In comments submitted today to the California Air Resources Board (CARB), the Renewable Fuels Association voiced concern that CARB’s recent Biofuels and Land Use Change Public Forum presented a biased and unbalanced view of the current state of research and understanding of indirect land use change (ILUC) analysis. RFA underscored that “CARB’s decade-old ILUC penalty for corn ethanol is obsolete” and must be updated to reflect “methodological improvements in assessing ILUC and more extensive historical data.”
RFA Chief Economist Scott Richman also noted that several of the speakers at CARB’s forum “are longtime critics of U.S. crop-based biofuels who were given a venue to air allegations that strayed far from analysis and sometimes veered into personal opinion unrelated to indirect land use change.” There was little opportunity for rebuttal based on the body of ILUC research that exists or for industry stakeholders to provide input. RFA also raised concern about potential conflicts of interest for some of the speakers chosen by CARB to present their views during the forum.
Richman’s comments also argued that there is no impetus for applying an ILUC penalty to corn ethanol, since corn yield growth has significantly outpaced changes in domestic consumption of ethanol, particularly in California. An analysis submitted by RFA earlier this year shows that the amount of land needed to produce ethanol used in California has fallen significantly since the state’s Low Carbon Fuel Standard was implemented.
Finally, RFA argued CARB’s ILUC analysis isn’t even focused on the right question. “To date, CARB’s ILUC analyses have failed to properly isolate the impacts of the state’s LCFS program on land use,” according to the comments. “We strongly recommend that any future modeling exercises by CARB focus on the right question, which is: What are the land use impacts of changes in fuel consumption attributable to the LCFS program?”
