To: Commissioner Piebalgs
cc: Commissioner Dimas
Commissioner Fischer Boel
Wednesday 9 January 2008
Dear Commissioner Piebalgs,
Directive on the promotion of the use of renewable energy sources
We are writing to express our urgent concerns about the Commission proposals which aim to regulate the production and use of biofuels in the forthcoming Directive on the promotion of renewable energy sources. We understand that the final proposal will be published in January and urge you to introduce substantial improvements to the draft copy now circulating in the public domain (version 6.3.3).
The European Council in March 2007 agreed to a 10% binding minimum target for the share of biofuels in transport by 2020. Council attached strict conditions to this target, notably, “subject to production being sustainable, second-generation biofuels becoming commercially available and the Fuel Quality Directive being amended accordingly to allow for adequate levels of blending.”
As it stands, the signatory organisations are convinced that the current draft proposal will not lead to the production of biofuels being sustainable and will therefore not meet the conditions set by Council. This in turn questions the appropriateness of setting a mandatory target for biofuels.
Our particular concerns regarding the current proposal include:
Important ecosystems and carbon sinks left unprotected: the current proposal does not provide protection for important ecosystems and carbon sinks such as savannas or permanent grasslands that may be threatened by expanding agriculture to meet the EU’s biofuel target. Destruction of these carbon sinks would lead to large emissions of carbon into the atmosphere, thereby reducing or neutralising the benefits from growing biofuels. Neither does the draft text provide any safeguards to protect water and soil resources.
Not withstanding the issues raised below, we welcome the exclusion of biofuels (for transport) planted in existing or previous wetland or forest areas. These areas are not only important for biodiversity but also contain enormous carbon stocks.
Major impacts sidelined: Large scale biofuel production can cause indirect or knock-on impacts such as increasing food and feed prices and increasing water scarcity which would lead to negative impacts on the world’s poor. In addition they can displace other agriculture activities into socially or environmentally sensitive areas (e.g. rainforests or savannas). It is widely reported that these serious indirect impacts are already happening. The draft text does not provide any meaningful plan to deal with these issues, proposing instead to simply monitor the situation using bi-annual reports from the Member States. These issues need to be addressed with adequate proposals before imposing new legally-binding targets to increase demand.
Social standards missing: The draft text does not provide any criteria to protect people, particularly in developing countries, from the negative impacts of biofuel production. The scramble to supply European markets is already causing frequent land disputes, forced evictions, human rights abuses, increased poverty and poor working conditions in developing countries. The EU must guarantee that human rights are protected, that all workers enjoy decent work, that cultivation does not adversely impact on local communities or indigenous peoples, that smallholders are treated fairly and transparently, and that the right to food is ensured. Without these safeguards in place the EU’s approach will not be deemed sustainable.
Weak greenhouse gas calculator: the draft proposal provides a greenhouse gas calculator that is too simplistic and is skewed towards making biofuels look better than they really are. The current version does not specify the minimum level of emission savings. This threshold must be set significantly high to ensure that only biofuels that are truly beneficial to mitigating climate change are used. The Directive should introduce a comprehensive, accurate and transparent greenhouse gas calculator that deals with the complexity of the issue. It should ensure that only biofuels delivering substantial reductions are accepted as counting towards the target.
Stronger rules banned: We have serious concerns that EU Member States will be prevented from introducing stronger criteria at a national level and that other national / international schemes will be accepted already if they meet only some of the criteria listed in this Directive. If the EU proceeds with a weak framework then it is essential that Member States are allowed to introduce stronger mechanisms to ensure the sustainability of biofuel production.
We would like to underline that we fully support and applaud the EU’s 20% renewable energy target and our concerns here relate only to the impacts of an increased use of biofuels. Given that it is more efficient to use biomass in stationary applications, the promotion of biomass for liquid fuels for transport may in fact undermine more cost effective ways to meet the 20% renewable energy target.
Summarising, in our opinion, the current draft Directive does not ensure that the production of biofuels will be sustainable and therefore the conditions set by Council would not be met. We therefore urge you to substantially improve the proposed draft legislation to take into account the points raised above. We believe that if proper safeguards cannot be put in place the EU’s mandatory biofuel target must be suspended.
As a final remark we would like to stress that sustainability safeguards must be applied to all forms of bio-energy. The limited criteria listed in the draft are only applicable to crops used as fuels in transport but not for the same fuels used elsewhere, for example, to produce electricity, heating or cooling. As the environmental and social impacts are the same, regardless of the end use, sustainability safeguards must accordingly apply to all targets.
We would welcome any opportunity for further discussion. Please refer, as a contact person, to Adrian Bebb, Friends of the Earth Europe (Rue Blanche 15, 1050 Brussels. firstname.lastname@example.org).
Paul de Clerck, Interim Director, Friends of the Earth Europe
Clairie Papazoglou, Head of European Division, BirdLife International
John Hontelez. Secretary General, European Environment Bureau
Jorgo Riss, Director, Greenpeace European Unit
Luis Morago, Head of Oxfam International’s Brussels Office, Oxfam International
Jane Madgwick, CEO, Wetlands International
Jos Dings, Director, T&E, the European Federation for Transport and Environment
Danuta Sacher, Head Policy and Campaign Department, Brot für die Welt, Germany
George Gelber, Head of Policy, CAFOD, UK
Andy Atkins, Advocacy Director, Tearfund, UK
Nina Holland, Corporate European Observatory
Reinhard Behrend, Rettet den Regenwald, Germany
Christine Fouarge, Policy Officer, AEFJN (Africa-Europe Faith & Justice Network)
Ms. M. De Rijk, Director, Stichting Natuur en Milieu, Netherlands
Helder Spinola, President, Quercus – Associacao Nacional de Conservacao da Natureza, Portugal
Hermann Edelmann, Pro REGENWALD, Germany
Dr. Bernd Bornhorst, Head of Policy Development, Misereor, Germany