The Issue of Indirect Land Use Change Associated with Biofuel Consumption; Submission to the European Commission

October 2010 – A Submission by World Growth

The EU Renewable Energy Directive directs the European Commission to prepare a report on the issue of indirect land use change associated with biofuel consumption.  The Commission is expected to present its report to the European Parliament and the European Council in December 2010.  Early in 2010 the Commission commissioned a number of analyses of different aspects of the issue. These analyses consist of three modelling analyses of the greenhouse impacts of indirect land use change, together with a review of the literature on this subject.  The Commission has published the reports of these analyses together with a Consultation Document. The latter seeks the views of interested parties on a series of speci?c questions to ensure the Commission’s report re?ects the latest thinking and evidence on the subject.  It has sought responses by 31 October 2010. This submission sets out World Growth’s responses to each of the questions in the Consultation Document.

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