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On 21 January 2008 the UK Government's Environmental Audit Committee (EAC) published its report …

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A European opportunity
- Are biofuels sustainable? The EU perspective

Of all of the problems flagged by the EAC, the impact of biofuel growth on land use is by far the most significant for GHG emissions. In 2000, agriculture and land use change together represented 32% of global GHG emissions, compared with just 14% for transport [9]. Land use GHG emissions are mostly down to deforestation for agriculture, and half are generated by land use changes in just two countries: Brazil and Indonesia [10]. In both cases agricultural expansion is being driven by the booming demand for biofuel feedstocks: sugar cane in Brazil and palm oil in Indonesia. Brazilian bioethanol is often regarded as the gold standard in renewable fuels, because its production and distribution saves around 10 times the fossil fuel inputs required, compared with less than twice the saving for corn ethanol in the US. Yet if this biofuel production causes deforestation, whether directly or indirectly through the displacement of other agricultural land use, the one-off GHG release during deforestation could take over 20 years to offset by growing sugar cane feedstock for bioethanol on the same land. Payback for land deforested for palm oil takes even longer, by some estimates this could be 400 years or more [11,12].

Biofuel produced from deforested land is clearly not sustainable, and therefore as both the EAC and Royal Society recognise, each biofuel must be assessed on its own merits including the impact of land use change. The question is, until differentiation based on this assessment is possible, should we promote the development and use of all biofuels, a select few or, as the EAC recommends, none at all?

Under current UK policy the Renewable Transport Fuel Obligation (RTFO) will be supported by a proposed carbon reporting and sustainability certification scheme, and incentives will be based on the carbon performance of the biofuel used, taking the feedstock source, processing and distribution into account [13]. The EAC states in no uncertain terms that this is not good enough, and that UK and EU targets for biofuel use should be suspended until adequate sustainability standards are in place.

This hard-line conclusion draws heavily on views expressed in environmental pressure group inputs to the inquiry. These include witness evidence from the WWF, Friends of the Earth and the Royal Society for the Protection of Birds (which counts several of the inquiry's committee amongst its members) and whose justifiable concern at the global habitat loss caused by deforestation and other land use changes found an outlet in this inquiry.

The effect of increased biofuel production from feedstocks grown within Europe cannot be likened to the devastating impact of palm-oil plantations that now roll across former Indonesian rainforests. Since the EU's Biofuels Directive was adopted in May 2003, EU biofuel production has more than doubled every two years [14]. Yet Europe's forests are not shrinking, but growing at about 0.4% annually as they have done since 1990 and represent almost twice the total area of Europe's arable farmland [15]. Biofuel feedstock production in Europe taps into two substantial resources: Eight million hectares of set-aside land, and productivity improvements through better plant varieties and agronomic practices. Productivity gains, particularly in the new member states in Eastern Europe, represent the larger of these resources. Several countries here currently achieve less than half the wheat yield compared with those from similar soils and climatic conditions in Western Europe, whereas East Germany's 'yield gap' has been closed since reunification and wheat yields, now similar to those achieved in West Germany, are amongst the highest in Europe [16].

Other arguments against the sustainability of biofuels in Europe raised by the EAC do not stand up to scrutiny. The economic case against biofuels cited by the EAC gives an uneconomic CO2 abatement cost for wheat bioethanol of £152/tonne and £137/tonne for biodiesel, supported by data sourced from the 2007 DTI paper 'UK Biomass Strategy' [17]. Yet on closer inspection, the DTI paper actually qualifies this data as 'illustrative'. Moreover, the DTI analysis dates back to 2005 and uses a projected oil cost of $40/barrel. True GHG abatement costs of biofuel incentives remain difficult to evaluate with any accuracy, as different production methods used for the same feedstock have a large impact, but agricultural GHG emissions can be reduced through known practices such as low-till cultivation to minimise soil CO2 losses [18], selective application of fertiliser in response to plant demand to minimise N2O emissions [19], and by new approaches such as application of 'Biochar' nutrients that sequester carbon whilst improving soil fertility [20]. Given that most agriculture is for food production, the right way to tackle this issue is through policy that controls all agricultural supply, rather than just biofuel feedstocks. The EU's single farm payment scheme already stipulates good environmental management practices that include control of chemical and fertiliser use, set-aside areas, field boundary sizes and highly specific measures such as patches within fields set aside for ground nesting birds. This scheme could also provide a mechanism for managing down the overall GHG contribution of European agriculture.

Perhaps the most emotive argument against sustainable biofuel production in Europe is 'food for fuel', that the diversion of agricultural output into biofuel production will drive up prices and deprive the world's poor of food. The EAC quote Jean Zeagler of the UN: " [It is] a crime against humanity to divert arable land to the production of crops which are then burned for fuel". This is an argument that resonates with the public awareness of rising food prices in supermarkets, particularly for foods with wheat- and corn-based ingredients, but again, here, all is not what it seems. Global wheat prices in real terms today remain well below their historic levels until the mid 1980s, when agricultural policies subsidising production in the EU and US conspired to create a global grain mountain [21]. This surplus depressed free market prices and led to massive flows of low-priced agricultural exports to developing countries, destroying the livelihoods of local farmers and stifling agricultural development. This is a bone of contention that continued to dog EU agricultural policy in 2006 according to Claire Godfrey, trade policy adviser for Oxfam: "Not only does the Common Agricultural Policy hit European shoppers in their pockets but strikes a blow against the heart of development in places like Africa. The UK government must lobby hard within the EU to agree an overhaul of the Common Agricultural Policy by 2008 to put an end to the vicious cycle of overproduction and dumping." [22].

In practice, the 'food for fuel' argument can be applied to any use of agricultural resources whose output does not directly feed people. Of these, the most significant are the production of animal feed and the production of biofuel feedstocks. Global growth in demand for animal feed is accelerating due to the combined impact of population increase and increased per capita income, which drives up consumption of meat. In Europe over 140 million tonnes, more than half of all grain produced, is used for animal feed each year [23] and a further 45 million tonnes of oil meals are imported to make up the necessary supply of animal feed protein [24].

What the EAC failed to acknowledge in its consideration of the impact of biofuels on food security is that a co-product of both bioethanol and biodiesel production is high-protein animal feed. The UK Government's Advisory Committee on Animal Feedingstuffs considered in 2007 whether biofuels would drive up the price of animal feed in the EU, and concluded that impact would be neutral, with any increase in grain prices offset by an increased supply of feed co-produced from biofuel processes [25].

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