This is the conclusion of Wetlands International after thorough analysis of the Renewable Energy Directive that was adopted by the European Parliament on the 17th of December 2008. The Directive was heavily critisised by a wide range of NGOs because the obligation for EU memberstates to use at least 10% biofuels of all fuel use by 2020. This would inevitably lead to millions of hectares more intensive biofuel production, with enormous environmental and social consequences. Wetlands International underscribed these concerns and joined the European Agrofuels Coalition to push for a greener directive.
Wetlands International is concerned about the impacts on people and biodiversity of biofuel production (see pages on this) due to the excessive use and pollution of water, the conversion of wetland areas into plantations, as well as the huge greenhouse gas emissions caused by the conversion of peatlands, in particular the peatswamp forests in Southeast Asia. Nevertheless, this global NGO welcomes the criteria for excluding wetlands as production areas for biofuels that will be supported by the incentives of this directive.
Main implications for wetland areas:
Exclusion of peat as ‘slow renewable’
Despite attempts by the Finnish government, peat is not regarded as a renewable biomass and cannot be used to produce biofuels or as biomass. Peat formation takes hundreds if not thousands of years to form and therefore, should not be labelled as ‘renewable’from any point of view .
Excluding carbon rich wetlands and peatlands
In article 17.4, the Directive completely excludes the conversion of all areas that were carbon rich wetlands in January 2008 into areas without a wetland status (areas that are saturated with water for at least a part of the year). In addition, the Directive also excludes peatlands from production of renewables unless it can be proven that these areas were drained prior to 2008 (article 17.5).
Article 17.5 is confusing
The exclusion of carbon rich wetlands from conversion will have a very positive impact on our work to sustain many crucial wetland areas and their values for people and nature. Many of the logged and drained peatswamp areas in Indonesia and Malaysia still qualify as wetlands under article 17.4. However, application of the article 17.5 on drained peatlands is unclear in this context. Many peatswamps, both in Europe and in Southeast Asia have been drained already to some extent. Confusion could arise around the question on what is drained and what is not and what qualifies as a wetland.
Weak exclusion of critical ecosystems
The Directive does not exclude biofuels that will be produced on converted crucial areas for the survival of endangered species or ecosystems like wetlands with the Ramsar status, Emerald sites (Bern Convention) or areas on the IUCN list. The Directive only creates the option for the European Commission to do so at a later stage. Wetlands International considers this policy to protect the current most valuable wetlands to be inadequate. Wetlands International will advocate for a rapid decision of the Commission to exclude all biofuels from supportive policies if coming from (formerly) critical and valuable natural areas.
Good criteria on GHG saving, weak implementation
According to article 17.2, bioliquids should have at least 35% less greenhouse gas emissions compared to fossil fuels. Implementation of this article would totally exclude all biofuels from for instance converted and drained peatswamps. This would apply for at least 25% of all Asian palm oil plantations. Nevertheless, the methodology to determine the greenhouse gas emissions from bioliquids is very weak. Default values to be used if the origin of the feedstock is unknown ignore emissions from the loss of organic peat soils. There is also no transparency on the information that biofuel producers provide on the origin of the feedstocks.
The European Parliament demanded the Commission, before adopting the resolution, to develop methodologies to account for carbon stocks and peat emissions (Consideration 69 and 70). Implementation of these considerations is crucial for an adequate greenhouse gas calculation.
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