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EU sustainability rules for biofuels lock in.

IT maybe an impossible task: but the European Union (EU) is trying to assess the environmental impact of biofuels sufficiently accurately to draft regulations that promote green biofuels, rather than generate too many greenhouse gas emissions. The European Commission last month (December) announced that rules on laying down sustainability standards for the direct impact on greenhouse gas emissions from biofuel production were now in force. This considers matters such as how much energy is used to make a biofuel, where its feedstock is grown and what was grown on land before that biofuel crop was planted. These are a complex set of calculations, but they have been encapsulated in a formula and are now formally approved as EU guidelines. These will help governments decide what biofuels are sufficiently green to count towards their renewable energy targets, also set by the EU.

However, that is not the end of the story. Just before Christmas, the Commission announced that it accepted this formula needed to better cover the effect of indirect land use changes caused by biofuel production--such as what virgin land is brought into production for food, because an old food crop area has been converted into energy feedstock production. The Commission is now investigating this problem and will report by July whether it is sufficiently quantifiable to be used to amend its biofuel legislation.

EU energy Commissioner, Gunther Oettinger said: "The potential effects of indirect land use need to be properly weighed in our biofuels policy. It is in our interest to investigate this seriously and ensure to have a legislation that avoids negative side effects."

The report will consider these potential policy options:

* Take no action for the time being, while continuing to monitor the problem;

* Increase the minimum greenhouse gas savings (compared to fossil fuels) for biofuels required under EU renewable energy and fuel quality directives; and

* Introduce additional sustainability requirements for the production and use of certain biofuels. What the Commission is trying to do is decide which biofuels are sufficiently green to count towards compulsory targets for member states to ensure 20% of their energy consumption was from renewable sources (well a 20% average anyway--some member states have to do more than others) under the EU renewable energy directive. The transport sector in all these 27 countries will have to ensure 10% of its energy usage is green, under this law. The renewable energy directive, which mandates all of this came into force last month (December).

And when Euro-politicians were debating this legislation, they heeded siren calls from environmentalists saying that while biofuels came from plants breathing CO2 rather than fossils with CO2 to release, it was not good enough to say biofuels equal green.

Concerns about soy and palm oil plantations destroying rainforest were foremost among a whole host of concerns. And these were written into secondary legislation underpinning the renewable energy directive, at least as far as direct impacts of biofuel production and use is concerned.

Oettinger said earlier this year: "In the years to come, biofuels are the main alternative to petrol and diesel used in transport, which produces more than 20% of the greenhouse gas emissions in the European Union. We have to ensure that the biofuels used are also sustainable." Detailed calculation models allowing governments and energy companies to assess the direct impact on greenhouse gas emissions of manufacturing and using biofuels were developed as a result.

In doing so, the Commission has played a clever game. Aware of the proliferation in sustainability certification schemes for a wide range of biofuels, it has laid down rules for these voluntary standards systems. And by insisting that member states demonstrate that the biofuels placed into the 'green' column when declaring their compliance with the renewable energy directive have a "high greenhouse gas savings count", (of 35% or more compared to fossil fuels, 50% from 2017), it has made these systems legally important. By adding that governments must explain how this is calculated, it more or less sanctions that certification schemes be in place.

So what are these principles like? Oettinger says they are tough. He has boasted: "Our certification scheme is the most stringent in the world and will make sure that our biofuels meet the highest environmental standards. It will have positive effects also on other regions as it covers imported biofuels."

The details are available online--see uri=OJ:L:2010:151:0019:0041:EN:PDF These 'guidelines for the calculation of land carbon stocks' guide the measurement of how much carbon was bound up in the land and the plants that grew on it before it was turned into a biofuel feedstock field, and how much less carbon is present afterwards? Making this calculation is anything but simple of course. After all--we are not talking laboratory conditions here--we are measuring the world, with all it mindboggling shades of content and multifarious life. So, the rules (called an EU decision) try to impose some order on this chaos. They say that a biofuel sustainability calculation measuring carbon content of the pre-biofuel land must be based on an area that was kind of uniform before the feedstock growers came along. It should have similar "biophysical conditions in terms of climate and soil type; management history in terms of tillage; and input history in terms of carbon input to soil." In other words, calculations must compare land that have similar soils and had similar plants before (whether natural or farmed) with whatever came afterwards. Of course, there may be two, three or more comparisons to make, if that land is divided amongst different types of feedstocks, because each biofuel plant breaths and holds different levels of carbon.

Whatever, with land parcelled up in this way, the calculation can be made for the difference in locked carbon in pre-biofuel times and post. And this is undertaken by this formula: 'CS i = (SOC + C VEG) x A'--with 'C S' meaning carbon stock per unit area, including both soil and vegetation. 'SOC' is soil organic carbon (measured as mass of carbon per hectare according to another set of formula--detailed in the decision). 'C VEG' is above and below-ground vegetation carbon stock, alive or dead, (measured as mass of carbon per hectare--also though another special formula). And 'A' is how many hectares are we considering here.

There are a whole bunch of variables too affecting these calculations, a critical one being climate zone and soil type, for which the Commission has created a comparative table which highlight where the most carbon can be assumed to be: in boreal wetland soils and tropical wet volcanic soils, and the least--for instance dry spodic soils. There are also complex factors to be added in regarding tillage, whether it is full, partial or reduced and even taking account of nutrient inputs, such as manure. Calculations also have to assess the presence and emissions of methane (CH4) and di-nitrous oxide (N2O), which are both stronger greenhouse gases than CO2.

While releasing these calculation rules, the Commission also released two policy papers (called Communications) that clarified its position on a number of sensitive issues regarding green biofuel production. It explained in a communique that it was clear "which types of land can NOT be used to produce biofuels. These are: natural forests, protected areas, wetlands, peatlands. It explicitly rules out that forests can be converted into palm oil plantations." Meanwhile, Brussels is now encouraging industry, governments and non-governmental organisations to establish voluntary certification schemes for biofuels. It explained: "The Commission will assess whether these schemes are reliable and have fraud-resistant auditing. The certificates guarantee that all the biofuels sold under the label are sustainable and produced under the criteria set by the renewable energy directive. All schemes have to have independent auditors which inspect the whole production chain, from the farmer to the trader and the fuel supplier."

Of course, if a fuel retailer wants to sell uncertified palm oil-based biofuels from recent plantations in clear-cut Amazonian jungle, then it can. But under the renewable energy directive, only green biofuels can receive national public support such as tax relief and production subsidies.

And although there is no obligation under the legislation for green certified biofuels to be labelled as such, the Commission clearly anticipates that they will. "It would make sense from a promotional point of view, if filling stations could show that they have sustainable biofuels. This is even more the case when a scheme applies sustainability criteria going even further than those required by EU law," noted a Brussels report.

Maybe understandably, within the biofuel industry there are some significant doubts about the Commission's whole approach here. The European Bioethanol Fuel Association (eBIO) communications director Christophe Bourillon said there was widespread concern about the initiative on indirect land use charges. "Currently, there is no scientific consensus on ILUC [indirect land use change] and, therefore, there cannot be ILUC based regulation. For the time being, ILUC will remain a concept, a theory. In addition, the more studies come out, the lower they show ILUC numbers for biofuels. Some studies do show positive ILUC effect for EU grown biofuels when co-products are (rightly so) taken into account." He added: "If policy makers are serious about ILUC and the environment, other industries should be considered (food, etc)."

He added: "We have yet to see how the system being developed by the Commission will be implemented concretely but we are looking for the administration of that system to be as light as possible in order not to burden the industry with additional and heavy reporting obligations, and applicable to all."
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Author:Nuthall, Keith
Publication:International News
Date:Dec 1, 2010
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