Europe's take on ILUC

By Robert Vierhout | August 10, 2009
European regulators have caught indirect land use change (ILUC) fever. A recently adopted EU law states that the European Commission must complete a review of the impact of ILUC on greenhouse gas (GHG) emissions and address ways to minimize that impact by Dec. 31, 2010. Interestingly, the law does not mention biofuels at all. Some might argue that ILUC occurs because of biofuels, so mentioning it explicitly is not necessary. However, one could also argue that by not mentioning biofuels, the legislator acknowledges that the causes of LUC (direct and indirect) and deforestation are multiple, complex and interlinked. To single out one human activity, such as the production of biofuels, is an oversimplification of reality. And this is the bone of contention: Is it possible to agree on a macro-economic model that can deliver proof as to what extent ILUC is caused by biofuels?

Several European Commission services Transport and Energy, Environment, Agriculture, Trade and the Joint Research Centre have different views on the role of biofuels and their effect on ILUC. Four of the groups decided to do modelling work either by themselves or through external researchers. The results will be presented this month for critique.

In advance of the modelling results, the Commission has called upon stakeholders and EU Member States to reflect on a document that contains, as they call it, "possible elements of a policy approach on ILUC." In its document, the Commission presented seven policy elements. Five elements are biofuel-specific and are to be considered as part of policy measures if modeling shows a "satisfactory understanding" of ILUC emissions and how they vary by biofuel has been reached.

This approach is somewhat messy. How can one discuss policy options if we do not know yet if a satisfactory understanding is possible at all? And what is meant by "satisfactory understanding?" Is it the understanding of the politician that often equals "better safe than sorry" or "minimize risk rather than being accurate" or is it the understanding of the scientist that "analytical work should be verifiable, rigorous and robust at the same time and should stand the test of falsification?"

Anticipating the verdict, European bioethanol fuel producers have put forth eight principles that we believe should be respected when accounting for GHG emissions from ILUC:

1. The data and methodology must be fully transparent and publicly available so that the results can be replicated and methodology peer reviewed.

2. Accounting must be done on the basis of marginal land use changes caused by increased biofuel use, according to crop and fuel type.

3. The "biofuel scenarios" and the "reference scenario" must be a set of equal amounts of equivalent products.

4. Account must be taken of changes in trade flows and biomass supply across regions to identify where ILUC is likely to occur.

5. Land area changes as a result of biofuel coproducts must be fully accounted for by applying a substitution approach, according to coproduct use.

6. Account must be taken of changes in biomass yield growth with increased demand growth for food, feed and fuel.

7. Account must be taken of the target biofuel trajectory with time.

8. Account must be taken of the type of land where ILUC is likely to occur and the carbon stocks associated with that land.

And I believe a 9th principle should be added:

9. The prevention of LUC arising from the oil supply chain must be fully accounted for by applying a substitution approach.

We are still at the beginning of a debate that will take a year or more if European regulators and politicians decide to follow what seems to be the U.S. approach take the time to be accurate on ILUC.

Robert Vierhout is the secretary-general of eBIO, the European Bioethanol Fuel Association. Reach him at