The Commission is aiming for "the earliest possible entry into the market of second-generation biofuels". Energy Commissioner Andris Piebalgs added: "Second-generation biofuels can considerably widen the feedstock options and provide for a far larger potential of market share, with the potential for significant greenhouse gas emission savings."
A study by the German Energy Agency found that "second-generation biofuels, such as Fischer-Tropsch Biomass-to-Liquids (BtL) are technically feasible and one of the most promising options for future fuels". The study concluded that Germany has sufficient biomass available for large-scale BtL production to meet 20% of today's fuel requirements or up to 35% by 2030 - at production costs of less than €0.80 per litre. It adds that costs can be further lowered by taking advantage of "substantial synergies" obtained by integrating BtL production in existing refinery and chemical plants.
The European Biomass Association (AEBIOM) calls on the Commission to avoid discrimination between first- and second-generation biofuels, claiming that this would not only lead to "endless discussions" regarding the definition of these fuels but also to potential negative discrimination against processes that are efficient in terms of CO2 mitigation, such as the production of "very efficient biofuels" like biogas, from agricultural by-products (manure) and energy crops.
It further asks the Commission to send out a clear message that first-generation biofuels are still needed in the short term as second-generation ones are not yet commercially ready. "Arguments from oil companies and some NGOs that we need to wait for better technically and environmentally-performing biofuels should not be considered. In fact, the first generation biofuels will prepare the ground for 2nd generation biofuels that will finally find their place in the market when they will become competitive."
The European Petroleum Industry Association (EUROPIA) also rejects any distinction between first- and second-generation biofuels, stating that any support must be technology-neutral and create a level playing field, in order to stimulate the development of biofuels capable of both delivering the greatest GHG-emissions benefits and achieving greater penetrations into the fuel pool.
The European Biodiesel Board (EBB) stresses: "It is not because a technology employs a particular kind of raw material that it should be preferred to others", adding that second-generation biofuels – or "future biofuels technologies" as it terms them – require much higher investment costs and are based on more energy-demanding processes.
Furthermore, it questions the cost-effectiveness and GHG efficiency of transporting impressive volumes of very low-weight raw materials - such as straw - towards very large-scale economy processing plants. It stresses that while ligno-cellolusic resources such as straw are considered to be "0" value-purchase raw materials – thus cutting production cost estimates – "it is clear that, if the technology were to be employed on a large scale, straw would become an economic good with much higher prices."
It adds that present technologies, such as biodiesel, already offer "very important advantages in terms of reduced GHG emissions, security of supply and rural development" and that the focus should lie on finding alternative raw materials to improve their environmental impact and price competitiveness.
The European Bioethanol Fuel Association (eBIO) on the other hand endorses a definition of second-generation biofuels based on the type of raw materials that they are made with. It recommends setting a minimum EU production target for cellulose bioethanol, for instance 1 billion litres by 2012, and proposes altering current support measures for energy crops in order to make growing crops for second-generation biofuels more attractive. "A strong boost will be achieved if we enter the stage where bioethanol fuel production is dominated by second-generation biofuels".
The European Automobile Manufacturers Association (ACEA) said that EU harmonisation will be key in promoting the development and deployment of second-generation biofuels: "There should, as far as possible, be a consistent EU framework on taxation policy related to biofuels and vehicles that are specifically adapted to use such biofuels."
The association does not see any objection to promoting particular pathways, so long as incentives are "proportional to the real environmental benefits in terms of CO2 savings and the availability of the different pathways".
Dr Thomas Schlick, managing director of the German Automobile Industry Federation (VDA) added: "BtL is one of the most promising renewable energy technologies for fuels. Thanks to their large potential for CO2 savings and increased efficiency, BtL fuels can make a crucial contribution to improving the climatic balance of transport." Furthermore, he noted: "BtL fuels are completely compatible with today's engines as well as future engine generations."
Global conservation organisation WWF acknowledges that the use of forest material for energy will allow higher yields, greater C02 emission savings, and require fewer inputs than agricultural energy crops such as sugar beet, oil seed rape or wheat. "However, they are not in themselves the answer. As with other agricultural crops, to reap their greatest environmental benefit, best practice in their production must be ensured. Non-use of best practices, such as intensive input use and complete harvesting of the resource could, for example, require a greater energy input than that generated from the processing of the resource", it warned.
Environmental NGO Friends of the Earth stressed the need for a debate on what is acceptable as a second-generation biofuel, stressing in particular that it does not support the use of genetically modified crops or trees as a source of biofuel. "The development of second-generation fuels should only be supported if they are acceptable to the public and the risks to the environment and to society are preventable or minimal. Second generation should not only be measured on climate performance but should also fulfill sustainability criteria. A complete life cycle analysis should supplement their development to ascertain the risks involved. They must also prevent irrational land use patterns and the skewing of food and commodity prices. The use of GM crops should not be permitted in the production of biomass."
BirdLife International, the European Environmental Bureau (EEB) and the European Federation for Transport and Environment (T&E) said: "We do not believe that any particular biofuel technology should be favoured over another, and that, instead, support should be organised for the delivery of GHG emissions savings."
According to them, the measures proposed under the draft review of the Fuel Quality Directive, aimed at cutting lifecycle greenhouse-gas emissions by 1% annually, combined with a "robust" sustainability certification system for biofuels, can serve this purpose better than specific support for second-generation fuels. Indeed, they stress, the latter option could lead to "perverse outcomes", such as encouraging production pathways that are considered second-generation but fail to deliver significant GHG emissions, or leaving out other biofuels that have the potential to bring about major GHG emission reductions, such as biogas from animal manure and sludge.
Green NGO Biofuelwatch laments the lack of discussion regarding the sustainability of second-generation biofuels. "The serious risks which GM crops and technologies pose to biodiversity appear have been ignored, even though second-generation technologies will depend on widespread use of GM crops and trees, as well as GM microbes and fungi, which pose serious risks to ecosystems and are likely to cross into food production via cross-pollination."
It recalls that cellulosic ethanol still produces far less energy than is needed to produce it and says that major breakthroughs in genetic engineering will have to occur for the technology to become affordable. "Nobody can predict whether those breakthroughs will happen in the next few years or decades."