I must say you all did a good job with this. Kudos, afew!

Well, there is also this (p. 5):

In general, NGOs are more sceptical about the validity of promoting biofuels in the EU than industrial stakehlders. Some argue that it is only valid if it is part of an energy policy in which biofuels—as a renewable energy source&meahs;are integrated into a broader context of e.g. promotion of greater energy efficiency, reduction of fossil fuel use, promotion of clean (vehicle) technlogy and low-carbon fuels, modal shifts, and decoupling od demand for transport and economic growth.

There is a very interesting table of the pros and cons of biofuels (Table 2, on p. 8). The document also says (p. 9)

Several NGOs and private citizens argue that the support of biofuels should be suspended and completely revised after thorough assessment of the sustainability of biofuels.

Pages 15-16 contain the following interesting bit

Differences between EU-produced feedstocks and imports:

Many respondents discern raw materials produced within the EU from materials produced in other countries.

For EU feedstocks, many respondents related to primary production indicate that there is an EU Common Agricultural Policy, including cross-compliance and Good Agricultural Practices. They state that there may be criticism on the policy, but that it is not useful to independently develop new criteria for biofuel crops. Others say that, if there would be need for extra criteria, this will be relatively easily implemented, compared with imports.

Sustainability of feedstock imports receives much more attention in the resposes. On one hand, certification is more important because the environmental risks are perceived as being larger, on the other hand it is more difficult to implement on foreign regions. Again, it is state[d] by some that such a certification should e.g. address all palm oil imports, not only the imports for biofuels. And there are issues on land use changes and competition for food.

Note, however, that Europe's main foreign biofuels supplier, Brazil, states in its response that WTO rules prevent sustainability criteria only to be developed for imports, since this can be regarded an illegal trade barrier.

On page 18, it says

If second generation biofuels are promising, their introduction may be enhanced by support in research and development, so indicate many.

(at this point the contorted grammar of the document, with no native English speakers in the team of 3 authors, is beginning to get on my nerves ;-)

On page 19 there is a bit that I know would not have made sense to me without having read essentially the same argument put forward by Jerome in relation with "a stable regulatory framework" for wind power:

The dominant [industry] argument favouring loger-term EU support for biofuels is that investment decisions to be taken now will have most of their impacts after 2010. A continuing supportive policy would therefore enhance opportunities for biofuels, also for the shorter term.

We have here the interesting issue of how expectations about future conditions influence present investment decisions. The argument is being made that the support already committed until 2010 will be wasted if it is announced that support will be cut after that, because investment by private enterprise will be cut not in 2010, but right now. I would also probably not have understood this argument as clearly had I not read Keynes earlier this summer [hat tip to Drew].

Still on page 19:

Of the governments the UK and Irish governments favour new targets. However, according to the UK they should be non-binding and related to GHG emission savings. The Netherlands states that it is too early to set a target now, given the problems with meeting the 5.75% target. The Irish government claims that the establishment of targets should therefore have regard to the difficulties, which individual member states have already encountered, and states that any proposals to revise targets should be fully debated so as to establish balanced and reasonable objectives that reflect the position of individual Member States.

I note that the UK advocates non-binding targets (if non-binding, then why bother?) and for GHG reduction (where we know biofuels are least effective). The position of the Netherlands and Ireland is interesting. They clearly can't meet their targets but they don't know why [could it be because the EU just doesn't have the agricultural capacity?]. Hopefully someone in the EU or the member states will start investigating why it is that the targets are not being met. I'd like to know what the Member States' excuses to the Commission will be.

On page 21, we have the pie-in-the-sky idea of the future that most of the industry and goverments have...

Question 5.4 If the EU is to define a quantified target for biofuels after 2010, what should it be? What year(s) should it relate to—2015? 2020? Both?
The biofuels industry clearly says yes, and many propose targets in the following band with

• 2015: from 8% to 15% (8% mentioned most, by which many refer to a statement by the eU heads of State)
  
• 2020: from 12% to 25%, most advises lying between 15% and 20%.
  

Except from the 8% 2015 target, these figures are generally not related to specific literature sources or forecasts.

This is worrying. First, 25% market share? We here think 6% is about as much as can be hoped for with domestic feedstock production. These targets are pulled out of thin air (for the space between the buttocks is indeed thin), but the summary understates it by saying they don't come from "specific literature or forecasts". In fact, the 8% target in 2015 comes from a statement by the EU heads of State! What is the point of regurgitating to the EU technical staff a statement from the political strata farthest removed from the nitty gritty? That it will look nice and so the rest of the document will be read more favourably? I mean, come on! But there is more

Within the bifuels industry, parties related to bioethanol appear to be the most ambitious, with 2020 targets of 20% and higher. One respondent pleads for a longer time span (2030) with a target of 75% in 2030. This with the argument that induced cost increases for fuels will trigger enery efficiency of vehicles and shifts to more energy efficient transport modi, thereby reducing fuel demand. ...  On average, the biodiesel-related respondents mention somewhat lower percentages (8-10% for 2015, 15-20% for 2020) Some explicitly mention that higher targets will lead to constraints in (domestic) production of feedstock. This may also be why industries related to feedstock production mention slightly lower targets (8% for 2015, 12-20% for 2020), although not all of these contributors mention this argument in this part of their response.

Hmmm... Is that industry respondent who suggests 75% biofuels in 2030 expecting transportation fuel consumption in the EU in 2030 to be 10% of that in 2005?

On page 23:

It is argued that biofuels should be seen as part of an overall package of measures to reduce the environmental impact of transport and the energy sector. Biofuels should also be evaluated in the context of other uses of biomass and the cost-effectiveness of these options in terms of GHG emission reduction. Several respondents state that, for reasons for limited indigenous resources, Member States should not be forced to apply policy incentives in favour of any one sector, where it could impact on the development of more effectve measures in other sectors.

Page 24:

Many stakeholders state that feedstocks as well as biofuels should be evaluated against a set of sustainability criteria, taking into account local conditions. Some of them see the emergence of a new industry as a unique opportunity to set new standards that could eventually be applied to the entire agricultural sector.

Nothing is 'mere'. — Richard P. Feynman

Afew, I think you should write back to the Transportation and Energy Directorate and congratulate them for the manner in which they have conducted this consultation, especially in comparison with the "interactive policy making" crap that we saw with the consultation on the energy green paper.

They need some positive feedback so that they see that the extra work they put (compared with just running an IPM questionnaire) not only results in hopefully better submissions, but also happier submitters. I, for one, am glad to see their summary of the consultation.

Nothing is 'mere'. — Richard P. Feynman

This is really wonderful, afew and everyone!  Great work.

Maybe we can eventually make language a complete impediment to understanding. -Hobbes

By the speed at which this collated document emerged from the EU.

You can't be me, I'm taken

Excellent work indeed!!

"Once in awhile we get shown the light, in the strangest of places, if we look at it right" - Hunter/Garcia

Here's a draft of an e-mail to return to the DG TREN Biofuels Consultation people:

Thank you for advising us of the posting of your summary of responses to the Biofuels Consultation. Those of us at European Tribune who have followed the Consultation are impressed by the speed with which you have collated a fairly large number of responses and complex points of view. By and large, we feel the Summary is exhaustive and fair-minded. It also seems to us that the overall spirit of the Consultation, as exemplified by the framing of the questions, has, up to this point, been open, inviting thoughtful contribution rather than attempting to direct public expression into predetermined channels.

We'd like to thank the team responsible for this work at DG TREN for making the effort to run a public consultation properly.

There's currently a discussion on the European Tribune site under the heading Biofuels Consultation Summary.

Best regards

Crits, changes, suggestions?

I think I said it once earlier...but this is really an impressive piece of work...and a huge step for the ET community. Major kudos and thanks to afew for all the work that has been put in by you on this!! <wow!!!>

"Once in awhile we get shown the light, in the strangest of places, if we look at it right" - Hunter/Garcia

I got to read this late, but a late congrats!

_{*Lunatic*, n.
One whose delusions are out of fashion.}