Title : Rethinking the iLUC factor in sustainable aviation fuels
Abstract:
Today, I present a critical analysis and proposal regarding the elimination of the indirect land use change (iLUC) factor in the environmental evaluation of Sustainable Aviation Fuels (SAF), with a particular focus on the Argentine context and global implications.
The iLUC factor has long been used to estimate the environmental impact of biofuels, penalizing or weighting certain crops based on assumed changes in land use. However, recent studies and industry experiences in Argentina have highlighted the arbitrary nature of the iLUC values employed by regulatory bodies such as CORCIA. These values are often applied without robust scientific evidence, leading to policies that are not only unilateral and discriminatory but also detrimental to exporters who strive for sustainability.
A detailed examination of the iLUC indicator reveals significant subjectivity. For example, default values for soybean oil biodiesel are typically set at around 75 gCO?e/MJ. Some proposals suggest that, through advanced agricultural practices and the use of degraded lands, emissions could be reduced by up to 30%, reaching approximately 50 gCO?e/MJ. Yet, these calculations are highly dependent on the models and historical data used, which vary widely across sources and timeframes. In Argentina, actual values considering production, logistics, and transformation are closer to 25 gCO?e/MJ, underscoring the disproportionate nature of default assignments.
The core issue lies in the scientific imprecision of the iLUC factor. Its estimation relies on assumptions, market scenarios, and data sources that differ dramatically depending on the chosen model. This variability introduces a level of uncertainty so great that it becomes impossible to objectively distinguish between a biofuel “free of iLUC” and one with significant impacts. The lack of empirical data and the ongoing need for methodological adjustments mean that the iLUC indicator lacks a solid scientific foundation.
Exporters face an asymmetric position. Despite implementing sustainable practices and optimizing land use, they are forced to accept default iLUC values applied uniformly, regardless of their specific production chains. This results in adverse environmental ratings that may not reflect the true impact of their activities, imposing an unfair and undifferentiated burden that limits the competitiveness of potentially more sustainable products.
Given the absence of consistent empirical evidence and the high variability of results, this proposal advocates for the progressive elimination of iLUC indicators in biofuel environmental assessments. Instead, evaluations should be based on direct, verifiable data regarding land use changes. Such a shift would create a fairer framework, ensuring exporters are not penalized by predetermined values lacking scientific justification.
In summary, while various scenarios attempt to minimize iLUC-related emissions in biofuels, the evidence demonstrates that the models’ variability and subjectivity prevent the indicator from being grounded in solid science. This perpetuates an asymmetric situation for exporters, who must accept default environmental impacts without the opportunity to prove their products’ true sustainability. Therefore, it is imperative to eliminate these speculative indicators and focus on assessments rooted in direct, verifiable data.
