# Challenges and Recommendations for Improved Identification of Low ILUC-Risk Agricultural Biomass
## 3 Results
### District-Level Above-Baseline Production
#### 3.2.2 Variability and the \"Additionally Ratchet\"  
Results such as the ones shown in Figures 8 and 9 imply varying levels of tailwind and headwind additionally for projects in different parts of the same country, with larger differences possible in countries with wide \"yield improvement gaps\". On the other hand, a country exhibiting a _small_ yield improvement gap may do so for a number of reasons: because there are uniform yield trends throughout the country; because the crop in question is grown in a small area of the country; or because there is a low rate of data reporting. We investigate variability at sub-national scales by calculating the \"above-baseline\" yield determined for each district, that is, the difference between the historically recorded yield and the baseline yield, which would be identified as additional by the low ILUC-risk methodology. Any significant amount of above-baseline production evident in these data would therefore indicate a limitation of the low ILUC-risk methodology, as it shows that non-additional material may be certified as additional. Figures 10 and 11 zoom into specific districts of two countries, to show the amount of above-baseline winter wheat that could be declared in each. The premise is that we consider a hypothetical typical farm in each district; this farm has a corresponding panel in the figures, indicated by the NUTS2 code in the legend. For the example under consideration, we say the farm gains low ILUC-risk certification in 2012; this means the initial point of its dynamic yield baseline is determined from records in the three-year period 2009-11. The baseline for each district is represented in the figures by straight dashed black lines spanning the ten years 2012-21; the actual data for the district are shown as solid, coloured lines, and the national average (for comparison) is the dotted coloured line in each district panel. Crop production above the baseline is shaded; this area represents the potential yield that could be spuriously certified as low ILUC-risk. The average above-baseline yield over the period is annotated in each panel. Based on the recorded district-level data, our certified \"farms\" would have been able to declare a varying amount of above-baseline production as low ILUC-risk, though in reality no additionally measure was taken; all effects are purely based on business-as-usual background trends. The Hungarian case in Figure 11 shows large above-baseline gains, and, consulting Figure 5, we indeed see that Hungary has a history of high yield growth compared with the global average. Inspection of the Austrian case in Figure 10 reveals a different phenomenon. Figure 5 shows that Austria's national yield growth is similar to the global average, but we still see substantial amounts of material above the baseline. This is because the Commission's methodology dictates that positive yield fluctuations are counted as additional, while negative yield fluctuations are bounded from below and are treated as zero additional material. This can be described as an \"additionaly ratchet\"; a ratchet is a wheel designed to only turn in one direction, and here we see that additionally is only credited in one direction (i.e., above the baseline). This means that the running total of \"additional\" production--from fluctuations or otherwise--can only increase. The new terms introduced in this paper to describe phenomena related to the RED II methodology are summarised in Figure 12.  
Figure 10: Above-baseline production for hypothetical Austrian low ILUC-risk projects which grow winter wheat and gain certification in 2012; the yield patterns are assumed to follow the district average. Note that each panel in this figure corresponds to a different NUTS2 district within Austria (AT); the district ID is indicated in the panel legend, along with the average above-baseline production in parentheses.