Europe continues to get biodiesel wrong

A provocative opinion piece on Europe's reliance on unsound indirect land use change theory
By Ron Kotrba | May 04, 2016

It is clear there is a politicized agenda in Europe to undermine sustainable, liquid biofuels such as biodiesel and forge a new path toward electrification of transportation. We saw the materialization of this agenda in 2015 with the new rules that came into effect amending current legislation on biofuels in the Renewable Energy and Fuel Quality directives, in which a 7 percent cap on so-called conventional biofuels was put in place while introducing stronger incentives for the use of renewable electricity in transport. The fulfillment of this agenda continues to play out through the manipulation of public perception by way of opaque indirect land use change modeling and biased analyses.

At the behest of the European Commission, IIASA research institute and energy and climate consultancy Ecofys performed a study using the Global Biosphere Management Model (Globiom) to attempt to quantify the impact of indirect land use changes as the result of biofuels consumed in Europe.

Indirect land use change is a questionable pseudoscience modeling approach that, at its core, suggests when agricultural products such as soybean oil are consumed by biofuel production, supply tightens, prices rise and market incentives are provided to essentially establish new cropland to grow comparable products such as palm in order to balance the market. The fear is new cropland is potentially established by the logging—oftentimes illegally—of indigenous rainforest in places such as Indonesia.

The referenced Globiom study and Transport & Environment’s subsequent lifecycle emissions analysis using Globiom’s findings—which haven’t been peer-reviewed and are not open to scientific scrutiny—indicate that when these indirect land use change emissions are taken into account, renewable fuels such as biodiesel are worse than fossil fuels in terms of lifecycle greenhouse gas emissions.

The fact is ILUC is not a science and its use in guiding biofuel policy has been at the heart of heated debate for the better part of a decade—and rightfully so. ILUC is based on hundreds, perhaps thousands, of assumptions that can be formulated with consciously or subconsciously biased points of view, and public and private agendas. In fact, the study recognizes this when it states, “There has been an important debate on whether or not LUC emission factors should be used in biofuel policy. Our results show that LUC emissions are likely to be substantial, but some inherent uncertainty cannot be avoided in the estimation of such emissions and many parameters and assumptions influence the results.”

The Globiom study also importantly states that “ILUC cannot be observed or measured in reality, because it is entangled with a large number of other changes in agricultural markets at both global and local levels. The effect can only be estimated through the use of models. The current study is part of a continuous effort to improve the understanding and representation of ILUC.”   

The study goes on to say that “questions on the uncertainty around LUC impacts have been raised more often and more strongly in recent years.”

Furthermore, it states “It can be concluded that a wealth of analysis has been undertaken on LUC impacts, but significant uncertainties remain in part due to shortcomings in the modeling approaches.”

With all of these known uncertainties in ILUC modeling, why then are we allowing it to drive public policy on biofuels?

Biofuel development has taken a lot of undue criticism from every side—fossil oil companies, food and so-called environmental groups, to name a few. They attempt to use every ill-conceived angle to discredit growth, which bleeds fear of change from the status quo. Oil companies want to retain their monopoly. Food and livestock industries want zero competition for cheap grain, feed and grazing lands. And certain environmental groups want to impede progress at any cost, even if that means chastising movements such as biodiesel that, oblivious to them, are on their side, the stymying of which means certain victory for oil and coal.

No other sector has to stand up to the rigors of ILUC’s bad science. Let’s take the sugar industry for example—even at the risk of marginalizing my farmer-neighbors in the upper Midwest who grow sugar beets, and my factory-neighbors who work in the many sugar processing facilities dotting the landscape here. What more nutrition-less, destructive crop can there be? Here we have a product for which profit-driven candy and sweet-goods companies are constantly and successfully expanding their markets, despite the rampant obesity and diabetes problems in the U.S., and yet these farmers, companies and the sector as a whole are not even held responsible for the direct impacts their products have on society, let alone uncertain indirect land use changes halfway across the globe. Think of all the kale or spinach that could be grown on those lands. Socially noble causes such as biofuels are shamed while indulgent, health-wrecking sugar is heralded as a job creator and wealth builder for farmers and factory workers.

What about the proliferation of fast-food restaurants in the U.S. and around the world? Their consumption of fryer oil is massive, yet as chains continue to pop up across the U.S. in developing countries, the expansion is lauded as progress despite how harmful consumption of fast food has been shown to be. So vegetable oil for fast food is good, despite how bad it is for us, yet vegetable oil consumption for biodiesel is bad, despite how good it is for us. This makes no sense. Thankfully, however, the biodiesel industry over the past decade has marginalized at least some of the indirect land use change effects from fast-food proliferation by recycling used fryer oil for biodiesel production—a fact that biodiesel opponents ignore.

Here is another example of how illogical ILUC is. Imagine a movement sweeps the U.S. to restore farmland natural, forested habitat. Millions of acres of once-tillable land goes back into forested canopy. This would be a good thing from an environmental perspective, right? Nope, because this, according to ILUC theory, would tighten supply on products that were once grown on those lands causing price spikes, incentivizing those same illegal loggers in Indonesia, Brazil or Malaysia to cut down virgin rainforests—forests that are more ecologically valuable than the hypothetically restored forests in North America—so profit-driven palm plantation companies can establish their monocrops to balance the market and provide the world with the goods it demands.

The Globiom study notes a reference period for deforestation is 2005–’12, as biofuel policies globally took off. Interestingly, the study states, “In spite of several initiatives to better control pressures on forests, clearings in Indonesia has increased over time from 0.9 Mha in 2001–’05, to 1.6 Mha in the period 2006–’12. The year 2012 has been marked by the highest deforestation rate registered to date, with more than 2 Mha of forest cleared.” Then, in a footnote in very small print, the study says, “At the time of redaction of this report, newly released statistics for the year 2013 by Global Forest Watch indicate for that year a much lower deforestation rate in Indonesia than on the previous years, at 1 Mha. This information could not be used by the consortium, but would have remained anyway too isolated to conclude that the trend has been reversed in this region…” Interesting, right? The one year deforestation decreases in Indonesia in the past decade is intentionally left out of the analysis, minimized to a footnote.

ILUC studies on biofuels would have you believe that no deforestation took place prior to biofuel development. Let’s see what Birdlife International, which has teamed up with Transport & Environment in several campaigns, says about this. In case study 144 on its website, Birdlife International states:

“Indonesia was still densely forested as recently as 1950, but between then and 2000 c.40 percent of the country’s forests was cleared (FWI/GFW 2002), and this rate of loss is accelerating (see figure). Approximately 10,000 km2 of forest were cleared annually in the 1980s, rising to c.17,000 km2 per year in the early 1990s. Since 1996, deforestation has increased to an average rate of 20,000 km2 per year. These losses are concentrated on nonswamp lowland forest, the type richest in biodiversity. Between 1985 and 1997, Sumatra lost 29 percent of its forests, and Kalimantan 22 percent (Holmes 2000). Unless the rate of deforestation is reduced or halted, nonswamp lowland forest in Sumatra will disappear by 2005, and in Kalimantan by 2010 (Holmes 2000). Indonesia’s forests are being felled for timber and wood-pulp (c.40 million cubic metres per year; FWI/GFW 2002), and the land is then converted to other uses such as oil palm plantations. Indonesia’s production capacity for wood-pulp and paper has grown by 700 percent since the late 1980s, and is at a level that cannot be met by any form of sustainable forest management (Bryant et al. 1997). This growth has been achieved mainly through illegal logging and land clearance. Around 73 percent of log production in Indonesia is illegal and occurs outside designated forestry concessions (Holmes 2000).”

This devastating problem existed long before biofuels came into the picture, but biofuels are a new, convenient, powerless scapegoat on which the problem can be blamed.

How about employing what many would consider a novel approach in today’s culture—putting responsibility where it belongs and hold nations, companies and individuals accountable for their direct actions rather than letting them skate, while indirectly holding environmentally responsible parties accountable for the direct irresponsible actions of others? Let’s hold nations that support destruction of virgin forests accountable by sanctions or other economic measures. Let’s put pressure on these nations to establish robust environmental defense initiatives and enforce the laws already on the books to curb illegal deforestation, and encourage penalizing the parties responsible.

The Globiom study states that, “If … deforestation and peatland drainage in Indonesia and Malaysia could be avoided by introducing appropriate environmental safeguard systems, LUC emissions for palm oil, soybean oil and other vegetable oils would strongly decrease. These effects should be kept in mind when discussing the emission impacts of current biofuel policy.”

Stop buying products from companies that establish crops on newly deforested lands. Market-based initiatives to make this happen already exist through programs like the Roundtable on Sustainable Palm Oil and the Roundtable on Sustainable Biomaterials, to name a few. And government programs such as the U.S.’s renewable fuel standard (RFS) disincentivize palm biodiesel by, for one, attributing lifecycle greenhouse gas emissions reductions that are not low enough to meet the threshold for desirable D4 RIN generation, and two, establishing that the land on which the biofuel crop was grown must have been in cultivation prior to 2008. 

If we must accept the fact that ILUC has become part of the equation, how can Europe ignore the fact that several reputable governments and organizations have conducted extensive, highly scrutinized, peer-reviewed, publicly open, transparent, and scientifically sound lifecycle analyses on biofuels?

The U.S. EPA quantifies soy biodiesel at more than 50 percent reduction in GHG emissions relative to 2005 diesel—and experts say today’s diesel is about 10 percent worse in GHG emissions than 2005’s. In September 2015, California Air Resources Board shows in its readopted LCFS program that biodiesel reduces GHG emissions 50 to 81 percent compared to CARB diesel, essentially classifying it as the most sustainable liquid fuel on the planet. A USDA/University of Idaho analysis shows 76.4 percent GHG reduction for biodiesel including ILUC. Argonne National Laboratory showed a 60 to 120 percent reduction in GHG emissions for biodiesel and renewable diesel.

The European Biodiesel Board characterizes Transport & Environment’s analysis and campaign as “surprisingly biased” and “antibiodiesel.”

“The Brussels-based communication group seem now decided to lobby against biodiesel and in favor of fossil fuels—that seems to be their solution for decarbonization,” EBB states. “By ignoring the lack of credibility of the Globiom modeling, and calling for a 0 percent cap on first-generation biofuels after 2020, Transport & Environment is actually advocating for more fossil fuels in road transport. They do not provide a constructive solution for the decarbonization of transport, in particular for sectors like heavy-duty vehicles and aviation where electrification is not an option.”

The organization also notes that Transport & Environment neglects the fact that, in most cases, the companies investing in advanced biofuels are also those with strong investments in first-generation sustainable biofuels.

Last year, Transport & Environment received €1,993,972 (nearly $2.3 million) in grants from foundations and private entities, according to the EU’s Transparency Register. Money is a powerful influencer.

“We are surprised about the fact that Transport & Environment focuses on unreliable studies such as Globiom, but ignore the study on ILUC done by CARB, which identified biodiesel as the best performing GHG biofuel,” says Raffaello Garofalo, secretary general of the EBB.

Jessica Robinson, the director of communications for the U.S.-based National Biodiesel Board, states, “The CARB process has been the most lengthy and rigorous process in the world. More than seven years of expert review by stakeholders from all sectors have contributed to the ever-improving reputation of CARB analysis. Consistent results have been replicated by Purdue, Argonne, EPA, ORNL and independent contractors. If anything, those other institutions show generally lower ILUC emissions than CARB. These trends have been upheld by independent expert review groups including the ISO Sustainability Metrics Expert Workgroup and the Coordinating Research Council. These results have also been acknowledged by NGOs such as the Union of Concerned Scientists, NRDC and the Environmental Defense Fund.”

Furthermore, Robinson notes that, as the data gets better at reflecting real world events, biodiesel’s benefits consistently improve. Since 2008, the U.S. has tripled biodiesel use, doubled export of whole soybeans to China, decreased U.S. farmland by 18 million acres, decreased protein prices by $20 to $40 a ton, and soybean oil prices have gone down by 40 percent.

While it is true the Globiom study focuses on Europe, and U.S. and European biodiesel policy and patterns are different—in the U.S., biodiesel production more closely follows U.S. consumption patterns so feedstock and production are in sync, resulting in lower lifecycle numbers compared to Europe where feedstock and production numbers are lower compared to use, Robinson says—this doesn’t discount the concerns of those who say the Globiom methodology is wrong.  

The fact is, not a lot is known about the Globiom study. The information behind the study cannot be reviewed publically, so we are left to guess at its assumptions. Does it account for coproducts, or does soybean oil, for instance, get all the impacts though it should only get 20 percent? Does it assign additional penalties because the soy meal competes with EU-produced protein sources?

Here’s what the authors of the study say about its lack of transparency. “Some stakeholders requested our consortium to obtain access to the model. It was not possible to fulfill this wish within the scope of our study, as the model in itself is not ‘open source’ and is proprietary owned by IIASA who invested significantly in developing and fine-tuning the model and datasets used. It is clear that the model, like any equilibrium model, is a highly complex tool, as it represents the entire global agricultural and forestry sectors and the most important global economic drivers and trade relations, with thousands of lines of modeling code. This means it can only be effectively operated by modeling experts. IIASA works with other research groups in several joint research projects, during which those research groups are being trained to use the model and subsequently have access to the model. IIASA is open to collaborate with research group(s) who would like to perform a research project, which could take the form of a peer review of the current study.

“The study consortium had several meetings with the scientific advisory committee, whose role was to critically assess our proposed modeling approach, suggest improvements to the Globiom model and assess draft modelling results. The committee was not involved in the actual modeling but was able to obtain a good overview of the way in which IIASA performed the modeling.”

Ultimately, if incorporation of the clearly questionable ILUC theory is forevermore to be part of biofuel analysis, then what is good for biofuels must be also good for oil, food, sugar and electrification of transportation. No longer should the societal costs of fossil fuel be externalized. And with all of the technological shortcomings of electric transport, use of electricity—renewable or not—displaces current, more conventional power uses, leaving the market begging for additional supply that may come through coal, nuclear or other undesirable means. 


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