Based upon this evidence the RFA have concluded that there is a significant risk
the current policy will not deliver its intended objective of significant net GHG emissions
savings. Accordingly, the RFA believe it would be unwise to proceed with
the introduction of biofuels in the manner, or at the pace, presently envisaged.

A moratorium is likely to lead to a stagnant, unprofitable industry that is less prepared and able to invest in new technologies or source feedstock that does not cause land-use change.

An EU-wide moratorium is also likely to lead to a further increase in fossil fuel prices (due to the additional demand created from the removal of biofuels) with knock-on impacts for both food prices and the poor. A moratorium on biofuels could also discourage much needed investment in agriculture that is required to address increasing global food demands and to
encourage the development of a more productive agricultural system. This could
have particular benefits for the poor in the medium and long term.

EU should not allow Member States to supply more than 5.75% (by energy) of biofuels; and allow more cautious Member States to supply to 4% biofuels (by energy).

A target range of 5% to 8% (including 1-2% from advanced technologies) with a higher target triggered only if milestones in 2013/14 are met.

In general, GHG savings from advanced technologies producing ethanol are about
90% compared to petrol whilst syndiesel can generate savings in excess of 100%
through co-generation of renewable energy (excluding emissions from land-use
change).

These new biofuels are unlikely to see significant market penetration until 2018.

A specific obligation on transport fuel suppliers to supply fuels produced from
wastes, residues and feedstock grown on marginal land will encourage investment
in these technologies and provide a mechanism to encourage production on
marginal land.

The use of agricultural or forest residues as biofuel feedstock will also have an
opportunity cost since, in some instances, the GHG savings for heat and power
may be better than for biofuels. A similar issue was recently identified in the use
of tallow for biodiesel in an AEAT report43 for the Department for Transport. This
highlighted that the use of a limited feedstock, in this case tallow, for biodiesel
production can lead, indirectly, to higher emissions in another sector (in this case,
the oleochemical and meat rendering industries).

The EU has suggested that by 2020 advanced fuels could make a contribution
of up to 30% towards the proposed 10% target. Given the current stage of
development of technologies this appears optimistic.

Based upon current evidence a market share of 1-2% by energy of transport fuels by 2020 seems feasible. A higher target market penetration may be possible but will require
technology to develop, and new feedstock supplies to be identified, more rapidly
than currently envisaged. Further detailed work is needed before firm targets
should be set.

There should be a specific obligation on transport fuel suppliers to supply
biofuels achieving a high level of GHG saving (possibly greater than 75%) from:
- Appropriate wastes and residues;
- Feedstock grown on marginal land; and
- Other technologies and feedstocks that avoid indirect land change (for
example algae).

The EU needs to determine how increasing targets for heat, power and
renewable transport fuels compete for wastes and residues and how this
competition should be managed.

Some futures traders argue since they never take delivery of the crop they cannot affect street prices but this ignores the affects on short term market volatility, a feature of current high prices. In these circumstances speculative price rises lead to positive feedback loop in which price4s rise far above the underlying value of the commodity creating an economic bubble that eventually  bursts and prices crash... George Soros, the renowned financial speculator and investor is quoted as saying " you have a generalised commodity bubble due to commodities having become an asset class that institutions use to an increasing extent."

We cannot afford to abandon biofuels as part of a low carbon transport future. Equally, we cannot continue producing biofuels which are ultimately more environmentally damaging than the fossil fuels they seek to replace.

"The world needs to start again and plan properly. If biofuels are to play a part in a renewable energy strategy we must ensure that they benefit the environment and that poor farmers and consumers are not harmed by their use."