What is Indirect Land Use Change (ILUC) and why does it matter? Environmental campaigners working on biofuels (or “agrofuels” – the preferred phrase, as it removes the eco-friendly connotations of ‘bio’ and replaces it with an analogy to big corporate agribusiness) at EU level have produced this video to introduce the public to the obscure and difficult to communicate issue of ILUC:
What is ILUC?
ILUC is the expansion of agricultural land into environmentally sensitive areas, when food production is displaced by fuel crops. In other words, when demand for biofuels causes existing farmland to be changed from growing food crops to growing energy crops, the demand for those food crops does not disappear. That food must still be grown somewhere, which necessitates indirect land use change – non-agricultural land – like forests, savannah, or peatland – is destroyed in order to make space for growing the food that used to be grown on the farmland that is now being used for biofuel crops.
Why does ILUC matter?
ILUC is the champion of unintended consequences, and EU biofuels policy puts me in mind of two old sayings: “the road to hell is paved with good intentions” and “the devil is in the detail”. ILUC often encroaches into highly biodiverse land, leading to a loss of biodiversity and ecosystem services, which many people in developing countries depend on directly for their livelihoods. What’s more, clearing forest, savannah and scrub land, as well as draining marsh land and peat bogs, releases vast amounts of CO2 and other greenhouse gasses (GHGs) into the atmosphere. GHGs which would otherwise have remained stored in these carbon sinks. Thus, the effects of ILUC on the overall GHG emissions of biofuels can make the potential savings (i.e. producing less GHG emissions, over their life-cycle, than fossil fuels) negative.
Biofuels end up being more damaging, releasing more GHGs, than their fossil fuel counterparts. This is the exact opposite of what they are intended to do – “bad” biofuels are making climate change worse, not better.
EU directives, by guaranteeing long-term demand for biofuels, are direct drivers of biofuels expansion and consequent ILUC. The Renewable Energy Directive (RED) requires 20% of energy production to come from renewables by 2020 – and a significant part is expected to come from bioenergy. The RED, along with the Fuel Quality Directive, requires 10% of transport fuel to come from renewable sources by 2020, which, in reality, translates to biofuels. Yet, the sustainability criteria in the RED do not take ILUC into consideration. The RED requires biofuels to have GHG savings of 35% compared to conventional fossil fuels (rising to 50% savings in 2017), over their lifecycle, but the methodology for calculating GHG lifecycles does not include ILUC factors.
EU Member States are legally obliged to meet these targets, and an analysis of the 27 National Renewable Energy Action Plans (the plans each Member State has to practically implement their obligations under these directives), using the Commission’s own ILUC science research, has shown that the 10% renewable transport fuel target will stimulate a major increase in the use of conventional biofuels up to 2020. This has been calculated to contribute up to 92% of total predicted biofuel use – or 27.3 Mtoe – in 2020. Much of this Member States expect to import.
This additional demand is anticipated to lead to between 4.7 and 7.9 million hectares of ILUC, an area equivalent to just larger than the Netherlands to just under that of the Republic of Ireland. ILUC on this scale is calculated to result in emissions of between 50 and 83 million tonnes of CO2 equivalent (MtCO2e) annually. Even with the 35% GHG savings stipulated by the RED, once the effects of ILUC are included, the total result is additional GHG emissions of between 31 and 65 MtCO2e annually. This is equivalent to an extra 14 to 29 million cars on the road across Europe in 2020.
EU biofuels policy is likely to lead to between 81% and 167% more GHG emissions than meeting the same need through fossil fuel use.
How do we fix it?
If ILUC is not taken into account, it will negate any gains expected by the substitution of regular fuels by biofuels. The European Commission has been doing an Impact Assessment on ILUC, and is expected to decide whether and how to include ILUC in the sustainability criteria of biofuels by the end of June. Of the four options they are considering, three are non sequiturs. ‘Doing nothing’ ignores the well-documented severe social and environmental consequences of ILUC. ‘Increasing the minimum GHG savings threshold’ would not remove the problem, as ILUC would still be unaccounted for in the lifecycle calculations. Unspecified ‘additional sustainability requirements’ is too vague, and it is unclear how they could address indirect effects. The only viable option is for the Commission to propose legislation which includes robust and precautionary feedstock specific ILUC factors in the GHG lifecycle calculation methodology – based on, and evolving with, best available science. This means including crop specific values for the expected ILUC, and its consequent GHG emissions, in the methodology which calculates how much GHGs a biofuel saves relative to fossil fuels.
Scientific research consistently shows that emissions from ILUC have the potential to negate any greenhouse gas emission savings which might be generated from biofuel use. The US Environmental Protection Agency concluded that;
“it would be far less scientifically credible to ignore the effects of land use changes altogether than it is to use the best approach available to assess these known emissions source”;
and subsequently included ILUC factors. If the EU does not do the same, a policy intended to help mitigate climate change, will exacerbate it.
ILUC must be accounted for, but it is not the only issue in the biofuels debate. The RED’s sustainability criteria have other weaknesses, notably their voluntary, non-binding nature, combined with reliance on self-monitoring. No social sustainability criteria have been included, meaning EU biofuels targets are driving plantations in developing countries that trample over indigenous peoples’ land rights and destroy livelihoods alongside biodiversity and carbon sinks.
A debate in the European Parliament about the Dakatcha woodlands in Kenya, one of Kenya’s last remaining coastal forests, home to over 20,000 people, globally threatened bird species, as well as being the home and livelihoods of the indigenous minority Watha and Giriama tribes, including their sacred burial sites, painted a dismal picture of what EU biofuels policy is driving.
Although legal evidence is mounting that the Dakatcha development could not meet the EU’s sustainability criteria, it is the EU’s targets that are giving companies the economic incentive to invest in projects like this. To say that the EU is not driving such projects, as one Commission representative did, because the sustainability criteria are likely to be breached and therefore they could not contribute to the biofuels target, is complacent, and even circular. It is only thanks to the campaigning and publicity by ActionAid, Birdlife International, with its Kenyan partners Nature Kenya, and the work of environmental lawyers at Client Earth, that it has come to light that this project is likely to breach the sustainability criteria, as well as lead to the forced displacement of indigenous people and loss of rare species and biodiversity. Without this furore, it seems probable that the company would have done no more or less than the RED’s sustainability criteria requires – self-reporting, ‘confirmed’ by consultants chosen and paid for by the companies. There is as yet no certification for these companies. Thus, with no provisions for any type of independent auditing, the already deficient standards cannot be enforced.
To suppose that the company, who is investing millions, guaranteed a lucrative turnover by the legal mandate that all EU countries have to buy their product, spurred even more by the subsidies that come hand in hand with this, would have found themselves to be contravening the sustainability criteria, seems blindly optimistic and naive. EU policy is encouraging companies to invest in biofuels – if, post facto, due to the courage and dedication of local populations and environmental groups, enough evidence is mounted to show non-compliance with (non-binding) sustainability criteria, which then prevents the company from being eligible for subsidies (but not from actually selling the product in Europe) it hardly seems a triumph of EU policy. The European Commission is wedded to its own pride in having “the best sustainability criteria in the world”. This is a very sorry first place to occupy. In this instance, the best criteria in the world are still woefully inadequate.
The Nuffield Council on Bioethics published a report in April concluding that current EU policies are unsuitable, unethical, violate human rights and damage the environment. Even the World Bank has recognised that biofuel expansion driven by targets like the EU’s are contributing to higher global food prices, which are pushing millions more people into poverty. The World Bank recommends relaxing biofuel mandates when food prices exceed threshold levels. Many environmental and development organizations are calling for the 10% target to be dropped, and for a complete reassessment of social and environmental implications of EU biofuel policy.
A world where more than one billion people are starving or malnourished must consider urgently whether converting agricultural land from food crops to energy crops can ever be sustainable. And from a legal perspective, the EU must consider whether it is compatible with the EU’s commitment to Policy Coherence for Development.
We cannot sacrifice the poor to meet the rich world’s energy demands.