REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the feasibility of drawing up lists of areas in third countries with low greenhouse gas emissions from cultivation
Date: 2010-08-10
Institutions: European Commission
Subjects: EU environmental policy, energy crop, greenhouse gas, motor fuel, pollution control measures, reduction of gas emissions, report

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EUROPEAN COMMISSION 

Brussels, 10.8.2010 
COM(2010) 427 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the feasibility of drawing up lists of areas in third countries with low greenhouse gas 
emissions from cultivation 

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

on the feasibility of drawing up lists of areas in third countries with low greenhouse gas 
emissions from cultivation 

(text with EEA relevance) 

1. 

INTRODUCTION 

The  Renewable  Energy  Directive1  (the  Directive)  sets  out  sustainability  criteria  for  biofuels 
and bioliquids. For biofuels, corresponding criteria are set out in the Fuel Quality Directive2. 
They  apply  to  biofuels  and  bioliquids  produced  in  the  EU  and  to  imported  biofuels  and 
bioliquids. 

A part of these sustainability criteria is a mechanism to ensure that the biofuels and bioliquids 
used to meet EU targets have greenhouse gas savings of at least 35% compared to the fuels 
they  replace3  when  substituting  fossil  fuels  with  biofuels.  In  order  to  facilitate  compliance 
with this criterion, the Directive contains in part A of Annex V default values for greenhouse 
gas savings for different fuel production pathways.  

As a general rule, producers may always cite a default value for the biofuel and the bioliquid 
they  supply,  as  an  alternative  to  calculating  an  actual  value.  However,  for  raw  materials 
cultivated in the Union, default values may only be used if the raw materials are cultivated in 
areas included in lists submitted by Member States, where emissions from cultivation can be 
expected  to  be  lower  than  or  equal  to  those  reported  under  part  D  of  Annex  V  of  the 
Directive4.  

The  Directive  requires  the  Commission  to  report,  by  31  March  2010,  on  whether  a  similar 
approach  could  be  applied  for  raw  materials  cultivated  in  third  countries.  This  is  the  report 
complying with that obligation5.  

This Report uses the article numbers of the Renewable Energy Directive to refer to specific 
provisions. Table 1 below indicates where corresponding provisions for biofuels are found in 
the Fuel Quality Directive. References in this Report to "the Directive" refer to the Renewable 
Energy Directive. Where the Fuel Quality Directive contains a corresponding provision, they 
apply equally to that Directive. 

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4 
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Directive 2009/28/EC on the promotion of the use of energy from renewable sources and amending and 
subsequently repealing Directives 2001/77/EC and 2003/30/EC, OJ L 140/16 of 5.6.2009 
Directive 98/70/EC as amended by Directive 2009/30/EC 
Rising to 50% in 2017 and 60% in 2018 when produced in new installations. 
Article 19(2) of the Renewable Energy Directive  
Article 19(4) of the Renewable Energy Directive  

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Table 1: Articles and annexes referred to in this Report 

Renewable Energy Directive 

Fuel Quality Directive 

Article 19: Calculation of the greenhouse 
gas impact of biofuels and bioliquids 

Article 7d: Calculation of life cycle 
greenhouse gas emissions of biofuels 

Annex V: Rules for calculating the 
greenhouse gas impact of biofuels, 
bioliquids and their fossil fuel comparators  

Annex IV: Rules for calculating life cycle 
greenhouse emissions from biofuels 

2. 

DEFAULT VALUES FOR GREENHOUSE GAS EMISSIONS 

The  default  values  in  the  Directive  divide  the  greenhouse  gas  emissions  from  biofuel  and 
bioliquids production pathways into three parts: "cultivation", "processing" and "transport and 
distribution". The default values in the Directive are based on the JEC Well-to-Wheel study6. 
The "cultivation" element typically contributes 30 – 70 % of overall emissions, depending on 
the pathway; "processing" is responsible for 25 – 60 %, and the remaining emissions (often 
relatively minor, normally in the range of: 2 – 20 %) come from "transport and distribution".  

The main constituents of the cultivation element, according to the JEC Well-to-Wheel study, 
are fertiliser production, machinery emissions and N2O emissions from soil7. The last of these 
accounts for 40 – 70 % of the cultivation emissions (in some cases even more), depending on 
the pathway. Some examples can be seen in table 2 below, where total cultivation emissions 
and N2O emissions from soil are compared, together with overall total pathway emissions8.  

Table 2: Greenhouse gas emissions from cultivation compared to total pathway emissions  

Cultivation 
emissions 
[gCO2eq./MJ] 
12 
14 
29 
18 

Total 
pathway 
emissions 
[gCO2eq./MJ] 
33 
24 
46 
35 

Cultivation as 
percentage of 
total pathway 
emissions 
35% 
60% 
63% 
50% 

N2O 
emissions 
[gCO2eq./MJ] 
6,2 
6,9 
18,0 
9,4 

N2O emissions as 
percentage of 
cultivation 
emissions 

54% 
47% 
62% 
53% 

Sugar beet ethanol 
Sugar cane ethanol 
Rape seed biodiesel 
Sunflower biodiesel 

Fertiliser production and machinery emissions from cultivation are not expected to be difficult 
to estimate for different regions. By contrast, N2O emissions show substantial spatial variation 
and  are  difficult  to  estimate.  Different  approaches  to  doing  this  exist  and  the  uncertainty  is 

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The  data  are  obtained  from  Institute  for  Environment  and  Sustainability  of  the  Commissions  Joint 
Research  Centre  (JRC),  as  part  of  the  JRC-,  EUCAR-  and  Concawe-consortium  (JEC),  which  is 
responsible  for  the  JEC  Well-to-Wheel  study:  http://ies.jrc.ec.europa.eu/our-activities/support-to-eu-
policies/well-to-wheels-analysis/WTW.html  
IPCC  default  methodology  assumes  that  continuous  cultivation  on  mineral  soils  without  changing 
cultivation  practices  does  not  change  the  soil  carbon  content.  According  to  the  same  methodology, 
continuous cultivation on organic soils leads to significant soil carbon losses. However, a very limited 
amount  of  crops  are  grown  on  organic  soils  in  the  EU.  Consequently,  the  JEC  Well-to-Wheel  study, 
which describes typical circumstances, does not include soil carbon changes from cultivation. 
The  exact  values  for  all  parts  of  the  pathways;  "cultivation",  "processing"  and  "transport  and 
distribution" can be found in part D of Annex V of the Directive. 

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considerable. In view of the above, this report focuses on the feasibility of reliably estimating 
regional N2O emissions in third countries. 

3. 

STATUS  OF  RESEARCH  IN  THE  FIELD  OF N2O  EMISSISIONS  FROM  CULTIVATION  OF 
CROPS 

There are two different ways of modelling N2O emissions: 

process-based  eco-system  models  replicating  the  processes  and  factors  causing 

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emissions in the soil;  

statistical  techniques  identifying  correlations  between  controlling  factors  and 

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emissions recorded through field measurements9.  

Both  approaches  can  be  used  to  develop  emissions  factors  such  as  those  presented  by  the 
IPCC  for  accounting  of  greenhouse  gas  emissions  under  the  UNFCCC.  The  IPCC  proposes 
three different  approaches  of  increasing complexity  according  to  available  data  and  models. 
The  simplest  one  is  called  Tier  1,  where  emission  factors  are  multiplied  by  values  for  e.g. 
fertilizer application. However, the Tier 1 approach is a broad simplification. An indication of 
the uncertainty  is  the -70%,  +300%  uncertainty range given  for the direct  emissions default 
factors provided by  IPCC10 for the Tier 1 approach. Even  this  range does not capture some 
field measurements made.11  

An example of a process based model is the DNDC-model. This was used to calculate the 
N2O  emissions  for  the  European  crops  presented  in  the  JEC  Well-to-Wheel  report12.  A 
process-based  model  such  as  the  DNDC  model  may  deliver  accurate  results,  as  a  range  of 
environmental factors can be considered, including their interactions. Nevertheless, the result 
hinges on the quality of the input data including the validation over the domain in which it is 
applied. On a global level with regional resolution, the current available data would not be of 
sufficient quality.  

An alternative to a process based model is a statistical model, such as the one developed by 
Stehfest  and  Bouwman  (the  S&B  model).  The  model  represents  the  frontier  of  current 
statistical understanding of N2O emissions. However, the model is uncertain as pointed out by 
Smeets et al.13 and some shortcomings exist, in particular;  

a) the model is based on around 1000 field measurements, but none of those are from 
boreal areas,  

b)  organic  soils  are  excluded  since  those  measurements  strongly  influenced  the 
predicted emission from mineral soils,  

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Stehfest  and  Bouwman  2006  N2O  and  NO  emissions  from  agricultural  fields  and  soils  under  natural 
vegetation: summarizing available measurement data and modelling of global annual emissions pp. 207 
- 228 
2006 IPCC Guidelines for National Greenhouse Gas Inventories, Chapter 11, table 11.1 
JEC WTW report, Well-to-Tank report version 2c, March 2007 page 31 
The calculations are based on a recent version of the DNDC model – a soil chemistry model (page 31 of 
the  WTT  report  (version  2c  –  2007  available  here:  http://ies.jrc.ec.europa.eu/our-activities/support-to-
eu-policies/well-to-wheels-analysis/WTW.html) 
Smeets,  Bouwman,  Stehfest,  van  Vuuren,  Posthuma  The  contribution  of  N2O  to  the  greenhouse  gas 
balance of first-generation biofuels pp. 1 - 23 

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c) crop type is recognised as an important parameter for N2O emissions, however, the 
sample of field measurements used as a basis of the model is not extensive enough to 
cover all crops. There is thus a need to improve the statistical model by reducing its 
uncertainties  by  increasing  the  amount  of  field  measurements  under  varying 
conditions14.  

The Joint Research Centre (JRC) of the Commission is working on analysis of N2O emissions 
disaggregated  down  to  regional  level.  The  current  level  of  sophistication  is  a  global 
implementation of the Stehfest and Bouwman model15 for a range of crops used for biofuels 
and  bioliquids.  However;  the  accuracy  of  the  input  data,  together  with  the  fact  that  most 
biofuels  and  bioliquids  fall  under  the  grouping  "other  crops",  when  crop  type  is  of  major 
importance  for  determining  the  emissions,  strongly  suggests  that  this  work  does  not  now 
provide the basis for binding legislative proposals.  

4. 

APPROPRIATE  ACTION  TO  ADDRESS  THE  UNCERTAINTY  OF  N2O  EMISSIONS  FROM 
CULTIVATION IN THIRD COUNTRIES 

The  understanding  of  factors  influencing  N2O  emissions  from  agricultural  soils  is  evolving 
rapidly,  but  is  still  rather  limited.  In  the  light  of  this  a  better  understanding  of  the  issue  is 
needed before attempts can be made to address the issue in relation to third countries.  

The Commission has made the results obtained by the current work of JRC available on its 
website, together with a description of the methodology and the data used. In doing this, the 
Commission  aims  to  obtain  feedback  on  the  methodology  and  the  data  used,  in  order  to 
improve the modelling, which at a later stage might serve as a basis for a legislative proposal. 
Of particular relevance is the improved understanding of N2O emissions from crops typically 
cropped in third countries, and the inclusion of those in N2O models. Statistical data on key 
parameters,  such  as  soil  characteristics,  fertilizer  use  and  yields  are  also  limited  in  some 
regions and need attention. 

5. 

CONCLUSION 

Article 19(4) of the Directive requires the Commission to assess the feasibility of extending 
this  requirement  to  third  countries.  In  light  of  above,  the  Commission  is  of  the  view  that, 
while desirable, it is not yet feasible to set up legally binding lists of areas for third countries 
where  a  major  component  of  the  underlying  calculation  is  uncertain  and  can  easily  be 

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Smeets,  Bouwman,  Stehfest,  van  Vuuren,  Posthuma  The  contribution  of  N2O  to  the  greenhouse  gas 
balance of first-generation biofuels pp. 1 - 23 
A description of the model is found here: Stehfest and Bouwman 2006 N2O and NO emissions from 
agricultural  fields  and  soils  under  natural  vegetation:  summarizing  available  measurement  data  and 
modelling of global annual emissions pp. 207 - 228 

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questioned,  and  where  third  countries  have  had  no  possibility  to  contribute  on  the 
methodology and data used.  

It  is  therefore  not  appropriate,  at  least  at  this  stage  to  produce  legislative  lists  for  third 
countries based on the current  modelling of N2O emissions from agriculture. However, it is 
important to enhance the understanding of the topic and survey the data used in view of a new 
assessment  in  2012. The Commission has thus published the preliminary results of the JRC 
work  together  with  all  necessary  data  and  description  of  methodology  to  support  such  a 
process on the webpage of the JRC16. It will use this as the basis for a discussion with third 
countries in the framework of its dialogue and exchange with them under Article 23(2) of the 
Renewable Energy Directive.  

16 

Updated versions, including detailed description of calculation methods and input data will be provided 
under: http://afoludata.jrc.ec.europa.eu/index.php/dataset/files/221  

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