Indirect land use change: ARB needs evidence, not theory

When the Greek philosopher Aristotle presented fellow scholars with empirical evidence and scientific proof that the world was round—not flat—around 330 BC, he was called a lunatic and a charlatan. Aristotle’s contemporaries were so blinded by their own preconceptions about a Flat Earth that not even a Hubble Telescope photo of our spherical world could have convinced them otherwise.

More than two millennia later, Sacramento has its own version of the Flat Earth Society—the California Air Resources Board (ARB). Only this time, the debate isn’t over the shape of the Earth; it’s over an obscure regulatory concept known as Indirect Land Use Change (ILUC), a component of the state’s Low Carbon Fuels Standard (LCFS).

In September, ARB told a room full of stakeholders that examining real-world land use data is “not productive.”

First, a little background. As part of its LCFS, ARB ranks individual transportation fuels based on the GHG emissions tied to the fuel’s production and use. To comply with the regulation, California fuel suppliers must annually lower the GHG intensity of the fuels they sell. Thus, fuels with low GHG rankings will be favored over fuels with comparatively higher GHG scores.

As ARB went about determining GHG scores for various fuels in 2009, it decided to include hypothetical ILUC emissions for biofuels like ethanol and biodiesel, without clear evidence they exist or can be measured. ARB’s theory was that increased use of crops like corn and soybeans for biofuels would lead farmers around the world to convert forest and grassland to cropland to replace crops “diverted” to biofuels. Converting these lands would release significant amounts of stored soil carbon into the atmosphere. ARB reasoned that these theoretical emissions had to be counted, whether they actually occurred or not. The agency used complex computer models and debatable assumptions to estimate that ILUC would increase GHG emissions for crop-based ethanol by 50-170%. Biodiesel and renewable diesel GHG emissions increased by up to 300%. According to ARB’s GHG scoring, average corn ethanol fares worse than gasoline due to the addition of ILUC emissions. The problem is these models were never validated to be accurate by comparing their results to real-world observations.

ARB still has an opportunity to put down the Flat Earth maps and pick up a globe.

So, back to Aristotle. Over the past five years, academics and industry stakeholders have provided ARB with empirical evidence showing that the land use changes predicted in 2009 have not occurred. But like Aristotle’s contemporaries, the agency has been so fixated on its own presumptions that the real-world data on land use have not been used.

The latest evidence comes from economists at Iowa State University, including Prof. Bruce Babcock (who earned his Ph.D. at UC Berkeley and once was an expert consultant to ARB). Rather than relying on computer models, the researchers examined real-world data on global land use patterns over the past decade. They found little or no evidence that native lands have been converted to cropland in response to U.S. biofuel expansion. Instead, “…the primary 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. This finding is not new. …But this finding has not been recognized by regulators who calculate indirect land use.”

ARB’s response to the empirical data and real-world observations? In September, ARB told a room full of stakeholders that examining real-world land use data is “not productive.” In other words, the agency prefers to continue relying on ideological theory and arcane computer models, dismissing the crucial step of validation.

The practical effect of including ILUC in the LCFS is that most crop-based biofuels will not be viewed as a viable means of complying with the regulation in the future. ARB itself expects corn ethanol use in California to fall by half over the next five years. California fuel costs will increase as more expensive substitutes are forced into the market, most likely imported from South America and Malaysia. Meanwhile, development of even cleaner fuels in California will slow as the economic platform created by first-generation biofuels erodes.

ARB is currently revising its ILUC analysis and new results are expected within weeks. But by all accounts, the latest analysis continues to favor theory over reality. It remains riddled with assumptions and judgment calls, and continues to devalue biofuels for imagined GHG emissions. But it’s not too late to fix the LCFS regulation. ARB still has an opportunity to put down the Flat Earth maps and pick up a globe. After all, as Aristotle once wrote, “Even when laws have been written down, they ought not always remain unaltered.”
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Ed’s Note:  Steve Shaffer, who resides in Davis, served eight years as Director of the California Department of Food and Agriculture’s Office of Agriculture and Environmental Stewardship. He is currently an environmental consultant to the agriculture industry.