IEEP has responded to the UK Government’s Consultation on the sustainability and carbon reporting system under the Road Transport Fuel Obligation, outlining some key concerns.
For biofuels to be a successful, green alternative to traditional transport fuels it is essential that mechanisms be put in place to ensure their sustainable production. These must be robust, reliable and equitable. While we are supportive of the efforts being made under the UK Road Transport Fuel Obligation to develop carbon and sustainability reporting concerns remain and certain aspects must be improved.
IEEP has a long track-record in the analysis of biofuels as a potential contributor to reducing transport’s greenhouse gas emissions. We have, however, consistently highlighted that not all biofuels offer good carbon reductions, and that the land-use changes resulting from large-scale biofuel production could have adverse environmental impacts both in Europe and in developing countries.
For this reason we regard the effective certification of biofuels as an essential component to ensure their sustainability. To this end we have been supportive of the efforts being made under the UK Road Transport Fuel Obligation to develop one of the first systems aimed at ensuring the sustainability of biofuels; IEEP Senior Fellow Malcolm Fergusson is a member of the advisory group assisting the Government in the development of its proposals on carbon and sustainability reporting under the RTFO.
IEEP is passionate that methods for ensuring the sustainability of biofuels are developed and that these are robust, reliable and equitable.
In June 2007 the UK Government launched a consultation outlining its proposals for the setting up of the carbon and sustainability reporting system. While we consider the proposals to be basically sound and pragmatic, we do have concerns regarding some elements of the system and feel certain aspects must be improved. Key points raised in IEEP’s recommendations to the Government include:
- concerns regarding the lack of enforcement in relation to the targets proposed;
- that the proposed approach relies on existing standards and that there may be limited control over their quality and rigour;
- that there should be a system in parallel designed to drive improvements in the level of sustainability achieved;
- the existing system would rely on the sustainability of biofuels on the market and support the use of the least worst of these, it would not act as a gold standard for biofuels sustainability;
- the need for a strong and empowered Administrator;
- concerns regarding the approach to land use change and the focus on idle land;
- the need to monitor potential indirect impacts on land use as well as direct ones;
- that the multiplicity of approaches set out, due to a meta-standards approach, my be confusing and achievements difficult to define;
- the need for a more effective system for overseeing the impacts of the scheme and a clear role for rigorous reporting by the Administrator;
- a system of feedback whereby regular reviews of the system are held and improvements made based on the results of monitoring;
- that lessons should be learnt from recent experiences with setting up novel systems of verification and accreditation eg under the EU Emissions Trading Scheme to improve the quality of these systems and their smooth implementation;
- concerns regarding the approach to by-products and mechanised farming.