Inadequacy of the Renewable Energy Directive

There is sufficient potential to have clean and green renewable energy without damaging wildlife ecosystems. However, there are currently insufficient environmental safeguards in the Directive, especially the 10% target would create huge demand for biofuels and import would be inevitable. The sustainability criteria need to be far stronger in order to avoid the negative impacts and ensure significant greenhouse gas saving and thus climate benefits from biofuels production.

Both first and second generation biofuels need huge amount of land to grown the feedstock, this demand of land neither replace habitats directly, or through displacing food production from arable land to new land that threatening wildlife habitats and/or important carbon store.

This displacement effect, or indirect land-use change, is not covered at all in the Renewable Energy Directive proposal. Due to the interconnection of global commodities trade, an increase in crop demand in one country often lead to effects in other parts of the world, frequently in developing countries rich in biodiversity. It is essential to take into account such effects in formulating EU policy.

Since not all biofuels are the same - their efficiencies depends on the crop, type of cultivated land, and farming practices, it is important that only biofuels that offer substantial reductions in greenhouse gases are accepted towards any target. Currently the threshold in the Renewable Energy Directive is set at savings of 35% compared to fossil fuels, which is severely inadequate. The use of inefficient biofuels would mean sacrificing huge amount of land for little GHG gain.

We propose that in order to make a sufficient contribution only biofuels offering a minimum 60% GHG saving compared to fossil fuels, should be accepted and that this percentage is calculated using the latest scientific data which must be reviewed regularly and updated.

Even a high GHG saving percentage is set, according to the Renewable Energy Directive calculation, there is huge amount of uncertainty regarding GHG emission due to nitrous oxide emission and indirect land-use change. The European Commission’s Joint Research Centre admitted that emissions due to indirect land use change are ‘worrying’, with the critical indirect effect on tropical peatlands, these emissions can be significant as a result of the EU biofuel policy. However, there is yet no systematic estimate of indirect emissions, and not surprisingly, it is not included in the GHG saving calculation in the Directive.

Although the sustainability criteria of the Directive offer protection to closed forests and ‘highly biodiverse grassland’, it does not protect scrubland or open woody-savannahs. This would open the door for exploitation of natural and extensively used habitats such as much of the South-American Cerrado, African savannahs and European grasslands. Moreover, the definition of ‘highly biodiverse grassland’ in Article 15.3 (c) is ambiguous and thus threatens all fallow or other low-input agricultural lands. Such habitats are a key refuge for threatened wildlife, particularly for species with poor dispersal abilities as the destruction and fragmentation of their habitat would inhibit their ability to adapt to climate change (Crick, 2004).

In order to provide sufficient carbon saving by biofuels, lands with high carbon stock must not be converted feedstock cultivation. The Directive stated that raw materials for biofuels should not come from forest and wetlands. However, the Directive proposal fails to include degraded peatlands that also store significant carbon stocks across the globe.

Although peatlands cover only 3% of the Earth’s land surface, boreal and subarctic peatlands stored about 15-30% of the world’s soil carbon as peat (Limpens et al., 2008); with the additional 42000 Megatons of carbon stored in 27.1 million hectares of peatlands in South East Asia, peatlands around the world is a significant store of carbon. Sadly, degradation of peatlands by logging or fire is common in South East Asia, especially in Indonesia. However, unless the peatland is drained, which is usually needed for oil palm plantation, degraded peatlands still store an enormous amount of carbon. The emission caused by decomposition of drained peatlands amounts to 632 Mt per year (Hooijer et al., 2006). The protection of only ‘pristine peatland’ from biofuel crop cultivation in the Directive could possibly lead to drainage of all degraded peatlands, contradicting the goal of reducing GHG emission.

Isolating wildlife habitats

Although the draft Renewable Energy Directives states that raw materials for biofuel production cannot come from protected areas, it does not provide any protection to the land that surrounds them. This has particular impacts on large mammal populations living in drylands, since their survival depend on access to larger landscape that usually extend beyond formal protected area. One such example is African elephants.

In March 2007, 10 000 hectares of land adjacent to the Babille Elephant Sanctuary were granted to a European biodiesel producer, to produce biofuel from castor oil. The Sanctuary and its surroundings are one of the most important areas in Ethiopia for the protection of an estimated remaining population of 300 African Elephants that are a unique sub-species. This area also protects an estimated remaining 1 000 Black-mane Lions – an Ethiopian national symbol found on national bank notes.

BirdLife International has also identified this area as an Important Bird Area (IBA ET035). A preliminary survey in 1995 found 106 bird species, including 24 Somali-Masai biome species, such as the Gillett’s Lark Mirafra gilletti and the Scaly Chatterer Turdoides aylmeri.

Elephants need to migrate periodically through this region to find water; however, the forest and bushland area has recently been cleared and cultivated with several thousand hectares of castor oil plants for biofuels. This either isolates the protected area and cut off species’ migration route, or increase confrontation of wildlife with human. Such impact is destined to get worse as there are 1.15 million hectares of land under negotiation for biofuel crops cultivation in Ethiopia (GRAIN, 2007).

A. Pautasso / BirdLife Migratory animals, like these African elephants, need access to large landscape for their survival. Large-scale biofuel feedstock cultivation around protected areas would seriously affect them. Zoom In | Hi-Res

Loose safeguard

The proposed Directive gives public support (e.g. tax breaks) to existing highly inefficient biofuel plants, which do not achieve even the 35% saving compared to fossil fuels, for a further 5 years. They do not have to comply with the 35% emission saving until 1 April 2013; this is not acceptable in a public policy point of view and can contribute to net greenhouse gas emissions.

There is a method for calculating the greenhouse gas impact of biofuels and other bioliquids laid out in the Directive, however, it only allows Member States to report figures that show biofuels to be more efficient (i.e. that are lower than the default emission values). This appears to be artificially pushing Member States to make biofuels appear more attractive. The use of such default values will not prevent any current unsustainable biofuels from entering the market (MNP, 2008). 

Disregard social impacts

Large-scale biofuels production are also causing serious social impacts, mostly in developing countries, where the land from local and indigenous communities were taken away with their livelihood destroyed, and/or forced into indecent work. The Commission proposal does not include any safeguards against such social impacts, which is indeed urgently needed in order to prevent the exploitation of vulnerable people in the South to satisfy the transport demand from the West.

Off-site pollution and water impacts

Beside pollutions by runoff due to heavy use of pesticide, herbicide and fertilizers in large-scale cultivation, the irrigation need for biofuel crops would impact the surrounding wildlife, particularly on wetland ecosystems. The example of the sugarcane development project in the Tana River Delta in Kenya illustrate how far reaching of a feedstock plantation could have on local wildlife due to irrigation need. 

Though the draft Renewable Energy Directive excludes biofuels crops planted directly on wetlands, it ignores the possible impact of feedstock cultivation have on downstream wetland ecosystem.

Food security

Numerous international organisations have warned the impact of using food crop to produce biofuels (e.g. FAO, 2008b; OECD/FAO, 2008; World Bank, 2007; World Resource Institute, 2007), and biofuels production has been suggested as one of the factors that lead to recent high food prices. Regardless of these warnings, current biofuel policies around the world ignore the possible negative impacts of diverting food to fuels especially on low-income families in poor countries, who are usually net food buyers and use up to 80% of their income on food. Such high food prices would potentially push 100 million people into deeper poverty (World Bank news, 14 April 2008). The proposed Directive has not address this problem properly; on the other hand actively encourage the use of first-generation biofuels which inevitable divert food crop to fuel use, or compete directly with food production on resources like land and water.

Reference:

Crick, H.Q.P. (2004) The impact of climate change on birds. Ibis, 146 (Supp. 1): 48-58.

FAO (2008b) Bioenergy, food security and sustainability – towards an international framework. High-level conference on world food security: the challenges of climate change and bioenergy. Available at: http://www.fao.org/fileadmin/user_upload/foodclimate/HLCdocs/HLC08-inf-3-E.pdf

GRAIN (2007) The new scramble for Africa. Seedling. July 2007. Available at: http://www.grain.org/seedling/?id=481

Limpens, J., et al (2008) Peatlands and the carbon cycle: from local processes to global implications – a synthesis. Biogeosciences Discuss. 5: 1379-1419.Hooijer, A., Silvius, M., Wosten, H. and Page, S. (2006) Peat-CO2, assessment of CO2 emissions from drained peatlands in SE Asia. Delft Hydraulics report Q3943(2006). Available at: http://www.wetlands.org/publication.aspx?id=51a80e5f-4479-4200-9be0-66f1aa9f9ca9

Milieu en Natuur Planbureau (MNP) (2008) Local and global consequences of the EU renewable directive for biofuels – testing the sustainability criteria. Netherlands Environmental Assessment Agency (MNP). MNP Report 500143001/2008. Available at: http://www.mnp.nl/en/publications/2008/LocalandglobalconsequencesoftheEUrenewabledirectiveforbiofuels.html

OECD/FAO (2008) Agricultural outlook 2008-2017. Available at: http://www.agri-outlook.org/dataoecd/54/15/40715381.pdf

World Bank (2007) The World Bank – World development report 2008.

World Resources Institute (2007) Plants at the Pump. Biofuels, climate change, and sustainability. Available at: http://www.wri.org/publication/plants-at-the-pump#

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