A position paper of CZ Biom to the promotion of the liquid biofuel

This document briefly refers to the 4 questions asked in public consultation “Biofuel issues in the new legislation on the promotion of renewable energy”. In general, always is necessary to distinguish between kinds of biofuels. There is unwritten rule to use word “biofuels” for liquid biofuels only. We suggest differentiating in principle:

• Solid biofuels
• Liquid biofuels
• Gaseous biofuels

There are several reasons to assume that more effective ways to use biomass exist than its transformation to liquid biofuels. For example, biogas production is significantly more effective and biogas is usable for electricity and heat generation, as transport fuel or for direct delivery to natural gas distribution system.

1. How should a biofuel sustainability system be designed?

Because the liquid biofuels are being used in an unsustainable way, they can not be part of the sustainability system; at first it is necessary to increase the efficiency in the traffic system - primarily by enforcing low consumption engines and in general the POL consumption has to be cut down by for example logistic measures; liquid biofuels contribute to the solution of environmental problems at the least out of all kinds of biomass utilization, however the highest attention is paid to this topic. The main effort should lead to transformation of the ineffective and contra productive direct subsidies like set aside (grasslands), C-credit etc.

2. How should overall effects on land use be monitored?

The impact of intensive biofuel crop production (grain, rape) may be catastrophic. The organic substances are not returned to the land, the soil is being exhausted, the soil erosion becomes a problem. Furthermore, the major part of the benefits (profits) from the biofuels production goes to refineries and to tradesmen, agriculture regains significantly lower part of the benefits (for example the tradesmen have, after the rules for the so called carbon credit had been published (ca 45 €/ha), notified sinking of purchase price of Rape seeds by 8 €/ton The whole procedure does not take in consideration sustainability of the biological process. In developing countries are the biofuels obtained at the price of virgin forest destruction; the system of biofuels support should be significantly supported by consequently controlled system of certifications, how has the biofuel been obtained (certificate of sustainability - for example analogy of FSC in area of forest biomass).

3. How should the use of second-generation biofuels be encouraged?

The support should be aimed predominantly on research. In area of practical implementation should not the support mechanisms differ from those that are already established. The support should be conducted only within the condition of system sustainability, which is the assurance of the complete life cycle of production and utilization of 2G biofuels. The support should be ever derived from the criteria of energy, economical and environmental sustainability. We recommend withdrawing from direct payment and considering the kind of biofuels, for which the support is aimed to: liquid, solid, gaseous.

4. What further action is needed to make it possible to achieve a 10% (liquid) biofuel share?

The major point for reaching the 10% proportion of biofuels is the total decrease of POL consumption. This will then automatically cause the decrease of negative impacts of biofuel use. At the same time, biofuels with origin which assure the highest utilization efficiency should be used, e.g. products of bio-refineries, where ethanol makes de facto a bi-product. The limit should be set for utilization of Rape, which has, if grown in large area of arable land, a negative impact on soil quality, biodiversity and brings more chemicals into agriculture.

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