ILUC Debate in EuropeThe Saga Continues

By Robert Vierhout | August 27, 2010
In Europe, we have now entered the next phase of the debate on indirect land use change (ILUC). The European Commission has just issued a three-page consultation document seeking input from stakeholders on four questions. It is the second public consultation on ILUC. The first a year ago was euphemistically called a "pre-consultation." The views expressed then will probably not vary much from those that will be voiced in this new consultation.

One year ago, environmental non-governmental organizations (NGOs) and green politicians were advocating the precautionary principle be applied with an ILUC factor high enough to make all biofuels impossible to produce with the exception of those produced from cellulosic material or crops grown on marginal land. We, the industry, said there is no sound scientific evidence to justify such punitive ILUC penalties. In the year since, a growing number of researchers have cast serious doubt on the hallucinating emission numbers made up by people like Searchinger et al.
The new consultation document raises (again) all the usual questions, including very sensitive ones that need answers.

The first question is crucial, asking if the analytical work carried out to date "provides a good basis for determining how significant ILUC resulting from the production of biofuels is." The commission could have stopped there, but instead is soliciting comments on important factors such as the split between first-and second-generation biofuels by 2020, the composition of the vehicle fleet, the diesel/gasoline split, crop yields, land use data and coproducts. By adding this list of variables, it is as if the commission is saying it is not all that obvious. On the other hand, the question implies that ILUC occurs and that the real issue is to find out the reasons why it occurs and whether it is big or small.

The three remaining questions are much more sensitive and political in nature. Question two asks whether the available evidence is persuasive enough to take regulatory steps. Question three asks if such action is taken, is there any relationship between the produced biofuel, the feedstock used, the region the biofuel comes from and the way land is managed? The answers given to the first three questions will provide the answer to question four which seeks input on policy options. The commission poses four options: a) No action, just monitoring; b) Encourage certain biofuels; c) Discourage certain biofuels; d)Some other action.

Two interesting remarks conclude the questionnaire. First, all responses must be justified by reference to available science, meaning that the commission will discard political discourses immediately. That makes sense. A lot of environmental NGOs tend to present only their own biased and unbalanced "science" which all too often reflects ideology rather than actual science. Second, responses may be submitted confidentially. This is remarkable knowing that the commission has been criticized before by several NGOs and the media for a lack of transparency. However, it will certainly lower the threshold for some respondents to suggest approaches that are too controversial or too economically sensitive to be put into the public domain.

Overall the document is predictable in both the issues that it raises and the way in which these are presented. Probably so will the answers that will be handed in by stakeholders.

My personal belief is that the commission is conducting the consultation for reasons of justification only. At the end of this year when the commission publishes its report, it cannot be accused of not having sought stakeholder input. It is highly unlikely that the commission expects anything new from this exercise. The state of the science is known and so are the positions of the most important stakeholders.
I am certain that just like the external stakeholders, the various commission services fighting internally over the issue made up their minds a long time ago. They might change their position marginally, but not because of what is being presented in this consultation. If the commission services changes its view on ILUC, it will either be because there are scientific breakthroughs (not to be expected) or because the political tide has changed. On the latter, we are working hard.

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