Biofuel production must be based on strict sustainability criteria

Dear Minister for the Environment,

As the informal environmental council meets in Slovenia to discuss biodiversity, biomass and biofuels, we would like to draw your attention to some of the potentially adverse impacts of biomass and biofuel production and use.

The proposal for Directive on the promotion of the use of energy from renewable sources by the European Commission includes an objective with potentially very unsustainable impacts: the objective of 10 % renewable energy in the transport sector by 2020. Although backed up by the Council, this objective is likely to have environmentally harmful impacts and will most likely trigger or enlarge the social problems, especially in developing countries.

Adverse environmental impacts
The boom of biofuel production brings along numerous environmental damages. Intensive use of pesticides, strong fertilisation, broad implementation of genetically modified crops in agriculture, biodiversity loss and burning down of the primeval forests are just some of the key negative impacts. Although initially proposed as a measure for reducing greenhouse gas emissions, the biofuel production can have an overall negative impact from the environmental perspective.

Adverse social impacts
As from the environmental perspective, the biofuel production opens numerous social challenges. It endangers living space of people, it leads to violations of human rights (land conflicts, poor social and work conditions), generally large plantations displace small farmers and the environmental threats endanger local people. Although generating cash flow into developing countries, the profit from biofuel production for the local population is mostly very low. The key social concern in some countries, however, is the competition to food crops, which can have a negative impact on food security and food prices. This concern applies mainly to the developing countries, but also to the socially weaker parts of the developed countries population.

Diversion from the real solutions
The debate about using biofuels for reducing transport related emissions is an important one, but it should certainly not be the only one. However, as the experience from the last few years shows, the transport debate is mainly focused on biofuels, while other measures are often neglected or pushed aside by the biofuel debate. This diversion is not just bad for the formulation of sustainable transport policies, but also for the investments. Money invested in biofuel production is tied up and cannot be invested into measures for sustainable mobility. Energy crop cultivation resources could be used more effectively by supporting local production of energy.

Our proposals
The current proposal is that the objective of 10% renewable energy in the transport sector is conditioned with fulfilment of the sustainability criteria, which is welcome. However, as numerous studies show, among which also an internal Commission study, there are serious doubts that the 10% objective is achievable under such criteria by 2020. We believe that people and their environment should not be victims of the swiftly growing transport sector and therefore we propose the following to be the minimum for a sustainable biofuel policy:

> We urge you to reject the 10% target for renewable energy in the transport sector in the Renewable Energy Directive and limit the amount of biofuels that count towards the 10% greenhouse gas reduction target in the Fuel Quality Directive.

> The proposed sustainability criteria should be substantially strengthened to ensure sustainable production of biofuels. The sustainability criteria should be applied to all sorts of biofuels, regardless of where they have been produced.

> The greenhouse gas savings should be at least 60% compared with the EU’s current average fuel mix. Only biofuels that are truly beneficial to climate change mitigation should be used and the most efficient use of sustainable biomass should be secured. The proposed threshold should be applied immediately after the entry into force of both Directives and not in 2015.

> Minimum environmental safeguards (sustainable agricultural practices, limited use of fertilisers and agrochemicals, measures for the protection of water and soil, preventing extension of monocultures and the release into the environment of any invasive species or genetically modified organisms) should be part of the Directives.

> Mandatory social standards should be respected, based on international conventions and agreements. Safe working environment and conditions should be secured and land rights should be protected. The criteria must also provide for monitoring of impacts on food security and implementation of corrective measures when necessary.

> The system of verification and monitoring has to be improved to secure the implementation of the sustainability criteria.

> Indirect land-use change effects have to be adequately addressed. If these indirect impacts are not included, the system can fail to ensure that only sustainable biofuels are supported.

> The criteria should ensure that the biomass is used in the most efficient way, only where its greenhouse gas avoiding impact is largest. The amount of sustainable biomass that is available can be more efficiently used in the electricity and heating sector.

> The sustainability criteria must be applied to production of all forms of bio-energy, unattached to the origin of production.

Only meaningful criteria can help preventing further damages in the environment and societies and therefore we strongly urge you not to support weak proposals for sustainability criteria, even if more time is needed to take the latest scientific evidence into consideration.

Yours sincerely,

Lidija Živčič, chair of Focus Association for Sustainable Development