Object of criticism – the IFPRI Study

Hypothesis or reality?

At first the basic concept that the cultivation of oilseed in the European Union for use as biodiesel leads to an expansion of cultivation elsewhere for harvesting plant oils is obvious in principle. The decisive question, however, is whether the results of the IFPRI study can offer a sufficient scientific basis for determining the ILUC factors within the framework of the Renewable Energy Directive (2009/28/EC). The EU Parliament also decides that. The EU Commission sees itself subjected to this criticism and underlines that ILUC factors are already justified as preventive measures. However, in view of the consequences this argument is unsustainable as in principle it would be applicable to all dangers.

In the ILUC debate a great many points of factually grounded criticism – including from the scientific community – were brought forward:

Different market significance of crops

The ILUC hypothesis says, for example, that the cultivation of rapeseed in Germany, of which around 1 million hectares serves for the cultivation of biodiesel production, leads to the extension of soya or oil palm acreage in South America and Asia – at the expense of the rainforest areas. The problem in calculating this effect consists, on the one hand, of the fact that the crops in question such as soya or oil palms must be assessed differently with regard to their market significance. Soya is primarily grown as a source of protein for feedstuff production, oil palms by contrast especially for use as food, for the oleochemicals and cosmetics industries. On the other hand the share of raw materials for biodiesel production is relatively small measured alongside the global requirement. Only 1.6 per cent of the global acreage of 1.53 billion hectares (FAO) is used for biofuel production (incl. bioethanol). Furthermore the different crops also differ significantly with regards to their biology. Moreover the question arises of why ILUC factors are only considered in calculating GHG balance sheets for biofuel materials. From an environmental point of view it would be absurd if no comparable GHG requirements had to be applied as a precondition for market access for the material use of sustainable raw materials. This shows clearly that the ILUC debate is still to reach areas of the bio-economy that are currently developing new product lines at enormous financial expense.

Uncertainties in ILUC models

The deficiencies and uncertainties in the ILUC models, which have been recognised by the EU Commission, have not been cleared up by the IFPRI and JRC. The model used by the IFPRI is not suitable for determining the ILUC. The results of the JRC are thus inadequately grounded in data.

The reports make the following statements:

• Fundamental uncertainties concerning the extent and regional distribution of land use changes stand in the way of ILUC quantification.
• The models used cannot distinguish between indirect and direct land use changes.
• The reports are based on a large number of uncertainties. In addition the reports are also based on significant errors in the data.

Weaknesses of the IFPRI study

• The study assumes that a higher global demand for agricultural produce leads to the destruction of rainforests. However, the clearing of forest areas is dependent on many factors, especially political ones.
• The EU sustainability standards could block land use changes. But the study does not take this into account.
• Government protection for valuable areas such as rain forests is not evaluated.
• There are many uncertainties in the assumptions. The study also points these out.
• The feedstuff value of rapeseed cake from biodiesel production is underestimated. Rapeseed meal from biodiesel production replaces protein feed made from soya in bovine feedstuffs proportionately.

Because of the uncertainties in the IFPRI and JRC studies, UFOP rejects the plan the EU Commission is considering to introduce ILUC factors either globally or differentiated according to raw material base.

End of the fossil era only with biofuels

According to the objectives of the European Union, renewable energies, which means biofuels above all, due to their important role in climate protection and energy provision, should account for around 10 percent of the transport sector's energy requirement by 2020. Currently it is a good 4 per cent. The ILUC debate ignores the fact that the end of the fossil age is also a matter of political will. Without an energy mix – which undoubtedly includes biofuels – this objective cannot be achieved. The agriculture and forestry industries are confronting the new challenges and would like to make a contribution to this.

Punishment of European farmers for cultivation methods overseas

An ILUC factor would punish European farmers, who ensure the sustainability of their agriculture via a multitude of national and European legal requirements, for environmentally-damaging methods of cultivation practised overseas.

Brazil example

In reality the ILUC theory has long since been refuted, for example in Brazil. There the clearance of rainforest has fallen by 75% since 2004, while biofuel production has doubled. This is the consequence of the ongoing, and German-supported, rainforest protection program "Amazon Region Protected Area" (ARPA). Effective protection of rainforest can only be achieved through local government initiatives and not through an ILUC penalty imposed on raw materials grown in Europe.