Mandatory Requirements in Relation to Air, Soil, or Water Protection: Analysis of Need and Feasibility - Final Report (Tasks 3 and 4). Diaz-Chavez, R.; Kunen, E.; Walden, D.; Fingerman, K.; Arya, L.; Chalmers, J.; Kretschmer, B.; Poláková, J.; Farmer, A.; Bowyer, C.; Menadue, H.; Alberici, S.; and Toop, G.
Mandatory Requirements in Relation to Air, Soil, or Water Protection: Analysis of Need and Feasibility - Final Report (Tasks 3 and 4) [pdf]Paper  abstract   bibtex   
Summary. This report presents the results of Task 3, the Analysis of the need to introduce mandatory requirements in relation to air, soil, or water protection and Task 4 the Analysis of the feasibility to introduce mandatory requirements in relation to air, soil or water protection in the context of the overall project for the Commission ” Study on the operation of the system for the biofuels and bioliquids sustainability scheme” (ENER/C1/2010-431). The main intention in encouraging an increase in biofuel use is the delivery of environmental and climate benefits. The Renewable Energy Directive (RED) set a target of 10\,% renewable energy in transport in all European Union (EU) Member States, which is envisaged to stimulate an increase in biofuel production and use. The increase in feedstock production is expected to take place both within the EU and outside. As such, it is appropriate for the RED to consider criteria that ensure that the cultivation of feedstocks used for biofuel consumption in the EU does not cause negative environmental impacts. The RED already contains mandatory sustainability criteria related to GHG emissions, biodiversity and carbon stock. This report explores the impacts of expansion and intensification of agricultural production for biofuel purposes on soil and water resources leading to air pollution. Criteria for addressing soil quality have been proposed, for example, by the ” RED plus” sustainability criteria developed under the Biomass Futures project and the indicators suggested are to ” avoid erosion” and ” maintain SOC” 1 . Given the need to avoid negative environmental impacts of biofuel use, it is important for the European Commission (EC) to understand the potential risks for soil, air and water resources in countries producing biofuels and/or their feedstocks. This is expected to facilitate the development of an appropriate policy response with the aim of ensuring the environmental integrity of biofuels and bioliquids consumed in the EU. An assessment presenting the environmental risks of some of the main crops used as feedstocks for biofuel production is presented in this report, and has informed the analysis of the need for mandatory criteria to protect soil, air and water. Following that, the feasibility of introducing mandatory criteria is discussed. The report concludes that considerable potential risks to sustainability from biofuel cultivation exist, particularly risks to soils and to water quality an d water availability. Given these risks to valuable non-renewable resources, introducing some form of environmental safeguards is necessary to avoid further aggravation of existing adverse impacts. Mitigation of these risks is critical not only for the sustainability of the resource base but also for ensuring continued provision of associated societal needs, including food and other ecosystem services. It is evident that the soil, water and air risks from feedstock cultivation for biofuel are on the whole the same as the risks from any kind of agricultural expansion. However, the study has found that in many situations, biofuel markets bring additional pressure on the areas under existing agricultural use and have acted as an important driver in the intensification and expansion of intensive agriculture into areas with challenging soil conditions in particular. Promoting good agricultural practices for the production of feedstocks used for biofuels, both within and outside the EU, through the RED, is likely to contribute to the mitigation of the risks identified. Good agricultural practice will vary depending on the type of crop and the prevailing bio-physical, environmental, and climatic conditions in diverse farming systems and has to be carefully targeted to these conditions. Applying mandatory quantitative criteria under the RED for protection of soils, water and air is therefore not feasible. This study recommends that greater emphasis be placed on targeted management practices to mitigate potential impacts on soils, water and air. We present in this report our key recommendations for soil, water and air. Apart from the specific recommendations, we propose that a minimum basic pre-condition on compliance with relevant existing legislation is put in place for soil, air and water: Biofuel production is required to be in compliance with national, regional and local soil/air/water protection legislation . The practicability of such a basic compliance criterion is demonstrated by its inclusion in many existing voluntary schemes. Compliance with national, region al and local legislation is also an element of, for example, the EU No 995/2010 Timber Regulation. A mandatory criterion requiring the existence of management plans (see Box 2) at farm level is proposed as a feasible way forward for soil and water management . In these plans, the farmer takes responsibility for identifying risks and designing management schemes which appropriately address the specific risks. It is recognised that management plans are not currently common practice in all countries, not even in the EU, and issues of effectiveness and enforceability must be addressed. However, management plans are already used in many countries and for many crops. Voluntary schemes, for example, already use the management plan requirement and report having achieved positive outcomes. Similarly, the EU Nitrates Directive requires nutrient management plans for farms in nitrate vulnerable zones. Consequently, this appears to be a feasible approach that provides a mandatory framework for improving management in specific farming systems involved in feedstock production whilst it gives sufficient flexibility to farmers to make choices about management practices that are adapted to their agronomic environmental, climatic and other bio-physical conditions. To take explicit account of risks to water availability from biofuel feedstock cultivation in sustainability criteria for water scarce regions is not straightforward. It may be hampered by political sensitivities and the fact that mitigation requires large scale approaches. However, there are some feasible solutions. For example, the EU Water Framework Directive contains the concept of river basin management plans (RBMPs), which identify regions at risk. Within those, farmers are being informed of effects of agricultural management on water in the region. The recently published EU Water Blueprint refines the understanding of priority actions to be taken in these regions and offers further opportunity for specifying sustainability criteria on the efficient use of water in agriculture for these regions. Water stress index maps are produced for regions outside the EU, which could serve as a basis for developing appropriate sustainability criteria for the imported feedstocks. Regarding air quality, three key recommendations are made to reduce risks from biofuel crops cultivation. Firstly, it is recommended to eliminate (where possible) open air burning. This entails avoiding or eliminating open-air burning of residues, wastes or by-products, and burning to clear the land. Permission to allow burning should be clearly limited and justified, for example: if workers' health and safety is at stake, or no viable alternative is available or affordable in the local context, or if burning is meant to prevent natural fires. The second recommendation on air is to reduce risks from processing facilities and from agrochemicals, and air emissions limits can be set for different production stages (e.g. at the farm, at the mill, at the processing facility) at national level. Monitoring systems must be put in place to ensure the emission s limits are met. The final recommendation is to reduce risks from agrochemicals by implementing management plans for agrochemical application following international standards and agreements. We also note that for the EU Member States, the existing mandatory RED criterion in Article 17(6) requires adherence to cross compliance requirements under the Common Agriculture Policy (CAP). We recommend clarifying that this provision of the RED will continue to apply to the revised cross compliance provisions given the forthcoming reform of the CAP. Finally, we note the important role voluntary schemes can play in advancing and implementing standards on soil, water and air. The voluntary schemes recognised by the EC allow certifiers to check an operator's compliance with the existing mandatory RED criteria. The advantage of this approach is that many of the existing voluntary certification schemes reach much further than the EC currently does in defining and certifying broad-based sustainability for bioenergy. Furthermore, some schemes are targeted to a particular feedstock and/or regional conditions and therefore have the local expertise needed to define management requirements targeted at local conditions.
@book{diaz-chavezMandatoryRequirementsRelation2013,
  title = {Mandatory Requirements in Relation to Air, Soil, or Water Protection: Analysis of Need and Feasibility - {{Final Report}} ({{Tasks}} 3 and 4)},
  author = {Diaz-Chavez, Rocio and Kunen, Emily and Walden, David and Fingerman, Kevin and Arya, Lalit and Chalmers, Jessica and Kretschmer, Bettina and Poláková, Jana and Farmer, Andrew and Bowyer, Catherine and Menadue, Henrietta and Alberici, Sacha and Toop, Gemma},
  date = {2013-02},
  url = {http://ec.europa.eu/energy/renewables/studies/doc/2013_tasks3and4_requirements_soil_air_water.pdf},
  abstract = {Summary. This report presents the results of Task 3, the Analysis of the need to introduce mandatory requirements in relation to air, soil, or water protection and Task 4 the Analysis of the feasibility to introduce mandatory requirements in relation to air, soil or water protection in the context of the overall project for the Commission ” Study on the operation of the system for the biofuels and bioliquids sustainability scheme” (ENER/C1/2010-431). The main intention in encouraging an increase in biofuel use is the delivery of environmental and climate benefits. The Renewable Energy Directive (RED) set a target of 10\,\% renewable energy in transport in all European Union (EU) Member States, which is envisaged to stimulate an increase in biofuel production and use. The increase in feedstock production is expected to take place both within the EU and outside. As such, it is appropriate for the RED to consider criteria that ensure that the cultivation of feedstocks used for biofuel consumption in the EU does not cause negative environmental impacts. The RED already contains mandatory sustainability criteria related to GHG emissions, biodiversity and carbon stock. This report explores the impacts of expansion and intensification of agricultural production for biofuel purposes on soil and water resources leading to air pollution. Criteria for addressing soil quality have been proposed, for example, by the ” RED plus” sustainability criteria developed under the Biomass Futures project and the indicators suggested are to ” avoid erosion” and ” maintain SOC” 1 . Given the need to avoid negative environmental impacts of biofuel use, it is important for the European Commission (EC) to understand the potential risks for soil, air and water resources in countries producing biofuels and/or their feedstocks. This is expected to facilitate the development of an appropriate policy response with the aim of ensuring the environmental integrity of biofuels and bioliquids consumed in the EU. An assessment presenting the environmental risks of some of the main crops used as feedstocks for biofuel production is presented in this report, and has informed the analysis of the need for mandatory criteria to protect soil, air and water. Following that, the feasibility of introducing mandatory criteria is discussed. The report concludes that considerable potential risks to sustainability from biofuel cultivation exist, particularly risks to soils and to water quality an d water availability. Given these risks to valuable non-renewable resources, introducing some form of environmental safeguards is necessary to avoid further aggravation of existing adverse impacts. Mitigation of these risks is critical not only for the sustainability of the resource base but also for ensuring continued provision of associated societal needs, including food and other ecosystem services. It is evident that the soil, water and air risks from feedstock cultivation for biofuel are on the whole the same as the risks from any kind of agricultural expansion. However, the study has found that in many situations, biofuel markets bring additional pressure on the areas under existing agricultural use and have acted as an important driver in the intensification and expansion of intensive agriculture into areas with challenging soil conditions in particular. Promoting good agricultural practices for the production of feedstocks used for biofuels, both within and outside the EU, through the RED, is likely to contribute to the mitigation of the risks identified. Good agricultural practice will vary depending on the type of crop and the prevailing bio-physical, environmental, and climatic conditions in diverse farming systems and has to be carefully targeted to these conditions. Applying mandatory quantitative criteria under the RED for protection of soils, water and air is therefore not feasible. This study recommends that greater emphasis be placed on targeted management practices to mitigate potential impacts on soils, water and air. We present in this report our key recommendations for soil, water and air. Apart from the specific recommendations, we propose that a minimum basic pre-condition on compliance with relevant existing legislation is put in place for soil, air and water: Biofuel production is required to be in compliance with national, regional and local soil/air/water protection legislation . The practicability of such a basic compliance criterion is demonstrated by its inclusion in many existing voluntary schemes. Compliance with national, region al and local legislation is also an element of, for example, the EU No 995/2010 Timber Regulation. A mandatory criterion requiring the existence of management plans (see Box 2) at farm level is proposed as a feasible way forward for soil and water management . In these plans, the farmer takes responsibility for identifying risks and designing management schemes which appropriately address the specific risks. It is recognised that management plans are not currently common practice in all countries, not even in the EU, and issues of effectiveness and enforceability must be addressed. However, management plans are already used in many countries and for many crops. Voluntary schemes, for example, already use the management plan requirement and report having achieved positive outcomes. Similarly, the EU Nitrates Directive requires nutrient management plans for farms in nitrate vulnerable zones. Consequently, this appears to be a feasible approach that provides a mandatory framework for improving management in specific farming systems involved in feedstock production whilst it gives sufficient flexibility to farmers to make choices about management practices that are adapted to their agronomic environmental, climatic and other bio-physical conditions. To take explicit account of risks to water availability from biofuel feedstock cultivation in sustainability criteria for water scarce regions is not straightforward. It may be hampered by political sensitivities and the fact that mitigation requires large scale approaches. However, there are some feasible solutions. For example, the EU Water Framework Directive contains the concept of river basin management plans (RBMPs), which identify regions at risk. Within those, farmers are being informed of effects of agricultural management on water in the region. The recently published EU Water Blueprint refines the understanding of priority actions to be taken in these regions and offers further opportunity for specifying sustainability criteria on the efficient use of water in agriculture for these regions. Water stress index maps are produced for regions outside the EU, which could serve as a basis for developing appropriate sustainability criteria for the imported feedstocks. Regarding air quality, three key recommendations are made to reduce risks from biofuel crops cultivation. Firstly, it is recommended to eliminate (where possible) open air burning. This entails avoiding or eliminating open-air burning of residues, wastes or by-products, and burning to clear the land. Permission to allow burning should be clearly limited and justified, for example: if workers' health and safety is at stake, or no viable alternative is available or affordable in the local context, or if burning is meant to prevent natural fires. The second recommendation on air is to reduce risks from processing facilities and from agrochemicals, and air emissions limits can be set for different production stages (e.g. at the farm, at the mill, at the processing facility) at national level. Monitoring systems must be put in place to ensure the emission s limits are met. The final recommendation is to reduce risks from agrochemicals by implementing management plans for agrochemical application following international standards and agreements. We also note that for the EU Member States, the existing mandatory RED criterion in Article 17(6) requires adherence to cross compliance requirements under the Common Agriculture Policy (CAP). We recommend clarifying that this provision of the RED will continue to apply to the revised cross compliance provisions given the forthcoming reform of the CAP. Finally, we note the important role voluntary schemes can play in advancing and implementing standards on soil, water and air. The voluntary schemes recognised by the EC allow certifiers to check an operator's compliance with the existing mandatory RED criteria. The advantage of this approach is that many of the existing voluntary certification schemes reach much further than the EC currently does in defining and certifying broad-based sustainability for bioenergy. Furthermore, some schemes are targeted to a particular feedstock and/or regional conditions and therefore have the local expertise needed to define management requirements targeted at local conditions.},
  keywords = {*imported-from-citeulike-INRMM,~INRMM-MiD:c-12632018,air-pollution,air-quality,multiauthor,protection,soil-resources,water-resources},
  number = {BIONL11469}
}
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