| Comment | We wish to propose a practical approach to dealing with Indirect
Land Use change (ILUC) that seeks to address the underlying problem
in an effective way.
Our proposed approach (attached) is based on a top down allocation
of actual emissions associated with the land use change (LUC)
attributable to commercial agriculture. This provides a
proportionate response based upon the scale of the actual problem,
rather than the output of a theoretical model.
The pool of allocated emissions is then reduced over time by
attributing specific responsibility for emissions to actors (such
as is being carried out within the Soy Moratorium).
As land use change is progressively managed (reduced), so the ILUC
factor will reduce over time.
This method has been peer reviewed. Reviews are available at:
http://www.ecometrica.co.uk/ecometrica-press-2/land-use-change/
We are currently undertaking further research to develop this
approach and have received interest from a number of European
regulators and biofuel companies.
yours,
Richard Tipper
Managing Director
Ecometrica Ltd
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