal growth and increased rooting depth and complexity [6]. For the same rainfall and soils, the water use of the energy grasses is likely to be less or comparable to that of the existing land cover where it is grass or tilled land and less if the existing land cover is woodland or heathland; and the results for SRC show a very high water use [43]. The extended growing season, high evapotranspiration rates and extensive root systems of SRC and miscanthus plantations has lead to much interest in the effect these plantations may have on nitrogen cycling, leaching and related changes in water quality [6]. Research has shown that both miscanthus and SRC require fewer inputs of fertilizer and pesticides than conventional crops [e.g. 44]. It has been shown that nitrate leaching from land under miscanthus was closer in value to rates recorded under extensively managed grassland rather than arable land [44]. The economic implications of ash disposal for electricity generation from biomass has been calculated, with the amount of ash being dependent on feedstock [45]. The assumption is made the ash needs to be land?lled, although this presupposes contamination which would be the case where biomass was co-?red. However, where wood ash is created, a portion can be used as forestry fertiliser, though the extent to which this is possible depends on combustion technology and settings [46]. Miscanthus and SRC have a potential for improved physical soil properties due to the role these compounds play in soil aggregate formation and stability and lead to reduced run-off and thus decrease the erosion process [6]. While SRC can increase avian diversity compared to arable crops, it represents a poorer habitat than many natural and semi-natural habitats such as ancient woodland, wet meadows and unimproved grassland. Miscanthus plantations may not support as many species as SRC plantations. Although both plantations could be generally regarded as bene?cial for biodiversity in an agricultural setting, they are not a substitute for natural and semi-natural habitats [6]. Using one butter?y biodiversity indicator, researchers have produced a study that suggests that dedicated biomass crops placed in arable farmland could be used to provide habitat for intrinsically interesting butter?ies, whilst not providing a source of economically harmful pest species [47]. Most emissions from biomass have been found to be associated with combustion end use [48]. A comparison of CO2, CH4, N2O emissions for a range of biofuels with that of conventional sources of energy found that total GHG requirements (in kg equivalent of CO2/MJ) were less for biofuels and biomass, but that the major savings related to CO2 as, depending on the technology, N20 and CH4 emissions associated with bioenergy crops could be higher than conventional sources [49]. A key variable is life cycle emissions related to the quantity of nitrogen fertiliser needed as its production demands considerable energy use [50]. There is a general consensus that the conversion of arable land to SRC or miscanthus will result in an increase in carbon sequestration, while the conversion of grassland may not be as bene?cial. In addition the extensive roots systems characteristic of SRC and miscanthus result in large below ground biomass storage, further improving the carbon mitigation potential of these plantations in addition to improving soil texture [6]. There have been a limited number of models constructed in relation to miscanthus, one of them concluded that inputs of pesticides, fertiliser and harvesting have the strongest negative impact on GHG emission and energy balance for this crop, while the energy ratio is most sensitive to changes in yield. The same study also suggested that energy grasses have a higher energy ratio and lower GHG emission than SRC, although other models refute this point [6]. For perennial biomass crops, the entire crop is harvested and so residual wastes are not a signi?cant issue. However, it has been suggested that these (non-food) crops can be used to dispose of waste, including sewage sludge. For SRC, evidence suggests NePeK rich ef?uent can be spread on the crop without threatening groundwater quality [51]. Advice to farmers recommends spreading of sewage sludge on SRC [52] and miscanthus [53]. First of all, they are non-food crops. According to some projected scenarios [8], if strategic land use and economic planning are taken into account, the non-crop food expansion in arable land would not necessarily greatly impact on UK food security. However, this conclusion is based on expansion to meet UK Biomass Strategy targets only. No information is available on labour conditions and workers rights.

Water and soil pollution


Soil erosion

Land use change, deforestation and biodiversity

Air emissions

Energy balance and GHG

Waste Management


Food security

Labour conditions and workers rights Social Responsibility and Bene?ts

The current small-scale of planting has not led to any academic interest over the potential for social responsibility and bene?ts. However, social bene?ts can accrue where biomass crops are used as a means of remediating contaminated land [54], although contaminants would be present in the ash after combustion.

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Table 3 (continued). Issue
Economic Jobs, wages, income distribution and land ownership

Miscanthus requires 25% more direct agricultural jobs than does SRC [55], however, SRC employs a tenth the number of agricultural workers as the equivalent area of arable crops. They further calculate that 1.27 man years/GWh of electricity are created in power plants associated with either crop when producing electricity only. Currently only 150 km2 of land is growing biomass crops [47], with individual farmers choosing to enter into contracts with end users or through dedicated biomass crop companies.

agricultural sector within the scope of the SEA and EIA Directives, no SEAs are conducted because there is no formal plansystem for agriculture. At the project level, speci?c regulations to implement EIA apply only to uncultivated land or seminatural areas (which tend to be largely grassland and, therefore, perennial) [67]. As such, they are unlikely to apply to bioenergy crop planting as these tend to replace existing arable crops. This means that expansion of bioenergy crops even on a large-scale basis is currently undertaken without appraisal in the UK [47]. The only exception would be where planting might affect a site designated as a Special Protection Area under the EU Birds Directive [68], or a Special Area of Conservation under the EU Habitats Directive [69] (collectively these sites are known as Natura 2000 sites). Planting would not be allowed to proceed if these sites were adversely affected unless it could be demonstrated (through an ‘Appropriate Assessment’) that there were Imperative Reasons of Overriding Public Interest (IROPI). One potential exception where EIA might have some in?uence is where the end use, for example a new biomass electricity generating plant, is itself subject to EIA through the need for planning permission. One particular proposal for an advanced gasi?er using miscanthus feedstock has been subjected to the EIA process. Some of the relevant concerns, mainly environmental, were identi?ed using survey questionnaires distributed to local people and are reported elsewhere [70e73].

There is some experience of trying to appraise the implications of signi?cantly increasing the planting of bioenergy crops through a Research Councils UK funded project, termed Relu-Biomass, that performed a holistic assessment of the potential impacts of increasing rural land use of miscanthus and SRC, focusing on two study regions e the South-West and the East Midlands both in England. This project has brought together experts from the ?elds of crop science, biodiversity and ecology, hydrology, social science and geography and rural economics, and has provided an integrated, interdisciplinary scienti?c evaluation of the implications of land conversion to energy crops. There are some available results based on the ReluBiomass project. Researchers used an empirical model with GIS to produce a yield map of the UK potential and a constraints map identifying the land areas where biomass crops should be planted to minimise impacts whilst still obtaining viable yields [8]. A biomass-planting-speci?c Sustainability Appraisal Framework was then introduced to recognize the implications for social, economic and environmental indicators of planting in the unconstrained areas [74]. This approach was taken as dialogue with stakeholders had expressed a concern that SA might lead to trade off decisions which allowed bioenergy crops to be planted on sensitive habitats. Thus, the constraints mapping excludes these

Fig. 1 e Agri-environmental Zoning: (modi?ed from [20]).


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Table 4 e Requirements for the approval of new projects in Sao Paulo. ? Type of zoning
In suitable areas

Main requirements
 appropriate environmental study (PER or EIS) in accordance with Resolution SMA 42/2006  Maximum water consumption 1 m3 t?1 of processed sugarcane  Rehabilitation of riparian vegetation  EIS  Continuous air emissions moni toring (particulate matter and NOx)  Detailed study of aquifer vulnerability  Underground water monitoring and target of maximum nitrate concentration of 5 mg m?3  Maximum water consumption 1 m3 t?1 of processed sugarcane  Full protection of remaining natural vegetation stands and wetlands  Landscape ecology studies to support any request to fell isolated remaining trees  As above and  Establishment of ecological corridors  Fauna monitoring during operation  Maximum water consumption 0.7 m3 t?1 of processed sugarcane  Detailed landscape ecology and ecological studies New projects are forbidden

In areas considered as suitable with environmental limitations

In areas considered as suitable with environmental constraints

In unsuitable areas Source [20].

habitats and the SA provides evidence on where best to plant in the remaining land area. The remaining issue is how such an SA, which has no statutory basis in England, can in?uence decision-making. Ultimately, farmers make their own decisions on which crops to plant and where they will plant them. The only signi?cant in?uence that can be brought to bear is through ?nancial incentives. For example, Natural England (which is a nondepartment public body of the UK Government) manage an Energy Crops Scheme whereby farmers can claim back some of the costs of planting energy crops. Thus, there is the potential for Natural England to be in?uenced in terms of which areas of land they will agree to ?nance under this scheme.

3.2.3. Evaluation of the effectiveness of the assessment systems
Table 5 sets out the evaluation of the effectiveness of the assessment systems in Sao Paulo and England based ? on the criteria developed for this purpose presented in Table 1.

It is clear from the analysis that neither system can be considered to be effective against all of the criteria. A particular failing is the lack of strategic assessment in either region. The limitations of project level EIA, where it does take place, in terms of managing cumulative impacts and considering alternatives is well documented (see, for example [76e78]). In addition, the real in?uence of EIA in decision-making can be very limited because it occurs in the latter stages of development proposals where important decisions related to a land use plan are already agreed. In England, the main shortcoming is related to the lack of legal requirement for any form of assessment, apart from limited cases where a Natura 2000 site may be affected or where the proposal is to plant energy crops on previously uncultivated land (which is considered to be unlikely). The critical issue appears to be the lack of any legal framework for decision-making in the agricultural sector because planting of speci?c crops is not considered to be development as de?ned by planning legislation. Whilst the potential need for an appropriate assessment does help to protect the Natura 2000 network against inadvertent damage by farmers, it does not cover any other land use change, for example from pasture land to arable, or arable to energy crops, irrespective of the scale of the change. The decision to change a crop is entirely down to the individual land owners and farmers. In this context, it might be argued that the Environmental Assessment Directive has failed to envisage the potential signi?cance of impacts associated with land use change on a scale not envisaged when the Directive was adopted in 1985, or subsequently amended. The 1985 Directive failed to require EIA for golf courses, for example, an omission which was recti?ed in subsequent amendments [79]. The Sao Paulo assessment system at the project level is ? focused on environmental impacts and their mitigation. However, with regard to the full consideration of environmental impacts (Table 2), the environmental assessment process has been found to have a restricted scope [26]. In addition, the focus is very much directed at new ethanol plants and captures the impacts of land use change through increased sugarcane planting as an indirect consequence. On these lines, it could be argued that EIA does take place for energy crop planting in England, where it is to be associated with a new biomass power plant. However, planting currently takes place to feed co-?ring in existing power plants (which therefore bypasses EIA), or where new power plants are proposed for power plants to use energy crops as the primary feedstock, off-site impacts (i.e. those caused by land use change) are not typically considered beyond the transport implications of transporting the feedstock to the power plant. The constraints maps (Agri-environmental Zoning) used as a land use planning tool in Sao Paulo (and in England the ? studies conducted under the Relu-biomass project) have demonstrated approaches for managing land use change associated with bioenergy crop planting, although it is only in Sao Paulo that this approach has a formal status. In both ? regions, formal strategic assessment of the land use change implications would be bene?cial to the future sustainability of agricultural practice.

Table 5 e Evaluation of environmental assessment of ethanol expansion in Sao Paulo and energy crop expansion in England. ? Criteria
1. Legal basis

Sao Paulo ?
Partially. Legal mandate for conducting assessment only at the project level.

There is no legal mandate for conducting assessment at different levels except where previously uncultivated land would be planted. Appropriate Assessment would be required under the EU Habitats Directive if planting was proposed which might affect a Natura 2000 site. Guidance exists only for the case of planting on uncultivated land or for conducting an Appropriate Assessment. There is partial assessment at the project level in some speci?c cases outlined above only. Appropriate Assessments and EIAs conducted for uncultivated areas would have a primarily environmental focus. Most planting would not be formally considered for sustainability implications. There is no commitment to socio-economic integrity.

2. Guidance

3. Level of assessment

4. Sustainable Development

Partially. There is formal guidance on conducting assessment at the project level. In order to tackle cumulative impacts related only to environmental aspects Agrienvironmental Zoning was developed in 2008. The level of assessment focuses only on particular projects. Agri-environmental Zoning could overcome part of this weakness for new undertakings related to their environmental aspects. In theory the assessments should cover all issues, but in practice there is a lack of consideration of social and economic aspects (see [26]). Partially. Some social aspects are not well integrated with biophysical aspects in the EIS and PER. A mismatch has been identi?ed between the predominantly environmental issues investigated by EIAs and PERs, and the full range of implications of planting identi?ed by the literature [26]. Partially. In general public participation and consultation takes place in the process after the EIS is presented to the environmental department for analysis. However there is a legal guarantee that results from public hearings and Consema analysis have to be considered in the decision-making process. No. Intergenerational equity is not an explicit objective of the EIA process in practice, although it may be an implicit outcome.

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5. Socio-ecological system integrity

6. Consultation and public participation

7. Intergenerational equity

8. Decision-making

Partially and only for project level. For some cases with regard to speci?c environmental aspects the assessment can contribute to improving the decision. For others the in?uence of the EIA process on decision-making can be very limited. No research has yet been conducted to try and measure speci?c in?uence on decisions of the EIAs. Partially. In the majority of cases the information is available after the EIS is completed, which precedes consultation and public participation, but comes after the main project aspects have been decided. Partially. The EIA process is often criticized because the consultation and decision stages occur late in the decision-making process and consultation and public participation occur generally after EIS or PER are completed. The Sao Paulo Secretariat for the ? Environment provides technical expertise to analyse the EIS or PER that in theory assures independency and credibility. The EIS or PER is prepared by the proponent that pays a prede?ned tax.

9. Timeliness

10. Credibility

Where EIA or Appropriate Assessment were undertaken, public participation would feature. However, in all other cases, there would be no consultation or public participation (other than that associated with a new power plant should one be built). There is currently limited evidence of the extent to which this would be covered in EIAs for uncultivated land; the assumption for Appropriate Assessment is that the Natura 2000 site should remain in place for future generations. In the absence of SEA and EIA, decision making is not normally in?uenced. For Appropriate Assessment, there is considerable in?uence on decisions and the assessments can stop development. For EIAs on uncultivated land, research from the spatial planning sector suggests in?uence would exist but would be limited [75]. In the absence of SEA and EIA, the assessment is not timely. Appropriate Assessment, if needed, would be timely. EIA of uncultivated land would, in practice, be expected to respond to proposals already made rather than help to in?uence the proposals. This is not applicable where there is no assessment. For Appropriate Assessment and EIA for uncultivated land, credibility is ensured, to an extent, by the involvement of statutory consultees with an environmental remit in the assessment, such as Natural England. Irrespective of this, the proponent pays for the assessment and some bias can be introduced.



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Conclusions and recommendations

The main world drivers supporting the expansion of bioenergy crops are primarily related to climate change and energy security. Accordingly, Sao Paulo and England have ? been experimenting at different levels in the development of their bioenergy industries. The former has a huge internal market that consolidates the sugarcane industry and there are forecasts of a massive increase in land use for the purpose of satisfying the demand from ?ex-fuel vehicles. With respect to the latter the forecast is of exponential growth in miscanthus and SRC in order to ful?l national strategic targets and international obligations. There are clear and tangible bene?ts of biomass crops regarding different aspects discussed in detail by some authors [6,7,11,16,39,40,47,80e82], however the concerns arising have to be appropriately understood. There are many potential impacts related to sugarcane crop expansion in Sao Paulo and to perennial crop expansion ? in England and, in order to determine the effectiveness of the assessment systems to identify the potential impacts from land use change, a set of criteria was developed and applied. We recognise that the understanding of the term ‘effectiveness’ is heavily contested [74,83] and we would caution that our approach is unlikely to be universally accepted as an appropriate de?nition. However, we have encompassed all recognised categories of effectiveness in our approach which, in combination, does make some attempt to acknowledge and accommodate a variety of theoretical perspectives on the effectiveness of EIA [84]. The Sao Paulo assessment system is focused on the project ? level, although a more strategic approach, through Agrienvironmental Zoning, exists for protecting some environmental aspects. In England, there is no legal mandate for conducting assessment at different levels for land use change to bioenergy crops except in some (unlikely) situations where protected areas are threatened, or uncultivated land is developed. Thus in both regions, there is considerable opportunity for signi?cant land use change in a context where the decision-making powers of the Government are limited, and so the opportunities to avoid or mitigate signi?cant impacts are absent. In Sao Paulo there is evidence of procedural effectiveness ? for individual projects, but the research suggests that more engagement with citizens and stakeholders early in the decision-making process, along with a broader scope encompassing all three pillars of sustainability (social, economic and environmental) in line with the anticipated implications is needed (see also [26]). In England, there is limited scope for any effectiveness because, as it stands, there is no decisionmaking structure in place for the majority of agricultural land use change. Thus, EIA is unlikely to be required for perennial biomass crops. To overcome this omission, some consideration should be given to the scale of planting which is considered signi?cant enough to trigger EIA. Previous research has identi?ed a mismatch between the geographical scale at which assessment tends to be applied and the scale at which impacts occur [74]. Our analysis had identi?ed a similar problem in relation to assessment practice for land use change involving perennial bioenergy crops. The

scale of planting is such that a strategic overview is required to fully acknowledge the impacts. For example, development on the scale of individual farms is not likely to demonstrate signi?cant implications for GHG emissions, whereas on a regional scale, it might. This suggests that some form of SEA is required that, in line with the ?ndings for EIA, has a broader sustainability scope. Agri-environmental Zoning used in Sao ? Paulo is a step in the right direction, and a similar approach has been taken in the UK [8]. However, these constraints mapping approaches need to feed into a broader consideration of sustainability implications. This, of course, has ?nancial implications and imposes obligations on the state, rather than on developers (the typical EIA model follows the polluter pays philosophy), however, it is more likely to lead to better planned land use change, and has the potential to reduce the need for EIAs written for inappropriate project proposals.

This paper draws on evidence gathered in the RELU-Biomass project (http://www.relu-biomass.org.uk) funded under the Rural Economy and Land Use programme of the ESRC, BBSRC and NERC.


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