ILUC Portal

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Welcome to the ILUC Portal -- a comprehensive source of information concerning indirect land use change (ILUC).

January 2011 YouTube video, "What is indirect land use change?"

by the International Council on Clean Transportation (ICCT).



Indirect land use change is an important issue related to the life-cycle greenhouse gas emissions of biofuels and other crops. The crux of the issue is that if the scope of impacts is viewed in a narrow fashion (that is, if only those impacts directly related to the production of a crop are considered), then biofuels may be considered to have lower greenhouse gas emissions than other fuels. However, if the impacts are tallied in a more comprehensive fashion -- including the fact that increased production of biofuel feedstocks may lead to changes in the use of land in other locations (as would occur if increased overall demand for agricultural products leads to the conversion of forested areas to grow crops) -- then the overall associated greenhouse gas emissions would be higher.


Most recent Twitter posts on "ILUC"






  • Uncertainty still clouds future of EU biodiesel, 3 May 2012 by Reuters: "Senior European Union officials failed on Wednesday to agree on how to measure the full climate impact of biofuels, prolonging uncertainty in a debate that threatens to wipe out large parts of Europe's biodiesel industry...."
    • "The debate centred on a relatively new concept known as indirect land use change (ILUC)....
    • "By estimating the ILUC emissions associated with each specific crop, scientists concluded that most biodiesel currently used in Europe emits more carbon than conventional diesel...."
    • "The realisation that EU rules on ILUC could kill off much of Europe's estimated 13 billion euro biodiesel industry and undermine its climate goals led to paralysis within the Commission, while officials argued over whether current ILUC models were robust enough to warrant such drastic action."
    • "Biodiesel producers say there is too much uncertainty in the assumptions used to model ILUC emissions to justify immediate action, and that specific rules should be delayed for several years in favour of an indirect approach."[1]
  • Further delay as Commissioners fail to agree biofuels clean-up plan, 2 May 2012 by Greenpeace: "European Commissioners today failed to agree how to close a major loophole in EU biofuels policy. The lack of progress adds to years of delay while the climate impact of harmful biofuels continues to grow, Greenpeace said...."
    • "In a debate this morning, the EU’s 27 commissioners were unable to agree a common approach on how to account for ILUC...."
    • "A Commission ILUC impact assessment found that habitats more than half the size of Belgium are set to be destroyed to meet EU demand for biofuels by 2020, increasing Europe’s greenhouse gas emissions by more than the total annual emissions of Italy or France."[2]
  • EPA palm oil analysis draws support, criticism as comments close, 26 April 2012 by Erin Voegele for Biodiesel Magazine: "The public comment period for the U.S. EPA’s palm oil pathway assessment under the renewable fuel standard (RFS2) closes April 27. As the deadline approaches, groups representing both sides of the issue are speaking out in an effort to sway the EPA’s final decision on the matter."
    • "As the deadline approaches, parties arguing in support and opposition of the EPA’s findings are speaking out. Robert Shapiro, chairman and co-founder of Sonecon LLC, a firm that advises organizations on market conditions and economic policy, is one of the people who has submitted comments opposing the EPA’s analysis of palm oil biofuels."
      • "First, he questions the accuracy of the agency’s method to predict indirect land use change (ILUC), noting that without the highly unreliable inclusion of ILUC data, palm oil-based biodiesel and renewable diesel would meet the prescribed RFS2 thresholds."
      • "He also states that his analysis has found that the EPA’s assumption that palm oil yields will not increase in the future is false. He also stated that the EPA’s calculated 'midpoints' for its projected range of emissions effects are inaccurate."
    • "However, there are also individuals and groups that are arguing that the EPA’s analysis was too lenient, and the actually GHG emissions associated with palm oil biofuels are much higher. A group of scientific and environmental groups, including the Union of Concerned Scientists, is set to submit a public comment on the issue April 27 agreeing with EPA’s assessment that these fuels don’t meet RFS2 GHG reduction thresholds, and also arguing that the agency’s GHG assessments are too low."
      • "According to Jeremy Martin, senior scientist for the UCS’ Clean Vehicles Program, the EPA’s analysis underestimates the serious environmental problems caused by palm oil production. 'We’ve done a thorough review of EPA’s analysis and have found that in several important areas they did substantially underestimate the emissions,' Martin said. 'We’ve provided EPA with data substantiating more appropriate values.' Using those new values, Martin said the analysis shows palm oil biofuels actually result in more GHG emissions than petroleum-based fuels. He also brought up issues associated with food production and the long history of deforestation associated with palm oil production." [4]
  • RSB announces Public Consultation on the issue of Indirect Impacts (PDF file), 13 April 2012 by the Roundtable on Sustainable Biofuels (RSB): "During the past three years, the RSB Secretariat, based at Ecole Polytechnique Fédérale de Lausanne (EPFL), has collected a considerable volume of information, data and knowledge about indirect impacts of biofuel production, thanks in part to the contribution of the RSB indirect impacts expert group (IIEG). It is now time for the RSB constituencies to decide on a way forward regarding a possible inclusion of indirect impacts in the RSB Standard.
    • "In May-June 2012, RSB members will discuss the issue of indirect impacts in a series of RSB Chamber calls and during the June in-person Steering Board meeting. But before these discussions take place at the membership level, the RSB Secretariat is launching Public Consultation on the subject, in which all members of the general public are invited to provide us with feedback on this issue."
    • "For this purpose, the RSB Secretariat has drafted the attached Background Paper (PDF file) (“Indirect Impacts of biofuel production and the RSB Standard”) that is meant to be a neutral and objective representation of indirect impacts, state of knowledge, potential options to address the issue in the Standard (including the option not to address it), and an evaluation of such options. This paper will form the basis for the public consultation and also for the discussion at the Chamber and Steering Board level."
    • Summary timeline for this consultation:
      • Public consultation (1 month): April 13 – May 15
      • RSB Chambers consultation: 2nd half of May
      • Steering Board Meeting and decision on way forward: June 12-13
    • To submit feedback, send an email or a marked-up pdf document to: victoria.junquera[at] or use the Feedback Form available at before May 15, 2012."
  • EU report questions conventional biofuels' sustainability, 11 April 2012 by Euractiv: "Conventional biofuels like biodiesel increase carbon dioxide emissions and are too expensive to consider as a long-term alternative fuel, a draft EU report says."
    • "The study 'EU Transport GHG [greenhouse gases]: Routes to 2050' estimates that before indirect effects are counted, the abatement cost of reducing Europe’s emissions with biofuels is between €100-€300 per tonne of carbon."
    • "At current market prices, this would make their CO2 reduction potential up to 49 times more expensive than buying carbon credits on the open market at €6.14 a tonne."
    • "But the EU’s authors conclude that it 'it is not possible (and useful) to determine cost effectiveness figures for [conventional] biofuels' because their indirect effect - measured in cleared forests and grasslands ('ILUC') - make it a CO2-emitting technology."
    • "The latest report will feed a growing unease about the reasons for the EU's original biofuels policy - justified in environmental terms - and the way it has developed since...."
    • "Brussels is due to publish a proposal measuring the indirect emissions caused by biofuels later this year, distinguishing between low-emitting biofuels such as ethanol and high-emitting ones like biodiesel."
    • "But the EU’s decision-making process has been paralysed by the ongoing dispute between its energy directorate – which does not want ILUC factors considered – and its climate directorate, which does...."
    • "For now, the proposal remains stuck in the corridors of an EU that appears equally frightened of the political consequences of admitting a policy mistake and the environmental consequences of denying it."[5]
  • Journal article explores hybridized life cycle analysis method by Kris Bevill for Ethanol Producer Magazine, 4 April 2012.
    • "A recently published article in the peer-reviewed Journal of the Royal Society Interface suggests that in order for life cycle analyses (LCA) of biomass-based products such as biofuels to be most accurately calculated, modelers should develop a hybridized methodology that considers both direct and indirect effects, to measure the carbon intensity of production. Further, the authors of the paper stressed the need for policymakers worldwide to develop methodologies that are compatible and comparable, rather than continue forward with the patchwork of individualized policies specific to country or region."
    • "Susan Tarka Sanchez served as lead author of the paper, titled 'Accounting for Indirect Land Use Change in the Life Cycle Assessment of Biofuel Supply Chains,' while working as the senior scientist at California-based business and environmental consulting firm Life Cycle Associates LLC, the company which developed the CA-GREET life cycle analyses model used by the California Air Resources Board in developing the state’s low carbon fuel standard. Sanchez admits that indirect land use change (ILUC) continues to be a controversial topic, but said the group of international experts that contributed to the journal paper feel it is essential to incorporate indirect effects into biofuels methodology in order to gauge the full effects of the product." [6]
    • Read the paper, Accounting for Indirect Land Use Change in the Life Cycle Assessment of Biofuel Supply Chains by Susan Tarka Sanchez, Jeremy Woods, Mark Akhurst, Matthew Brander, Michael O'Hare, Terence P. Dawson, Robert Edwards, Adam J. Liska and Rick Malpas.
  • Neste Oil: European Commission Indirect Land Use Change (ILUC) Public Consultation, 27 March 2012 by Greenpeace Finland: "The core position of Neste Oil on ILUC is that 'Clearly it is not possible with any degree of accuracy to give a value for ILUC (p.3)'.” [(Based on comments submitted by Neste Oil for the European Commission Indirect Land Use Change (ILUC) Public Consultation.)]
    • "However, 'if ILUC actions are taken before the full understanding of the phenomenon the policy should be to offer incentive to do additional ILUC mitigation actions by the operator. The example of such incentives could be added bonus - -. As the intention of the RED directive is to improve the environmental performance of biofuels, then the only workable solution to this problem will be to have all sectors included (p.5)'"
    • Other excerpts from Neste Oil's comments:
      • "Especially in developing countries, poverty is a major cause of deforestation."(p.1)
      • "It is not reasonable to assume that ILUC could be controlled by imposing restrictions on one industrial sector." (p.1)
      • "Trying to combat ILUC in by starting with a minor user of global commodities is merely poor policy making and in this case, may also be threatening the targets of actions against climate change." (p.1) [7]
    • Read the full comments submitted by Neste Oil for the European Commission Indirect Land Use Change (ILUC) Public Consultation (PDF File)]
  • Environmental burden shifting and sustainability criteria for biofuels, 26 March 2012 by Anil Baral for ICCT blog: "Biofuels are here for three reasons – climate change mitigation, energy security and to increase rural incomes. The supposed climate change mitigation potential of biofuels comes with the idea that renewability implies carbon neutrality. However, with the introduction of the systems approach of analyzing environmental costs and benefits, it has emerged that biofuels, especially first generation biofuels, do not offer environmental and human health benefits on all fronts. The systems approach, such as life cycle analysis (LCA), looks into far ranging impacts including GHG emissions from indirect land use change (ILUC). We find that in many cases we may not expect to achieve net greenhouse gas reductions from biofuel policies – but also that even where climate change mitigation might be effective, there can be other tradeoffs in choosing biofuels, indicating a potential risk of environmental burden shifting for policies that solely focus on GHG mitigation." [8]
  • Biofuels About More Than Climate 21 March 2012 by Alessandro Torello, (blog) for Wall Street Journal: "Biofuels have been heavily promoted in the European Union as the most straightforward way to reduce greenhouse-gas emissions from transport."
    • "Other ways of doing it are a more distant prospect. Electric cars are making a push, but are still some way from taking off, as are other innovative technologies. Biofuels, meanwhile, are perfectly compatible with combustion engines used today and are–more or less–readily available... They are considered greener than gasoline and [[diesel based on fossil fuels because their carbon dioxide emissions –just the same as regular fuels when burned in an engine–are offset by the plants that are grown to produce them."
    • "Now, however, a phenomenon called Indirect Land Use Change–or ILUC, in Brussels jargon– is calling into question their green credentials." [9]
  • The rise and fall of biofuels and why they failed key test 20 March 2012 by George Wachira, for Business Daily Africa: "An energy expert asked me the other day if I still believed in biofuels as feasible alternative transport fuels for Kenya. We had met at a biofuels conference in Dar-es-Salaam about four years ago where I presented a paper. Around the same time I was the vice-chairman of the National Biofuels Committee at the Ministry of Energy. My hesitant answer was that emphasis on biofuels has reduced, globally and here in Kenya, as priorities have definitely changed."
    • "So what caused a shift in biofuels emphasis? Globally, around 2008/09 the western world was experiencing serious economic downturn and economic survival may have become more urgent that the global warming subject. Downgraded commitment to global warming issues by the western nations was apparent at all subsequent global climate meetings (Bali, Copenhagen, Cancun, and Durban)... About the same time, the sudden shift from food to biofuel crops was starting to negatively impact global food sufficiency. Food commodity prices shot up, prompting caution on biofuel production across the globe."
    • "Further, it was emerging across the world that other more effective green solutions (wind, solar, geothermal, nuclear, afforestation) could deliver quicker and more effective carbon reduction solutions, and these have now been embraced on a massive scale. Thereafter, there has been less emphasis on biofuels to provide green energy."
    • "Kenya’s energy mix has plenty of green content and this is sufficient national contribution towards global warming mitigation efforts. The country has also opted to emphasise tree planting for both climate change reasons and also for reinforcing the country’s hydrology. With these measures and plans in place, we may not need to produce biofuels justified on global warming mitigation." [10]
  • ‘This must be the most researched subject in the EU’s history!’, 19 March 2012 by Nusa Urbancic for European Federation for Transport and Environment: "Two new reports are expected to put more pressure on the Commission over its biofuels policy. Both add to the growing bank of evidence that under current policies, changes in land use caused by growing biofuels crops will wipe out the climate benefits of using certain biofuels, especially in the case of biodiesel."
    • "One report on the cost-effectiveness of policies to decarbonise transport, due to be published by a group of consultancies later this month, says most models show that indirect land-use change (Iluc) will mean ‘a net increase of greenhouse gases’ for biodiesel. The other report, also still to be published, says that if biofuels’ lifecycle emissions, rather than just direct emissions, from Iluc are taken into account, the EU would achieve little more than half its goal of reducing greenhouse gas emissions by 60% by 2050." [11]
  • 7 states fight California rule over ethanol carbon scores 19 March 2012 by Adam Belz for USA TODAY: "A California rule assigning higher carbon scores to fuel produced outside the state has drawn the ire of the ethanol industry and the Midwestern states that produce most of the ethanol in the U.S."
    • "At least seven states — Nebraska, Iowa, Kansas, Michigan, Missouri, North Dakota and South Dakota— are opposing California's effort to enforce the mandate, which critics say threatens the renewable fuels business in the nation's grain belt."
    • "In December, a federal judge blocked California's Air Resources Board from enforcing the regulation, which encourages refiners to blend gasoline with ethanol produced in Brazil or California. The California rule considers Midwestern ethanol to have a larger carbon footprint. The judge said the rule unconstitutionally interferes with interstate commerce. California officials are appealing the decision."
    • "The rule hinges on the concept of indirect land use change, Thorne said. The idea is that if farmers in the U.S. sell their grain for ethanol, farmers in other parts of the world must grow more corn for the food supply, pumping more carbon into the atmosphere, he said."
    • "Nebraska Attorney General Jon Bruning, who said the regulation threatens $1.3 billion in annual ethanol sales from his state alone, called the indirect land use change a 'highly controversial and undeveloped theory,' in a brief signed by attorneys general from five other states."[12]
  • Europe: Pressure mounts over side-effects of biofuel, 5 March 2012 by Population Matters: "The debate over whether biofuel does more environmental harm than good has reached boiling point in the European Commission – and... new studies are likely to raise the temperature further."
    • "A report to be published later this month on the cost-effectiveness of policies to decarbonise transport concludes that without weeding out the biofuel that causes indirect land-use change (ILUC), the fuel source is so bad for the environment that its benefits cannot even be calculated. 'Most of the models predict a net increase of greenhouse gases when incorporating the ILUC effect for biodiesel,' says a draft of the report, written by a group of consultancies including CE Delft. 'For these biofuels, determining the cost-effectiveness in terms of euros/tonne of carbon dioxide reduction makes no sense.'" [13]
  • ANALYSIS-Biodiesel doubts threaten EU green transport targets, 5 March 2012 by Charlie Dunmore and Ivana Sekularac, in Sharenet: "Growing consensus that EU may miss 2020 biofuel targets... Demand for biodiesel threatened by land use change studies... Switch to bioethanol seen as unlikely to make up shortfall."
    • "The European Union will almost certainly miss its 2020 targets for cutting transport fuel emissions if policymakers act on scientific warnings about the climate impact of biofuels."
    • "Several EU studies have questioned the climate benefits of biodiesel made from European rapeseed and imported palm oil and soybeans, and some have warned that it releases as many climate-warming emissions as conventional diesel."
    • "With two-thirds of EU biofuel use in 2020 projected to come from biodiesel, there is a growing consensus that any move to exclude some biodiesel feedstocks, such as the U.S. has proposed in the case of palm oil, would put the goals out of reach. Even if Europe tried to boost its use of bioethanol and advanced biofuels from non-crop sources to make up the shortfall, technical barriers and the EU's rising thirst for diesel would still leave it short of the mark." [14]
  • ILUC: The ‘Soap’ Continues, 5 March 2012 by Robert Vierhout, Secretary-general of ePURE, in Ethanol Producer Magazine: "Contrary to the USA where the U.S. EPA managed to get some indirect land use change (ILUC) values out of a black box relatively quickly, the EU is progressing slowly in ‘solving’ ILUC. For already more than two years, the European Commission services have been deliberating what to do."
    • "In my opinion, the delay in putting a bill on the table is caused by the fact that the ILUC ‘science’ is simply not conclusive. A study by the International Food Policy Research Institute assessing ILUC caused by biofuel policy does not seem to convince everyone within the commission that indirect land use change is more than just an imaginary problem...."
    • "The latest compromise under discussion by the commission services would allocate an ILUC value differentiated by crop (vegetable oil, sugar and starch) to biofuels to be used to achieve the target set in the law on fuel quality...."
    • "If countries in Southeast Asia can no longer, due to this ILUC value, export their palm oil to the EU, they will find other markets, most likely closer to home. A leakage effect would occur. If, as a result, the EU produces less biofuel, would we then not even need to import more biofuels to compensate for the lower GHG saving? More imports, more risk of unwanted land use change? Finally, we would not be addressing the problem where it is occurring: outside Europe."
    • "A more effective way to prevent unwanted land use changes leading to higher carbon release is by concluding agreements with the countries that are exporting biofuels to Europe. These agreements should restrict or forbid imports of certain biofuels unless proper land management is guaranteed."[15]
  • Biodiesel doubts threaten EU green transport targets, 5 March 2012 by Reuters: "The European Union will almost certainly miss its 2020 targets for cutting transport fuel emissions if policymakers act on scientific warnings about the climate impact of biofuels."
    • "Several EU studies have questioned the climate benefits of biodiesel made from European rapeseed and imported palm oil and soybeans, and some have warned that it releases as many climate-warming emissions as conventional diesel...."
    • "If the EU penalises crop-specific biofuels for their estimated ILUC emissions, any incentive for governments and oil firms to promote biodiesel from rapeseed, palm oil and soybeans would disappear...."
    • "The Commission has already drafted two compromise proposals on ILUC without reaching an agreement on either, reflecting deep internal divisions on the issue."
    • "The deal now under discussion would penalise biofuels for their crop-specific ILUC emissions in the fuel quality law but not the renewable energy directive, removing the incentive for oil companies to buy biodiesel without excluding it entirely...."[16]
  • Airbus urges EU to scrap biodiesel incentives for road transport, 16 February 2012 by EurActive: "The EU should bin incentives for road-transport biodiesel or provide equal ones for the production of biokerosene used in airplanes, a senior Airbus executive has told EurActiv."
    • "'We are asking for a level playing field or the scrapping of incentives that cover the biodiesel industry,'said Paul Nash, the Airbus head of environment and new energies."
    • "Biodiesel, which is primarily used in road transport, may eventually be deemed one of the ‘worst performing biofuels’ with leaked EU data putting its emissions on a par with those from tar sands, when ILUC effects are counted...."
    • "Industry insiders argue airlines should be given priority access to sustainable biofuels as aviation will continue to rely on liquid fuels for decades. Road transport, by contrast, has already started its transition to electricity, something that airlines simply cannot do." [17]
  • EU energy chief against higher biofuel target for now, 7 February 2012 by AlertNet: "The EU's energy chief said on Tuesday for now he was opposed to raising the bloc's 10 percent biofuel target due to environmental concerns and urged the bloc to agree 2030 energy goals within two years."
    • "On the biofuel target, he told a conference: 'If I had to decide today, I would reject a proposal to go beyond 10 percent (on biofuels). The whole question of sustainability has to be addressed.'"
    • "The European Union has a binding target to raise the share of renewable energy in road transport to 10 percent by the end of the decade, almost all of which is expected to be met by blending biofuels with conventional fuels."
    • "The EU executive is grappling with the question of how to regulate the unintended environmental consequences of biofuel production and has repeatedly delayed legislative proposals due last year on indirect land use change (ILUC)." [18]
  • Location key to calculating biofuel carbon footprint, 4 February 2012 by “The US government has set a target for producing cellulosic ethanol of nearly 40 billion litres each year by 2020. The perennial grass Miscanthus x giganteus is one potential source… But the climate impact of using the grass to make cellulosic ethanol depends on how and where it's grown, processed and transported. With that in mind, researchers from the University of California, Berkeley and Lawrence Berkeley National Laboratory, US, have assessed the optimum conditions for producing the fuel, using six different scenarios.”
    • “The team found that, provided indirect land-use change (ILUC) was successfully minimized or mitigated, the major factors affecting the greenhouse-gas emissions of cellulosic ethanol production were the amount of soil carbon emitted or stored during growth of the grass, and greenhouse-gas offset credits for electricity exported to the grid by biorefineries.”
    • "What also became increasingly clear to us is the importance of location; where the biomass is grown, where the biorefineries are located, and by what mode and how far both the biomass and ethanol product must be transported are all key to assessing the environmental impacts," said Scown. "These are all unknowns for an industry such as cellulosic ethanol production that has yet to develop on a commercial scale."[19]
    • Read the article, Lifecycle greenhouse gas implications of US national scenarios for cellulosic ethanol production, published in Environmental Research Letters (ERL).
  • IATP paper probes deeper implications of ILUC debate, 2 February 2012 by Ethanol Producer Magazine: "Looking for a middle ground where environmentalists and ethanol advocates could meet, the Minneapolis-based Institute for Agriculture and Trade Policy released a paper by Julia Olmstead reflecting on the lessons learned regarding the debate over indirect land use change (ILUC)."
    • "One of the points made in the six-page paper emerging from those efforts is that although those in support of the ILUC factor have argued higher demand for corn for ethanol production stimulates land conversion, it may be based on a faulty assumption. 'Although the connection between price signals and reduced land conversion isn’t often part of the ILUC conversation, the implicit assumption is that low prices will help stem land conversion,' the paper states. 'High prices stimulate agricultural expansion, but there is evidence that low commodity prices can do the same.'"[20]
    • Download the paper, Learning from the Indirect Land Use Change Debate (PDF file)
  • Fuelish Choices, Uncut, published online January 2012 by John Sheehan for Momentum: "In spring 2011, I received an invitation from the Institute for Agriculture and Trade Policy to participate in a fact-finding mission to Brazil as part of a dialogue aimed at untangling contentious questions about the effect of biofuels on global land use change, known (in the insider jargon of policy wonks) as the indirect land use change or “ILUC”—pronounced “eye-luck”—effect of biofuels." [21]
  • FEDIOL Position on Indirect Land Use Change (iLUC) (PDF file), 30 January 2012 by the European Vegetable Oil and Proteinmeal Industry (FEDIOL): "FEDIOL strongly believes that indirect land-use change (iLUC) is a phenomenon which cannot be quantified with the available scientific knowledge. In the decision-making process, we urge the European Institutions to carefully examine the entirety of the food and energy supply chains, and take a holistic approach which would not jeopardise food and energy security, which would not limit access to sustainable raw materials and which would not endanger competitiveness of EU industries...."
    • "Studies trying to measure iLUC so far have given misleading account of vegetable oils‟ and proteinmeals‟ role in food, feed and technical uses...."
    • "If biodiesel pathways in Europe are to be disqualified with a precautionary decision on iLUC, this could make 70% (15.8 million tonnes) of rapeseed and 25% (3.2 million tonnes) of soybean crushing redundant, depriving the livestock sector from up to 12 million tonnes of protein rich meals made available through the often integrated oilseeds crushing, refining and biodiesel production processes...."
    • "Based on the currently available studies, including the IFPRI Report, there is no converging evidence to draw undisputable conclusions to the extent of iLUC. In this view, the European Commission should abstain from addressing iLUC by taking any quantifying measures, including iLUC factors."
    • "If the EU would introduce quantified measures (thresholds, iLUC factors, etc.) to address iLUC, this would represent a turnover loss between 11.2 billion and 13.4 billion Euros annually for the FEDIOL members. The crushing industry would have to fundamentally restructure to go back to pre-biofuels levels with considerable negative effects on jobs and on rural development."
    • Download the position paper, FEDIOL Position on Indirect Land Use Change (iLUC) (PDF file)
  • The ILUC Debate, Four Years Later, 11 January 2012 by Ethanol Producer Magazine: “Four years ago, the biofuels industry was boorishly introduced to the theory of indirect land use change, or ILUC.”
    • “Timothy Searchinger’s now infamous article in the February 2008 edition of Science magazine boldly suggested increased corn ethanol production in the United States would lead to massive deforestation and conversion of grassland in nations halfway around the world. These hypothetical land conversions, he proffered, would release large amounts of stored carbon, indirectly making ethanol’s carbon footprint twice as bad as gasoline’s.”
    • “[Today] the scientific community has better data, improved modeling tools, and a better appreciation of the uncertainty and complexity involved in ILUC analysis. But, above all, they have the benefit of some experience and hindsight.”
    • Real world data show that Searchinger was dead wrong in his predictions that ethanol expansion would cause U.S. farmers to plant fewer soybean acres, or that they would '…directly plow up more forest or grassland.'”
    • Empirical data also prove wrong Searchinger’s notion that “higher prices triggered by biofuels will accelerate forest and grassland conversion” in South America. Data from Brazil’s Ministry of Science and Technology show dramatic reductions in Amazon deforestation over the past five years. In fact, 2010 saw the lowest level of deforestation since the government began collecting the data in 1988.
    • “While methods to empirically verify the past occurrence and magnitude of ILUC continue to improve, the economic models used to predict potential future ILUC also are being refined…. Contrasting these latest estimates with Searchinger’s outrageous value of 104 g/MJ shows his worst-case analysis was simply out of touch with reality.”
    • "Unfortunately, advancements in the science of ILUC have not been mirrored by improvements in biofuels regulations that penalize ethanol for hypothetical ILUC emissions. California and EPA continue to rely on outdated and inflated estimates of ILUC, to the detriment of our industry." [23]
  • Sugarcane ethanol in Brazil a substantial pollution source, 27 December 2011 by Western Farm Press: "University of Iowa researchers and their colleagues have shown that ethanol fuel producers in Brazil — the world's top producer of ethanol from sugarcane as an alternative to petroleum-based fuel — generate up to seven times more air pollutants than previously thought."
    • "The study, titled 'Increased estimates of air-pollution emissions from Brazilian sugarcane ethanol,' is featured in the Nature Highlights section and published in the Dec. 11 advance online publication of the journal Nature Climate Change."
    • "The research team used agricultural survey data from Brazil to calculate emissions of air pollutants and greenhouse gases from the entire production, distribution, and lifecycle of sugarcane ethanol from 2000 to 2008."
    • "The estimated pollutants were 1.5 to 7.3 times higher than those from satellite-based methods, according to lead author Elliott Campbell of the University of California, Merced."[24]
  • CARB releases 2011 LCFS review report, 22 December 2011 by Ethanol Producer Magazine: "The California Air Resources Board has completed the first required formal review of the state’s Low Carbon Fuel Standard, a regulatory program that requires stakeholders to reduce the carbon intensity (CI) of fuels sold within its borders each year until reaching a 10 percent reduction by 2020."
    • "The reduction was modest—just .25 percent—and CARB concluded that there has been no change in the state’s air quality since the program was implemented."
    • "At issue for Midwest ethanol producers in particular is the inclusion of indirect land use change (ILUC) in the methodology used by CARB to calculate a fuel’s CI."
    • "In the report, CARB said that while the inclusion of ILUC in its model could make it more difficult to harmonize the LCFS with other regional emissions programs that do not require ILUC calculations, it does not plan to alter its program at this time."
    • "It will also not consider any changes to the CI values on a set schedule, but rather will evaluate new information as it becomes available."[25]
  • Call for an effective implementation of the Indirect Land Use Change (ILUC) issue in the EU biofuels policy, 21 December 2011 by E-Energy Market: "A group of companies, trade associations and NGOs have send a letter to the commission that a practical and effective solution are needed to address the ongoing debate about Indirect Land Use Change (ILUC) in European biofuels policy."
    • "The group warns that it blocks 1)Meeting EU renewables targets, 2)Helping to deliver energy security, 3)Fostering rural economic development and, 4)Developing a sustainable bioenergy system that can help towards decarbonising transport in Europe and beyond."
    • "The companies also fear the ILUC policy is counterproductive in its exclusion of certain feedstocks. The effects of banning one feedstock would lead to an increased demand of the alternative feedstock and herewith increasing the need for land."
    • "The group claims that none one of policy options being assessed encourage producers to adopt additional practices that reduce ILUC risks, nor do they improve investor confidence for biofuel development."[26]
  • IFPRI report criticised for inaccuracies, 20 December 2011 by Biofuels International: "The German biofuels association UFOP has dismissed claims in a new report carried out by the International Food Policy Research Institute (IFPRI) into the predicted emissions to be created by indirect land use change policy."
    • "The UFOP says it opposes the adoption of ILUC factors specific for biofuels outlined in the report and says more investment protection needs to be given for existing biodiesel production plants around Europe."
    • "The report, which was published in November 2011 after the European Commission asked for more research to be conducted into ILUC, says proposed European biofuels mandates are 'likely to cause significant indirect land use change emissions'."[27]
  • Growth Energy: Let’s base energy policy on reality, 8 December 2011 by Growth Energy: "Though we’ll always believe in Santa Claus, it’s time to finally put the Indirect Land Use Change (ILUC) myth to bed."
    • "For a long time, the facts simply haven’t matched the rhetoric surrounding this theory, which claims that growing grains for biofuel production displaces other crops, leading to deforestation."
    • "...[C]heck out today’s story from Reuters showing that deforestation in Brazil’s Amazon region fell to its lowest in 23 years this past July, as ethanol production in that country and across the world continued to grow."
    • "Despite the fact that ILUC is untested, highly disputed and clearly detached from reality, an ILUC penalty was included in the Energy Independence and Security Act of 2007. That means that corn-based ethanol cannot be considered an 'advanced biofuel,' even though it fits the bill in other aspects."
    • "It’s time to stop basing out nation’s energy policies on fairytales. The stakes are too high."[28]

  • OSU study questions cost-effectiveness of biofuels and their ability to cut fossil fuel use, 29 November 2011 press release by OSU: "A new study by economists at Oregon State University questions the cost-effectiveness of biofuels and says they would barely reduce fossil fuel use and would likely increase greenhouse gas emissions."
    • "Biofuels were initially seen as a solution to energy and environmental problems, [the lead author of the study, Bill Jaeger said], because the carbon dioxide that's emitted when they're burned is equivalent to what they had absorbed from the atmosphere when the crops were growing. Thus, biofuels were assumed to add little or no carbon dioxide to the atmosphere."
    • "But the bigger picture is more complex, Jaeger said, in part because biofuels are produced and transported using fossil fuels. For example, nitrogen fertilizer, which is made using natural gas, is used to grow corn for ethanol. Additionally, growing biofuel feedstocks can push food production onto previously unfarmed land, according to well-documented research, Jaeger said. When this new acreage is cleared and tilled, it can release carbon that accumulated over long periods in soil and vegetation, thus increasing greenhouse gas emissions, he said."
    • "'Each dollar spent on energy improvement programs would be 20 times more effective in reducing fossil fuel use and greenhouse gas emissions than a similar cost for the corn ethanol program,' Jaeger said. 'Likewise, a gas tax increase would be 21 times more effective than promoting cellulosic ethanol.'"[29]
    • Download the study, Biofuel Economics in a Setting of Multiple Objectives and Unintended Consequences.
  • Indirect Land Use Change and Biofuels: Real or Hypothetical?, 17 November 2011 by Center for a Livable Future: "While increased food prices is the most contentious of the many controversies surrounding the rapid increase in ethanol production from corn, the increase in greenhouse gas emissions from what is termed 'indirect land use change' (ILUC) ranks a close second in the debates."
    • "In a September 2010 briefing Transport and Environment, a pan-European association with scientific and educational aims, summarized the findings of numerous EU, US and UN agencies relative to ILUC. They concluded:
      • "'The RED (Renewable Energy Directive) and the FQD (Fuel Quality Directive) include a legislative mandate for the Commission to produce a proposal for including the emissions from indirect land use change. There is clearly an overwhelming body of scientific evidence revealing the appropriateness and the urgency of addressing these known but as yet unaccounted sources of GHG emissions. The Commission should therefore use the best available science to propose a robust ILUC factor, which is the only short and medium term measure that would send a market signal to biofuels producers and drive sustainable development of the industry.'"
    • "However this overwhelming scientific evidence is under attack in a manner similar to that conducted on the science of other issues that affect industry, such as climate change...."
    • "...ILUC as an abstract concept has been fodder for the anti-science lobbyists. And they have thrown much confusion into the debate to convince policymakers that the connection is weak."
    • "But when the foreign direct investment in land to grow fuel and food largely for export is the issue, ILUC comes alive. The debate must not be allowed to die. Biofuels that use food crops, particularly corn ethanol, are in fact adding a large extra load of carbon dioxide because of their [effects on] food prices."[30]
  • EU biofuel target seen driving species loss: study, 16 November 2011 by Reuters: "A European Union target to promote the use of biofuels will accelerate global species loss because it encourages the conversion of pasture, savanna and forests into new cropland, EU scientists have warned."
    • "The finding raises fresh doubts over the benefits of biofuels, which were once seen as the most effective way of cutting road transport emissions, but whose environmental credentials have increasingly been called into question."
    • "The scale of species loss in areas converted into new cropland could be more than 80 percent, the scientists from the European Commission's Joint Research Center (JRC) said in a newly published report."
    • "One of the report's authors stressed that the finding was based on a preliminary analysis of the issue and that more research was needed to accurately quantify the likely impact on biodiversity caused by the EU's biofuel mandate."
    • "Modeling exercises carried out by IFPRI and others have also suggested that the land use impacts of the EU target -- both direct and indirect -- could wipe out most of the predicted emissions saving from biofuels."[31]
  • Indirect land use change in Europe: Considering the policy options, 16 November 2011 by the International Council on Clean Transportation: "The European Commission recently released updated results of modelling by the International Food Policy Research Institute of the likely indirect effects of the EU’s biofuels mandate."
    • "We critically assess this work, concluding that while there are inevitably areas that could be improved with further development it is a robust study and representative of best practice in the field of CGE modelling of iLUC."
    • "Based on a simple spreadsheet model of available biofuel feedstocks and pathways under various policy alternatives, and treating the IFPRI MIRAGE modelling results as the best available evidence, we show that without action on iLUC there are unlikely to be significant (if any) net emissions reductions from European biofuel support policies."
    • "We find that the introduction of iLUC factors, or of policies that otherwise prevented the use of the highest iLUC fuels (biodiesel from unused vegetable oil), would increase the expected carbon savings of the policy by a factor of ten, but note that it might be challenging to meet the current level of aspiration for total energy use with such strong policies."[32]
  • EU biofuels industry in denial over CO2 error, 15 November 2011 by Commodities Now: "The European Union wants bio-energy use to rise by more than half by 2020 arguing that the energy source is carbon neutral: the trouble is it isn't, and the target should in fact be scrapped."
    • "Yet carbon emissions from burning bio-energy are actually often higher than for fossil fuels, while being deemed zero carbon under emissions trading rules and low-carbon in renewable energy targets."
    • "A European Environment Agency (EEA) panel of scientists two months ago in a note said: 'The potential consequences of this bioenergy accounting error are immense'."
    • "The error originally arose in the 1992 U.N. Climate Convention where bio-energy emissions were categorised under land use instead of energy, says Princeton University's Timothy Searchinger."
    • "But under Kyoto, countries didn't have to account for land-use emissions in their emission targets, and so CO2 from bio-energy disappeared from such accounting altogether."
    • "So while bio-energy from plants still has a role as an alternative energy source, it should not be supported in renewable or low-carbon targets any more than fossil fuels. It does makes sense to continue to support making energy from waste products including food, animal and sawmill waste."[33]
  • Solving ILUC by Thinking Out of the Box, 15 November 2011 by Ethanol Producer Magazine: "Assuming ILUC [indirect land use change] could occur, policymakers should go for measures that will not cause this leakage effect. They should go for a win-win situation and promote biofuels whilst, at the same time, adopting measures that promote only those biofuels without a high risk of unwanted land use changes."
    • "A consortium of nongovernmental organizations and industry was formed earlier this year to confront policy makers with this more positive, incentive-based approach. The partners, including Shell, Neste Oil, Riverstone Holdings LLC, the International Union for Conservation of Nature, Partners for Euro-African Green Energy and ePURE, commissioned Ernst & Young to study a policy approach that incentivizes ILUC-mitigation practices and supports best practices in the production of biofuels and crops for biofuels."
    • "All the policy options being studied by the European Commission have serious drawbacks. None encourage producers to adopt practices that reduce ILUC risks, nor do they improve investor confidence for biofuel development. By assigning a carbon credit to biofuels that prevent or reduce the risk of ILUC, Ernst & Young suggest, financial value can be created to incentivize the adoption of practices that prevent or mitigate ILUC."[34]
  • German biofuels industry disagrees with EU law changes, 7 November 2011 by Argus Media: "Germany's oilseed association Ufop is opposing changes to EU legislation that are set to address indirect land use change effects (ILUC) caused by biofuels production."
    • "Ufop calls instead for investment protection for all existing biodiesel production plants. The volume for existing production plants by EU member states would total about 10mn t of biodiesel, based on sales volume between 2008-10."
    • "Only volumes in excess of that traded within the EU would have to come from so-called ILUC-free acreage, Ufop said."
    • "Biofuels producers argue that so-called ILUC mitigation factors currently under consideration by the EU could put an end to the European biodiesel industry, as it introduces excessive bad points for greenhouse gas (GHG) production starting in 2017."
    • "Ufop and other industry associations — including the EBB — have previously expressed concern that a report from the International Food Policy Research Institute (IFPRI), which the EBB alleges uses flawed methodology and exhibits an anti-biodiesel bias, is unduly influencing the European Commission's thinking on a methodology for measuring the ILUC impact of biofuels cultivation."[35]
  • Study Suggests EU Biofuels Are As Carbon Intensive As Petrol, 5 November 2011 by "A new study on greenhouse gas emissions from oil palm plantations has calculated a more than 50% increase in levels of CO2 emissions than previously thought – and warned that the demand for 'green' biofuels could be costing the earth."
    • "Biodiesel mandates can increase palm oil demand directly (the European Biodiesel Board recently reported big increases in biodiesel imported from Indonesia) and also indirectly, because palm oil is the world's most important source of vegetable oil and will replace oil from rapeseed or soy in food if they are instead used to make biodiesel."
    • "They concluded that a value of 86 tonnes of carbon dioxide (CO2) per hectare per year (annualised over 50 years) is the most robust currently available estimate; this compares with previous estimates of around 50 tonnes of carbon dioxide (CO2) per hectare per year."
    • "CO2 emissions increase further if you are interested specifically in the short term greenhouse gas implications of palm oil production – for instance under the EU Renewable Energy Directive which assesses emissions over 20 years, the corresponding emissions rate would be 106 tonnes of carbon dioxide (CO2) per hectare per year."[36]
  • Tanzania: Rising Food Prices Affect Biofuel Projects, 24 October 2011 by "United States Department of Agriculture Chief Advisor for Government, Academia and Industry Partnership, Cindy Smith and Deputy Coordinator for Feed the Future Initiative, Tjada McKenna argued last week that use of corn in biofuel manufacturing to drive vehicles consumes less than one per cent of the country's annual production."
    • "Both the US and EU adopted energy policies between 2008 and 2010 which targets to source up to 20 per cent of their energy needs from renewable sources."
    • "In its recent report titled, 'Meal per gallon,' an international charity, ActionAid estimated that the EU plan to source 10 per cent of transport fuels from biofuels would increase competition for agricultural lands and spur a sharp rise in food prices."
    • "The report argues that cropland expansion (17.5 million hectares will be needed in developing countries to meet the EU's 10 per cent target) will come at the expense of tropical forests and peatlands, worsening climate change."[37]
  • Biofuels growth stifled by EU policy delays: BP, 18 October 2011 by Reuters: "Biofuels for use in transport are becoming more competitive compared with oil but the pace of growth has slowed due to a lack of regulation and sustainability standards in Europe, the chief executive of BP's biofuels division said."
    • "'In the UK, biofuels get no tax breaks whatsoever. The biggest obstacle (to biofuel growth) is uncertainty around the future of mandates and clear (European Union) sustainability standards,' Philip New of BP Biofuels told Reuters in an interview on Tuesday."
    • "EU policymakers are currently debating the green credentials of some biofuels and should present proposals for approval by EU governments and lawmakers before the end of the year. However, legislation might not emerge for several years."
    • "Critics say some biofuels production can occupy land that would otherwise be used for agricultural purposes, thus limiting food and water resources for a rapidly rising world population."
    • "Some biofuel production could also increase carbon emissions, especially if rainforests are cut down to facilitate production."[38]
  • Scheme for Mitigating Indirect Land Use Change (ILUC) Risks in the Use of Biofuels Proposed, 14 October 2011 by "The risk associated with 'Indirect Land Use Change (ILUC) Risk' in the production and use of biofuels has been a contentious issue in the assessment of biofuels sustainability."
    • "The European Energy Review website mentions a report published by Ernstand Young, (and commissioned by a consortium of industry/NGO partners) which aimed to: (1) establish the facts surrounding the issue of ILUC by examining existing literature, and (2) investigate 'issues concerning implementation of practical ILUC mitigation measures and their effectiveness in biofuels production'."
    • "The report indicated that 'indirect land use change (ILUC) risks can be mitigated by incentives that encourage existing and additional sustainable practices in biofuels production, as well as other sectors that use agricultural commodities'."
    • "The proposal involves the application of an 'ILUC mitigation credit scheme', which could work alongside with, and remain subject to the existing polices of the EU Renewable Energy Directive."[40]
  • “Not the right time to call for more idle agricultural land,” warns biofuels association, 14 October 2011 by Renewable Energy Magazine: "ePURE is deeply concerned about the European Commission’s plans to set-aside 7% of EU agricultural land as 'ecological focus areas', in effect marking the reintroduction of the EU's set-aside policy."
    • "Initially intended to curb agricultural surpluses, mandatory set-aside has been abolished in 2009 against the backdrop of soaring soft commodity prices. In the light of a global food crisis in 2008, the EU could no longer afford to keep arable land out of production."
    • "This new set-aside proposal comes in addition to the continuous land idling in Europe, which already leads to a substantial loss of agricultural land in the EU."
    • "In parallel the Commission reflects on possible policy measures to hedge against potential indirect land use change (ILUC) effects of biofuels production. As the ILUC debate boils down to the availability of enough arable land to fulfill our needs now and in the future, the proposal shows a clear lack of consistency between the different EU policies."
    • "The solution to both the ILUC debate and the quest for an environmentally more sustainable agriculture lies in the enlargement of the scope of binding sustainability criteria."[41]
  • EU to establish full carbon emissions, 13 October 2011 by IOL Scitech: "The European Union's efforts to establish the full carbon emissions from burning bio-energy is an all but impossible task which illustrates the difficulty of trying to cut humankind's environmental impact, which first has to be measured."
    • "But a fuller measure of carbon emissions is important, even an inaccurate number beats ignoring the issue, especially given the lessons from a related food versus fuel battle which sparked a global backlash against liquid biofuels three years ago"
    • "In a world of limited land and a growing population decisions taken in Europe can cause farmers to wield chainsaws in a tropical rainforest."
    • "Qualification for support payments and numerical targets is conditional on liquid biofuels cutting carbon emissions by at least 35 percent compared with gasoline and diesel under the EU's Renewable Energy Directive, rising to 60 percent from 2018."
    • "But the rule only applies to direct emissions, not so-called indirect land use change (ILUC), where some bio-energy displaces grazing and food crops, driving carbon emissions from causing land to be ploughed up elsewhere."[42]
  • Indirect land use change (ILUC) risks can be mitigated, says E&Y report, 10 October 2011 by Biofuels Digest: "In Belgium, a new report by Ernst & Young indicates that indirect land use change (ILUC) risks can be mitigated by incentives that encourage existing and additional sustainable practices in biofuels production, as well as other sectors that use agricultural commodities."
    • "The report, commissioned by a diverse consortium of industry and NGOs, supports a new policy option that incentivizes land use change mitigation practices and supports best practice and behavioral change in the production of biofuels."
    • "This proposal could be implemented by extending the application of carbon incentives, already established by the Directive for degraded land, to qualifying mitigation measures identified in the report."
    • "ILUC mitigation practices identified by Ernst & Young include the development of advanced generation biofuels, improvements to crop yields on existing agricultural land, the use of co-products for animal feed purposes, and crop production on abandoned lands."[43]
  • Biodiesel industry rejects EU land use impact study, 7 October 2011 by Reuters: "Europe's biodiesel industry rejected the findings of a draft EU study showing that the cultivation of rapeseed to make road transport fuels is worse for the climate than using conventional diesel."
    • "The European Biodiesel Board (EBB) said on Friday the study's central finding -- that the effects of indirect land use to produce most types of biodiesel cancel out any theoretical emissions savings -- was 'highly debatable and unscientific.'"
    • "A series of leaked EU studies showed that biodiesel from European rapeseed, South American soy beans and Asian palm oil all have a greater overall climate impact that normal diesel."
    • "If the Commission follows the advice contained in the studies and penalizes individual biofuel crops on the basis of their estimated ILUC emissions, it could wipe out the bloc's 13 billion euro ($17.5 billion) biodiesel industry overnight."
    • "It would also give a boost to ethanol producers such as Spain's Abengoa and increase the market for fuels derived from Brazilian sugar cane as the EU seeks to fill the 80 percent gap in its biofuel market currently occupied by biodiesel."[44]
  • European biofuels target condemned by leading US scientists, 7 October 2011 by The Guardian: "Over 100 top scientists and economists have written to the European commission calling for indirect land use change (ILUC) to be accounted for in EU biofuels policy making."
    • "The letter, seen by EurActiv, argues that assigning biofuels a zero or 'carbon neutral' emissions value – as the EU has done – 'is clearly not supported by the [best available] science'."
    • "Because of 'flawed' accounting conventions, 'the European Union's target for renewable energy in transport may fail to deliver genuine carbon savings in the real world,' the scientists argue."
    • "Since 2008, EU member states have been obliged to raise the share of biofuels in the energy mix to 10% by 2020."
    • "But recent reports by the European Environment Agency and four other EU agencies have questioned whether meeting the EU's target would cut any CO2 emissions at all."
    • "But because of 'scientific uncertainties,' the Commissioners decided to introduce a contested 'threshold' measurement of CO2 savings until 2018 that would not penalise individual biofuels emissions."[45]
  • Carrots and sticks for sustainable biofuels, 6 October 2011 by IUCN: "In an independent report launched by a consortium of industry and non-governmental organizations, IUCN promotes an innovative policy approach to address the risk of indirect land use change through biofuel production."
    • "'IUCN supports the development of a policy that encourages and rewards practices that reduce the risk of indirect impacts of biofuel production and penalizes producers who take no action,' says Deviah Aiama, IUCN’s Bioenergy Programme Officer. 'These practices include improving crop yields on existing agricultural land, introducing integrated food and fuel cropping systems and the use of wastes and degraded land.'"
    • "IUCN aims to make sure that the use of natural resources for the production of biofuels is equitable and ecologically sustainable, while also taking into account the realities faced by biofuel producers on the ground."
    • "The study was published by Ernst & Young and commissioned by a consortium including IUCN, European Renewable Ethanol Association (ePURE), Partners for Euro-African Green Energy (PANGEA), Riverstone, Shell and Neste Oil."[46]
  • Biofuels may meet development needs of Sub-Saharan Africa, 3 October 2011 by Center for International Forestry Research blog: "Biofuel expansion has enormous potential to stimulate rural development in Sub-Saharan Africa, but ensuring local community benefits and adequate protections for food production and forests will require strategic policy interventions and close collaboration among stakeholders, according to a new study by the Center for International Forestry Research."
    • "Biofuels have been touted as a ‘green’ alternative to fossil fuels, however critics of biofuel production argue that the expansion of biofuel development can often contribute to deforestation."
    • "Moreover, increasing land acquisition for biofuel expansion rather than food production in Africa could undermine food security and exacerbate a number of underlying social issues."
    • "The study urges for increased collaboration between government and the biofuel industry which will ensure that biofuel development can enhance livelihoods by bringing in urgently needed investment in the agricultural sector that would result in improved infrastructure and increased cash income in impoverished rural areas."[48]
  • The International Scientists and Economists Statement on Biofuels and Land Use, October 2011 by Union of Concerned Scientists: "When land used for food or feed production is turned over to growing biofuel crops, agriculture has to expand elsewhere. This often results in new deforestation and destruction of other ecosystems, particularly in tropical regions in the developing world. The resulting heat-trapping emissions from clearing new land can be significant and may outweigh any emissions savings from the use of biofuels. Numerous scientific studies have warned about the unintended climate consequences of the indirect land use changes associated with increased demand for biofuels and the need to address the issue by changing existing biofuel policies."
  • Brussels slammed for bad science on biofuels, 27 September 2011 by Euractiv: "Several environmental NGOs have written to the European Commission President, José Manuel Barroso, demanding action on five scientific studies that question the clean energy benefits of biofuels, as a row over a land use report by the EU's scientific advisors escalates."
    • "...[T]he letter cites five world-class studies for the EU which, it says, all agree that the Indirect Land Use Change (ILUC) effects of biofuels 'could not only negate the expected carbon savings, but even lead to an increase in emissions.'"
    • The most recent, a report by the scientific committee of the European Environment Agency (EEA) slammed the official EU policy that biofuels are 'carbon neutral' as a 'serious accounting error' with 'immense' potential consequences."
    • "The letter's signatories include ActionAid, Birdlife, ClientEarth, European Environmental Bureau, Oxfam, Transport and Environment and Wetlands International."
    • "The science involved in the report is of crucial importance. On Page 8, the EEA report cites the IEA as saying that biofuels could provide 20% of the world’s energy by 2050, and the UNFCCC claiming that bioenergy could supply 800 exajoules of energy per year (EJ/yr)."
    • "But today's entire global cultivatable land for food, feed, fibre and wood only has a chemical energy value of 230 (EJ/yr), just over a quarter of that figure."[50]
    • Download the NGO letter (PDF file)
  • Questioning Europe's Math on Biofuels, 25 September 2011 by The New York Times: "Much of the appeal of generating energy from plants was that they emit only as much carbon when burned in cars and power plants as they absorb while growing."
    • "It turns out that the emissions from growing and processing some biofuels significantly diminish their benefits, when taking into account factors like the use of fertilizers manufactured with fossil fuels."
    • "Concerns have also grown that large swaths of forest and grassland will be chopped down or burned to grow fuel crops — and to grow food that has been displaced by growing fuel crops elsewhere — thereby releasing additional stocks of carbon into the atmosphere."
    • "The Scientific Committee of the European Environment Agency said the European Union had committed a 'serious accounting error' by failing to measure how much additional carbon dioxide was absorbed by existing fields, forests and grasslands, compared with that absorbed by energy crops."
    • "Bioenergy, including the burning of wood to produce electricity, would meet about half of the overall renewable energy target under national plans, while biofuels would provide the majority of renewable transport fuels."[51]
  • Commission to fudge CO2 effects of biofuel, 22 September 2011 by "The European Commission has rejected the advice of its scientific experts and backed away from imposing tough carbon-dioxide emissions standards on specific types of biofuel."
    • "Günther Oettinger, the European commissioner for energy, and Connie Hedegaard, the European commissioner for climate action, are poised to propose instead a cruder environmental standard, that all biofuel sold in the European Union will have to produce carbon-dioxide savings of 50% compared with fossil fuel."
    • "Different types of biofuel have different ILUC effects, which means that their environmental performance varies, sometimes widely."
    • "Only this week, a scientific committee of the European Environment Agency, an EU body charged with providing advice to the EU institutions, warned that to assume that using biomass as an energy source was carbon neutral was 'a serious accounting error'."
    • "But the commissioners have now agreed to postpone action until 2014, the last year of the mandate of the current Commission. Only then will they make their proposals to attach specific CO2 values to each type of biofuel – deferring any impact from new measures until 2016 at the earliest."[52]
  • EU to delay action on biofuels' indirect impact, 8 September 2011 by Reuters: "The European Union's top climate and energy officials have agreed to delay by up to seven years rules that would penalize individual biofuels for their indirect climate impacts, details of the deal showed."
    • "The political compromise is designed to protect EU farmers' incomes and existing investments in the bloc's 17 billion euro-a-year ($24 billion) biofuel sector, while discouraging new investments in biofuels that do nothing to fight climate change."
    • "At issue is an emerging concept known as indirect land use change (ILUC), which states that if you divert food crops to biofuel production, someone, somewhere, will go hungry unless those missing metric tons of grain are grown elsewhere."
    • "If the crops to make up the shortfall are grown on new farmland created by cutting down rainforests or draining peat land, this can release enough climate-warming emissions to cancel out any theoretical emission savings from biofuels."
    • "The July agreement would delay crop-specific rules on ILUC in favor of an indirect approach that penalizes all biofuels equally."
    • "This involves raising the carbon-savings threshold that all biofuels must meet compared with conventional fossil fuel to count toward the EU's target, which aims to raise the share of biofuel in road transport fuels to about 10 percent in 2020."
    • "By sending a clear message that ILUC factors will be introduced in the future, the Commission said its approach would help to 'phase out the worst performing biofuels and to prevent further investments in unsustainable biofuels.'"
    • "The Commission is expected to present formally its ILUC proposals in the coming months, after which EU governments and the European Parliament will have a limited time in which to raise any objections."[53]
  • Rethinking Life-Cycle Fuel Regulations, 20 August 2011 by Forbes: "In the most recent issue of Climatic Change, one of the resident geniuses that populate the faculty of the University of Michigan School of Natural Resources and Environment, Dr. John DeCicco, argues that attempting to regulate fuels using a lifecycle analysis (LCA)-based approach—as is currently done by California’s Low Carbon Fuel Standard and the U.S. Renewable Fuel Standard—is an exercise in futility for purposes of gaging environmental effectiveness."
    • "Instead, in 'Biofuels and carbon management,' DeCicco proposes a method using annual basis carbon (ABC) accounting to track the stocks and flows of carbon and other relevant greenhouse gases (GHGs) throughout fuel supply chains."
    • "ABC accounting would avoid an automatic credit of biogenic carbon in biofuels, and minimize and accumulation of carbon debt due to indirect land-use change, he says."
    • "Upon reflection, policy is best defined using current-period accounting of carbon stocks and flows, ideally with direct, measurement-based, verifiable tallies of GHG emissions from the production and use of all fuels and feedstocks."[55]
  • ILUC and the Food Versus Fuel Paradox, 11 August 2011 by Biomass Hub: "Indirect land use change (ILUC) is based on the premise that there may be unintended consequence associated with the expansion of croplands for ethanol or biodiesel production in response to increased global demand for biofuels, including the destruction of “virgin” lands and a corresponding release of carbon emissions."
    • "The ILUC backlash is inimical to the global expansion of biofuels as a traded commodity, as was seen in the EU’s most recent debate during a rework of its Renewable Energy Directive."
    • "Managing public perception, and more importantly, expectations, is key to expanding biofuels production worldwide to offset a much more worrisome public policy issue, petroleum dependence."
    • "Like ILUC, the food versus fuel debate exploded on the scene in 2008 as food prices around the world skyrocketed. In truth, the causes are complex and attributed to a web of factors. To attribute increases in food prices to the use of biofuels alone is both misleading and irresponsible."
    • "As we transition into the “Post Oil Age,” the ILUC and food versus fuel debates continue to constrain progress towards more sustainable fuels made from biomass. Although not necessarily a bad thing in all cases, the debate obscures the reality that all biofuels are not created equal."[56]
  • EBB slams EU thinking on biofuel land use impacts, 5 August 2011 by Argus Media: "Europe's biodiesel producers have commissioned an independent review of a policy document on biodiesel's indirect effects on land use change, which the European Biodiesel Board (EBB) maintains has skewed the European Commission's thinking on the subject to the detriment of the European biodiesel industry."
    • The commission has yet to define its methodology for gauging the possibility that diverting additional land to agriculture to feed biofuels demand could be increasing carbon emissions, an issue commonly referred to by the acronym ILUC. But several reports commissioned by the EU, which were subsequently leaked, have suggested incorporating ILUC into carbon calculation methodologies could have a negative impact on biodiesel made from virgin vegetable oils."
    • "In particular, EBB criticises [an] IFPRI report for underestimating the positive impact of increased oilseeds production in increasing animal feed production, containing flawed calculations on the amount of substitution between vegetable oils — which occurs in the EU market — and failing to include improvements in agricultural productivity among its calculations."
    • "EBB has commissioned Dr Don O'Connor of (S&T)² Consultants and Professor Gernot Klepper of the Kiel Institute for World Economy, to perform a critical review of the IFPRI study. The EBB expects to present its findings in September, when the college of commissioners will consider the findings of the commission's ILUC impact assessment. "[57]
  • EU gets tough on dirty biofuel, pledges more action, 19 July 2011 by Reuters: "Europe's energy chief announced seven green certification schemes for biofuels on Tuesday and promised in future to tackle the unwanted side-effects of turning food into fuel."
    • "Guenther Oettinger said biofuels' indirect impacts were dangerous for the planet's carbon balance and food supply."
    • "The European Union agreed three years ago to get 10 percent of its road fuels from biofuels -- at a time when such fuels were widely regarded as good for the environment -- but since then controversy has raged in Europe over the target."
    • "Oettinger took a first step toward limiting biofuels' impact on the environment on Tuesday, launching a green standard to prevent companies from clearing forest, peatlands or grassland to grow biofuels for the European market."
    • "Critics say the EU's biofuel target creates an incentive for farmers to hack directly into forests to create space to grow fuel crops -- known as direct land use change."
    • "But they also charge that even biofuel crops planted in Europe can send shock waves through global food markets and indirectly promote deforestation -- indirect land use change."
    • "Recent research shows that when more food is needed, the majority of new farmland, possibly as much as 80 percent, comes from burning down forests."[58]
  • Analysis: EU cushions biodiesel from damning carbon research, 15 July 2011 by Reuters: "The EU will protect existing investment in its $13 billion biodiesel sector even as it acts on new evidence that suggests making the fuel from food crops can do more harm than good in fighting climate change."
    • "The reports said using Asian palm oil, South American soybeans and EU rapeseed to make biodiesel has a bigger overall impact than conventional diesel on climate change, partly due to forests or wetlands being destroyed to grow replacement food."
    • "European Union policymakers are preparing a political compromise that will safeguard existing biodiesel investments, having baulked at penalizing individual biofuel crops."
    • "With biodiesel representing about 80 percent of Europe's estimated $17 billion market for biofuels and the bloc dependent on diesel imports to meet rising demand, the officials agreed to delay any action that could kill off the biodiesel sector."
    • "The dilemma facing EU policymakers concerns a relatively new concept known as indirect land-use change (ILUC), which challenges the notion that biofuels only emit as much carbon when burned as they absorbed during growth."[59]
  • Climate impact threatens biodiesel future in EU, 8 July 2011 by Reuters: "Europe's world-leading $13 billion biodiesel industry, which has boomed in the wake of a decision by Brussels policymakers in 2003 to promote it, is now on the verge of being legislated out of existence after the studies revealed biodiesel's indirect impact cancels out most of its benefits."
    • "The EU has been arguing for two years over the extent of indirect damage to the environment caused by it setting a target of increasing biofuel use to 10 percent of all road fuels by 2020, from less than three percent today."
    • "Its own analysis shows the target may lead to an indirect one-off release of around 1,000 megatonnes of carbon dioxide -- more than twice the annual emissions of Germany."
    • "Biofuels were once seen as a silver bullet for curbing transport emissions, based on a theory that they only emit as much carbon as they absorbed during growth."
    • "But that has been undermined by a new concept known as 'indirect land-use change' (ILUC), which scientists are still struggling to accurately quantify."
    • "'The experts unanimously agreed that, even when uncertainties are high, there is strong evidence that the ILUC effect is significant,' said the report from the Commission's November workshop."
    • "Biodiesel from Asian palm oil, South American soy beans, and EU rapeseed all had a bigger overall climate impact than conventional diesel, said a fourth leaked document."
    • "'Ethanol feedstocks have a lower land use change effect than the biodiesel feedstocks. For ethanol, sugar beet has the lowest land use emission coefficients,' said [an] IFPRI report."
    • "The Commission's impact analysis predicts EU demand for biodiesel will collapse if their indirect impacts are taken into account in EU legislation. But at the same time it sees a sharp rise in demand for bioethanol from cereal crops and sugarcane, as well as advanced biodiesel produced from algae."[60]
  • Another analysis NOT disproving ILUC, 24 May 2011 blog post by Nathanael Greene on the NRDC Switchboard blog: "The latest paper on indirect land-use change is getting a lot of press, but unfortunately does not, as some have claimed, prove that the ILUC doesn't exist or isn't happening."
    • "[Authors] Kim and Dale have asked and answered the wrong question. You can't detect ILUC by just looking at where we are today or by comparing where we are to an historical baseline."[61]
  • Statistical confirmation of indirect land use change in the Brazilian Amazon, 24 May 2011 by Eugenio Y Arima, Peter Richards, Robert Walker and Marcellus M Caldas in Environmental Research Letters; from the Abstract:
    • "Expansion of global demand for soy products and biofuel poses threats to food security and the environment. One environmental impact that has raised serious concerns is loss of Amazonian forest through indirect land use change (ILUC), whereby mechanized agriculture encroaches on existing pastures, displacing them to the frontier. This phenomenon has been hypothesized by many researchers and projected on the basis of simulation for the Amazonian forests of Brazil....The present article [utilizes] a spatial regression model capable of linking the expansion of mechanized agriculture in settled agricultural areas to pasture conversions on distant, forest frontiers. In an application for a recent period (20032008), the model demonstrates that ILUC is significant and of considerable magnitude. Specifically, a 10% reduction of soy in old pasture areas would have decreased deforestation by as much as 40% in heavily forested counties of the Brazilian Amazon...."[62]
  • New Study Shows No Bond Between Land Use Changes and Biofuels, 16 May 2011 by Hoosier Ag Today: "Researchers at Michigan State University used historical data on U.S. croplands, commodity grain exports and land use trends to see if there was a link between indirect land use change (ILUC) and biofuels expansion through 2007. They concluded that U.S. biofuel production has not provoked ILUC, saying crop intensification may have absorbed the effects of expanding biofuels production or the effects of production expansion may be negligible within the accuracy of the data. This conclusion is similar to that of a recent conclusion made by the U.S. Department of Energy’s Oak Ridge National Laboratory, which says ILUC as a result of corn ethanol expansion during the past 10 years has been minimal to zero."[63]
  • Analysis: Bioethanol may win in crunch time for EU biofuels, 13 May 2011 by Reuters: "After a two-year investigation, the European Commission has decided that the complex issue of 'indirect land use change' (ILUC) can lessen carbon savings from biofuels."
    • "The battle over ILUC has poured doubt on the security of any new investments, but that could be ended this summer when the Commission announces moves to curb the least sustainable."
    • "EU sources involved in the debate say a ranking is starting to emerge, giving the cleanest credentials to advanced bioethanol from farming residues such as straw. Next comes bioethanol from sugar beet and sugar cane, followed by the most efficient bioethanol from wheat."
    • "The Commission's new evidence will also create pressure to speed up the adoption of next-generation biofuels from agricultural residues such as straw, which do not compete with food and therefore do not create ILUC."[64]
  • Europe's biofuel dispute splits the industry, 3 May 2011 by Reuters: "After a two-year investigation, the European Commission has decided that the complex issue of "indirect land use change" (ILUC) can lessen carbon savings from biofuels. In July it may announce moves to curb the least sustainable -- possibly by raising an EU-wide sustainability benchmark."
    • "The battle over ILUC has thrown into doubt EU plans to create a $17 billion annual market for biofuels from producers such as France, Germany, Brazil, Malaysia and Indonesia."
    • "Some in the biofuels industry argue that the science is flawed and that the issue could be tackled by a major overhaul of agricultural strategy to improve productivity or by pressing abandoned farmland back into action."[65]
  • European ethanol, ag sectors unite in criticizing ILUC modeling, 3 May 2011 press release by ePURE in Ethanol Producer Magazine: "At a jointly hosted conference on May 3 in Brussels, the European Renewable Ethanol Association (ePURE) and European farmers body Copa-Cogeca joined forces to criticize European Commission plans to introduce an ILUC factor for biofuels."
    • "At the meeting, organized to examine the commission’s current thinking on indirect land use change (ILUC), both organizations urged the EC to step back from considering introducing unwarranted and punitive measures on the European ethanol and farming sector. In a December 2010 communication, the commission suggested that it may introduce an ILUC factor in regulations which ePURE and Copa-Cogeca would render the European biofuel industry unviable."
    • "The focal point of the Brussels meeting was a set of well-researched presentations by several ILUC experts. These experts all agree that the current modeling is simply not adequate as a basis for good policy-making...."[66]
  • Recent developments of biofuels/bioenergy sustainability certification: A global overview , March 2011 by ScienceDirect:
    • From the abstract: "A large number of national and international initiatives lately experienced rapid development in the view of the biofuels and bioenergy targets announced in the European Union, United States and other countries worldwide. The main certification initiatives are analysed in detail, including certification schemes for crops used as feedstock for biofuels, the various initiatives in the European Union, United States and globally, to cover biofuels and/or biofuels production and use....The effects of biofuels/bioenergy production on indirect land use change (ILUC) is still very uncertain; addressing the unwanted ILUC requires sustainable land use planning and adequate monitoring tools such as remote sensing, regardless of the end-use of the product."[69]
  • Midwest senators strike back with pro-biofuels bill, 11 March 2011 by Ethanol Producer Magazine: "The Securing America’s Future with Energy and Sustainable Technologies Act, introduced by Sens. Amy Klobuchar, D-Minn., and Tim Johnson, D-S.D., would establish incentives for biofuels infrastructure and deployment, develop a 'more cost-effective' tax credit program for ethanol and biodiesel, establish a renewable energy standard and encourage greater production of hybrid, electric and flex-fuel vehicles (FFVs)."
    • "The legislation also includes text that would prevent the U.S. EPA from considering international indirect land use changes when calculating biofuels’ lifecycle greenhouse gas (GHG) emissions and calls for the National Academies of Science to conduct a review of methodologies used to project indirect GHG emissions relating to transportation fuels."[71]
  • IFPRI Publishes Study on the EU Biofuels Mandate, March 2010 by The International Food Policy Research Institute: "The report is one of four commissioned by the European Commission to assess the impacts of the 10% target for the use of renewable energy in road transport fuels by 2020."
    • "The study uses a global general equilibrium model, separately including numerous first generation ethanol and biodiesel feedstocks, co-generated products, farming techniques, as well as direct, and indirect land-use changes (ILUC) resulting from the mandated increase in consumption of biofuels. Additionally, as the model is global, it also considers different multi- and bilateral trade scenarios."
    • "The results indicate that there is ILUC associated with the EU mandate, but that the mandate will still result in global greenhouse gas (GHG) emission savings of nearly 13 million tons over 20 years. Additionally, the authors find that the mandate will have only a negligible effect on food prices and, concerning biodiesel, even with ILUC taken into account, imported palm oil remains as efficient as European rapeseed."[75]

Key issues

Comparison with Fossil Fuel Baseline

  • Land Use Greenhouse Gas Emissions from Conventional Oil Production and Oil Sands (PDF file) - by Sonia Yeh et. al. in Environmental Science & Technology, October 2010. From the Abstract: "Debates surrounding the greenhouse gas (GHG) emissions from land use of biofuels production have created a need to quantify the relative land use GHG intensity of fossil fuels...Although emissions released from land disturbed by fossil fuels can be comparable or higher than biofuels, the energy yield of oil production is typically 2-3 orders of magnitude higher...."



Time horizons

Related organizations

Reports and resources


General reports

November 2010 YouTube video, "Mitigating the
risks of indirect landuse change from biofuels" by IUCN.

  • Greenhouse Gas Accounting: Lifecycle Analysis of Biofuels and Land Use Change by John A. Miranowski for the Organisation for Economic Co-operation and Development [OECD], 23 April 2012. "By definition, an LCA [lifecycle analysis] is a comprehensive accounting of all the energy inputs into the process and outputs out of the process, including GHG and other emissions. Ideally, sustainability should be incorporated into the system. Others have argued that increased GHG emissions in the biofuel system from global LUC [land use change] should be included in the LCA for biofuel as well."
    • "The high level of uncertainty created by model incompatibility and by aggregate agricultural models not capable of capturing necessary refinements in LUC and agricultural management practices has led to two positions on including indirect LUC in LCA models. First, we know that indirect LUC and associated GHG emissions are not zero, so we are doing a disservice to society by not including them in LCA estimates, even though the “confidence interval” is extremely wide (Hertel et al., 2010). Second, we do not have the tools to obtain a reasonably accurate estimate of the GHG emission effects of indirect LUC, and we are doing a disservice by trying to measure the unmeasurable (Babcock, 2009b)."
    • "Although there are a number of qualifiers, the same LCA model should be used to derive GHG

emission estimates when comparing different feedstocks or different fuels since cross-model comparisons simply highlight model differences (i.e., it is important to create a stable market environment when comparing fuels). Yet, in order to provide a complete understanding of the sensitivity of LCA results and policy impacts to model assumptions, it is important to consider alternative LCA models (and assumptions)." [[77]

  • Reconciling top-down and bottom-up modelling on future bioenergy deployment by Felix Creutzig, Alexander Popp, Richard Plevin, Gunnar Luderer, Jan Minx & Ottmar Edenhofer, March 2012. "The Intergovernmental Panel on Climate Change's Special Report on Renewable Energy Sources and Climate Change Mitigation (SRREN) assesses the role of bioenergy as a solution to meeting energy demand in a climate-constrained world. Based on integrated assessment models, the SRREN states that deployed bioenergy will contribute the greatest proportion of primary energy among renewable energies and result in greenhouse-gas emission reductions."
    • "The report also acknowledges insights from life-cycle assessments, which characterize biofuels as a potential source of significant greenhouse-gas emissions and environmental harm. The SRREN made considerable progress in bringing together contrasting views on indirect land-use change (ILUC) from inductive bottom-up studies, such as life-cycle analysis, and deductive top-down assessments. However, a reconciliation of these contrasting views is still missing. Tackling this challenge is a fundamental prerequisite for future bioenergy assessment." [78]
  • The dilemma of indirect land-use changes in EU biofuel policy – An empirical study of policy-making in the context of scientific uncertainty by Lorenzo Di Lucia, Serina Ahlgren and Karin Ericsson, 2011. "The potential impact of policies promoting transport biofuels on the use of land due to the indirect effects of feedstock cultivation has generated a controversy in the EU. Policy-makers are urged to regulate the matter without conclusive scientific evidence concerning the scale and severity of indirect land-use change (iLUC). By looking at this situation as an instance of policy making in the context of scientific uncertainty, this study analyses ways to deal with iLUC of biofuels policies learning from policy fields where similar dilemmas were confronted in the past. The experience with technologies such as genetically modified organisms, carbon capture and storage, nuclear power and radioactive waste, and transport biofuels is instructive for this purpose. Policy approaches identified in the case studies are applied to the case of iLUC."
  • A review of environmental issues in the context of biofuel sustainability frameworks by M.R. Guariguata, O.R. Masera, F.X. Johnson, G. von Maltitz, N. Bird, P. Tella, R. Martínez-Bravo, 2011. "This report examines how the most developed sustainability frameworks for feedstock production (including biofuels) address key environmental issues. It identifies critical gaps in these frameworks and proposes areas for improvement. The main finding is that the frameworks share broad sustainability principles yet they differ greatly in terms of their comprehensiveness and how they apply specific indicators for environmental issues, particularly with respect to land use change (both direct and indirect), allocation of degraded land for feedstock cultivation, and related accounting of greenhouse gas emissions."
  • Biofuel Policies and Indirect Land Use Change (PDF File), November 2011 by Ruth Delzeit and Mareike Lange for Kiel Institute for the World Economy.
    • From the Abstract: "We start with a discussion how iLUC could be reduced for the whole EU biofuel mandate by theoretically demonstrating the mechanism of the minimum emission saving threshold on the amount of land used to fulfil the mandate. In the next section, we shortly present the requirements to model iLUC, which is followed by a discussion on how model results can help to concretise iLUC policies. Finally, we relate modelling results to iLUC policy options of the EU and draw conclusions and policy advice."
  • Technical Report for the ICCT: Empirical Evidence on Crop Yield Elasticities (PDF Files), August 2011 by Steven Berry and Wolfram Schlenker for International Council on Clean Transportation.
    • From the Abstract: "If higher prices drive higher crops yields, the amount of indirect land use associated with biofuel production will be reduced. In general, indirect land use change will be larger the larger the land-price elasticity and the lower the yield-price elasticity. Our report provides direct empirical evidence on crop yield-price (and land-price) elasticities. These are critically important quantities in any attempt to simulate the effect of the massive bio-fuel policies that are presently implemented and/or under consideration around the world."
  • Regional level actions to avoid ILUC, June 2011 by Department of Transport.
    • From the Abstract: "The increasing use of biofuels internationally introduces the risk that crops grown for biofuel use on existing farmland displace crops grown for other uses, increasing the pressure to clear new land for agriculture. This knock-on effect is known as Indirect Land Use Change (ILUC). This report considers the potential to reduce the risk of ILUC by actions taken at a regional level, for example by a region with a country, a national government or an international body such as the European Union."
  • The iLUC dilemma: How to deal with indirect land use changes when governing energy crops?, 8 April 2011 article in Land Use Policy by Erik Gawel and Grit Ludwig. From the abstract: "[B]ioenergy policies worldwide face a dilemma: Neglecting iLUC effects that do in fact exist or taking them into account although no sound methodology is available? The article covers the current state of the discussion and also analyses the approaches developed for taking indirect land use change into account. Assessment criteria for coping with the iLUC dilemma are developed and policy recommendations are derived from that."
  • Report of the Shell‐IUCN Indirect Land Use Change Workshop (PDF file), report of the meeting held 21‐22 September 2010, Chatham House, London: "The workshop produced 4 outcomes:
    • I) A framework to enable the selection of viable iLUC mitigation measures, in the form of success criteria;
    • II) Indicative list of potentially viable iLUC mitigation options;
    • III) Success criteria for effective iLUC mitigation policy; and
    • IV) Indicative list of iLUC mitigation policy options."
  • Biofuels: indirect land use change and climate impact (PDF) June 2010 by H.J. Croezen, G.C. Bergsma, M.B.J. Otten and M.P.J. van Valkengoed. "The objectives of this study are to compile the available recent literature on ILUC emissions, compare these emissions with the assumed gains of biofuels, assess how ILUC changes the carbon balance of using biofuels and formulate policies to avoid these extra emissions associated with ILUC."
  • Global land-use implications of first and second generation biofuel targets, April 2010 by Petr Havlík, Uwe A. Schneider, Erwin Schmid, Hannes Böttcher, Steffen Fritz, Rastislav Skalský, Kentaro Aoki, Stéphane De Cara, Georg Kindermann, Florian Kraxner, Sylvain Leduc, Ian McCallum, Aline Mosnier, Timm Sauer and Michael Obersteiner. "In this paper we provide a detailed analysis of the iLUC effect, and further address the issues of deforestation, irrigation water use, and crop price increases due to expanding biofuel acreage. We use GLOBIOM – an economic partial equilibrium model of the global forest, agriculture, and biomass sectors with a bottom-up representation of agricultural and forestry management practices. The results indicate that second generation biofuel production fed by wood from sustainably managed existing forests would lead to a negative iLUC factor, meaning that overall emissions are 27% lower compared to the 'No biofuel' scenario by 2030."
  • Global Trade and Environmental Impact Study of the EU Biofuels Mandate (PDF file), March 2010 by Al-Riffai, P., B. Dimaranan and D. Laborde for IFPRI. From the Executive Summary:
    • "The primary objective of this study is to analyse the impact of possible changes in EU biofuels trade policies on global agricultural production and the environmental performance of the EU biofuel policy as concretised in the [European Union's Renewable Energy Directive (RED)]. The study pays particular attention to the ILUC effects, and the associated emissions, of the main feedstocks used for first-generation biofuels production."
    • "...World cropland increases by 0.07%, showing that there is indeed indirect land use change associated with the EU biofuels mandate."
    • "...Analysis of ILUC effects by crop indicates that ethanol, and particularly sugar-based ethanol, will generate the highest potential gains in terms of net emission savings."
    • "Finally, considerable uncertainty remains regarding the impact of the sustainability criteria on biofuels markets. The role of certification and the emergence of differentiation in biofuels, feedstock crops and land prices, based on carbon content and the respect of sustainability criteria, require more empirical research."[79]

Reports by country

Brazil & Countries of the Amazon

Video from the Institute for Sustainable Futures.
  • Ethanol Expansion And Indirect Land Use Change In Brazil, June 2011 by Joaquim Bento de Souza Ferreira Filho and Mark Horridge from the Centre of Policy Studies. From the Abstract: "Indirect land use change from ethanol in Brazil is modelled by Ferreira Filho and Horridge using dynamic general equilibrium modelling (the ‘Brazilian Input-Output model’). For 2020, they find that each hectare of additional sugarcane for ethanol requires 0.14 hectare of new land conversion. This is nearly double the value reported by Nassar et al. (2010)."[81]
  • Statistical confirmation of indirect land use change in the Brazilian Amazon, 24 May 2011 by Eugenio Y Arima, Peter Richards, Robert Walker and Marcellus M Caldas in Environmental Research Letters. From the Abstract: The model utilized in this study "demonstrates that ILUC is significant and of considerable magnitude. Specifically, a 10% reduction of soy in old pasture areas would have decreased deforestation by as much as 40% in heavily forested counties of the Brazilian Amazon...."[82]
  • Food, fuel, and the hidden margins of capital, by Peter D. Richards; April 2011 in the Journal of Land Use Science. From the Abstract: "Perhaps no region has drawn more attention to the environmental impacts of expanding agricultural production than the Amazon....In this article, I provide a location-based conceptualization of indirect land use change that brings to light the intra-regional movement of capital and skills between the cattle and agriculture sectors. The article suggests that amid rapid increases in rents for soy production and land prices, ranchers face strong incentives to relocate their operations to forest regions."[83]

Southeast Asian Countries

  • Historical Analysis and Projection of Oil Palm Plantation Expansion on Peatland in Southeast Asia by Jukka Miettinen, Al Hooijer, Daniel Tollenaar, Sue Page, Chris Malins, Ronald Vernimmen, Chenghua Shi, and Soo Chin Liew; ICCT, February 2012. "Study using satellite mapping data of historical and projected rates at which oil palm plantations in Indonesia and Malaysia have expanded and will expand onto peat soils."
    • "This study demonstrates that the area of industrial oil palm (OP) plantations in the peatlands of insular Southeast Asia (Malaysia and Indonesia, except the Papua Provinces) has increased drastically over the past 20 years. From a small area in 1990 to at least 2.15 million hectares in 2010, expansion has affected every region of Malaysia and Indonesia reviewed here."


  • Europe - General
    • Grandfathering options under an EU ILUC policy by Ecofys, March 2012: "The European Commission is expected to publish an Impact Assessment and legislative proposal on the issue of Indirect Land Use Change (ILUC) associated with biofuel production. The introduction of an ILUC policy measure in the Renewable Energy Directive (RED) and Fuel Quality Directive (FQD) could impact current investments and jobs in the EU biofuel industry. Ecofys investigated on behalf of Transport&Environment to what extent the biofuel sector may need protection - so called 'grandfathering'- against the introduction of an EU policy measure.
      • "The report starts with an overview of the EU biofuels market and sector and analyses the impact of possible ILUC policy options on the sector and the level of protection of current investments and jobs that would be required. Subsequently, the report analyses the grandfathering clause as currently included in the RED and FQD as well as other possible grandfathering options."
      • "The study concludes that the introduction of an ILUC policy measure is possible while maintaining employment and paying back current investments in biofuel production installations if the 2010-2012 EU biofuel consumption level would be exempted from ILUC policy up to 2020. This means that an ILUC policy option would be targeted towards the future increase in biofuel production until 2020. The ILUC policy would not significantly reduce the total quantity of biofuels used in the EU because the RED and FQD 2020-targets will remain unchanged...." [84]
      • Read the full study here (PDF file)


August 2009 YouTube video, "Indirect Land Use and Its Effects"

by Clean Skies News.

Reports by feedstock



Palm oil

  • Historical Analysis and Projection of Oil Palm Plantation Expansion on Peatland in Southeast Asia by Jukka Miettinen, Al Hooijer, Daniel Tollenaar, Sue Page, Chris Malins, Ronald Vernimmen, Chenghua Shi, and Soo Chin Liew; ICCT, February 2012. "Study using satellite mapping data of historical and projected rates at which oil palm plantations in Indonesia and Malaysia have expanded and will expand onto peat soils."
    • "This study demonstrates that the area of industrial oil palm (OP) plantations in the peatlands of insular Southeast Asia (Malaysia and Indonesia, except the Papua Provinces) has increased drastically over the past 20 years. From a small area in 1990 to at least 2.15 million hectares in 2010, expansion has affected every region of Malaysia and Indonesia reviewed here."


  • Food, fuel, and the hidden margins of capital, by Peter D. Richards; April 2011 in the Journal of Land Use Science. From the Abstract: "[This] article suggests that amid rapid increases in rents for soy production and land prices, ranchers face strong incentives to relocate their operations to forest regions [in the Amazon]."[88]


Land Use Impacts of Fossil Fuels

  • While the indirect land use change (ILUC) impacts of biofuel production has become a major concern for the industry (for more information, see the BioenergyWiki ILUC Portal page), to date there has not been a corresponding level of scrutiny of the ILUC impacts of fossil fuels – despite the fact that such impacts would also affect the lifecycle GHG emissions of fossil fuels.
    • ”The calculation of biofuels emissions based on both direct and indirect impacts introduces a methodological inconsistency into the FQD [the Fuel Quality Directive of the European Union]. Greenhouse gas intensity under the FQD of both fossil fuels and biofuels is based on direct emissions, so using a different approach for just biofuels would make meaningful comparisons extremely difficult.” (Ernst and Young 2011 (PDF)).
  • Land Use Greenhouse Gas Emissions from Conventional Oil Production and Oil Sands, a study published in 2010 in Environmental Science & Technology, examined the land use impacts of conventional (drilling) and nonconventional (oil shale) extraction methods for fossil fuels, and provided one of the first estimates of land use change GHG emissions from petroleum production. “Their findings conclude that emissions released from land disturbed by certain fossil fuels extraction methods can be comparable to or higher than emissions from land disturbed by farming crop-based biofuels—when measured as tons of carbon emitted per unit of land disturbed.”
  • Other studies have found that traditional oil drilling is also associated with deforestation, particularly in tropical rainforest regions. Furthermore, indirect impacts from fossil fuel extraction, such as increased risk of wildfires or introduction of invasive species [90], or increased access by settlers to previously remote areas [91], could have land use change impacts which are not yet fully understood.

Indirect Land Use Change (ILUC) edit
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