Memorandum submitted by James Levy
Re: the dangerous adverse consequences of the
present combination of biofuel incentives and free trade policies.
I would like to testify that:
1. Attempts to reduce climate impacts using
biofuel incentives are being frustrated by subservience to a free
trade agenda on the source commodities both by the UK and EU as
2. In particular, it is strongly evidence
that the current free market policy on vegetable oils means that
biodiesel incentives are having a dramatically counter-productive
2.1 palm oil grown in tropical countries
is able to undercut all other potential large-scale sources of
2.2 the additional market for palm oil is
pushing its market price and leading to massive speculative forest
clearance for new plantations.
2.3 deforestation itself, and oxidation of
peat beds accelerated by forest clearance, are very considerable
sources of carbon dioxide discharges, while the forests and peat
beds are valuable carbon sinks, but conventional biofuel life
cycle emissions models do not account for this.
2.4 the effect of these massive discharges
is to narrow, not widen, the window of opportunity to stabilize
greenhouse gas levels below a critical threshold.
2.5 in addition, the loss of precious natural
heritage (orang-utan) and displacement of native peoples must
3. The effect of the free market is that
even if the government disqualified palm oil from the Renewable
Transport Fuels Obligation, the additional demand for veg-oil
would create new demand for palm oil in the wider veg-oil market.
4. Incentives for soya oil are also being
criticized for encouraging forest displacement.
5. The consequences of incentives for bioethanol
replacing petrol are more complex and unclear, but are still deserving
6. The government has not taken adequate
account of, and has sometimes omitted reference to, major adverse
consequences of current biofuels policies:
6.1 The 2006 Budget (item 7.67) has not disqualified
any kind of imported biofuels from the Fuel Duty Discount. This
creates a boundless market for imported biofuesl, in particular
palm and soya oil, beyond the dictates of the EU biofuels directive
and regardless of their adverse consequences.
6.2 The 2006 Budget (item 7.66) stated that
it intends to increase biofuel incentives after 2010-11 subject
to infrastructure, vehicle capabilities nad cost, while "ensuring
biofuels are sourced sustainably" (7.68) with no caution
expressed or mention of potential adverse environmental consequences.
6.3 The 2005 Pre-Budget Report (item 7.54)
announced consultations with "stakeholders" over the
implementation of biofuels incentives, but not with conservationists
or anyone else.
6.4 "Climate Change, The UK Programme
2006" report notes that emissions savings are lower than
headline due to the agricultural and processing costs (section
5 Transport, 17). However, such models do not allow for the massive
carbon discharges when rainforests are displaced, or loss of their
value as carbon sinks, which is occurring considerably in practice
(see 2.1-2.3 above).
6.5 The plans to encourage sustainable supply
(ibid, 21-23) appear insufficient to deter the displacement of
the additional demand for veg-oils on to new forest clearances
for palm oil (as set out in 2 above) in the current free market
approach to the supply commodities adhered to by the UK nad wider
Appendices [not printed]
1. "Worse Than Fossil Fuel", article
b George Monbiot in The Guardian, 6 December 2005, pages 1-3.
2. Canadian government report "Vegetable
Oils: Competition in a changing market", 10 June 2005, pages
3. "CPO Prices Seen UP in 06 As Biodiesel
Fuels Demand", Dow Jones Newswires, 24 February 2006 pages
4. "Asian peat fires add to warming",
BBC News, 3 September 2005 pages 1-2.
5. "Soya is not the solution to climate
change", letter by WWF-Brazil to The Guardian, 16 March 2006.
6. "EU must ensure bioenergy is really
green", press release by Birdlife (international federation
of bird protection societies), 7 December 2005.