Comment Log Display

March 16, 2009

Mary D. Nichols, Chairwoman

California Air Resources Board

Headquarters Building

1001 “I” Street

Sacramento, CA 95812

Chairwoman Nichols:

Reducing greenhouse gas emissions from transportation fuels is an
important and urgent challenge for both California and our nation. 
It is one of the many hurdles that our nation will need to overcome
if we are to address the climate crisis effectively and quickly. 
We at the Environmental and Energy Study Institute commend the
staff of the California Air Resources Board for its thoughtful
effort and leadership to establish a low carbon fuel standard –
for the State of California and as a model for the nation. 

However, we are writing to express our concern that the excellent
work the staff has done to assess the direct life cycle carbon
emissions of various fuels, based upon scientifically sound and
generally accepted methodologies, is significantly undermined by
the inclusion of indirect carbon emissions from land use changes
attributed to biofuels production, about which there is very little
consensus in the scientific community.  Scientists are only just
beginning to explore the indirect relationships (if any) between
biofuels production in the U.S. and land use changes around the
world.  To base such a critical policy decision upon such an
uncertain and unsettled body of knowledge inserts a significant,
unfounded bias against a class of fuels which may offer, in the
final analysis, great promise in meeting our nation’s pressing
climate and energy challenges.

Traditional life cycle assessments include only what have come to
be known as ‘direct emissions’.  Direct emissions include the
carbon contents of the fuel itself, as well as the greenhouse gases
released during each stage of production (from “well to
wheels”).  Direct emissions are measurable, attributable, and
described in well-tested models (such as the GREET model).  

“Indirect emissions”, on the other hand, are those emissions
that are assumed to occur somewhere in the world as a result of
general market forces exerted by the production of a particular
kind of fuel – in this case, the greenhouse gas emissions thought
to be released from tropical deforestation and other land use
changes as an indirect, market-driven result of farmland in the
U.S. being diverted away from food or feed crops to growing biofuel
crops.  Unlike direct emissions, indirect emissions cannot be
observed, measured in situ or attributed to particular production
chains.  

The CARB staff is calculating these indirect emissions using a
general equilibrium model to estimate aggregate emissions from land
use change at the global level due to the impact of U.S. biofuel
production on global markets.  General equilibrium models simulate
changes and trends in commodity production by assuming a closed
system that seeks economic ‘equilibrium’ as determined by
regional constraints of supply and demand.  These models, however,
are especially sensitive to the assumptions underlying the inputs
and processes included in the model.  In particular, assumptions
regarding the supply of agricultural land, the availability of
marginal lands, farmer behavior, agricultural production practices,
economic value and use of biofuel co-products, and competing uses
for land and natural resources, substantially affect model results.
 Determining the ‘right’ assumptions and assigning values can
be a highly subjective process over which scientists, policymakers,
and stakeholders frequently disagree.  

Confounding the problem further is the difficulty of determining
additionality.  Even if one assumes that biofuel production is the
proximate cause of a certain amount of deforestation, one cannot
assume that those forests would have otherwise remained intact in
the absence of biofuel production. There are many causes of
deforestation and land use change – timber demand, livestock
grazing, mining, urban sprawl, global food and feed demand, and
subsistence activities.   People continually seek to realize the
highest value from the land.  If biofuels are removed as a market
driving factor, other factors will likely fill the void.  In sum,
using these models to calculate indirect emissions remains a highly
subjective and speculative process, dependent on a number of a
priori assumptions that bias the outcome.

There is another, more fundamental issue with including indirect
emissions in the LCFS assessment: this concerns the precedent of
holding an industry in the U.S. responsible for activities (real or
supposed) undertaken by people across distant borders in other
sovereign nations.  If this standard is to be applied to biofuels,
in fairness, should it not also be applied to the assessment of
fossil fuels, hydrogen, and electricity?  On a broader level, is
this a new standard to which other industries and public policy
decisions should be held?  The analysis of indirect effects could
be applied to regulate against a host of other economic and social
activities.  All large scale activities that use scarce resources,
affect markets, or influence economic or social behavior are likely
to have some distant, indirect effects.  

Global deforestation, conversion of native grasslands and
shrublands, and ecosystem degradation are very real problems, with
impacts on biodiversity, water security, and the welfare of
indigenous peoples.  These land use changes have been accelerating
for decades, driven by many factors – long before the U.S.
biofuel industry came on the scene.  The resulting greenhouse gas
emissions are huge, amounting to over 18% of total global
emissions.  The international community must work together with
urgency and speed – through international negotiations, treaties,
and financial and technical assistance - to prevent further loss of
forests and ecosystems across the globe.  

Including indirect emissions from land use change in the LCFS,
however, is not likely to promote the stable climate and healthy
ecosystems that we all seek.  Instead, it will only reduce the
political legitimacy of the LCFS as a fair and objective tool for
comparing fuel options and unfairly penalize an industry that
offers great promise for addressing the nation’s climate and
energy challenges.  If the LCFS is to be an objective,
technology-neutral assessment tool, it must treat all fuels
equitably, using consistent, generally accepted, scientific
criteria and methods.  Otherwise, it will merely serve to reinforce
the predispositions of the modelers. 

Sincerely,

Carol Werner

Executive Director, Environmental and Energy Study Institute

 

Cc: The Honorable Arnold Schwarzenegger, Governor of California

David Crane, Special Advisor for Jobs and Economic Growth, Office
of Governor Schwarzenegger

Linda Adams, Secretary, California Department of Food &
Agriculture

Mike Scheible, Deputy Director, Air Resources Board

Karen Douglas, Chairwoman, California Energy Commission