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    • Letter to Commissioner Oettinger on the impact of ILUC from biofuels

    We are writing to present a groundbreaking report by the Institute for European Environmental Policy on the anticipated impacts of current EU biofuel policies with respect to indirect land- use change (ILUC).

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    These GHG emissions from ILUC are currently unaccounted in the existing methodologies for calculating GHG emissions from biofuels, presenting a misleading picture of their actual impact. It is critical that the Commission act on its legal obligations.

    The Renewable Energy and Fuel Quality Directives set out clear reporting and proposal obligations on the Commission to address ILUC resulting from EU biofuel policies. The first obligation is to submit a report by 31 December 2010 “reviewing the impact of indirect land-use change on greenhouse gas emissions and addressing ways to minimise that impact.” Anything less than a full report is inadequate.

    The second obligation requires the Commission to determine whether an accompanying proposal is appropriate. The recent IEEP report is the latest addition to a long list of scientific studies pointing out that EU biofuel policies, if left unchanged, will increase GHG emissions from the transport sector. It reaffirms the need for the Commission to submit a meaningful proposal that will address and minimise emissions from ILUC in line with its legal obligations. It is imperative that the proposal is based on the best available scientific evidence and contains a concrete methodology for tackling emissions from ILUC.

    Failure to act will have significant and ongoing implications for our climate system and forests and biodiversity worldwide. Immediate action is required to prevent deforestation, destruction of natural areas, and loss of biodiversity from EU biofuel policies. In addition, any delay by the Commission in complying with its legal obligations will undermine investment certainty and create a domino effect of further delays for completing several related provisions.