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Ethanol producers and legislators remain concerned over reports indicating California's Air Resource Board (ARB) and the Environmental Protection Agency (EPA) may calculate indirect land use changes from the use of biofuels without proper data or methods.
In testimony before the California State Senate Committee on Transportation and Housing, the Renewable Fuels Association (RFA) pointedly stated that the California ARB is not honoring the "performance-based" goal of the state's effort to develop and implement a low-carbon fuel standard (LCFS).
The current draft of the ARB's LCFS fails to evenly apply its rules across all fuel technologies, assigning excessive and scientifically unsupported carbon penalties against biofuels while seemingly rewarding the increasingly environmentally damaging portfolio of petroleum and coal, RFA said.
In addition, ARB's current draft has the potential to undermine the development of next generation biofuels, like cellulosic ethanol, because of the arbitrary nature in which the carbon accounting modeling is applied to biofuels and ethanol specifically.
ARB's analysis is largely based on one model, the Purdue University's Global Trade Analysis Project (GTAP) model, which was rejected by the federal Environmental Protection Agency that is contemplating a similar issue.
RFA said the model is not equipped to measure the impact of ethanol production over the period of time from 2001 to 2015, when ethanol production from corn will be 15 billion gallons. California also is not accounting for yield increases in crop production or value of distillers grains displacements in feed rations.
Senators speak out
Also last week, a bipartisan group of 12 U.S. senators led by Tom Harkin (D-Iowa) and Chuck Grassley (R-Iowa) called on the EPA not to propose regulations assuming that greater U.S. biofuels use would increase carbon dioxide emissions, according to a March 17 statement from Harkin's office.
The senators argued the data and methods for calculating such "indirect land use changes" such as from forest or grassland to crops are not adequately developed, and should not be used to make it harder for ethanol and biodiesel to meet requirements of the Energy Independence and Security Act of 2007. That law requires reduced carbon emissions from advanced biofuels under the Renewable Fuel Standard (RFS).
"This Renewable Fuel Standard is essential to breaking our over-dependence on oil. To do that, we need new domestic fuels as well as new vehicle technologies," said Harkin, chairman of the Senate Committee on Agriculture, Nutrition and Forestry. "With the RFS, we put ourselves on a clear path of producing and using steadily increasing levels of a variety of biofuels over the next 15 years, and we included these emissions' limits to ensure that these new fuels would also be good for our environment and climate. However, for this to work, we simply must have valid data and methods for calculating the emissions. Otherwise, we'll exclude some good biofuels and stifle the investment that is so essential to our national renewable fuels strategy.
"It defies common sense that EPA would publish a proposed rulemaking with harmful conclusions for biofuels based on incomplete science and inaccurate assumptions," Grassley said. "EPA's actions, if based on erroneous indirect land use assumptions, could hinder biofuels development and actually extend America's reliance on dirtier fossil fuels. Agricultural practices and land use decisions in other countries are not driven by U.S. biofuels policy, and should not be used to undermine our domestic biofuels industry."
Their letter to EPA Administrator Lisa Jackson recommends that EPA refrain from including calculations of the effects of indirect land use changes in their rulemaking at this time. The law requires biofuels to meet certain life-cycle greenhouse gas emission caps in order to qualify for the RFS. And, it specifies that those life-cycle greenhouse gas emissions are to include the effects of indirect land use changes. The challenge is that the ability to calculate future indirect land use changes resulting from production of biofuels is very limited by the lack of both proven and accepted land use models and sufficient information about input data.
Policy is one of the most important issues facing farmers today, but often the most difficult to digest. Jacqui Fatka has a passion to decode the often difficult world of agricultural policy into terms understandable for today's ag players.
Fatka joined the Farm Progress team as E-Content Editor in August 2003 after graduating from Iowa State University. Prior to full-time employment with Farm Progress, she interned at Wallaces Farmer magazine, Iowa Sen. Chuck Grassley's press office and the Iowa Pork Producers Association and freelanced for National Hog Farmer. She also worked as a public relations consultant with Iowa Industries for the Future, an effort to bring together major players in the biorenewables industry.
Currently Fatka is a staff editor at a sister publication, Feedstuffs. For Farm Futures she regularly tells the story of ongoing agricultural policy changes. Her byline can also be found on management profiles.
Fatka grew up on a grain and livestock farm near Atlantic, Iowa. She currently lives in central Ohio with her husband Eric.
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