ANALYSIS OF THE UNCERTAINTIES OF THE INCLUSION OF INDIRECT LAND USE CHANGE INTO THE EUROPEAN UNION RENEWABLE ENERGY SOURCES DIRECTIVE II

Indirect land use change (ILUC) occurs when vegetable oils which were previously used for food are now also used as fuels, which compels more land to be cleared to fulfil this additional demand. This article analyses the uncertainties and biasness of the inclusion of ILUC into the European Union Renewable Energy Sources Directive (EU RED) II especially towards palm oil. The consideration of a feedstock globally instead of regions penalises sustainable producers of a feedstock. Loading a detrimental projected deforestation percentage on palm oil based on limited publication with high uncertainties is not acceptable. Disregarding the increasing forest cover in Malaysia now at 55.6% due to Malaysian government pledge and intervention to maintain at least 50% of the country as forest cover seems unfair. Projections were based on historical data which contradicts developments and improvements which never follows historical data or events. In terms of oil yield, palm oil is 5.56, 10.53 and 7.84 times more productive than rapeseed, soyabean and sunflower oil, respectively. To substitute one million tonnes of palm oil which can be produced in 250 000 ha yr(-1) will require soyabean, rapeseed and sunflower oil 2 632 500, 1 390 000 and 1 960 000 ha yr' respectively which will increase the greenhouse gas (GHG) emissions from the land use change and ILUC for these crops as well. National sustainability certifications need to be supported by EU to fill the gap and to be recognised to certify the low ILUC risk and additionality. Generally, many components of the Commission Delegated Regulation are very restrictive to palm oil and are presented without clear scientific evidence which appears to be targeted at disqualifying the use of palm oil as biofuel. This can be construed as a form of trade protectionism and more politically driven rather than science.