European Commission Raises Queries over the Reliability of Biofuel Policy

UFOP supports the German Federal Government’s position relating to grandfather rights

Berlin, 12 September 2012 – The Union for the Promotion of Oil and Protein Plants e.V. (UFOP) considers the proposals announced by the EC’s General Directorate (GD) for Climate Policy to be a complete renunciation of a reliable, future-oriented climate and biofuel policy.

It is unfortunate that despite all of the evidence available, the GD for Climate Policy is determined to introduce charges for greenhouse gas emissions from biofuels. This should take into consideration the hypothesis that, for example, rapeseed cultivation for the production of biodiesel has taken over areas allocated to other purposes in the EU, such those cleared for the cultivation of palm oil plantations. UFOP points out critically that a cause-and effect relationship for these indirect land-use changes (iLUC) cannot so far be scientifically proven. Rapeseed cultivation in the EU would be particularly affected by the introduction of these so-called “iLUC factor” charges.

The main victims would be German and European rapeseed producers, the pioneers of its development, who began cultivation on fallow land at the beginning of the 1990s. They are no longer able to market their rapeseed through oil mills for biofuel production. The GD for Climate Policy has ignored the fact that effective forest protection can only be achieved by means of bilateral negotiations with the affected third-party countries. Furthermore, by means of its proposals, it raises questions regarding existing international initiatives to introduce certification systems and sustainability certificates for biomass and biofuel sources. Why should countries such as Brazil, Argentina, Malaysia or Indonesia continue to show any interest, questions UFOP.

With its proposals, the European Commission has raised queries over European climate and environmental protection objectives. Further investment in European biofuel production will remain elusive. These proposals will drive an entire industry into financial ruin. Land clearance in third-party countries will however continue, as there are purchasers around the world other than the EU. The EC overlooks the fact that countries which are a particular focus of the “iLUC policy” will find a new orientation on the international market.

The EU Commission is wrong if they believe that they can turn back the clock on biofuel policy without any environmental crop damage. Making such a fundamental change a mere three years after adopting the Renewable Energy Directive is no indication of reliability. With its proposal, the EU Commission thus refutes its own objective of investment security for existing facilities.

The UFOP therefore strongly supports the approach brought into the discussion by the Federal Government with the EU Commission and the Member States for the application of grandfather rights for German and European biofuel production on the basis of consumption amounts for 2010. This approach imposes no time limitations, and thus at least provides a platform for securing the livelihood of the most competitive biofuel manufacturers.

UFOP calls on the EU Commission to review the proposals of the GD for Climate Policy and finally to assess the question of the “iLUC hypothesis” on a scientific basis. The study by the IFPRI Institute used as the basis for the proposal for the introduction of “iLUC” factors has not so far been subject to any scientific review. Furthermore, the fact that the processing of rapeseed oil at a mass fraction of 60% as well as a high-protein animal feed has not been sufficiently taken into account in the greenhouse gas analysis. In Germany alone, a halt to further rapeseed growth for biodiesel production will require the importation of an additional approx. 3 million tonnes of soybean meal – a change in land use corresponding to approx. 1.4 million hectares of additional cultivation in South America.