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Liebe Regenwaldfreunde,
zahlreiche Gruppen in Europa bitten um Ihre Unterschrift unter den folgenden Briefentwurf.
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Mit freundlichen Grüßen und herzlichem Dank

Reinhard Behrend
Rettet den Regenwald e. V.
Friedhofsweg 28
22337 Hamburg
040 4103804
info@regenwald.de

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OPEN LETTER: WE CALL ON THE EU TO ABANDON TARGETS FOR BIOFUEL USE IN EUROPE

30 January 2007

Dear Minister,

We are extremely concerned by the plans as presented by the European Commission to adopt a mandatory target for biofuel use in transport1, and strongly object biofuel use in other energy sectors with subsidies and tax incentives. Implementing these measures means that the EU will risk breaching its international commitments to reduce greenhouse gas emissions, protect biodiversity and human rights because, as set out below - the proposed targets will among others promote crops with poor greenhouse gas balances, will trigger deforestation and loss of biodiversity and exacerbate local land use conflicts.

BIOFUEL TARGETS WITHOUT MUCH STRONGER COMMITMENTS TO REDUCE CONSUMPTION ARE COUNTERPRODUCTIVE

Any targets relating to energy, we believe must therefore first be directed towards reducing overall energy [and commodity] use, including in the transport sector, and improving energy efficiency. Instead of addressing Europe's excessive overall consumption, the Commission proposes a biofuels target as a percentage of as yet unlimited - and quickly growing for overall transport fuel consumption2. This approach must be rejected as counterproductive. The fact that the European Commission's 'Energy Package'3 proposes targets only for biofuels for transport but not other alternative energies is indication of a seriously flawed policy approach to addressing fuel emissions in the transport sector. This approach must be rejected as counterproductive.

TARGETS WILL NEGATIVELY IMPACT THE GLOBAL SOUTH

The EU is suggesting that much of the biofuel crop will have to be produced in the global South and exported to Europe4. Although presented as an opportunity for Southern countries' economies, evidence suggests that monoculture crops for biofuel such as oil palm, soya, sugar cane and corn lead to increased destruction of biodiversity and rural livelihoods, further erosion of food security, with serious impacts on water, soil, and regional climate patterns5. Several statements already made by civil society organisations from the South are expressing deep concern and call for a rejection of the EU biofuel plans6.

RISK OF INCREASED CLIMATE IMPACTS OF BIOFUELS

Biofuel is arguably the least desirable alternative energy form the EU could set a target for. Biofuels for transport are less (cost?) effective than wind, solar or solid biomass energy schemes.7 The production of biofuel crops uses scarce resources such as fresh water8 and productive land9 and in most crops used today, the greenhouse gas savings are marginal at best in comparison to fossil fuels. A thorough understanding of the emissions produced throughout the chain from land conversion to production, refining and use of biofuels is essential to ensure biofuel use will truly reduce greenhouse gas emissions. Not only is deforestation itself a major cause of CO2 emissions, but biodiesel from South East Asian palm oil (where most world palm oil currently originates), can be expected to cause between two and eight times as much CO2 emission from damage to peat as the CO2 emissions from the mineral diesel it replaces (by conservative estimates, and according to the most recent science). These emissions make it less likely for the EU to meet their commitment of keeping within 2 degrees C of global warming. Furthermore, research already suggests that the carbon balance of some biofuel crops may actually be negative when taking the complete process into account.10 Further study is thus needed before setting biofuel targets.

BIOFUELS WILL INCREASE PRESSURE ON WORLD FOOD SUPPLIES AND FURTHER ERODE FOOD SOVEREIGNTY

Price increases for some biofuel crops that are also staple foods will exacerbate not only deforestation, but also put food security at risk11. Since biofuel targets in the EU would promote the production of biomass in the global South, the EU could be responsible for reducing the area of land devoted to food production, so eroding local and international food security and sovereignty and causing shortages. Like EU targets, the US biofuel targets have been criticized for requiring the equivalent of more than the US' entire corn harvest12. The combined additional pressure from these two economies on crops widely used as essential food crops seriously threatens price increases of food in poorer countries. Already, US demand for biofuel from corn has increased the current world grain deficit, raising corn prices significantly13. In addition, The FAO in 2006 reported a historical low in world stocks-to-use ratio for grains and record levels of demand (surpassing global production) for oil crops due to biofuel production, and world cereal reserves have fallen to the lowest level in more than two decades.14

MORE HUMAN RIGHTS VIOLATIONS RELATED TO MONOCULTURE EXPANSION

Serious human rights abuses have been reported from sugar cane, palm oil and soy plantations in Brazil, Argentina, Paraguay, Colombia and South-East Asia. The incidents include slavery, very poor working conditions and low wages, violent land conflicts and health crises due to use of agrochemicals.15

NO CREDIBLE CERTIFICATION PROCESS AVAILABLE AT THIS POINT

Sustainability certification is being proposed as a way of addressing many of the problems outlined above. However, the European Commission energy package does not provide clarity on whether a certification scheme for biofuels will be introduced, and if so, whether it would be voluntary or mandatory. Previous certification initiatives suggest that certification processes by themselves cannot address most of the environmental and social 'problems', particularly in countries with poor human rights records or weak enforcement of environmental and labour legislation. The Round Table on Responsible Soy, a voluntary certification process led by environmental NGO's and industry, has run into great controversy with civil society organisations and small farmers' movements in Latin America and is widely perceived as acting against their interests. The Round Table on Sustainable Palm Oil has yet to agree on procedures for verifying adherence to its standards and some of the RSPO industry members continue to destroy large areas of rainforest and openly bid for concessions which contravene RSPO principles, such as Wilmar International's bid for Bugala Island, Uganda, or PT SMART's plans for palm oil expansion in Indonesia. At present, no credible certification process to come to strong and mandatory standards, with full involvement of affected groups in producer countries, is available. Setting targets for biofuels before fully addressing the problems it can cause has to be strongly rejected.

TARGETS WILL FUEL GM EXPANSION

The genetic engineering sector of the biotechnology industry is promoting biofuels to gain access to a new market. The GM varieties of several crops now used as biofuel crops (eg: corn/maize, soya, rape) have met strong resistance to their use as food, especially in Europe. The industry hopes that by promoting them as biofuels, these crops will gain acceptance. However, contamination problems would not be addressed. The introduction of GM crops in the South has also had a massive impact on farming methods, human rights and the environment16. An EU target will give support to the GM industry to expand further. The industry also plans to use GM to alter, break down or remove the lignin and cellulose of plants to facilitate and increase biofuel yields 17, with consequences that cannot be predicted.

INCENTIVES AND SUBSIDIES

If the EU applies incentives and subsidies to biofuels targets, these will increase the pressures that we foresee from the targets. They will also distort markets and undermine food production. They should not be applied while there is still so much argument about the real contribution biofuels can make to energy use and climate. Finally, incentives for biofuels contradict the pro-poor strategies of the Millenium Development Goals and disregard the 2010 Target agreed on at the World Summit for Sustainable Development in Johannesburg by adding a severe additional driver of biodiversity loss.

We therefore call on the Member States to reject the biofuel target for transport and halt all other incentives for biofuel production. Instead, focus should be on drastic reduction of energy use and support for genuinely sustainable renewables.