The letter was organised by the Union of Concerned Scientists, an American not-for-profit group that has taken positions on indirect land-use change in statements to other bodies. The letter says: ‘Without addressing land-use change, the European Union’s target for renewable energy in transport may fail to develop genuine carbon savings in the real world. It could end up as merely an exercise on paper that promotes widespread deforestation and higher food prices.’
The scientists join a growing list of people and bodies warning the EU that ignoring Iluc could cause the EU’s biofuels target to increase greenhouse gas emissions, not reduce them. The Commission’s position is still that ‘scientific uncertainty’ prevents it from taking Iluc into account, and the scientists’ letter does admit there are uncertainties in estimating the magnitude of indirect land-use emissions from biofuels. ‘But,’ it adds, ‘a policy that implicitly or explicitly assigns a value of zero is clearly not supported by the science. All the studies of land-use change indicate that the emissions related to biofuels expansion are significant and can be quite large.’
In a letter to European Voice, T&E’s biofuels policy officer Nusa Urbancic said: ‘This “scientific uncertainty” is a bit of a stretch. Numerous scientific and public bodies agree that Iluc is real and should be accounted for when calculating total emissions from biofuels – the list could hardly be more venerable. We never took the Commission for a bunch of flat-earthers, but on this issue we are getting the sense of an administration in denial.’
Another organisation to come out in support of accounting for Iluc is a group of bioethanol producers, whose fuels stand to gain an advantage over biodiesel if the EU factors in land-use impacts. In a letter to the energy commissioner Guenther Oettinger and the climate commissioner Connie Hedegaard, the bioethanol lobby group ePure says it will support a policy that ‘differentiates between good and bad biofuels pathways and addresses Iluc directly’.
Urbancic added: ‘This is not just about environmental gains and social justice, it’s also about ensuring investment certainty for the biofuels industry. Doing nothing on Iluc will leave the industry in turmoil because no biofuel producer will be able to plan properly for the future.’