Leaders of Sustainable Biofuels release statement on European Commission proposals

The Leaders of Sustainable Biofuels (LSB) have released a statement regarding their position on the European Commission's proposal to amend the Fuel Quality Directive (FQD) and Renewable Energy Directive (RED).

On 17 October 2012, the Commission published a proposal to limit global land conversion for biofuel production, and to improve the climate benefits of biofuels used in the EU.

The proposal is currently under discussion in the European Parliament. On June 25th the ITRE committee (associated committee) published its final report which will go into plenary voting. The voting in the lead committee ENVI is scheduled for July 11th.

The Leaders of Sustainable Biofuels:

• welcome the statement to support advanced biofuels and support a gradual phasing-in of advanced biofuels mandated targets to 2020 and an increasing trajectory beyond 2020 (1)

• support the ILUC principle however a more in depth study must firstly be carried out to evaluate the true indirect effects of biofuels

• foresee a threat in the extended list of feedstock eligible for advanced biofuels especially on the use of animal fats (2) and used cooking oil, palm oil residue/waste and any other food feedstock derived residue/waste from the oleochemical, biodiesel and vegetable oil refining (3)

• believe that feedstock eligible for advanced biofuels such as residue/waste derived from oleochemical, biodiesel and vegetable oil refining processing (3), where non-advanced / non-sustainable feedstock such as palm oil is used, is absurd and is counter-productive to the objectives of this legislation.

The adoption of the long list of feedstock eligible for advanced biofuels, especially in the ITRE opinion amendment 45 including a number of disputable raw materials, is a clear threat to the development of genuine advanced biofuels. Such feedstock clearly need to be excluded from the definition. A broadening of the definition to include such feedstock opens the door to unsustainable biofuels production from food and feed crops. This will not only have a negative impact on truly advanced biofuels but also poses a high risk for the public perception and image of biofuels: the objective of a long-term development of feedstock used for advanced biofuels not competing with food and feed products will be clearly jeopardized. The consequences of such a questionable broadening clause and the foreseeable misdeclaration of feedstock will be received very negatively by the general public and will bring industry, the product itself and last but not least political decision makers into discredit.

Thus, the Leaders of Sustainable Biofuels strongly believe that it is essential for an effective implementation of the proposal, that the feedstock eligible for advanced biofuels production are lignocellulosic derived (i.e. straw, bagasse, EFB, forestry residues, crude tall oil & tall oil pitch), or manufactured from the biomass fraction of municipal wastes, truly sustainable and that the potential for fraud has to be excluded.

About the Leaders of Sustainable Biofuels

The LSB is a group composed by the Chief Executive Officers of Leading European biofuel producers and European airlines. The initiative aims at supporting the development of second generation biofuels in Europe. The leaders of Clariant, British Airways, BTG, Chemrec, Chemtex, Dong Energy, Forest BtL Oy, St1 Biofuels Oy and UPM and are joining forces to ensure the market uptake of advanced sustainable biofuels by all transport sectors.
 

(1) ITRE OPINION 31 Article 2 – point 2 – point c
(2) ITRE OPINION 45 Annex II – point 3 (p)
(3) ITRE OPINION 45 Annex II – point 3 (s, t, u, w)