Bio-fuels are being sold as "environmentally friendly" and because they involve growing rops for non-food purposes are an obvious target for GM crop introduction.
The following analysis focuses on the East of England but variants on it are being considered world-wide.
In the UK the Green Party is supporting campaigns against large scale biofuel schemes, in line with national policy.
1.Biofuels and GM
2.Eastern Region Plans for Biofuels: Wasting Time in a Cul-de-Sac
1.Biofuels and GM
GM companies are hoping that the rush for biofuels will mean large new markets for their products. It is probably not a co-incidence that two of the main crops for 'biodiesel' and 'bioethanol' are sugar beet and oil seed rape (OSR), two of the three in the Farm Scale Trials. GM trees are also a possibility for complex, very expensive and energy intensive technologies being developed to produce ethanol from wood (ligno-cellulosic processes), including poplar and willow for Short Rotation Coppice (SRC).
*GM biofuel crops
There is considerable public concern about the scientific uncertainties of GM crops, and growing evidence of harm to animal and human health (see below).
Articles in the EDP [Eastern Daily Press] about biofuels reveal intentions for 'designer biomass crops' for 'improved' characteristics for biofuel crops. For example, OSR requires considerable chemical inputs, and the production and transportation of these inputs entails considerable ghg emissions. So, hey, why not design crops to need less inputs...
Short rotation coppice (SRC) is one of the major options being promoted for wood supply for electricity. Syngenta, formed by the merger of Novartis and Astra-Zeneca (see Corporate Watch web site for corporate profile) had what appears to be the only GM tree crop destroyed by protesters (Jellots Hill) - this was poplar for SRC.
See the petition for UN: GLOBAL BAN ON GM-TREES http://elonmerkki.net/forestforum
Massive land requirement for biofuel crops, further intensification of unsustainable agriculture
The proposed Eastern Region Bioethanol plant would require 38,000 hectares of crop land and a catchment area of more than 24,000 sq k. The UK programme would require 500,000 hectares of crop land, with about another 500,000 for biodiesel crops.
The amount of land required for bioethanol, biodiesel, and crops to burn for electricity production will be immense and the additional pressures on agriculture will be tremendous.
The practices and chemical inputs of intensive industrial agriculture (IIA) are already known to be unsustainable because they are causing serious damage to soils (erosion, contamination and degradation) and water (pollution of ground and surface waters), as well as accelerating losses of biodiversity.
"In the EU, an estimated 52 million hectares, representing more than 16% of the total land area, are affected by some kind of degradation process. In the accession countries this figure is 35%"
"Figures for England and Wales show that the percentage of soils with less than 3.5% organic matter rose from 35% to 42% in the period 1980- 1995 probably due to changing management practices. In the same period, in the Beauce region south of Paris, soil organic matter had decreased by half for the same reason" (COM(2002) 179 final. Towards a Thematic Strategy for Soil Protection. Pages 9 and 11)
*Soils: a non-renewable resource
Biofuels are referred to as 'renewable' fuels because the carbon dioxide released by burning them is absorbed by the next crop. What is often forgotten is that the soil in which they are grown should be regarded as a non-renewable resource, since soil formation takes place slowly over long time periods. Vast amounts of soil are blown or washed away each year, levels of soil organic matter are falling and knowledge about the damage to the myriad soil organisms is limited, yet they are vital to soil health and recycling of organic matter and nutrients (GM poses particular risks for soil organisms).
A further worry is that because SRC would be classed as an industrial crop (possibly on set-side land), the limits for sewage sludge (SS) applications would be relaxed. This is very short sighted. SS doesn't only contain heavy metals, but a whole range of toxic (and bioaccumulative) chemicals which have not been tested for their effects on the environment. Cumulative and synergistic effects are rarely even considered.
As the degradation and desertification of land accelerates world wide we cannot afford to pollute land which will be needed for long term Food Security. The contamination could be irreversibly in time spans that mean anything to us.
The implications for small-scale and family farms, and remaining forests and wildlands, across the world does not look hopeful if the corporations and their instruments succeed in pushing biofuels as an alternative to fossil fuels. There is currently a concerted campaign to promote biofuels as environmentally friendly, helping beleaguered farmers and as the only effective option to reduce transport emissions. The evidence says the contrary - but that is carefully ignored
Large scale biofuel schemes are a Business As Usual option which keeps major corporate interests happy, but limits the options for communities to develop small scale energy technologies using their local resources - because the large plants will devour them. On the consideration of associated transportation emissions alone, this would seem to be a very bad idea:
* A 100,000 tonne/year Plant requires 12 - 18 HGV drivers (300,000 t/y: 30-40) to transport crops from farms to plants, entailing more road building to accommodate substantial associated vehicle use. The transportation miles are estimated at well over 3 million miles, though it is not clear if this includes empty trips (so could be 6+ million miles? Just think of the emissions from all those HGVs.
See Biofuel Notes for full information.
*Important additional info: CReD - The East of England Development Agency, or EEDA' s Carbon Reduction team
Cheer leader Bruce Tofield of CReD is tirelessly campaigning amongst local groups to join together in the great CRed Mission: Follow the Star of the East (initally proposed as an incinerator to link up with energy 'nodes' across the Region, including a Wind Farm and ...... er,... Bacton and Sizewell).
Tofield finds "exciting" prospects for Norfolk in developing low-freezing point aviation fuel, including working with the John Innes Centre - eg for modifying soya so it will grow better here so we can produce the fuel? (EDP, 'Norfolk's role in new plane fuel', 25/3/04, p37).
CReD's stated objectives may be laudable, but just look at what their 'partners' may unwittingly be endorsing. CReD is supporting EEDA's large scale Bioethanol Plant plans, and the 'oil fields' of East Anglia' to produce biodiesel from vast areas of Oil Seed Rape (GM if they can drum up "consumer demand" for biofuels, which would then be construed as demand for GM). The competition for which CReD, funded by EEDA, have entered their 'Slug of the East' brain wave (hailed as 'World Leader' and 'Green' Incinerator at Trowse by the EDP) just happens to be run by ... EEDA). * Caution: watch out for claims of benefiting the people of Norwich (sic) - this is the cover for a very severe case of inflamed egos preoccupied with the size of their GDP.
This might all seem quite entertaining except that some groups appear to be taking this CRud seriously at the moment. This is perhaps understandable because CRed are parasitic on the excellent reputation of the School of Environmental Sciences. But, they are only based in Env., under the Leadership of Prof Trevor Davies (soon to be Pro Vice Chancellor ...... ) and are in fact a tentacle of EEDA, which is where their funding comes from. The insidious creep of corporate interests into Universities is becoming very worrying.
(See http://www.guardian.co.uk/comment/story/0,3604,1154585,00.html>http://www. guardian.co.uk/comment/story/0,3604,1154585,00.html for George Monbiot's 'The corporate stooges who nobble serious science', Tuesday February 24, 2004)
*And Who EEDA, many people wonder?
Many people are unaware of what EEDA is, or what they do. It is important that they should know because this unelected Quango, and associated bodies, has a mission to promote business interests and wields a great deal of power over our lives. An example would be the increasing control of social housing, planning and funding. In this brave new world, the term housing 'need' is liberated from the traditional meaning of meeting social need, it now means meeting business needs.
EEDA's mission is to make the Eastern Region one of the 20 most prosperous in the EU and so they are pushing for massive economic growth. Their Regional Economic Development Strategy (REDS) was subject to an independent Sustainability Appraisal, which demonstrates that EEDA thinks that sustainability means 'sustained economic growth':
"The REDS clearly states its priority for economic growth in its vision statement. It immediately qualifies this economic priority with a statement of core values including a recognition that social and environmental factors must also be considered in order to achieve economic development which will be sustainable as well as sustained. This is the most important acknowledgement of the issue of sustainable development in the strategy report" (Arcardis Geraghty and Miller, International (AGMI) and Segal Quince Wicksteed Ltd (SQW), p.18)
However, the consultation process for the REDS revealed considerable concerns about the over-riding growth objective, and the East of England Regional Assembly (EERA) subsequently voted against the REDS. The response of EEDA towards these concerns was one of 'disappointment' and no apparent interest in addressing them. The following extracts are from EEDA's web site 'Press releases - EEDA disapointment at Regional Assembly reluctance to sign up to prosperity' (undated)
"The East of Enjgland Development Agency (EEDA) announced its disappointment today as the East of England Regional Assembly (EERA) failed to endorse the revised regional economic strategy at the Regional Assembly's quarterly forum, held at Chelmsford."
"It is disappointing that, despite significant time and effort on EEDA's part, some Regional Assembly members still do not buy into EEDA's recommendations for creating more prosperity, better opportunities and an increased quality of life for all who live and work in the region."
"It is vital that all partner organisations, businesses and individuals help contribute to its delivery, and we will be working with the Regional Assembly over the coming months to persuade its members that this revised economic strategy is the best way to move the region forward" (If that doesn't send a shiver to the very heart of your democratic bones........)
Can anyone get EEDA and their lackeys at CReD to think realistically about the land requirements and the immense implications of all their corporate techno-fix wheezes?
*Additional info on GM and health
The government has given the go-ahead for planting GM maize in the face of considerable public concern, and increasing evidence of serious consequences.
For more information see Spring 2004 edition of 'Science in Society' for article by Mae-Wan Ho and Sam Burcher 'Cows ate GM Maize and Died'. According to a report by Greenpeace Germany, "common errors in feeding and infections had by and large been ruled out as the cause of death", and the farmer involved, Gottfried Glockener, a supporter of GM crops, now suspects that Syngenta's GM maize Bt 176 is to be blamed. This paper also outlines other research showing damage to animal health from Gm crops. http://www.i-sis.org.uk/index.php>http://www.i-sis.org.uk/index.php
And, 'Scientists suspect health threat from GM maize' John Vidal, environment editor, Friday February 27, 2004. http://www.guardian.co.uk/ "Doctors thought they had an infectious disease, but when four families left the village and recovered, and then showed the same symptoms on return, an environmental cause was suspected. ..... Blood tests showed the villagers had developed antibodies to the maize's inbuilt pesticide. ...
His studies suggest that a virus promoter - which is like a motor driving the production of the genetic message - was unexpectedly found intact in human cells...
His team also said it had found that genetically engineered viruses used in the GM process recombined with natural viruses to create new hybrid viruses with unpredictable characteristics. If confirmed, this could suggest that they could cause new diseases.....
Prof Traavik said tests so far showed evidence of an immune reaction" http://www.guardian.co.uk/international/story/0,3604,1157210,00.html
UK supermarkets sell meat from animals fed on GM food, even under their alleged GM-free own-label products. FoE Norwich recently contacted supermarkets about policies on GM foods and replies appear to reveal that meat is described as GM-free if the animal has been fed on non-GM food for the 90 days previous to slaughter.
2.Eastern Region Plans for Biofuels: Wasting Time in a Cul-de-Sac
The East of England Development Agency (EEDA) plans to put considerable amounts of public money into supporting large-scale private sector development of biofuels Press Headlines refer to the 'Oil Fields of East Anglia' and proponents1 assert that biofuels will reduce dependence on imported oil, help struggling farmers, provide "environmental benefits" and make "significant" reductions in greenhouse gas (ghg) emissions.
A recent report (EEDA 20032) makes the case for a 100,000 tonne/year Bioethanol Plant to produce ethanol from sugar beet and wheat, at a cost of between GBP50 and GBP60 million, and a land requirement of about 38,000 hectares. It would be one of 10 or 12 being considered for a UK Bioethanol Programme (100,000, 200,000, and 300,000 tonne capacities) to meet about half of the non-binding EU target of 5.75% by 2010. The cost of the UK Programme is estimated at about GBP600 million a year (p53).
However, Eastern Region plans pay little attention to environmental impacts of this scale of industry, either on a local, regional or global scale, and none to the impacts of climate change on agriculture. Neither do they consider the problems which have beset large-scale biomass schemes. The Plant is being strongly promoted and the following benefits are claimed:
Claim: Biofuels will make a significant contribution to cutting Greenhouse Gas (ghg) emissions
* EU road traffic is growing at around 2% per year. The Carbon Dioxide (CO2) reductions claimed for biofuels (and these are highly contested), would be wiped out by the emissions from the additional vehicles of just 4 years traffic growth.
* Globally, road transport is increasing fast, eg vehicle numbers doubled in China over the last three years to 10 million.
* Carbon Dioxide is not the only pollutant of concern in vehicle exhaust fumes. Eg oxides of nitrogen (NOx) contribute to total greenhouse gases and to photochemical smog
* Regional bioethanol plans go no further than claiming "relatively modest green house gas reductions" and acknowledge that "the quantities of bioethanol that are likely to be produced, even with the most positive scenario used in the analysis in this study, will be relatively small compared with the total demand for gasoline in the UK." (EEDA, p42)
Claim: Biofuels are 'Carbon neutral'
This is based only on CO2 emissions from the engine: vehicle exhaust is said to be 'carbon neutral' because the CO2 is absorbed by the next crop grown to produce fuel. However, if ghg emissions for the whole production life-cycle for ethanol and biodiesel are taken into account, the overall ghg emissions associated with biofuels are far from 'Carbon neutral'.
Associated emissions include:
* Production of Fertilizers requires considerable amounts of energy, therefore also ghg emissions.
* Nitrogen fertilizers cause nitrous oxide (N2O) to be released from soils (direct and indirect emissions). N2O is a far more powerful ghg than CO2: 1 unit of N2O is equivalent to 310 units of CO2.
With regard to Bioethanol:
* "the energy use in the process is considerable, being in the range of 30 - 40% of the energy content of the bioethanol produced from wheat" (EEDA, p150)
* The Eastern Region plant would require 38,000 hectares of crop land and a catchment area of more than 24,000 sq k. The UK programme would require 500,000 hectares of crop land, with about another 500,000 for biodiesel crops.
* A 100,000 tonne/year Plant requires 12 - 18 HGV drivers (300,000 t/y: 30-40) to transport crops from farms to plants, entailing more road building to accommodate substantial associated vehicle use. The transportation miles are estimated at well over 3million miles, though it is not clear if this includes empty trips (so could be 6+ million miles?).
Claim: Biofuels are 'clean'
A range of vehicle exhaust components are harmful to human, wildlife, plant and soil health.
* A German study shows that there is little difference in exhaust emissions between vehicles run on biodiesel compared to conventional diesel, and a British study shows small reductions in some exhaust components (carbon monoxide, hydrocarbons and particulates), but some increase in nitrogen oxides (NOx)3.
* According to the Regional document, bioethanol "provides few air quality benefits" and " would not have any major positive or negative effects on air quality" (p6).
Claim: Growing crops for Biofuels will help farmers
Large Scale Biofuel plans will not help beleaguered small farmers: long-term contract prices will have to be kept low for production to be 'viable', so are likely to benefit large landowners and agri-businesses which have received most money under the current CAP subsidy system. Small farms will continue to be bought out by large ones.
* A recent report by Nuffield College, Oxford, using EU and Defra sources, shows that wealthy landowners and agri-businesses in the six counties of the Eastern Region receive over a quarter of the £2 billion EU agricultural subsidy payments to the UK
* "More than 20 cereal farmers in the area are thought to get more than £500,000 a year, with 6 big agribusinesses swallowing up more than £1m." (Hetherington, P., 'Barley barons reap rich EU subsidy harvest', Guardian, 22/11/03).
Claim: Biofuels are good for the Environment and Biodiversity
* On the European scale, to meet non-binding EU targets of 5.7% biofuels by 2010 (for road transport) would require 14 million hectares of land, according to the European Environmental Bureau. That would mean all EU set-aside land and some food producing land, so the environmental and wildlife benefits of set-side land would be lost.
* To meet low price contracts, farmers will have to go for high yields, so biofuel crops will depend on Intensive Industrial Agriculture (IIA) now widely recognised to be unsustainable because of the damage (so-called 'external costs') it causes to the natural resource base: accelerating degradation and erosion of soils; disruption of soil carbon and nitrogen cycles; pollution of surface and ground waters; great loss of wildlife and biodiversity.
* Biofuels are referred to as 'renewable' fuels, so are said to be a better option to using non-renewable Fossil Fuels. What is often forgotten is that the soil in which they are grown should be regarded as a non-renewable resource, since soil formation takes place slowly over long time periods. Vast amounts of soil are blown or washed away each year, and levels of soil organic matter are falling. This is one key reason why DEFRA and the EU advocate 'extensification' of agriculture.
The Global Dimension
The knock-on effects across the world if Europe goes in for large scale biofuel production will be to increase dependence on imported foods. This will lead to rising emissions for food transportation (food miles), and increased pressures on global agriculture and food supplies. If many countries across the world choose to promote biofuels, the consequences will be accelerating land and forest clearance and further intensification of global agriculture. The ghgs associated with forest clearances are immense, and no-one really knows what will happen to global weather systems if a lot more tropical forest is lost, but the words "catastrophic" and "irreversible" are often applied. Intensively farmed 'Biomass' (Short Rotation Coppice, Miscanthus) to burn for large-scale electricity generation, and further crops for industrial raw materials, will add to the pressures.
Regional Bioethanol Plant plans are economically unviable. Even with full public subsidy for private sector businesses in the UK to build processing plants (and the EU would only allow 40%), bioethanol Plants would still require fuel duty reductions, sale of high value waste/by-products (such as animal feed), and long-term, low-price contracts with farms, to be 'viable'.
The Impacts of Global Warming are not taken into account in Regional Plans, despite the need to address Climate Change being a stated objective. Anticipated impacts include:
* Loss of some of world's most fertile food producing lands to flooding and salt intrusion
o Great human suffering, hunger and loss of life; increasing numbers of environmental refugees.
* Severe weather events across the world: crop prices are likely to fluctuate far more than in the past, with the overall trend being upwards, exacerbated by demand for fuel crops.
* Accelerating degradation and erosion of soils; likelihood of release of accumulated toxins in soils; desertification.
* Drought: a growing concern in the UK and across the EU. Fuel and industrial crops on set-aside land will require additional water.
* New pests and diseases: spread more easily across large-scale monocultures (trees and arable crops).
* Disruption of global food production: Home Food Security is likely to become very important.
o This year drought and floods across the world have damaged crops. Some farmers in the UK have broken low-price contracts in order to benefit from higher prices, more than 40% for some crops (Farming Today, 24/11/03)
o "Economic losses in Europe because of the summer drought exceeded £7 billion in the agriculture sector alone because of loss of crops and livestock...." ('Extreme weather of climate change gives insurers a costly headache". Paul Brown, Guardian, 11/12/03). concern'.
Large-scale plants: 'white elephants'?
Example: The Arbre Project at Eggborough, Yorkshire
This plant applied new technology to produce biogas from gasification of wood. It received EU and government grants. After delays and escalating costs, the project went into liquidation in August 2003 after only eight days in operation ('Farmers burned as green energy plant faces export: £30m power station goes bankrupt after eight days, leaving growers high and dry', Stewart Boyle and Paul Brown, May 31, 2003). The following reasons for failure were put forward during conversations with people who had some involvement with the project
* Problems with the new technology
* Farmers were reluctant to commit to the minimum contract period of 10 years
* Partners got 'cold feet' and backed out as
o Far behind schedule
o Far over budget
There are growing numbers of examples of successful small-scale schemes (eg Llandwddyn Community Biomass Scheme, Powys; Ecotech, Swaffham), but they require careful planning and management. A report for a Biomass Energy Plant on the Norfolk Broads using conservation wastes, and requiring up to 80% additional wood supplies, included the following caution:
"We have identified from other existing schemes that the Achilles' heel of such plants is often the establishment and maintaining of a reliable fuel supply chain"
The UK Bioethanol programme is a 'Business As Usual' (BAU) option which meets a whole range of associated Corporate interests: the Petro-chemical industry (extension of agricultural fertilizers, pesticides and herbicide sales); the Oil Industry (biofuels offer no threat to ever-rising sales of Oil); Construction Industry (Production Plants and Roads); Chemical Engineering (Processing plants; development of complex technologies); Motor Companies (sales of haulage vehicles; no real change in technology); Large-scale Agri-business; and the persistent and optimistic GM Seed Corporations which anticipate huge markets for genetically engineered Oil Seed Rape and Sugar Beet (the main crops in the recent Farm Trials) and 'designer biomass crops'.
Small farms will continue to be swallowed up by large operators, though it is unlikely that many farmers will want to accept long-term low-price contracts as prices are likely to fluctuate, with overall rise. Globally, production of fuel crops will extend IIA at the expense of small and family farms, food land, forests and wildlife. Ghgs and damages associated with IIA will increase.
Biofuels will make little difference to dependence on imported Fossil Fuels, and road transport and energy consumption are increasing. Similarly, biofuels will have little effect on overall CO2 emissions, and are no solution to increasingly serious vehicle air pollution (Smog above critical levels for human and plant health across much of the EU, the US and Asia).
Invest in Small-scale Local Energy Supply Webs - "embedded generation", including mix of following:
* Combined Heat and Power (CHP) systems using local wood supplies for fuel. This should be carefully planned so that long-term forest management makes a reliable contribution to farm income and energy supplies, and meets a range of important objectives:
o Certified wood supply to local CHP plants, so avoiding complex, expensive and energy intensive large-scale Processing Plants, and mass lorry transportation of feedstocks around countryside,
o To bind and strengthen river banks against increased floods
o For wind breaks, as part of strategy to reduce soil erosion
o For tree species diversity: mixture of varieties depending on soil quality and water availability, as well as resilience to changing conditions
o For biodiversity and wildlife corridors to help species migrations as conditions change
o To meet increasing demand for leisure and enjoyment of nature
* Solar has been the ignored and maligned Cinderella for many decades, while her polluting sisters have been strongly promoted. Yet Solar technologies are well-tested and efficient
o Provide clean heat and energy for buildings, with clear and immediate emissions reductions.
o Start to build clean energy infrastructure for Hydrogen Fuel Cell (HFC) technology - domestic and vehicle. Trials of Hydrogen fuel cell buses are currently taking place in cities across the world.
* Anaerobic Digestion of wastes and sewage to produce biogas to run vehicles, or for electricity generation.
* Local scale biodiesel production from used cooking oils utilises a waste product and can avoid additional transportation emissions if the collections are for local processing and use, and can be integrated with recycling schemes.
Agricultural diversification and income
* On-farm production of biodiesel: Farmers process own oil seed crops with simple equipment for farm and local fuel supply. This would
o Avoid associated emissions and loss of land for large-scale Plants, infrastructure, processing and transportation
o Avoid farmers being 'locked-in' to low price contracts, so they have more control over their cropping regimes, with better possibility to work more sensitively within the capacity of natural resources and ecosystems.
o Support agricultural production in case of disruption of oil supplies and/or large price increases.
* Biogas production from anaerobic digestion of slurries and organic residues : Farms can process their own waste materials to produce biogas for vehicle fuel, or to generate their own electricity. Residues can be used as soil conditioner. This would have a range of associated benefits:
o Reduce synthetic Fertilizer use, costs and associated emissions
o Build up soil organic matter and health
o Keep money within local economy
* Support payments for Organic production
o Would cut agricultural ghg emissions effectively
o Nurture the health and resilience of natural systems to withstand more extreme conditions,
o Reduce high current high level of imports
There is simply no time to waste on ineffective and costly Business As Usual schemes. Real change is needed across the transport, energy and agriculture sectors, which are responsible for some of the highest emissions.
If Solar Energy is combined with local Wind Energy and CHP systems, electricity generation can be based on small-scale local supply webs - this would avoid increasing emissions from further intensification of agriculture, and reduce emissions from the decaying National Grid, so achieving large-scale Carbon reductions at rather lower costs than ineffective large-scale 'Biofuel' Schemes. Many farms could meet a considerable proportion of their fuel and energy requirement with relatively simple equipment. This is where public money should be invested - in long term infrastructure which will considerably reduce overall ghg emissions and provide the basis for clean energy generation infrastructure for farms, buildings and transport.
The taxation system effectively subsidises Fossil Fuels and supports their use because it does not reflect
* the 'external', or 'public cost', of pollution damage, including the damage caused by climate change4
* the rapid and escalating depletion of a non-renewable resource.
The growing realisation of the scale of damage to global life-support systems if the majority of remaining oil reserves are burnt should demand immediate action to reduce demand for oil and to apply clean and less damaging, but currently uncompetitive, alternatives. A Carbon Tax could help to achieve these objectives.
A Carbon Tax could change the structures which favour Fossil Fuel, and make the necessary alternatives uncompetitive. Revenue could support further development and applications of clean and renewable technologies, as well as the redesign of the national grid away from one-way supply towards co-ordination and balancing of local energy webs. Allowances and supports could help those on low incomes to meet their energy needs, and more efficiently. Reduction of National Insurance Contributions by employers would boost employment, and help to offset small losses in competitiveness in some sectors5
Proposals for a Carbon Tax come from a range of sources including environmental economists, businesses who feel disadvantaged by the Climate Change Levy (CCL), NGOs, and bodies such as the Royal Society, the Sustainable Development Commission6 and the Royal Commission on Environmental Pollution. The UK CCL is a small start, but it does not tax Carbon emissions across all sectors so cannot bring about the structural changes which so urgently need to be made.
2 www.eastofenglandobservatory.org.uk/observatory/reports/environment/Bioethan olFinalReportJune2003.pdf
3 'Evaluation of the comparative energy, global warming and socio-economic costs and benefits of biodiesel' Report for Defra, Mortimer et al, Sheffield Hallam University, January 2003, (p4). http://www.shu.ac.uk/rru/reports/scp21-3.pdf
5 Taxing Pollution instead of Jobs: Towards more employment without inflation through fiscal reform in the UK' Terry Barker. In 'Ecotaxation', editor T.O'Riordan, 1997)
6 Sustainable Energy! Response to the government's 'Energy Policy: Key issues for consultation'