The Commission proposals on the Farm to Fork and Biodiversity Strategies have been released without any impact assessment – on the agriculture production, on prices, on the trade balance, on food security.

It is worth quickly reminding which their key targets were, to be achieved by 2030:

• 10% agricultural land set-aside
• -20% chemical fertilizers
• -50% chemical pesticides
• 25% share of organic production
• Plantation of 3bn trees
• -50% antimicrobials for livestock

You do not need to be an expert to figure out that the impact of such drastic reductions in just a decade has to be huge.

The Commission was criticised by farmer’s organisations and by EP leading MEPs for the lack of an impact assessment – a normal, obligatory procedural step on other Commission proposals.

The Commission has responded that the impact assessment would still be carried out, but no precise indications on timing and specifics were given. Some Commission officials seemed to say that the impact assessment could be fractioned, which would make it impossible to have a clear view on the real impact; whilst others seemed to be more open to revise the targets if the impact assessment shows how negative the consequences would be.

Meanwhile in its impact assessment of the 2030 Climate Plan, the Commission refers to a Modelling Study conducted to evaluate the impact of the Farm to Fork and Biodiversity Strategies on agriculture, but gives no further details on the results, nor is the study available to the public.

The only impact assessment published so far was the recent ERS/USDA “Economic and Food Security Impacts of Agricultural Input Reduction Under the European Union Green Deal’s Farm to Fork and Biodiversity Strategies”.

Without even taking into account the impact of achieving a 25% share of organic production and planting 3bn trees, the ERS/USDA impact assessment finds that the Commission proposals would reduce EU agriculture production by 12%, increase prices by 17%, reduce exports by 20%, increase imports by 2%, shrink gross farm income by 16%, and increase the annual per capita food cost in the EU by $ 153.

If that were to be the case that would spell disaster for our farmers, wipe out our food security, compromise the food security of many developing countries in particular in Africa, and weigh on the pockets of consumers.

It is high time that the Commission publishes an Impact Assessment on its proposals. It must be comprehensive and independent from political pressure. We have the right to know what we should expect, and the Commission has the duty to come clean on the results and act accordingly.

The European Commission recently published its Renewable Energy Progress Report[1] in which it highlights the positive contribution of domestically sourced biofuels in reducing GHG emissions.

The Commission assessment clearly asserts the sustainability of biofuels produced from EU feedstock, invalidating its concerns relating to land use or food security and demonstrating them to be wholly unfounded in the context of EU climate action. By whatever means of analysis applied, it is unequivocally evident that EU biofuels come with effectively no risk of adverse land use change, i.e. they are effectively zero-ILUC.

Quoting from the Report:

“In recent years, no correlation has been observed between food prices and biofuel demand.”” Most Member States did not observe any impacts on prices due to increased bioenergy demand within their countries.”

“Several Member States point out that all agricultural production is regulated with respect to environmental impacts and therefore consider that no more impacts should be expected from biofuel crop production than from other crop production.”

It couldn’t be clearer: earlier predictions of Commission policy makers for EU sourced biofuels in 2020, pointing to higher food prices or adverse land and environmental impacts, were plainly incorrect and should be revised.

These predictions had no factual basis, yet they have served very well the interests of the still growing fossil fuel industry, the source of all GHG emissions in the transport sector; and the interests of imported biofuels, whose linkage to deforestation is not adequately checked.

The Commission goes further in the Report in pointing out the benefits of EU sourced biofuels:

“It is estimated that the biofuels industry employed 208,000 people in 2018, being the third largest renewable energy job creator after wind energy and solid biomass (314,000 and 387,000).”

“According to information reported by Member States, total emission savings from the use of renewables in transport in the EU amounted to 45.6 Mt CO2eq in 2018.””… given the overwhelming share of biofuels in the RES-T (89%), it is reasonable to assume that the emission savings result largely from the use of biofuels.”

Thus far the Commission recognises the importance of EU biofuels to the economy, and to reducing GHG emissions. Thus far we agree with their findings.

Unfortunately however, the Commission loses sight of these findings in the rest of the report and in recent communications on aviation biofuels, in the Taxonomy secondary regulations and the Green Deal: it persists with its intent to limit the contribution of conventional EU biofuels.

The negative impact of trying to minimize the use of EU biofuels is twofold: it makes it more difficult to achieve the targets of transport decarbonisation, as advanced biofuels are often more expensive and in shorter supply; and it increases deforestation, as it promotes imports of palm oil to produce biofuels, and of soybeans that would otherwise be replaced by the high protein by-products generated by EU biofuels.

At no time was there a scientific or evidential basis for the Commission policy to phase-out or cap EU crop biofuels and the positive performance of these renewables over the last decade has illustrated that the policy was wrong.

The Green Energy Platform and its peers across Europe will be key partners in the achievement of the Green Deal objectives.   To be successful that partnership must rest on a foundation of truth and a true understanding of the workings of renewable energy systems.

We call on the Commission to come forward now with scientific and evidential justification of its continued opposition to EU crop biofuels in the framing of the Green Deal policy programme, or to set about correcting its position.

Green Energy Platform is a group of companies, mostly family owned, that make biofuels – and other bioproducts – with materials sourced from European farms. We make biodiesel, bioethanol and biogas- in each case both conventional and advanced. We care about the climate. We care about Europe- its economy and its environment. We are proud of what we do. We have contributed to climate action and economic development over the past decade. We are transparent. We believe in accountability.

[1] https://ec.europa.eu/energy/sites/ener/files/renewable_energy_progress_report_com_2020_952.pdf

In a Fact-Sheet published this week “Working with Parliament and Council to make the CAP reform fit for the European Green Deal” the Commission tries to re-write the history of the latest CAP reform.

The Commission criticises the European Parliament and Council positions because they ask for flexibility in the implementation of eco-schemes and that according to the Commission could lower resources for climate and environmental benefit.

The Commission seems to forget that it proposed total flexibility for the implementation of the eco-schemes, without any ring-fencing of resources, contrary to the positions of the EP and Council. In fact what the Commission proposed could lead to fewer resources for climate and environment, and in any case make it impossible to attain EU wide objectives.

The Commission also criticises the co-legislators for watering down the performance framework of the reformed CAP. The Commission seems to forget that it did not propose a single performance indicator to be monitored, all the targets proposed were no more than statistical outputs.

We could go on giving more examples, as the Commission left to Member States the design of the national and regional policies, including basic conditionality requirements like the definition of rotation.

The fact is that the impact of the Commission proposal on the climate and environment was a black box.

The Commission seems to attempt to re-write the history to find a new legitimacy to impose its own Green Deal objectives and align the CAP with the Farm to Fork and Biodiversity Strategies. The reasoning of the Commission is that the Green Deal objectives were agreed by all, but unfortunately “certain aspects of the positions of the legislator do not match with the shared objective that the new CAP delivers on the Green deal objectives”, and therefore the Commission is entitled to “verify coherence of the Strategic Plans with the Green Deal targets”.

We see in the Commission position two serious issues of legitimacy. Firstly, only the Green Deal overall objectives of reducing GHG emissions are shared at this stage. The Commission objectives in the Farm to Fork and Biodiversity Strategies were not agreed. There isn’t even a legislative proposal. Thus the Commission lacks institutional legitimacy to try to impose them through the approval of the CAP Strategic Plans.

The Commission also lacks the policy legitimacy to impose those targets (10% agricultural land set-aside, -20% chemical fertilizers,-50% chemical pesticides, 25% share of organic production, plantation of 3bn trees, -50% antimicrobials for livestock), as the Commission did not make a prior Impact Assessment of these far-reaching proposals, nor did it publish studies on their impact so far.

According to the sole Impact Assessment published, by the USDA, it would be a disaster for the agriculture sector, for EU consumers and food security (it would reduce EU agriculture production by 12%, increase prices by 17%, reduce exports by 20%, increase imports by 2%, shrink gross farm income by 16%, and increase the annual per capita food cost in the EU by $ 153).

In this context, it is high time that the Commission publishes an Impact Assessment independent from political pressure, and without delay releases the evaluation study on the impact of the Farm to Fork and Biodiversity strategies on agriculture, as it referred to in its impact assessment of the 2030 Climate plan.