The Renewable Fuels Association (RFA) is urging the California Air Resource Board (CARB) 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 Senior Vice President Geoff Cooper pointed to the recent study released by Iowa State University’s Center for Agricultural and Rural Development (CARD) raising concerns about 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 calls the study a “remarkably important—and potentially gamechanging—contribution to the debate over ILUC modeling” which 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.”
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.”