Currently two EU laws, adopted in 2009 and running until 2020, promote the use of biofuels in the EU, ostensibly for the purpose of reducing greenhouse gas emissions from the transport sector. But both the Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) could lead to higher, not lower greenhouse gas emissions as the issue of indirect land use change (ILUC) has not been addressed.
In October 2012, the European Commission published a proposal to address the problem of ILUC. The final directive adopted in 2015 limits to 7% of transport energy the maximum contribution of biofuels made from food and energy crops. In addition, ILUC emissions have to be reported but they are not taken into account when evaluating the GHG performance of a biofuel, making it still possible for high-emitting biofuels to access the EU market and receive support.
In November 2016 the European Commission published its proposal for the recast of the Renewable energy directive, as a part of the clean energy package, setting the scene for discussions in the European Parliament and European Council. The Commission's proposal is a step in the right direction, as it further limits the contribution of food-based biofuels and provides incentives for advanced alternative fuels. But on sustainability criteria the proposal is still not making the necessary changes to ensure Europe doesn’t make past mistakes.
What should the EU do?
Environmental groups are calling on the European Commission to propose a 2030 biofuels policy, which moves away from land-based biofuels towards more sustainable low carbon alternatives. In order to achieve this, it should:
Environmental groups are calling on EU policy makers to move away from land-based biofuels towards more sustainable low carbon alternatives such as sustainable advanced biofuels and renewable electricity in the EU renewables policy until 2030. In order to achieve this, it should:
1. Gradually decrease the 7% cap on land-based biofuels to zero in 2030; starting with biodiesel made from vegetable oils such as rapeseed, soy, palm and sunflower;
2. Put in place a robust sustainability framework for bioenergy use at EU level, which would also cover advanced biofuels;
3. Stop counting biofuels as zero-emission fuels towards climate objectives;
4. Set a GHG based target for incentivizing advanced fuels, and scrap quantity targets for biofuels in transport (in the RED) completely if sufficient sustainability criteria are not put into place.
Biofuels and the Renewable Energy Directive (RED)
The current RED requires EU member states to source 10% of transport energy from renewable sources - including biofuels - by 2020. The law includes ‘sustainability criteria’ that dictate the minimum CO2 savings biofuels should achieve relative to fossil fuels in order to qualify for the scheme (and receive state subsidies). These criteria only account for the emissions that occur when land is converted specifically to grow biofuel crops (direct land use change).
Following the 2015 reform of the EU biofuels policies, member states can only count 7% land-based biofuels (food and energy crops) towards the 10% target. They also have the option to set up a lower limit. Moreover, there is a mandatory reporting of ILUC emissions, but “ILUC factors” are still not included in the sustainability criteria. This omission means that high-emitting biofuels will still be allowed to count towards renewable targets and receive public support. The final version of the EU reform also sets an indicative 0.5% target for so-called “advanced” biofuels.
The European Commission proposal for the recast of the Renewable energy directive, as a part of the Clean energy package, sets the discussion for the renewable energy and biofuel policy from 2021 up to 2030. In the Commission’s proposal a limit on the maximum contribution of food and feed-based biofuels gets lowered to 3.8% in 2030 but still doesn’t take ILUC emissions into consideration when assessing the GHG performance of a biofuel. The proposal also sets a target for advanced alternative fuels in order to promote advanced biofuels and renewable electricity use in transport. The proposed sustainability criteria will change little from the existing one.
Biofuels and the Fuel Quality Directive (FQD) – Article 7a
The FQD requires fuel suppliers to reduce the carbon footprint of transport fuels by 6% per unit of energy by 2020. It was expected that using more biofuels would be an important way for suppliers to meet that target. The same biofuels sustainability criteria agreed for the RED apply - there is a mandatory reporting of ILUC emissions, but “ILUC factors” are still not included. There is also a possibility for member states to apply the 7% limit to the FQD target. The Commission has signalled its intention not to continue the current GHG target in the FQD, meaning the 2020 is a “one-off” target which will unfortunately not be continued.
What is at stake?
Many conventional biofuels, in particular many types of biodiesel, have such high ILUC emissions that when counting these emissions in would cause them to no longer pass criteria for GHG savings. Some biofuels even lead to more GHG emissions than the fossil fuels they are supposed to replace. Based on estimates from the Globiom study, the ILUC emissions from vegetable oil biodiesel are higher than the emissions associated to fossil fuels. This makes biodiesel worse for the climate than fossil diesel, even when you exclude the production emissions. With the addition of the direct emissions from the production of biodiesel the full GHG profile is even worse, about 80% worse.
What is ILUC?
The production of biofuels can indirectly cause additional deforestation and land conversion. When existing agricultural land is turned over to biofuel production, agriculture has to expand elsewhere to meet the existing (and ever-growing) demand for crops for food and feed. This expansion happens at the expense of forests, grasslands, peatlands, wetlands, and other carbon-rich ecosystems. This results in substantial increases in greenhouse gas (GHG) emissions from the soil and removed vegetation (e.g. deforestation).
Is there a scientific consensus that ILUC is a real problem?
ILUC is real. Numerous scientific and public bodies agree that ILUC should be accounted for when calculating the GHG emissions from biofuels. The Commission has ordered several studies of its own and consulted extensively with scientists who also agreed that ILUC is a problem. Separate ILUC CO2 ‘factors’ for each type of biofuel crop, ILUC factors by crop category (e.g. starch crops, oil crops) or capping the contribution of food-based biofuel are ways of dealing with the issue. The study for the Commission’s trade department by the International Food Policy Research Institute (IFPRI) assessed the impact of various policy options for dealing with ILUC. It concluded that “emissions related to land use changes driven by biofuels policies are a serious concern”. The most recent study for the Commission’s Energy Directorate General – the so called Globiom study – reinforces this message. Its results show that biodiesel from vegetable oils, projected to be brought in by the RED, leads to around 80% higher emissions than the fossil diesel it replaces.
Are biofuels being unfairly targeted?
Biofuels were introduced as a measure to reduce GHG emissions - but scientific evidence shows that many do not achieve that purpose. The amount of biofuel used in Europe is mandated by law and the fuels themselves are often subsidised with public money. Many activities have a negative impact on the climate, such as eating beef or flying. However, unlike for biofuels, the EU has not passed laws forcing everyone to get 10% of their calories from eating beef, or fly for at least 10% of their transport!