UFOP questions the scientific quality of the greenhouse gas study from the University of Jena on rapeseed biodiesel

Experts from the Union zur Förderung von Oel- und Proteinpflanzen e.V. (UFOP) question the scientific quality of the study "Uncertainties about the GHG Emissions Saving of Rapeseed Biodiesel" published as part of the "Jena Economic Research Papers" series. In the association's view, it is once again clear that studies which are not subject to neutral testing by experts should not be published, especially when they raise questions about political decisions.

The authors of the study, who work not as academics at the University of Jena but for a private company, criticise their results on the basis that the values listed for the greenhouse gas reduction of rapeseed biodiesel in the EU Directive on the Promotion of Renewable Energies (2009/28/EC) are not correct or not comprehensible. They say that they have been calculated as too high. They arrive at the result that the greenhouse gas (GHG) reduction is just 30%. Thus rapeseed biodiesel would not fulfil the requirement for the quota obligation credit or for claiming a tax concession (at least 35% GHG reduction).

UFOP notes as a grave methodological error that the years 1991 to 2005 were used as the basis for calculations of the EU-wide average rapeseed output. The output calculation is too low. It would have been more appropriate to take into account the average for the last five years in order to take the progress in output into account.

In UFOP's opinion, it would be more sensible to check the calculation methods specified by the EU Directive. In relation to the GHG balance sheet, single-year crops such as cereals and oilseeds are compared with the multi-year cultivation of oil palms.  Crop rotation interactions, such as the positive preceding crop effect of rapeseed in cereal crop rotations, thus have not been taken into account.

The authors have also overlooked the fact that the GHG balance sheet as a European average value is no longer significant, for, according to article 19 paragraph 2 of the Directive, member states have already been obligated since 31st March 2010 to do crop-specific reporting of GHG values, based on the so-called NUTS areas. This means that the member states must demonstrate that the standard GHG value is fulfilled on the basis of this regional sovereign territory and consequently the specified intensity for the production of rapeseed and cereal. 

UFOP takes this study as the occasion to appeal to the scientific community, in this case at the University of Jena, to only publish studies that also claim to offer politically-oriented advice when they have been subjected to an expert review process and this process is also identified in the study. The damage that studies of this type can cause is currently the subject of discussion on the introduction of ILUC factors, discussion of which is based on the so-called IFPRI study. As the client, the EU Commission has failed to subject this study to a scientific review process.