The warning was sent to Energy Commissioner Andris Piebalgs on 15 December, questioning the EU executive's quest for a methodology to account for greenhouse gas emissions that result from converting forests or farmland to energy crops.
The signatories range from Brazil and Argentina to Indonesia and Mozambique, which are all biofuel-producing nations. They have been keeping a close eye on EU developments as any European regulation could impact on their export products.
The Commission is preparing a report detailing how "indirect land-use change" (ILUC) is caused by biofuel production and whether it needs to be tackled. The deadline is the end of 2010, but the EU executive seems to be planning a release as early as next March.
"The lack of appropriate data at global level raises important concerns about the possibility of building a well-designed and comprehensive methodology in a very short time," the letter from the developing countries said.
Consequently, they argue that the issue should be addressed in an international framework, preferably the UN Framework Convention on Climate Change (UNFCCC).
In its "pre-consultation" last summer, the Commission outlined several measures that could be taken to address land-use changes either across an array of products or specifically in the case of biofuels (EurActiv 30/07/09).
For example, the minimum required greenhouse gas savings required already could be tightened. Alternatively, the existing sustainability criteria could be considered adequate to ensure an "acceptably high" greenhouse gas benefit.
But the developing countries slammed the EU's consultation document for being biased, because it describes such an option as equivalent to "doing nothing".
"In many of our regions, biofuels' greenhouse gas savings thresholds already effectively offset the indirect impacts of land use change," the coalition said. This is particularly the case when the generation of by-products like protein or energy are taken into account, it argued.
"There is a need for more solid scientific data on ILUC, so we do not think that a short-term modelling option could be feasible," they stressed.
The countries ask the Commission for access to the economic models that it is considering as a means of quantifying emissions resulting from indirect land-use changes. Moreover, third countries should be invited to comment on the ensuing data, they demanded.
A study last week argued that existing methodologies used to calculate the impact of land-use change on greenhouse gas emissions are inconsistent and vary a lot depending on the crop and zone of production (EurActiv 11/12/09).
