Earlier this month, the California Air Resources Board (CARB) made a positive step for ethanol by updating its indirect land use models in the Low Carbon Fuel Standard (LCFS). This in effect, will reduce the ILUC penalties in half. Unfortunately, the new rule doesn’t take effect until mid-2011 although LCFS kicks in on January 1, 2011.
In light of this change, the ethanol industry is calling for the Environmental Protection Agency (EPA) to also reevaluate its modeling of lifecycle GHG emissions as defined in the Renewable Fuels Standard (RFS2). Recently the Renewable Fuels Association (RFA) submitted a letter to EPA Administrator Lisa Jackson asking for this very change. In fact, EPA was represented on CARB’s LCFS Workshop and has publicly highlighted the fact that its ILUC results were similar to those originally obtained by CARB.
“The proposed changes to the California LCFS analysis are likely to result in substantially lower ILUC values, meaning EPA’s analysis for the RFS2 will be inconsistent with the latest science being adopted by CARB. Because EPA was represented by two staff members on the LCFS Expert Workgroup that recommended the changes to CARB’s LUC analysis, we are curious as to whether EPA similarly plans to revisit its LUC analysis for the RFS2 and incorporate more up-to-date assumptions and data,” wrote RFA President and CEO Bob Dinneen in a letter dated November 23, 2010.
According to RFA, while EPA and CARB used different modeling approaches, some of the changes being adopted by CARB would result in lower values for ILUC in EPA’s RFS2 as well. Currently, corn-based ethanol has been given a 20 percent GHG emission reduction number in RFS2, but the industry wants to see this number much higher. Other areas that RFA would like EPA to visit again are the treatment of crop yields on newly converted land, treatment of carbon sequestration in harvested wood products and the effect of higher prices on crop yields.
The second purpose of the letter to Jackson was to respond to the EPA’s letter sent to RFA on September 29, 2010. Back in September, the RFA wrote to EPA “examining the impact of volume increases for individual biofuels in isolation of one another exaggerates the LUC impacts and misrepresents the real-world progression of the RFS2 as required by [the Energy Independence and Security Act].” They have argued, and continue to argue, that EPA’s isolation approach to calculating ILUC values for the various biofuels covered under the RFS2 ignores the dynamic relationships that exist between the fuels, the feedstocks and in the marketplace.
The bottom line, says RFA, is that the science behind ILUC is constantly evolving and requires continual monitoring and updating to ensure the best available science is being utilized to make decisions.