This week, the California Air Resources Board (CARB) convened a group of experts to discuss issues related to the Low Carbon Fuel Standard (LCFS) that was approved last year. The Expert Working Group has been working to examine the gaps in the original research produced by CARB staff which was used as the basis for fuel regulation, including the highly disputed indirect land use change (ILUC) theory which threatens the future of biofuels in California and across the country. The group has been meeting every few weeks over the course of this year and will provide regulatory amendments to CARB in September.
While those of us at the California Ethanol Vehicle Coalition appreciate that CARB is convening this group in order to better refine its regulations, we still feel that it is clinging too closely to discredited ILUC theories. According to the bizarre ILUC theory, corn used for ethanol follows a hypothetical chain of events that ultimately ends in Amazonian deforestation. Because it is “indirect” it can’t be tracked, so CARB uses an economic model to hold American biofuel producers responsible for carbon emissions they have no control over—the carbon emitted from a Brazilian farmer clearing a rainforest. Under these flawed calculations, corn ethanol has a carbon score similar to gasoline and would be shut out of California.
There is now new scientific evidence that undermines the entire concept of ILUC theory. Although CARB was warned about this prior to adopting the LCFS, it moved forward with approving the regulation anyway. Even worse, CARB now has been presented with new data showing far less indirect effects than their estimate by Purdue University’s Dr. Wally Tyner – the same researcher that developed the original model adopted by CARB – yet has failed to move forward in adopting it. This new modeling raises the question of whether CARB should revisit ILUC penalties on grain ethanol. This is something we urge them to do today. Why would we not use the best science available in determining our fuel regulations?
Today’s grain ethanol fuel is a finely-developed, low-carbon alternative to oil. A recent peer-reviewed study published in Yale’s Journal of Industrial Ecology found that grain ethanol is 59 percent cleaner than conventional gasoline. With such a significant reduction in greenhouse gasses, there is no doubt that grain ethanol is a low-carbon fuel. Additionally, the production of grain ethanol is becoming cleaner and more efficient. Our nation’s ethanol makers are constantly driving the development of new bio-refinery technology, whether it is the recycling of energy in ethanol plants, or reducing water u se in plants. They are also working to create second-generation ethanol, like cellulosic, a product even cleaner and more efficient than grain ethanol. It would be silly to put this practical technology at a competitive disadvantage because of CARB’s insistence on using discredited science.
We encourage CARB to work with the ethanol industry to allocate resources for a thorough research deployment plan that is capable of looking at the ILUC theory from all angles, across all fuel types, in as transparent a way as possible. Applying controversial indirect penalties against ethanol, and not other fuels – including fossil fuels – puts our only commercially-viable alternative to oil at a disadvantage, and places additional obstacles in our nation’s path to carbon neutrality and fuel independence.
The stakes of this policy are too high to not get it right the first time around. CARB can and should do the right thing here and take the time needed to review this new research before moving forward with the LCFS. This is too important a regulation to get wrong—we hope they make the right decision.