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Biofuels Consultation Summary

by afew Fri Aug 25th, 2006 at 04:22:37 AM EST

I got an e-mail this afternoon from the European Commission DG for Transport and Energy group that is running the Biofuels Consultation.

Good afternoon,

We thank you again for your contribution to the public consultation on the review of the EU Biofuels Directive and we inform you that a summary of the responses is published today on our website :

[web link - exact text edited for formatting reasons]

Best regards,

As I mentioned before, our contribution is posted under European Tribune in the list of participating NGOs (on the page linked to in the e-mail). A breakdown in the Summary (it's a PDF file) says this of NGOs:


"Group responses" means those who sent practically identical contributions, so I think they put us in "Other", which is fair enough.

As far as I can see from a quick look through the Summary file, this is quite different from the appallingly biased Energy Green Paper Consultation. The summary is well-written and seems, at first sight, an honest attempt to account for the points of view expressed. And it seems far from leaning heavily in favour of biofuels industry or agri-business advocacy.

Here's a bit that covers points we made (p.6):

Both NGOs and private citizens express their concerns about the sustainability of biomass feedstock production (i.e. competition with food production, deforestation and biodiversity loss) and the environmental impact of biofuel use. From their point of view, the sustainability of biofuels should be guaranteed in order to make their promotion a valid objective. Some NGOs also mention that the use of biomass in the heat and power sector is more cost-effective in the view of GHG emission reduction. From an environmental point of view, the importance of the second generation of biofuels is also mentioned by several respondents.

On the other hand, our specific argument, that the EU simply doesn't have enough land to go in heavily for mass production of first-generation biofuel feedstocks, is only mentioned in passing, as far as I have seen. For example, page 8,

· Lack of indigenous feedstock production potential (especially first generation of biofuels)

is cited as an obstacle to the development of biofuels.

If you're interested in biofuels, it's not an uninteresting document to look at. All those who take a look (or for any other reason!), please comment.

[For past diaries on this topic, see European Energy in the ETWiki. Scroll down for the Biofuels links.]

Display:
I must say you all did a good job with this. Kudos, afew!
by Alex in Toulouse on Wed Aug 23rd, 2006 at 05:23:06 PM EST
Thanks, Alex. Pity we didn't have more time, since we only responded to part of the questions. But we did get our document in, which is a step forward...
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 01:27:51 AM EST
[ Parent ]
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
by Migeru (migeru at eurotrib dot com) on Wed Aug 23rd, 2006 at 06:24:03 PM EST
to both you and afew for your extensive work on this.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Thu Aug 24th, 2006 at 12:33:31 AM EST
[ Parent ]
I'll definitely front page this later on.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Thu Aug 24th, 2006 at 12:33:59 AM EST
[ Parent ]
Thanks for pulling out some plums. yes, there are a number of places where ideas like ours (where our contribution may be considered to have counted) are summarized. The (in our view) impossibility of producing enough first-generation feedstocks within the EU doesn't seem to me to have been given much play, however. And the distinction, from that point of view, between first and second generations of biofuel isn't stressed enough, imo.

As for

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?

I don't think I would criticize the authors of the summary as much as those who set up these consultations in the first place: why are Member States allowed to participate, when they have, by definition and by treaty, full rights over policy decisions, and cannot be considered to lack representation or an avenue for the expression of their policy preferences? (On second reading, that may be what you meant, but it bears re-stating!)

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 01:21:21 AM EST
[ Parent ]
No, I'm saying the industry respondents regurgitated to the T&E Directorate what the heads of State had said on a previous occasion, presumably based on nothing, and I don't understand what the point is of using your personal response to regurgitate points made by politicians.

I don't see anything wrong with allowing the Member States to submit entries (even Brazil did, as a trading partner). It is much easier to influence the commission process at this point than it is to amend an actual policy/legislation proposal.

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 04:25:28 AM EST
[ Parent ]
OK, I see (and take) your point.

I don't object to Brazil participating, it's only MSs that seem to me to have other means at their disposal to influence policy. Either that, or if they haven't, the EU really is run by the bureaucrats alone.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 07:33:51 AM EST
[ Parent ]
Although the Commission has the right to take any initiative it considers appropriate to attain the objectives of the Treaties, most proposals are a response to legal obligations, technical requirements or to a specific request for action from another institution, a Member State or from the interested parties.
(EU commission "basic facts")

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 07:37:07 AM EST
[ Parent ]
Are you saying "specific request for action" = "consultation participation"?
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 07:49:03 AM EST
[ Parent ]
No, but I'm saying that if the Member States are expected to submit suggestions to the Commission on their own initiative, they have all the more reason to be expected to submit input into  a public consultation, especially as the discussion includes imposing quotas to the member states.

After the commission produces its proposal for an updated regime under the 2003 directove, or even a new directive, the Member States will be less able to steer the proccess. The earlier you put your input in, the bigger the final effect of your input.

I don't see anything wrong, it's all in the public eye. For instance, now we have a position by the UK government and in the future they could be challenged if they contradict themselves.

If you want to conclude that the EU is indeed run by bureaucrats, I won't stand in your way.

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 07:54:17 AM EST
[ Parent ]
I don't want to conclude anything, but I think you know that ;)

OK, so let MSs contribute input to public consultations. It's still very far from the only influence they have. Take the "online poll" for the Energy Green paper, for example. If the only way Member States can have their say about an essential aspect of policy like energy is to go through that manipulative process, then...

No, don't let me reach a conclusion...

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 08:07:25 AM EST
[ Parent ]
It's the only way we can see. We can safely assume there are personal, political, institutional contacts that we can't see, more informal than formal. Formally, the mmeber states get involved in "codecision" with the EP after the Commission is done with it. But there's more than what's formally codified. We might even be able to get somewhere as citizens by writing directly to the commissioners, we just don't know that. If a commissioner were or had been your elected representative back at home at some point you might have a better shot than others.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 08:11:22 AM EST
[ Parent ]
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?

Anyone got any idea how changing the fleet to plug-in hybrids would affect liquid fuel consumption? I know I'd use hardly any liquid fuel with a plug-in hybrid.

by Colman (colman at eurotrib.com) on Thu Aug 24th, 2006 at 03:01:01 AM EST
[ Parent ]
No firm idea, but if EU car fuel consumption were to drop to one-tenth (say) of current levels, that would change the entire situation. Biofuels might be less capable of competing with petrofuels pricewise. And we'd be looking at directing biomass into electricity production.

Second-generation ethanol might, however, come into its own and free us from oil dependence (as the Swedish government hopes).

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 07:46:09 AM EST
[ Parent ]
How about if oil prices grew so much that demand for liquid fuels for transportation could drop to 10% of present values while keeping fuel prices at around £1 per litre? We're talking 2030 here. It's 25 years away.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 07:48:27 AM EST
[ Parent ]
Yes, that's possible if world oil demand continues to rise. There's no easy answer. As you say, it's in 25 years. We may have very nifty hybrid cars by then. Certainly, second-generation ethanol (supposing the technology comes smoothly on line and costs are competitive) could come into its own.

The main point then becomes, in this perspective, how do we generate electricity?

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 07:56:13 AM EST
[ Parent ]
I mentioned at the London meetup that I'd like to see a summary of the EU's primary energy production capacity, by source. Example:

Electricity [Solar, Wind, Hydroelectric]
Heat [Solar, Geothermal, Radioactive]
Fuel [Coal, Gas, Oil, Nuclear]

As well as the efficiencies involved in turning electricity into heat, heat into electricity, fuel into heat, electricity or fuel into motion...

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 08:01:22 AM EST
[ Parent ]
Here are some energy conversion efficiency estimates.

  • The efficiency of turning electricity into heat is 100%. Any inefficiency in the process shows up as heat, which is what you're trying to get in the first place.
  • The efficiency of turning heat into electricity is much worse, around 30% or so depending on exactly how you do it.
  • Turning fuel into heat is also pretty efficient because again, any "waste" energy is given off as heat.
  • Turning electricity into motion is pretty efficient (ignoring storage and electricity transmission factors), with good electric motors in the >90% range.
  • Turning fuel into motion depends again on the system, but a diesel engine in a truck is around 40%.

In fact, this list shows the basic two problems:
1.) Burning stuff to make electricity is not very efficient.
2.) Burning stuff to get motion is also not very efficient.
Unfortunately, those are the two things you most want to do.
by asdf on Thu Aug 24th, 2006 at 11:23:15 PM EST
[ Parent ]
Actually with a high-temperature heat source (>800°C) the efficiency of electricity generation can be >50% (this is the case with state-of-the-art coal/gas fired power plants, but it is impossible to reach with current technology nuclear plants).

Note also that turning fuel into heat may be only 60% efficient with older burners that let a good portion of the heat go away with the CO2 through the exhaust pipe, instead of into the heat transfer fluid (the water for the radiators in a house). You need recent "recondensing" boilers to reach >90% efficiency (they cool the exhaust so much that steam condenses and must be drained: if the boiler has a tiny pipe to the sewer, it is one of those). Also, tap-water boilers with a permanent candle were using ~50% of the gas just to stay online...

Pierre

by Pierre on Fri Aug 25th, 2006 at 05:08:55 AM EST
[ Parent ]
Yes, that's possible if world oil demand continues to rise.

If peak oil is really hit in 2005-2010, supply will decline and even if demand stays constant prices will go up.

Nothing is 'mere'. — Richard P. Feynman

by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 08:05:01 AM EST
[ Parent ]
I said "world" to bring in outside-the-EU, since we were supposing a drop in EU consumption. The overall result (EU + extra-EU) could be constant demand, as you say, and of course Peak Oil (diminishing supply) could then determine rising prices.

As you say elsewhere, the matter of what our expectations are about all this has a determining effect on investment decisions taken now. What seems important from this POV is what the engineers, the industry, the technocrats decide is the forecast they will be guiding the money towards. For example, we may not have super-nifty hybrids all over the place in 2030 if the automobile industry decides it is urgent to do nothing (or almost), as at the moment.

BTW, I may have missed it, but I didn't find our point that the auto industry needed coercing into urgent work on energy efficiency and GHG emissions came out very clearly in the summary; just, (p.5):

Some argue that it is only valid if it is part of an energy policy in which biofuels - as a renewable energy source - are integrated into a broader context of e.g. promotion of greater energy efficiency, reduction of fossil fuel use, promotion of clean (vehicle) technology and low-carbon fuels
by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 08:35:29 AM EST
[ Parent ]
Well, at least the Swedish seem to have the collective mindset of weaning themselves out of oil, and Starvid loves his hybrid scooter... Who cares whether Ford and GM don't develop cool hybrids? There's always Saab.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Thu Aug 24th, 2006 at 08:37:54 AM EST
[ Parent ]
I think there are some opportunities for the smaller car companies. While totally new engine development is beyond them financially, there's lot's of other automative technologies that they can excel in - reducing weight, mechanical efficiency, overall size in relation to use, designed for zipcar use, biofuels etc etc

You can't be me, I'm taken
by Sven Triloqvist on Thu Aug 24th, 2006 at 12:08:07 PM EST
[ Parent ]
"...there are some opportunities for the smaller car companies...there's lot's of other automative technologies that they can excel in - reducing weight, mechanical efficiency, overall size in relation to use, designed for zipcar use, biofuels etc etc"

You will have to work pretty hard to beat Honda and Toyota. They have already squeezed almost all of the fat out of their hybrids...the Honda Insight being the most extreme example...

by asdf on Thu Aug 24th, 2006 at 11:25:30 PM EST
[ Parent ]
But Toyota et al are still aiming for large scale production (volume cost efficiency) and thus a one-size-fits-all-solution.

The concrete world of highways and motorways, with nodes for fuelling etc, are a homogeneity all over the world. The one size solution fits this replicated microcosm well.

But all these concrete systems run through very diverse types of landscape and cultures which favour perhaps, different types of vehicles. Seen in this light, the one size solution works less well and offers scope for smaller automotive companies.

To give an example; you can find in some tropical/sub-tropical countries (Thailand eg) the concept of the open flat bed hop on-hop off taxi which cruise main routes. I don't know how efficient these are in terms of fuel use per passenger mile, but I would assume they are fairly good. (Certainly the ones I have been on were always packed). These vehicles are always heavily customised - but possibly only 'decoratively'. But I assume it might be worthwhile to also customise suspension, weight distribution, access etc as well as modifying engine peripherals for greater fuel efficiency under stop-go conditions.

All I am saying is that there are many other types of vehicles than family cars, and there is scope for smaller vehicle companies (I should have said this in my earlier comment, not 'smaller car companies') to provide transport solutions that take better account of the local environment and culture.

Instead of us adapting our lives to the mass produced car and the concrete system that has been built to support it, perhaps it would be more fuel/energy efficient for the vehicles to be adapted to us?

You can't be me, I'm taken

by Sven Triloqvist on Fri Aug 25th, 2006 at 05:55:16 AM EST
[ Parent ]
Who cares whether Ford and GM don't develop cool hybrids? There's always Saab.

SAAB is owned by GM. Volvo is owned by Ford.

by Trond Ove on Sat Aug 26th, 2006 at 01:35:43 AM EST
[ Parent ]
Just wait until supply begins to fall.  As I've said, there are two ways for us to make the transition from oil: The interventionist way, in which we use the tax code and regulations to "drive the market" (as they say in monetary policy), and the market way.  I guarantee we do not want to do it the market way, because it's going to be a lot tougher.  One way or another, we're going to have to make the transition, but, under the purely market scenario, a lot of people are going to suffer a lot of pain as prices continue to rise, whereas the interventionist way offers, I think, a smooth transition by comparison.  Prices are going to rise at much faster rates when we move to the right side of the peak.

Be nice to America. Or we'll bring democracy to your country.
by Drew J Jones (pedobear@pennstatefootball.com) on Sat Aug 26th, 2006 at 03:22:35 PM EST
[ Parent ]
Does the document mention that human power consumption (~13.5 TW) is already approaching 20% of the biosphere's total net primary production (~75 TW)?

I'd have thought that the human fraction would be much smaller, but the numbers check against other sources. The 13.5 TW doesn't include non-fuel uses of agricultural biomass (e.g., as food), but the 75 TW does.

Words and ideas I offer here may be used freely and without attribution.

by technopolitical on Fri Aug 25th, 2006 at 04:54:26 AM EST
[ Parent ]
Have you read A Treatise on Probability yet?  I expect diaries on that one.

Be nice to America. Or we'll bring democracy to your country.
by Drew J Jones (pedobear@pennstatefootball.com) on Sat Aug 26th, 2006 at 03:13:08 PM EST
[ Parent ]
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

by Migeru (migeru at eurotrib dot com) on Wed Aug 23rd, 2006 at 06:27:11 PM EST
I was thinking of doing so. The spirit in which this work is done is very different from the one we came across in the Green Paper Consultation.

I'll propose a text later today.

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 01:24:03 AM EST
[ Parent ]
This is really wonderful, afew and everyone!  Great work.

Maybe we can eventually make language a complete impediment to understanding. -Hobbes
by Izzy (izzy at eurotrib dot com) on Thu Aug 24th, 2006 at 02:48:05 AM EST
By the speed at which this collated document emerged from the EU.

You can't be me, I'm taken
by Sven Triloqvist on Thu Aug 24th, 2006 at 03:41:15 AM EST
Citizens! Congratulations!

You can't be me, I'm taken
by Sven Triloqvist on Thu Aug 24th, 2006 at 03:42:57 AM EST
[ Parent ]
Excellent work indeed!!

"Once in awhile we get shown the light, in the strangest of places, if we look at it right" - Hunter/Garcia
by whataboutbob on Thu Aug 24th, 2006 at 04:20:13 AM EST
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?

by afew (afew(a in a circle)eurotrib_dot_com) on Thu Aug 24th, 2006 at 11:12:35 AM EST
rather than attempting to direct public expression into predetermined channels.

Sounds negative , will made them suspicious about our intentions. First part of the sentence says the same in a positive way. Suggest replacing it by a . .

The struggle of man against tyranny is the struggle of memory against forgetting.(Kundera)
by Elco B (elcob at scarlet dot be) on Thu Aug 24th, 2006 at 12:00:48 PM EST
[ Parent ]
I'd go with Elco

You can't be me, I'm taken
by Sven Triloqvist on Thu Aug 24th, 2006 at 12:02:54 PM EST
[ Parent ]
It's excellent, and I support Elco B's amendment.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Fri Aug 25th, 2006 at 01:04:37 AM EST
[ Parent ]
So that sentence would be:

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 and has favoured thoughtful contribution.

?

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Aug 25th, 2006 at 03:47:59 AM EST
[ Parent ]
Sounds good to me.

In the long run, we're all dead. John Maynard Keynes
by Jerome a Paris (etg@eurotrib.com) on Fri Aug 25th, 2006 at 04:21:38 AM EST
[ Parent ]
Shouldn't we mention the "Interactive Policy Making" explicitly as what we think is "not running a consultation properly"?

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Fri Aug 25th, 2006 at 05:07:39 AM EST
[ Parent ]
Not here. Here we should praise them for doing the right thing.
by Colman (colman at eurotrib.com) on Fri Aug 25th, 2006 at 05:11:41 AM EST
[ Parent ]
Right.

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Fri Aug 25th, 2006 at 05:13:40 AM EST
[ Parent ]
I think we can make our thinking clear about that in another text. ("make clear" = clarify our thinking + express it clearly). This is a brief one to say: this is a good consultation (to date).

However this question occurs to me: the Summary is at the draft stage. Do we want to comment on it, i.e. suggest some points might be stressed more?

by afew (afew(a in a circle)eurotrib_dot_com) on Fri Aug 25th, 2006 at 05:52:59 AM EST
[ Parent ]
Might as well, but I wouldn't overdo it. It might work to nudge them a little bit more forcefully into looking at this diary...

Nothing is 'mere'. — Richard P. Feynman
by Migeru (migeru at eurotrib dot com) on Fri Aug 25th, 2006 at 06:45:03 AM EST
[ Parent ]
Since there has been no further comment, I sent this this morning:

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 and has favoured thoughtful contribution.

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

The discussion on the European Tribune site (under the heading Biofuels Consultation Summary) suggests some points we feel the final summary might underline a little more clearly.

Best regards

by afew (afew(a in a circle)eurotrib_dot_com) on Mon Aug 28th, 2006 at 04:50:29 AM EST
[ Parent ]
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
by whataboutbob on Fri Aug 25th, 2006 at 11:39:19 AM EST
I got to read this late, but a late congrats!

*Lunatic*, n.
One whose delusions are out of fashion.
by DoDo on Wed Sep 6th, 2006 at 06:01:08 PM EST


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