Below is the text of an open letter sent to all MEPs by seven
organisations, including Biofuelwatch on 4th June (sorry I forgot to
post this at the time!):

Open Letter to the Members of European Parliament

Re: EU Biofuel Policy

URGENT: re amendments and vote on the Draft Opinion on A Roadmap for
Renewable Energy in Europe (Rapporteur: Britta Thomsen)

Date: 4th June 2007

Dear Madam/Sir,

As you know, the European Commission is currently working on a
proposal for a revised Biofuels Directive, expected to be published
in autumn. According to these plans, 10% of all transport fuels have
to be biofuels by 2020. Many organisations now prefer to call
biofuels 'agrofuels', since the word 'bio' fuels creates an image of
being environmentally friendly by definition, which most of them
certainly are not.

In earlier communications from the Commission, it has always been
stressed that the promotion of biofuel use in transport should make
sure that these agrofuels are 'sustainably produced'. The Spring
Council has emphasised that again by making the mandatory target of
10% by 2020 for agrofuels 'subject to' their sustainable production.

We call upon Members of European Parliament not to support this 10%
target in the absence of clear sustainability safeguards, and to do
everything they can to ensure that all financial and other forms of
support for the production of agrofuels from large-scale
monocultures are suspended. At this moment, the sustainability of
agrofuel production for the EU market cannot be guaranteed, for
reasons that are outlined below.

It should be stressed, in particular, that despite the earlier
expressed intentions to put in place safeguards for the
sustainability of agrofuel production, the three criteria and the
monitoring system the European Commission is planning to introduce
leave nearly all sustainability issues uncovered, do not address the
indirect impacts and do not even guarantee a substantial climate
benefit.

MEPs HAVE THE OPPORTUNITY TO COMMENT ON A DRAFT OPINION: A Roadmap
for
Renewable Energy in Europe (Rapporteur: Britta Thomsen) BY 6TH JUNE.
We ask
you to suggest amendments and to support amendments from other MEPs
that
call for the following:

1. No targets OR incentives (subsidies, tax breaks) UNLESS and UNTIL
satisfactory sustainability guarantees are in place.

2. Indirect impacts, especially macro-impacts must be included in
any assessment of the impact of agrofuels and must be fully
addressed by sustainability safeguards, as these could be far
greater than any CO2 saving agrofuels could provide.

Macro-impacts

While it is acknowledged that criteria and certification cannot
address impacts on macro-level such as displacement and rising food
prices, the EC only proposes monitoring and reporting about land use
change, without any implications for the target. The European
Commission have confirmed in a
response to a parliamentary question by Caroline Lucas MEP that they
will not be able to guarantee the sustainability of imports, and
that they will not address indirect impacts. The Cramer Report, on
the other hand, stresses that some of the most serious negative
impacts of biofuel production are indirect impacts on land use, and
that those must be controlled if sustainability is to be guaranteed.
We believe that the European Commissionıs proposal does not fulfil
the conditions set by the
Spring Council.

Indirect impacts include:

* plantation companies selling produce grown on previously
deforested land for the EU biofuel market, whilst at the same time
destroying virgin rainforest to grow produce for food markets or
biofuel markets outside the EU;

* displacement of other agricultural activities, including
subsistence farming and cattle ranching into old growth forests as
plantations are expanded;

* the increasing use of rapeseed oil for biodiesel in Europe pushing
up palm oil prices, as palm oil fills the gap in food and chemical
markets (tinyurl.com/2kmgb5) ,thus incentivising investment in new
plantations, often at the expense of rainforests;

* the growing global demand for biofuels pushing up the price of
soya which, according to NASA, correlates with the rate of Amazon
deforestation (http://tinyurl.com/2pfga4).

Any system to guarantee the sustainability of agrofuels production
should be capable of addressing the indirect effects of large-scale
agrofuel production, as the Cramer Report rightly stresses. We also
highlight the devastating impact of rising prices of commodities
like soy on forests.

No social or environmental criteria included

No social criteria or environmental criteria protecting water, soil
quality or preventing pollution are being considered by the EC at
this point. This makes nonsense of any notion of 'sustainable
agrofuels'. Like many other NGOs and social movements, we insist
that sustainability standards and
criteria should also address the social and human rights impacts of
agrofuels.

Food security and food sovereignty, human rights, working
conditions, land rights and rural poverty are all issues that should
be included. Monoculture plantations are notorious for their impact
on local populations. This cannot be allowed to continue, especially
not with EU public support like tax breaks and subsidies.

The Chair of the U.N. Permanent Forum on Indigenous Issues has
warned that 5 million indigenous people in West Kalimantan alone are
likely to become refugees because of biofuel expansion. The EU
proposals suggest, however, that palm oil grown on land from which
people have been evicted, quite possibly through violence and
without any compensation, can be classed as 'sustainable'. This is
not acceptable.

No climate ambition

The criteria the EC is thinking to propose state that agrofuels are
only eligible for support if their greenhouse gas balance is at
least just above zero (or perhaps, give 10% CO2 saving). The Dutch
Cramer report mentions a minimum of 30% CO2 saving, while Dutch
environmental NGOs demand a minimum of 50% for agrofuels. However,
the expansion of monoculture crops, this time
for agrofuels, is in fact threatening to greatly accelerate climate
change. This was confirmed by scientists meeting in Hong Kong at the
end of May (http://www.alertnet.org/thenews/newsdesk/HKG80770.htm).

Indonesiaıs biofuel plans are set to expand Palm Oil production 43-
fold (http://tinyurl.com/33lb7r) and threaten most of that countryıs
remaining rainforests and peatlands. If those plans are implemented,
42-50 billion tonnes of carbon could well be released into the
atmosphere. This is the
equivalent of around six years of global fossil fuel burning. Palm
oil expansion in South-east Asia is fuelled by rising commodity
prices. Losing this carbon sink alone will make climate
stabilization very difficult it not unlikely to achieve. Even if the
EU tried to discriminate against palm oil for agrofuel, increased
demand for palm oil in the food, cosmetic and chemical industries
due to resource displacement (using palm oil where rape oil is being
diverted to biofuel) will have the same effect.

NASA scientists have shown that the rate of Amazon deforestation
directly correlates with the world market price of soya
[http://tinyurl.com/2pfga4]. That price is expected to rise sharply
as demand for soya biodiesel grows. Soya expansion is linked to
deforestation not just in the Amazon but also elsewhere, including
the Pantanal, Cerrado, South Americaıs Atlantic Forest and a portion
of the Paranaense forest in Paraguay and North of Argentina.
Scientists are warning that the Amazon may be close to a tipping
point, beyond which it could die back in a vicious cycle of mega-
fires and droughts. The Amazon relies on rainfall which is recycled
by the forest itself. Deforestation reduces the amount of rainfall
and threatens to tip the whole ecosystem into collapse. 2005 and
2006 saw two years of drought unprecedented in living memory and
there are indications that drought conditions are returning in 2007,
which could be a first sign of imminent collapse of large parts of
the Amazon forest. Biofuel expansion is pushing up the price of soya
and is thus becoming another driver for deforestation, making the
collapse of the Amazon ecosystem more likely. If the Amazon was to
die back, it would be impossible to stabilise the global climate at
all,
and global food supplies could be immediately threatened due to
major changes in rainfall patterns. This is not a risk which we can
afford to take.

No adequate stakeholder consultation with the South

In addition, we are very concerned that the EC is engaged in this
policy making process without full and effective consultation of
NGOs, farmer's movements, Indigenous Peoples and other stakeholders
in developing countries, which are likely to produce the majority of
agrofuels needed to meet the proposed target of 10%. These groups
are the ones likely to be affected by the expansion of plantations
for agrofuel production.

This lack of consultation is unacceptable from a moral point of
view, as environmental and social standards might be developed that
do not address local and national priorities, including in the field
of biodiversity conservation. Moreover, it also creates a major risk
that the system that will be designed will not be enforceable in the
main producer countries, as it does not take into account
limitations in law enforcement capacity and the capacity to monitor
and verify the implementation of the standards and criteria
proposed.

Civil society organisations in the South have had very mixed
experiences with 'sustainability certification schemes'. The
existing voluntary schemes for certification are now often taken as
an example to be used in EU policy. However those stakeholder
forums, namely the Round Table for Sustainable Palm Oil (RSPO) and
the Roundtable on Responsible Soy (RTRS), do not actually certify
any produce as yet. In addition, they have all had issues with
failing to ensure stakeholder participation or have been strongly
criticised, including by NGOs in Papua New Guinea (RSPO) and NGOs
and farmers organisations in Paraguay and Argentina (RTRS).

Without addressing these indirect impacts, the effects of the target
of 10% are likely to be absolutely dramatic for the world's forests
and Indigenous Peoples, and many other ecosystems and rural
communities.

In our opinion, trying to achieve the sustainable production of
commodities for the EU market, something which is highly necessary,
has to be accompanied by a decrease, rather than an increase, of EU
demand for these commodities. It is hard to see how with a world
wide demand increase any set of criteria can guarantee
sustainability of production. Sustainability criteria are only a
valid tool if they really can guarantee sustainability, which by
definition includes securing a sustainable livelihood for societies
living in areas of production.

Major investment is being made in completely unsustainable forms of
agrofuel production in countries such as Indonesia, Paraguay,
Argentina, Brazil and Colombia, in anticipation of fast growing
demand, including from the EU. In West Papua alone, it is expected
that up to 10 million hectares of virgin rainforest is being
considered for palm oil plantations, largely for biodiesel, and
investment deals are being made now which will be very difficult to
reverse. This is why true sustainability guarantees must come
before biofuel targets and incentives, i.e. market expansion ­
otherwise irreversible damage will be done to old growth forests,
other ecosystems and carbon sinks and to local communities. Such
damage is likely to have implications for us all in terms of the
damage to global climate systems it is predicted to cause.

In this light we call upon the European Parliament to take the above
concerns into account while forming an opinion on the EU agrofuel
policy.


Sincerely yours,

Biofuelwatch (Almuth Ernsting)
Corporate Europe Observatory (Nina Holland)
Grupo de Reflexion Rural, Argentina (Stella Semino)
Munlochy Vigil (Anthony Jackson)
Rettet den Regenwald e.V. (Reinahrd Behrend)
Watch Indonesia (Marianne Klute)
EcoNexus (Helena Paul)



NB: See for criteria system currently suggested by the European
Commission
is currently subject of a consultation process and can be found on:
http://ec.europa.eu/energy/res/consultation/index_en.htm