The California Air Resources Board (ARB) held a public workshop on Friday to discuss updates to the recently modified Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (CA-GREET 2.0) Model under the Low Carbon Fuel Standard (LCFS). Stakeholder input was received at the workshop on the new model which made some changes to the Indirect Land Use Change (ILUC) component.

Renewable Fuels Association (RFA) Vice President Geoff Cooper said that while they are pleased that CARB made some updates to the CA-GREET model that were recommended by stakeholders, certain elements remain problematic, such as the model’s handling of emissions related to denaturant. “Our larger concern, however, continues to be CARB’s gross overestimation of indirect land use change (ILUC) emissions,” said Cooper. “While CARB is proposing to lower ILUC emissions somewhat, the Agency’s newest estimates are still far above the estimates coming from the rest of the scientific community. Further, CARB continues to rely on speculative and hypothetical scenarios to derive ILUC penalties, rather than using real-world land use data to inform the program. Empirical data from the past 10 years clearly show that farmers have responded to higher crop prices by using existing cropland more efficiently, not by converting non-agricultural lands to cropland. We will continue to encourage CARB to consider the most recent data and best available science on ILUC.”

On the other hand, the Brazilian Sugarcane Industry Association (UNICA) is pleased with the ILUC changes but has other concerns. “CARB’s revision of indirect land-use change (ILUC) modeling resulted in reduced penalties for Brazilian sugarcane ethanol and the lowest overall number in the LCFS, confirming it as the lowest-carbon biofuel available at commercial scale today,” said UNICA’s North American Representative Leticia Phillips.

However, Phillips says the environmental benefits of sugarcane ethanol in the LCFS would be even more significant if CARB included the emissions benefits of electricity co-generation in sugarcane mills using leftover plant material. “We are disappointed CARB has chosen to apply a U.S.-style average electricity mix to Brazil rather than crediting sugarcane biofuel producers for this marginal displacement of fossil energy.”

CARB will be considering re-adoption of the California LCFS at its July 2015 hearing,