# Challenges and Recommendations for Improved Identification of Low ILUC-Risk Agricultural Biomass
#### 1.1.1. Additionally  
The requirement that low ILUC-risk feedstock should go beyond the business-as-usual production is known as \"additionality\" [10; 11; 12]. This section outlines the set of rules developed by the European Commission for assessing additionally in crop production; we refer to this as the \"Commission methodology\" or the \"RED II methodology\" interchangeably, and we note that it is already being operationalised by sustainability certification bodies to award low ILUC-risk certificates at the farm level. The objective of this paper is to study the practical implications of the Commission's methodology; this will be elaborated in Section 1.2 below. The RED II and subsidiary texts specify three stages of additionally screening for low ILUC-risk certification. In the first stage, the feedstock producer must implement an \"additionality measure\" on their land (second box in Figure 1); this means [9]:  
_\"any improvement of agricultural practices leading, in a sustainable manner, to an increase in yields... on land that is already used for cultivation...; and any action that enables the cultivation of... crops on unused land, including abandoned land, for the production of biofuels, bidiquids and biomass fuels'._  
From this, we may identify three broad types of low ILUC-risk projects, according to what kind of additionally measure was employed in order to achieve higher overall productivity. These types are:  
1. projects which increase yields from existing crop cycles, by improving the efficiency and targeting of the agricultural management practices;
2. projects which increase land productivity by adopting new types of cropping systems and rotations (e.g., intercropping and sequential cropping); and
3. projects which bring formerly unused or abandoned land into production, while minimising any associated environmental impacts. The requirement that an additionally measure is implemented ensures that some extra effort has been made on the part of the biomass producer to boost yields; this limits the potential for \"free riding\" on yields that would have risen anyway [7]. Examples of additionality measures include adoption of new seed varieties, introduction of sequential cropping, and investment in new machinery. A review of relevant practices and crops which may be financially and agronomically suitable for low ILUC-risk production in Europe can be found in [13]. The second stage of additionality screening evaluates the evidence that whatever additionally measure has been undertaken would not have been undertaken as a matter of course, i.e., that some barrier to implementation prevents the farmer from adopting the improved practices (third box in in Figure 1). The rationale is that, even if steps have been taken to improve agricultural practices, these may be part of business-as-usual trends aimed at meeting increasing demand from food and other markets; any extra production arising from such measures should not be diverted to the biofuel sector if ILUC is to be avoided. In many situations, a project can pass this stage of screening by showing that the net present value (NPV) of the candidate low ILUC-risk project is negative in the absence of incentives from the bioenergy sector. A negative NPV means that the proposed project would not be financially viable on its own, and hence that it would not go ahead under business-as-usual conditions; it only becomes attractive because of extra demand from the renewable energy sector. For the third stage of additionally screening (the highlighted fourth box in Figure 1), the low ILUC-risk rules specify that certification applies only to the fraction of the yield which surpasses business-as-usual performance; this in turn is determined by the \"dynamic yield baseline\", discussed in more detail in Section 1.3. The amount of yield that qualifies as additional depends both upon the success of the additionally measure and upon other external factors that affect the yield with respect to the baseline (e.g., good weather, other changes in management practices).