Multiple objectives in biofuels sustainability policy

See discussions, stats, and author profiles for this publication at: https://www.researchgate.net/publication/255748787 Multiple objectives in biofuels sustainability policy Article in Energy & Environmental Science · February 2011 DOI: 10.1039/C0EE00041H CITATIONS READS 13 32 4 authors, including: Jon C. Lovett Joy Clancy 212 PUBLICATIONS 5,791 CITATIONS 110 PUBLICATIONS 522 CITATIONS University of Leeds SEE PROFILE University of Twente SEE PROFILE All content following this page was uploaded by Jon C. Lovett on 11 February 2015. The user has requested enhancement of the downloaded file. All in-text references underlined in blue are added to the original document and are linked to publications on ResearchGate, letting you access and read them immediately. OPINION www.rsc.org/ees | Energy & Environmental Science Multiple objectives in biofuels sustainability policy Jon C. Lovett,*a Sarah Hards,b Joy Clancya and Carolyn Snellb DOI: 10.1039/c0ee00041h Sustainability, with its multiple environmental, economic and social objectives, is now prominent in many national and international policies. These are implemented in a classical incrementalist approach. We use the example of biofuels to demonstrate the way that multiple objectives are developed in energy and environmental policy. Biofuels are promoted as replacements for transport fuels, but biofuel policy is also geared towards socio-economic goals such as agricultural subsidy and strategic goals such as security of energy supply. We discuss examples of multiple objectives and regulatory instruments applied to biofuels with a focus on the United Kingdom and highlight the difficulties of applying sustainability criteria under international trade agreements. In conclusion we briefly contrast biofuels policy against that of fossil fuels. 1. Introduction The politically acceptable definition of sustainability is that adopted by the Report of the World Commission on Environment and Development (often called the Brundtland Commission) in 1987.1 This definition states that sustainable development ‘‘meets the needs of the a CSTM - Twente Centre for Studies in Technology and Sustainable Development, University of Twente, Postbus 217, 7500 AE, Enschede, Netherlands. E-mail: j.lovett@ utwente.nl; Fax: +31-53-4894850; Tel: +31-534893203 b Department of Social Policy and Social Work, University of York, Heslington, York, YO10 5DD present without compromising the ability of future generations to meet their own needs’’ and should encompass environmental, social and economic dimensions. The concept of meeting the needs of present generations endorses a ‘business as usual’ approach, contrasting with the notion of limits to growth imposed by finite natural resource availability2 which would require marked changes in lifestyle and so are less likely to receive popular support. From a public administration perspective, practical application of Brundtland sustainability is an example of what Charles Lindblom called ‘incrementalism’; or perhaps more famously, ‘muddling through’.3,4 Policies are made Jon Lovett is professor of Sustainable Development in a North South Perspective at the University of Twente in the Netherlands and leader of the sustainability strategic research orientation in the Institute for Governance Studies. His main interest is the institutional economics of natural resource management. In 2008–2009 he was the Environmental Economist on the Chief Scientist’s Jon C: Lovett team of Natural England and an advisor to the 2009 Sustainable Development in the European Union report prepared by EuroStat. He works with Joy Clancy on a range of biofuel issues in developing countries. This journal is ª The Royal Society of Chemistry 2011 incrementally because the generational time perspective and multiple objectives implicit in sustainability mean that a calculated balance between inter- and intra-generational equity, or on a reasoned analysis of trade-offs between the three different dimensions, is not possible. Biofuels for the transport sector are particularly interesting in the context of the multiple objectives of sustainability policy. Although they have been in use since the invention of the internal combustion engine, the recent global push for increased use has coincided with a general political acceptance of sustainability as a guiding concept. There are two Sarah Hards is completing a PhD in the Department of Social Policy and Social Work at the University of York. Her research focuses on the sustainable practices of individuals and their variation over time. Sarah Hards Energy Environ. Sci., 2011, 4, 261–268 | 261 additional issues. One is that agricultural products are used as feedstocks in biofuel manufacture, which leads to both trade and substitution complications; and the other is that biofuels offer the possibility of supplementing or replacing fossil fuels with a renewable resource thereby reducing greenhouse gas emissions and so mitigating anthropogenically induced climate change. Climate change is a global environmental issue attributed, at least in part, to anthropogenic activity5 and which warrants immediate coordinated action to offset the adverse social, economic and ecological threats to sustainability,6 in other words more decisive than the normal incremental approach. On taking up the presidency of the G8 at Gleneagles in July 2005, the then British Prime Minister, Tony Blair, stated that climate change is ‘‘probably, long-term the single most important issue we face as a global community’’. An initiative of the Gleneagles meeting was to propose the launch of a Global Bio-energy Partnership ‘‘to support wider, cost effective, biomass and biofuels deployment, particularly in developing countries where biomass use is prevalent’’. When the ‘Stern Report’ on the economics of climate change was published in 20067 with estimates that global warming could cause a 20% reduction in the global economy but action taken now would only cost 1% of global gross domestic product, Tony Blair said that scientific evidence of global warming was ‘‘overwhelming’’ and its consequences ‘‘disastrous’’.8 Despite the urgency of climate change, and the apparent need for a leap in policy, biofuels are subject to incremental policies with multiple objectives.9 For example the 2003 European Biofuels Directive10 contained two major policy goals in addition to being part of a package of measures to comply with the Kyoto Protocol (Article 6). These were opening a new market for agricultural products (Article 15) and reduction in energy import dependency (Article 22). The 2009 European Renewable Energy Directive (2009/28/EC) on promotion of the use of energy from renewable resources went a step further and added a fourth policy goal of stimulating innovation, jobs and economic growth. In this article we use the example of UK and European policy to examine multiple objectives and sustainability. We review regulatory issues, socio-economic and environmental implications of biofuels in the context of multiple, often contradictory, policies. There is also a lack of consistency between energy policies. We illustrate this point in the discussion by showing that other policies related to fossil fuels are based primarily on economic criteria with less emphasis on environmental and social impacts. 2. Multiple objectives and sustainability in UK policy The Brundtland approach to sustainable development is deeply embedded in UK policy, and government supports its multiple objectives. For example, in 2003, Dr Joy Clancy MRSC is a Reader (Associate Professor) in Development Studies specializing in Technology Transfer. Dr Clancy’s research has focused, for more than 25 years, on small scale energy systems for developing countries, including the technology transfer process and the role that energy plays as an input for small businesses and the potential it offers entrepreneurs through the provision of Joy Clancy a new infrastructure service. Her PhD was on alcohol fuels in stationary engines (University of Reading). She is currently supervising research on conflict and biofuels in Colombia and actor networks in biofuel innovations in Indonesia. 262 | Energy Environ. Sci., 2011, 4, 261–268 three ambitious objectives were boldly declared in the Government’s ‘‘Changing Patterns’’ report on Sustainable Consumption and Production: ‘‘The challenge is to ensure that we make progress in parallel on three fronts – economic development, environmental protection and social cohesion – and that initiatives to promote any one of them do not undermine either of the other two.’’11 In order to establish this multipleobjective approach as valid and achievable, various ‘‘frameworks’’ have been drawn upon by policy-makers. In the 2005 UK Sustainable Development Strategy, the introduction written by Tony Blair states that: ‘‘.policies to promote better quality environments also have the capacity to have long-term social and economic benefits .Our goals are a strong economy, and decent homes in places with clean, safe and green public spaces, where people are able to lead healthy lives, and enjoy the environment around them.’’12 In this statement, environmental, economic and social goals are blended into a single ‘‘quality of life’’ framework. This has been a dominant framework in UK sustainability policy for at least a decade – the UK’s 1999 Sustainable Development Strategy was entitled ‘‘A Better Quality of Life’’.13 Another framework used to reconcile multiple objectives is that of ‘‘environmental justice’’ – also employed in Blair’s introduction to the Sustainable Development Strategy, when he argues that ‘‘Often those people who are most Dr Carolyn Snell is a Lecturer in Social Policy in the Department of Social Policy and Social Work, and a Research Fellow at the Stockholm Environment Institute (both at the University of York). Carolyn specialises in the links between social policy and the environment, environmental policy analysis, and the implementation of sustainable development. Carolyn Snell This journal is ª The Royal Society of Chemistry 2011 economically and socially disadvantaged also live in degraded environments with fewer jobs, unsafe and ugly streets’’.12 Blair employed this framework in order to reinforce his message that environmental goals are intertwined with socioeconomic goals. He also presented a conceptualization of the local environment as a ‘‘major public service’’12 – a metaphor that makes environmental goals indistinguishable from socioeconomic ones. The justice position was echoed in a statement by Gordon Brown, who succeeded Blair as Prime Minister, two weeks before the 2007 UNFCCC Bali meeting in which he gave three government objectives including fairness and transforming economic growth to prosperity ‘‘. the role of government from now on is transformed. Once government objectives were economic growth and social cohesion. Now they are prosperity, fairness and environmental care.’’14 The methods used to reconcile multiple objectives in sustainability policy are different when the concept of environmental limits is involved. ‘‘Limits to growth’’ sustainability in the original 1972 Meadows et al. conceptualization2 is very rarely apparent in UK sustainability policy. Indeed, it is flatly rejected in the UK Sustainable Development Strategy, which states, ‘‘Development, growth, and prosperity need not and should not be in conflict with sustainability’’.12 However, the concept of environmental limits does play a part in government thinking, as shown by the existence of reports such as DEFRA’s 2007 ‘‘Perspectives on the ‘Environmental Limits’ Concept’’.15 In May 2007, David Miliband, then Secretary of State for the Environment, argued that ‘‘.if you are a throw-away society, a wasteful society, you can’t live within environmental limits’’.16 Living within environmental limits even forms one of the UK Government’s ‘‘Principles of Sustainable Development’’. However, there are also four other principles: a strong, healthy and just society; a sustainable economy; sound science and good governance. In this context, for a policy to be considered sustainable, it must ‘‘respect all five principles’’.17 So even when environmental limits are acknowledged, the aim is still to both live within limits and simultaneously achieve socio-economic goals – as summed up in the ‘‘Changing Patterns’’ report: ‘‘We all have aspirations for better living standards and we need to find ways of meeting those expectations, in the UK and developing world, without the side effects that undermine the quality of life in other ways and without breaching environmental limits’’.11 In UK policy, the most commonly proposed means of reconciling these multiple objectives is the ‘decoupling’ of economic growth from environmental degradation: ‘‘Given that there are limits to the capacity of the Earth’s ecosystems to absorb pollution and provide natural resources, the only way to maintain economic progress in the long term without approaching these limits is to decouple economic growth from environmental degradation’’11 (bold font in original). Decoupling is sometimes presented as having an almost infinite capacity to bring about desired outcomes, however ambitious and diverse they may be, as can be seen in this statement: ‘‘The Government seeks to deliver continuous economic and social progress that respects the limits of the Earth’s ecosystems, and meets the needs and aspirations of everyone for a better quality of life now and for future generations to come. This vision will be accomplished by: 1. ‘Decoupling’ economic growth and environmental degradation.’’.11 Decoupling here means ‘‘ensuring environmental degradation does not automatically grow with the economy to the extent that environmental limits could be threatened in the medium term. In practical terms this means getting more from less’’11 (bold font in original). So the government seems to be suggesting that the solution to the dilemma of multiple objectives is, essentially, efficiency. The concept of environmental limits is absorbed into a technocentric framework for sustainable development – an optimistic approach that sees innovation, especially in technology, as the basis of sustainable development in keeping with the Brundtland approach. For example, Tony Blair stated in a speech on climate change in September 2004: ‘‘But there is no doubt that the time to act is now. It is now that timely action can avert disaster. Just as science and technology has given us the This journal is ª The Royal Society of Chemistry 2011 evidence to measure the danger of climate change, so it can help us find safety from it. The potential for innovation, for scientific discovery and hence, of course for business investment and growth, is enormous.’’18 Reconciliation of economic growth and environmental limits in this way is sometimes called a ‘weak’ form of sustainability, and linked to the ecological modernisation paradigm. This approach has also been adopted internationally – at the World Summit on Sustainable Development in Johannesburg, world leaders committed themselves to: ‘‘. delinking economic growth and environmental degradation.’’11 Multiple objectives are apparent in policy relating specifically to climate change. The UK Sustainable Development Strategy links climate change policy objectives with socio-economic objectives in a ‘‘quality of life’’ framework similar to that described above: ‘‘Although climate change is the most serious global environmental threat, promoting new, modern, sustainable ways of living, working, producing and travelling also stand to achieve wider benefits to human health and well being.’’12 The UK Climate Change Programme 2006 stresses the compatibility of climateprotection goals and socio-economic goals, arguing that, ‘‘emissions reductions and prosperity can go hand-in-hand’’ and declaring that, ‘‘Our approach seeks to secure steady emissions reductions over time, through a framework that recognises the importance of maintaining our economic competitiveness and our responsibilities to all members of society – particularly those experiencing fuel poverty.’’19 Later in 2006, the Stern Review7 argued strongly that the goal of addressing climate change and the goal of economic benefit are not only compatible, but furthermore that economic goals can only be met if the goal of addressing climate change is achieved. In May 2007, David Miliband, then Secretary of State for the Environment, reflected this shift in thinking on climate change when he argued that, ‘‘Climate change is sometimes described as an environmental issue.But actually the more you look at it the less you think it is an environmental issue, the more you think it is an economic issue, a social issue and a cultural issue as well.’’16 Energy Environ. Sci., 2011, 4, 261–268 | 263 3. Biofuels and multiple objectives Biofuels have been used to promote multiple objectives at global, regional and local levels. They have been available for a long time: initial development of the internal combustion engine in the early 1900s envisaged ethanol and biodiesel as the fuels. But technical innovation not only created cheap engines, it also enabled mass extraction, processing and marketing of fossil fuels which made biofuels uncompetitive. Rising fossil fuel costs played a role in serious reconsideration of biofuels and led to development of an ethanol fuel industry in Brazil20 stimulated by increased oil prices in the 1970s following the 1973 Arab oil embargo and 1979 regime change in Iran. Environmental concerns over excessive fossil oil use were raised in the 1970s due to localised atmospheric pollution use for transport in cities and passing of legislation to create cleaner exhausts21 caused biofuels to be revisited. However, collapse of the oil price in the 1980s, Brazil’s discovery of oil off-shore (domestic oil production in Brazil increased from 170,000 b/d in 1970 to 600,000 b/d in 198622) and improved engine emission controls prevented widespread adoption of biofuels. More recently, concern over security of supply together with reform of support from the European Union to the agricultural sector and climate change obligations prompted re-examination of biofuels for transport fuel. All the more so because transport is the main driver for increasing global oil demand.23 European biofuel policy is geared to simultaneously tackle global environment problems, enhance regional integration, stimulate rural economies and provide strategic fuel supplies. The 2003 European Parliament Directive10 on biofuels has three different objectives. Firstly compliance with international measures to tackle climate change ‘‘Greater use of biofuels for transport forms a part of the package of measures needed to comply with the Kyoto Protocol.’’ Secondly, to provide a market for agricultural products ‘‘Promoting the use of biofuels in keeping with sustainable farming. could create new opportunities for sustainable rural development.’’; and thirdly for strategic reasons ‘‘Promotion of the production and use of biofuels could 264 | Energy Environ. Sci., 2011, 4, 261–268 contribute to a reduction in energy import dependency.’’ In policy terms, although the global objective of climate change is perhaps of overriding environmental importance, it is the local and regional objectives which are the decision-making drivers. For example, Bulgaria and Romania, which joined the European Union in 2007, have around 0.7 ha of agricultural land per capita compared to an average of 0.4 ha for the other 25 EU countries. Agricultural production of biofuels for the European market was therefore envisaged as a potential way of enhancing European harmonisation.24 The House of Lords report on the 2006 EU Strategy on Biofuels24 also recognized the three major motivations for EU policy in this area as strategic, environmental and economic. The agricultural economic objective relates to reform of the Common Agricultural Policy, with biofuels acting as a ‘‘possible route through which farmers can enter this new, competitively-focused, agricultural landscape.’’25 Entry of biofuels in the agricultural economy is incrementalist5 as illustrated by the following quotations from an interview with Tony Blair about climate change in New Zealand on 29 March 2006.26 New Zealand formerly had protected access to UK agricultural markets under the Commonwealth, but this status was lost with protection and subsidy of the European Market when the UK joined the EU in 1973. New Zealand is thus interested to know if European commitment to biofuels will result in a switch of subsidies from areas such as meat, wool and dairy products. The New Zealand interviewer asked ‘‘.where does moving. food production across into production of crops to produce biofuel fit into the future.?’’, to which Tony Blair replied ‘‘.obviously we in Britain fight very hard for changes to the agricultural policy, and the whole question of biomass, which we are developing in the UK incidentally, is potentially a major future role for the agriculture industry in the whole of Europe. Now I think that it would be unwise of me to promise that agricultural policy was going to be changed in a very rapid timescale, but yes it does offer opportunities to switch from subsidised production of food to diversifying into biomass, and that as I say is something we are trying to encourage in the UK at the moment.’’ This incremental approach contrasts with the statements made by Blair on the seriousness of climate change and the need for action cited here in the Introduction. Motives in other parts of the world are broadly similar, with the USA, India and China encouraging biofuel production for energy security, rural development and technological innovation.25 In the USA, by 2005 14.4% of the United States maize crop was used to produce ethanol and 3% by volume of US consumption of gasoline was composed of ethanol.27 Between 1995 and 2003 the US maize sector received $37.4 billion in subsidies and biodiesel is used for major government transport fleets such as the Post Office, Military and metropolitan transit systems.28 Demand in developing countries is also rapidly increasing, India has an indicative target for both biodiesel and bioethanol of 20% by 201729 and China has enacted a ‘Renewable Energy Law of the People’s Republic of China’ to promote biofuel use.28 Potentially biofuels could be used to work towards international objectives such as providing markets for developing countries that will help meet agreements for poverty alleviation such as those formulated in the year 2000 by the United Nations in the form of Millennium Development Goals which aim to meet targets such as ‘‘Reduce by half the proportion of people living on less than a dollar a day; Achieve full and productive employment and decent work for all, including women and young people; Reduce by half the proportion of people who suffer from hunger’’ by 2015.30 Wealth creation in Africa through increasing agricultural output was a central theme in the Blair ‘Commission for Africa’.31 For example, Europe is unlikely to be able to meet its own demand for biofuels:23 the total available agricultural land is about 97 million hectares of which 17 million hectares would be needed to meet EU Directive targets using current technologies.24 Biofuels thus present a major opportunity for developing countries to supply the certain and growing European fuel requirements. 4. Biofuels, sustainability and trade The implications of adopting sustainability criteria to trade in biofuels can be This journal is ª The Royal Society of Chemistry 2011 illustrated by the case of Germany. In 2007 Germany’s primary energy needs were 13,842 petajoules (PJ) of which 792 PJ (5.7%) were supplied from bioenergy with a planned rise to 1,309 PJ in 2020.32 Currently, the country produces about 5 million tonnes of biodiesel a year.33 The 2009 European Union Renewable Energy Directive (2009/28/EC) requires biofuels to be produced under a range of sustainability criteria in order to be eligible for financial incentives and contribute to national targets for renewable energy use. Germany is the first member state to put the directive into national law through two laws, one for biomass for electricity generation (BioSt-NachV) and one for biofuels (Biokraft-NachV). The biofuels law contains a range of sustainability criteria that have to be met for biofuels to be eligible for financial incentives. These include: greenhouse gas emission savings must be at least 35%, increasing to at least 50% on January 1, 2017, and 60% from January 1, 2018, for installations starting production after December 31, 2016; biomass must not be obtained from land with high biodiversity value; biomass must not be obtained from land with high carbon stock; biomass must not be obtained from land that was peat land in January 2008; and biomass production on agricultural land in the EU must be in compliance with council regulation EC/73/2009.34,35 Imposition of sustainability criteria in German law could be viewed in two ways. Firstly it represents an incremental shift of policy from relatively vague statements about sustainability to a legal requirement. Secondly it represents a potential barrier to trade as the criteria are difficult to quantify and ultimately the decision on compliance is made by the importing nation. If imported biofuels come from tropical developing countries with agricultural expansion replacing natural vegetation then they will be de facto derived from lands with high biodiversity, carbon stock and, in some cases, peat lands. This is because tropical countries naturally have higher biodiversity than northern Europe and developing countries are opening new land for agriculture whereas in Europe intensive farming systems are well established. Moreover, compared to large scale developed country producers, obtaining sustainability certification can be expensive for developing countries and small scale producers.36 Sustainability criteria are hard to quantify and methodology, such as that for green house gas emissions, is still under debate.37 Commodities are also often subsidized by governments or regulated by complex overlapping international agreements. Biofuels are particularly complicated because they are simultaneously an agricultural, energy and industrial chemical product. For example, under WTO rules ethanol is classified as an agricultural product whereas biodiesel is an industrial chemical.27 The EU has an aid programme for energy crops grown on nonset-aside land28 and Pakistan and Guatemala have been cited in a case brought by industrial ethanol producers for dumping ethanol on the European market through an import tariff concession.28 Pakistan was given preferential import tariffs as part of a programme to combat narcotics production and trafficking. India objected to the WTO because they didn’t qualify for the same programme. Set against this policy complexity are environmental and food security concerns. Environmental concerns rest on two main issues. Firstly, increasing demand for biofuels results in land conversion from natural vegetation to biofuel plantations. Oil palm in particular has been criticized as it is a high yielding oil crop that can be used for biodiesel production and is undergoing a major expansion on land that would naturally be occupied by species rich tropical rain forest. The main oil palm producing countries are Indonesia and Malaysia, which are also home to many rare species, and oil palm plantations are an order of magnitude less diverse in birds and butterflies than primary tropical forest.38 However, the main importers of palm oil are China and India, and the main use is cooking oil rather than biofuel. Some rural villagers who have benefited from a strong palm oil export market39 while there are others who have been distinctly disadvantaged, for example in Latin America. Moreover, 95% of global biodiesel feedstock is from the temperate crop rape seed with oil palm only providing 1%40 and palm oil is considered by the industry to be expensive as a biofuel feedstock in comparison to its value in the food industry.41 Secondly, from an environmental perspective, the carbon This journal is ª The Royal Society of Chemistry 2011 balance of growing crops for biofuels has been called into question. Production of biofuels from energy intensive agriculture such as ethanol from maize does not have a positive carbon balance42 and land clearance for planting biofuels creates a ‘carbon debt’ from lost carbon in soils and vegetation,43 particularly in the case of tropical deforestation.44 Nonetheless, if land use change is disregarded, some crops in certain countries, such as oil palm in South East Asia, sugar cane in Brazil and sweet sorghum in China perform well on sustainability indicators.45 Estimating competition between biofuels and food production is more complicated than assessing impacts from land use change on biodiversity and carbon. During the 2005–2007 increase in food prices many commentators attributed spiraling costs to diversion of US maize into ethanol production, with Jacques Diouf, FAO director-general, saying ironically at the UN food summit in June 2008 whilst arguing for increased levels of funding for combating hunger ‘‘Nobody understands how $11–12 billiona-year subsidies in 2006 and protective tariff polices have had the effect of diverting 100m tonnes of cereals from human consumption, mostly to satisfy a thirst for fuel for vehicles.’’46 However, at the same meeting the Brazilian President Luiz In acio Lula da Silva attributed food price increases to ‘‘. a combination of factors: soaring oil prices, which affect the cost of fertilizers and freight; climate change; speculation in financial markets; falling world food stocks; growing food consumption in developing countries like China, India, Brazil and several others; and, above all, the maintenance of absurdly protectionist farm policies in rich countries.’’47 Recent analyses suggest that biofuel production is indeed not strongly linked to food price increases.48,49 Despite the confusion, diversion of land and crops into biofuel production has encouraged investment for a switch from first generation biofuels derived directly from food crops into second generation biofuels produced from lignocellulose.50 High reliance of modern society on transport fuels means that a 10% replacement of fossil fuels with first generation biofuels in the US, Canada and the EU would require 30–70% of national crop area.9 However cost remains a significant factor mitigating Energy Environ. Sci., 2011, 4, 261–268 | 265 against widespread introduction of second generation biofuels using dedicated lignocellulosic crops which potentially have comparatively low environmental impacts.51 There are two methods of biofuel production from lignocellulose: biochemical using enzymes to produce ethanol; and thermo-chemical to produce a synthesis gas which can be reformed into a range of long chain carbon fuels. Aviation fuels can only be made from the latter process. Future cost estimates for the biochemical method are 0.8–0.9 UDS/litre gasoline equivalent and for the thermo-chemical method 1.0–1.2 USD/litre gasoline equivalent.52 For these costs to be competitive against fossil fuels the crude oil price would need to be 100– 130 USD per barrel. Stable prices at this level are unlikely because alternatives such as tar sands, of which there are extensive deposits, compete with crude oil at 65 USD per barrel.52 To favour second generation biofuel production over fossil fuels or first generation biofuels there has to be substantial policy support in place.53--55 Important lessons can also be learnt from preventable failures of early attempts such as the Arable Biomass Renewable Energy (ARBRE) in Yorkshire which used gasification technology to produce energy from short-rotation willow fertilized with sewage but which foundered due to changes in commercial strategy of the main company, bankruptcy of the contractor overseeing the project and technical problems with the gasification.56 5. Biofuels, sustainability and regulation in the UK In the UK, as in Germany, multiple sustainability objectives have moved from political rhetoric to statutory instruments and in the case of biofuels they are part of the 2007 Renewable Transport Fuel Obligations (RTFO) Order.57 The RTFO arose out of the 2003 Sustainable Energy Act58 and 2004 Energy Act59 with the aim of helping the UK meet the 5.75% renewable transport fuels target for 2010 created by the 2003 European Biofuels Directive and work towards the 10% target for 2020 in the 2009 European Renewable Energy Directive.60 Transport fuel suppliers obtain certificates from the Renewable Fuels Agency on the basis of sustainability criteria and potentially, if 266 | Energy Environ. Sci., 2011, 4, 261–268 they exceed their targets, can trade their certificates with other suppliers. The sustainability criteria of the RTFO are complex and multi-dimensional involving ‘‘carbon emissions, agriculture, other economic activities, sustainable development, or the environment generally’’ (Article 4). The RTFO has been challenged. The ‘Gallagher Review’61 notes that the RTFO was formulated before indirect effects were established and recommended that ‘‘it would be unwise to proceed with introduction of biofuels in this manner’’ (p. 65). Translating the RTFO criteria into practise is being initially achieved through selecting appropriate existing industry certification schemes for biofuel feedstocks, such as the Round Table on Sustainable Palm.62 This will develop into a tighter system of benchmarking which the Renewable Fuels Agency calls a ‘meta-standard approach to sustainability’. The standards can become quite complex, for example, the Benchmark of the Better Sugarcane Initiative (BSI) Principles and Criteria of November 2009 has five principles, 20 criteria and 46 indicators:63 1 Obey the law (2 criteria); 2 Respect human rights and labour standards (5 criteria, 13 indicators); 3 Manage input, production and processing efficiencies to enhance sustainability (2 criteria, 7 indicators); 4 Actively manage biodiversity and ecosystem services (2 criteria, 8 indicators); 5 Commit to continuous improvement in key areas of their business (9 criteria, 18 indicators). Inevitably the RTFO has imposed additional costs on the transport fuel supply industry, estimated as £240m in capital costs with resource costs being somewhere between £280–6254m for the period 2009–2020 more than fossil fuel costs, the wide range being due to potential fluctuations in commodity prices.64 Incentives can be put in place to counter the additional costs, those proposed by the 2006 EU Strategy for Biofuels24 included: eco-labelling, price differentiation through emission charges and product levies, environmental quality promotion through education, tradable permits, environmental performance bonds, funds and environmental risk assessment in banking procedures, tax exemptions for vehicle fleets and review of the Common Agricultural Policy. In the UK there is a progressive incentive structure based around both pricing and obligation (Fig. 1). Duty on fossil fuels in 2009 in the UK was 56.19 p/litre (unleaded petrol and diesel) whereas that on biodiesel and bioethanol is 36.19p/ litre. With the RTFO certificate scheme in which 15 p per certificate is transferred from companies not meeting their obligations to companies that do, which together with the duty creates a possible incentive of 35 p per litre.64 However, imposing sustainability criteria on biofuel imports may be problematic under current World Trade Agreements as it represents an imposition of the laws of one State on the processes involved in the production of goods in another State.65 The question here is whether the product should be considered separately from the process by which it is produced, in other words can biofuels produced without reference to sustainability criteria be considered a ‘like’ product’ under (WTO) agreements with those which meet the criteria.36 If the products are essentially the same, then they should compete equally in international trade. If there is a trade dispute the procedures can be lengthy. A case brought by Argentina involving import of agricultural biotechnology products into Europe (WTO Dispute DS293) was initiated in May 2003 and resolved in March 2010 with little more than an agreement to establish a bilateral dialogue. Moreover, social sustainability criteria, such as labour conditions, are problematic as international indicators. A Ministerial World Trade Organisation (WTO) meeting in 1996 agreed: ‘‘We reject the use of labour standards for protectionist purposes, and agree that the comparative advantage of countries, particularly lowwage developing countries, must in no way be put into question.’’66 In consequence labour standards cannot be cited as a reason for restricting trade thereby eliminating a key social sustainability criterion. To make environmental and social regulation work effectively for biofuels there needs to be international cooperation over certification on use of land and working practises.67,68 Some of the sustainability issues may be overcome through the introduction of second This journal is ª The Royal Society of Chemistry 2011 Fig. 1 Progression of UK biofuels regulation (from BIS, 2009 p. 1364). generation biofuel feedstocks and new technologies69 but there are still major economic obstacles to surmount due to the higher cost of processing lignocellulose. 6. Conclusions Despite the scientific consensus that acknowledges dangerous anthropogenic interference with the climate, the potential for developing renewable energy sources that can replace fossil fuels has some way to go before being realised. Biofuels are being introduced by incremental policies5 that maintain the status quo as much as possible70 through aiming at multiple policy objectives based on sustainability concepts that require complex criteria to operationalize and so increase costs. In terms of practical implementation, biofuel production costs are reduced by inclusion in combined heat and power plants,71,72 and there are major economies of scale with larger plants reducing operating costs by 15–20%.73 For achieving overall sustainability gains integrating other energy use considerations into policy could make major contributions. For example, reducing car fuel consumption by 30% in Germany would cause greenhouse emission savings greater than that achieved by the biofuel national quota policy.74 But this type of action requires lifestyle changes which, as noted in the introduction, can be politically unpopular. As final remarks we would like to draw attention to the policy contrast between the integrated sustainability approaches applied biofuels and other related sectors such as fossil fuel and agriculture for food. For example the energy and land intensive oil extraction from tar sands in Canada, a major supplier of petroleum products to the USA, has been called ‘The most destructive project on Earth’75 and Canada’s greenhouse gas emissions in 2007 were 26% above 1990 levels instead of being reduced as agreed in the Kyoto Protocol. Fossil fuel extraction industries have also attracted criticism for the human rights records in areas such as the Niger Delta, Chad and Sudan.76–78 Aviation fuel is not taxed and expansion of airports, such as Heathrow in the UK,79 is favoured by governments for economic reasons over both environmental and human rights considerations.80 For agriculture, perhaps the most significant conclusion from the life cycle analyses carried out on different cropping systems for the purpose of biofuel sustainability assessment is the high energy use of intensive maize production. Moreover, concern that biofuel production will increase per capita use of land, particularly in industrial nations needs to be put into the context that altering eating habits could lower individual land use ‘footprints’ for example reducing household food waste and meat consumption in Germany could save up to 700 m2 per capita.74 Application of legal instruments similar to the RTFO meta-standard sustainability criteria to fossil fuels and agricultural products would go a long way to levelling the playing field for biofuels and making real changes to our impact on the environment, but considerations of ‘realpolitik’ mean that this is unlikely to happen. Acknowledgements We are grateful to Dr Rafael Luque for the invitation to submit this paper. Vicky Marin and two anonymous reviewers provided useful and insightful comments. 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