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The European Union´s (EU) Renewable Energy Directive (RED) continues to be the focus of much debate over the validity of biofuel sustainability. The debate is driven in part by ongoing concerns of transparency and regional variations of emissions from feedstock cultivation and processing. In a working paper, Pehnelt and Vietze (2012) undertook a general analysis of rapeseed biodiesel greenhouse gas (GHG) savings. In light of the recent effort to decentralize assessments to regional (i.e. Member State) authorities to assess the sustainability of biofuel feedstocks, we have done the same for three Member States, incorporating the comments and critique we received on our latest working paper (Pehnelt and Vietze 2012). Using publicly available cultivation and production figures from Germany (the largest producer and consumer of rapeseed biodiesel), Poland and Romania, we analyse the greenhouse gas (GHG) emissions savings of rapeseed biodiesel which we then compare to the values of GHG savings identified in the RED. Under average conditions and conservative assumptions on N2O emissions, German rapeseed biodiesel meets the GHG savings requirements of 35 percent in the RED. However, in years with unfavourable weather conditions and lower yields, German rapeseed biodiesel may fail to reach the 35 percent threshold even with efficient production technologies in the subsequent steps of the supply chain. Taking into account higher N2O emissions due to fertilizer input as suggested by some researchers, German rapeseed biodiesel clearly fails to fulfil the 35 percent criterion required by the RED. Meanwhile, in no instance Polish or Romanian rapeseed biodiesel meet the RED's 35% GHG savings threshold. The assessment of the sustainability of rapeseed biodiesel heavily depends on the very production conditions and assumptions regarding the N2O field emissions. As a matter of fact, not every liter of rapeseed biodiesel produced in the EU is sustainable in the sense of RED. Therefore, the use of standard values (e.g. default values) in order to categorize rapeseed biodiesel - or any other biofuel - as sustainable or not is not justifiable. With renewable energy strategies proliferating throughout the world, the validity of technical criteria has become increasingly critical to the success of these strategies - particularly the fiercely debated RED. The application of technical criteria remains inconsistent, and in the case of the RED, resulting in unreliable assessments of biofuel feedstocks and heated debates over the authority of these assessments.

During the last years, the renewable energy strategy of the European Union (EU) and the proposed policies and regulations, namely the Renewable Energy Directive (RED), have been heavily discussed among scientific circles and various interest groups. The sustainability of different biofuels and their contribution to the reduction of greenhouse gas (GHG) emissions and the whole renewable strategy has become one of the most controversial issues. RED requires that the greenhouse gas emissions associated with production and use of biofuels are at least 35% lower than those associated with the production and use of conventional fuels to be classified as sustainable and therefore eligible for the mandatory blending scheme applied within the EU. In a recent working paper, we analyze the GHG emissions savings potential of rapeseed biodiesel. For this purpose, we ran a life cycle assessment of rapeseed biodiesel using the same basic methodology and background data contained in RED by considering the whole production chain from cultivation of the feedstock up to use of the biofuels. Unlike other studies, we refer only to publicly available and published data in our calculations. In order to ensure full transparency - again contrary to the vast majority of other studies - we provide a detailed documentation of all data. We follow a rather conservative approach by using average values and assuming common conditions along the supply chain in our scenarios. In most of the scenarios, rapeseed biodiesel does not reach the GHG emissions saving values using the formula contained in RED. Neither the RED typical value for rapeseed oil (45%) nor even the lower default value (38%) can be supported by the analysis. Furthermore, most of the scenarios indicate that rapeseed biodiesel does not reach the 35% threshold required by the EU Directive for being considered as sustainable biofuel. In the standard scenario, we calculate a GHG emissions saving value of not even 30% which is not only well below the GHG emissions saving values (default and typical) that can be found in RED but also far below the 35% threshold. To summarize, we are not able to reproduce the GHG emissions saving values published in the annex of RED. Therefore, the GHG emissions saving values of rapeseed biodiesel stated by the EU are more than questionable. Given these striking differences as well as the lack of transparency in the EU's calculations, we assume that the EU seems to prefer politically achieved typical and default values regarding rapeseed biodiesel over scientifically proven ones.

On 05 December 2010, the Renewable Energy Directive (RED) came into force in the EU. Member States are still working to fully transpose the Directive into national law and establish a framework for achieving their legally binding greenhouse gas (GHG) emission reductions. However, governments got off to a slow start as debate continues on the validity of the directives foundations including the default values used to measure the sustainability of biofuels. Only sustainable biofuels can be counted towards Member State targets. This, as a matter of principle, makes sense with respect to the very aim of renewable energy policies. On the other hand, the vague and distortive formulation and values regarding what is to be classified as sustainable have negatively impacted the perception of the underlying scientific base and methodologies as well as the reliability in the European biofuels sector. This uncertainty and the ongoing controversial debates are affecting investment and progress in the biofuel sector not just in Europe but all over the world. Producers of soybeans in the US, sugarcane in Brazil and palm oil in Malaysia and Indonesia as well as European importers and end-users of these products have all been sharply critical of the default values, citing significant variations in calculations that undermine the credibility of the values contained in the Directive. Given the remarkable difference between the calculation of carbon reduction performance of palm oil based biofuel by the EU and a range of scientific studies which we documented in an earlier paper (Pehnelt and Vietze 2009), we are re-calculating GHG emissions saving potentials for palm oil biodiesel in order to further assess the carbon footprint of palm oil to overcome the lack of transparency in existing publications on the issue and EU regulations governing the biofuel feed-stocks. The aim of this paper is to calculate realistic and transparent scenario based CO2-emission values for the GHG emission savings of palm oil fuel compared with fossil fuel. Using the calculation scheme proposed by the Renewable Energy Directive (RED), we derive a more realistic overall default value for palm oil diesel by using current input and output data of biofuel production (e.g. in South-East Asia) and documenting every single step in detail. We calculate different scenarios in which reliable data on the production conditions (and the regarding emission values during the production chain) of palm oil diesel are used. Our conservative calculations based on the Joint Research Centre's (JEC 2011) background data and current publications on palm oil production result in GHG emissions saving potentials of palm oil based biodiesel fairly above the 35% threshold. We cannot reproduce the EU's GHG saving values for palm oil. Rather, our results confirm the higher values obtained by other studies mentioned in our last paper (Pehnelt and Vietze 2009) and elsewhere in this study. Our results indicate default values for the GHG emission savings potential of palm oil biodiesel not only way beyond the 19 percent default value published in RED but also beyond the 35 percent threshold. Our findings conclude that the more accurate default value for palm oil feedstock for electricity generation to be 52%, and for transportation biodiesel between 38.5% and 41%, depending on the fossil fuel comparator. Our results confirm the findings by other studies and challenge the official default values published in RED. As indicated by lawsuits filed by environmental NGOs against the Commission for greater transparency related to the assessment of biofuels, the process has been severely lacking in full disclosure of metrics used to achieve the values contained in the Renewable Energy Directive. As a result, the reliability of the Directive to support the EU's low-carbon ambitions is being undermined, exposing the EU and Commission to charges of trade discrimination and limiting the ability of Member States to achieve their legally binding GHG emission reductions. This analysis demonstrates that a full review of the values contained in the Directive should be undertaken and the values revised to ensure their accuracy, and raises questions as to the method that the values were originally established. Were outside parties consulted, including the industries directly affected by the assessments in the Directive? Were these values peer reviewed? In light of grievances expressed by producers throughout the world, including US soybean growers, Brazilian sugarcane farmers, and Malaysian and Indonesian palm growers, ensuring the Directive does not discriminate against imports is critical to the long-term efforts in the EU to reduce GHG emissions.