Comment Log Display

April 16, 2009

Mary Nichols
Chair, California Air Resources Board
1001 I Street
Sacramento, CA 95814

RE: Low Carbon Fuel Standard

Dear Chairwoman Nichols,

Thank you for the opportunity to comment on the proposed rules for
the Low Carbon Fuel Standard (LCFS 09).  The Illinois Corn Growers
Association and the Illinois ethanol industry have a strong
commitment to environmental stewardship.  This is best demonstrated
by our work over the past thirteen years with Michael Wang at
Argonne Natinoal Laboratories.  Over the history of this
relationship, we have provided data to Michael for the development
of the corn-based ethanol GREET model.  The GREET Model, managed
and updated by Argonne National Laboratory, is still the gold
standard among models assessing greenhouse gas emissons based on a
life cycle analysis.  Additionally, we have taken practices back to
the field and to our ethanol plants to continue to improve the
greenhouse gas reduction benefits of corn-based ethanol. 
 
Therefore you can understand our excitement and interest when we
began our discussions with Dr. Alex Farrell of the University of
California-Berkley over two years ago regarding California’s
proposal to develop standards to increase the use of  low carbon
fuels such as ethanol and other biofuels.  On May 10th, 2007 at the
National Corn to Ethanol Research Center at SIU-Edwardsville, Alex
Farrell met with the Illinois Corn Growers Association and members
of the Illinois ethanol industry to discuss the biofuel
implications of the proposed Low Carbon Fuel Standard. This
presentation was based on Dr. Farrell’s vision and work supported
by Argonne National Laboratory, University of California-Berkeley,
and University of California-Davis (see Attachment 1).  His numbers
showed that Midwestern corn ethanol (including both coal and
natural gas fired ethanol plants) would reduce greenhouse gas
emissions 18% compared to gasoline.  Natural gas powered ethanol
plants, in isolation, realized about a 33% reduction.  These
numbers were based on 2001 agriculture input data and older ethanol
production technologies and are thus conservative relative to
current corn and ethanol production technologies. The discussion
focused on the possibility of California moving toward a 10% blend
of ethanol to immediately realize a very cost effective way of
achieving lower carbon fuels for California’s transportation
sector.  This would be a seamless transition, helping California
economically achieve its environmental objectives while also
forwarding our national objectives of displacing offshore fuel
sources with home grown renewable fuels. 
 
While we were disappointed with the results that Alex showed for
our coal fired ethanol plants, collectively we analyzed ways that
their GWI could be improved.  These open discussions resulted in
several of our coal fired ethanol plants looking to apply for
permits allowing them to co-fire with biomass sometime in the
future and one plant entered into a project with USDOE to sequester
CO2 emissions.

After the meeting we agreed to work with Argonne National
Laboratory to update the GREET model with the most current
agricultural and ethanol technology data available.  We looked at
where corn-based ethanol could be by 2030 with the projected yield
increases.  We also analyzed the new technologies being
incorporated by the ethanol industry which would further reduce
ethanol’s carbon footprint.  These studies were to be used to help
document the further reductions in the GWI of corn to ethanol and
to set a road map for the industry to help California meet its
objectives (Attached are the three studies referred to in this
paragraph).

In January 2008 we again met with Alex Farrell at the Illinois
River Energy ethanol plant near Rochelle, Illinois to discuss the
latest work on the proposed California Low Carbon Fuel Standard and
present the reports and information we developed since our first
meeting.  The meeting in Rochelle focused on the need to consider
land use change in the analysis of the carbon footprint for ethanol
and other biofuels.  This was not a new concept since Argonne used
a default value for land use change in their analysis due to the
fact that no models were designed to ascertain land use change with
any certainty that was worth the high risk of being wrong.  During
our meeting we agreed to analyze land use change using the latest
data available to us and ground-truthed our analysis to ensure that
our degree of error would be as low as possible.

The Illinois Corn Marketing Board commissioned the University of
Illinois-Chicago to conduct a bottom up approach to document the
actual carbon footprint of Illinois River Energy including land use
change as a result of an addition to the plant which created new
demand for corn produced in the area.  The study utilized actual
data from growers delivering corn to the IRE facility.  IRE was a
55 million gallon ethanol plant which purchased approximately 18.6
million bushels of corn per year from family farms within a 40 mile
radius of the plant.  It also produces 156,000 tons of high quality
DDGS which is exported in back loaded containers to the Pacific Rim
for animal feed.  In summary, the study concludes “that the
construction and operation of the Rochelle, Illinois ethanol plant
did not contribute to land use change.  It follows that greenhouse
gas emissions from IRE related land use change are insignificant.” 
This study represents the most detailed and ground-truthed analysis
of land use change for a biofuels production ever conducted.  The
life cycle global warming analysis for IRE produced corn ethanol
(including farming, conversion, distribution, denaturing) totals
54.8 gCO2e/MJ  (see attached).  This plant is representative of
approximately 3 billion gallons of ethanol capacity constructed
since 2006 using similar technologies.

The differences between the study that was completed for IRE
versus the modeling which was done by CARB to ascertain land use
change from corn to ethanol are the significant error factors and
uncertainties in the CARB analysis due to the macro nature of the
analysis. This is due in part to the fact that the model that is
being used was not designed for this type of analysis.  Also, it
takes time to ground truth the results and ensure accuracy and we
do not believe the staff at CARB had time to do this.

The other serious problem in the proposed land use penalties for
biofuels is the lack of any degree of certainty related to cause
and effect of increased biofuels production on land use change. 
Dr. Wally Tyner, Purdue University, has conducted some excellent
work related to the close correlation of commodity prices,
especially corn and soybeans, with the price of crude oil.  As
crude oil increased, we saw corn and soybean prices raise as well. 
If indeed there is a direct relationship, then the impact of land
use change needs to be assigned to crude oil as well as biofuels.

We are very concerned that the proposed rule in no way reflects
the original objective vision for the California Low Carbon Fuel
Standard.  Instead of a standard that will result in an immediate
and cost effective reduction in CO2 emissions for the citizens of
California and a model for a national LCFS, the proposed rules are
fraught with errors, poor assumptions, inconsistencies, weak
science, and subjective models.  Unfortunately these proposed
rules, if implemented, may not decrease CO2 

emissions as predicted, may cost the citizens of California
further economic pain and suffering, may increase our dependence on
imported fuels and harm the economy of the agricultural sector in
the U.S. resulting in higher food, fuel, and feed costs.

Our recommendations are the following:

1.	Due to the uncertainty of the data and models and without
appropriate time to ground-truth the data, defer the incorporation
of indirect land use numbers until the quality of the data can be
improved by involving experts in the field and until indirect land
use can be determined for all fuels and energy sectors.  Acting on
recommendations that are not based on sound science could result in
an increase, rather than a decrease, in the greenhouse gas
emissions in California. This would place California even further
behind in meeting its 2020 objectives and at a substantial cost. 

2.	Because the economic assessment that CARB has conducted depends
on the accuracy of the assumptions made, the economic impact
conclusions drawn are also flawed. The citizens of California are
at risk of significant negative economic consequences from the
implementation of this rule. Recongition of the uncertainty of the
assumptions made needs to be factored into CARB’s economic analysis
such that citizens can recognize the economic risk to the state and
them personally if the assumptions are incorrect. The staff of CARB
needs to work closely with experts in the field with first hand
information to gather accurate information for the development of
their model.  This includes the corn to ethanol industry, the land
grant colleges, animal nutritionists, agriculture economists, and
Midwestern states to better understand the increased efficiencies
of production agriculture, the reduced inputs, the increased
sustainability of agriculture and the new technologies being
employed in ethanol plants to increase the value of the co-products
and to reduce their carbon footprint.

The Illinois Corn Growers Association, the Illinois ethanol
industry and our universities are committed to work with California
to provide the most accurate scientific data on modern agriculture,
 the case studies of existing ethanol plants related to their
carbon footprint and providing support to develop the models that
will accurately determine CO2 emissions.  The Midwest and the U.S.
has a huge stake in these proposed rules.

Sincerely,

 
Rob Elliott
PRESIDENT