The EU Commission has this week proposed a new target for the percentage of transport fuel from renewable sources to be made up by food crop-based biofuels. Specifically, the proposal says: “The share of energy from biofuels produced from cereal and other starch rich crops, sugars and oil crops shall be no more than 5 per cent, the estimated share at the end of 2011, of the final consumption of energy in transport in 2020.” This five per cent is half of the 10 per cent of total EU transport fuel demand to be met from renewable sources by 2020, a target set in the 2009 Renewable Energy Directive.

The reason for the proposed restriction on the use of food crop-derived fuels appears to be the direct competition between food and fuel for certain crops, and also some scientific modelling of indirect land use change (ILUC) that has now found favour in the EU executive. ILUC modelling strives to account for the overall environmental impact – in terms of carbon emissions – of turning over existing carbon sinks or displacing land used for food production. (It doesn’t account for the social or economic impact). In an intended fillip for development of advanced, second generation fuels made from algae and some waste materials (among other things), the proposal also provides for quadruple counting of these within the 10% target. (These fuels are double counted at present).

Understandably the biofuels lobbies feel embattled, suggesting that the proposal will decimate their industry. The proposal falls particularly hard on the bioethanol producers and there is some internecine squabbling between bioethanol and biodiesel (the bioethanol lobby putting forward modelling that suggests that their product is responsible for less greenhouse gas (GGH) emitted than biodiesel, and claiming that the five per cent cap will just mean that biodiesel continues to dominate the biofuels market). Since the same companies also invest in developing other renewable sources such as second generation biofuels, they are talking tough about the impact of this proposal on the resources they will be able to invest in these areas.

Moving targets, in whatever direction, clearly destabilise industries that rely ultimately on agriculture and annual growing cycles as well as complex innovation systems, investment processes and adaptations that lock-in or crowd out alternative technologies. But target setting itself risks putting the cart before the horse. It is not biofuels themselves that are desirable, but their capacity to reduce undesirable environmental and social impacts. ILUC modelling addresses some aspects of this but with substantial margins of uncertainty. (Hence the ILUC emissions being a proposed as a reporting requirement rather than a regulatory standard in the proposal). There are other aspects that it simply ignores. In our 2011 report, Biofuels: ethical issues, we identified the dangers to natural ecologies and human rights (food, land, labour, etc.) that can result from target setting, including effects that reach beyond the EU’s borders. Biofuels policy, and the choice of policy instruments to achieve it, needs to start with the objectives of policy.

Our Biofuels reportsets out six ethical principles with which policy in this area should conform. These require ethical, social, environmental and economic standards to be met, but they also, importantly, define conditions that create a moral injunction to pursue the development of biofuels, where these standards are met. It is important to focus on how biofuels are produced, rather than assuming only an invariant correlation between the quantity of biofuels used and significant environmental consequences. An EU-wide system of certification designed to ensure that biofuels production (wherever it originates) meets standards of human rights, environmental sustainability, fairness to producers, and equitable distribution of costs and benefits (based, for example, on standards such as those proposed by the Roundtable on Sustainable Biofuels) should come first. Policy should concentrate on getting these standards in place, so that the targets for renewable fuel use can be raised, rather than lowering the targets because they are not being met.

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