RFA calls on CARB to adjust ILUC analysis

By Renewable Fuels Association | December 08, 2014

The Renewable Fuels Association has again called on the California Air Resource Board to adjust its current indirect land use change (ILUC) analysis to better reflect real-world land use patterns. In written comments submitted on Friday, RFA’s Geoff Cooper highlighted a recently-released study from Iowa State University’s Center for Agricultural and Rural Development that exposes the implausibility of CARB’s current ILUC predictions. Cooper called on CARB to “take into account the new CARD/ISU research and use it to immediately re-calibrate” the agency’s ILUC model.

Cooper points to the CARD/ISU study as a “remarkably important—and potentially gamechanging—contribution to the debate over ILUC modeling.” The study used empirical data to conclude 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. This finding is not new…however, this finding has not been recognized by regulators who calculate indirect land use.”

Cooper goes on to state that the CARD/ISU analysis “demonstrates that CARB’s ILUC results are directionally inconsistent with real-world data and observed market behaviors in many regions” and that “the data and discussion presented in the paper challenge the very underpinnings of CARB’s analysis.” For example, CARB’s analysis suggests corn ethanol expansion caused conversion of forest and grassland to cropland in Canada, the European Union, Russia, Japan, China, and the United States—but in reality, cropland in those countries and regions had decreased or stayed the same over the past decade.

RFA’s comments urged CARB to calibrate its ILUC model using the new CARD/ISU analysis as a guide before sending the proposed rule for Low Carbon Fuel Standard (LCFS) re-adoption to the Board for consideration. If adjustments are unable to be made before the final proposal is submitted, RFA calls on CARB to “…delay proposing new ILUC factors until such time as the calibration is completed and new ILUC results are generated.”

RFA’s full comments, which also recommend adjustments to CARB’s treatment of distiller grains displacement in ILUC modeling, are available here.

The Center for Agricultural and Rural Development’s study entitled “Using Recent Land Use Changes to Validate Land Use Change Models” can be found here.