The Oregon Department of Environmental Quality (DEQ) has offered a proposal to include indirect land use change (ILUC) emissions when calculating the carbon intensity of biofuels regulated under the state’s Clean Fuels Program (CFP). The Renewable Fuels Association (RFA) has expressed disappointment in the proposal that is to take effect on January 1, 2016 and aims for a 10 percent reduction in the carbon intensity (CI) of transportation fuels in the state over a 10-year period.
RFA President and CEO Bob Dinneen said that the DEQ proposal would have the effect of creating an inconsistent and unfair methodology for estimating the carbon intensity of competing fuel options under the CFP. Specifically, DEQ’s proposal would penalize certain biofuels for theoretical indirect emissions, while assuming that no other fuels induce any indirect greenhouse gas (GHG) emissions at all. DEQ proposed to integrate the flawed ILUC analysis conducted by the California Air Resources Board (CARB), despite the fact that recent analyses have shown that the land use changes predicted by CARB’s computer models have not occurred in the real world. DEQ also flatly ignored the results of new land use modeling approaches, including recently published data from the Department of Energy’s Argonne National Laboratory.
“Oregon DEQ really fumbles the ball with this proposal,” said Dinneen. “The Oregon CFP previously enjoyed broad-based support from the biofuels and ag industries because the CI impacts of all fuels were being evaluated fairly and consistently. But the program is headed off the rails now that DEQ is planning to simply regurgitate CARB’s faulty and biased ILUC penalties, while pretending that other fuels don’t have indirect GHG effects.”
Dinneen continued, “Regrettably, Oregon’s proposal puts politics ahead of science, a problem that has plagued the California program, harming consumers by limiting choice at the pump. The U.S. ethanol industry will continue to support performance-based low carbon fuel programs that are grounded in the principles of fairness, sound science, and consistent analytical boundaries. Unfortunately, Oregon’s proposal doesn’t meet any of those criteria.”
Oregon DEQ is hosting a public hearing on the proposed rule on October 19, 2015 and will accept written comments from the public through October 21, 2015.