The full exchange of correspondence is published below, starting with Abengoa’s original letter of 2 October:
LETTER FROM ABENGOA – PUBLISHED IN EUROPEAN VOICE – 2 OCTOBER
You are correct in identifying indirect land use change as an important facet of the new biofuels policy (‘Bid to save countryside from biofuels’, September 18-24), as it ought to be in all European policies that affect global land productivity and values.
But your article fails to consider two crucial issues: long-term land availability in the EU and the positive land use impacts of European bioethanol. The recent Gallagher Review for the UK government observed that agricultural production is shifting to other parts of the world as agricultural markets are increasingly liberalised. This will indeed cause land-use change, though it is not at all clear that the EU’s trade policy even takes the resulting greenhouse gas emissions into account. The effect of this dynamic is that agricultural land may be left idle in some regions even where demand at the global level is increasing. Biofuels policy, particularly in the EU, was developed partly in response to this dynamic in which the stock of agricultural land was shrinking and was expected to decline further into the future.
Having investigated the long-term trends in agricultural productivity and the projections of the Commission and industry, Biofuel Matters has concluded that it is well within the EU’s capabilities to grow all its own biofuel crops from traditional raw materials to achieve the 10% biofuel target by 2020. This without land-use change (direct or indirect) and with no impact either on the European food markets or existing food exports. Its report concludes that the necessary commercialisation of lignocellulosic raw material (so-called second-generation biofuels) from residues such as straw will reinforce this opportunity.
Secondly, both the article and European policy-makers have neglected to recognise that the bioethanol production process results in similar quantities of bioethanol and protein-rich animal feed, known as DDGS. Europe imports large volumes of soy to meet its animal feed requirements, mostly from the US and Brazil, where soy cultivation has been linked to rainforest destruction. The Heidelberg-based Institute for Energy and Environment, has recently confirmed that producing DDGS from land surplus to European food requirements reduces the demand for soy, improving Europe’s food security and reducing the negative consequences of agricultural indirect land-use change.
Greenhouse gas emissions resulting from indirect land use change is a new policy issue for Europe and the world. Currently there is no accepted scientific measure of its impact that allows us to determine the correct policy response. The UK proposes that should no such policy response be agreed by 2011, then all biofuels will be penalised in a way that European production would cease completely. While this threat exists there will be no investments in first and second-generation plants. This issue needs to be thoroughly examined, so that the environmental and other public benefits as well as the risks can be firmly established, before a reasonable decision on policy can be formulated. And when we incorporate these impacts we should not forget to compare them with the indirect greenhouse gas emissions from the petrol and diesel life-cycle.
Javier Salgado Leirado
President and CEO
LETTER FROM T&E – PUBLISHED IN EUROPEAN VOICE – 9 OCTOBER
In last week’s European Voice (Letters, 2-8 October), Javier Salgado-Leirado, the president of Abengoa, claimed that all the biofuel crops needed to reach the EU’s proposed 10% target by 2020 could be grown in Europe without direct or indirect land-use change.
That claim was based on a study by Biofuel Matters. But Leirado did not mention that the study was commissioned by eBIO, the European Bioethanol Fuel Association, of which Abengoa is a key member. And it was written by one of eBIO’s former directors, who is the owner and only member of staff at Biofuel Matters.
In contrast, the independent and wide-ranging Gallagher Review of the Indirect Effects of Biofuels for the UK government says that “the displacement of existing agricultural production, due to biofuel demand, is accelerating land-use change and, if left unchecked, will reduce biodiversity and may even cause greenhouse gas emissions rather than savings”. It concludes that “the introduction of biofuels should be significantly slowed until adequate controls to address the displacement effects are implemented and are demonstrated to be effective”.
Leirado argues that “there is no accepted scientific measure” of the greenhouse gas impact of indirect land use change. The Gallagher review, on the other hand, states that “the balance of evidence shows a significant risk that current policies will lead to net greenhouse gas emissions”.
And that is the point. The EU’s justification for its biofuels policy is to reduce greenhouse gas emissions. Leirado is apparently asking the EU to ignore the inconvenient truth that many biofuels, when the impact of land use change is properly accounted for, result in higher green-house gas emissions overall than the petrol and diesel they are designed to replace. Policymakers who ignore this would be gravely, and perhaps catastrophically, irresponsible.
Policy officer, low carbon fuels
Transport and Environment (T&E)
SECOND LETTER FROM ABENGOA – PUBLISHED IN EUROPEAN VOICE – 23 OCTOBER
Last summer, the ‘Gallagher Review on the indirect effects of biofuels’ to the UK government stated that mechanisms do not exist to accurately measure the indirect effects of land-use change.
The UK government is actively promoting biofuels. In ‘Bid to save countryside from biofuels’ (18-24 September) European Voice wrote that the UK government proposes to penalise all biofuels in a way that threatens the very existence of the European industry, if no such methodology can be established by 2011.
I was therefore surprised to read a letter (‘Biofuels can result in more emissions’, 9-15 October) from Transport and the Environment (T&E), in which it claims that I am “asking the EU to ignore the inconvenient truth that many biofuels, when the impact of biofuels change is properly accounted for, result in higher greenhouse gas emissions overall than the petrol and diesel they are designed to replace”.
The clear assertion in this letter is that, unlike the Gallagher review, the UK government, the European Commission, the Council of Ministers, industry and academia, T&E has a robust methodology to measure the impact of indirect land-use change. Although, apparently, it does not yet wish to share it.
To put the record straight, I am not the president of Abengoa and I made no such a claim. What I am trying to do is to bring to the attention of your readership two new pieces of research that were not available to the Gallagher review and were not addressed by the review, both of which are deeply pertinent to this issue.
One of the studies presents scenarios and criteria under which, it argues, the successful implementation of the European biofuel policy does not lead to indirect land-use change. The second study presents results that show that certain biofuels can lower the risk of greenhouse gas emissions arising from indirect land-use change driven by the food sector. Both studies were conducted by experts in their respective fields. Both studies are available to public scrutiny and comment and can be downloaded from the website of eBIO, the European bioethanol fuel association.
The association plans to hold a workshop in Brussels in which these findings can be further discussed and considered. If T&E has indeed invented a robust methodology to measure indirect land- use change, as it purports, I feel sure that eBlO will want it to join the platform of speakers at this event.
Greenhouse gas emissions resulting from indirect land- use change is a new policy issue for Europe and the world. If new evidence suggests that we can avoid land-use change, are stakeholders willing to open their minds to that possibility? If new evidence suggests that biofuels can reduce indirect land-use change, are stakeholders to open their minds to that possibility? And when we incorporate these emissions and savings in policy, are policymakers willing to compare them with the indirect greenhouse gas emissions from deep sea oil exploration and other aspects of the petrol and diesel life-cycle?
Javier Salgado Leirado
President and CEO
SECOND LETTER FROM T&E – PUBLISHED IN EUROPEAN VOICE – 30 OCTOBER
It is unfortunate, especially considering the millions of euros his company is spending on advertising its views on EU biofuel policy, that the president and CEO of Abengoa Bioenergy is apparently not aware of studies that calculate the impacts of land-use change (LUC) on lifecycle greenhouse gas emissions from biofuel production (‘Truth about biofuels is not inconvenient’, 23-29 October).
According to its website, Abengoa Bioenergy is “currently one of the largest producers of bioethanol in the US”. So one such study, by Searchinger et al, published in the journal Science in February seems particularly relevant. “By using a worldwide agricultural model to estimate emissions from land-use change, we found that corn-based ethanol, instead of producing a 20% saving, nearly doubles greenhouse emissions over 30 years and increases greenhouse gases for 167 years,” he says.
The US government has passed a law that requires direct and indirect emissions from LUC to be included in calculations of lifecycle greenhouse gas emissions from biofuels. Europe is still lagging behind with a proposal to increase its volume target without accounting for indirect impacts in any way.
The European Parliament’s industry and environment committees have both wisely voted to reverse this stance and include a conservative correction factor that would apply in 2011, if a comprehensive methodology is not developed before. That approach follows the precautionary principle, which is a fundamental element of European law. Or as John Maynard Keynes put it: “It’s better to be approximately right [ie, with a correction factor] than to be precisely wrong [without one].” The impacts of biofuel production are occurring now, so we believe the correction factor should apply as soon as the directive comes into force.
T&E is not against biofuels per se. We simply argue that only those that bring genuine environmental benefits should be brought to market and rewarded for their environmental performance. That is why T&E and others have long argued to replace biofuel volume targets with a greenhouse gas reduction target for transport fuels. Accounting for land-use change must be absolutely central to the policy.
Transport and Environment (T&E)
LETTER FROM TIMOTHY SEARCHINGER OF PRINCETON UNVERSITY – PUBLISHED IN EUROPEAN VOICE – 30 OCTOBER
Ten major reports this year from international and European technical agencies have warned that using productive land to make biofuels competes with land needed to grow food and to store carbon and therefore risks both hunger and increases in greenhouse gases.
Productive land is already in short supply in a world that must produce roughly twice as much food by 2050 to feed a growing population and yet somehow reduce the large deforestation already occurring to do so. Biofuels are simply one way of taking advantage of the capacity of land to grow plants that remove carbon from the atmosphere – forest and food are others.
To assess whether biofuels reduce greenhouse gas emissions, any fair accounting must calculate not only the benefit of using this land for biofuels but also the cost. This cost is the carbon emitted directly by ploughing up forest or grassland to grow biofuels or indirectly to replace food diverted to biofuels.
This basic accounting principle represents an absolute consensus of such technical organisations as the International Energy Agency, the Food and Agricultural Organization of the UN, the OECD, the European Commission’s Joint Research Committee, the European Economic and Social Committee and the Science Committee of the European Environmental Agency.
I therefore read with interest Javier Salgado Leirado’s letter ‘Truth about biofuels is not inconvenient’ (23-29 October) arguing that “certain biofuels” can avoid indirect land use change. His letter does not elaborate, but this statement is certainly true.
Biofuels from municipal and forest waste, and some crop residues provide excellent examples because these raw materials do not need to be replaced by clearing more land.
For the EU to encourage these kinds of good biofuels that do not compete with food and forest, the Union must enact policies that calculate the land use change resulting from different biofuels and therefore differentiate between them. The original biofuels directive proposed by the European Commission last January did not do so, but the European Parliament has improved on that proposal and its version would distinguish biofuels based on their land use change.
It is a pleasure that Leirado, who represents one of Europe’s largest biofuel producers, recognises the potential to pursue biofuels that do not compete with food and forest. It is now up to those crafting the final directive to ensure that it reflects this wisdom, differentiates biofuels by their land use change and encourages only those that avoid it.
Timothy D. Searchinger
THIRD LETTER FROM ABENGOA – PUBLISHED IN EUROPEAN VOICE – 13 NOVEMBER
In the run-up to final negotiations on biofuel sustainability criteria, the European Parliament’s energy committee (ITRE) has threatened to kill off the European biofuel industry in three years’ time, unless a metric is found to scientifically measure its current uncertain relationship with indirect land-use change and a policy instrument to control any negative impacts is agreed. Fresh investments in European first-generation and second-generation biofuels would be frozen until this is resolved.
Jos Dings, the director of Transport and the Environment (T&E), has defended ITRE’s proposal by resorting to the precautionary principle (‘Emissions from land-use change must not be ignored’, Letters, 30 October-5 November). A surprising defence really, given that in this series of correspondence I have referenced research that concludes that biofuel production can reduce greenhouse gases caused by indirect land-use change made by the food sector. The precautionary principle is invalid if the potential impact is equally positive and negative.
Moreover, I pointed to research that shows that the EU biofuel policy target can be met in full, while guaranteeing that only existing cropland is used. The hazard of land-use change could be avoided without blocking investments and threatening to kill the industry if ITRE had wanted to develop the policy in this direction.
How are we to understand ITRE’s proposal without generally accepted scientific backing, without knowing if that precaution would ultimately be beneficial or damaging to the environment and when, in any case, the biofuel policy could be designed to avoid indirect land-use change? Who is the big winner if ITRE’s proposal is adopted? The answer is, of course, the oil monopoly.
To receive its sustainability certificate, the greenhouse gas benefits of a biofuel will have to be judged against petrol and diesel. So consistency and fairness dictate that ITRE should have made an equivalent proposal to account for or penalise the indirect greenhouse emissions from oil products. It did not. Consistency and fairness also demand that ITRE should have proposed sustainability criteria for petrol and diesel. But again, the products of the oil monopoly were left unregulated.
Like T&E, I believe that only biofuels that bring public benefits should be supported and that the calculation of their greenhouse gases should include indirect emissions. But the calculation must be scientifically valid, able to recognise and reward biofuels that save indirect emissions as well as punish those that increase them. And we must compare like with like. Indirect emissions of oil products must be added to the direct emissions when we do the same for biofuels.
Javier Salgado Leirado
President and CEO
THIRD LETTER FROM T&E – PUBLISHED IN EUROPEAN VOICE – 20 NOVEMBER
Javier Salgado Leirado of Abengoa Bioenergy does not believe that the ‘precautionary principle’ applies to the question of whether to account for the impact of land-use change when calculating greenhouse gas emissions from biofuels (‘Parliament vote ignores land-use change research’, 13-19 November).
The research cited by Abengoa was commissioned by the European bioethanol lobby group and written by one of its former directors.
Without doubt, the European bioethanol industry stands to benefit substantially from a massive expansion of biofuel production in Europe. So instead of relying on research carried out by and for that industry, we would urge your readers to consider the findings of the following independent experts, scientists and institutions: ‘Biofuels in the European context, facts and uncertainties’ (European Commission Joint Research Centre, 2008), ‘Maximising the environmental benefits of Europe’s bioenergy potential’ (European Environment Agency, 2008), ‘Land clearing and the biofuel carbon debt’ (J. Fargione et al, in Science, February 2008), ‘The state of food and agriculture 2008 – biofuels: prospects, risks and opportunities’ (Food and Agriculture Organization of the UN 2008), ‘Gallagher review of the indirect effects of biofuel production’ (Renewable Fuels Agency for the UK Department for Transport, 2008), ‘Local and global consequences of the EU renewable directive for biofuels’ (Netherlands Environmental Assessment Agency, 2008).
If Abengoa knows of any independent studies that show how a massive increase of biofuel production can be achieved with no impact on land-use change worldwide, we look forward to seeing a corresponding list on their website. We will not hold our breath.
Transport and Environment (T&E)