Two weekends ago I wrote... er... copied-and-pasted a diary on the European Union Public Consultations. In it I listed about twenty open consultations, most of them open to "stakeholders" (read: locusts). Then, a couple of days later, an article critical of biofuels in the FT prompted Jerome to write a front-page story. In it we learned that...
1. it would take >700% of the available agricultural land in the EU to produce enough biofuels to replace fossil fuels for transport EU-wide, at 2004 consumption levels. Worldwide, between 80% and 90% of all agricultural land would be necessary.

2. While biofuels are carbon-neutral, if would cost at least €100 per tonne of greenhouse gas emissions saved. If reducing greenhouse gas emissions is a goal, then according to companies selling so-called "carbon offsets", it costs as little as £7.50 per tonne to save carbon emissions by other means.

In any case, Jerome's diary was the perfect excuse to brainstorm on the above EU consultation which closes on July 10. Wait! what day is it today? July 1st already? Better get to work if we want to have our voice heard! Having it listened to is another matter entirely, though there is hope:

The questions cover a wide range of topics. Some are primarily political, others focus on scientific, legal or economic aspects. If you have views on some questions and not others, do not hesitate to send an answer covering only these questions.

For this diary, let's concentrate on just the first question:

1. Is the objective of promoting biofuels still valid?

The directive "aims at promoting the use of biofuels ... with a view to contributing to objectives such as meeting climate change commitments, environmentally friendly security of supply and promoting renewable energy sources".

Biofuels also hold out the prospect of new economic opportunities for people in rural areas in Europe and developing countries. One of the Commission's priorities is to explore and encourage new market outlets for agricultural products.
Some commentators argue that:

• developments since the directive was adopted in 2003 have reinforced the case for biofuels.
  
• The importance of security of supply has been underlined as the cost of conventional transport fuels has more than doubled.
  
• The challenge of climate change has not become less urgent.
  
• The agricultural sector is facing increasing competition, and it has a key role in providing feedstocks for biofuels.
  

By contrast, others argue that:

• biofuels' advantages in terms of greenhouse gas emissions and security of energy supply can be obtained at lower cost through other policies - for example, energy efficiency or the use of renewable energy (including biomass) in heating and electricity;
  
• the benefits of biofuels for rural areas have been exaggerated or are offset by negative impacts on consumers and the wider economy.
  

Question 1.1: Is the objective of promoting biofuels still valid?

On the consultation homepage one can already find three documents submitted by "stakeholders". Let's see what they have to say about question 1.
Forest Products Biotechnology group at the University of British Columbia [PDF]

Yes. 1st-generation biofuels still have a long way to go towards reinforcing the security of fuel supplies; in countries with significant biomass reserves, including France, Germany, Spain, Italy, the UK, Poland, etc. the potential supply of these fuels coul be significant. Moreover, industrial success with 1st-generation biofuels (i.e., those that are derived from foodstuffs or food residues and which are commercially available today) is starting to enable real investment in 2nd-generatin biofuels (i.e., those derived from non-food biomass which can be used in conventional vehicles and distribution systems). When 2nd-generation biofuels reach commercial status, the potential supply of these fuels in Europe will be a statistically significant portion of light vehicle fuel demand. The impact of these fuels will continue to provide employment in the agriculture and forestry sectors, will reduce volatility of fuel prices by increasing the security of fuel supplies, and wil have a beneficial environmental impact by reducing fossil carbon emissions. THE PROMOTION OF EXISTING IOFUELS TODAY IS ENABLING NEW TECHNOLOGIES THAT WILL INCREASE THE SUPPLY AND IMPACT OF BIOFUELS IN THE FUTURE.

Yes.
Novozymes finds that developments since the directive was adopted in 2003 have reinforced the case for biofuels. The importance of security of supply has been underlined as the costs of oil have increased. The challenge of climate change is still there and alternatives to liquid fossil fuels  are still very limited.
The technologies involved in biofuels have improved continuously over the last years thereby allowing bifuels to become increasingly cost effective. However it is also the opinion of Novozymes that Europe should not base itself on only one alternative to fossil fuel, but look at all potential ways of securing energy supply and reducing greenhouse gas emissions, so the possibilities of biofuels should be pursued in parallel with other technologies.
Novozymes would like to add that whereas security of energy supply and climate change may seem to be the main reasons for a continuous promotion of biofuels in Europe the effect on job creation should also be empasized. The biofuel area requires intensive R&D resources, which allows for the creation of a significant amount of knowledge based jobs and the agricultural sector will benefit from job creation in rural areas, which is particularly important after the CAP reform in Europe.
Furthermore the development of advanced technologies will potentially allow for future technology export from Europe.

Biotechnology is seen as a promising option to curb greenhouse gas emissions. There is, however, a potential competition for land due to increased demand for biomass resulting in increased food prices. This also would exacerbate future global water scarcity and negatively affect the food security of poor countries depending on cereal imports. Furtheron, the question of how a sufficiently large amount of biomass for energy production could be grown sustainably needs to be addressed. Conventional agriculture often has negative effedts on the environment. Organic agriculture is one sustainable alternative. Burning significant quantities of organic matter, however is incompatible with the principles of organic agriculture. Nevertheless, there is potential for sustainable impplementation of small-scale, on-site bioenergy projects, in particular in developing countries, and also of some forestry practives to harvest biomass for energy use. On the other hand, large-scale production of biomass for transport fuels is likely to be particularly unsustainable. To assess the sustainability of bioenergy on project level and as a global strategy, detailed differentiation is necessary. This paper combines these issues focusing on the potential challenges related to sustainable bioenergy production and its potential incompatibility with sustainable agricultural practices.

We are obviously not going to base our submission on these three, but it is useful to know what people are saying. What I suggest is taking a look at the 2003 directive [Google HTML conversion of this PDF original] and looking at the "whereases", that is, the rationale behind the directive, and debunking (or reaffirming) each one of them. For instance, the ones pertaining to climate change:

Whereas

(6) Greater use of biofuels for transport forms a part of the package of measures needed to comply with the Kyoto Protocol, and of any policy package to meet further commitments in this respect.

(22) Promotion of the production and use of biofuels could contribute to a reduction in energy import dependency and in emissions of greenhouse gases. In addition, biofuels, in pure form or as a blend, may in principle be used in existing motor vehicles and use the current motor vehicle fuel distribution system. The blending of biofuel with fossil fuels could facilitate a potential cost reduction in the distribution system in the Community.

In the comments to Jerome's diary there are additional sources both from old ET diaries and freshly contributed by commenters.