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I read this more carefully and think the Suggestions section matters more than the Justification (which doesn't seem to show much knowledge of biofuels...).

And the Suggestions are not out-and-out wrong. They are rather bland. What we could add is probably to stress points about:

  • EU production capacity of 1st-generation biofuels is insufficient to reach targets such as 5.75% biofuels in 2010;
  • it follows that reaching targets = importing biofuels;
  • importing biofuels is no better dependency-wise than importing oil;
  • importing biofuels runs high sustainability risks (rainforest clearance, monoculture) that certification seems a weak shield against;
  • 1st-generation biofuels are therefore not a magic bullet, we should aim for 2nd-generation fuels that use marginal land and present better sustainability and supply independence prospects;
  • in the meantime, demand reduction is the key.

Does that appear right?
by afew (afew(a in a circle)eurotrib_dot_com) on Tue Sep 12th, 2006 at 03:51:59 AM EST
I agree completely.

I' try qualifying the statements a little:

# EU production capacity of 1st-generation biofuels seems barely sufficient to reach targets such as the 5.75% biofuels in 2010 demanded by the 2003 biofuels directive;
# it follows that reaching the current targets*, let alone increased targets, is likely to* require importing biofuels;

Should we also send them our biofuels consultation submission, or at least say where they can find it on the DG-TREN site?

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Tue Sep 12th, 2006 at 04:59:40 AM EST
[ Parent ]
I would say we have submitted a biofuel consultation there and there with the exact calculations. How pushy do we want to be? If they're genuinely interested, they may contact us.
by Nomad on Tue Sep 12th, 2006 at 05:44:27 AM EST
[ Parent ]
They are not exact calculations, but they are close enough to the mark. Call them detailed.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Tue Sep 12th, 2006 at 05:45:34 AM EST
[ Parent ]

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