Anticipated Indirect Land Use Change Associated with Expanded Use of Biofuels and Bioliquids in the EU – An Analysis of the National Renewable Energy Action Plans


This study represents a first analysis and estimate of the effects of Indirect Land Use Change (ILUC) associated with the increased use of conventional biofuels that EU Member States have planned for within their National Renewable Energy Action Plans (NREAPs). These documents specify how European governments plan to deliver their transport targets under the Renewable Energy Directive (RED). 23 NREAPs were available at the time of drafting and the analysis is based upon these. ILUC effects have been
calculated using recently released studies by the European Commission.

The RED target, for 10% of transport fuel to be from renewable sources by 2020, is anticipated to stimulate a major increase in the use of conventional biofuels up to 2020, contributing up to 92% of total predicted biofuel use or 24.3 Mtoe in 2020. This would represent 8.8% of the total energy in transport by 2020; 72% of this demand is anticipated to be met through the use of biodiesel and 28% from bioethanol. Member States are anticipating importing significant proportions of these fuels and their associated feedstocks. Figures reported equate to 50% of bioethanol and 41% of biodiesel in 2020. However, actual imported levels of feedstock are anticipated to be higher as it is unclear whether the imports anticipated by Member States refer to feedstock for ‘domestic’ processing into biofuels as well as imports of processed biofuels.

Additionally Member States are estimated to be sourcing 4349 Ktoe of bioliquids from conventional feedstocks in 2020. Used for heating and electricity, these will have similar ILUC consequences as for biofuels representing an additional emission source of greenhouse gas emissions(GHG). ILUC impacts from these bioliquids are estimated to equate to an area of between 1 and 1.9 million ha and GHG emissions of
between 211 and 400 MtCO2e.

In 2020 15,047 Ktoe of the biofuels used would be additional to 2008 levels and sourced from conventional ie primarily food crop based feedstocks; this can be considered to be additional demand stimulated by the RED. Using currently available data, this additional demand for these fuels is anticipated to lead to between 4.1 and 6.9 million ha of ILUC ie an area equivalent to just larger than Belgium to just under that of the Republic of Ireland. This additional ILUC was calculated to result in between 44 and 73 million tonnes of CO2 equivalent (MtCO2e) on an annualised basis ie between 876 and 1459 MtCO2e in total. Under the RED biofuels must deliver a required level of GHG savings relative to fossil fuels to count towards the targets. Even when this saving is taken into account estimated additional GHG emissions arising from ILUC are between 273 and 564MtCO2e (for the period 2011 to 2020) or between 27 and 56 MtCO2e annually.

The latter equates to up to 12% of emissions from EU agriculture in 2007 or 6% of total transport emissions. Put another way this would be equivalent to between 12 and 26 million additional cars on theroad across Europe in 2020. Based on this assessment, and the assumptions adopted, use of additional conventional biofuels up to 2020 on the scale anticipated in the 23 NREAPs would lead to between 80.5% and 167% more GHG emissions than meeting the same need through fossil fuel use.

This analysis was based on what were considered the most appropriate assumptions using the evidence and models available at the time of drafting. However, sensitivity analysis shows that even with far lower estimates of ILUC arising per unit of additional biofuel consumption and of GHG emissions per unit area of ILUC the use of conventional biofuels envisaged in the NREAPs fails to deliver the reduction in GHG emissions required under the RED, and leads to an increase in GHG emissions overall. This analysis underlines the need to address the question of ILUC as a priority for biofuels policy and to include ILUC in the criteria for assessing whether biofuels should count towards the delivery of targets under the RED for 2020, and more generally EU European climate change mitigation goals. Moreover, it also raises urgent questions about the appropriateness of projected levels of conventional biofuel use by Member States in 2020. Many have focused little effort in their NREAPs on promoting advanced biofuels or pursuing a greater efficiency in their transport sector so as to reduce the overall climate burden.


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