Public policy should be built on firm foundations. Objective analysis, verifiable facts and solid science are good starting points, but that was absent in biofuels policy-making, writes Dick Roche.
Dick Roche was a senior Irish Fianna Fáil politician, and Ireland’s former Minister of State for European Affairs.
The foundations on which Europe’s biofuel policy has been built are anything but firm: objective analysis, facts and solid science have been conspicuous by their absence.
On 20th July, the EU Commission launched the ‘European Strategy for low Emission Mobility’ focused on reducing transport emissions in the post 2020 period.
Given the implacable opposition to all conventional biofuels within the Commission’s bureaucracy it is no surprise that the policy aims to phase out the EU targets for conventional biofuels post 2020: a case of never mind the facts, analysis, experience or indeed the science – just listen to the mandarins!
Before EU Governments plunge into the next biofuels debate they need to take a long hard look at how appallingly those same bureaucrats have performed on the issue to date.
In the 2012 press conference to announce dramatic alterations to the Renewable Energy Directive (RED), Commissioner Hedegaard referred to some biofuels being worse than fossil fuels spoke about carbon sinks being destroyed to grow biofuel feedstock and flagged her concerns about global land conversion impacts – ILUC.
In an extraordinarily negative presentation the Commissioner failed to mention that all ethanol produced in Europe from European feedstock is superior to all fossil fuels, forgot to mention that sustainable EU produced biofuel feedstocks do not involve carbon sink destruction and omitted to mention that across Europe it is the norm to produce biofuels in a way that is sustainable with negligible ILUC implications.
While Commissioner Hedegaard has moved on, the Commission officials responsible for the disastrous policy promoted in 2012 remain at their posts and, like Hedegaard, dismiss inconvenient facts and science that do not suit their mind-set.
The level of bias against conventional biofuels that exists in the Commission is exemplified in a 2015 report by the Joint Research Centre (JRC) the EU Commission’s ‘science and knowledge service’ for the EU Parliament.
The report is littered with inaccuracies, questionable analysis and downright distortions, raising fundamental questions about those who have charted Commission ‘thinking’ on biofuels.
A disturbing propensity to cherry pick data that runs through the JRC’s work on biofuels and is a major feature of the report. A striking example is the atypical data set drawn from a single and troubled ethanol plant which the JRC used in its analysis. Available data from better performing plants was eschewed. The result is a skewed and biased analysis
A startling lack of objectivity is evident in the report’s treatment of job creation. Hypothetical arguments are used to diminish the job potential of biofuel production.
The report contains assumptions the level of on-farm jobs that do not stand examination. It concludes that “many of the farm related jobs would probably have existed if the alternative to biofuels is more EU crop exports’. No evidence to support the existence of untapped export markets is supplied.
The report suggests that job creation in biofuels should be ‘discounted’ by the number of job reductions in fossil fuels: a line missing when the benefits of electric cars are discussed.
Ignoring the fact that most Member States have abolished excise tax exemptions for biofuels the JRC argues that taxation arrangements supporting biofuels may lead to job losses in other sectors. The JRC fails to mention that ethanol is the most heavily taxed fuel in the EU or that the French Cour de Comptes found that far from losing tax take with biofuels State tax revenues increased.
Another odd feature is the fossil fuel comparator used by the JRC in making calculations. Instead of using the fossil emission figures adopted for implementing Regulation Article 7a the JRC used the older comparator of the RED skewing results in favour of fossil fuels.
By failing to use the best available science on fossil fuel GHG emissions the JRC grossly underestimates the GHG savings from biofuels in general, and ethanol in particular. A 2016 study by Ricardo Energy & Environment demonstrated that use of E20 in the EU would contribute to a GHG reduction of over 14% in the transport sector, even after ILUC considerations are taken into account.
The JRC analysis relating to agriculture is particularly offkey. There is a substantial question mark over the JRC’s use of self generated data. Out of date figures are used in calculating fertiliser impacts. The JRC also makes basic errors in considering feedstock moisture content, questionable asssumptions on cultivation emissions and used models that had not been independently reviewed.
The report is littered with loaded and misleading references to subsidies ignoring the fact that since 2011 subsidies on biofuel production have been systematically removed. Any pay-outs made since 2011 go to the oil companies and not to biofuel producers.
Another example of questionable behaviour by Commision officials is their determined efforts to ‘bury’ the 2015 ILUC Quantification Study of EU Biofuels.
This study was produced by three respected consultancies, IIASA, Ecofys and E4Tech appointed by the Commission. The Commission received their completed study in August 2015 – and locked it away for seven months until March 2016.
A request for access to the study under the EU Access Regulation was rejected on the ludicrous basis that allowing access could undermine international relations and would undermine the EU decision-making process.
Under pressure for access, officials announced that a public meeting would be held in November to discuss its results – the meeting was cancelled without explanation.
From December 2015 through March 2016 a string of Parliamentary Questions (PQ) about the study were lodged by MEPs. Like other interested parties the Parliament was kept waiting, PQs were left unanswered for months and when eventually reached received risible responses.
By March 2015 MEPs, annoyed at the delaying tactics, wrote to Commission President Juncker on the matter.
With a formal appeal to the EU Ombudsman from industry underway, the Commission finally capitulated and, on 16th March 2016, uploaded the study on the Commission’s website – without the usual fanfare.
Reading through the ILUC Quantification Study it becomes obvious why Commission officials wanted it supressed: its findings run directly counter to the direction of travel being taken by EU Commission officials for years.
The study concludes that increased demand for ethanol produced from sugar, starch crops and cellulosic biomass can be met with low impacts on land use change and low resultant land use change emissions. It rejects the view that ethanol produced from sugars or starch will impact food prices. It concludes that the risk of land use change impacts tend to zero where abandoned land is available and the potential for higher productivity exists – a point of particular interest to EU Member States in Central & Eastern Europe which have significant underutilised land available.
The study reaches an uncompromising conclusion on the use of palm oil suggesting that Europe could play its part by banning palm oil imports for biofuel and curtailing imports for areas such as cosmetics and confectionary: it does not have to close down its biofuel industry.
The manner in which the Commission’s officials have handled biofuels policy since the turn of the decade has been a case study in how not to formulate public policy.
Changes the Commission introduced in 2012 have been a ‘train wreck”. They have caused plant closures, job losses, denied farmers access to a valuable income stream, have denied rural communities, particularly in Central and Eastern EU Member States, the prosperity that a vibrant ethanol industry could bring, and have killed investor confidence. And now the Commission wants to go even further.
As Member State governments start to consider the latest policy offering from Commission officials whose contribution in recent years has caused much damage the old maxim springs to mind: “fool me once shame on you; fool me twice, shame on me.