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Producers of biofuels for the EU market may use 'low ILUC-risk' certification as evidence that they have not deprived other economic sectors of feedstock material, and hence that indirect land use change (ILUC) emissions have been avoided. At present, the uptake of low ILUC-risk certification is limited to a handful of niche projects, as there is little commercial incentive for obtaining certification. This may be considered a missed opportunity, because low ILUC-risk farming methods offer a range of sustainability co-benefits beyond the mitigation of ILUC emissions. This paper examines the policy foundations of low ILUC-risk and develops policy recommendations that would aim to confer advantages to low ILUC-risk biofuels. Some weaknesses in the low ILUC-risk system's environmental safeguards are also highlighted. [ABSTRACT FROM AUTHOR]

Indirect land use change (ILUC) is considered a significant challenge, resulting from an increasing demand for biomass and bioenergy. On a political level sustainability certification of biomass-derived products is discussed as one potential instrument to manage the risk of ILUC. However, extending existing schemes towards a credible and reliable certification approach to account for ILUC-risks is still an open challenge. To develop such a certification instrument, so-called "additionality practices" are gaining relevance. Such practices include measures that an individual producer can adopt to provide an amount of biomass in addition to the business-as-usual feedstock production. This applies in particular to the certification of low ILUC-risk biofuels through voluntary certification schemes recognised by the European Commission. To date, however, no studies have been conducted that examine how such schemes account for potential trade-offs that may arise from the use of additionality practices. In preparation of an integrated assessment framework for low ILUC-risk certification, this study presents a gap analysis that examines whether such trade-offs are considered already in existing sustainability certification schemes for biofuels. In this way, we have found trade-offs that are preferentially addressed by the schemes, e.g., biodiversity loss, on the one hand, and considerable gaps for certain trade-offs, e.g., resource depletion, on the other. In addition, we identified biomass cultivation on unused land as the most promising additionality practice. Most schemes already have certification instruments in place to verify the large number of trade-offs that could be identified as preferentially addressed for this additionality practice. Moreover, only a few new criteria and indicators need to be developed for the small number of gaps found for biomass cultivation on unused land. Finally, this paper recommends future work to verify the scientific evidence of existing certification instruments for the trade-offs addressed and to develop assessment approaches for the identified gaps. [ABSTRACT FROM AUTHOR]

The "low indirect land use change risk" ("low ILUC-risk") concept was developed to assess whether crop-based biofuels would compete with other land uses and cause the expansion of agricultural land. At the core of low ILUC-risk is an "additionality principle", which requires that biofuel feedstock receive special treatment only if it is produced over and above the business-as-usual baseline. This paper examines and tests the European Commission's methodology for calculating the baseline for yield improvement projects, by applying it to publicly available Eurostat data at national and NUTS2 scales. We assess from a statistical perspective how variation in regional yield trends would lead to differences in the long-term outcomes of low ILUC-risk certification; we conclude that, as currently designed, the methodology would over-state the amount of additional production in some cases and could hence incentivise the diversion of crops from other uses into the biofuel sector. We introduce the terms "tailwind additionality", "headwind additionality", and "additionality ratchet" to characterise the phenomena which contribute to this outcome. Our results lead us to recommendations which may enhance both the attractiveness and the robustness of the low ILUC-risk system. [ABSTRACT FROM AUTHOR]

The “low indirect land use change risk” (“low ILUC-risk”) concept was developed to assess whether crop-based biofuels would compete with other land uses and cause the expansion of agricultural land. At the core of low ILUC-risk is an “additionality principle”, which requires that biofuel feedstock receive special treatment only if it is produced over and above the business-as-usual baseline. This paper examines and tests the European Commission’s methodology for calculating the baseline for yield improvement projects, by applying it to publicly available Eurostat data at national and NUTS2 scales. We assess from a statistical perspective how variation in regional yield trends would lead to differences in the long-term outcomes of low ILUC-risk certification; we conclude that, as currently designed, the methodology would over-state the amount of additional production in some cases and could hence incentivise the diversion of crops from other uses into the biofuel sector. We introduce the terms “tailwind additionality”, “headwind additionality”, and “additionality ratchet” to characterise the phenomena which contribute to this outcome. Our results lead us to recommendations which may enhance both the attractiveness and the robustness of the low ILUC-risk system.

The support for vegetable oils biodiesel is defined by the Renewable Energy Directive (RED). After three years of negotiations, RED II (recast of the 2010–2020 RED I) has been adopted and published in December 2018. RED II sets the framework for the EU renewable energy policy for 2021–2030. Although RED II gives a priority to advanced biofuels and electricity in transport with specific targets and multipliers. For crop-based biofuels as vegetable oil biodiesel, RED II offers the possibility to preserve the current investments by giving the Member States the possibility to cap their consumption at the national 2020 consumption level (plus 1%) with maximum of 7%. With the idea to cut the link of crop-based biofuels with deforestation, a change of approach on the ILUC issue is introduced by RED II with the definition of “high ILUC-risk feedstocks with a significant expansion on land with high carbon stocks”. The high ILUC-risk feedstocks will be capped in each Member State at the 2019 level until 2023, and then progressively eliminated by 2030. An exemption from these constraints is provided for to low ILUC-risk feedstocks not linked to deforestation – direct or indirect – and identified by a certification granted to additional feedstocks produced either through productivity improvements or from cultivation on abandoned or degraded land. An Implementing Act will further detail by 2021 the conditions of the low ILUC-risk certification. In a Delegated Act published in March 2019, the EU Commission classified the palm oil as the sole high ILUC-risk feedstock with more than 40% expansion on high carbon stock land (vs. 8% for soybean) on the base of the current available data. Nevertheless, there is a certain uncertainty on the final use of palm oil in bioenergy, as the details of the certification of low ILUC-risk feedstocks are unknown before the publication of the Implementing Act (2021), and as the Delegated Act himself will be reviewed in 2021 and 2023.