Select Committee on Environmental Audit Minutes of Evidence

House of Commons Environmental Audit Committee inquiry Are biofuels sustainable?

Memorandum by the Joint Nature Conservation Committee, 28 September 2007

  The Joint Nature Conservation Committee (JNCC) is the statutory adviser to Government on UK and international nature conservation, on behalf of the Council for Nature Conservation and the Countryside, the Countryside Council for Wales, Natural England and Scottish Natural Heritage. Its work contributes to maintaining and enriching biological diversity, conserving geological features and sustaining natural systems.

1.  What are the possible positive and negative social, environmental and economic consequences of biofuels? How might trade-offs between climate benefits and environmental and social impacts be made? Is there a need to develop a new biofuel strategy for the UK or EU, to balance the environmental, social, economic and climate impacts of biofuels?

Environmental impacts of biofuel production

  1.1  We recognise the potential positive contribution biofuels could make to reducing greenhouse gas emissions, ensuring energy security, and providing economic and social benefits, particularly in developing countries. However, we are concerned that the rapidly growing biofuel industry and trade will, without appropriate safeguards, add another significant pressure on the environment with negative consequences for biodiversity and the supply of ecosystem goods and services1. Recent evidence demonstrates that biodiversity loss is already occurring as a direct or indirect consequence of biofuel production2.

  1.2  In the UK, Europe and globally, environmental damage may occur through:

    i.  land use changes to accommodate energy crop plantations which result in loss, fragmentation and degradation of valuable habitats (especially grasslands, forests, wetlands and extensive agricultural areas) and negative impacts on associated biodiversity and ecosystem services;

    ii.  intensification of agricultural production, ie increased use of agro-chemicals and water resources which leads to water shortages, increased water pollution and eutrophication, and soil degradation and erosion;

    iii.  the release of carbon from natural carbon stores, such as peatlands and forests, through land use changes, negating any carbon savings made through the use of biofuels whilst at the same time increasing global greenhouse gas emissions;

    iv.  displaced food production encroaching on valuable habitats (land leakage); and

    v.  the unregulated use of genetically modified feedstocks (outside Europe), which may be damaging to wildlife, competitively displace native species, or lead to gene flow with native species.

An example of habitat loss—the use of palm oil as a feedstock for biodiesel

  1.3  JNCC is concerned about the rapid loss of areas with high biodiversity, such as rainforests and tropical peatlands, in key biomass/biofuel-producing countries. The conversion of valuable habitat to palm oil plantations in south-east Asia is of particular concern.

  1.4  Palm oil is the second most traded vegetable oil crop in the world, after soy3, and over 83% of the world's palm oil exports are produced in Malaysia and Indonesia4. Palm oil is mostly used in the manufacture of food and is found in one out of ten products sold in UK supermarkets5. Currently, only approximately 3% of imported palm oil is used for biodiesel production in Europe6. However, this new market has the potential to dramatically increase global demand for palm oil, which will further fuel the destruction of valuable habitats in the countries in which it is produced.

  1.5  It has been suggested that as much as 87% of Malaysia's deforestation between 1985 and 2000 was caused by the expansion of oil-palm plantations7. Malaysia has now reached its natural land limit for new plantations and most of the new oil-palm cultivation areas are being cleared in neighbouring Indonesia, which has recently earmarked six million hectares for biofuel production8. Between 1967 and 2000 the total oil-palm area in Indonesia grew from less than 2,000 km2 to over 30,000 km2. The demand for palm oil is expected to double this area by 2020, which implies the conversion of another 30,000 km2 of forest and tropical peatland9.

Increase in global greenhouse gas emissions

  1.6  JNCC is also concerned that the land use changes associated with some biofuel production will not only negate any potential carbon savings made through the use of transport biofuels but will considerably increase global greenhouse gas emissions.

  1.7  Research demonstrates that the draining of tropical peatlands and the clearance of tropical rainforests are a major source of greenhouse gas emissions. Peatlands cover just over 3% of the world's land area yet are the largest terrestrial store of biomass carbon10. Of this, 7.6% is found in south-east Asia, which stores 42 billion tonnes of carbon11. A recent study showed that 27% of oil-palm plantations in Indonesia are planted on drained peatlands12. When peatlands are drained, cleared and burned for agriculture or energy crop production, there are two sources of emissions, one from peat oxidation, the second from fire. Together, these emissions from south-east Asian peatlands, which cover just 0.2% of the world's land surface, are responsible for the release of two billion tonnes of CO2 to the atmosphere each year (equivalent to 8% of annual global emissions)13. Indonesia alone contributes 75% of this figure, making it the world's third largest greenhouse gas emitter after the USA and China. Biodiesel produced from feedstocks grown on cleared peatlands emits five times as much carbon over its life-cycle as conventional diesel14.

  1.8  Clearly, some biofuels are not effective in mitigating climate change. The conservation of existing forests, peatlands and savannahs and the restoration of natural forests and grasslands is a far more effective climate change mitigation measure than the production of biofuels. A recent study has shown that afforestation of an equivalent area of land to one set aside for energy crop cultivation would sequester two to nine times more carbon over a 30-year period than the emissions avoided by the use of biofuels15.

Social and economic impacts of biofuels

  1.9  The social and economic impacts of biofuels can be positive or negative depending on the way they are produced.

  1.10  Positive social and economic benefits of biofuel production include opportunities for rural development through job creation and the generation of extra income for small-holder farmers, especially in developing countries. For example, sugarcane production in Brazil (which is directly related to bioethanol production) employs around one million workers and the number is expected to grow by 204,000 in the next five years. In China, the liquid biofuel programme is predicted to create up to 9.26 million jobs across the country, thus leading to a significant increase in income generation and rural development16. Fuel security for rural areas in developing countries is another benefit from biofuel production.

  1.11  On the other hand, increased energy crop production may lead to "food versus fuel" conflicts, potentially exacerbating poverty. It is likely that greater demand for biofuels will lead to land being drawn away from food production, thus increasing food prices. Corn prices, for example, reached an 11-year high this year of $4.30 a bushel, while wheat prices rose to $6.96 a bushel at the beginning of August. The US biofuel industry consumed 20% of the country's corn crop, far more than in the past. The US demand for corn led to increases in prices for Mexico's staple food, the tortilla; the price for tortilla tripled, leading to riots earlier this year17.

  1.12  In addition, industrial-style cultivation of bioenergy crops could conflict with the diversified agriculture traditionally practiced by family businesses, cooperatives and rural communities and may lead to the displacement of indigenous communities and small-holder farmers18. This would increase reliance on bought-in food stuffs and fuel, whose prices and availability could be affected by both biofuel demands and natural events such as droughts. It would also open up these fragile communities to long-term issues of sustainable food production, particularly if biofuel markets decline (eg due to the increased use of second-generation technologies). This could be especially dire if sustainable farming practices and locally adapted crop varieties have been lost to intensive forms of production.

  1.13  There are also concerns that widespread biofuel production may result in, or exacerbate, poor labour practices. There is evidence in some developing countries that the cultivation of certain feedstocks, notably sugarcane and palm oil, is linked to poor working conditions, health and safety risks, child labour and forced labour19.

Trade-offs between climate benefits and environmental and social impacts

  1.14  JNCC acknowledges that some trade-offs will have to be made. However, we believe that biofuel policy must meet certain minimum environmental and social standards, as set out in 1.18.

The need for a UK/EU biofuel strategy

  1.15  Achieving the politically agreed European Union target of 10% biofuel in transport fuels by 202020 will require (based on current estimates of fuel use in 2020) approximately 42 million tonnes of liquid biofuel—20 million tonnes of biodiesel and 22 million tonnes of bioethanol, assuming equal substitution21. Much of the biomass will have to be imported. The European Commission estimates that imports could be as low as 10% of the total biofuel market if 30% of the EU's biofuel could be produced using second-generation technologies. However, if second-generation technologies are not available, imports would make up to 50% of the total biofuel market22. The EU demand for biomass for bioenergy therefore has the potential to significantly distort global food supplies and promote land use changes in supplying countries (particularly in the tropics) that will have significant negative social and environmental impacts, with limited benefits for greenhouse gas reductions and fuel security.

  1.16  Biomass production will also have a considerable impact on land use within the EU. To achieve the 10% target it has been estimated that as much as 38% of the EU's current cropland area could be required for bioenergy crops23.

  1.17  Energy crops in the UK currently only account for a small percentage of land use and, to date, a high proportion of bioenergy feedstocks have been imported. A large area could be cropped in future for biofuels, particularly land currently used for conventional food crops. Increasing the area of land used for biofuel production in the UK will impact on the provision of ecosystem goods and services, such as food, fibre and timber production, wildlife conservation, recreation, flood protection and carbon storage. The nature and scale of the impact will depend on the type of feedstock grown, whether production is intensive or extensive, the total area of land used for biofuels and its spatial distribution.

  1.18  Against this background, it is essential that there is a UK and EU strategy for biofuels, the primary aim of which should be to achieve sustainable biofuel production and use. JNCC believes that any future biofuels policy should, as a minimum:

    i.  sit within a policy context that seeks to improve energy efficiency and reduce total energy demand;

    ii.  deliver considerable reductions in greenhouse gas emissions compared to conventional fuels, based on whole life-cycle carbon assessment;

    iii.  fully assess both the negative and positive environmental impacts of all aspects of biofuel production and use, and ensure that no significant biodiversity loss occurs as a consequence of its production;

    iv.  not lead to the degradation of ecosystem services and consequent negative impacts on human well-being and poverty;

    v.  be consistent with existing environmental policy commitments, policies and legislation24, and in particular should not compromise the EU's commitment to halt the decline in biodiversity in the EU by 2010, nor the global World Summit on Sustainable Development commitment to significantly reduce the rate of biodiversity loss by 201025;

    vi.  be guided by the Precautionary Approach26 and the Ecosystem Approach27, as promoted by the Convention on Biological Diversity;

    vii.  incentivise research into biofuel technology (such as second-generation) which leads to more efficient production with lower environmental impacts; and

    viii.  consider both positive and negative social impacts of all biofuel production and use, and ensure their production is consistent with long-term sustainable land use practices which do not exacerbate poverty through the unsustainable use of natural resources.

  1.19  Within the UK, it will be necessary to assess the potential for biofuel production against other mechanisms and capacity for energy production (including other renewables). It will also be essential to ensure that the planning system is able to respond to competing land use demands, and, if necessary, to establish spatial planning methodologies which take into account multiple land uses and ensure that only land environmentally suited for energy production is used for this purpose.

  1.20  Biofuel production in the UK from conventional crops such as wheat and oil seed rape is not particularly carbon-efficient. The UK's climate is better suited to growing biomass crops such as short-rotation coppice and miscanthus. Furthermore, such crops are best suited to produce heat or power locally given the costs (financially and in carbon emissions) of transport. The use of such crops is currently constrained by a lack of infrastructure and markets28.

2.  Should biofuels be regulated to minimise the negative environmental and social impacts, and in what way? How might regulation fit in with international trade agreements and rules? Should there be regulation of the entire carbon cycle of biofuels?

  2.1  JNCC believes that biofuel production should be regulated and incentivised by policies which minimise negative environmental and social impacts. Such policies should be underpinned by the principles set out in 1.18 and must take account of the whole carbon life-cycle of biofuels29.

  2.2  JNCC believes that it is crucial to develop stringent global sustainability standards for biofuels. Our ideal long-term solution would be for mandatory criteria to be developed. Such standards should be developed in association with the WTO, and may require the adjustment of existing WTO rules.

  2.3  We recommend that the UK Government should push for an international agreement regulating the bioenergy market and laying down rules and standards for environmentally sustainable biofuel production and use. A step towards this would be to engage with the UN Food and Agriculture Organisation (FAO), which is organising a high-level bioenergy meeting in June 200830. We also recommend that the UK should continue to cooperate with the Global Bioenergy Partnership and the International Bioenergy Platform, both located at FAO's headquarters, in order to promote the development and adoption of sustainability criteria.

  2.4  Minimum environmental land use standards in the UK and EU mean that the potential environmental impacts of biofuel production will not be as severe as those that might be experienced in other countries where such standards do not exist. Farmers in the UK and EU are required to meet minimum environmental standards, such as codes of practice and legislation (eg relating to water quality). Where they are in receipt of EU funding (such as the Single Farm Payment) the requirements of Good Agricultural and Environmental Condition (GAEC) also have to be met. Such conditions will go some way to ensuring environmental impacts are reduced, and areas important for wildlife are not threatened with land conversion. However, the regulatory framework and GAEC are insufficient to address issues such as diffuse pollution and soil erosion. Other potential changes, such as the use of set-aside for energy crops, could also have negative implications for biodiversity.

3.  How successful are existing international structures, such as the Roundtable on Sustainable Palm Oil, at ensuring that imports of biofuels can be obtained from sustainable sources? To what extent is it currently possible to identify the provenance and production standards of imported biofuels?

International structures

  3.1  Existing international structures include the Roundtable on Sustainable Palm Oil (RSPO), established in April 2004, the Roundtable on Responsible Soy (RTRS), launched in November 2006, and the Better Sugarcane Initiative (BSI), set up in 2005. These initiatives are still new and need time to develop further. They provide a good starting point but have limitations.

  3.2  The RSPO's principles and criteria for sustainable palm oil production, published in October 2005, are currently being applied during a pilot implementation period of two years. Therefore RSPO is not yet operational and no certified palm oil is on the market today. The current membership of the RSPO only covers around 40% of the world's palm oil production31, and so global sustainability is not ensured through this mechanism.

  3.3  The RSPO criteria are not specifically focussed on the production of palm oil for bioenergy, and so some sustainability issues are insufficiently covered. In particular, RSPO does not have a criterion on minimum greenhouse gas savings compared to fossil fuel alternatives and does not sufficiently address changes in carbon stock resulting from land use change (eg RSPO has a criterion on the conservation of primary forests and forests with High Conservation Values but does not exclude deforestation of other forests or production on peat soils)32.

  3.4  An example of a more mature certification scheme, which, although not related to biofuels, may offer some pointers for the future development of the initiatives listed above, is the Forest Stewardship Council (FSC), which has been working since the mid-1990s. A recent study of the impacts of the FSC in developing and transitioning countries33 identifies many positive effects of forest certification for workers, communities and the environment, although some issues, such as illegal logging and increasing demand for certified products which is outstripping supply, still need to be addressed. However, in the case of the Asia Pacific region, results are rather disappointing. This is mainly due to the lack of support from governments and industry. Overall, the market still focuses heavily on unsustainable timber production.

Identifying the provenance and production standards of imported biofuels

  3.5  Understanding the social, economic and environmental impacts of biofuels sourced from outside the EU requires the materials imported to be quantified and traced to source areas within producing countries. Customs data from national sources, Eurostat or the UN Comtrade database, provide the basis for a "first order" analysis of commodity quantity and value and the country of origin. Other sources are needed for "second order" analysis, which tracks individual biofuel commodities to specific source areas, enabling assessment of production techniques, social and other impacts, and assignment of sustainability criteria.

  3.6  There is currently no specific customs classification for bioethanol for biofuel production. Ethanol is traded under customs HS code 2207, which covers un-denatured (HS 2207 10) and denatured alcohol (HS 2207 20). Both denatured and un-denatured alcohol can be used for biofuel production. It is not possible to establish from trade flows and customs returns alone what share of EU imported alcohol is used in biofuel production as opposed to other industrial or food applications34.

  3.7  International trade in biodiesel is recorded under customs code 38249099 but trade in biodiesel, in contrast to plant oils that can be converted into biodiesel, is currently minimal. Trade flows show that plant oil feedstocks are extensively traded internationally and that oil processing into biodiesel takes place in countries different from those which produce the feedstocks. The EU, as the largest global producer of biodiesel, imports palm, soya and rapeseed oils to supplement domestically produced rapeseed oil on which the EU industry is currently based. The multiple potential uses of plant oils makes it difficult to track the percentage of EU imported plant oil that is devoted to biofuel manufacture as opposed to feed and food consumption or other industrial uses.

  3.8  Global flows, in terms of volume and value of biofuels and their feedstocks, can be mapped using international trade statistics. These can show source country, destination country and the weight and value of the commodity but cannot identify end use of the commodity. Effective quantification of bioenergy use of imported ethanol and plant oils will require reporting mechanisms other than EU and Member States' customs requirements. These mechanisms will need to identify the "end use" of imports that can be used for various industrial applications, only one of which is bioenergy.

4.  At what stage is biofuel technology? Is there enough support for the development of biofuel technology? A UN report found that the climate change benefits of solid biomass fuels outweigh those of liquid biofuels. Are current policies promoting the development and deployment of a range of biofuel technologies? How successful have EU strategies and Directives been in stimulating biofuel usage? Will the 2010 biofuel target be reached? How effective are the Government's fiscal arrangements for biofuels?

The development of biofuel technology

  4.1  Given the benefits of second-generation biofuels over first-generation biofuels (greater carbon savings, less land-take, less waste), the UK and EU should make sufficient research and technology investments to enable a rapid switch to second-generation biofuels. EU structural funds could provide key funding for bioenergy investment.

Reaching the 2010 biofuel target

  4.2  JNCC welcomes the UK's and EU's commitment to greenhouse gas reduction in the transport sector and the ambitious targets for renewable transport fuels. However, a precondition must be that these targets are achieved in an environmentally sustainable way.

  4.3  Meeting the EU bioethanol target in 2010 will require 10-14 million tonnes of ethanol35. The European Bioethanol Fuel Association estimates that in 2006 the EU produced approximately 1.3 million tonnes of ethanol. Even with continued growth (eg the potential to produce over five billion tonnes in 2008) there is likely to be a considerable shortfall for 2010. Imports of ethanol to the EU have risen year on year over the past five years, doubling from 2002 to 2006, with three million tonnes imported in the latter year36. Over a third of the globally traded ethanol is imported to the EU. The 2010 EU target for ethanol substitution is, however, likely to be met by few Member States, and so total bioethanol demand for 2010 may not significantly exceed domestic capacity although imports may remain high because of price differences and EU production potentially being below capacity.

  4.4  With regard to biodiesel, the full achievement of the EU target would require approximately 13 million tonnes of biodiesel37. Production in 2006 was nearly five million tonnes and capacity for 2007 is expected to reach 10 million tonnes, although market fluctuations mean that production is unlikely to reach this figure. The plant oil feedstocks needed for biodiesel production will increasingly come from beyond the EU as production from domestic rapeseed oil begins to peak. It is unlikely that the 2010 target will be met.

  4.5  The probable failure of the EU to meet its 2010 target for biofuel substitution should be seen as fortuitous in that the target could only be met by use of significant imports for which no effective sustainability criteria have been established. Delay in reaching substitution targets offers the opportunity to develop effective monitoring and control measures in anticipation of growth in biofuel use beyond 2010.

5.  How might farm viability in both developed and developing countries change with an expansion of biofuels? What implications are there for poverty in developing countries? Should we be concerned about large monopolies forming in the biofuel sector?

  5.1  In developing countries, many people are directly reliant on natural resources, including land for subsistence agriculture, wild food sources, wood for fuel, and water. These ecosystem goods and services are potentially threatened by biofuel monopolies and monocultures, leading to increased poverty and other social problems that the Millennium Development Goals seek to address. Inappropriate land use changes or the introduction of monocultures will therefore have a negative impact on the attainment of the Millennium Development Goals. We recommend that any expansion of biofuel production in developing or developed countries must meet the minimum requirements outlined in 1.18.

  5.2  It is important that developing countries do not exploit least developed countries. In some southern African countries (eg Zambia and Malawi) jatropha is being grown to create biodiesel for export, at the expense of food production for local populations who depend on food aid38. The introduction of minimum policy measures is essential if anomalies such as these are not to increase.

  5.3  The points made in 1.12 are also relevant here.

28 September 2007


1.  The Millennium Ecosystem Assessment describes ecosystem goods and services as the benefits people obtain from ecosystems. These include provisioning services such as food, water, timber, fuel and fibre; regulating services that affect climate, floods, disease, wastes and water quality; cultural services that provide recreational, aesthetic and spiritual benefits; and supporting services such as soil formation, photosynthesis and nutrient cycling.

2.  For example: European Environment Agency (EEA). (2007). How much bioenergy can Europe produce without harming the environment? EEA report no 7/2007; UNEP/UNESCO. (2007). The last stand of the orang-utan, state of emergency: illegal logging, fire and palm oil in Indonesia's national parks. Rapid response assessment; Friends of the Earth. (2005). The oil for ape scandal, how palm oil is threatening the orang-utan. Research report.

3.  Oil World (1999), cited in Casson, A. (2003). Oil-palm, soy beans and critical habitat loss. WWF Forest Conversion Initiative, Gland, Switzerland.

4.  The US Department of Agriculture has forecasted that Indonesian palm oil production will reach 17.2 million tonnes in 2006-07, in comparison to Malaysia's 16.5 million tonnes. See: F.O. Licht's World Ethanol & Biofuels Report, Indonesia set to become largest palm oil producer, 11 May 2007.

5.  Friends of the Earth. (2005). The oil for ape scandal, how palm oil is threatening the orang-utan. Research report.

6.  Raffaello Garofalo, Secretary General of the European Biodiesel Board at the World Biofuels Market conference, Brussels, February 2007.

7.  Friends of the Earth. (2005). The oil for ape scandal, how palm oil is threatening the orang-utan. Research report.

8.  Guerin, B (2007). European blowback for Asian biofuels. Asia Times, 8 February 2007.

9.  FWI/GFW. (2002). The state of the forest: Indonesia. Forest Watch Indonesia, Global Forest Watch, World Resources Institute, Washington; also: UNEP/UNESCO. (2007). The last stand of the orang-utan, state of emergency: illegal logging, fire and palm oil in Indonesia's national parks. Rapid response assessment.

10.  Hooijer, A. et al (2006). PEAT-CO2, Assessment of CO2 emissions from drained peatlands in SE Asia. Delft Hydraulics Report Q3943, The Netherlands. See also: Global Canopy Programme. (2007). Forests first in the fight against climate change. The VivoCarbon Initiative.

11.  Biofuelswatch. (2007). Biofuels threaten to accelerate global warming.

12.  Hooijer, A. et al (2006). PEAT-CO2, Assessment of CO2 emissions from drained peatlands in SE Asia. Delft Hydraulics Report Q3943, The Netherlands.

13.  Ibid.

14.  Global Canopy Programme. (2007). Forests first in the fight against climate change. The VivoCarbon Initiative.

15.  Righelato, R. & Spracklen, D V (2007). Carbon mitigation by biofuels or saving and restoring forests? Science, Vol. 317, pp. 902.

16.  Ibid.

17.  Blas, J (2007). UN food chief urges rethink on biofuels. Financial Times, 15 August 2007; Fuel or food? Reuters, 23 February 2007.

18.  WWF Germany. (2006). Sustainability standards for bioenergy. Frankfurt am Main.

19.  Dufey, A (2006). Biofuels production, trade and sustainable development: emerging issues. International Institute for Environment and Development, London, UK.

20.  European Council conclusions, 8-9 March 2007, 7224/1/07 REV 1.

21.  Weighell, T (2007). The global implications of EU biofuels consumption in 2020. An initial analysis. JNCC, Peterborough, UK. Unpublished.

22.  European Commission. (March 2007). The impact of a minimum 10% obligation for biofuel use in the EU-27 in 2020 on agricultural markets. Impact assessment for European Energy Roadmap. Brussels.

23.  Righelato, R & Spracklen, D V (2007). Carbon mitigation by biofuels or saving and restoring forests? Science, Vol. 317, p. 902; International Energy Agency. (2004). Biofuels for transport: an international perspective, chapter 6. IEA, Paris, France.

24.  Within the EU, key environmental commitments include achieving Favourable Conservation Status according to the Habitats Directive, achieving good environmental status according to the Water Framework Directive, and the targets and actions of the 2006 Biodiversity Communication and Action Plan.

25.  The EU target was agreed by EU Heads of State and Governments at the Gteborg European Council (15/16 June 2001) ( The international target was adopted by governments at the World Summit on Sustainable Development in Johannesburg in 2002.

26.  The Precautionary Approach was adopted by the UN Conference on the Environment and Development in Rio de Janeiro in 1992 and stipulates that in order to protect the environment, a precautionary approach should be widely applied, meaning that where there are threats of serious or irreversible damage to the environment, lack of full scientific certainty should not be used as a reason for postponing cost-effective measures to prevent environmental degradation.

27.  For background information on the Ecosystem Approach see

28.  Wildlife and Countryside Link. (2007). Bioenergy: environmental impact and best practice. Prepared for Wildlife and Countryside Link by Land Use Consultants, UK.

29.  For whole life-cycle analysis, see CONCAWE/ EUCAR (European Centre for Automotive R&D)/ JRC (European Commission Joint Research Centre). (2006). WTW study.

30.  Jacques Diouf (FAO Director General). UN food chief urges rethink on biofuels. Financial Times, 15 August 2007.

31.  Essent (2007). Sourcing palm oil from sustainable sources. The Netherlands.

32.  Ibid.

33.  Cashore B, Gale F, Meidinger E & Newsom D (2006). Confronting sustainability—forest certification in developing and transitioning countries. Yale School of Forestry & Environmental Studies.

34.  USDA Foreign Agricultural Service GAIN Report. (2006). EU-25 agricultural situation import duties for biofuels.

35.  Von Wissel, A (2006). Biodiesel's growths in Europe and its impact on the oilseed industry. President of the EU Oil and Proteinmeal Industry (FEDIOL), PowerPoint presentation, San Francisco, USA, 16 June 2006.

36.  F O Licht. (2007). World ethanol and biofuels report. Germany.

37.  Von Wissel, A (2006). Biodiesel's growth in Europe and its impact on the oilseed industry. President of the EU Oil and Proteinmeal Industry (FEDIOL), PowerPoint presentation, San Francisco, USA, 16 June 2006.

38.  Global Forest Coalition and Global Justice Ecology Project. (2007). From meals to wheels: the social and ecological catastrophe of agrofuels.

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