Memorandum submitted by the Agricultural
Biotechnology Council
INTRODUCTION
The Agricultural Biotechnology Council (abc)
welcomes the opportunity to respond to the Environmental Audit
Select Committee's inquiry on biofuels. Our submission will seek
to respond to each of the questions posed by the Committee.
abc is the umbrella group for the agricultural
biotechnology industry in the UK. The companies involved include
BASF, Bayer CropScience, Dow Agrosciences, Pioneer (Du Pont),
Monsanto and Syngenta. Our aim is to provide information about
genetically modified (GM) crops in the UK and around the world
and in particular describe the important role of GM technology
in delivering sustainable agriculture of which biofuels could
be an important element.
EXECUTIVE SUMMARY
— Farmers should be in a position to
utilise and benefit from opportunities arising from the growing
demand for biofuels grown in the UK.
— The provision of biofuels needs to
be balanced with food security and the provision of a diverse
countryside.
— Given the limited land available
in the UK, it must be used as efficiently as possible, and modern
crop technologies, such as GM, that can help increase productivity
and environmental sustainability of both food and fuel should
be used to help deliver this.
— In the longer term, GM technology
has a contribution to make in developing a sustainable agricultural
sector in the UK as it is already doing elsewhere in Europe and
other parts of the world. Such sustainability, based on both production
efficiency and the delivery of environmental benefits, will be
important if we are to achieve ambitious targets set for biofuel
adoption.
— The term "biofuels" covers
a variety of different fuels, crops and processes. There will
be regional variations in selection and promotion of biofuel systems
appropriate to local conditions and situations, but UK crop-based
biofuel production will be an important component of that mix.
RESPONSES TO
SPECIFIC QUESTIONS
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?
a) Environment—Several studies have
been published on the eco-efficiency of biofuels[1]
which all found that CO2 savings with the present biofuel technologies
are between 20% and 80% (depending on the crop and conversion
process) compared with using conventional petrol. In the future
it is possible that this may increase to 90% and higher for second
generation biofuels such as cellulosic ethanol which can be facilitated
through genetic modification. High energy feedstock, less fuel
intensive cultivation of crops and low carbon conversion processes
could further help us to achieve this. Even within current generation
biofuels, a study conducted for Northeast Biofuels has shown that
total life cycle carbon efficiency for rapeseed-based biodiesel
can be as high as over 90% providing allowance is made for the
savings from use of meal co-product as fuel. (Mortimer and Elsayed,
2006, see http://www.northeastbiofuels.com/)
b) Economics—Some biofuels have demonstrated
economic viability, depending on the fluctuating prices of the
feedstock commodities relative to the crude oil price, although
in early stages of development it is often the case that support
is necessary to facilitate viability of production. Because biofuels
can be blended with existing transport fuels, and are compatible
with existing vehicles, their use as blends with conventional
fuels enhances their economics. Biofuel production also has the
potential to create jobs, in both rural communities in the UK
and EU (as has been demonstrated by studies in Germany and elsewhere)
and also offers opportunities to developing countries where expansion
of certain crops and local processing will be needed to help supply
internationally traded biofuels.
c) Social—The impact of biofuels as
a major new supply and demand sector will undoubtedly have societal
implications, potentially both positive and negative, and it is
vital that these receive proper attention and analysis. However
such an analysis should not be disabling or lead to unjustified
constraints or delays in the development of biofuels production
and technology. To take one major area of debate, there is clearly
a need to meet the demand for both the food and fuel supply. The
growth of biofuels should not jeopardise any country's ability
to secure its peoples' food supply. Nor should it prevent achieving
sustainable agricultural and environmental priorities such as
protecting forests, soil fertility, water, biodiversity while
enhancing waste reduction. Nevertheless, some commentary on this
subject has suggested that non-food crops should be used for biofuels.
We consider that this position has disregarded some basic realities.
Optimum production efficiency of biomass should not discriminate
between crop or plant species or variety, but should be based
on the most efficient productivity, in order to optimise use of
land and natural resources. There is a powerful argument that
obtaining both fuel and food supplies from a common resource provides
flexibility in the event of temporary shortages. In the event
of natural disasters, such as flood or drought, potential crops
can readily be diverted from fuel to food supply.
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?
a) abc supports moves to ensure that biofuel
production should not adversely impact environmental or societal
needs, but urges that any measures implemented should be proportionate
and not adversely affect industry competitiveness within the UK
or EU.
b) abc recognizes that this goal can be
achieved through either regulation or non-regulatory, voluntary
means, or indeed a combination. Often non-regulatory approaches
can be more successful in delivering such aims, and can do this
at much lower cost. There are many good examples of this, such
as the development of Round Tables (on palm, soya, and biofuels),
industry-led crop assurance schemes and non-governmental environmental
stewardship schemes (such as LEAF). The consultation is right
to recognize that considerations of international trade, and trade
agreements will be central to the success or failure of measures
to manage and control environmental and societal impacts of biofuels.
It would be detrimental to the economics of industry within the
EU to implement punitive and disabling regulation upon its member
states whilst international competitors are free of such constraints.
abc strongly recommends that any such measures should be developed
in full consultation with industry representing entire supply
chains.
c) More specifically:
i) abc believes that the current European
framework for the sustainability of biofuels is a credible attempt
to reduce greenhouse gas emissions from road transport fuels.
We recognize that concepts and measures to deliver carbon and
sustainability standards on biofuel production are currently in
active development.
ii) Within the EU, extensive environmental
protection measures already apply to agricultural production,
and we believe that these measures can readily apply to biofuels
from crops, but should not prejudice biofuels development in comparison
with other commodity sectors.
iii) abc believes that farmers should be
able to access new technologies, including genetically modified
crops, to help them compete in the global market and produce crops
in a sustainable manner. This will be an essential foundation
if high quality, affordable biofuels are to be produced in such
a way to minimise the environmental footprint.
iv) Biotechnology, including genetic marker
assistance, genomics and genetic modification, are already delivering
improvements which help enhance the productivity and environmental
benefits of crops for biofuel productivity, and developments within
research pipelines promise even greater benefits to come. For
example, crops which have enhanced nitrogen utilisation efficiency
are already under evaluation in field trials. Such crops promise
significant improvements in the productivity per unit input of
nitrogen fertilizer, which is a major component of the input side
of carbon and greenhouse gas balance.
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?
We believe that the Roundtable on Sustainable
Palm Oil is a positive and proactive initiative to encourage sustainable
farming practices and should be supported by further initiatives.
As stated earlier, we support such initiatives involving industry
and NGO partnerships working at appropriate national and international
levels, and believe that they can often be more cost-effective,
as well as being more rapidly implemented than attempts at international
regulation.
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?
a) The global biofuels market consists of
approximately 85% bioethanol and 15% biodiesel. Bioethanol is
produced and consumed mainly in Brazil and North America. On the
other hand, Europe is the world leader in biodiesel production
and this fuel represents about ¾ of the European biofuels
market. First generation bioethanol and biodiesel production is
a maturing industry, but efficiency improvements are still to
be made and deserve further support. Advanced generation biofuels
offer significant gains and benefits, and clearly require considerable
support and encouragement at a research and development level.
It is highly likely in the near and mid-term that advanced biofuel
methods, such as cellulosic ethanol production, will see first
economic implementation in conjunction with first generation processes.
Biotechnology will become an increasingly key component of both
current and future generations of biofuel production.
b) In order to achieve the ambitious goals
of biofuel use set by the European Union (5.75% in 2010 and 10%
in 2020) in a sustainable and competitive way, the available biomass
in Europe will need to increase. Cultivating energy crops on set-aside
and non-cultivated land will contribute, but this will not be
sufficient to fulfil all the demand. Complimentary sources of
biofuels from the EU and other world areas will be required to
meet these targets, and this will necessitate a more constructive
approach to both international trade conditions, and the harmonization
of approvals and adoption of new technologies, particularly in
the field of biotechnology.
c) It will also be critical to sustainably
increase land productivity (meaning more biomass output/ha), as
well as crop quality (for example through more fermentable carbohydrates
or higher oil content). Techniques within plant science (modern
plant breeding techniques and biotechnology); crop protection
technology and enhanced farming practices all have an important
role to play in this area.
d) Another important step to increase the
biofuel production will be the competitive production of biofuels
from (hemi) cellulose and agricultural waste instead of from starch,
sugar and oils. These are the so-called second generation biofuels.
Again innovation in plant science and industrial biotechnology—especially
in the area of enzymes capable of fermenting sugars from (hemi)
cellulose degradation—will be crucial to obtain this.
e) Biotechnology can provide effective and
innovative tools which should not be overlooked as we try to attain
European targets for biofuel use, while reducing adverse environmental
impacts of transport, and limiting the impact of the increased
cultivated land.
f) Plant science techniques can help to:
i) Increase biomass yield/ha while reducing
the needs for production inputs.
ii) Improve crop quality (higher biofuel
yields).
iv) Develop efficient micro-organisms and
enzymes to ferment sugars derived from (hemi) cellulose.
v) Convert agricultural waste into biofuels
and bioenergy.
g) The fiscal arrangements for biofuels
in other countries vary considerably, and to date fiscal support
in some EU member states and non EU countries have exceeded those
found in the UK. By implementing a transport fuel obligation,
the cost of biofuel promotion will move from the taxpayer to the
fuel user, and there is considerable evidence that this effect
has also spread to other sectors such as food. A reconsideration
of commodity control measures and measures to support increased
agricultural output is clearly required to allow production to
adjust to the new dynamics of supply and demand.
h) Whilst it is likely that solid biofuel
can deliver more in absolute energy terms, current technology
prevents such biomass from contributing to the liquid transport
fuel sector in the near and mid-term. Transport fuel is a large
and most rapidly increasing sector in terms of GHG emissions.
Crop-based liquid biofuels can deliver very worthwhile levels
of GHG emission reduction and warrant further support and development.
5) The EU Strategy for Biofuels claims that
biofuels "are a direct substitute for fossil fuels in transport
and can readily be integrated into fuel supply systems".
What proportion of UK domestic transport and energy generation
could be fuelled by UK-produced biofuels? Is it possible for biofuels
to entirely replace oil for transport purposes? Is there a role
for public procurement or public transport? Will biofuels improve
fuel security? How secure are biofuel crops from unexpected events
such as drought or disease?
a) The UK's agriculture sector has the ability
to produce a proportion of the UK's demand for biofuels. abc believes
that biotechnology provides tools to help the agriculture sector
in this area.
b) For the foreseeable future, the transport
sector can only operate with energy in liquid form (fuel) and
the only realistic alternatives to fossil based energy for the
transport sector are biofuels—such as bioethanol, biobutanol
or biodiesel—produced from renewable raw materials from
agricultural production or thermal processes. As stated above,
a key advantage of biofuels is indeed that they can be blended
readily with existing transport fuels, and that they are compatible
with existing vehicles.
c) Well-to-wheel assessments indicate that
the use of biofuels in vehicles can yield significant benefits
in terms of GHG emissions compared to petroleum-based automotive
fuels, although the precise amount of saved CO2 emission depends
on the specific type of raw material used, the production process
for the agricultural raw materials, the conversion process and
several other elements. Further life cycle analyses can help to
drive progress to realise an effective biofuel strategy for Europe.
d) abc believes that sufficient production
of fuel feedstocks for biofuels could replace around 1%-2% of
current fossil fuel use in the medium term without either a significant
increase in the productivity in current land use or a significant
reduction in food security. GM technology could contribute to
this production.
e) Feedstocks for industry from agricultural
crops are inevitably prone to fluctuations in climatic conditions
and external pressures such as pests and diseases. Some of these
pressures can be exacerbated by increasing cultivation area and
scale of production, but biotechnology can deliver crop improvements
to help address these challenges. In particular we would highlight
the active research but our member companies and other research
organisations around the world on drought tolerance, nitrogen
use efficiency and pest and disease control.
6) What impact would an expansion of UK production
of biofuels have on the ability of the UK to produce its own food?
How might this impact on greenhouse gas emissions from international
trade patterns? What impact might the expansion of biofuels have
on international food security and prices?
a) If significantly more land and resources
are diverted towards biofuel production, this could have an impact
on the UK's domestic food production in certain areas, such as
the relevant feedstock crops (mainly cereals, sugar beet and oilseeds
in the near term). However, within current targets and trade conditions,
we do not expect UK biofuel production, from either UK agriculture
or imported feedstock, to have a significant effect on the UK
food supply. In particular, the release of a proportion of set-aside
land for cultivation, and diversion of some produce currently
exported, will deliver most of the requirement for home-grown
feedstock to compliment anticipated imported feedstock and finished
biofuels.
b) Inevitably in a free-market, farmers
are more likely to grow crops that give them a favourable return
on their investment and will take into consideration external
factors eg effects of supply and demand on commodity prices. The
recent rise in wheat prices has been caused, in part, by the shift
from wheat and other crops to maize production in the US as a
result of expanding bioethanol production and the influence of
federal policy.
c) Various commentaries, including from
the UNEP, suggests there is considerable capacity worldwide to
produce more feedstocks for biofuels, without affecting food availability.
Clearly, it is important that land use policy and market intervention
measures must continually be adjusted to take account of the large
emerging market for biofuels, releasing land and facilitating
shifting of cropping patterns, as well as the adjustment of trade
patterns.
7) 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?
a) abc believes that the provision of biofuels
offers farmers a viable alternative income stream to complement
food production. Particularly in the case of current commodities
used as fuel, as in wheat for ethanol or oilseed rape for biodiesel,
the growth of an additional large sector should provide farmers
with a measure of stability, as alternative markets open up for
their produce. In the UK biofuel production could help revitalising
parts of UK agriculture and have a beneficial knock-on effect
on the rural economy. Recent high cereal and oilseed prices have
a knock-on effect in terms of feed prices for livestock farmers,
but this situation is likely to ameliorate as out-dated production
constraints are removed and markets adjust to meet the new supply
and demand dynamics.
b) To produce the economies of scale to
have a large impact on reductions of greenhouse gas emissions
there needs to be large scale investments in the industry, particularly
where this involves a large scale distribution network as in the
case of liquid transport fuels. As a result it tends to require
larger companies to be involved to make these investments.
c) There is also a significant opportunity
for farm scale production of certain forms of bio-energy to add
to the rural economy.
CONCLUSION
abc believes that biofuels offer a significant
opportunity to contribute to the mitigation of carbon and other
greenhouse gas emissions, and that given appropriate policy support,
farmers are in a good position to benefit from the opportunities
arising from the growing demand for biofuels grown in the UK,
and thereby to help increase the competitiveness and sustainability
of British agriculture.
In the longer term, GM technology has a contribution
to make in developing a productive and sustainable biofuels sector,
delivering higher and more consistent yields, and making more
efficient use of the land.
Plant biotechnology may also help by enabling
farmers to grow energy plants in areas with marginal agricultural
conditions, such as drought and saline zones or areas with very
heterogeneous production conditions (frost, heat, flooding etc.)
and research is ongoing at present.
abc is the umbrella group for the agricultural
biotechnology industry, comprising representation from Bayer CropScience,
BASF, Dow AgroSciences, DuPont, Monsanto and Syngenta. Our goal
is to provide factual information and education about the agricultural
use of GM technology in the UK, based on respect for public interest,
opinions and concerns.
1 October 2007
1 http://ies.jrc.ec.europa.eu/wtw.html Back
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