 I work in the Renewable and Sustainable Energy Division of the Department of Communications, Energy Natural Resources with responsibility for renewable transport and renewable heat. Both areas remain to the topic we're discussing today. As was my presentation, I'll briefly rehearse the policy context of the Directive or the proposed Directive. I suppose to paraphrase Julius Caesar, I suppose I come to expose the Directive not to praise it or endorse it. And I'll give you an update on the discussions held today at Council Working Party and where I see it going next. So as everybody here will be familiar with the 2020 Climate Energy Targets and the two directives relevant to that at the moment that we're discussing are the Renewable Energy Directives which ascribes Ireland a 16% target from renewable sources broken down by 10% for legal transport or legal target for transport in common with all other member states. We'll also meet that through 40% renewable electricity principally wind and then 12% heat. And the Fuel Quality Directive also requires us to achieve a 6% reduction in life cycle greenhouse gas emissions by 2020 in comparison to 2010. The Renewable Energy Directives does not require us to use biofuels to meet the 10% target but if we do it sets out a number of sustainability criteria such as prohibition on using biofuels or counting biofuels towards that target that have come from certain types of categories of land. And that biofuel must also achieve greenhouse gas savings over the life cycle. The reality is that biofuels are going to play a significant role in Ireland and most of the member states meeting the 10% target and indeed will have a significant role beyond 2020 and towards 2050 but with a post 2020 would anticipate a far greater proportion of biofuels second generation biofuels or advanced biofuels and very very little biofuels source from crops. And since the directive the burden on biofuels has increased or is expected to increase due largely I think to a slower than anticipated uptake in electric vehicles both here and throughout Europe but again it would anticipate by 2050 they would have about 60% of the market in Ireland in any event. I suppose I've mentioned this before about the sustainability criteria but the one missing element of the sustainability criteria is the indirect land use change. It's mentioned in directive but not provided for and likewise in our national legislation sustainability criteria are transposed into Irish legislation but not so accommodating indirect land use change. Both directives required a report from the commission by 2010 and that report has been provided. The I suppose just briefly about indirect land use change this was the theory behind it is that the increased demand for biofuels in Europe displaces agricultural activity to land that was previously not used for agriculture and and releases greenhouse gases that were previously in a carbon sink or and indeed methane sink. The IFPRI study in 2011 presented the commission estimated that 70% of the direct emissions savings from that could be achieved from biofuels would be would be negated where I look to be taken into account and it's obviously a very serious issue but indeed it's a global issue and in fact it's probably bigger than biofuels itself it's it comes down to land use and land use change and agricultural policy and food policy so it in many ways it's far bigger than biofuels and addressing the biofuel issue is probably just a step a small step in in that direction. It also the issue of eye look is hampered to some extent that it can't be accurately measured directly sorry and relies on modeling and so obviously it's subject to the weaknesses of modeling and depending on the assumptions and the framework underpinning doubts those modeling. This is from the impact assessment that accompanied the directive and did the commission in coming to its proposal considered five different policy options ranging from doing nothing which would result in 22% greenhouse gas emissions but indirect land use change emissions of 48 million tons and the second option considered was going immediately to a 60% minimum greenhouse gas emissions circuit and that would automatically rule out soybean rape seed and in the absence of methane it capture palm oil and it also assumed that model or assessment assumed a high uptake of electric vehicles and a high uptake of double counted biofuels this would result in 56% greenhouse gas emissions and a 70% reduction in eye look to about 14 million tons. The third option was looking at increased intensification of agriculture and cultivation of land in third countries and it required country level and project level intervention and so the principle underpinning that there would no additional land would be set aside for biofuel production and that was not possible to model because it needs a global framework in order to implement. The fourth option was to include the indirect land use change and emissions in the sustainability criteria this would have the benefit of reducing greenhouse gas emissions by 70% and reducing emissions by 85% or 80% to 8 million tons. The technological limits on bioethanol and the ability to blend those high levels of ethanol meant that this was this was ruled out for the time being as well as the difficulty I referred to earlier in relation to modelling. I suppose the compromise solution of the was option E and combined with options B and D or elements of options B and D and that would be to limit the contribution that certain food based biofuels could contribute to national targets and that would is estimated to say 44% in greenhouse gas emissions and 20 million tons in islet that's roughly half what the do nothing proposal would envisage. The stated aims of the proposal are to cap at 5% towards the 10% target and important to note that any biofuels that used in the generation of heat and electricity would also be taken from that 5% so it's not that 5% of in transport alone. To improve the greenhouse gas performance of new installations from now until 2020 by requiring 6% for new installations and encourage the uptake of next generation biofuels and production between by offering multiple counting we'll come back to that later and improve reporting of emissions due to indirect land use change and I suppose it's a reporting of indirect land use change and not accounting for and also critical and not to be overlooked is to protect the investments that made today and in the pipeline for biofuel in biofuel production facilities within the European Union and probably it's been the this file is progressed during our presidency through an ad hoc working group of environment and and and energy and I suppose it's it's co-chaired and and it will be discussed next at the energy council later this month and again in the Environment Council in March and there are further working party meetings scheduled we've already had one read through of a complete read through of a short but very difficult directive and there as you can imagine there are a number of very complicated some irreconcilable at the moment and differences are very difficult to to surmount and number of states are still arriving at national positions and taking into account environmental agricultural industrial and energy and concerns and there's also the concerns about balancing investments and jobs and job creation in the European Union and achieving the very very real environmental concerns so the views across the whole spectrum and from those who believe the directive doesn't go far enough and to those who think it goes too far and so another issue that of concern is the impact of the 5% cap will have on achieving the 10% target and the cost of achieving that and whether or not it is feasible to do so in the current economic circumstances facing the facing the European Union there's also concerns have been heard that the 5% cap has not been transposed or it's not reflected in the fuel quality directive the commission has asserted that that that is because the range of options open to achieving the 6% saving in the fuel quality directive go beyond renewable energy and include improved efficiencies and and flaring technologies multiple counting has has again elicited a spectrum of opinions ranging from disagreement as to what should be included indeed whether or not there should be a positive list or just a description there's concerns about the impact multiple counting will have on national targets and in that regard for example where where a member states succeed in developing sufficient for quadruple counted biofuels to meet the 5% the remaining 5% one could achieve the the 10% target with 6.25% percent in in energy terms and that 3 that deficit of 3.5 3.75% would would would rest with the heating and cooling sectors as well as the electricity there would also be a knock on impact upon the real greenhouse gas savings and that's obviously a real concern across the spectrum at the moment possibly for different reasons there's also the issue with fraud and and because of multiple counting and there would be a real incentive to um so it's labeled something as it as it is not um what topic let's suppose at the moment and there is also issues regarding impacts on agriculture and other member states arguing that there's no i-lock factors in their in their countries and then I suppose fundamentally as well a number of member states have have very serious concerns that the i-lock is not taken into account for sustainability and it's merely reporting at this stage complexity and diversity of views is reflected in the emerging views in the European Parliament from the ITRI committee or the industry and research energy committee um probably taking what could be perceived as a more pragmatic view um saying that they've got concerns regarding the target and the impact the target would have on investment and jobs uh to the environment committee um believing that the proposal doesn't go far enough and that uh the the i-lock should be a factor in in sustainability criteria the committees are going to vote on this in the summer and meaning that um the Irish presidency will not be engaging with with the in any kind of uh formal sense with the with the European Parliament um and that discussion is is like to start during the Lithuanian presidency so as the next step will be that we will have to agree um some sort of revised text that is agreeable to um to the council um and that this will be um referred into Lithuanian presidency to to continue discussions at council I don't see this being resolved uh given the complexity and the divergence of views uh before year end thank you very good thank