Biofuels and Regulatory Co-Production Critical Stakeholder Perceptions of Carbon and Sustainability Reporting in the UK Renewable Transport Fuel

Obligation

Paul Upham and Julia Tomei

April 2010

Tyndall Centre for Climate Change Research

Working Paper 143

Tyndall Working Paper 143, 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.

BIOFUELS AND REGULATORY CO-PRODUCTION

CRITICAL STAKEHOLDER PERCEPTIONS OF CARBON AND SUSTAINABILITY REPORTING IN THE UK RENEWABLE TRANSPORT FUEL OBLIGATION

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
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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
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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
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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.
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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
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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.

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 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.
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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).

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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.

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 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.
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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.

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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

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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).

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Table 3a Selected sustainability-related stakeholder responses to and comments on the RTFO

Organisation Explicit concern over impacts on food prices and/or availability Incentivise use of inedible crops Incentivise second generation R&D Explicit concern over theft of tribal and/or communal land Explicit concern over deforestation and cultivation of biodiverse land Explicit concern over working conditions in some producer countries Explicit concern over use of genetically modified crops Sustainable biofuels = small scale, with crops Sustainable biofuels = no adverse effect on old growth forests, Lack of trust in existing certification schemes (for the meta- standard) Advocates alternative transport policies, inc demand manage- ment / reduction, car efficiency measures

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

Country Land and Business Association FoE

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Food and Drink Federation General Motors

Greenpeace UK

Natural England

Oxfam

Total

Note: sources are all 2007 and are listed in the References by name of organisation.

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Table 3b Selected sustainability-related stakeholder responses to and comments on the RTFO

Organisation Recognition of a renewable gas when transported through the grid system not just at point of production Must link credits to GHG performance and take land use change into account EC Fuels Directive will encourage lower carbon fossil fuels for transport Use biomass for heat and electricity before transport fuel for GHG efficiency reasons Mandator y GHG saving of 50% minimum per feedstock Consider primarily European supply to minimise indirect land use effects (leakage) Biofuel as an intermediate stage to an end point of hydrogen and plug-in electric vehicles Incentivise use of higher blend biofuels No minimum GHG saving threshold; reward proportionately to GHG saving Delay / suspend biofuel targets unless and until effective sustainability assurance exists Second generation technologies not inherently more sustainable States to be helped to monitor and avoid adverse indirect land use changes, targeting degraded land and protecting high biodiversity land

National Forum on Biomethane as a Road Transport Fuel

Five BarGate Consultants FoE England and Wales

General

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Motors

Greenergy

Greenpeace UK LowCVP

NFU

Oxfam

Total

Note: sources are all 2007 and are listed in the References by name of organisation.

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Table 3c Selected sustainability-related stakeholder responses to and comments on the RTFO

Organisation Limit transport fuel target to 5% until sustainable production assured Concern for impact on biomass for heat and electricity sectors (target biomass to best GHG savings) Impact on UK landscape character and diversity to be considered Immediate use of GHG-based incentives would disadvantage domestic production No linkage of certificates and sustainability/carbon performance before 2011 at earliest Food prices unlikely to be a concern: supply responses can be expected and there is surplus land Reduced agricultural surpluses in developed world provide opportunity for agriculture in developing nations via raised prices Support the involvement of small-holders (alleviates rural poverty)

Natural England

NFU

Total

Note: sources are all 2007 and are listed in the References by name of organisation.

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Table 4 Number of references to carbon or emissions reduction in stakeholder response documents

Stakeholder African NGOs Biofuelwatch Country Land and Business Association D1 Oils Count Stakeholder 2 29 9 21 Greenergy Greenpeace UK LowCVP Count 1 5 3

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,
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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).

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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
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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
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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.
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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.

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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.

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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.

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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:

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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).

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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.

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Table 5. Interviewee responses to key biofuel policy contentions

A large-scale, international trade in bioenergy feedstocks: Is essential for Risks a net Poses little risk Will primarily UK energy increase in in terms of food benefit well- security global GHG poverty in capitalised land emissions from developing owners land conversion countries I have confidence in the RTFO carbon and sustainability reporting methodology (current or near future) as a model for managing bioenergy feedstock impacts 3 5 5 5 U I 2 2 4 U U Reducing energy demand in developed countries should be a higher priority than further developing an international bioenergy market 1 1 1 1 2 1 3 4 1 5 2 Where land is scarce, cultivation of energy crops for power and heat should be prioritised over crops for transport fuel

Organisation

Is essential to tackle climate change

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

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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
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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)
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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).

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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.

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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.

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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.

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 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.

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D1 Oils (2007) Response to the Consultation on the Governments proposed draft Requirements and Guidance for Carbon and Sustainability Reporting under the Renewable Transport Fuels Obligations (RTFO) D1 Oils website, D1 Oils Plc, Middlesbrough, http://www.d1plc.com/pdf/D1%20Oils%20Consultation%20response%20September%202007%20RT FO%20Final.pdf DfT (2007a) Consultation on the Draft Renewable Transport Fuel Obligations Order 2007. Department for Transport, London, http://www.dft.gov.uk/consultations/closed/draftrtfo/rtfo DfT (2007b) Carbon and Sustainability Reporting Within the Renewable Transport Fuel Obligation Requirements and Guidance Draft Government Recommendation to RTFO Administrator. Department for Transport, London, http://www.dft.gov.uk/consultations/closed/rtforeporting/consultation
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DfT (2007c) About the RTFO Programme, RTFO website, Department for Transport, London, http://www.dft.gov.uk/pgr/roads/environment/rtfo/aboutrtfo#belowNav DfT (2008a) Carbon and Sustainability Reporting Within the Renewable Transport Fuel Obligation. Requirements and Guidance Government Recommendation to the Office of the Renewable Fuels Agency. Department for Transport, London, http://www.dft.gov.uk/pgr/roads/environment/rtfo/govrecrfa.pdf DfT (2008b) Summary of Responses to the Consultation on the draft Renewable Transport Fuel Obligations Order. Department for Transport, London, http://www.dft.gov.uk/consultations/closed/draftrtfo/rtforesponsestoconsul DfT (2008c) Summary of responses to consultation on RTFO's carbon and sustainability reporting requirements. Department for Transport, London, http://www.dft.gov.uk/pgr/roads/environment/rtfo/sumresponrtfo DfT (2008d) Carbon Pathways Analysis Informing Development of a Carbon Reduction Strategy for the Transport Sector. Department for Transport, London, http://www.dft.gov.uk/pgr/sustainable/analysis.pdf Doornbosch, R. and Steenblik, R. (2007) Biofuels: Is the cure worse than the disease? OECD, Paris, http://www.oecd.org/LongAbstract/0,3425,en_39315735_39313128_39348697_119684_1_1_1,00. html Dryzek, J. (1990) Discursive Democracy: Politics, Policy, and Political Science, Cambridge: Cambridge University Press. Dryzek, J. (1997) The Politics of the Earth: Environmental Discourses, Oxford University Press. Directive 2003/30/EC of The European Parliament And Of The Council of 8 May 2003 on the promotion of the use of biofuels or other renewable fuels for transport. Official Journal of the European Union L 123/42, 17.5.2003, Brussels, http://ec.europa.eu/energy/res/legislation/doc/biofuels/en_final.pdf Ecofys. Sustainability Reporting within the RTFO: Framework Report. A report by Ecofys, Utrecht. London: DfT, 2007. http://www.dft.gov.uk/consultations/closed/rtforeporting/sustainabilityreportingv2 Elghali, L., R. Clift, et al. (2007). "Developing a sustainability framework for the assessment of bioenergy systems." Energy Policy 35(12): 6075-6083. Elliott, C. and Schlaepfer, R. (2001) Understanding forest certification using the Advocacy Coalition Framework, Forest Policy and Economics 2:257-266. Environment Agency (2007) Biofuels for transport position statement. UK Environment Agency, Bristol, http://www.environment-agency.gov.uk/research/library/position/41179.aspx EurActiv.com (2008) Biofuel-makers denounce target downgrade, Euractiv.com website, 12th September 2008. Fondation EurActiv, Brussels, http://www.euractiv.com/en/transport/biofuel- makers-denounce-target-downgrade/article-175298
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European Parliament (2008) Texts Adopted at the sitting of Wednesday 17 December 2008. P6_TA- PROV(2008)12-17. Provisional Edition Pe 417.801. Brussels, European Parliament. [accessible at http://www.euractiv.com/en/climate-change/mixed-reactions-parliament-approves-eu-climate- deal/article-178163] FAO (2008) The State of Food and Agriculture. BIOFUELS: prospects, risks and opportunities 2008. FAO, Rome, http://www.fao.org/sof/sofa/index_en.html FiveBarGate Consultants (2007) Response to the Consultation on the Draft Renewable Transport Fuel Obligations Order 2007. FiveBarGate Consultants, Stockton on Tees. FoE England and Wales (2007) Consultation on the draft Renewable Transport Fuels Obligation Order 2007, Friends of the Earth England Wales and Northern Ireland Response. Friends of the Earth England and Wales, London, http://www.foe.co.uk/resource/consultation_responses/rtfo_consultation_response.pdf FoE Scotland (2007) Department for Transport Consultation on The Draft Renewable Fuels Transport Obligation Order. A response from Friends of the Earth Scotland. Friends of the Earth Scotland, Edinburgh, http://www.foe-scotland.org.uk/publications/RTFO_consultation_response.pdf FoE England and Wales (2008) Public in the dark about biofuels in their petrol, Friends of the Earth website, FoE, London, http://www.foe.co.uk/resource/press_releases/public_in_the_dark_about_b_15042008.html Food and Drink Federation (2007) FDF response to DfTs public consultation on the draft renewable transport fuel obligations order 2007, Food and Drink Federation. London, https://www.fdf.org.uk/response_DfT_Renewable_Transport_Fuel_Obligation.aspx Forecourt Trader (2009) Oil companies slammed for biofuels failure. Forecourt Trader 16th January 2009, William Reed Business Media Ltd, Crawley, England, http://www.forecourttrader.co.uk/news/fullstory.php/aid/2704/Oil_companies_slammed_for_biofu el_failure.html Forsyth, T. (2004). "States of knowledge: the coproduction of science and social order." Environment and Planning A 36(9): 1708-1709. Frame, B. and J. Brown (2008). "Developing post-normal technologies for sustainability." Ecological Economics 65(2): 225-241. Frantzi, S., Carter, N.T., Lovett, J.C. (2009) Exploring discourses on international environmental regime effectiveness with Q methodology: A case study of the Mediterranean Action Plan, Journal of Environmental Management, 90: 1, pp. 177-186. Funtowicz, S. O. and J. R. Ravetz (1990). Uncertainty and Quality in Science for Policy. Dordrecht, Kluwer. Funtowicz, S. O. and J. R. Ravetz (1993). "Science for the post-normal age." Futures 25(7): 739-755. Funtowicz, S. O. and J. R. Ravetz (1994). "The worth of a songbird: ecological economics as a post- normal science." Ecological Economics 10(3): 197-207. Funtowicz, Silvio and Jerry Ravetz (Lead Authors); International Society for Ecological Economics (Content Partner); Robert Costanza (Topic Editor). 2008. "Post-Normal Science." In: Encyclopedia of
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Upham, P., Thornley, P., Tomei, J. and Boucher, P. (2009) Substitutable biodiesel feedstocks for the UK: a review of sustainability issues, Journal of Cleaner Production, available online May 9th 2009. van Dam, J., M. Junginger, et al. (2008). "Overview of recent developments in sustainable biomass certification." Biomass and Bioenergy 32(8): 749-780. Van Huijstee, M. M., M. Francken, et al. (2007). "Partnerships for sustainable development: a review of current literature." Environmental Sciences 4(2): 75-89 Verweij, M., M. Douglas, et al. (2006). "Clumsy solutions for a complex world: The case of climate change." Public Administration 84(4): 817-843. Visseren-Hamakers, I. J. and P. Glasbergen (2007) "Partnerships in forest governance", Global Environmental Change 17(3-4): 408-419. Webb, T. (2009) Shell dumps wind, solar and hydro power in favour of biofuels. The Guardian, Tuesday 17 March 2009, Guardian News and Media Ltd, London and Manchester, http://www.guardian.co.uk/business/2009/mar/17/royaldutchshell-energy Wilkinson, J. (2006) Network theories and Political economy: from Attrition to convergence? Between the Local and the Global: Confronting Complexity in the Contemporary Agri-Food Sector, Research in Rural Sociology and Development Volume 12, 1138. doi:10.1016/S1057- 1922(06)12002-8 Williams, M. (2000) Interpretivism and Generalisation, Sociology, 34 (2), 209-224. Wynne, B. (1996). May the sheep safely graze? A reflexive view of the expert-lay knowledge divide. Risk, environment and modernity: towards a new ecology. B. Szerszynski, Lash, S. & Wynne, B. E. London, Sage. Zah, R., Bni, H., Gauch, M., Hischier, R., Lehmann, M. and Wger, P. (2007) kobilanz von Energieprodukten: kologische Bewertung von Biotreibstoffen. EMPA fr die Bundesampt fr Energie, die Bundesampt fr Umwelt, und die Bundesampt fr Landwirtschaft, Bern, www.empa.ch/plugin/template/empa/3/60542/---/l=2 and http://www.theoildrum.com/node/2976#more

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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.

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Stakeholder Opinion on UK Bioenergy Sustainability Policy

Dear bioenergy stakeholder, thank you for your time. This interview concerning bioenergy (including biofuel) policy will take about 45 minutes. There is some emphasis on the suitability of the RTFO as a model for a European standard on sustainably produced biomass. We aim to report your anonymised views at a multi- sector bioenergy conference in autumn 2010 (http://www.bioten.co.uk/), if not earlier. Funding is by EPSRC Supergen Biomass and Bioenergy and contacts are: paul.upham@manchester.ac.uk & j.tomei@ucl.ac.uk

Section 1: questions on general bioenergy policy

Please circle one number per question, answering as a representative of your organisation. Please also explain your reasoning in as much detail as time permits. 1. A large-scale, international trade in bioenergy feedstocks is essential to tackle climate change 2 3 4 5 Strongly disagree

Strongly agree 1

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

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

Unsure / dont know

Reasons/comments:

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Section 2: questions on sustainability standards

9. How would you rate the effectiveness of the following standards for environmental and social protection?

Round Table on Responsible Soy (RTRS) Highly effective 1 2 3 4 5 Not at all effective

Unsure / dont know

Reasons/comments: Roundtable on Sustainable Palm Oil (RSPO) Highly effective 1 2 3 4 5 Not at all effective

Unsure / dont know

Reasons/comments: Forest Stewardship Council (FSC) Highly effective 1 2 3 4 5 Not at all effective

Unsure / dont know

Reasons/comments: 10. Is a January 2008 baseline date for land use change in biomass sustainability reporting agreeable to you? Yes No

Unsure / dont know

Reasons/comments 11. Do you think that biomass sustainability reporting for the RED can adequately indicate indirect land use change? Yes No

Unsure / dont know

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Reasons/comments 12. In what ways, if at all, have your opinions on biofuels and/or bioenergy changed over the last two years?

Section 3 Questions on RTFO carbon and sustainability reporting method

In this section we are interested in your opinion on the specific content and process of the RTFO carbon and sustainability reporting method. This need not be in relation to the following questions. 13. In your view, does the scientific content of the RTFO adequately account for the breadth of scientific knowledge on biofuels? 14. Do you think the same can be said for the sustainability criteria of the RED? 15. For the RTFO, to your knowledge, what guidance was given by DfT in terms of scope and content? 16. Which other agencies and organisations were involved in developing the RTFO, to your knowledge? 17. How were any differences of opinion handled and what did these relate to (if any)? 18. The rewarding of GHG credits for co-products is critical to the LCA performance of many biofuels but 1 is also controversial . What are your views on the treatment of co-products in biofuel LCA? Any other comments you want us to record?
1

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

Tyndall Working Paper series 2000 - 2010

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

Tyndall Working Papers

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
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Tyndall Working Papers

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
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Tyndall Working Papers

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

the US Economy?, Working Paper 4

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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