Comment Log Display

Chairwoman Nichols:	

The Wisconsin Bio Industry Alliance applauds the efforts of the
California Air Resources Board (ARB) to identify ways to curb
greenhouse gas (GHG) emissions and to attempt to set the stage for
the rest of the country to follow suit. California has consistently
been at the forefront of the environmental movement, calling for
thorough research of environmental impacts oftentimes in opposition
to industry and even to policymakers in the nation’s capital. For
that, we should all be proud of your efforts.

It is for that very reason that I am writing to you today. As
Executive Director of the WBIA, I urge the California ARB to move
ahead with the Low Carbon Fuel Standard (LCFS) regulation for
energy sources based on their direct effects only, until a time
when further studies can be completed on Indirect Land Use Change
(ILUC) and the indirect costs of all forms of energy can be
analyzed. As it now stands, we cannot make policy decisions based
on a flawed ILUC model that is being only selectively applied,
before we’ve had the chance to fully explore the potential
ramifications of land use change.

It’s irresponsible to only apply the indirect costs associated
with a type of fuel to corn-based ethanol alone, without applying
the same principles to all types of fuel across the board. Doing so
is equivalent to saying electric cars produce zero emissions,
without considering that those very same electric batteries were
produced through energy resources run on natural gas, or even via
coal-fired power plants.
We agree that both direct and indirect land use impacts need to be
considered when analyzing the carbon intensity of energy sources.
The problem is, the ILUC model that the ARB staff is using applies
the indirect costs only to corn-based ethanol—and thus, it ignores
the indirect costs associated with all other alternatives.

Furthermore, singling out the ethanol industry could not come at a
worse time. Our economy is in deep recession. Shutting down ethanol
plants not only kills more jobs, it also destroys all incentive for
further (and much-needed) investments in the cellulosic ethanol
industry—one of the most promising alternative energy sources that
has come about in decades. To put it simply, corn ethanol must
increase—or at the very least, maintain—its market share in
California to ensure continued support for cellulosic ethanol. If
corn ethanol is not allowed to continue we will lose any chance to
ever have cellulosic ethanol in the future.

The ILUC theory is a very controversial one that lacks scientific
consensus, and which still needs considerable work before it can be
applicable. Rather than applying it today, the California ARB
should first work with industry to allocate resources for a
thorough research deployment plan that is capable of looking at the
ILUC theory from all angles, across all fuel types, in as
transparent way as possible. We fully support a research deployment
plan that plays out over a time period that is appropriate to
answer the questions that still exist among the scientific
community with regard to the ILUC theory and to achieve these
vitally important goals for the betterment of all of California,
and the nation as a whole.
I applaud your efforts to identify environmentally-sound
alternative energy sources to reduce our dependence on foreign oil
while drastically impacting our carbon footprint. But now is not
the time for incorporating this flawed ILUC theory, into the ARB
staff report.

Sincerely,

Joshua Morby
Executive Director
Wisconsin Bio Industry Alliance