Inadequacy of the Renewable Energy Directive
The Sustainability Criteria
Not all biofuels perform equally: their efficiencies depend on the crop, type of cultivated land, and farming practices, and thus have a different impact on the state of the environment - some are more likely to worsen the environment rather than making a meaningful contribution for improvement. Therefore only the best performing biofuels which can offer substantial reduction in GHG identified through a life-cycle analysis should be accepted and eligible for public support. 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 leading to impacts both inside and outside the EU.
Moreover, due to the interconnection of global commodities trade, an increase in crop demand in one country often can 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.
A set of sustainability criteria was included under the Renewable Energy Directive in order to make biofuels and bioliquids meet certain environmental safeguards. It identifies the GHG saving threshold as well as protected areas which should not be used for the production of biofuels, such as biodiversity rich lands and land with high carbon-stocks. However, 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. Furthermore an effective and transparent implementation and verification mechanism of compliance should be developed to ensure proper analysis of the adequacy of the Directive and its targets.
Insignificant, uncertain greenhouse gas savings and incomplete calculation methodCurrently the threshold in the Renewable Energy Directive is set at savings of 35% until 2017 compared to fossil fuels, which is severely inadequate. The use of inefficient biofuels would mean sacrificing huge amount of land for little GHG gain. From 2017 the threshold rises to 50% and from 2018 to 60% for biofuels produced in installations working from that year onwards. When calculating GHG impacts, Member States are allowed to use default values which have been set at such a level that most biofuels automatically comply with the thresholds without taking into account all the real impacts.
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 a reliable method including all direct and indirect emissions based on 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.
Even though assessing the impacts of indirect land use change is complex, this has already been done by the US Environment Protection Agency (EPA) and the California Air Resources Board (CARB). An ILUC factor should be developed and included in the GHG calculation methodology. As displacement of feedstock is the major cause for ILUC, biofuels should be classified according to their impact on land use change.
During the evaluation of impacts, Birdlife proposes that the next principles should be taken into account:
- Modelling of global impacts which can occur as a result of additional demand from biofuel production.
Development of an indirect land use change correction factor.
- Addition of this correction factor to the direct GHG calculation method.
- Identification of feedstock with a correction factor of zero and which therefore do not produce land use change independently of their name (as second-generation biofuels can also cause displacement).
- Classification of the different biofuels in accordance to their risk and impact on indirect land use change assigning them a correction factor in accordance.
- Establishment of robust sustainable land use planning at a local, national and global level, which would introduce a mandatory global accounting system.
- Adjustment of the EU target if the safeguards measures fail to prevent from substantial indirect impacts.
The Renewable Energy Directive requires the European Commission to come up with proposals to address this problem. You can find BirdLife's response to the Commission pre-consultation here.
Ignored important wildlife habitats
Although the sustainability criteria of the Directive offer protection to closed forests and ‘highly biodiverse grassland’, it excludes other high biodiversity areas as it does not offer protection to scrubland or open woody-savannahs, as they do not fall under the scope of the primary forest definition or highly bio diverse 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.
But even the areas included under the definition may be subject to biofuels production and count towards the 10% target, as the Directive gives the Commission the right to allow production on areas with high numbers of endangered species or ecosystems. The Commission will also determine which biodiversity-rich grasslands fall under the scope of protection, which could lead to insufficient protection. 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).
Insufficient protection of high-carbon storage habitats
In order to provide sufficient carbon saving by biofuels, lands with high carbon stock must not be converted into feedstock cultivation. The Directive states that biofuels should not be made from raw material obtained from high carbon stock lands such as wetlands or forested areas. It also prohibits the production on peatlands unless it is proved that such production did not involve drainage of previously undrained soil.
This definition excludes many other high carbon areas, potentially allowing up to 95% of peatlands and 50% of forests to be converted into the production of biofuels. Furthermore, the definition of undrained peatland is still to be defined by the Commission.
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 are 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), being the result emissions in South East Asia 10 times higher than on the boreal zone. 95% of the peatlands in South East Asia have already been drained to some extent, which can make the owners claim that their crops are grown in pre-drained lands and therefore comply with the regulation.
The protection of only ‘undrained peatland’ from biofuel crop cultivation in the Directive could possibly lead to further drainage of all degraded peatlands, contradicting the goal of reducing GHG emission as it is not clear whether emissions from drainage will be included in the life-cycle analysis.
Also ‘intermediate ecosystems’ between forest and grassland that are important for carbon storage are omitted, for example scrubland areas including the Brazilian Cerrado and African savannah, as well as permanent grassland.
Forests in danger
The Directive protects forested areas of more than one hectare with trees higher than five metres and a canopy cover of more than 30%. This can potentially allow up to 50% of global forested areas to be converted to biofuel production (IPCC). Moreover it does not take into account the recognised forest definition of the FAO for which forest is defined as: “land spanning more than 0.5 hectares, with trees higher than 5 metres and a canopy cover of more than 10%, or trees able to reach these thresholds in situ”. (FAO 2006)
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).
The Directive gives public support (e.g. tax breaks) to highly inefficient biofuel plants operating by 23 January 2008 as they do not have to comply with the 35% emission saving until 1 April 2013. This represents an unacceptable waste of public money and can contribute to net greenhouse gas emissions (given the many loopholes allowing producers to ignore emmissions when calculating those saving levels).
The method for calculating the greenhouse gas impact of biofuels and other bioliquids laid out in the Directive, furthermore, 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 have been taken away with their livelihood destroyed, and/or forced into indecent work, as a consequence of high foreign investment on stocks.
Foreign investments that do not consider labour, social and environmental standards are increasing rapidly at southern developing countries.
The Directive sets the requirement on the European Commission to report on the impact on social sustainability and if whether the producer countries have ratified and implemented relevant International Labour Organisation conventions. However this is inadequate to ensure social sustainability as the real situation is that even though these producer countries as Brazil have ratified and implemented ILO conventions, organizations such as Amnesty International continue reporting on violation on human rights.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 Renewable Energy Directive excludes biofuels crops planted directly on wetlands, it ignores the possible impact of feedstock cultivation have on downstream wetland ecosystem.
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 Directive does not address this problem properly; on the other hand it actively encourages 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.
Fuelling the ecological crisis - six examples of habitat destruction driven by biofuels
At this report BirdLife's presents six case studies of ecological damage that is being driven by commodity production boosted by the European Biofuel policy. If the current situation stays without an increase on the implementation of true and robust safeguards the EU policy will be responsible for many more such examples. While this report does not cover any social implications of biofuel production, these are highly significant and must also be addressed.
Click here to download the full version (PDF) of the BirdLife Biofuels Report 'Fuelling the ecological crisis - six examples of habitat destruction driven by biofuels'
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#