The term “Highly sustainable crop based biofuels” (HSCBBs) sounds environmentally friendly. It sounds like the kind of low-carbon biofuel that avoids the food vs. fuel debate. But unfortunately, the term now means perpetuating the biofuel business as usual in the European Union (EU).
The European Commission’s proposal for a recast of the Renewable Energy Directive to 2030 (RED II), released in late 2016, was big news in the fuels world because it directs the gradual phase out of food-based biofuels. This proposal introduced the world’s first alternative fuels target that cannot be met with food feedstocks. According to this proposal, food-based biofuels can still contribute to the EU’s overall renewable energy targets, but that contribution is capped at 7% in 2021, declining to 3.8% in 2030. The Commission is serious about transitioning to advanced alternative fuel pathways that don’t impact land-use change, food supply or food prices.
The European Parliament will soon vote on amendments to the Commission’s RED II proposal, and, along with the European Council, must approve a final position before the directive can be finalized. Several Members of Parliament have introduced amendments defining a new category of fuel: HSCBBs that are exempt from the 3.8% cap on food-based biofuels. The problem is that the HSCBB category includes basically all types of food-based biofuels that are eligible to count towards the overall renewable energy target.
These proposed amendments define HSCBBs as biofuels that:
- “ are produced from cereals, other starch-rich crops, sugars and oil crops;
-  save at least 60% [greenhouse gas] GHG emissions compared to fossil fuels according to the methodology in article 28(1);
-  generate high value protein, other animal feed or cellulosic by-products;
-  are produced from feedstocks obtained in accordance with the requirements and standards under the provisions referred to in Article 93 of Regulation (EU) No 1306/2013 of the European Parliament and of the Council”
None of these four conditions meaningfully restrict the eligibility of any food-based biofuels to be exempt from the cap. The first criterion identifies all food feedstocks that are currently used for biofuel. The second only marginally improves the GHG requirements for existing food-based biofuel facilities. According to the current Renewable Energy Directive (RED), which applies in the year 2020, and to the Commission’s RED II proposal, facilities that began operation before 2015 must achieve a 50% GHG reduction compared to the fossil fuel baseline, and all facilities beginning operation in 2015 or after must meet either a 60% or 70% GHG reduction threshold. The second criterion thus tightens the GHG requirements for the oldest food-based biofuel facilities, but does not impact biofuels produced at newer plants. It’s important to note that these GHG thresholds do not take into account emissions from indirect land use change (ILUC), which can be very high for some feedstocks. The third condition, biofuels must generate high value by-products, describes all major food-based pathways. The extraction of vegetable oil from rapeseed, soybeans, and sunflowers produces high-protein meal, ethanol production from maize, wheat and other cereals generates distillers, grains, sugar extraction from sugar beet produces pulp, and palm oil production generates palm fatty acid distillate (PFAD) – all of these products are used in animal feed. The term “cellulosic by-product” doubtlessly refers to bagasse produced from processing sugarcane, which can then be combusted for electricity and heat generation. The fourth criterion requires cross-compliance with the environmental protection rules in the Common Agricultural Program – rules that most EU agricultural producers must comply with already in order to receive farm subsidies.
These amendments thus render the 3.8% cap almost entirely meaningless, as there are few examples of biofuels that would qualify towards the overall renewable energy target, but fail to qualify as a HSCBB under this definition. This maneuver is greenwashing because it effectively deletes a major sustainability requirement, while posing as a sustainability safeguard.
It’s important to remember why the food-based biofuel cap was introduced in the first place. The 7% cap on the contribution of food-based biofuels to the overall 2021 renewable energy target corresponds to a 7% cap on the contribution of these fuels to the 2020 transport target in the current RED. The 2020 cap was put in place by the ILUC Directive as a compromise measure to partially mitigate the negative land use change impacts of biofuels without actually accounting for ILUC emissions. The 2020 cap reduces the negative impacts of the RED transport target, but even with it in place, the current RED is expected to result in greater GHG emissions than simply burning petroleum. The Commission’s proposal lowers the cap from 7% to 3.8% in 2030 in order to further mitigate ILUC emissions.
The figure below illustrates the climate benefits of the cap. The first column shows the average GHG emissions from biofuel if there was no cap on food-based biofuels at all. The second column includes a 7% food-based cap and additional incentives for advanced biofuels, required by the ILUC Directive. The third column represents a scenario similar to the Commission’s RED II proposal, with a 7% cap on food-based biofuels, phasing down to 3.9% in 2030. The fourth column shows the same scenario, but with a faster ramp down in food-based biodiesel in comparison to ethanol. The land use change values used in this graph were taken from the recent GLOBIOM study performed for the Commission and its complementary scenarios. Direct emissions were taken from the typical values in the current RED or the RED II proposal, or reflect 60% GHG savings compared to the updated fossil fuel comparator (94 gCO2e/MJ), whichever is lowest for each feedstock, and reflect the feedstock mix in the GLOBIOM study. What the figure shows us is that the 3.8% cap in the Commission’s proposal is vitally important in limiting ILUC emissions and ensuring that the RED II does not worsen the climate in comparison to petroleum.
The food-based biofuel cap is in the Commission’s RED II proposal for a reason, and effectively removing it through the exception for HSCCBs can hardly be called “sustainable.”