# Challenges and Recommendations for Improved Identification of Low ILUC-Risk Agricultural Biomass
## 4 Discussion  
The European Union's \"low ILUC-risk\" system for biofuel certification allows economic actors in this sector to demonstrate that they have avoided the indirect land-use change (ILUC) impacts associated with growing crop-based biofuel feedstocks. The goal  
Figure 16: Total additional yield of winter wheat in district AT31 (Austria) over the ten-year certification period, split into genuine and spurious improvement. Note that the vertical axis starts above zero in order to magnify the above-baseline portion. of this paper was to investigate the potential implications of how the rules for calculation of additional biomass production by yield improvement projects have been defined in policy. In particular, we have assessed provisions for calculating baseline yields; these are the baselines against which actual observed yields are to be compared when assessing the success of yield improvement measures undertaken by participating farms. The baselines thus determine the amount of agricultural production that can be certified for the market as low ILUC-risk. The first step of this research was the creation of a cleaning pipeline for publicly available Eurostat data on crop productivity, covering countries in Europe at the national level and EU Member States at the scale of NUTS2 districts. We provide the final dataset and processing routine alongside this paper (see Annex B of the Supplementary Material) in the hope that it may be a useful starting point for other researchers or national agencies. This dataset then allowed us to quantify--at the NUTS2 district level--variability in crop yields and yield growth over time for a range of crops, including the cereal crops barley (summer and winter seasons), wheat (summer and winter seasons), durum wheat, maize, rye, sorghum, and triticale; the oil crops rapeseed (summer and winter seasons), sunflower seed, and soybean; and the sugar crop sugar beet. On the basis of this, we were able to analyse potential weaknesses of the RED II low ILUC-risk methodology, whereby business-as-usual production of agricultural biomass could be wrongly classified as additional. The first of these potential weaknesses were termed \"tailwind additionally\" and \"headwind additionally\". These effects are the result of background yield trends, which would make it easier or harder for projects to report production of additional biomass based on their geography, among other factors, rather than on the actual implementation or success of improved farm management practices. Were there to be widespread uptake of the low ILUC-risk concept, tailwind effects could tend to encourage the introduction of low ILUC-risk projects and cultivation of bioenergy feedstocks in areas where background yield growth is high. This would have the effect of allowing business-as-usual yield gains to be labelled as low ILUC-risk biomass and diverted into the bioenergy sector, undermining the goal of using certification to reduce ILUC emissions by identifying only additional biomass production. On the other side of the coin, headwinds would undermine the potential to use low ILUC-risk certification to support efforts to improve agricultural practices and productivity in areas where yield growth is low, as headwinds reduce the amount of truly additional biomass that could be detected and certified. A second potential weakness of the RED II methodology was termed the \"additionality ratchet\"; this is where weather-driven annual yield fluctuations above the baseline are treated as additional, while fluctuations below the baseline are ignored. To illustrate, consider a low ILUC-risk project where the adopted yield increase measure fails for some reason; in principle this project should generate no creditable feedstock. However, the additionally ratchet guarantees that such a project will generate spurious additional material in every year in which the weather is favourable to the crop being grown, resulting in above-average yield.