REPORT FROM THE COMMISSION on indirect land-use change related to biofuels and bioliquids
Date: 2010-12-22
Institutions: European Commission
Subjects: agricultural land, biofuel, energy policy, environmental protection, fossil fuel, greenhouse gas, land use, renewable energy, sustainable development

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EUROPEAN COMMISSION 

Brussels, 22.12.2010 
COM(2010) 811 final 

REPORT FROM THE COMMISSION  

on indirect land-use change related to biofuels and bioliquids 

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REPORT FROM THE COMMISSION  

on indirect land-use change related to biofuels and bioliquids 

1. 

INTRODUCTION 

1.1. 

Background  

Renewable energy, including biofuels, is an essential element of the EU´s energy and climate 
strategy.  Biofuels  are  important  because  they  help  tackle  two  of  the  most  fundamental 
challenges  in  energy  policy  with  regards  to  transport:  the  overwhelming  dependency  of  the 
transport sector for oil and the need to decarbonise transport.  

Supporting biofuels offers other opportunities too. They can contribute to employment in rural 
areas,  both  in  the  EU  and  in  developing  countries  and  they  offer  scope  for  technological 
development, for example in second-generation biofuels.  

In 2009, through Directive 2009/28/EC on the promotion of the use of energy from renewable 
sources (the "Renewable Energy Directive"), the EU adopted mandatory targets to achieve by 
2020 a:  

– 

– 

20% overall share of renewable energy 

10% share for renewable energy in the transport sector 

These  mandatory  targets  are  to  provide  certainty  for  investors  and  to  encourage  continuous 
development of technologies which generate energy from all types of renewable sources. 

At  the  same  time,  through  Directive  2009/30/EC  ("the  Fuel  Quality  Directive")  the  EU 
adopted a mandatory target to achieve by 2020 a: 

– 

6% reduction in the greenhouse gas intensity of fuels used in transport  

The aim of this target is to secure specific reductions in greenhouse gas emission associated 
with all aspects of production and use of energy used for road transport and non-road mobile 
machinery.  

The contribution towards these targets from biofuels is expected to be significant1. Therefore, 
it  is  important  that  biofuel  production  is  sustainable.  In  order  to  avoid  negative  side-effects 
both Directives (hereafter referred to as "the Directives") include the most comprehensive and 
advanced  sustainability  scheme  anywhere  in  the  world.  They  impose  a  number  of 
sustainability criteria that economic operators need to meet in order for biofuels to be counted 
towards  the  legislative  targets  and  qualify  for  support  schemes2.  These  criteria  aim  at 
preventing  the  conversion  of  areas  of  high  carbon  stock  and  high  biodiversity  for  the 
production  of  raw  materials  for  biofuels.  Moreover,  they  also  require  biofuels  to  achieve 
minimum greenhouse gas emission savings of 35% compared to fossil fuels. This requirement 
is progressive as it increases to 50% in 2017 and 60% in 2018 for new installations.  

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The recently submitted National Renewable Energy Action Plans estimate that biofuels will represent 
around 9% of the total energy consumption in transport in 2020.  
The sustainability criteria also apply to 'bioliquids' used for electricity or heating and cooling. 

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The sustainability criteria3 may have an impact in commodity markets broader than biofuels, 
potentially  enhancing  sustainable  production  of  agricultural  raw  materials  as  a  side-effect. 
However, due to growing global demand for agricultural commodities there is a risk that part 
of the demand for biofuels will be met through an increase in the amount of land devoted to 
agriculture worldwide.  

Therefore, the Directives require the Commission to report to the European Parliament and to 
the  Council  by  31  December  2010,  reviewing  the  impact  of  indirect  land-use  change  on 
greenhouse gas emissions and addressing ways to minimise that impact4. The report should, if 
appropriate,  be  accompanied  by  a  proposal,  based  on  the  best  available  scientific  evidence, 
containing  a  concrete  methodology  for  emissions  from  carbon  stock  changes  caused  by 
indirect land-use change5.  

Although  land-use  change  can  have  a  wide  range  of  positive  and  negative  impacts  (i.e. 
greenhouse  gas  emissions,  biodiversity,  social  issues,  etc),  this  report  focuses  on  the 
consequences for the greenhouse gas emissions of biofuels, as required by the Directives. The 
Commission  will  analyse  wider  sustainability  impacts  associated  with  the  promotion  of 
biofuels in the Renewable Energy Directive's biennial reports to the European Parliament and 
the  Council  from  2012  onwards.  Moreover,  the  Commission  believes  that  it  is  important  to 
tackle  indirect  land-use  change  for  biofuels  through  a  holistic  approach  considering, 
comparatively, the life-cycle sustainability of fuels used in the transport sector. This will also 
be considered in the forthcoming impact assessment. 

1.2.  What is indirect land-use change? 

The  use  of  fossil  fuels  and  land-use  change  are  the  main  contributors  to  anthropogenic 
greenhouse gas emissions. The use of biofuels may reduce greenhouse gas emissions provided 
that direct and indirect greenhouse gas emissions are lower than those from fossil fuels they 
replace. 

In the next decades it is foreseen that a higher world population and standards of living will 
lead to increasing demand for food, feed, energy and fibre from the earth's ecosystems. These 
increased  demands  are  likely  to  lead  to  an  increased  need  for  agricultural  commodities 
globally. This increase can come from yield increases and expansion of agricultural land. The 
increased use of biofuels in the EU adds to this existing demand for agricultural commodities.  

Biofuel  feedstock  may  be  produced  on  land  directly  converted  from  another  status  to 
agricultural land. The carbon emissions from such land-use change have to be included in the 
overall calculation of greenhouse gas emissions of the specific biofuel, in order to determine 
if  it  meets  the  sustainability  criteria6.  However,  if  it  is  instead  cultivated  on  existing 
agricultural  land,  it  may  then  displace  other  crop  production  some  of  which  ultimately  may 
lead to conversion of land into agricultural land. Through this route, the extra biofuel demand 
can  lead  indirectly  to  land-use  change,  from  which  the  term  indirect  land-use  change  is 
derived.  This  indirect  effect  manifests  itself  through  a  change  in  demand  for  agricultural 
commodities,  and  their  substitutes,  in  global  markets.  The  change  of  price  may  give 

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The Commission adopted in June 2010, two Communications aimed at facilitating the implementation 
of  the  sustainability  criteria  included  in  the  Directives  including  through  recognition  of  voluntary 
schemes. 
The requirement in the Renewable Energy Directive also applies to bioliquids. As such, references to 
biofuels in this report will also apply to bioliquids where appropriate.  
Article 7d(6) of Directive 2009/30/EC and Article 19(6) of Directive 2009/28/EC 
There are also restrictions related to specific no-go areas, see Article 17 of Directive 2009/28/EC and 
Article 7b of Directive 2009/30/EC. 

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incentives  to  change  behaviour,  leading  to  the  increased  use  of  land,  which  in  many  cases 
implies  land-use  change.  The  increased  price  can  also  change  behaviour  by  incentivising 
increased yields on existing agricultural land. 

The basic driver for indirect land-use change is the increased demand for agricultural crops in 
a situation where both suitable agricultural land availability and potential yield increases are 
limited. Some other key factors, such as achieving maximum profit from the production and 
complying with related legislation in place, are also likely to play a role in determining how 
the increased demand is to be realised.  

The  extent  to  which  land  availability  is  limited  in  various  regions  of  the  world  is  much 
debated.  Figure  1  below7  depicts  the  harvested  area  in  different  regions  of  the  world. 
Compared  to  1981  the  harvested  land  has  significantly  declined  in  Europe,  CIS  and  North 
America, thus suggesting that there would be low carbon stock land available8.  

Globally harvested area (FAOSTAT)

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East and South Asia

Eastern Europe and CIS

Latin America and
Caribbean

North Africa and West
Asia

North America

Northern, Western and
Southern Europe

Oceania

South-East Asia

Sub-Saharan Africa

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1981

2001

2007

Figure 1: Globally harvested area from 1961 to 2007 

The limited availability of low-carbon stock land in other parts of the world and the lack of 
more  stringent  protection  of  forests  and  carbon  rich  areas  are  factors  that  can  contribute  to 
damaging indirect land-use change. If conversion of carbon rich areas were to be limited or if 
more agriculture commodities were subject to sustainability criteria comparable to those laid 
down for biofuels, indirect  land-use change  could be  limited. The reason for this is that  the 

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FAO  Statistics.  Note  that  there  is  an  important  difference  between  "harvested  area"  and  "cultivated 
area".  Double-cropping  in  a  field  would  double  the  amount  of  harvested  area,  while  cultivated  area 
remains constant.  
However, if it is the least fertile land that has been recently abandoned, then its future production could 
be  expected  to  show  typical  yields  below  average,  leading  to  either  increased  land  requirements  or 
increased use of fertilisers. In addition, if the land is under a process of afforestation, its reversion to 
agricultural production could result in the release of carbon emissions,. 

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indirect  land-use  change  effect  of  biofuels  is  the  direct  land-use  change  of  another 
commodity. 

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2. 

ESTIMATING GREENHOUSE GAS EMISSIONS DUE TO INDIRECT LAND-USE CHANGE 

Estimating  the  greenhouse  gas  impact  due  to  indirect  land-use  change  requires  projecting 
impacts  into  the  future,  which  is  inherently  uncertain,  since  future  developments  will  not 
necessarily follow trends of the past. Moreover, the estimated land-use change can never be 
validated, as indirect land-use change is a phenomenon that is impossible to directly observe 
or measure. Therefore modelling is necessary to estimate indirect land-use change9. In order 
to base its work on the best available scientific evidence, the Commission launched a number 
of analytical exercises and a review of existing literature on the subject of indirect land-use 
change during 2009 and 201010. In addition, the Commission conducted various consultation 
exercises  with  the  wider  community,  including  a  pre-consultation  on  the  possible  policy 
approaches11,  and  one  further  exercise  once  final  versions  of  the  studies  were  made 
available12. In recognising the difficulties associated with the numerous uncertainties in these 
modelling studies, leading global technical experts were involved in exploring the outputs and 
conclusions from the analytical work.  

The analytical work carried out was based on several studies, namely  

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Impacts of the EU biofuel target on agricultural markets and land-use: a comparative 
modelling  assessment  by  the  Institute  for  Prospective  Technological  Studies  of  the 
EC's Joint Research Centre. (IPTS) 

Global  trade  and  environmental  impact  study  of  the  EU  biofuels  mandate  by  the 
International Food Policy Research Institute (IFPRI) 

The  impact  of  land-use  change  on  greenhouse  gas  emissions  from  biofuels  and 
bioliquids, an in-house review conducted for DG Energy (Literature review). 

Indirect  land-use  change  from  increased  biofuels  demand  –  comparison  of  models 
and results for marginal biofuels production from different feedstocks by the Institute 
for Environment and Sustainability of the EC's Joint Research Centre (JRC).  

In addition, a range of other external reports or articles deemed relevant, of which most have 
their  origin  in  the  debate  on  indirect  land-use  change  in  the  US,  have  been  considered, 
including the most recent report13 done by the JRC (Joint Research Centre). The nature of the 
work  was  wide-ranging,  covering  several  aspects  including  economic  modelling  of  the 
impacts  of  EU  biofuel  demand  on  global  commodity  markets  and  their  likely  response;  a 
comparison of the main economic models used at a global level to understand indirect land-
use  change  including  the  facilitation  of  dialogue  between  the  various  modelling  teams;  a 
novel approach to determine the likely location of land that would be converted to agricultural 
use as a result of increased demand, and a literature review.  

Two  of  these  reports  involved  separate  modelling  exercises.  The  first,  carried  out  by  IPTS, 
used the AGLINK-COSIMO model. This modelling assumed that the 10% renewable energy 
in transport target would be met using 7% conventional biofuels and 1.5% advanced biofuels 
that  would  be  double  counted.  Although  this  model  considered  the  impacts  from  the 
additional demand of conventional biofuels needed to meet the target, it did not consider any 

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The models do not distinguish between indirect and direct land-use change 
http://ec.europa.eu/energy/renewables/studies/land_use_change_en.htm  
http://ec.europa.eu/energy/renewables/consultations/2009_07_31_iluc_pre_consultation_en.htm 
http://ec.europa.eu/energy/renewables/consultations/2010_10_31_iluc_and_biofuels_en.htm 
"Biofuels  a  new  methodology 
http://re.jrc.ec.europa.eu/bf-tp/download/EU_report_24483_Final.pdf  

to  estimate  GHG  emissions 

from  global 

land-use  change", 

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impacts  resulting  from  additional  demand  for  either  advanced  biofuels  or  bioliquids.  The 
bioethanol-biodiesel  shares  considered  were  identical  to  the  shares  of  petrol  and  diesel,  i.e. 
approximately  35%  and  65%,  so  that  the  share  of  biofuel  in  petrol  and  diesel  were  each 
respectively  approximately  8.5%.  The  final  conclusion  of  the  modelling  was  that  the 
additional  demand  resulting  from  the  policy  compared  to  a  counterfactual  2020  scenario14, 
equalled  to  21  Mtoe,  which  would  result  in  an  increase  of  the  total  land  area  required  for 
crops of 5.2 million hectares globally, one quarter of which is in the EU. This modelling did 
not provide a calculation of the greenhouse gas impacts of this land conversion. 

The second modelling exercise was carried out using the MIRAGE model by the International 
Food Policy Research Institute (IFPRI). This modelling was based on the assumption that the 
10%  renewable  energy  in  transport  target  would  be  met  using  5.6%  conventional  biofuels 
with  the  remainder  met  in  other  ways,  including  a  contribution  of  1.5%  from  advanced 
biofuels, under current trade policy and assuming full trade liberalisation. Additional demand 
for advanced biofuels and bioliquids was not modelled. The conclusion of the modelling was 
that  the  additional  demand  resulting  from  the  policy  compared  to  a  counterfactual  2020 
scenario15, equalled to 8 Mtoe, which would result in an increase of total land area required 
for  crops  of  0.8  and  1  million  hectares  globally,  under  the  business  as  usual  and  free  trade 
scenarios, respectively. Converted into greenhouse gas emissions this compares to 18 grams16 
of CO2-eq. per MJ of energy (subsequently written as g/MJ). The bioethanol-biodiesel shares 
were set as 45% and 55% respectively. The overall land requirements increased to 2.8 million 
hectares  globally  in  the  scenario  using  8.6%  conventional  biofuels,  resulting  into  average 
emissions of 30g/MJ. 

The  split  between  bioethanol  and  biodiesel  turned  out  to  be  of  great  importance  for  the 
(indirect)  land-use  change  impact  estimated  using  the  IFPRI  MIRAGE  model.  In  a  further 
IFPRI  MIRAGE  model  run  using  the  5.6%  scenario,  and  a  25%  bioethanol/75%  biodiesel 
split gave average (indirect) land-use change emissions of around 45 g/MJ17. These results are 
summarized in the table below. 

Split between bioethanol and biodiesel (%) 

45/55 

35/65 

25/75 

Average land-use change emissions (g/MJ) 

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31 

45 

Table 1: Results of sensitivity analysis of various bioethanol/biodiesel splits on the 
average (indirect) land-use change emissions-  

The  crop-specific  greenhouse  emissions  resulting  from  each  additional  MJ  of  biofuel  were 
also calculated and are outlined in figure 218.  

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The  baseline  of  the  counterfactual  scenario  assumes  very  low  levels  of  biofuel  penetration  as  main 
policy incentives are removed.  
The baseline of the counterfactual scenario assumes 2008 biofuel penetration levels are maintained.  
The emissions from land-use change are distributed over 20 years.  
See slide 34 of the presentation given by David Laborde of IFPRI at the 2nd consultation meeting (26 
October 2010) available at 
http://ec.europa.eu/energy/renewables/consultations/doc/public_consultation_iluc/global_trade_environ
mental_impact_study_eu_biofuels_mandate.pdf 
The  marginal  values  are  computed  by  adding  0.1%  of  the  total  EU  consumption  of  biofuels  to  the 
consumption in 2020 for one crop at a time. The marginal increase gives unexpected results due to the 
high  dependence  on  specific  marginal  effects  in  the  agro-economic  zone  of  the  last  marginal  unit  of 
biofuel. This effect results for sugar beet ethanol in estimated land-use change impact to change from 
16  g/MJ  to  65  g/MJ  as  a  result  of  moving  from  a  business  as  usual  scenario  to  a  free  trade  scenario 
without tariffs on bioethanol imports. The reason is that when sugar beet is used to produce bioethanol, 

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Business as usual scenario

Free trade scenario

Biodiesel Sunflower oil

Biodiesel Soybean oil

Biodiesel Rapeseed oil

Biodiesel Palm oil

Ethanol Wheat

Ethanol Maize

Ethanol Sugarcane

Ethanol Sugarbeet

0

20

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60

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gram CO2eq./MJ

Figure 2: (Indirect) land-use change emissions for different feedstocks, and trade 
scenarios (IFPRI 2010) 

As  can  be  seen,  model  results  thus  vary  considerably  across  feedstocks  and  trade 
assumptions19. 

In  view  of  the  fact  that  the  AGLINK-COSIMO  model  does  not  have  a  land  conversion 
module,  it  was  agreed  to  develop  a  methodology  for  allocating  land  areas  converted  and 
calculating  the  resulting  greenhouse  gas  emissions.  This  Spatial  Allocation  Methodology 
(SAM) was developed by the Joint Research Centre based upon a number of GIS databases. 
Within the model, the decision on where to convert new land is based upon land suitability 
and  distance  to  existing  cultivated  areas.  It  has  so  far  only  been  used  with  the  land 
requirements  resulting  from  the  AGLINK-COSIMO  and  IFPRI  MIRAGE  modelling.  For 
these data sets the SAM calculates that greenhouse gas emissions would amount to 1092 Mt 
CO2eq and 201Mt CO2eq respectively, which translates into average (indirect) land-use change 
emissions  of  64  g/MJ  for  AGLINK-COSIMO,  and  34-41  g/MJ  for  the  IFPRI  MIRAGE 
central scenario. The SAM can be used with land area inputs from any model, thus helping to 
remove one of the causes of variation in GHG emissions between different models20. 

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additional imports of sugar (not sugar beet) occur from land (in Africa and South East Asia) with very 
high carbon content.  
Additional  model  scenarios  runs  of  the  IFPRI-MIRAGE  are  being  conducted,  as  to  ensure  the  latest 
demand estimates to 2020 from the Member States are captured. In addition, further sensitivity analysis 
aimed  at  providing  a  better  characterisation  of  the  probability  distribution  associated  with  the  crop 
specific ILUC emission values is also being conducted.  
The Joint Research Centre will extend the application of their Spatial Allocation Methodology (SAM) 
beyond  the  central  IFPRI  MIRAGE  scenario  (5.6%)  to  higher  demand  scenarios.  The  possibility  of 
using this methodology to calculate crop-specific greenhouse gas emission values will also be explored. 

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For specific feedstocks, various modelling exercises give different results for the same crop. 
The  literature  mostly  contains  figures  for  US-relevant  biofuel  feedstocks,  i.e.  mainly  maize 
and  to  some  extent  soya.  The  table  below  summarizes  the  main  results  found  for  these  two 
feedstocks: 

Land-use change in g/MJ21 

Maize 
ethanol 

Soya 
biodiesel 

Searchinger et.al. (2008) 

156 

 165-270 

CARB (2009) 

EPA (2010) 

Hertel et.al. (2010) 

Tyner et.al (2010) 

IFPRI MIRAGE (2010) 

45 

47 

40 

21 

54 

63 

54 

- 

- 

75 

Table 2: Summary of feedstock specific land-use change emission values (Literature 
review)  

The  results  outlined  above  are  the  result  of  different  models  working  under  different 
assumptions. As can be seen from the table, the results vary considerably, thus showing the 
deficiencies  and  uncertainties  in  modelling  (indirect)  land-use  change,  with  the  values  for 
maize bioethanol ranging between 21 and 156 g/MJ. 

The geographical origin of the feedstock could also be a significant variable in estimating the 
(indirect) land-use change impact of a specific biofuel. However, none of the modelling done 
so far has explored this variability, which may in fact not be possible with today's models. 

In  the  model  comparison  exercise  managed  by  the  Commission's  Joint  Research  Centre, 
contact  was  made  with  the  main  modelling  teams  who  had  been  carrying  out  modelling  of 
(indirect)  land-use  change.  Two  expert  meetings  were  held  to  agree  how  to  carry  out  the 
comparison,  to  discuss  findings  and  to  understand  the  scope  for  further  improving  the 
underlying data. The (indirect) land-use change estimated by the models was in the range of 
223 to 743 kha per Mtoe of ethanol used in the EU and in the range of 242 to 1928 kha per 
Mtoe  of  biodiesel  used  in  the  EU.  In  comparison  AGLINK-COSIMO  scenarios  (run  by  the 
OECD  for  the  model  comparison  exercise)  for  Brazilian  sugar  cane  and  US  ethanol  are 
respectively  134  and  574  kha  per  Mtoe;  IFPRI  MIRAGE  scenarios  were  estimated  to  be 
around  100  kha  per  Mtoe.  The  work  explored  the  reasons  for  the  variations  in  land  area 
required. The main factors influencing the outputs were found to be the fraction of crop saved 
by by-products, reductions in food and feed consumption22, increases in yields and effects of 
crop displacements. Moreover, the modelling comparison study found that current models do 
not  capture  a  number  of  factors,  which  if  taken  into  account,  would  increase  the  estimated 

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Results have been adjusted to a 20 years timeframe. 
The  economic  models  compared  estimate  that  part  of  the  feedstock  for  biofuels  comes  from  reduced 
food and feed consumption and this can significantly reduce (indirect) land-use change emissions. 

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land-use change impact. These factors include emissions from the conversion of peat-lands23. 
Moreover, apart from (indirect) land-use change emissions as discussed in this report, models 
do  not  consider  at  least  two  additional  sources  of  increased  emissions:  the  emissions  from 
yield  intensification  due  to  crop  price  rises,  and  the  extra  emissions  from  growing  crops  on 
marginal land rather than on existing cropland.  

The  Literature  review,  among  other  things  discussed  various  deficiencies  and  uncertainties 
associated with the modelling, most of which is based on economic principles, where decision 
making on e.g. land-use change, is reduced to a least-cost optimization problem. However, it 
is  known  that  in  reality  several  non-economic  factors  influence  what  land-use  change  takes 
place and where it occurs. Some of these drivers are related to political choices (land-use and 
agricultural  policy,  land  rights,  etc.),  others  to  institutional  features  (proximity  to 
infrastructure and markets, land-use legislation). Therefore conceptual limitations will always 
remain. While prices affect decisions about what to plant, other factors than price are drivers 
for which land was cleared for cropping24. 

Notwithstanding  these  conceptual  limitations,  it  can  be  argued  that  the  best  available 
methodology  to  estimate  (indirect)  land-use  change  is  still  through  economic  models  where 
decisions are made based on relative prices25. However, within this framework of economic 
modelling,  there  will  always  be  a  range  of  unsolved  issues,  which  influence  the  results 
considerably.  The  modelling  is  dependent  on  assumptions,  most  importantly  related  to  the 
treatment of co-products26, existing yields27, marginal yields28, food and feed consumption29, 
classification  of  land30,  elasticities31,  carbon  stock  values32,  type  of  land  converted33, 
modelling  of  pasture34  and  the  drivers  of  deforestation35.  Our  understanding  of  these  has 
evolved in the recent years, but a number of deficiencies and uncertainties remain. 

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Models do not properly take into account the emissions from peat oxidation following drainage process 
required  in  the  cultivation  of  palm  oil,  which  could  underestimate  real  emissions  by  an  order  of 
magnitude. 
Even with substantial additional investments in data and analysis there seem to be limits to the degree to 
which quantitative estimates of the role of any one factor influencing land-use change can be improved.  
One alternative approach has emerged recently, which rather uses a "causal-descriptive" methodology, 
where the main critical inputs are expert/stakeholder based, together with historical and statistical data 
(E4tech 2010) 
Most biofuel feedstocks co-produce considerable quantities of co-products. Most models do now take 
this  into  account,  although  at  various  ratios,  greatly  influencing  model  results.  Co-products  normally 
replace animal feed, freeing up land that would otherwise be needed for its production. 
Yields  increases  are  normally  assumed  to  continue  at  historic  rates  whereas  such  predictions  are 
uncertain. 
There is little empirical evidence on developments of marginal yields.  
Economic models assume demand being a function of price, with different assumptions as to how the 
additional demand for biofuels will impact on food and feed commodity markets.  
Land availability and land classification is an essential input for land-use change modelling, however, 
figures and terminology are not consistent across datasets.  
Elasticities  are  often  estimated  on  basis  of  data  from  developed  countries,  while  models  suggest  that 
indirect land-use change typically takes place in developing countries. 
Carbon stock values attributed to different vegetations and soils vary considerably across studies, and 
play an essential part in determining the indirect land-use change impact. 
The type of land that is converted to cropland has a major influence, as carbon stocks vary considerably 
across  land  types.  Due  to  too  course  spatial  resolution  regional  differences  risk  getting  lost  in  the 
geographical aggregations. 
Pasture for  animals  covers  large parts of  the  globe,  and offer  potential  supply  of  land for  cultivation. 
However, how pasture is modelled and its interlinkages with feed markets and cropland differs between 
models. The assumptions has major impacts on the overall results, as pasture is covering a large fraction 
of the terrestrial surface, and has relatively low carbon stocks. 

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In  addition,  the  Literature  review  found  that  current  models  are  incapable  of  capturing  a 
number  of  factors,  including  the  conversion  of  forest  on  peat-land  which  can  lead  to 
considerable  carbon  emissions.  However,  the  majority  of  such  factors  would,  if  captured, 
reduce the estimated land-use change impact. These include- the allocation of all emissions to 
crop expansion, whereas deforestation may be driven simultaneously by crop expansion and 
logging; rate of yield improvements in response to increased demand for biofuels36; structural 
changes37;  and;  the  protein  content  of  various  feeds  and  co-products,  which  is  rarely  fully 
reflected38.  In  addition,  the  effects  of  the  binding  sustainability  criteria  for  biofuels  in  the 
Directives  (which  the  models  take  as  having  no  impact)  have  not  been  taken  into  account. 
Finally, the literature review notes that in order to compare the greenhouse gas impacts of the 
policy, it is important that the sum of direct emissions from biofuels and the unknown indirect 
land-use  change  emissions  are  compared  to  the  fossil  fuels  not  being  extracted  as  a 
consequence of using biofuels. 

35 

36 

37 

38 

Drivers behind deforestation are complex, where local authorities, land-use rights and political economy 
all play a role. It is not possible to properly reflect this real world effects in the models, where decision 
making is reduced to a purely rational economic question. 
Increased  yields  are  a  function  of  a  complex  set  of  variables,  among  them  increased  investment  and 
research, both of which take place as a response to the biofuel policy. It is however difficult to capture 
this effect in the models.  
Structural changes are typically difficult to predict by models as elasticities are based on historical data. 
Considerable  increase  in  use  of  land  in  e.g.  CIS  is  therefore  unlikely  according  to  the  models,  while 
such a structural change could take place both in the baseline and in the policy scenario. 
This is thus underestimating the land saved by co-products. For example, in the EU soy meal is a key 
source of protein, of which around 97% is imported. There is thus considerable scope of substitution. 

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3. 

DEVELOPMENTS 
(INDIRECT) LAND-USE CHANGE 

IN 

INTERNATIONAL  REGULATORY  ACTIONS  TO  ADDRESS 

In  the  United  States,  biofuel  use  is  promoted  at  Federal  level  with  different  targets  for 
different types of biofuels A minimum greenhouse gas savings of 20% applies and it is higher 
(50%, 60%) for second generation biofuels. Greenhouse gas savings have been established for 
different  types  of  biofuels  through  consequential  lifecycle  assessment  in  order  to  determine 
whether  they  meet  the  relevant  threshold  (a  type  of  biofuel  either  meets  the  threshold  or  it 
does not; economic operators do not have an alternative of showing evidence for any actual 
emissions). This analysis includes emissions from (indirect) land-use change decided through 
modelling, distinguishing between national and international land-use change. Grandfathering 
until 2022 applies for existing installations.  

In  the  United  States  at  the  State  level,  California  has  implemented  a  Low  Carbon  Fuel 
Standard39. Lifecycle greenhouse gas emissions for all fuels within the scope of the legislation 
need to be known for the legislation to function. Greenhouse gas emission factors have been 
developed for the various fuel pathways including (indirect) land-use change emissions.  

A number of countries have put in place land-use policies to prevent land expansion into land 
with high carbon stock. One example is Brazil, the biofuels producer with the most historical 
experience, which has put in place agro-ecological zoning for sugarcane in order manage land 
expansion  for  energy  crops  and,  at  the  same  time,  improve  the  conditions  for  protection  of 
sensitive areas. It is currently complementing this with zoning for economic activities in the 
Amazon region, according to environmental criteria. Argentina, the main exporter of biofuels 
to EU, has a moratorium in law on any cutting of natural forest until every Argentine province 
has produced an inventory and land management plan as well as an obligation to produce an 
environmental impact study before approving any clearing of the forests. Argentine provinces 
have  begun  enacting  land  zoning  policies,  laying  out  areas  where  agricultural  expansion  is 
banned due to environmental concerns and areas where agricultural expansion is permissible. 
Norway  and  Indonesia  have  signed  a  detailed  letter  of  intent  on  cooperation  on  reducing 
greenhouse gas emissions from deforestation and forest degradation in which Norway would 
provide  funding  to  enhance  Indonesia's  capacity  on  this,  including  a  suspension  on  all  new 
concessions for conversion of peat and natural forest. 

Further, the Global Bioenergy Partnership40, to which the Commission and seven EU Member 
States  are  a  Partner  as  well  as  Argentina,  Brazil,  the  US  and  other  biofuel  producing 
countries, is working to develop a set of relevant, practical, science-based, voluntary criteria 
and  indicators  regarding  the  sustainability  of  bioenergy.  The  criteria  and  indicators  are 
intended to guide any analysis undertaken of bioenergy at the domestic level with a view to 
informing  decision  making  and  facilitating  the  sustainable  development  of  bioenergy  in  a 
manner consistent with multilateral trade obligations. The Partnership has made progress on 
this, though the issue of indirect land-use change is one of the issues for further discussion.  

39 
40 

http://www.arb.ca.gov/fuels/lcfs/lcfs.htm 
http://www.globalbioenergy.org/ 

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4. 

SUMMARY OF THE CONSULTATION RESPONSES  

As  a  first  step  for  addressing  indirect  land-use  change,  the  Commission  carried  out  a  pre-
consultation in July 2009 on eight potential policy approaches in response to indirect land-use 
change. 
A  total  of  71  responses  were  received.41  Most  industry,  farmers'  associations  and  overseas 
countries  supported  either  no  action  or  dealing  with  indirect  land-use  change  through  wider 
policy  action,  either  through  international  action  on  protection  of  high  carbon  stock  land 
and/or  extending  sustainability  criteria  to  all  agricultural  commodities.  Most  NGOs  and  an 
industrial  stakeholder  from  the  non-biofuel  sector,  supported  the  inclusion  of  the  indirect 
land-use  change  emissions  within  the  existing  greenhouse  gas  emission  calculation  for 
biofuels. Member States were divided on this issue. 

Following  the  publication  of  the  relevant  analytical  work  in  July  2010,  the  Commission 
launched a second public consultation exercise. This sought views on whether this analytical 
work  provided  a  good  basis  for  determining  the  significance  of  indirect  land-use  change; 
whether action was required, and if so what course of action would be appropriate. It also set 
out a number of short-listed potential policy approaches. 
A total of 145 responses were received42. The majority of respondents were divided into two 
groups.  Most  respondents  from  industry,  farmers'  associations  and  overseas  countries 
considered  that  the  analytical  work  did  not  provide  a  good  basis  for  determining  the 
significance  of  indirect  land-use  change.  They  considered  that  no  further  action  specific  to 
biofuel policy should be taken, although many supported action on international agreements 
towards the protection of land with high carbon stock. On the other hand, most NGOs and a 
few industrial stakeholders from non-biofuel sectors considered that further action was needed 
and  supported  the  inclusion  of  the  indirect  land-use  change  emissions  within  the  existing 
greenhouse  gas  emission  calculation.  A  number  of  other  respondents  recognised  that  action 
may be needed, favouring a variety of other measures. Member States were divided on this. 

Following  this  public  consultation,  the  JRC  organised  in  November  on  behalf  of  the 
Commission an expert consultation, grouping world-recognised academics and experts in the 
field.  This  consultation  aimed  at  discussing  the  main  uncertainties  related  to  estimations  of 
indirect land use change 43. 

41 

42 

43 

All responses are available at 
http://ec.europa.eu/energy/renewables/consultations/2009_07_31_iluc_pre_consultation_en.htm 
All responses are available at 
http://ec.europa.eu/energy/renewables/consultations/2010_10_31_iluc_and_biofuels_en.htm  
All contributions are available via http://re.jrc.ec.europa.eu/bf-tp/ 

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5. 

PRELIMINARY CONCLUSIONS AND NEXT STEPS 

Renewable energy, including biofuels, is an essential element of the EU´s energy and climate 
strategy.  In  this  context  the  stable  and  predictable  investment  climate  created  by  the 
Renewable Energy Directive, which already contains strict sustainability criteria for biofuels 
and bioliquids, including on their green house gas performance, needs to be preserved, as well 
as  respect  for  the  Fuel  Quality  Directive’s  ambitious  reduction  target  in  the  greenhouse  gas 
intensity of fuels used in transport. 

As  far  as  indirect  land-use  change  is  concerned,  based  on  the  work  carried  out  to  date,  the 
Commission  believes  it  is  possible  to  draw  a  number  of  conclusions.  The  Commission 
recognises  that  a  number  of  deficiencies  and  uncertainties  associated  with  the  modelling, 
which is required to estimate the impacts, remain to be addressed, which could significantly 
impact  on  the  results  of  the  analytical  work  carried  out  to  date.  Therefore,  the  Commission 
will continue to conduct work in this area in order to ensure that policy decisions are based on 
the best available science and to meet its future reporting obligations on this matter.  

However, the Commission acknowledges that indirect land-use change can have an impact on 
greenhouse  gas  emissions  savings  associated  with  biofuels,  which  could  reduce  their 
contribution  to  the  policy  goals,  under  certain  circumstances  in  the  absence  of  intervention. 
As such, the Commission considers that, if action is required, indirect land-use change should 
be addressed under a precautionary approach.  

The  Commission  is  currently  finalising  its  impact  assessment,  which  would  focus  on  the 
assessment of the following policy options:  

(1) 

(2) 

(3) 

(4) 

take no action for the time being, while continuing to monitor, 

increase the minimum greenhouse gas saving threshold for biofuels,  

introduce additional sustainability requirements on certain categories of biofuels, 

attribute  a  quantity  of  greenhouse  gas  emissions  to  biofuels  reflecting  the  estimated 
indirect land-use impact.  

The Commission will present the Impact Assessment, if appropriate together with a legislative 
proposal  for  amending  the  Renewable  Energy  Directive  and  the  Fuel  Quality  Directive  as 
necessary no later than by July 2011. 

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