EU Biofuel Directive Consultation (27.6.2006)

The EU is currently consulting on the EU biofuels directive. The principal questions and our suggested answers appear below. You can find more detailed versions of these questions and read more about the consultation at the EC Biofuel Directive Consultation page.

Please copy the following response to TREN-BIOFUELS-DIRECTIVE-REVIEW@cec.eu.int by Monday 10th July 2006.


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Dear Sir/Madam,

I would like to respond to the public consultation on the European Biofuel Directive.

Q 1. Is the objective of promoting biofuels still valid?

The objective of "promoting biofuels" per se has been shown to be invalid.

Firstly, there is evidence that the EU Biofuel Directive is already leading to massive CO2 emissions as rainforests are cut down to plant soya and palm oil for European cars. The peat fires in Indonesia are responsible for as much as 15% of annual global CO2 emissions, and satellites have shown that 75% of the fire hotspots are on palm oil plantation land. These emissions are dangerously accelerating progress toward 2°C of global warming - and the EU have a stated policy of working to avoid such warming.

The European Commission have accepted, following several studies, that the 5.75% target cannot be met without imports, hence pressures on rainforests can only grow.

Secondly, there is now a global grain deficit for the second year running. World grain reserves are at the lowest level in decades. Grain prices are rising and this is threatening the livelihoods of some of the poorest people. Bioethanol produced in the US has been shown to give little or no life cycle emissions savings compared with fossil fuels, yet requires large amounts of land.

Thirdly, the EU are committed to halting biodiversity loss in Europe by 2010, something which will be impossible if set-asides are lost to plant biofuel crops.

Q 2. The directive sets a reference value of 5.75% for the market share of biofuels in 2010. Will this share be achieved with existing policies and measures? If not, why not?

Current evidence suggests that the target could only be met at an enormous environmental cost, including higher global CO2 emissions, massive biodiversity loss, and pollution of soil and water. Pressure on grain prices is likely to lead to more suffering in poor countries.

Q 3. Looking towards 2010, does the EU system of targets for biofuels need to be adapted? If so, how?

The European Biofuel Directive has to be completely revised, based on the new evidence of disastrous environmental impacts, lack of proven greenhouse gas savings, and falling grain supplies.

I support a moratorium on the EU Biofuel Directive and all current subsidiary targets or obligations in individual member states. Any future targets must be based on science-based research which shows exactly how much can be produced sustainably.

There needs to be a full mandatory certification scheme, to ban the use of imported biofuels which are linked to rainforest destruction, the destruction of natural grasslands and wet-lands, biodiversity loss, soil or water pollution, or human rights abuses, and to ensure that there is no adverse effect on food supplies. Also, no biofuels must be used unless they are shown to have lower life-cycle greenhouse gas emissions than the petrol or diesel they replace.

Specifically, there should be a ban on the use of imported palm oil biodiesel, and potentially other commodities, from tropical countries engaged in deforestation, to counter deforestation resulting from growing markets for commodities used in biofuels.

The EU also needs to lead concerted international efforts to regulate the biofuel market, so as to prevent a dash to unsustainable biofuels causing rainforest destruction and other problems as raised above.

The use of waste vegetable oil for transport fuel, however, deserves special support.

CO2 emissions from transport must be reduced primarily through strict fuel efficiency and traffic reduction policies.

Q 4. Should a certification system be introduced to avoid using “poor performing” biofuels or give more support to “better performing” ones?

As set out in answer to q. 3, there must be a mandatory certification scheme, and the EU should lead efforts for parallel control measures internationally.

‘Performance’ must mean ‘sustainability’: The most energy efficient biofuel crops happen to be those most likely to be grown at the expense of rainforests, and most likely to be linked to massive CO2 emissions from peat fires and deforestation.

Q 5. Looking towards 2015 and 2020, should further measures be adopted to promote biofuels?

The main priority must be for research to develop biofuels which are more sustainable and efficient. Biodiesel from algae research appears to be particularly promising in both respects.

Research into life-cycle emissions of different biofuels and their full environmental impacts should be carried out now.

Future planning must take account of the fact that global agricultural production is set to decline because of climate change.

CO2 emissions from transport must be reduced primarily through strict fuel efficiency and traffic reduction policies.


Yours sincerely,

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