UFOP: Conservation through legally binding conventions, not ILUC
December 2, 2014
BY UFOP
The Union for the Promotion of Oil and Protein Plants (Union zur Förderung von Oel- und Proteinpflanzen, or UFOP) demands the continuation of a sustainable European biofuel policy after 2020. The union criticizes that, in its draft for a national climate conservation action program 2020, the German federal department of the environment doesn't take bioenergy or biofuels into account. Measures adopted in the framework of this program ultimately determine the climate conservation strategy beyond 2020, UFOP emphasized.
In this context and with an eye on the position adopted by the European Parliament in September 2013 and, finally, by the Energy Council of Ministers this June, regarding the recommendations from the commission to amend the renewable energy guideline (2009/28/EG) and the fuel quality guideline (2009/30/EG), the UFOP updated its position paper.
In this updated paper, reference is made to the introduction of the obligation to reduce greenhouse gases in Germany from 2015 and the consequential role as a pioneer by introducing the raw material-dependent greenhouse gas efficiency as a new element of competition in the biofuel policy on a national level. The UFOP demands that conventional biofuels in the framework of technologically open competition after 2020 (second- and third-generation) must be the platforms for the further development of the European biofuel strategy as a contribution toward climate and resource conservation. Effective resource conservation for investments made, which is based on a quantity of biofuels marketed prior to 2008, must be the basis.
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A particular challenge is taking the hypothesis on the “indirect land use changes” (ILUC) into account. Experts agree that ILUC effects in accordance with the principle of cause and effect cannot be concretely calculated, but, at best, can be derived by using models and specific assumptions. Therefore, in the opinion of the UFOP, the “polluter pays” principle does not apply, in the narrower sense, as a basis for statutory grounds for introducing so-called ILUC factors and thus raw material-specific negative greenhouse gas values. Since, with the ILUC hypotheses the principle applies that by promoting the use as a nonfoodstuff, an “ILUC effect” is created, this approach would then also have to apply to promotional measures if the resultant management requirements inherently lead to an extensification, thus excluding the exhaustion of the potential local earnings potential. In contrast, in its position paper (www.ufop.de), the UFOP determines the role model function of the sustainability certification for biofuels and agrees with the recommendation from scientists at the University of Darmstadt, that habitat conservation must be promptly ensured by legally binding conservation conventions.
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