Neste Oil: European comission indirect land use change (ILUC) public consultation

Publication - March 27, 2012
The core position of Neste Oil on ILUC is that “Clearly it is not possible with any degree of accuracy to give a value for ILUC (p.3)”

27 March 2012

Neste Oil ILUC © Neste Oil


However, “if ILUC actions are taken before the full understanding of the phenomenon the policy should be to offer incentive to do additional ILUC mitigation actions by the operator. The example of such incentives could be added bonus - -. As the intention of the RED directive is to improve the environmental performance of biofuels, then the only workable solution to this problem will be to have all sectors included (p.5)

The best of Neste Oil’s arguments regarding ILUC:

Especially in developing countries, poverty is a major cause of deforestation.(p.1)

It is not reasonable to assume that ILUC could be controlled by imposing restrictions on one industrial sector. (p.1)

Trying to combat ILUC in by starting with a minor user of global commodities is merely poor policy making and in this case, may also be threatening the targets of actions against climate change. (p.1)

Scoping the impact of indirect land use change to biofuels fails to recognize the overall nature or the ILUC. (p.2)

The existing analytical work is also very inadequate in capturing the role of poverty and unemployment in some geographical areas as the underlying driver for LUC (land use change). Stopping biofuel production will not improve the circumstances of the poor. In fact biofuels feedstock production is a major employer and this will reduce pressure on expansion into carbon rich areas. (p.3)

Individual economic operators may only be held responsible for the impacts of their own operations over the whole production life cycle, where they have full control --. Indirect land use changes area outside the control - - and thus outside the scope of an economic operator. (p.3-4)

-- it is not possible to draw sufficiently reliable conclusions. Action should be taken at this stage which does not discriminate against any feedstock or biofuel. (p.4)

-- attempts to introduce control tools might easily provide counterproductive. Including an indirect land use change factor in greenhouse gas calculations for biofuels would definitely be a counterproductive action. (p.4)

Read here how these arguments are highly controversial with contemporary, peer-reviewed, scientific evidence.

Read here the full submission from Neste Oil to the European Commission indirect land use change (ILUC) public consultation:

Neste Oil ILUC