Am 06.09. erreichte uns dieser dreiste Lobbyversuch vom European Biodiesel Board (EBB). Der EBB ist die Interessenvertretung der größten Biodieselproduzenten:
Dear Member of Parliament,
As a biodiesel sector committed to greening the EU’s road transport, we are very concerned about current developments in EU debates around indirect land use change (iLUC) and the future role of biofuels in the EU after 2020.
Next week Wednesday the 11th of September you will be asked to vote on the amendments of the Environment Committee and the Industry committee to amend Directive 98/70/CE relating to the fuel quality and Directive 2009/28/CE on the promotion of the use of energy from renewable sources. This vote will impact the existence of a whole industry. The amendments of the Environment Committee will have an undeniable negative impact on the approximately 220.000 jobs related to biofuels in the EU and on the billions of investments made in the last few years to grow and process European agriculture feedstock and produce biofuels.
In 2008, the European Parliament found the biofuels target of 5.75% not enough for the greening of European transport. The Renewable Energy Directive (RED) has only been adopted in 2009 by the Council and the European Parliament and set up an EU-wide target of 10% renewable energy in transport by 2020. The main pillars for this RED were supporting rural areas, increasing energy independence and reducing carbon emissions from transport. Biofuels were considered as a key solution to meet the 10% target, since they were readily available and could be directly added to fuels consumed in European cars and trucks. This reality has not changed. Currently the most strict sustainability criteria in the world—that embodied by the Renewable Energy Directive—ensure that only biofuels with high greenhouse gas savings compared to fossil fuels count towards the EU renewable energy target.
Indirect Land Use Change (ILUC) and updated ILUC values
The European Commission acknowledges that the iLUC science is immature and the results obtained from one study are unreliable to be the basis of legislation.[i] Most recent studies show that potential iLUC impact of biofuels is 80% to 95% lower than the iLUC values of the IFPRI study (2011) used in the Commission’s proposal and the ENVI amendments. In June 2013, the French National Institute for Agricultural Research (INRA) concluded in a 80% reduction of indirect emissions, with a value for biodiesel of 10gCO2eq/MJ. The French research center concludes that the ILUC model of IFRPI used lower values for increasing yields than actual observed data trends.
The new study Land Use Change Greenhouse Gas emissions of European Biofuel Policies Utilizing the Global Trade Analysis Project (GTAP) evaluates land us changes for several biofuels pathways and policies. This work has found that ILUC calculated using the latest version of GTAP are much less than those calculated by IFPRI in 2011. It concludes that biodiesel could account for as little as 2,33gCO2eq/MJ, compared to current 55gCO2eq/MJ allocated in a Commission proposal amending biofuels policy. The study concludes that the databases of the IFPRI are outdated and highlights the need for greater investment in this research field. In the light of such recent evidence, we do not believe that any ILUC values should be settled in European policy making.
Limitation of first generation biofuels will not solve world hunger
Biofuels production within the EU is not threatening the food supplies nor causing food price hikes in the rest of the world. In its recent study Long-term drivers of food prices the World Bank states that the role of biofuels in the rise of food prices is limited. For example only 1.5% of the global current arable land is used for biofuels. The World Bank points out that oilseed prices dropped when the EU increased impressively its use of biodiesel. To put things in perspective approximately one third of world’s food goes to waste according the FAO.
Food versus fuel is a false choice. The reality is that biofuel production in fact reduces global hunger by its substantial production of its co-products, particularly protein meal. Did you know that the crushing of rapeseed produces 60% protein meal and 40% vegetable oil? This is important as Europe has a big protein feed deficit for its livestock and depends on imports. EU biodiesel production led to the production of 13 million tons of protein meal, which corresponds to half of the EU protein meals produced. It is also a false choice as we have in the EU enough land to supply the food and fuel market. According Commission statistics over 1.5 million hectares of uncultivated agricultural land available within the EU and this acreage is growing.
The majority of EU biodiesel production relies on EU-grown rapeseed, boosting the economic activity of rural areas and generating an extra income for farmers. Rapeseed is an important element in the rotation of crops which increases the yields of subsequent cereal crops harvests the year after. For example rapeseed in a crop rotation can increase the yields of the subsequent cereal crop harvest by up to 11%.
ENVI Report is a serious threat for jobs, investments and advanced biofuels
The amendments of the ENVI committee are a serious concern to the European biodiesel sector; agriculture, green chemistry, oilseed crushing, R&D, and transport. The amendments of the ENVI committee will directly lead to a loss of many European jobs in the biodiesel industry and its supply chain and will make a significant share of the billions invested by the industry in good faith since 2009 redundant. This dramatic anticipated change in policy will definitely create a negative environment for further investments in advanced biofuels and R&D. The development of the second generation of biofuels depends on a stable first generation biofuels sector. The investors in the first and second generation are often the same and investments are long term commitments as well as consistent policy framework.
We as economic operators are convinced that this policy orientation doesn’t protect current investments at all. For example:
- · The suggested 5.5% cap for first generation is too low to reflect existing biofuel production capacity, built up by investors following the 2009 energy and climate change package.
- · iLUC factors for reporting or accounting, based on immature and inconsistent science, will lead to a direct distortion of the biofuel market, as biodiesel will not be blended any more in fossil fuels as it will be perceived as worse than fossil diesel
- · The proposed grandfathering approach does not provide the necessary mechanisms to protect investments and jobs linked to biofuels production
- · Support to advanced biofuels should consider all products from waste and residues within the dedicated target.
Valuable jobs and investments in Europe need to be protected. European investments, jobs and agriculture should not be punished for potential indirect effects in third countries that cannot be observed, and over which the European industry does not have any control. Europe should be proud of its innovation and investment in clean, sustainable biodiesel. Don’t turn your back on European farmers, European biodiesel industry and the progress we have made. We count on your support and vote!
|Raffaello GAROFALO |
EBB – European Biodiesel Board
Und hier ist die aktuelle grüne Position zu diesem Thema:
GHG emissions linked to Indirect Land Use Change impact of agrofuels (ILUC) 
|Rapporteur + Politic group+Nat.||Corinne LEPAGE (ALDE, FR)|
|Report Number and Committee||A7-0279/2013 ENVI|
|Procedure||legislative, first reading, shared competence with ITRE|
|Staff||Terhi Lehtonen, Michel Raquet|
Background – COM proposal
The Renewable Energy Directive established a mandatory target of 10% share for renewable energy in the transport sector. At the same time, the Fuel Quality Directive was amended to include a mandatory target of a 6% reduction by 2020 in the greenhouse gas intensity of fuels used in road transport. The contribution of biofuels towards these targets is expected to be significant. The sustainability criteria and minimum greenhouse gas saving thresholds do not currently take into account the carbon stock impacts resulting from indirect changes in land use (ILUC). According to scientific work climate impacts from indirect land-use change can vary substantially between feedstocks and can negate all of the ghg savings of biofuels relative to the fossil fuels they replace. Due to EP insistence, the legislation includes a mandate for Commission to come back with a proposal to address ILUC and to consider ILUC factors to the accounting. The Commission proposal (CLIMA and ENER) introduces a 5% cap on conventional food crop biofuels that can be accounted towards the RES targets. It also introduces ILUC estimate values to be used in reporting only, with a review clause to consider accounting them under sustainability criteria after 2020.
ENVI and ITRE reports
The conflict of competence between ENVI and ITRE was resolved through an agreement to have ENVI as lead committee but granting ITRE shared competences on the whole proposal. This means ITRE could retable to plenary any amendment that was not adopted by ENVI. Main content of the ITRE report: 6.5% cap for biofuels from food crops, without energy crops; mandatory 7,5% share of ethanol in petrol by 2020; sub-target for advanced biofuels: 0.5% in 2016, 2.5% in 2020 and 4% in 2025 (including forestry residues, energy crops and animal fats, without sustainability safeguards); references to ILUC factors deleted or weakened. ITRE final vote 47 in favour, 8 against (5 Greens, one S&D, one GUE and one independent).
Contrary to the very negative ITRE outcome, ENVI voted for a strengthening of the Commission proposal, partly through compromises and partly as a result of the vote on individual amendments. ENVI report main content: ILUC factors in accounting for FQD from 2018, and for RED (i.e. in accounting towards sustainability cut of saving criteria) without grandfathering (!), 5,5% cap for biofuels from food crops, incl energy crops; binding FQD target trajectory prior/beyond 2020; MS can opt out from 10% if overall target met, sub-target for advanced biofuels: 2% in 2020 (including strong safeguards). ENVI final vote 43 in favour, 26 against (large part EPP, ECR).
Strategy for plenary
Claude will do his outmost to try to prevent ITRE from tabling all amendments to plenary. In order to support the ENVI outcome we will table very few if any amendments to plenary. The +/- in end vote and vote on deferral of final vote will depend on the plenary vote outcome on ILUC factors and the cap on food-based fuels allowed in 2020.
Vote in Committee
|Vote of our group||in favour|
|Vote of the others groups – Majority||43-26-1 (EPP, ECR majority against)|
Strategy for the Plenary Session
|Amendments tabled by our group||possibly one on banning subsidies to agrofuels|
|Proposal – Vote our group||+/- depending on vote result|