Answer to the Commission’s consultation on ILUC (indirect land use change)
The Academy does not think the analytical work presented provides the necessary basis for regulation of ILUC at this time, and stresses certain points, such as crop yield and yield response, availability of land, handling of co-products, converted land. The Academy thinks that the analysis is based on complex modelling using numerous assumptions and estimations that can vary greatly between different researchers and studies. The end results therefore also vary within a very wide range.
The Academy does not think that action is needed to address indirect land use change – it is not adviceable to base legisation on such uncertain grounds.