Context In November 2016, the European Commission published a proposal for a recast of the Renewable Energy Directive (RED) to set new rules for the use of biofuels in Europe for the period 2021-2030. These new rules will replace the 2009 RED and the 2015 ‘ ILUC directive’, both running until 2020. The European Council, the European Parliament and the Commission embarked in negotiations and finally agreed on the new biofuels rules in June 2018. While taking a step in the right direction by freezing the amount of crop biofuels in the EU after 2020, the EU still doesn’t properly take into account their Indirect Land Use Change (ILUC) emissions and impacts. This means that almost all types of biofuels can be used in the EU, no matter what their ILUC impacts are. In the case of high-ILUC biofuels, these will be fully phased-out in the law, but only in 2030. What is ILUC? The production of biofuels can indirectly cause additional deforestation and land conversion. When existing agricultural land is turned over to biofuel production, agriculture has to expand elsewhere to meet the existing (and ever-growing) demand for crops for food and feed. This expansion happens at the expense of forests, grasslands, peatlands, wetlands, and other carbon-rich ecosystems. This results in substantial increases in greenhouse gas (GHG) emissions from the soil and removed vegetation (e.g. deforestation). An accurate measure of the sustainability of biofuels must account for ILUC. Since the very first RED, many scientific reports were already indicating that ILUC, due to increased biofuel production, has a high potential to outweigh any GHG benefits from the use of biofuels. Since the laws were passed, scientific evidence has accumulated further. This is a compilation of the findings of a number of major reports on biofuels that examine the issue of ILUC and GHG emissions calculations for biofuels. Drawing from a large amount of scientific evidence, it shows that accounting for ILUC in the emissions calculations of biofuels is appropriate. Already back in 2011, over 200 scientists wrote to the European Commission calling for policies to take account of indirect land use change: "Without addressing land use change, the European Union's target for renewable energy in transport may fail to deliver 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.” EU-funded studies ECOFYS, IIASA and E4tech “Biofuel policies aim to mitigate climate change, but high emissions could compromise biofuels’ mitigation potential.” “There has been an important debate on whether or not LUC emission factors should be used in biofuel policy. Our results show that LUC emissions are likely to be substantial, but some inherent uncertainty cannot be avoided in the estimation of such emissions and many parameters and assumptions influence the results. (...) However, our work also identifies some clear chains of effects and highlights impact patterns that can vary significantly between feedstocks.” Valin, H. (2015): The land use change impact of biofuels consumed in the EU - Quantification of area and greenhouse gas impactshttps://ec.europa.eu/energy/sites/ener/files/documents/Final%20Report_GLOBIOM_publication.pdf “Our analysis confirms that emissions from the policy are significant, although the feedstock mix can play an important role in the overall results.”https://ec.europa.eu/energy/sites/ener/files/documents/globiom_complimentary_2016_published.pdf International Food Policy Research Institute (IFPRI) “Simulations for EU biofuels consumption above 5.6% of road transport fuels show that ILUC emissions can rapidly increase and erode the environmental sustainability of biofuels.” Al-Riffai, P. et al (2010): Global Trade and Environmental Impact Study of the EU Biofuels Mandate. IFPRI study for DG TRADEhttp://www.ifpri.org/sites/default/files/publications/biofuelsreportec.pdf “Globally, the additional biofuels mandate leads to an increase in cropland area by 1.73 million hectares without trade liberalization and by 1.87 million hectares with trade liberalization. The most affected regions are Latin America (primarily Brazil), CIS, and Sub Saharan Africa, while the cropland extension remains under 6 percent in the EU regardless of the trade policy scenario.” “Overall land use emissions for the entire EU biofuels additional mandate eliminate more than two-thirds of the direct emission savings when we apply the direct savings coefficients of improved production technology expected in 2020.” Laborde, D. (2011): Assessing the Land Use Change Consequences of European Biofuel Policieshttp://www.ifpri.org/sites/default/files/publications/biofuelsreportec2011.pdf Joint Research Center (JRC) "The experts unanimously agreed that, even when uncertainties are high, there is strong evidence that the ILUC effect is significant and that this effect is crop-specific. The sustainability criteria in the Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) limit direct land use change (LUC) but they are ineffective to avoid ILUC, and therefore additional policy measures are necessary.” Edwards, J. et al. (2011): Critical issues in estimating ILUC emissionshttp://publications.jrc.ec.europa.eu/repository/handle/111111111/22908 "Indirect land use change could potentially release enough greenhouse gas to negate the savings from conventional EU biofuels.” De Santi, G. et al (ed.) (2008): Biofuels in the European Context: Facts and Uncertainties. JRC, European Commissionhttp://ec.europa.eu/dgs/jrc/downloads/jrc_biofuels_report.pdf “Using more (conventional) biofuels in the EU, even if they are produced from EU crops, will increase the overall world demand for crops. If not managed properly, it could displace arable production onto land used for other purposes, both inside and outside the EU, and could lead to extra GHG emissions”. Blujdea, V. et al. (2010): Biofuels: A new methodology to estimate GHG emissions from global land use changehttp://publications.jrc.ec.europa.eu/repository/handle/111111111/15307 “Some people may view ILUC as a secondary effect of biofuel production, but it is really a critical component of answering the question of whether diverting the photosynthetic capacity of land to biofuels from its present use results in greenhouse gas reductions or not.” Edwards, R. et al (2010): Indirect Land Use Change from increased biofuels demand. JRC, European Commissionhttp://re.jrc.ec.europa.eu/bf-tp/download/ILUC_modelling_comparison.pdf “Legislators need to understand how ILUC differs between biofuels from different feedstocks and regions. In fact, if an ILUC adder is used in legislation, we need to know this quantitatively for all biofuels/feedstocks.” Brandao, M. et al. (2010): The effects of increased demand for biofuel feedstocks on the world agricultural markets and areashttp://publications.jrc.ec.europa.eu/repository/bitstream/111111111/16193/1/en24464_iluc%20workshop.pdf European Environment Agency (EEA) “Further expansion of bioenergy production may cause direct adverse effects on the environment and indirect effects due to displacement effects (changes and shifts in land-use, e.g. from grassland to arable land). These direct and indirect effects may undermine an important goal society is trying to achieve with the use of bioenergy — reducing greenhouse gas emissions — and jeopardise the achievement of other environmental goals, such as the protection of biodiversity and water resources.” “This matters as indirect land-use change, in particular deforestation, affects the overall greenhouse balance of bioenergy production (Fargione et al., 2008; MNP, 2008). Deforestation and associated land-use change were responsible for about 17% of global greenhouse gas emissions in 2004 (IPCC, 2007). In fact, deforestation is a more important factor at the global level than emissions from transport (Stern, 2006).” “Future revisions of the EEA 2006 modelling work should therefore address potential indirect effects of EU bioenergy production and consumption, in particular on land use.” EEA Technical Report (2008): Maximising the environmental benefits of Europe's bioenergy potential. European Environment Agencywww.eea.europa.eu/publications/technical_report_2008_10/at_download/file “Critically, indirect land-use change (ILUC) is not currently factored into the sustainability criteria and GHG assessment within the RED (EC, 2009b). This has the potential to substantially undermine the life-cycle effectiveness of biofuels” “A further concern is the long-term competition for a limited biomass/land resource across a range of alternatives, with impacts on both cost and sustainability.” EEA (2011): Laying the foundations of greener transporthttp://www.eea.europa.eu/publications/foundations-for-greener-transport/at_download/file AEA Group “The most important message from the modelling steps are that direct and indirect land use changes play a very important role for assessing GHG emission reductions with a significant impact for the ex-post evaluation of the Directive itself.” AEA (2009): Quantification of the effects on greenhouse gas emissions of policies and measures. Annex 1: Examination of landuse change on emissions savings [unpublished annex] CE Delft “Policy implementation should focus on effective implementation and improvement of the biofuels GHG emission reduction and other sustainability criteria. Prevention of negative impacts due to ILUC is key in this development.” “Recent studies on the abatement potential of biofuels show that due to indirect land use change (ILUC) effects most of the biofuels will result in a net increase of GHG emissions. Therefore, it is not possible (and useful) to determine cost effectiveness figures for these biofuels.” CE Delft. et al. (2012): EU transport GHG 2050 II Final Reporthttp://www.eutransportghg2050.eu/cms/assets/Uploads/Reports/EU-Transport-GHG-2050-II-Final-Report-29Jul12.pdf European Parliament study “Assuming current bioenergy and land use policy in the EU to remain unchanged until 2020, the order of magnitude of possible ILUC-related GHG emissions could nearly negate GHG savings from fossil fuels substituted by biofuels from dedicated energy crops.” Directorate General for Internal Policies: Policy Department A: Economic and Scientific policy (2011): Indirect Land Use Change and Biofuelshttp://www.europarl.europa.eu/committees/en/envi/studiesdownload.html?languageDocument=EN&file=35128 Institute for European Environmental Policy “Based on the assumptions set out in this study the additional emissions from ILUC, associated with the predicted increase in conventional biofuels use within the 23 Member States up to 2020, can be estimated to lead between 80.7 and 166.6% more GHG emissions than if these same fuel needs were met using fossil fuels, i.e. diesel and petrol, taking account of emission savings from biofuel use.” IEEP (2011): Anticipated Indirect Land Use Change Associated with Expanded Use of Biofuels and Bioliquids in the EU – An Analysis of the National Renewable Energy Action Plans.http://www.ieep.eu/assets/786/Analysis_of_ILUC_Based_on_the_National_Renewable_Energy_Action_Plans.pdf Government advisory bodies Committee on Climate Change (UK) “EU and UK regulatory approaches do not fully mitigate the risks of emissions from indirect land use change, and should therefore be strengthened. Specifically, both frameworks should reflect indirect land use change emissions, and the emissions saving relative to fossil fuels required for use of biomass in UK power and heat generation should be increased. If more robust regulations limit the supply of bioenergy which can meet defined sustainability criteria, the current 2020 targets for biofuels and biomass penetration should be adjusted down.” CCC (2011): Bioenergy reviewhttp://downloads.theccc.org.uk.s3.amazonaws.com/Bioenergy/1463%20CCC_Bioenergy%20review_bookmarked_1.pdf Renewable Fuels Agency, UK “…current greenhouse gas lifecycle analysis fails to take account of either indirect land change or avoided land use from co-products. Failing to include these factors may create perverse incentives which lead to higher greenhouse gas emissions by encouraging feedstocks that lead to higher net land use.” “The balance of evidence shows a significant risk that current [biofuel] policies will lead to net greenhouse gas emissions.” Gallagher, E.et al (2008): The Gallagher Review of the Indirect Effects of Biofuel Production, Renewable Fuels Agencyhttp://www.dft.gov.uk/rfa/_db/_documents/Report_of_the_Gallagher_review.pdf Netherlands Environmental Assessment Agency (PBL) “Even with emission reductions of 35 or even 60% (criteria for direct emissions in the EU-Directive for biofuels), model calculations indicate that it would take several hundreds of years to compensate for the short term direct biodiversity loss due to the conversion of natural area for the energy crop.” Kos, J.P.M. et al (2010): Identifying the indirect effects of bio-energy productionhttp://www.pbl.nl/en/publications/2010/Identifying-the-indirect-effects-of-bio-energy-production.html Netherlands Commission on Sustainability Issues concerning Biomass (CDB) “...indirect land use change effects are real and must therefore figure in biofuel and bioenergy policy. Doing nothing is clearly not an option, as the unintended indirect consequences (threats) of incentives for energy crops are too serious.” “By including the ILUC value in the greenhouse gas balance sheet, inefficient energy crops are ruled out and the maximum utilisation of residual flows and by-products is encouraged. This will cause productivity to rise and investments in efficiency to increase.” CDB (2009): Make agriculture part of the solution! - Recommendation on Indirect Land Use Change (ILUC)http://www.corbey.nl/includes/download.asp?media_id=585 "Given the increasing demand for food, combined with policy driven needs for biofuel feedstocks, and awaiting development of technologies that allow biofuel generation from non-food feedstocks, on the short run we will be confronted with increasing competition for crop material and, hence, for land (inputs).” CDB: Constraining the need for more land - Managing crop production, land use, biofuels and iLUChttp://www.corbey.nl/files/media_base/original/108.pdf German Advisory Council on Global Change (WBGU) “From the point of view of climate change mitigation the first-generation biofuels (such as biodiesel from rape or bioethanol from maize), which involve the cultivation of temperate, annual crops on agricultural land, score very badly. When emissions from indirect land-use changes are taken into account, they frequently result in higher emissions than would arise from the use of fossil fuels.” “WBGU considers emissions from indirect land-use change to be an indispensable part of any appraisal of the climate change mitigation effect of bioenergy use. Although research on the quantification of such emissions has only just started, it is necessary to produce quantitative estimates of these effects even today. WBGU therefore proposes using the iLUC factor (50 per cent) (...) for standard-setting (...), while adjusting it in future in line with new scientific findings.” “In all pathways for liquid fuels in the transport sector, the analysis shows that if energy crops are deployed whose cultivation leads to indirect land-use changes the emissions balance is even negative, i.e. emissions are higher than they would be if fossil fuels were used.” Schubert, R. et al (2009): Future Bioenergy and Sustainable Land Use. London: Earthscan. International institutions Food and Agriculture Organization of the United Nations (FAO) “Some biofuels may, under certain conditions, help reduce greenhouse gas emissions. In practice, however, the global effects of an expansion of biofuel production will depend crucially on where and how the feedstocks are produced. Land-use change resulting from increased feedstock production is a key determining factor. For many locations, emissions from land-use change – whether direct or indirect – are likely to exceed, or at least offset, much of the greenhouse gas savings obtained by using biofuels for transport. Moreover, even when biofuels are effective in reducing greenhouse gas emissions, they may not be the most cost-effective way of achieving this objective compared with other options.” “It must be ensured that further expansion of biofuel production will provide a positive contribution to climate-change mitigation. For this purpose, there is a critical need for an improved understanding of the effects of biofuels on land-use change, which is the source of the most significant effects on greenhouse gas emissions.” FAO (2008): The State of Food and Agriculture 2008ftp.fao.org/docrep/fao/011/i0100e/i0100e.pdf “EU palm oil imports have already doubled during the 2000-2006 period, mostly to substitute for rapeseed oil diverted from food to fuel uses.” Thoenes, P. (2006): Biofuels and Commodity Markets – Palm Oil Focus. Rome: FAO Commodities and Trade Division.http://www.rlc.fao.org/es/prioridades/bioenergia/pdf/commodity.pdf OECD “During the 2007-2009 period biofuels accounted for a significant share of global use of several crops – 20% for sugar cane, 9% for vegetable oil and coarse grains and 4% for sugar beet. Projections encompass a broad range of possible effects but all suggest that biofuel production will exert considerable upward pressure on prices in the future.” “Moreover, as long as governments impose mandates (obligations to blend fixed proportions of biofuels with fossil fuels, or binding targets for share of biofuels in energy use), biofuel production will aggravate the price inelasticity of demand that contributes to volatility in agricultural prices.” OECD et al. (2011): Price volatility in Food & Agricultural Markets - Policy Responseshttp://www.oecd.org/tad/agriculturaltrade/48152638.pdf “If biofuel production incentives increase a country’s market price for a commodity that is used as a biofuel feedstock, domestic cropland may be used more intensively, crops may be reallocated on existing cropland, or the cropland base may be expanded onto non-cropland acres, leading to higher world market prices. Higher world market prices will induce both intensity and expansion of crop production use in other countries, releasing additional GHG emissions into the atmosphere.” OECD (2012): Greenhouse Gas Accounting: Life Cycle Analysis of Biofuels and Land Use Changehttp://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=COM/TAD/CA/ENV/EPOC%282010%2920/FINAL&docLanguage=En United Nations Environment Programme (UNEP) “Altogether, the land conversion for biofuel cropland could lead to significant GHG emissions. Even if abandoned land and pastures were mainly used, a global average of up to 10% biofuel use for transport would render the overall mitigation effect of the use of first-generation biofuels questionable.” Bringezu, S. et al (2009): Towards sustainable production and use of resources: Assessing Biofuelshttp://www.unep.fr/scp/rpanel/pdf/assessing_biofuels_full_report.pdf Scientific bodies / consultancies The International Council on Clean Transportation (ICCT) “There is no question that indirect land use change will be a consequence of European biofuel mandates. The additional supply of feedstock required to produce biofuels for Europe must come from some combination of: Reduced stocks of agricultural commodities; Reduced consumption in food and other sectors; Increased productivity on currently cultivated land; Cultivation of biofuel feedstocks on currently uncultivated land.” ICCT (2011): Indirect land use change in Europe – considering the policy options.http://www.theicct.org/sites/default/files/publications/ICCT_iLUC-EU-options_Nov2011-1.pdf “Anyone who has studied market and trade analysis appreciates the fact that increased demand for biofuel feedstock and related market price shocks will increase returns to cropland and thus competition for agricultural land. These market price impacts will reverberate through global commodity markets and induce both domestic and global LUC.” ICCT (2012): A model-based quantitative assessment of the carbon benefits of introducing iLUC factors in the European Renewable Energy Directivehttp://www.theicct.org/sites/default/files/publications/Malins_gcbb1207.pdf Center for International Forestry Research (CIFOR) “With the rapid growth of biofuel production and consumption, and the proliferation of policy decisions supporting this expansion, concerns about the biofuel sector’s environmental and social impacts are increasing.” “Avoiding indirect land use change will be almost impossible to control solely through project-level certification of good practice.” CIFOR (2011): A review of environmental issues in the context of biofuel sustainability frameworkshttp://www.cifor.org/publications/pdf_files/OccPapers/OP-69.pdf Scientific Committee on Problems of the Environment (SCOPE) “Recent studies on potential indirect land-use change identify and focus on a real concern, i.e. the risk that biofuel deployment could accelerate and worsen the current unsustainable trends of deforestation and depletion of natural resources in a framework of accelerated growing population, and food and feed demand.” “Recent studies (...) show that land-use conversion from native land-uses to biofuel crops lead consistently to significant GHG emissions and a negative carbon balance, or carbon-debt, for decades to centuries.” “According to the present assessment, the potential CO2 emission from land conversion to biofuel crops by growing first-generation biofuel crops is likely to be greater than the savings expected from the first thirty years of growing biofuel crops.” Howarth, R.W. and Bringezu, S. (eds) (2009): Biofuels: Environmental Consequences and Interactions with Changing Land Use. Proceedings of the SCOPE International Biofuels Project Rapid Assessment, 22-25 September 2008, Gummersbach Germany. Cornell University, Ithaca NY, USA.http://cip.cornell.edu/biofuels/ Oeko-Institut – Institute for Applied Ecology (OEKO) “Disregarding how and in which quantitative figures the possible GHG emissions from ILUC are expressed, it should be noted that the EU RED scheme in its current format is, in comparison to the Californian LCFS, fundamentally flawed with regard to favoring low-ILUC risk biofuels.” Fritsche, U. R. et al (2010): The “iLUC Factor” as a Means to Hedge Risks of GHG Emissionshttp://www.oeko.de/oekodoc/1030/2010-082-en.pdf Smith School of Enterprise and the Environment “When land-use is taken into account, these first-generation biofuels have significantly higher GHG emissions than conventional fuels due to substantial biomass and soil carbon release if carbon-rich land such as forest is cleared to grow the feedstocks (so-called carbon debt). It could take decades or centuries to offset these upfront carbon emissions by substituting conventional fuels with biofuels. Furthermore, additional impacts could also include soil erosion and biodiversity loss.” “Conserving the existing forest and restoring forest on cropland not used for food production could achieve greater GHG mitigation than first-generation biofuels as well as additional environmental benefits.” King. D. (ed.) (2009): Future of Mobility Roadmap. Oxford: University of Oxford.http://www.smithschool.ox.ac.uk/wp-content/uploads/2010/02/Future_of_Mobility.pdf CE Delft “Studies show that emissions resulting from ILUC are so significant that they could sway the climate effects of biofuels from positive to negative, compared with fossil fuels.” CE DELFT (2010): Biofuels: indirect land use change and climate impacthttp://www.cedelft.eu/?go=home.downloadPub&id=1068&file=8169_defreportHCMV.pdf Ernst and Young “Certain types of land use change can have very significant greenhouse gas impacts due to the conversion of natural carbon stocks into atmospheric carbon emissions which could negate any transport fuel greenhouse gas intensity reductions being achieved by the biofuels policy.” Ernst & Young (2011): Biofuels and indirect land use changehttp://ww.endseurope.com/docs/111005a.pdf US agencies Californian Air Resource Board (CARB) “ARB staff has concluded that the land use impacts of crop-based biofuels are significant and must be included in LCFS [California Low Carbon Fuel Standard] fuel carbon intensities. To exclude them would allow fuels with carbon intensities that are similar to gasoline and diesel fuel to function as low-carbon fuels under the LCFS. This would delay the development of truly low-carbon fuels and jeopardize the achievement of a 10 percent reduction in fuel carbon intensity by 2020.” CARB (2009): Proposed Regulation to Implement the Low Carbon Fuel Standard. Volume I.http://www.arb.ca.gov/fuels/lcfs/030409lcfs_isor_vol1.pdf US Environmental Protection Agency (EPA) “...it would be far less scientifically credible to ignore the effects of land use changes altogether than it is to use the best approach available to assess these known emissions sources.” “We believe that uncertainty in the effects and extent of land use changes is not a reason for not accounting for land use change emissions.” EPA (2009): Draft Regulatory Impact Analysis: Changes to Renewable Fuels Standard Program.http://www.epa.gov/orcdizux/renewablefuels/420d09001.pdf Scientific publications "Our model predicts that indirect land use will be responsible for substantially more carbon loss (up to twice as much) than direct land use; however, because of predicted increases in fertilizer use, nitrous oxide emissions will be more important than carbon losses themselves in terms of warming potential.” Melillo, J. et al (2009): Indirect Emissions from Biofuels: How Important? Science vol. 326, 4 December 2009 pp. 1397-1399http://www.sciencemag.org/cgi/reprint/326/5958/1397.pdf “Policymakers would (...) be wise to assign emissions factors for ILUC that are high enough to provide a level of reasonable assurance that hoped for greenhouse gas reductions will be real.” Searchinger, T. (2010) Biofuels and the need for additional carbon. Environmental Research Letters 5 (2010) 024007.http://iopscience.iop.org/1748-9326/5/2/024007/fulltext “Our results demonstrate that the net effect of biofuel production via clearing of carbon-rich habitats is to increase CO2 emissions for decades or centuries relative to fossil fuel use.” Fargione, J.; Hill, J.; Tilman, D.; Polasky, S., and Hawthorne, P., 2008. Land clearing and the biofuel carbon debt. Science, 29/02/2008, pp. 1235–1238http://www.sciencemag.org/cgi/content/abstract/319/5867/1235 “By using a worldwide agricultural model to estimate emissions from land-use change, we found that corn-based ethanol, instead of producing a 20% savings, nearly doubles greenhouse emissions over 30 years and increases greenhouse gases for 167 years. Biofuels from switchgrass, if grown on U.S. corn lands, increase emissions by 50%. This result raises concerns about large biofuel mandates and highlights the value of using waste products.” Searchinger, T. et al (2008): Use of U.S. Croplands for Biofuels Increases Greenhouse Gasses through Emissions from Land Use Change. Science, 08/02/2008, pp. 1238-1240http://www.sciencemag.org/cgi/content/abstract/1151861 “One environmental impact that has raised serious concerns is loss of Amazonian forest through indirect land use changes (ILUC), whereby mechanized agriculture encroaches on existing pastures, displacing them to the frontier.” “The voluntary moratorium on primary forest conversions by Brazilian soy farmers has failed to stop the deforestation effects of expanding soy production. Thus, environmental policy in Brazil must pay attention to ILUC, which can complicate efforts to achieve its REDD targets.” Arima, E.Y. et al., Abstract “Statistical confirmation of indirect land use change in the Brazilian Amazon”, Environmental Research Letters, 6, (April-June 2011) http://iopscience.iop.org/1748-9326/6/2/024010/fulltext/ Conclusions There is clearly an overwhelming body of scientific evidence revealing the appropriateness and the urgency of addressing ILUC emissions. The new RED for 2020-2030 is a step in the right direction for addressing ILUC emissions, but a lot will depend on member states’ implementation. The new law provides the opportunity for member states to end the support to crop-based biofuels. We call on EU governments to ensure an ambitious and robust implementation in the years to come. At the same time, if member states decide to continue the support to crop biofuels, their share will continue to be limited and there is now a commitment to phase out the support to the highest emitting biofuels such as palm oil.