# Challenges and Recommendations for Improved Identification of Low ILUC-Risk Agricultural Biomass
## 4 Discussion
These challenges speak to the tension between creating, on the one hand, robust rewards for genuinely additional production, and on the other, a practical system that can be applied on the ground by economic operators with limited visibility on their future yields. To its credit, the European Commission has established some guardrails. For example, an applicant for low ILUC-risk certification must submit their prediction of the yield improvement impact following the change in management practices on their fields (regardless of which types of crops are to be grown). Once certification has been granted and additional yields have been recorded, auditors are directed to refer back to this initial prediction and flag discrepancies of over 20% in the volume of additional biomass produced (which could arise from a strong tailwind). However, this is in itself a blunt instrument and there is no defined process to further investigate such a discrepancy, which may limit the utility of these checks. _Recommendations for Low ILUC-Risk Certification Systems_  
Based on our analysis, we offer the following recommendations for consideration in the development of systems for certifying low ILUC-risk biomass. 1. Yield improvement projections. Existing regulations require economic operators to estimate the impact of their additionally measures on future yields, which is a delicate task for which little to no guidance is provided. This imposes not only analytical burden, but also uncertainty on farmers and on auditors. The Commission could consider devising a template for forecasting, possibly with look-up tables, in collaboration with certification bodies. 2. More localised yield baseline slopes. Current regulations specify use of the global average yield trend for the slope of the dynamic yield baseline. The global average trend is a poor approximation to actual trend yields in many locations, and the use of a single slope of the dynamic yield baseline in all areas tends to exaggerate the systematic unfairness due to headwind and tailwind additionally. Adopting national or regional averages rather than global averages may give a more useful characterisation of what can be expected from business-as-usual yield development in a given location. 3. Surpassing yield predictions. At present, auditors must seek justification when operators' production of additional biomass exceeds the predictions from the management plan by over 20%. What constitutes adequate justification is not precisely specified, nor does the Implementing Regulation specify what (if any) corrective actions should be taken on the part of the auditors if the justification given is inadequate or if the justification confirms that the material is not all additional (e.g., if the justification is that it was a good year for yields for all farms in the region). Without further specification this provision may have limited value in ensuring the integrity of the system; for instance, it does not actually control the benefits arising from tailwind additionally. It would be appropriate to review the application of this part of the rules, and to consider extending discretion to auditors to place some form of limit on the amount of biomass that is treated as additional when this threshold is passed. 4. Practice-based crediting. The aforementioned risk of certifying non-additional biomass due to tailwind additionally and the additionally ratchet has a flipside. This is that operators successfully applying additionally measures and delivering higher yields than would otherwise have been possible may yet find themselves unable to claim certifiable production due to adverse conditions in a given year or years. This uncertainty about rates of credit generation in the face of variability or of inauspicious background trends will reduce the value of low ILUC-risk certification as a driver of improved practices.