Ref. Ares(2016)1398783 - 21/03/2016
328B/PRO/15
Brussels, July 10th, 2015
TO: Mr. Frans Timmermans, First Vice-President for Better Regulation, Interinstitutional Relations,
the Rule of Law, and the Charter of Fundamental Rights
CC: Mr. Dominique Ristori, Director General Commission, DG Energy;
Ms. Yvon Slingenberg, Cabinet of Energy and Climate Action Commissioner M. Cañete
Mr. Jo
ão Aguiar
Machado,
Director General of DG Mobility and Transport
Mr. Jos Delbeke, Director General of DG Climate Action
Mr. Jerzy Plewa, Director General of DG Agriculture and Rural Development
Mr. Robert-Jan Smits, Director General of DG Research and Innovation
Mr. Daniel Calleja Crespo, Director General of DG Internal Market, Industry,
Entrepreneurship and SMEs
Re: Biodiesel chain concerns about the lack of scientific openness in GLOBIOM�s ILUC
modelling funded by DG Energy
Dear Sir,
Our industrial and agricultural associations represent the European production chain of biodiesel. We
would like to attract your attention to our deep concerns about the lack of scientific openness of an
ILUC modelling study - denominated GLOBIOM - which is being performed by the IIASA research
Institute, within a consortium co-ordinated by Ecofys and funded by the Commission Directorate
General for Energy.
We understand that the results of such a study could be published in the next months. However,
considering that the results of this modelling exercise could be used as a basis for the EU's future
biofuel policy, the lack of scientific transparency in GLOBIOM becomes highly problematic when we
look back at the controversies that surrounded the ILUC debates. In spite of various written and
verbal requests that we made to IIASA and Ecofys, the following points raise our concerns:
although our associations provided data and information to Ecofys and to the IIASA experts,
we have no information about whether this data or that of other sources will be used and
retained. In fact, the full (and extremely large) set of statistical and quantitative data (from
agriculture, industry etc.) on which the GLOBIOM exercise is running is so far unknown to the
public and interested stakeholders (except from some very draft and partial excerpts which
have been provided to us for very specific comments);
the range of assumptions and scenarios that will be used by the model was announced in
general terms but the effective data, the detailed quantitative figures and the equations used
are today still unknown;
in fact, despite a clear commitment from the GLOBIOM consortium to publish a document
with key parameters and descriptions of main datasets, with a view to allow for comments on
data and definitions, stakeholders have not been consulted on how the consortium progressed
with data and definitions. Since the sensitivity of data used and definitions applied to the
model have a significant impact on the end results, the biodiesel chain finds it unacceptable
that the modelling was carried out without even a minimum of openness with regard to data
and definitions, despite a clear commitment (page 3 of 20 February 2014 meeting minutes
between our Associations and Globiom representatives).
an advisory board of experts that was set up by the Consortium, officially for consultation
purposes, held one face-to-face meeting at the very beginning of the project for introduction
purposes and then only held a very limited number of short conference calls where
attendance and representation was uneven. The experts on this advisory board where only in
very general terms aware of the work done by IIASA. Although free to comment on the work
and to propose changes to the dataset decisions, they had no direct access to the scientific
activities, neither to the full data or the methodologies of the study as they were only
informed by conference-cal s;
most importantly, although Ecofys considered IIASA could possibly allow partner research
institutes/universities, to run the model for sensitivity analysis, IIASA clearly indicated on
many occasions that the "GLOBIOM model" itself, with its full set of equations, figures,
methodologies and assumptions would not be available for use or cross-checking by any
researcher other than the very few employed on this subject by the IIASA. We enquired as to
whether this is due to an economic issue linked to the defence of GLOBIOM intellectual
property, but GLOBIOM categorically refused to make the model available, despite being
offered adequate royalties for temporary access.
This creates a situation whereby the IIASA will publish a study - funded and supported by the
European Commission - with findings which will not be peer reviewed prior to publication, but which
are going to be presented to the public as the result of objective, scientific research likely to be
promoted by the European Commission as basis for policy decisions.
In a letter dated January 20th 2015, following the concerns raised by one of our Associations, Ecofys
indicated to us that: Unilateral access to the model will not be possible. Not just for the reasons of
costs that we discussed earlier, but also because we feel that the debate on ILUC quantification is not
served by unilateral reviews. However, IIASA is open to facilitating a real independent review of the
model and our modelling exercise if credible guarantees of independence, and hence added value
beyond this project, could be provided. Such an independent review can only take place after the
modelling results have been published to avoid a delay in our study time planning.
According to this statement the GLOBIOM results would be published by the IIASA and the
Commission before and not after a truly open peer review will be realised by other independent and
recognised groups of experts. We believe that, given the strong impact that these study results will
almost certainly have on long term biofuel policies, and the potential damage it could cause to our
industries and the image of biofuels as already happened for the IFPRI study, the European
Commission should ensure that such a review takes place before the final GLOBIOM ILUC model
publication.
We believe in fact that transparency and scientific openness should be the key word of all Commission
action or funding especially in sensitive thematic areas and issue as ILUC is. The ILUC debate in the
past has been characterised by a high degree of confusion if not disinformation that has largely
damaged the EU biofuels and biodiesel industry: it is now time to come back to scientific openness
and EU institutional transparency.
This is why we believe that it is crucial that the GLOBIOM model, the full data-set, equations,
variables and assumptions employed should be made available to the academia or at least to two or
three other scientific groups of experts well on time before publication.
A transparent scientific approach to the issue of land-use and biofuels would be particularly important
in order to make the debate on post-2020 transport decarbonisation less emotional, by establishing a
more rational and open perspective. This needs all studies, and particularly those published by the
European Commission to be based on facts and figures whose scientific basis, assumptions and data
are transparently available to the scientific community and whose methodologies and work have been
fully peer-reviewed by independent scientists.
Kind Regards,
Raffaello Garofalo
Philippe Dusser
Nathalie Lecocq
Secretary General of EBB
Secretary General of EOA Secretary General of Fediol