Neither, of course. Actually, the question makes about as much sense as asking “Are people good or evil?”. Unless you have unshakable faith in human nature or, conversely, hold a marked preference for dogs over humans, the only sensible answer is “It depends”. In fact, when it comes to biofuels, sustainability specialists working for the likes of RSB or ISCC have spent countless hours attempting to define what it actually depends ON, in great detail and across many criteria.
Therefore, why has the European Union decided that all crop-based biofuels should be considered equal, in the sense that they are all subject to the same caps and limitations under RED2 (the European Directive steering the growth of renewable energy in the period 2021-30)? Isn’t that in effect the equivalent of putting the whole of humankind under house arrest, on the premise that there is much wickedness in the world? Possibly a reasonable conclusion at cosmic level, but one that would leave the many of us trying to live a decent life, feeling rather hard done by.
Incidentally, I was guilty of an oversimplification just now by stating that all crop biofuels were considered equal. There exists of course in RED2 the much-debated notion of “high iLUC” biofuels, to address the fact that some crops used for biofuels production are linked to deforestation of natural carbon sinks, in particular tropical rainforests of south-east Asia and central/south America. I totally support the need to stop deforestation, and for what it’s worth I am also of the opinion that much harm has come from the massive expansion of palm plantations over the last 20 years, so something HAD to be done. But there again, regulators are attempting to draw a line, attempting to call out what is good and what is bad across the many shades of grey out there.
And who could blame them? A key demand of Industry (and Society at large) is for regulations to be simple. What is simpler than drawing a line, and putting things that look similar into one box? So perhaps we shouldn’t be surprised that all crop biofuels, unless they have been classified as high iLUC, ended up as one category in RED2. But is there another way to think about this? And do we even need to? After all, aren’t there enough renewable transport energies out there, from electricity to green hydrogen to bio-methane? Not to mention the multiple advanced biofuels pathways, from LC ethanol to Fischer-Tropsch diesel and many others, which seem to be getting a strong second wind after the disappointments of the 00’s? Can we not afford to take this simplifying step, and bundle all first-generation biofuels in one wide-ranging but tightly capped block? As far as I can tell, this seems to be the prevailing logic in the Commission.
Actually, I’m not sure we can. Or to put it another way, if we do, we may be foregoing a big opportunity and throwing the proverbial baby out with the bathwater. I have two reasons for saying this.
One is of course timing of carbon savings. Yes, these other technologies are all great and will play a huge role in the fullness of time, but the necessary technology development, infrastructure changes and production investment cycle are capping the pace of their adoption. And as we know, our carbon budget to limit climate change to 2C is time-dependent: The faster we reduce fossil fuel emissions by front-loading their replacement by lower carbon energy, the bigger our budget (or the lower the final temperature increase).
The second argument, and I think the most potent one, is that this battleground is fundamentally about the sustainability of agriculture. How to produce what we need from the land in an optimal way, while maximising the wider ecosystem services and recovering precious ground (no pun intended) for bio-diversity? In this context, an increasingly crucial ecosystem service is the storage of carbon, not just in forests and uncultivated land, but also in the soil through the right agronomy practices. As an example, the “4 per 1000 initiative” aims to grow soil carbon stocks by 0.4% annually, taking CO2 from the atmosphere and creating a whole range of incidental benefits, not least improving food security for communities who depend critically on keeping soils alive. This is too big a prize to ignore, and it can be grasped PROVIDED the incentives exist for farmers to do the right thing and adopt those enlightened agronomy and land management practices.
A regulation which lumps all crop biofuels as one block, caps them to an arbitrary limit, mandates their use on the simplistic basis of volume or energy content, and takes no account of actual emission reductions, does not provide said incentive. In Europe today, few countries – with the notable exception of Germany – are rewarding biofuels based on their specific GHG savings. For our friends across the pond, the German regulation functions in a similar way to an LCFS, allocating Carbon Intensity factors to different types of biofuels and relating their value to the carbon savings that can be claimed versus the fossil fuel (gasoline or diesel) baseline. Do we not have a great opportunity to incentivise best practice in agriculture, and sort the wheat from the chaff (ok, pun intended this time!) when it comes to crop biofuels?
LCFS-type regulations operating across Europe, combined with some clear methodologies to recognise good agronomy, good land management and carbon capture in soil, have the potential to unlock the status quo and lift the better 1st gen biofuels from the quagmire. Most importantly, it has the potential to kick-start a new agricultural revolution, based on environmental science and the holistic delivery of all ecosystem services.
This opinion piece was originally published as part of the “2021 Outlook” in the 1Q edition of Biofuels International magazine.