WASHINGTON — The Renewable Fuels Association (RFA) applauded the Oregon Environmental Quality Commission for its decision to exclude indirect emissions when calculating the carbon intensity of various fuels regulated under the state’s Clean Fuels Program (CFP). Phase 2 of Oregon’s CFP was approved by the Commission today in Portland.
The Oregon CFP bears close resemblance to the California Low Carbon Fuel Standard (LCFS) in that both programs aim for a 10 percent reduction in the carbon intensity (CI) of transportation fuels used in the state over a 10-year period. However, the two programs take fundamentally different approaches to estimating the CI of individual regulated fuels. Oregon’s pragmatic approach ensures that all fuels are analyzed consistently and fairly by basing CI estimates strictly on verifiable, direct emissions. Meanwhile, the California LCFS uses predictive economic modeling scenarios to penalize certain biofuels for theoretical “indirect land use change” (ILUC) emissions, while assuming no other fuels induce any indirect GHG emissions at all.
In its recommendations to the Commission, Oregon’s Department of Environmental Quality (DEQ) reported that “Recent data has shown that both food (human and animal) and fuel production has increased while the amount of land farmed has stayed constant.” Thus, DEQ proposed to exclude ILUC emissions for now and resolved to “…continue to monitor the status of technical work on this issue and will determine whether to recommend including ILUC and other indirect effects in a subsequent rulemaking, as appropriate.”
In response to the decision, Bob Dinneen, president and CEO of the Renewable Fuels Association, stated, “Oregon officials used common sense and good judgment in proposing and approving the framework for Phase 2 of the CFP. All fuels have indirect carbon effects. But even after five years of rigorous debate and analysis, there is still no consensus on the best methods and data for estimating—and verifying—those effects for all fuels. On ILUC specifically, results from economic computer models remain disparate, highly uncertain and subject to debate. Oregon did the right thing by taking a careful approach to indirect effects and not putting the policy cart in front of the science horse. We hope other jurisdictions considering LCFS-like policies will follow the lead of Oregon and British Columbia when it comes to carbon intensity scoring.”
Dinneen also pointed out that real-world global land use data is casting grave doubt on the hypothetical scenarios and predictions used by California for the LCFS. A November report from researchers at Iowa State University’s Center for Agricultural and Rural Development (CARD) examined empirical land use data from 2004 to 2012. They found that “…the primary land use change response of the world’s farmers in the last 10 years has been to use available land resources more efficiently rather than to expand the amount of land brought into production.” The researchers pointed to California’s LCFS, noting that, “This finding is not new…however, this finding has not been recognized by regulators who calculate indirect land use.”