Fores – Forum för reformer och entreprenörskap
Fores
Fores – Forum for Reforms, Entrepreneurship and Sustainability – is the green and liberal think tank.
ID: 646210732392-25
Lobbying Activity
Response to High and low Indirect Land-Use Change (ILUC) - risks biofuels, bioliquids and biomass fuels
8 Mar 2019
The proposal, while well meaning, is too arbitrary.
ILUC can hardly be calculated with any accuracy, it is a flawed system. We strongly support that all industries carry the burden of their environmental impact, but this does not mean that one industry should carry the burden of others.
The 2015 so called GLOBIOM report argued that Land Use Change should be the measuring stock rather than the vague ILUC. We support that.
Now, in the suggested delegated act the Commission attempts to divide between High ILUC risk, and Low ILUC risk. On the one hand, production leading to deforestation is deemed to have high ILUC, on the other hand if this is not the case, and if some increased production can be measured it is low ILUC risk.
Our general aim should be to increase agricultural production with decreased environmental impact. We need a more detailed approach to differentiate between one and the other, and we need to see both a carrot and a stick to ensure this development.
The Government of Norway has been in discussion with Indonesia since 2010 in efforts to decrease and halt deforestation. They have now seen enough positive change with verified decreased forest loss to start paying out a first payment rumored to be around 20 million dollars. This is the carrot. At the same time the Norwegian Oil fund has disinvested from 33 palm oil projects for environmental reasons. This is the stick.
For the Commission proposal we have the following comments:
First, the Commission should move away from ILUC, and move towards LUC.
Now, from one perspective we understand the global outlook, the market is global. But it is far-fetched to classify one country’s production based on another country’s bad example. Also, we do not want a good regional production practise to allow other production facilities to increase their environmental impact.
We do need a cut off date, and we do not want to benefit companies that sped up deforestation in recent years, just to benefit from a lax policy. But we need a faster track for a production that can prove an increased yield without encroaching on forest land. A fixed date could be preferred.
We support that only actual increases in productivity can be low ILUC risk. A plan to increase productivity is not enough.
We would like a positive criteria for production to be declared as low ILUC risk based on past performance. Most agriculture can show impressing increases in productivity, and should be rewarded.
Overall, formulate the delegated act as a way to support and incentivise positive development of different regional markets, in order to define a path way for sustainably produced biofuels.
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