Joint NGO letter on the environment, climate and social impacts of biofuels

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Courtesy of Wetlands International

RE: Biofuels’ environment, climate and social impacts – what you can do in second reading

Dear Member of the European Parliament ENVI committee,

You will soon be taking a decision on how to reform the EU biofuels policy to avoid the damaging impacts from land-based biofuels on contributing to biodiversity loss, deforestation, increased greenhouse gas emissions, food price pressures and displacement of communities from their land. At the same time you have an opportunity to positively steer the future of EU transport in a more sustainable direction.

With the announcement of the start of the second reading of these crucial reforms this week, we would like to express our hopes for what the ENVI committee needs to achieve: an agreement with the Council and Commission to halt further expansion of land-based biofuels in European transport and to establish a system to account for the full greenhouse gas emissions of biofuels.

The draft report prepared by rapporteur Mr Nils Torvalds MEP provides a constructive starting point, but ENVI MEPs should seek to further increase the level of environmental and social ambition – and this is analysed below.

1. Addressing the land-use conflict: the EU must limit the share of land-based biofuels used to achieve EU renewable energy and fuel quality targets
The draft report seeks to set a limit at 6% of EU transport energy. This is a minimum level of ambition which restores the Parliament’s first reading position. A lower limit would be more appropriate, to halt the further expansion of damaging land-based biofuels: here, the EU Commission proposed 5% (roughly current consumption levels) and the ENVI Committee 5.5% in its first reading position.

The draft report does seek to make the limit more strong and robust – by applying the limit to all biofuels that cause competition with land (including energy crops grown on cropland) (AM 45), applying the limit to the Renewable Energy Directive and Fuel Quality Directive equally (AM 24), and to the eligibility for subsidies (AM 50). These elements would contribute to improving the level of environmental ambition of the overall text and relieving the damaging impacts of the current policy on global food security.

2. Correct carbon accounting: the EU must take into account carbon emissions from indirect land use change (ILUC)
The draft report goes in the right direction to ensure correct carbon accounting of biofuels, by including ILUC emissions in the Fuel Quality Directive from 2020 (reinstating the Parliament’s first reading position) (AMs 13, 60, 29 and 26). However, to ensure consistency, such full carbon accounting should go further, by also including ILUC emissions accounting in the Renewable Energy Directive, and these should apply at the earliest possible date – these provisions were endorsed by the ENVI committee in the first reading.

It is welcome that the draft report reintroduces clearer ILUC calculations – deleting the range of ILUC estimates (AMs 36, 61, 71, 74) and the language overstating the ‘provisional and uncertain’ character of ILUC science. ILUC reporting should be further strengthened by the Parliament.

3. Promoting sustainable advanced biofuels and long term sustainable solutions to decarbonise transport
The draft report strongly seeks to promote advanced biofuels by reintroducing a 2.5% ‘sub-target’ for advanced fuels (AMs 4 and 46). However we believe that the green fuels of the future will only be green and viable if there are stronger sustainability checks in place. Many raw materials are already heavily in demand by other industries that may pose environmental risks if prioritised for energy.

Advanced biofuels should be carefully defined. A number of important sustainability provisions that were introduced by the Parliament in plenary vote, such as an improved and limited list of advanced feedstocks, should be restored in full. The Council position allowing additional unspecified feedstocks is too broad in scope and should be removed. Some useful safeguards introduced by the Council to respect the waste hierarchy – i.e. to prioritise reduction, reuse and recycling of waste before energy recovery – should be upheld, not deleted, by the Parliament (AMs 58 and 62 should be rejected). This is important to avoid the competing uses with other industries.

Lastly, renewable electricity in transport should be given greater support for a green transport future (AMs 11 and 44 should be rejected) by aligning the incentives for electric vehicles with advanced biofuels.

MEPs now have an opportunity to reinstate environmental and social credibility in these biofuels reforms – reforms that were originally instigated by the European Parliament. This can compensate for the Council’s position, which is much worse from the perspective of increased greenhouse gas emissions, food competition, biodiversity and subsidies. In this regard, we note that the EU Commission also “regrets... the significantly lowered level of environmental ambition”1 of the Council’s position, and appears to look to the European Parliament to restore balance.

Now is the time to seize the chance to correct the policy mistakes of the past and make a head start for the options of the future. We look forward to working with you to achieve that, and we remain fully available to further discuss this reform.

Yours faithfully,

Magda Stoczkiewicz

Director, Friends of the Earth Europe - on behalf of the above named organisations

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