Official Journal of the European Union

C 77/43

Opinion of the European Economic and Social Committee on the ‘Proposal for a Directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources’

COM(2008) 19 final — 2008/0016 (COD)

(2009/C 77/12)

On 3 March 2008 the Council decided to consult the European Economic and Social Committee, under Articles 175(1) and 95 of the Treaty establishing the European Community, on the

Proposal for a directive of the European Parliament and of the Council on the promotion of the use of energy from renewable sources.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 16 July The rapporteur was Mr Ribbe.

At its 447th plenary session, held on 17 and 18 September 2008 (meeting of 17 September), the European Economic and Social Committee adopted the following opinion by 105 votes to 38 with 10 abstentions.

1.   Conclusion and recommendations


The EESC welcomed the European Commission's 2007 climate protection plans, which this directive is intended to help implement.


The Committee fully endorses the Commission's statement that the proposed development of renewable energies not only makes sense in climate policy terms but also has, or can have, a clear positive impact on security of energy supply, regional and local development opportunities, rural development, export prospects, social cohesion and employment opportunities, especially as concerns small and medium-sized undertakings as well as independent power producers.


The EESC therefore welcomes the draft directive and the renewables target of 20 %. It sees renewable energies not only as a contribution to climate protection but also as correct in strategic energy-policy terms, leading to a higher degree of energy self-sufficiency and thus greater security of supply.


The objective of cutting CO2 by 20 % by 2020, which is to be achieved by means of other directives (1), and the target of 20 % of final energy from renewables, which is dealt with in this draft, are closely correlated and complement each other. They should, however, always be considered independently of each other, particularly as some renewable energies do not have a clearly positive impact on the climate (see point 6 on agrofuels).


As the necessary reorganisation of our energy system will entail heavy investment costs, the Member States need to be allowed a high degree of flexibility to ensure that they can always act in those areas where the greatest impact can be achieved in terms of climate protection and job creation, at the lowest cost.


The EESC wishes to make it clear that it fully supports the expansion of renewables and that it is aware that in the medium to long term a much higher percentage of renewables than the 20 % envisaged for 2020 will be required if the Council's ambitious target (a 60-80 % CO2 emissions reduction and greater energy self-sufficiency) is to be achieved.


The EESC notes that the strategic requirement for the partial substitution of diesel or petrol by agrofuels is one of the least effective and most expensive climate protection measures, and that it represents an extreme misallocation of financial resources. The EESC cannot understand why the most expensive measures are to be promoted politically with the greatest intensity, particularly as a huge number of environmental and social questions, let alone economic ones, remain completely unanswered (see point 6). It therefore opposes the separate 10 % target for agrofuels.


The EU's plan to introduce sustainability criteria for agrofuels is welcome. However, the environmental criteria set out in the draft do not go far enough. Moreover, social questions are not touched on at all, and the draft directive is completely inadequate in this respect (2).

2.   Introduction


The directive will establish binding targets for the development of renewable energies. The aim is a 20 % share of renewable energy sources in final energy consumption in the EU by 2020 and a 10 % binding minimum target for biofuels (3) in transport to be achieved by each Member State (4).


The European 20 % goal is to be achieved by applying individual national targets which are listed in part A of Annex I. The Member States are required to draw up national action plans setting out sectoral targets for electricity, heating/cooling and transport/agrofuels, as well as measures for the achievement of these goals.


The directive is based on the decisions of the spring 2007 European Council on the grounds that the use of regenerative energies can counter climate change. At the same time, however, it states that ‘the renewable energy sector stands out for its ability to (…) exploit local and decentralised energy sources, and stimulate world-class high-tech industries’.


The Commission states that ‘renewable energy sources are largely indigenous, they do not rely on the future availability of conventional sources of energy, and their predominantly decentralised nature makes our economies less vulnerable to volatile energy supply’. Security of supply is then, alongside climate protection and innovation and economic growth, a further important argument used by the Commission.


The Commission argues that: ‘The development of a market for renewable energy sources and technologies also has a clear positive impact on security of energy supply, regional and local development opportunities, rural development, export prospects, social cohesion and employment opportunities, especially as concerns small and medium-sized undertakings as well as independent power producers’.


The directive does not only lay down the quantitative targets referred to above but also, inter alia, addresses the following issues:

how the share of energy from renewable sources (Article 5) is to be calculated, taking account of imports,

guarantees of origin (Articles 6-10),

access to the electricity grid (Article 14),

environmental sustainability criteria for agrofuels and their climate relevance (Article 15 et seq.),

the framework for the national support systems, prevention of distortions of competition.


The new directive replaces Directives 2001/77/EC on the Promotion of the electricity produced from renewable energy source in the internal electricity market, which laid down the existing target of 21 % of total electricity consumption to come from renewable energy sources by 2010, and Directive 2003/30/EC on the Promotion of the use of biofuels or other renewable fuels for transport, under which a 5.75 % share was to be achieved by 2010.

3.   General comments on the overarching and climate-policy objectives of the directive


The European Council reiterated in 2007 ‘that absolute emission reduction commitments are the backbone of a global carbon market and that developed countries should continue to take the lead by committing to collectively reducing their emissions of greenhouse gases in the order of 30 % by 2020 compared to 1990 with a view to collectively reducing their emissions by 60 to 80 % by 2050 compared to 1990’.


The draft directive under consideration is part of the implementation of this decision. The EESC has welcomed the climate decisions of the European Council and has stressed that energy economies and efficiency must enjoy the highest priority. There is no alternative to a massive development of renewable energy. Not only is it a requirement for climate protection; growing shortages of fossil resources will in themselves make it necessary in the medium to long term. The rapid increases in the prices of fossil energies currently being experienced will help ensure that many renewable energies become financially viable sooner.


The EESC is very glad that, in the explanatory memorandum, the Commission does not only address the climate aspects but also attaches high importance to the questions of security of supply and employment. The importance of decentralised energy supply structures for the regional economy and rural areas is, for example, repeatedly stressed (points 2.4 and 2.5). The Committee shares this view. But it also feels it essential to consider the individual strategies for renewables in a more differentiated way than hitherto, taking these aspects into account.


The EESC shares the Commission's view that a leading role for Europe in the development and implementation of renewable energies will not only be good for climate policy but also hold out the prospect of making Europe a more competitive location for business. The draft directive is a clear energy, environmental and industrial policy signal — also a signal to the international community in the run-up to the international climate negotiations.


The actual arrangements for sharing the burden, i.e. the individual national contributions to the European target of an overall 20 % CO2 reduction, are set out in the Proposal for a Decision of the European Parliament and of the Council on the effort of Member States to reduce their greenhouse gas emissions to meet the Community's greenhouse gas emission reduction commitments up to 2020 (COM(2008) 17 final) and the Proposal for a Directive of the European Parliament and of the Council amending Directive 2003/87/EC so as to improve and extend the greenhouse gas emission allowance trading system of the Community (COM(2008) 16 final).


The EESC considers a target of 20 % renewable energy by 2020 to be appropriate in political and strategic terms as well as technically and economically feasible. It is a tangible sign of the transition to a post-fossil energy policy. The Committee also believes that the individual national goals can be achieved, particularly as the Member States are offered flexible options (purchase, participation in projects etc). What is clear is that reorganisation of the energy system will not be free, nor can it be done without structural change. Investment is not only needed in plants for generating electricity from renewable energy sources but also in energy storage technologies and capacities to even out fluctuations in power generation resulting from insufficient wind strength or solar radiation, as well as in the development of international power lines in the EU. We will not achieve the planned objectives by concentrating exclusively on power generation.


Germany for example promotes power generation from renewable energies via its electricity feed law, and the country's proportion of green electricity is currently 15 %. The additional costs of higher feed premiums to be borne by electricity users amount to around EUR 3.5 bn per year. This does not, however, allow for the economic benefit in terms of new jobs, the prevention of environmental damage and additional tax revenues.


In order to keep the cost of meeting the target to a minimum, it is provided in the directive that individual targets can also be met by supporting measures for the development of renewable energy in other Member States. The import of electricity from guaranteed renewable sources is also allowed. The EESC considers this to be a good idea in principle. However, it supports the calls by some Member States for this trade to be subject to authorisation, in order to prevent measures to promote renewable energy financed by one Member State (5) from being used to achieve cost savings in another Member State.

4.   Restriction of flexibility in the development of renewable energies


The EESC considers the Commission's approach of laying down an overall target for the three sectors in which renewable energies will play a part (electricity, heating/cooling and transport) rather than three separate targets to be correct. In this way Member States are given the freedom to decide how they will combine measures in the three individual sectors in such a way that the overall national targets can be achieved.


This flexibility is, however, massively compromised, by the fact that a separate, binding goal is to be set, applicable to only one of these three sectors, i.e. the replacement of diesel fuel and petrol in the transport sector.

5.   The special role of agrofuels in the draft directive


The Commission assigns a special role to agrofuels.


Many studies published in recent months on the subject of agrofuels have pointed out that biomass, unlike solar energy, is a limited resource and will inevitably find itself in competition with foodstuff production or the maintenance of biodiversity. Just how massive this competition will be is at present still a matter of debate. Before policy intervenes there is therefore a need for a very precise strategic analysis of which form of renewable energy can most usefully be deployed, and in which area. This will require very precise impact assessments.


In a November 2007 recommendation on the use of biomass for energy production, the scientific advisory council of the German Federal Agriculture Ministry expressed the view that in the long term solar and wind energy will play the dominant role in renewable energies, in part because they have considerably higher potential than biomass. The council cites three reasons for this:


Solar energy can use land which would not otherwise be used for the production of biomass for foodstuffs; much higher energy yields can be achieved for a given area than through the use of bioenergy.


The worldwide shortage of arable land will mean that, as oil prices rise, so will the price of bioenergy; as a result all agricultural prices will be driven up. This will in turn mean higher raw material costs for bioenergy plants, whereas higher oil, coal and gas prices simply make solar energy more profitable.


If arable land is in short supply, large-scale expansion of bioenergy will necessarily mean that land not previously used for arable farming will be brought into use (ploughing up of grassland, deforestation) or that land will be farmed more intensively. This will cause increased CO2 and N2O emissions, with the result that the expansion of bioenergy production on agricultural land will in the end be detrimental to climate protection.


When existing natural resources are scarce, while at the switch to new, regenerative and as far as possible decentralised energy supply structures will require relatively heavy investment, the principle to keep in mind must be that of concentrating financial resources on the most efficient climate protection strategies.


At EU level, however, some of the existing forms of bioenergy, which in some cases benefit from state support, such as agrofuels (as well as the production of biogas from maize) go hand-in-hand with very high CO2 prevention costs (6) (EUR 150 to over 300 per tonne CO2).


Other types of bioenergy, e.g. biogas production from liquid manure (ideally combined with heat production), combined heat and power production from wood chips (wood residues, short rotation farming) and the combustion of wood chips in existing large power plants have CO2 prevention costs of only EUR 50 per tonne CO2  (7).


The European Commission's Joint Research Centre concludes that in terms of GHG reduction per ha of land it is substantially more efficient to use the biomass to generate electricity than to produce liquid agrofuels (8). The efficiency of modern biomass burners is nearly as high as fossil fuel burners, so in heating and electricity production, 1MJ biomass replaces about 0.95 MJ fossil fuel. Transforming biomass into liquid fuel for transport is typically only 30-40 % efficient in energy terms. 1 MJ biomass replaces only around 0.35-0.45MJ crude oil in the transport sector.


A CO2 prevention figure of 3 t CO2/ha can be achieved with the production of agrofuels, and more than 12 t CO2/ha with the bioenergy products described (in point 4.6).


Against this background the EESC wonders why the Commission wishes to lay down an explicit 10 % target for agrofuels. It points out that the Spring European Council said that this objective should be achieved ‘cost efficiently’, and that three conditions had to be met, namely that:

production was sustainable,

second-generation agrofuels were commercially available, and

Directive 98/70/EC relating to the quality of petrol and diesel fuels was amended.


Where sustainability is concerned, there are more questions than answers (see also point 5), and second-generation agrofuels are still not available. Thus, at least two out of the three criteria laid down by the European Council have not been met, which has not, however, prevented the Commission from planning to include the 10 % target in the directive.


It justifies this, inter alia, with the arguments that the transport sector is the economic sector showing the fastest rise in greenhouse gas emissions and that agrofuels ‘are currently more expensive to produce than other forms of renewable energy, which might mean that they would hardly be developed without a specific requirement’.


The EESC cannot endorse this line of argument:


It is true that greenhouse gas emissions are getting out of control in the transport sector. But, in the EESC's view, more stringent exhaust gas limit values and a 10 % additive for petrol and diesel will not solve the problem, nor even compensate for the environmental impact of the growth expected in the transport sector over the next few years.


The EESC has pointed out on a number of occasions that this problem should be tackled with a policy of traffic prevention and a change in the modal split in favour of more climate-friendly modes of transport like railways, local public transport and shipping.


In technological terms the EESC believes that the future of private cars lies not with the internal combustion engine but with electric traction powered by renewable energies. To power a VW Golf over 10 000 km with agrodiesel would, according to an estimate by EMPA (9), require the entire annual crop from 2 062 m2 of arable land planted with oilseed rape. The same energy could, on the other hand, be obtained from the annual output of solar cells covering 37 m2, around one sixtieth of the area.


The strategic requirement for the substitution of diesel or petrol by agrofuels is one of the least effective and most expensive climate protection measures, and it represents an extreme misallocation of financial resources. The EESC cannot understand why the most expensive measures are being promoted politically with the greatest intensity, particularly as a huge number of environmental and social questions, let alone economic ones, remain completely unanswered.


The Committee does not therefore agree with the Commission's statement that ‘increased use of biofuels for transport is one of the most effective tools’ for meeting the challenges.


Considering that the Commission is aiming to authorise agrofuels if they offer at least a 35 % cut in greenhouse gas emissions — by comparison with fuels derived from fossil oils — the 10 % target will — assuming unchanged traffic volumes — mean a cut in greenhouse gas emissions from motorised transport of only 3.5 %. As transport accounts for around a quarter of total greenhouse gas emissions, we are speaking here of a potential 1 % cut in total emissions! This is a value which is out of all proportion to the cost and the associated risks.


Even if agrofuels for transport were seen as a way of usefully harnessing biomass, the accent should be on absolute efficiency. Annex VII to the directive makes it clear, however, that the conversion of biomass to esters or ethanol is not the right approach. Any (industrial) molecular change is associated with energy input and thus energy loss. It would make more sense to use the biomass directly, without industrial/chemical change.


The fact that some tractor manufacturers are now offering engines which run on pure plant oil shows that this is technically possible.


Annex VII demonstrates that the greatest greenhouse gas emission savings can be achieved using this technology; pure rape seed oil offers standard greenhouse gas emission savings of 55 %, agrodiesel from rape only 36 %, ethanol from wheat 0 %, compared with fuels derived from fossil oil. The EESC cannot understand why the Commission does not make it clear that this path offers the greatest benefits, particularly as this is the way in which decentralised energy supply structures — and thus jobs in agriculture and rural areas — can be most easily developed.


The EESC considers that a good strategy would be to promote the use of pure plant oils, which can, for example, be obtained from environment-friendly mixed cultivation, in agriculture itself and also, for example, in local transport and waterborne transport (10). In this way farmers could be directly involved in the development of regional energy cycles and would benefit directly from this. Under the agrofuel strategy, on the other hand, they would become producers of the cheapest possible raw materials for the oil industry, if indeed raw materials grown in Europe were used at all.

6.   Comments on the security of supply argument


The Commission believes that the bulk of the biomass needed for agrofuels will be produced in regions with more suitable climates outside the EU. Replacing imports of crude oil with imports of biomass does not, however, mean reducing import dependency but merely diversifying it.


It cannot seriously be the objective of a new EU energy policy to replace one form of dependency with another.


Rather, the priority approach should be actually to place decentralised, locally or regionally available sources at the heart of the new renewable energy strategy. Bioenergies could and must play a role here, but not the one envisaged by the agrofuel strategy.

7.   Employment


The Commission writes that ‘renewable energy is a close substitute for conventional energy and is supplied through the same infrastructure and logistic systems’. The EESC considers this statement to be crucially misleading: renewable energies from decentralised structures are diametrically opposed to conventional energies, which tend to be produced in centrally organised, large-scale plants.


An agrofuels strategy based on energy imports and diesel and petrol additives uses the traditional, i.e. centrally organised, structures of global oil companies. It thus cements their central production and distribution structures, which is entirely in the industry's interests. It creates hardly any new jobs in Europe, however (11).


If, on the other hand, the accent is placed on the energy-efficient use of, for example, wood chips for heat and power production, or pure plant oils grown regionally, or the use of biogas in vehicles or in areas without mains gas, or decentralised solar technologies etc, new, regionally organised forms of manufacturing and distribution can be developed which will open up major potential for new jobs.


In the case of solar thermal energy and the decentralised use of photovoltaic technology (energy) consumers produce the bulk of their energy needs themselves, which is also proof that energy supply based on renewable energies is organised quite differently from the existing energy supply structure.


Other measures, such as greater energy-efficiency and energy savings, could create hundreds of thousands of jobs in small and medium-sized businesses — in the construction phase alone. Insulation of buildings, the installation of solar and wind energy equipment and the construction of biogas plants are examples of this. The role of policy-making is to ensure that this potential is actually tapped; the agrofuels strategy envisaged by the directive is not the most efficient way.


This means that, in relation to the question of jobs too, a very precise and much more differentiated analysis of the various renewable energies is urgently needed. Renewable energies can indeed promote and support regional economic structures; they can, however, also help to perpetuate large-scale, centralised structures.


The same also applies to the countries in which biomass for agrofuels is grown. In a March 2008 discussion paper entitled Development-policy position on agrofuels, the German federal ministry responsible for development aid comes to the conclusion that, in terms of the economic, environmental and social development of developing countries, a strategy of export-orientated mass production of biomass, as a reaction to sharply increased demand from industrialised countries, is associated with high risks and will not create jobs, whereas biomass for decentralised energy supply, with small farms involved in production, gets a generally positive assessment.

8.   Comments on the sustainability criteria


The EESC is glad that the Commission also plans to introduce sustainability criteria for the production of agrofuels. This is a major step forward, but the Committee considers the proposal submitted to be completely inadequate.


The Commission itself has repeatedly stressed the importance for sustainability policy of a balance between the economic, environmental and social pillars. And yet this total exclusion of social issues from the criteria alone leads the EESC to the conclusion that the draft directive does not implement a well thought-out sustainability strategy or sustainability criteria for agrofuels. In this respect the draft needs to be completely revised.


The EESC considers it important in this context that, because of indirect changes to land use, effective environmental and social criteria be drawn up not only for agrofuels but for all imported agricultural products, including feed.


Moreover, it is illusory to believe that, for example, rainforests or peat bogs can be protected against use for agrofuel production by setting a cut-off date (in this case January 2008). This would require a functioning land registry system as well as a functioning administrative and monitoring system. Experience shows that these do not exist in most emerging and developing countries.


The EESC considers the criteria, listed in Article 15(3) and (4), for preserving biodiversity and preventing land with a high carbon content from being used to be inadequate. Far more areas than just those listed in paragraphs 3(a) to (c) are important for the maintenance of biodiversity. The same is true of paragraphs 4(a) and (b) in relation to carbon sinks.


In Annex VII part B the Commission lists ‘estimated typical and default values for future biofuels that are not or in negligible quantities on the market’. The EESC believes that values based on hard data should be used rather than estimates.

Brussels, 17 September 2008.

The President

of the European Economic and Social Committee


(1)  See point 3.5.

(2)  The EESC pointed out the need for environmental and social sustainability criteria for agrofuels in its opinions on Progress in the use of biofuels, TEN/286 — CESE 1449/2007, OJ C 44, 16.2.2008, p. 34 and Reducing greenhouse gas emissions/Road transport, NAT/354 — CESE 1454/2007.

(3)  The draft directive uses the term ‘biofuels’. In various opinions, however, the EESC has drawn attention to many environmental problems caused by these ‘bio’ fuels. The prefix ‘bio’ suggests an environment-friendly product, and in this opinion the EESC therefore instead uses the more neutral term ‘agrofuel’.

(4)  The draft directive states that: ‘(…) it is proposed that each Member State shall achieve at least a 10 % share of renewable energy (primarily biofuels) in the transport sector by 2020’.

(5)  Or that State's consumers.

(6)  CO2 prevention costs here mean CO2 equivalents.

(7)  Source: ‘Nutzung von Biomasse zur Energiegewinnung — Empfehlungen an die Politik’, agricultural policy advisory council of the German Federal Ministry for Food, Agriculture and Consumer Protection, published in November 2007.

(8)  European Commission, Joint Research Centre, ‘Biofuels in the European Context: Facts, Uncertainties and Recommendations’, 2008,


(9)  EMPA is a research institute for material sciences and technology. It is part of the Swiss Technical University of Zürich (ETH). Source: Ökobilanz von Energieprodukten: Ökologische Bewertung von Biotreibstoffen. Schlussbericht, April 2007. Commissioned by the Federal Offices for Energy, the Environment and Agriculture; Empa, Department of Technology and Society, St. Gallen: R. Zah, H. Böni, M. Gauch, R. Hischier, M. Lehmann, P. Wäger;

Download: http://www.news-service.admin.ch/NSBSubscriber/message/attachments/8514.pdf.

(10)  See also opinion TEN/211 — CESE 1502/2005, Renewable energy sources of 15.12.2005 (rapporteur: Ms Sirkeinen), point 3.3.1.

(11)  See also the study carried out by the European Commission's Joint Research Centre, Biofuels in the European Context: Facts, Uncertainties and Recommendations, 2008,