Memorandum submitted by Greenpeace UK
Greenpeace recognizes that biofuels could potentially
play a small part in tackling greenhouse gas emissions from the
transport sector. This is because the farming of agricultural
crops for biofuels only releases the carbon dioxide that those
plants absorbed during their lifecycle not massive quantities
of compressed, fossilised carbon that has been locked out of the
carbon cycle for millions of years.
That said, the hype around biofuels has grossly
exaggerated their role in mitigating climate change. Biofuels
are no "magic bullet" that are going to dramatically
reduce the emissions of the global transport sector and may in
fact substantially increase carbon emissions through the burning
of vast tracts of rainforest to make space to grow such fuels.
Even if successful, evidence suggests that biofuels are an expensive
way of achieving emissions reductions. These issues are explored
further below:
1. Land availability: There simply
isn't the land available to grow the quantities of crops necessary
to achieve this since most land is already in use for the essential
purposes of food production. It has been estimated that if the
world's largest maize producer, USA, were to divert its entire
production towards ethanol production it would only deliver 18%
of the nation's fuel use. We are already witnessing a "competition
for food between cars and people" and crop prices are rising
as a result. Recent shortages in major food-stuffs such as wheat
and maize have multi-factoral origins, but the expected increase
in demand for biofuel proposed by EU and potentially in China
and US will strain capacity of land to deliver. As food becomes
more and more expensive, it is the poor who will suffer most.
In addition, increases in biofuels volumes will either come from
efficiency increases or bring new land into production but both
of these will have significant environmental and social risks
associated with them.
2. Carbon savings: If land is to be
used for energy production, it is estimated that greater carbon
savings will be made from using the land to grow biomass for Combined
Heat and Power (CHP) or district heating rather than biofuels.
3. Diverting political agenda: The
focus on biofuels as the new "green" solution has taken
political attention away from more effective and lower risk ways
of dealing with transport like mandatory emission limits on car
manufacturers, extending road fuel charging and enforcement of
speed limits. Yet the current policy mechanism for biofuels in
UK, the RTFO, seems to be the flagship policy for carbon emissions
reduction in the transport sector.
4. Rainforest destruction: Emissions
from deforestation are hugely significant with up to a fifth of
all man made greenhouse gas emissions coming from deforestation,
particularly in tropical forests such as the Amazon and Indonesia.
The rapid expansion of agricultural commodities like soya and
palm oil for biofuels is a key driver in such destruction. For
example, in January 2007 a $12 billion investment was announced
for biofuels in Indonesia, where there are already 6 million hectares
of oil palm plantations. This is expected to expand to 20 million
hectares with 9 million of those being in Papua. Huge quantities
of greenhouse gases are being released, including through the
draining of peatlands and the setting of fires for forest clearance
to make way for such plantations. This is having a devastating
impact on both forest dependent communities and the incredible
biodiversity in the region.
Most of the exported palm oil in the world,
and the growth in recent years, has come from Malaysia and Indonesia.
It is widely expected that increases in demand for palm oil arising
from the creation of biofuel markets will drive further production
increases from here either directly or indirectly. The specific
concern is not only that some biofuels will be grown on land that
has been deforested (or taken from other high value conservation
land) but also that biofuels production displaces the crop previously
grown there. Ultimately this will drive an increase in demand
for yield from the agricultural sector and an expansion of the
demand for land (see point 1 above). Already rainforest in SE
Asia and the Amazon is being lost through conversion for agriculture.
Increases in demand will intensify the forces that cause this,
and its is therefore highly likely that demand for biofuels will
drive deforestation. It is argued that there are tracts of "idle"
land which are available for biofuel production. But this land
has not been brought into production previously whilst incursions
into forest areas have taken place. Given that the drivers and
market mechanisms which drive agricultural production are essentially
unaltered by biofuel demand, on what basis would one expect that
this idle land suddenly becomes the preferred area of development
when it has not been previously? Yet while the EU Parliament's
industry committee recently called for EU wide ban on use of biofuels
derived from palm oil the first commercial bio diesel containing
palm oil will go on sale in Sweden before the end of 2007.
Given the above Greenpeace has significant concerns
about the sustainability of biofuels. If they are to be used at
all then mandatory standards must be introduced which ensure safeguarding
of environmental and social well-being. Without these it is likely
that biofuels will increase greenhouse gas emissions and result
in environmentally and socially destructive practices. Similar
concerns have also been raised by Co-op Insurance, the UN and
the OECD as well as numerous academics, environmental and developmental
NGOs. These concerns are also extending into the commercial sector,
for example National Express recently suspended its trials of
biodiesel on this basis.
HOW CAN
WE BEST
REGULATE BIOFUELS?
The EU has seized onto biofuels as the new "green"
solution and as such has set targets for all member states for
biofuels supply—5.75% of fuel by 2010. This is filtering
down to the national level where it is on the way to being enshrined
in legislation including in the UK through the Renewable Transport
Fuel Obligation (RTFO), with similar initiatives being taken Netherlands
and Germany. Greenpeace is extremely concerned that the EU 5.75%
target can not be met sustainably. We are equally concerned that
further extending this target to 10% is premature.
The tradable certificate scheme advanced by
UK (RTFO) drives low-cost compliance with the percentage target
required. Experience from the Renewables Obligation indicates
that it will maximize the lowest cost compliance (in the case
of the Renewable Obligation, onshore wind) but not deliver much
variety. We see no reason for the RTFO to operate differently.
And so biofuels will generally be sourced from where crops grow
well and where land and labour costs are cheap. This will tend
to be tropical developing countries.
Consequently, we believe that if the production
of these fuels are not properly monitored and controlled, it will
spell disaster for rainforests, food and water supplies and climate
change. To ensure high production standards, Greenpeace currently
believe that certification is one response to the challenges of
sustainable biofuel production. However, this would have to be
alongside other measures that were capable of monitoring and responding
to the wider changes in markets that large-scale production of
biofuels would bring.
Whether the implementation of such additional
measures could actually deliver sustainability is not clear at
present. However the allocation of targets for biofuels supply,
given the uncertainties, remains premature. Policy interventions
to ensure that genuinely "idle" land is brought into
production remain undeveloped and without them there have to be
very severe doubts about the sustainability of biofuel production
on the scale envisaged. For specific commodities like palm oil
and soya that are used for other purposes beyond biofuels, certification
may need to cover the entire commodity rather than just the biofuels
part.
Further, even setting these macro demand issues
aside, certification schemes are not a panacea. The development
of certification systems for timber has only met with mixed success.
Whilst the Forest Stewardship Council (FSC) system is acknowledged
as a good way for ensuring that timber products come from environmentally
and socially responsible sources, other schemes like the Canadian
Standards Association (CSA), the Sustainable Forestry Initiative
(SFI), the Programme for Endorsement of Forest Certification Schemes
(PEFC) and the Malaysian Timber Certification Council Scheme (MTCC)
fail to recognise the rights of indigenous people and protect
forests of critical importance as well as having weak chain of
custody tracing and no third party auditing.
With respect to the standards methodologies
being developed by Low Carbon Vehicles Partnership and DfT, we
recognise that they are world-leading in terms of their depth
and sophistication, and that further development to reward greenhouse
gas savings is underway. However we believe their implementation
should still include the following:
Greenhouse gas certification:
— compulsory standards rather than
reporting, with full implementation from the commencement of the
scheme
— "cut off point" for greenhouse
gases saved where failure to meet savings threshold means fuel
is not eligible for RTFO certificates.
— independent external auditing of
company process and validity of information
Sustainability certification:
— Standards scoped to include impact
on biodiversity, indigenous and forest dependant peoples and worker
conditions
— Independent and external auditing
— Basic compulsory standards at start
of scheme to be tightened over the following 2 years
We do not believe that international trade is
a barrier to certification and we believe that if the RTFO standards
are strongly challenged by other countries under WTO rules then
this would strongly demonstrate the need for the WTO to be reformed—it
would not be fit for purpose in tackling the global threat to
climate change.
Beyond certification, other issues should also
be explored, monitored and responded to by the Government. These
include establishing:
— Mechanism in place to assess indirect
impact of biofuels on land use change ie whether certified biofuel
feedstock production is displacing other (uncertified) agriculture
into pristine areas, to include watch on global commodity flows
— Similar for food market impacts especially
with respect to any changes leading to food insecurity for vulnerable
populations
— Legislative tool to rein back biofuel
targets in the event of negative impacts being detected and attributed,
on a "balance of evidence" standard of proof.
— Process to establish similar at EU
level (indeed this process would be better done at a regional
level)
As outlined above, these final set of mechanisms
will be extremely challenging to develop and implement, but would
be necessary to assure biofuel sustainability.
THE ROUNDTABLE
ON SUSTAINABLE
PALM OIL
As discussed above, one of the sources of vegetable
oil for biodiesel production is palm oil from Malaysia and Indonesia,
places where deforestation continues. One of the main "assurances"
about the sustainability of palm oil is the creation of the industry/producer/NGO
body called the Roundtable on Sustainable Palm Oil or RSPO. Greenpeace
has significant reservations about the effectiveness of the RSPO
in guaranteeing sustainability.
Greenpeace does not believe the RSPO is currently
a credible scheme to ensure environmentally responsible and socially
just production of palm oil. At this point in time there are fundamental
flaws in the RSPO scheme: it will not stop the conversion of forests
and peatlands, its has weak membership requirements, and no chain
of custody system that prevents mixing certified palm oil with
palm oil coming from uncertified plantations. While it is likely
that some plantations not engaging in environmentally destructive
or socially unjust practices will be certified, the RSPO will
not be able to provide assurances to markets that what they are
buying is not coming from deforestation.
Although the RSPO criteria contain some strong
elements they are worthless if they do not stop the certification
of bad practice and allow companies engaged in destructive practices
to greenwash their operations through membership.
SECOND GENERATION
BIOFUELS
These, more specifically ligno-cellulosic technologies,
are advocated by some as being a response to the use of food crops
for biofuels. Sophisticated processing allows the use of woody
material such as grasses or woody material to be turned into ethanol.
These may be able to mitigate some of the concerns around competition
between food and fuel, but not all.
1. Direct competition between food and fuel
will be avoided by ligno-cellulosic technologies, but they do
not conjure up new land. Competition for land between food and
fuel would continue with high biofuels targets
2. It is true that lingo-cellulosic technologies
give the capability of countries from temperate latitudes like
UK sourcing more material for biofuels. But under a tradable certificate
obligation mechanism like the RTFO, it could still mean that large
quantities of biomass were sourced abroad. Remember that a significant
proportion of biomass for pulp and paper used globally have been
sourced from ancient forest areas in places like Finland, Russia
and Canada—the economics of the use of biomass do not necessarily
mean domestic sourcing for second generation biofuels.
3. It is expected that it will be a number
of years before these fuels are "commercially viable".
However a definition of "commercially viable" given
that biofuels are already a politically created market is not
clear. It is very likely that further incentives would need to
be provided to promote widespread uptake.
4. Better carbon dioxide reductions can
be obtained from biomass by its use for heating/CHP rather than
for transformation into liquid biofuel.
1 October 2007
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