Comment Log Display

See also:
www.ucsusa.org/biofuels-letter 
 
April 21, 2009

Mary D. Nichols, Chairman
California Air Resources Board
Headquarters Building
1001 “I” Street
Sacramento, CA 95812

Dear Chairman Nichols,

As scientists and economists with relevant expertise, we are
writing to recommend that you include indirect land use change in
the lifecycle analyses of heat-trapping emissions from biofuels and
other transportation fuels. This policy will encourage development
of sustainable, low-carbon fuels that avoid conflict with food and
minimize harmful environmental impacts.  

Our comments are relevant to the development of California’s Low
Carbon Fuel Standard (LCFS), which the Air Resources Board (ARB)
will consider for adoption in its April hearing, as well as other
policies that evaluate lifecycle heat-trapping emissions from
biofuels.  For policies like the LCFS to successfully reduce GHG
emissions, it is critical to include all major sources of
emissions, including indirect land use emissions from biofuels.  

We encourage you to investigate and include significant direct and
indirect emissions from all fuels, including conventional
petroleum, heavy oils, natural gas for transportation, oil
sand-based fuels, and the range of fuels used to power electrified
transportation, consistent with the best available science. 
However, you should not delay inclusion of known sources of
emissions, including indirect emissions from biofuels, pending
discovery of potential effects from other fuels.

Recent peer-reviewed research indicates that conventional biofuels
can directly or indirectly result in substantial heat-trapping
emissions through the conversion of forests and grasslands to
croplands to accommodate biofuel production. Increased demand for
crops to make fuel results in higher global commodity prices that
can induce farmers in other countries to plow up sensitive,
high-carbon ecosystems—including rain forests in South America and
Southeast Asia.  Previous lifecycle analyses did not adequately
account for these emissions, giving biofuels credit for greater
carbon savings than actually achieved. 

There are uncertainties inherent in estimating the magnitude of
indirect land use emissions from biofuels, but assigning a value of
zero is clearly not supported by the science.  The data on land use
change indicate that the emissions related to biofuels are
significant and can be quite large.  Grappling with the technical
uncertainty and developing a regulation based on the best available
science is preferable to ignoring a major source of emissions. 
Over time, greater accuracy and detail in a more refined analysis
can be reflected in future LCFS rulemakings.

The need to address uncertainties applies to other areas the
analysis as well, and we urge you to evaluate the increasing use of
nitrogen fertilizers and herbicides associated with greater biofuel
production.  In particular, nitrogen fertilizers enhance the
emission of nitrous oxide—a powerful greenhouse gas in Earth’s
atmosphere.

To spur innovation in low carbon fuels, the LCFS must send an
accurate signal to the growing clean energy market.  Strategic
investment decisions should be based upon the best available data
of the carbon footprint of alternative fuels. Failure to include a
major source of pollution, like indirect land use emissions, will
distort the carbon market, suppress investment in truly low carbon
fuels, and ultimately result in higher emissions.  

The work you are doing in California sets an important precedent
for transportation fuel policy nationally and internationally, as
well as for action to confront climate change more broadly.  We
urge you to ensure that your policies are based on the best
science, including consideration of emissions from indirect changes
in land use.
 
Sincerely, 
- Original Authors - 

PAM MATSON, Ph.D. 
Chester Naramore Dean of the School of Earth Sciences
Richard and Rhoda Goldman Professor of Environmental Studies
Stanford University
Stanford, CA
Member of the United States National Academy of Sciences

STUART L. PIMM, Ph.D. 
Doris Duke Professor of Conservation Ecology
Nicholas School of the Environment and Earth Sciences
Duke University
Durham, NC

WILLIAM SCHLESINGER, Ph.D. 
President
Cary Institute of Ecosystem Studies
Millbrook, NY
Member of the United States National Academy of Sciences

PETER C. FRUMHOFF, Ph.D. 
Director of Science and Policy
Chief Scientist, Climate Campaign
Union of Concerned Scientists
Cambridge, MA

W. MICHAEL HANEMANN, Ph.D. 
Chancellor's Professor
Department of Agricultural and Resource Economics
University of California, Berkeley
Berkeley, CA

For full list of 177 signers, go to:
www.ucsusa.org/biofuels-letter