RFA: CARB’s ILUC Analysis Out of Date, Out of Step

rfa-logo-09A biofuels advocate is taking exception with one state’s evaluation of indirect land use change associated with the green fuels. The Renewable Fuels Association (RFA) says the California Air Resources Board’s (CARB) draft indirect land use change (ILUC) analysis is not in step with current ILUC science.

Geoff Cooper, RFA’s senior vice president, notes in his submission that RFA is greatly concerned by many aspects of the draft.

Cooper writes, “….several of the assumptions and methodological approaches chosen for CARB’s draft analysis run counter to the recommendations of the Expert Work Group (EWG). In particular, the values selected by CARB for key GTAP elasticities are in conflict with values recommended by EWG and well-known agricultural economists. More generally, CARB’s draft analysis lacks sufficient justification for certain judgment calls made by staff with regard to important model parameters.

“… the results of CARB’s draft analysis are in conflict with the results of recent independent ILUC studies. As described in a recent letter to CARB Chair Mary Nichols from 14 scientists and researchers (including CARB-appointed Expert Work Group members), the corn ethanol ILUC results from CARB’s draft analysis are significantly higher than estimates from recent peer-reviewed scientific analyses…. We believe CARB should explain and justify the divergence of its draft results with estimates from other recent studies.”

RFA addresses key modeling parameters in CARB’s analysis, such as crop yield elasticities and emissions factors, which RFA believes are not in line with what current ILUC science says. In addition, the group says CARB needs to correct in its draft price yield elasticity, what RFA considers to be the single more important factor in the analysis. You can read RFA’s full comment letter here.

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