Submission on the Sustainable Biofuels Bill

To the Local Government and Environment Select Committee, 29 October 2009

Available in the column on the right are both the Commissioner's written submission and summary of her oral presentation on the Sustainable Biofuels Bill.

The notes from the Commissioner's oral presentation follow on from the written submission, but cover slightly different ground.

Written submission - Introduction

Biofuels for transport can and should play a significant role in New Zealand’s energy future.

In April 2008, I recommended to this committee that the Biofuel Bill 2007 not proceed. That bill was intended to establish a biofuel sales obligation, under which fuel companies were to ensure that a small percentage of biofuel was mixed in with their conventional fuels. The obligation was clearly meant to assist the development of a biofuel industry in New Zealand. But there was nothing in that bill to prevent fuel companies meeting the obligation by importing ‘bad’ biofuels from the developing world, produced at the expense of food production or rainforests. Subsequently, sustainability criteria for biofuels were incorporated into that bill, it was enacted, then repealed, and now the sustainability criteria are incorporated in the current Sustainable Biofuels Bill 2009.

The distinction between biofuels produced in New Zealand and those imported from other countries still seems to me to be extremely important. I struggle to see how the sustainability criteria can be applied in exactly the same way to both domestic and imported biofuel, and my major recommendations address this. At the same time, I am aware that New Zealand has a commitment to free trade, and I am not advocating protectionism.

In this submission I discuss the three “principles of sustainable biofuels” in the Bill – less greenhouse gas emissions, not competing with food production, and protecting biodiversity and land with high conservation value. I then question whether importing biofuels can ever make good sense. Finally I comment on the issue of transport fuel consumption.