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March 11, 2018

Re: Position on agrofuels in EU post 2020

Dear Sir or Madam,

We, several Czech and Slovak non-profit organizations, feel to be obliged to officially comment on the forthcoming changes to vegetable fuel use legislation after 2020, outlined in the revision of the Renewable Energy Directive (RED). The European Commission’s RED II proposal of November 2016 contains a plan to abandon the original transport target, a significant reduction of agrofuels[1] (1st generation or conventional vegetable fuels) and their replacement by 2nd generation or advanced vegetable fuels.

Although the overwhelming majority of the scientific community and non-profit conservation organizations have pointed out for years the serious environmental and social impacts of some agrofuels production, especially in the case of fuels containing tropical oils such as palm oil, whose combustion can produce up to 3 times higher amount of greenhouse gas emissions compared to conventional fossil fuels (GLOBIOM study), differences must be taken into account also in the case of conventional vegetable fuels.

Individual crops used for the production of agrofuels differ in their environmental and social impacts as well as their yield and efficiency. In the case of agrofuels, it is absolutely necessary to strive for the most economical and most responsible way of producing such crops. Ideally, in organic (BIO) mode, even at the expense of lower yields, to minimize negative impacts on biodiversity, soil and water, which are often degraded when intensive crops are grown. This condition includes also the local origin of the crops. Agrodiesel from soybeans and palm oil or sugarcane ethanol, i. e. crops grown often in former areas of forests or other valuable biotopes of Indonesia, Amazon and Equatorial Africa, are unacceptable to us. In addition to the significant negative impacts on the environment, biodiversity and communities at the place of production of these crops, there is a problem of high greenhouse gas emissions associated with growing these crops as well as with long-distance transport of their products.

At the same time, we would like to express certain doubts about the self-sustainability of 2nd generation vegetable fuels, as there are some risks in their case as well. In the case of the introduction of mandatory quotas, and hence an increase in demand for plant materials for use as second generation vegetable fuels, such as residual biomass of agricultural crops currently serving as valuable natural fertilizer on agricultural land, there is likely to be a significant increase in the need for industrially-made fertilizers. Another example can be residual biomass after forest extraction, which plays an important role in forest ecosystems – this role could be lost if the biomass was to be used as a 2nd generation vegetable fuel.

We therefore call for the need for a closer look at the possible benefits of some types of agrofuels. Some conventional vegetable fuel pathways offer well documented advantages over continuing using oil as a transport fuel. European produced crop based ethanol, such as produced from corn, wheat or sugarbeet, brings significant climate benefits by saving GHG emissions compared to petrol even after indirect land use change (ILUC) is accounted for, lowers EU’s animal feed protein deficit hence alleviating the pressure on American ecosystems by replacing imported soy, creates rural jobs, and signs are it has not aggravated pressures on the environment in the past decade when conventional vegetable fuel production took off in Europe.

We therefore believe, it is necessary to take into account the best possible mix of vegetable fuels of both generations, both ecologically and economically. We ask for a detailed assessment of all the positive and negative characteristics of different types of sources used for the production of both generations of vegetable fuels in the EU and to distinguish between crops and other vegetable fuel sources on the basis of their scientifically substantiated parameters in all legislative measures. We believe we should support those vegetable fuel sources that are the most appropriate and most advantageous combination of multiple criteria – at least in terms of minimizing greenhouse gas emissions, environmental friendliness and relative economic ease. By rejecting all 1st generation vegetable fuels or by adopting all types of 2nd generation vegetable fuels without taking into account the individual differences between them, the European Union could move further away from achieving the goals of a greenhouse gas reduction strategy and unwittingly cause a serious threat to the environment.

Furthermore, the EU’s priority should be to move as quickly as possible to electromobility and to promote energy-saving measures.


Yours faithfully,

Mgr. Kateřina Holubová

Speaker & Fundraiser

+420 777 153 133


The Czech Republic
Czech Union for Nature Conservation (ČSOP) JARO Jaroměř
ČSOP Morava
CSOP Arion Olomouc
Environmental Service Organization Praha
ČSOP Pardubice
ČSOP Podještědí
ČSOP Smiřice










[1] Herewith preference is given to the use of the term agrofuels, as the label biofuels may be ambiguous as potentially implying bio or organic production. Having said this, in our terminology agrofuels refer to conventional vegetable fuels.