Det Energipolitiske Udvalg 2009-10
S 2647
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INDIRECT LAND USE CHANGE IMPACTS OF BIOFUELS-CONSULTATIONIntroductionThe Renewable Energy Directive and Fuel Quality Directive require the Commission, by theend of 2010, to submit a report to the European Parliament and to the Council- reviewing the impact of indirect land use change on greenhouse gas emissions of biofuels1and- addressing ways to minimise that impact.The report shall, if appropriate, be accompanied by a proposal based on the best availablescientific evidence, which could also contain a concrete methodology for emissions fromcarbon stock changes caused by indirect land-use changes.In the summer of 2009 the Commission sought views on possible elements of a policyapproach to address such impacts in a "pre-consultation", without taking a view on whethersuch action would in fact be needed. All the contributions received were made public and canbe found athttp://ec.europa.eu/energy/renewables/consultations/2009_07_31_iluc_pre_consultation_en.htm
The Commission has also launched a number of analytical exercises in order to betterunderstand the magnitude of these impacts:Global trade and environmental impact study of the EU biofuels mandateImpacts of the EU biofuel target on agricultural markets and land use: a comparativemodelling assessmentThe impact of land use change on greenhouse gas emissions from biofuels and bioliquids– literature reviewIndirect land use change from increased biofuels demand – comparison of models andresults for marginal biofuels production from different feedstocks
The final versions of these reports can be found athttp://ec.europa.eu/energy/renewables/studies/land_use_change_en.htm
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The requirement in the Renewable Energy Directive also applies to bioliquids. References to 'biofuels' in thisconsultation document should be taken as also applying to bioliquids.
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Next stepsIn order to ensure that the contents of the report and any accompanying recommendations orproposals reflect the latest thinking and available evidence on this subject, the Commission isnow seeking the views of stakeholders and other interested parties on a number of questions,listed below:1) Do you consider that the analytical work referred to above, and/or other analyticalwork in this field, provides a good basis for determining how significant indirect landuse change resulting from the production of biofuels is?In answering this question you may for example wish to comment on:-------projected volumes of conventional and advanced biofuels in 2020assumptions around EU vehicle fleet and infrastructure in 2020, includingdiesel/petrol split and pace of introduction of new technologiesmodels' treatment of crop yield growth "in the baseline" and in response to growth indemand;the underlying land use datathe carbon stock values used in modelling and type of converted landmodels' treatment of co-productssignificance of the results in terms of hectares of land use change and emissions
2) On the basis of the available evidence, do you think that EU action is needed toaddress indirect land use change?3) If action is to be taken, and if it is to have the effect of encouraging greater use ofsome categories of biofuel and/or less use of other categories of biofuel than wouldotherwise be the case, it would be necessary to identify these categories of biofuel on thebasis of the analytical work. As such, do you think it is possible to draw sufficientlyreliable conclusions on whether indirect land use change impacts of biofuels varyaccording to:feedstock type?geographical location?land management?
If so, please say which, and indicate the evidence used to reach your conclusion.4) Based on your responses to the above questions, what course of action do you thinkappropriate?A. Take no action for the time being, while monitoring impacts including trends incertain key parameters and, if appropriate, proposing corrective action at a later datePlease say how the monitoring should be done and what these parameters should be.
B. Take action by encouraging greater use of some categories of biofuelPlease say which biofuels, why and what sort of encouragement should be given.C. Take action by discouraging the use of some categories of biofuelPlease say which biofuels and why, as well as what sort of measure should be taken, forexample:--increasing the minimum greenhouse gas saving threshold for biofuelsimposing additional sustainability requirements on certain categories of biofuel(these could, for example, require the use of practices that can help mitigateindirect land use change impacts)attributing a quantity of greenhouse gas emissions from indirect land use change toall biofuels that use land2
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If the latter, please say how this should be calculated, and demonstrated – for example:---a factor based on the estimated (modelled) land use change from amarginalextraquantity of crop production;a factor based on theaverageland use change from crops over some recent period;a factor based on any other consideration.
Please also say--whether it should be reviewed and if so how oftenwhether it should be implemented with any accompanying measures
D. Take some other form of actionPlease say what action and why***
In commenting, respondents are invited to justify their responses to all questions by referenceto available science.This paper is without prejudice to the Commission's final position.You are invited to submit comments to the mailboxec-land-use-change-[email protected]by 31stOctober 2010. If respondents wish to submit confidentialresponses, they should indicate clearly which part of their submission is confidential andshould not be published on the Commission's website. All other submissions, not clearlymarked as confidential, will be placed on the website by the Commission.
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It should be pointed out that in fact, what is calculated by the modelling work on this topic is the quantity ofadditional "land use change", not "indirect land use change", in a scenario with biofuels.