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Renewable Fuels Association’s (RFA) President and CEO Bob Dinneen has submitted a letter to the California Air Resources Board (CARB) where he expresses concern over their analysis of indirect land use (ILUC). He writes, “serious concerns about the openness, transparency, and scientific integrity of staff’s new indirect land use change (ILUC) analysis for the California Low Carbon Fuel Standard (LCFS).”

On September 29, 2014 CARB hosted a workshop where they disclosed they were planning to disregard the latest published research on ILUC. They have committed to using the current ILUC modeling despite the voluminous amount of stakeholder comments received.

RFA, along with near 40 other stakeholders, submitted detailed technical comments in April 2014 aimed at improving CARB’s analysis, but “it was abundantly clear that the information submitted by stakeholders in the spring had been wholly disregarded” by the time CARB held its September public workshop. CARB staff gave no reason as to why it ignored the comments “even when stakeholders explicitly asked for staff’s rationale for ignoring new information.” CARB staff also remained vague about future plans to examine the new information. Because CARB staff failed to explain why it disregarded the technical comments submitted by RFA in April, the extensive comments were re-submitted.

Moreover, Dinneen’s letter highlighted CARB staff’s misguided belief that it is “not productive” to examine real-world data concerning agricultural land use. Dinneen remarked that, “Any objective scientist would find it prudent to examine the real-world data to determine whether predictive model results agreed with actual observed outcomes… Certainly, it is difficult to disentangle the real-world impact of biofuels expansion from the effects of other factors on actual global land use—but that does not mean CARB staff shouldn’t at least attempt to ground-truth its predictive results against real-world data.”

As an example of the disconnect between CARB’s ILUC modeling results and the real world, Dinneen noted that CARB’s model predicted that roughly 100,000 hectares of forest would be converted to cropland for biofuels production between 2001 and 2015. But real-world data show no U.S. forest loss has occurred; instead, U.S. forestland has grown 7 million hectares since 2001.

Dinneen concluded by calling on CARB to ensure its staff is transparent in its decision making and responsive to legitimate stakeholder concerns, stating, “We urge you to ensure that the CARB staff responsible for the ILUC analysis are held accountable for their decisions and abide by the agency’s long-standing norms for science-based rulemaking.”

The full letter can be found here.