Comments on the transport elements of the Renewable Energy Directive and on article 7 of the EU Fuel Quality Directive
EcoNexus is responding to the two consultations on implementation of the transport elements of the Renewable Energy Directive and on proposals for the implementation of Articles 7a to 7e of the EU Fuel Quality Directive in the same document. We believe that serious damage being done in the global south by the EU biofuel target and that sustainability criteria are completely inadequate to address this. The EU biofuel target, set in 2007 at 10% in 2020, was explicitly designed to provide stability for commercial investment in biofuels. Only after establishing the target did the EU begin to develop sustainability criteria for biofuels. Developing sustainability criteria after imposing the target was no solution to a premature target. The criteria are flawed in a number of ways and there are no criteria for social impacts. Another major issue is this: criteria without monitoring are valueless; who is going to monitor compliance with criteria and how? Furthermore, there are no sanctions for not applying the criteria beyond losing rewards/subsidy attached to them. As things stand, the criteria themselves could have the perverse effect of encouraging the public to believe that biofuels are sustainable, while also enabling companies to (for example) claim a small amount of certified biofuels under the criteria (good for advertising purposes), while also profiting massively from importing uncertified biofuels. But above all, the target provides a strong attraction for investment in biofuels for Europe that is likely to overwhelm the impact of any protective measures. At a meeting in Parliament on 10th May, representatives from Kenya and Senegal spoke clearly about how the target is already implicated in destroying biodiversity and damaging people’s livelihoods. For example, the Dakatcha woodlands in Kenya are targeted for jatropha production for export to Europe.1 Public ignorance: we have found that the public does not realise that each time a person fills their car at the pump, they are burning biofuels. The public was not consulted about biofuel blending and they cannot choose petrol without added biofuel or decide which biofuel they wish to support, if any. We believe this is unethical. Now, in spite of mounting evidence of irreversible damage, the UK plans to increase the volume of biofuels in transport to 5% in 2013-14. This still means that, in common with many countries, the UK is not up to speed on implementing the target and little is said about how it will reach 10% by 2020. But this is not enough to address the incentive provided by the target. The target itself needs to be changed. The review of 2014 is too late for any of this.
The EU should cancel its biofuel target, not simply fail to meet it.
We therefore believe that the UK Government should take the lead, apply the precautionary principle to biofuels and challenge the target now.
Latest biofuel news
- 31.5.2011: Oxfam is calling for the EU biofuel target to be dropped, joining Action Aid, Friends of the Earth, EcoNexus and many other organisations.
- 1.6.2011: British firms have acquired more land in Africa for controversial biofuel plantations than companies from any other country, a Guardian investigation has revealed.2
Some more reasons to challenge the target
Indirect land-use change (ILUC)
This is the displacement of other activities by biofuels production, causing deforestation and expropriation of farmers, communities and indigenous peoples. The EU has just decided to delay any pronouncement on ILUC, yet it is clear that the issue is serious and urgently needs to be addressed. The Institute for European Environmental Policy (IEEP) notes that just for EU biofuels under the Renewable Energy Directive target by 2020: “Using currently available data, this additional demand for these fuels is anticipated to lead to between 4.1 and 6.9 million ha of ILUC ie an area equivalent to just larger than Belgium to just under that of the Republic of Ireland.” 3
Bioenergy production is not actually carbon neutral.
We now know that, contrary to the standard assumptions used for previous impact projections, bioenergy production is not actually carbon neutral.4 The assumption that it is creates perverse incentives to convert productive land and remove forest to establish biofuel crops, even though the emissions from such activities may far outweigh the benefits of biofuels, as shown by Searchinger et al.: "We calculated that GHG savings from corn ethanol would equalize and therefore “pay-back” carbon emissions from land use change in 167 years, meaning greenhouse gasses increase until the end of that period. Over a 30-year period, counting land use change, GHG emissions from corn ethanol nearly double those from gasoline."5 And Fargione et al.: "Converting rainforests, peatlands, savannas, or grasslands to produce food-based biofuels in Brazil, Southeast Asia, and the United States creates a ‘biofuel carbon debt’ by releasing 17 to 420 times more CO2 than the annual greenhouse gas (GHG) reductions these biofuels provide by displacing fossil fuels."6 These conclusions are reinforced by a more recent report from Joanneum Research, The upfront carbon debt of bioenergy.7
The public is not informed and has no choice
As we noted above, everyone who buys petrol at the pump in the UK is burning biofuel. The level is currently 3.5%, derived from crops such as soy, palm oil and sugarcane, and 80% of this is imported. However, we have found that many people are not aware they are using biofuel. And in any case, they were not consulted and, worse still, they have no choice about whether they purchase biofuel or not. We think this is unethical, especially in view of the impacts of biofuels and believe that many members of the public would be horrified to find themselves unknowingly implicated in the destruction of forests and biodiversity, communities, indigenous peoples and small farmers. Biofuels are a distraction from the real priority, which is for the EU to reduce its energy consumption.
Some background about our involvement in the biofuels discussion
At the end of 2006, EcoNexus, with Corporate Europe Observatory and Grupo Reflexion Rural, Argentina, wrote to MEPs in the European Parliament, calling on them to oppose the setting of an EU target for biofuels because of the serious impacts we believed this would have on ecosystems, biodiversity, communities and land. As an example we cited Argentina, where GM soy monocultures for export have displaced mixed farming, sending thousands to the slums of Buenos Aires. Our research Argentina: A Case Study on the Impact of Genetically Engineered Soya from 2005 remains current as regards the issues.8 This is clear from a more recent report on Argentinean soy and certification.9 Yet Argentina is currently a major producer of biofuel used in the UK. Also in January 2007, we also informed groups in the global south of the plans to set a target and asked them to respond. We then developed a call for a moratorium on biofuel imports, targets and incentives. Many groups and individuals responded. But in common with other organisations we found both larger NGOs and policy-makers very slow to respond. During this time the target has continued to generate investment and serious impacts.
- 1. ActionAid and three other organisations (March 2011): Jatropha biofuels in Dakatcha, Kenya ‐ The climate consequences
- 2. D. Carrington & S. Valentino (2011): Biofuels boom in Africa as British firms lead rush on land for plantations Guardian, 31 May 2011
- 3. Anticipated Indirect Land Use Change Associated with Expanded Use of Biofuels and Bioliquids in the EU – An Analysis of the National Renewable Energy Action Plans, Institute of European Environmental Policy, November 2010
- 4. Searchinger et al. (2009): Fixing a Critical Climate Accounting Error. Science, 326: 527-528.
- 5. Searchinger, T., et al. (2008): Use of U.S. Croplands for Biofuels Increases Greenhouse Gases Through Emissions from Land-Use Change. Science 319: 1238-1240.
- 6. Fargione, J., et al. (2008): Land Clearing and the Biofuel Carbon Debt. Science 319: 1235-1238.
- 7. Transport & Environment (2010): Studies cast further doubt on sustainability of bioenergy
- 8. L. Joensen et al. (2005): Argentina: A Case Study on the Impact of Genetically Engineered Soya. Report by Grupo de Reflexión and EcoNexus
- 9. Julia Tomei, Stella Semino, Helena Paul, Lilian Joensen, Mario Monti, Erling Jelsøe (2010): Soy production and certification: the case of Argentinean soy-based biodiesel Mitigation and Adaptation Strategies for Global Change 15(4):371–394; DOI 10.1007/s11027-010-9225-2