"Commission proposals to examine the contribution of direct and indirect land use change on greenhouse gas emissions from production of biofuels in the developing world are leading nowhere and threaten to undermine the negotiations in the UNFCCC over a global strategy to reduce emissions.
"World Growth does not believe it is possible to draw reliable conclusions on whether, or to what extent, the impacts of direct or indirect land use change associated with biofuel consumption has varied according to the type of feedstock that has been used to produce the biofuel in question, the geographical location of the land that is used differently as a consequence of the biofuel consumption, or how that land was managed prior to the change. This situation is unlikely change in the future. This is clear from submissions to the Commission consultation.
"The EU Strategy undermines the UNFCCC negotiations. The mandate for those negotiations rests with the Climate Change Convention. They specify that each party is to develop an economy-wide strategy to reduce emissions. The EU biofuel policy would require priority be given to those biofuels which are unlikely to be a major source of emissions in the countries concerned. It is anyway their sovereign right to decide their priorities for reducing emissions and not to be dictated to by the EU or anyone else under threat of restriction of trade.
"Any further work on indirect land use change should focus specifically on whether or not science and economics support the idea. Policies cannot be scientifically assessed at this point, and it would be inappropriate, inefficient, and costly to apply it in trade policy. This will disproportionately undermine rural and agricultural development efforts and poverty alleviation programs that are contained within land that has been set aside for agriculture production. This land use criteria, in the case of palm oil, was announced following countries' commitments to conservation of forested land.
"Furthermore, the EU biofuel strategy, according to trade exports, is likely to run afoul of WTO rules. Adding controls on indirect land use would enhance that probability."