As the EU looks to increase current biodiesel use from 3 percent to 10 percent by 2020, they are also concerned that such a move would increase environmental damage rather than reduce environmental concerns. Their own analysis concludes that a 10 percent biodiesel mandate could lead to “an indirect one-off release of around 1,000 megatonnes of carbon dioxide — more than twice the annual emissions of Germany.” In addition, one report concludes that more use of biofuels could “squeeze food supplies and increase global hunger.”

The studies to which Reuters is referring have not been released by the European Commission and the authors surmise it is because it would “have significant implications for the existing EU biodiesel industry.”

These negative impacts could include a reduction of investments in plants and infrastructure. It could also cause a reduction of biodiesel use, rather than what the country has been aiming for since 2003, an increase in biodiesel use.

One of the biggest concerns with increased biofuels use is indirect land use change (ILUC) a proposed theory that the pro-biofuels groups have been trying to fight for several years. The ILUC argues that more biofuel production (tied to biofuel mandates) will cause trees to be cut down in other areas, increasing carbon and if the crop competes for “food” causing hunger in other areas of the world.  In other words, the “indirect effects” of biofuel production outweigh the positive benefits of the fuel.

“The land use change effects make nearly half of the expected gains of shifting from fossil fuels to renewable biofuels disappear,” said a third report by the International Food Policy Research Institute (IFPRI) for the EU.

A fourth leaked document concluded biodiesel from Asian palm oil, South American soy beans, and EU rapeseed all had a bigger overall climate impact than conventional diesel.

The hope of the European biodiesel industry is that since the science is still young and inconclusive, the country should not pass legislation based on its deductions and theories.

This entire story reads like a “biodiesel conspiracy” theory- and who doesn’t love a little drama? It will be interesting to see if the as-of-now unreleased reports will in fact be released by the EU, and if so, what type of tail-spin the reports could cause.

The report is comprised of a series of step-by-step evaluations that seek to answer critical questions regarding the feasibility of bioenergy development and the impacts on food availability and household food security. In addition, social and environmental dimensions are also considered. The paper also serves as a platform for bringing key ministries and institutions together so they can work on the same page.

“Our goal is to help policy-makers take informed decisions regarding whether bioenergy development is a viable option and, if so, identify policies that will maximize benefits and minimize risks,” explains Heiner Thofern, who heads FAO’s Bioenergy and Food Security (BEFS) project.

The drive to biofuels have been driven by both worries over greenhouse gas emissions from fossil fuels as well as high oil prices and energy security concerns. FAO believes that one important benefit of investments into the bioenergy sector is that it could spark much-needed investment in agricultural and transport infrastructure in rural areas. This would create jobs and boost household income. These benefits could lesson both poverty and food security concerns. FAO has also conducted separate studies that show small-scale bioenergy projects not designed for export markets can improve food security and help boost rural economies.

“FAO has been saying for years that under-investment in agriculture is a problem that seriously handicaps food production in the developing world, and that this, coupled with rural poverty, is a key driver of world hunger,” says Thofern. “Done properly and when appropriate, bioenergy development offers a chance to drive investment and jobs into areas that are literally starving for them.”

Yet while there are major potential benefits to bioenergy production, FAO warns there are also potential negatives. They write that large-scale biofuel production could come at the expense of food production, leading to less food available, and higher food prices. In addition, deforestation is also a concern. Therefore, potential risks and benefits need to be weighed.

Dale and Kim empirically tested whether indirect land use change (ILUC) occurred through 2007 as a result of the expansion of the U.S. biofuels industry, spurred in part by the Renewable Fuels Standard (RFS2) that calls for 36 billion gallons of renewable fuel to be blended in fuel supplies by 2022. The researcher’s derived their conclusion after studying historical data on U.S. croplands, commodity grain exports to specific regions and land use trends in these geographical regions.

The authors write, “Biofuel production in the United States up through the end of 2007 in all probability has not induced indirect land use change. There are two feasible dependent conclusions that might be drawn from this interpretation: 1) crop intensification may have absorbed the effects of expanding US biofuel production or 2) the effects of US biofuel production expansion may be simply negligible, and not resolvable within the accuracy of the data.”

In response to the study, Renewable Fuels President and CEO Bob Dinneen stated, “Solving America’s energy crisis must rely on the best available science. Since its inception, the notion indirect land use change has been deeply flawed and repeatedly disputed. It is refreshing to see academia using real-world data and actual market behaviors to challenge the hypothetical results and ‘what if’ scenarios that have so far dominated the ILUC discussion.”

“Biofuels like ethanol offered unparalleled environmental benefits as a renewable alternative to gasoline. Hiding behind the faux science of ILUC, some have attempted to stall and thwart the sustainable growth of biofuels across the globe and especially in the U.S. This work from MSU, coming on the heels of other recent scientific analyses, has demonstrated that ILUC as a matter of science and fact is wrong,” continued Dinneen.

This report comes on the heels of report from the U.S. Department of Energy’s Oak Ridge National Laboratory that concluded ILUC resulting from corn ethanol expansion over the past decade has likely been “minimal to zero.”

Kim and Dale noted in the report that “prior ILUC studies have failed to compare their predictions to past global historical data.” Both the Environmental Protection Agency and the California Air Resources Board have used highly controversial ILUC modeling tools. The report concludes, “No arable land increases from the 1990s are observed in the United States. Furthermore, no declines in natural ecosystem lands in the United States have been observed since 1998.” In addition, the analysis suggests cropland expansion in foreign countries is not well correlated to U.S. biofuels demand for certain feedstocks.

“Farming systems that combine food and energy crops present numerous benefits to poor rural communities,” said Alexander Müller, FAO Assistant Director-General for Natural Resources. “For example, poor farmers can use leftovers from rice crops to produce bioenergy, or in an agroforestry system can use debris of trees used to grow crops like fruits, coconuts or coffee beans for cooking.”

Müller noted that other types of food and energy systems use byproducts from livestock or biogas production and with this type of integrated systems, farmers can save money – they don’t have to buy expensive fossil fuel or chemical fertilizers. Rather, than can use the slurry from biogas production, a more sustainable, less costly alternative.

“They can then use the savings to buy necessary inputs to increase agricultural productivity, such as seeds adapted to changing climatic conditions — an important factor given that a significant increase in food production in the next decades will have to be carried out under conditions of climate change. All this increases their resilience, hence their capacity to adapt to climate change,” said Müller.

IFES are also beneficial to women as they can eliminate the need to leave their crops to go in search of firewood. In addition, the report concludes that IFES farming can help to mitigate climate change, especially emissions stemming from land use change, because there is less chance land will need to be converted.

In conclusion, Olivier Dubois, an FAO energy expert said, “Promoting the advantages of IFES and improving the policy and institutional environment for such systems should become a priority. FAO is well placed to coordinate these efforts by providing knowledge and technical support for IFES implementation.”

The study was led by civil and environmental engineering professor Ximing Cai who identified land around the globe available to produce grass crops for biofuels, with minimal impact on agriculture or the environment. Cai noted going into the study that prior research concentrated on biofuel crop viability focused on biomass yield or how productive a crop could be regionally; yet, there was little research on land availability, a key constraint of biofuel development. He also noted that there is major concern as to whether, on a global scale, biofuels can meet fuel demand without compromising food production.

“The questions we’re trying to address are, what kind of land could be used for biofuel crops? “If we have land, where is it, and what is the current land cover?” said Cai.

For this particular study, Cai’s team assessed land availability from a physical perspective – focusing on soil properties, soil quality, land slope, and regional climate. The researchers collected data on soil, topography, climate and current land use from some of the best data sources available, including remote sensing maps but the point of differentiation of this research was that the study only considered marking land for biofuel crops. By doing this, current crop land, pasture land and forests were ruled out as viable land options for biofuel production. In addition, the research team ruled out any land that must be irrigated, thus eliminating concerns over the need to divert water from agriculture crops.

Using fuzzy logic modeling, a technique to address uncertainty and ambiguity in analysis, the researchers considered multiple scenarios for land availability. First, they considered only idle land and vegetation land with marginal productivity; for the second scenario, they added degraded or low-quality cropland. For the second scenario, they estimated 702 million hectares of land available for second-generation biofuel crops, such as switchgrass or miscanthus.

The researchers then expanded their sights to marginal grassland including low-impact high-diversity (LIHD) perennial grasses. By adding this category, the amount of land nearly doubled to 1,107 million hectares globally.

“Based on the historical data, we now have an estimation for current land use, but climate may change in the near future as a result of the increase in greenhouse gas emissions, which will have effect on the land availability,” said graduate student Xiao Zhang, a co-author of the paper.

“We hope this will provide a physical basis for future research,” said Cai “For example, agricultural economists could use the dataset to do some research with the impact of institutions, community acceptance and so on, or some impact on the market. “We want to provide a start so others can use our research data.”

Next, the team plans to study the possible effect of climate change on land use and availability. Former postdoctoral fellow Dingbao Wang, now at the University of Central Florida, also co-wrote the paper.

The report sets forth the premise that while two goals of biofuel production are to reduce greenhouse gases and to protect natural resources, they may in fact exacerbate the problems rather than help them. Therefore the report recommends that before decisions are made, future monitoring, experimenting and modeling in different locations must take place in an effort to assess the true impact of changing land use caused by biofuel production.

“There is a need to establish standard methodologies to evaluate the wide range of effects, direct and indirect, that ensue from the growing global biofuels market. This would enable much greater confidence when comparing future studies and enable decision-makers to make more informed judgments,” said Tammy Klein, Assistant Vice President of Hart Energy Consulting.

According to the report, “marginal, abandoned, degraded and unused lands” are really the only possible sources of significant land for biofuel expansion. Yet the report continues, it is these very lands that are rarely quantified and so the report asks how much of this type of land is available and what problems would need to be overcome to bring these lands into production.

In conclusion, the report calls for the establishment of effective land-use management and best agriculture practice policies for biofuels feedstock crops.

“The switch away from fossil fuels to renewable alternatives will have unforeseen consequences, especially for highly populated resource-poor countries,” said Janny Vos, Business Development Manager of CABI. “At present the role of biofuels in this process is unclear. We hope that this review goes some way towards identifying the questions that need to be asked about land use change, and the areas in which we need further research.”

Brazilian President Luiz Inacio Lula da Silva announced today that deforestation rates in the Brazilian Amazon declined 14 percent from August 2009 to July 2010, reaching the lowest rates ever recorded for the second consecutive year.

Satellite images analyzed by Brazil’s National Institute for Space Research (INPE) show that an estimated 6,450 square kilometers of forests were cleared in the 12-month period, bringing rates to their lowest since monitoring started in 1988. The record-breaking decrease represents a major contribution to reducing Brazil’s greenhouse gas emissions, as global negotiations progress at the 16th Conference of the Parties to the United Nations Framework Convention on Climate Change (COP16), currently underway in Cancun, Mexico.

In a post on the Renewable Fuels Association E-xchange blog, Vice President of Research and Analysis Geoff Cooper says this development is yet another blow to the already roundly rejected hypothesis of international land use change (ILUC) first proposed three years ago by Environmental Defense Fund attorney Timothy Searchinger.

“Today’s announcement by Lula is just the latest exhibit in a recent barrage of evidence that is undermining the argument that ILUC is a significant concern in the context of U.S. biofuels expansion,” writes Cooper, noting that annual U.S. ethanol production stood at 3.4 billion when deforestation peaked in 2004. “In 2010, the ethanol industry will produce nearly 13 billion gallons. So, Amazon deforestation has fallen 76% since 2004, while U.S. ethanol production has increased 279% in the same period.”

Cooper adds that he hopes the news out of Brazil will be greeted warmly by the environmental community, but he doubts it. “Unfortunately, I have a feeling the response from NRDC and others may go something like this: “Well, how much lower would deforestation have been without biofuels in the U.S.?” This response, of course, dodges the real issues at hand and resorts back to hypotheticals and computer models.”

In light of this change, the ethanol industry is calling for the Environmental Protection Agency (EPA) to also reevaluate its modeling of lifecycle GHG emissions as defined in the Renewable Fuels Standard (RFS2). Recently the Renewable Fuels Association (RFA) submitted a letter to EPA Administrator Lisa Jackson asking for this very change. In fact, EPA was represented on CARB’s LCFS Workshop and has publicly highlighted the fact that its ILUC results were similar to those originally obtained by CARB.

“The proposed changes to the California LCFS analysis are likely to result in substantially lower ILUC values, meaning EPA’s analysis for the RFS2 will be inconsistent with the latest science being adopted by CARB. Because EPA was represented by two staff members on the LCFS Expert Workgroup that recommended the changes to CARB’s LUC analysis, we are curious as to whether EPA similarly plans to revisit its LUC analysis for the RFS2 and incorporate more up-to-date assumptions and data,” wrote RFA President and CEO Bob Dinneen in a letter dated November 23, 2010.

According to RFA, while EPA and CARB used different modeling approaches, some of the changes being adopted by CARB would result in lower values for ILUC in EPA’s RFS2 as well. Currently, corn-based ethanol has been given a 20 percent GHG emission reduction number in RFS2, but the industry wants to see this number much higher. Other areas that RFA would like EPA to visit again are the treatment of crop yields on newly converted land, treatment of carbon sequestration in harvested wood products and the effect of higher prices on crop yields.

The second purpose of the letter to Jackson was to respond to the EPA’s letter sent to RFA on September 29, 2010. Back in September, the RFA wrote to EPA “examining the impact of volume increases for individual biofuels in isolation of one another exaggerates the LUC impacts and misrepresents the real-world progression of the RFS2 as required by [the Energy Independence and Security Act].” They have argued, and continue to argue, that EPA’s isolation approach to calculating ILUC values for the various biofuels covered under the RFS2 ignores the dynamic relationships that exist between the fuels, the feedstocks and in the marketplace.

The bottom line, says RFA, is that the science behind ILUC is constantly evolving and requires continual monitoring and updating to ensure the best available science is being utilized to make decisions.

“Biofuels are not a climate-friendly solution to our energy needs. The EU plans effectively give companies a blank cheque to continue grabbing land from the world’s poor by growing biofuels that fill our cars rather than their stomachs,” said Laura Sullivan, ActionAid’s European Policy and Campaigns Manager. “Europe’s energy policies are putting millions of people in danger and threaten Africa’s fragile food security.”

The global biofuels community is not taking the report lying down. “As a matter of record, our industry has always welcomed the debate about biofuels sustainability in large part because the alternative – more oil – is by definition unsustainable,” said Bliss Baker with the Global Renewable Fuels Alliance (GRFA). “However, NGO’s that use this debate as an opportunity to stoke fears and sell memberships in their organizations do a disservice to us all.”

According to the report, an area over twice the size of Belgium will need to be converted into biofuels plantations putting poor communities in danger if European countries use industrial biofuels to meet their renewable energy targets by 2020. Even more, the report claims that when indirect land use change is taken into account, a highly contested theory, biofuels will emit an extra 27-56 million tonnes of greenhouse gas emissions per year – the equivalent to an extra 12 to 26 million cars on Europe’s roads by 2020. Lastly, the report states that under the plans, 5 countries will be responsible for three quarters of all extra emissions. The UK, Spain, Germany, Italy, and France are projected to produce the most extra greenhouse gas emissions from biofuels.

Baker continued, “The research is chalk full of allegations disguised as facts. The report repeatedly makes statements as if they are facts such as ‘…the EU plans WILL result in the conversion of up to 69,000 sq. km of land for the use of biofuels.’ Sounds ominous but for the one word “upto.” It could be 1 square kilometer that gets converted. The point is they don’t know how many kilometres will be converted (if any) and predicting it with any degree of confidence has yet to be demonstrated anywhere.”

Baker continued by explaining that many of these ILUC models make critical assumptions such as keeping crop yields static despite the fact that yields in many parts of the world have doubled over the past 20 years. Many models, Baker says, for simplicity sake, assume that trees will live forever (they assume this because it is too hard to calculate the capturing and release of carbon over the life cycle of a forest). These are the kinds of very detailed assumptions that must go into making these calculations. No where do they list the assumptions that went into the models for these calculations. He also notes that “there is no rationale argument you could make that would withstand any level of scrutiny that would suggest large numbers of trees would be cut down to make room for new biofuels use in Europe.”

“As far as the science of ILUC is concerned, the academic work on modeling land use change impacts is very much in its infancy and is an incredibly complicated exercise,” explained Baker. “I know that does not work well for “bumper sticker” campaigns like the one being launched but it is true. Several leading scientists have raised serious questions about the ability of these models to predict for example the impact of crop rotations in Southeast Asia as a result of increased biofuels production on the other side of the world. That is what these models are attempting to do and there are more unanswered questions about the science of ILUC than there are answered questions. So basing public policy decisions on science that is at best questionable would be irresponsible.”

Baker concluded, “In short, the Global Renewable Fuels Alliance agrees with the scientific community that the science of ILUC is unpredictable and raises more questions than it answers.”

In response to the news, Geoff Cooper, the Vice President for Research and Analysis for the Renewable Fuels Association remarked, “The most recent work on ILUC is showing that ethanol expansion in the U.S. simply isn’t incurring the type of land use changes that were originally hypothesized. The initial results recently presented by the Department of Energy are further proof that America can continue to meet its global responsibilities to provide food and feed, while simultaneously providing a cleaner, domestic alternative to petroleum—all without needing to bring new lands into agriculture.”

The results of the study were released during the last CARB meeting focused on ILUC held last week. The time frame reviewed was during 2001-2008, when the U.S. ethanol industry more than quadrupled. The researchers concluded, “Empirical evidence does not support significant effects on U.S. commodity exports [and] other crops or cropland expansion in the U.S.”

“This should put the stake into the heart of the bizarre ILUC scheme. Here are some of the best scientists in the country – scientists who have no stake in the game – who found that ethanol had little to no impact from ILUC,” said Tom Buis, CEO of Growth Energy. “We must ask why California insists on going forward with a regulation that is based not just on controversial theory, but a theory that has been disproven.”

Coinciding with the Oak Ridge National Laboratory’s research, a paper published in Environmental Science & Technology and authored by Bruce Dale and other researchers at Michigan State University, “Biofuels Done Right: Land Efficient Animal Feeds Enable Large Environmental and Energy Benefits,” found that significantly larger volumes of biofuels can be produced without incurring ILUC.

“Using less than 30% of total U.S. cropland, pasture, and range, 400 billion liters (106 billion gallons) of ethanol can be produced annually without decreasing domestic food production or agricultural exports. This approach also reduces U.S. greenhouse gas emissions by 670 Tg CO2-equivalent per year, or over 10% of total U.S. annual emissions, while increasing soil fertility and promoting biodiversity. Thus we can replace a large fraction of U.S. petroleum consumption without indirect land use change,” the authors concluded in the paper.

The goals of the road map are threefold and designed to overcome several major obstacles that if not addressed, could keep the country from meeting its renewable fuels goals as set out in the Renewable Fuels Standard (RFS2) that mandates the country use 36 billion gallons of biofuels by 2022.

Goal 1: Accelerate the deployment of blender pumps and flex-fuel vehicles (FFVs). Both of these actions will allow market access and a level playing field for biofuels.

Goal 2: Put into place long-term policy that will create a marketplace that investors feel confident in and one that will revive rural economies and create jobs.

Goal 3: Reward energy efficient technologies and practices that reduce greenhouse gas emissions at biorefineries creating a more sustainable future for ethanol.

While the details are still being discussed behind closed doors in DC, here are a few elements of the tentative plan that have surfaced through various media reports as well as from a communication from a Republican DC staffer.

The current proposed plan would extend the current $54 cent ethanol import tariff for one year, expiring on December 31, 2011. Over five years, VEETC would be phased out and replaced by an ethanol producer’s tax credit that would go to funding biofuel infrastructure (aka blender pumps) as well as to encourage more flex-fuel vehicles on the road. This could be done through a variety of grants, incentives or through a loan guarantee program.

Two of the most critical elements of the tentative proposal, and the two that have already created a heated debate, is that through this revised program, corn-based ethanol would qualify as an “advanced biofuel” under the RFS2. This would remove the corn-based ethanol cap of 15 billion gallons.

The second critical element of the road map would be to suspend indirect land use penalties on corn ethanol pending a sound science program that would determine the lifecycle greenhouse gas emissions of all fuels being sold into the U.S. market.

It is important to note that no details of this road map have been officially released by the ethanol industry, but there is hope that a refined version of the proposal will be presented during a lame duck session in November.

In a letter to the EPA, RFA wrote, “While RFA generally supports a national policy to address climate change, we believe biogenic emissions must be exempt from GHG accounting schemes and regulatory frameworks. Specifically, inclusion of biogenic GHG emissions in determinations of applicability of the Prevention of Significant Deterioration (“PSD”) or Title V Permitting Programs is not scientifically justified, runs afoul of accepted national and international GHG accounting methods, and is contrary to public policies enacted to encourage development of a robust renewable fuels industry in the United States.”

According the the RFA, it is “indisputable that CO2 emissions resulting from the combustion, fermentation, and decay of biomass, are by nature, carbon neutral in that those emissions are naturally offset when the biomass removes an equivalent amount of CO2 from the atmosphere via photosynthesis during growth.”

Therefore, RFA is calling for the EPA to reconfirm that the carbon neutrality convention for accounting of biogenic GHG emissions is both scientifically justified and appropriate for regulatory contexts.

In addition, the RFA is questioning the EPA’s actual authority to regulate biogenic emissions under the Clean Air Act (CAA). Last November, carbon dioxide was determined to be a greenhouse gas emission and as such, became open game for regulation by the EPA under the CCA.

Finally, RFA took issue again with the inclusion of indirect land change emissions in the current policy referencing the oft disputed Searching and Hamburg studies who are both proponents of indirect land use. RFA writes, “Like those experts who have disagreed with the Searchinger/Hamburg approach, we believe land use change emissions in no way obfuscate or change the inherent carbon neutrality of biomass and biofuels. Rather, we believe biogenic emissions accounting and policy must remain distinctly separate from and independent of land use policy and accounting of land use change emissions.”

To read RFA’s letter to the EPA in full, including their supporting documentation, click here.

The result of correcting this error, says RFA, is that it would greatly increase the greenhouse gas reduction benefits offered by ethanol under EPA’s calculations.

“Correcting this miscalculation reduces net LUC emissions (international and domestic) assigned to corn ethanol by 62% from 28.4 grams of CO2-equivalent/mega joule (g/MJ) to 10.8 g/MJ. Such a reduction in LUC emissions means overall lifecycle GHG emissions for 2022 average corn ethanol would be 38% less than baseline gasoline emissions, rather than the 21% estimate finalized by EPA.”

Regardless of RFA’s analysis, they still maintain that the inclusion of LUC impacts, particularly international impacts over which the U.S. has no control, is flawed policy and that EPA misinterpreted the intent of Congress when it passed the RFS.

In a recent blog post discussing their letter to EPA, Geoff Cooper, RFA’s Vice President of Research and Analysis, writes, “Despite the fact that real-world data and events have disputed the ILUC theory at every turn, EPA’s final rule for the RFS2 institutes a net LUC penalty (domestic and international) against corn ethanol of 30 kg CO2e/mmBTU (or 28.4 g CO2e/mega joule). This represents nearly 40% of the total GHG intensity of corn ethanol as estimated by EPA. When LUC emissions are excluded, EPA found corn ethanol from a natural gas dry mill reduces GHG emissions by 50% compared to gasoline. With LUC emissions, that benefit falls to around a 20% reduction.”

RFA says that this overestimation occurred as a result of the questionable methodological choice EPA made to isolate the LUC impacts of individual biofuels by increasing their production one at a time and holding all other biofuels at constant levels. More appropriately, the RFA notes, if EPA felt compelled by the statute to penalize biofuels for ILUC, it should have based those penalties on modeling that simultaneously increased production for all biofuels in accordance with the RFS requirements.

RFA notes that these problems are endemic of larger concerns regarding attempts to limit emissions from vehicles by unfairly penalizing biofuels.

You can read RFA’s letter to the EPA here and read Cooper’s comments regarding this issue here.

The Land Use Conundrum . . . Corn, An Advanced Biofuel? That was the title of one of the sessions that was moderated by Jamey Cline, NCGA. One of his panelists was Adam Liska, University of Nebraska-Lincoln. His remarks were on “Uncertainty in Indirect Land Use Change Emissions from Biofuels.” Adam has focused his work on the life cycle efficiency of producing ethanol.

Adam says that there has been increased agricultural production worldwide due to increased demand and it seems like attributing some of that to increased biofuels production makes sense. However, he says that quantifying the emissions related to agricultural production due to biofuels use is very uncertain because it’s done “as a projection into the future.” The bottom line is we don’t know what will happen in the future. He says “it’s nearly impossible.” He says that there are estimates for corn ethanol but they get smaller and smaller with more research and information. He says that they’ve started to do some research on the indirect effects of gasoline production and figure they’re roughly equivalent to that of ethanol. He also points to the impact of changes in livestock production as a result of higher grain prices and says it may have more impact than land use changes. Seems like there is a huge amount of variability in how you look at the future when it comes to biofuels production and especially corn ethanol.

In a nutshell, the authors contend that American farmers, or farmers anywhere for that matter, should not, and cannot be held accountable for the decisions made by others in other countries, such as Brazil. “The differences in the treatment of technical and pecuniary externalities is that producers control their production and hence their pollution. But in a competitive market, they don’t control the prices. This reflects a basic principle: Individuals should be responsible for activities that they control and not for those they don’t. This basic message of accountability suggests that producers of biofuel shouldn’t be held responsible for indirect land-use decisions made by others.”

The authors continue by explaining that there is a related flaw in the use of indirect land use and in how it is applied to regulating biofuels. Basic principles of public economics dictates that all emitters of greenhouse gas emissions are held responsible for their own activities and thus their own emissions. However, ILUE suggests that farmers are responsible for possible emissions by other farmers elsewhere. Therefore, the authors contend, it makes more sense to strive to enact policies that will make countries like Brazil, responsible for their own GHG emissions related to indirect land use.

Ultimately, while the authors acknowledge that there are indirect land use changes inherent in biofuel development, these will be reduced over time as the technologies improve. Yet they caution that the technologies won’t improve, and we won’t move to next generation biofuels if the investment community continues to ignore the industry, in part driven by the flawed theory of indirect land use.

“In 2010, the U.S. Department of Agriculture predicts our corn farmers will produce more than 300 million more bushels than just three years ago, and do so on nearly 5 million fewer acres,” NCGA President Darrin Ihnen said in a news release. “International indirect land use change theory completely ignores or significantly downplays grower ingenuity and modern agronomy. This junk science needs to go the way of the horse-drawn plow.”

The unproven theory and models related to it are being used by the California Air Resources Board to implement that state’s low carbon fuel standard in such a way that ethanol made from corn would not qualify for use. Ihnen points to the recent Purdue study that found California is overestimating the greenhouse-gas impact of land use changes related to corn ethanol by a factor of two.

“The inclusion of model results in policy before the science has been fully established is not just a problem of rushing to judgment; in this case, it goes against the goal of reducing greenhouse gas emissions,” Ihnen said. “By saddling corn-based ethanol with incorrect emissions, the California standard may actually increase its reliance on petroleum or foreign sources of ethanol, therefore worsening the environment and our national economy.”

The Purdue research also reflects the scientific community’s rejection of the initial paper that brought the land use change theory to the front burner in February 2008, according to the Renewable Fuels Association. Since then, the estimated emissions purportedly occurring from the indirect land use change penalty have fallen by nearly 90 percent.

National Corn Growers Association Director of Biofuels & Business Development Jamey Cline is chairman of the plenary session “Land Use Conundrum…Corn, an Advanced Biofuel?” which will focus on the role land use criteria played in the decision that corn does not currently meet the qualifications of an advanced biofuel. The session will include both presentations and a panel discussion and will also explore how the United States will meet its greenhouse gas reduction mandates given that corn is currently the only significant source of ethanol in today’s marketplace.

Chuck Zimmerman talked with Jamey about CUTC in general and this session in particular. Listen to or download that interview in the player below:

“With about one in every ten U.S. cars driven in California, the largest state in the country with one of the highest carbon intensities in the world is seeking to do its share to fight climate change,” said Joel Velasco, UNICA’s Chief Representative in North America. “After exhaustive study, state officials have identified sugarcane ethanol as an important part of the solution to achieving California’s low-carbon goals, and our industry is prepared to help meet the challenge.”

However, Growth Energy CEO Tom Buis says the Brazilian sugarcane ethanol industry is defending a flawed formula that overestimates theoretical “indirect land use change” (ILUC) penalties on U.S.-made grain ethanol – when ILUC itself has yet to be proven as fact. “The foreign interests that would stand to gain under California’s flawed low-carbon fuel standard are rushing to defend it – despite the fact that ILUC is far from certain, and despite new evidence that the California Air Resources Board’s use of a Purdue University formula estimating ILUC was wrong. And that evidence comes from the very university that designed the formula,” said Buis in a news release.

Buis notes that a recent Purdue University study shows that the formula used by California overestimates corn ethanol’s ILUC emissions by more than twice as much.

Growth Energy, in conjunction with the Renewable Fuel Association and several agricutlural organizations, are challenging California’s LCFS on grounds that the regulations violate the Commerce and Supremacy clauses of the U.S. Constitution. The case will be heard on May 26 in Federal District Court in Fresno, California.

POST UPDATE: UNICA’s Joel Velasco wrote in to comment that Growth Energy’s issues with indirect land use change “have nothing to do with the challenges before the court – the lawsuit is about whether the Constitution allows California to regulate its fuels.” Velasco says he was not defending CARB’s ILUC calculations in his quote, “In fact, CARB assesses a higher ILUC penalty on sugarcane than corn — 46 vs. 30 gram of CO2 per megajoule. We just think California has a right to regulate its fuels under the Constitution.”

Geoff Cooper with the Renewable Fuels Association is chair of the “Maximizing DDG Quality” technical session. “We are coming off of a very late, wet harvest that presented a variety of quality challenges,” said Cooper. “It is important that both producers and processors of the grain recognize the unique quality challenges that they face and take appropriate steps to maintain and maximize quality throughout the process.”

The plenary session “Land Use Conundrum…Corn, an Advanced Biofuel?” will focus on the role land use criteria played in the decision that corn does not currently meet the qualifications of an advanced biofuel, the session will include both presentations and a panel discussion. The session will also explore how the United States will meet its greenhouse gas reduction mandates given that corn is currently the only significant source of ethanol in today’s marketplace.

CUTC is designed for anyone seeking to learn the latest developments in technologies related to corn. Registration information is available on-line.

The Renewable Fuels Association sent a letter sent this week to ARB Chair Mary Nichols pointing out this dramatic conclusion and reminded her of the board’s promise to review and incorporate new science as it becomes available. In the letter, RFA President Bob Dinneen wrote:

“New research conducted and published by Purdue University using the Global Trade Analysis Project model (GTAP) concludes that land use change emissions potentially associated with corn ethanol expansion are likely less than half of the level estimated by the California Air Resources Board (ARB) staff for the LCFS. While we continue to have grave concerns about including highly uncertain and prescriptive indirect emissions penalties in the LCFS (for instance, we do not believe ARB has the authority to account for ILUC consistent with the Commerce Clause of the U.S. Constitution), we write to point out the new Purdue findings because we believe ARB has committed itself to consider and respond to critical developments like these.”

Read a pdf of the Purdue report here.

The good news is that the RFS2 improves upon the rule EPA proposed last year, and that it is much better than what California is using to determine lifecycle greenhouse gas emissions. The bad news is the continued reliance on the non-scientific indirect land use change. EPA’s new calculations determined that corn ethanol was better than they first thought when it comes to indirect land use change, so they cut that penalty in half, while they totally eliminated it for sugarcane ethanol – a move that has RFA mystified.

This podcast was recorded at the recent National Ethanol Conference, where RFS2 was the main topic of discussion. We reference a presentation done at the conference by EPA’s Sarah Dunham, which you can find in a previous post here on Domestic Fuel.

You can subscribe to this twice monthly podcast by following this link.

Listen to or download the podcast here:

And here’s why: when a tree is cut down in Brazil, it is not to plant crops for biofuels, it is to sell the wood because the tree is of greater value as wood, then as part of the rainforest. Only then is the land converted to pasture and then to land for crops like soybeans. Sugarcane is rarely grown in the rainforest and Brazil doesn’t produce biofuels from corn. So what I just can’t seem to wrap my head around is what exactly does that tree have to do with corn ethanol?

So what has caused today’s diatribe on indirect land use? A new paper published this month in Bioscience Magazine titled, “Effects of US Maize Ethanol on Global Land Use and Greenhouse Gas Emissions: Estimating Market-mediated Responses.” The paper was authored by Thomas W. Hertel of Purdue University and five co-authors. In a nutshell, the authors argue that the greenhouse gas emission reductions from corn-based ethanol are canceled out when factoring in the increased carbon output from indirect land use change. Therefore, their contribution to California’s Low Carbon Fuel Standard is negligible, even when compared to conventional petroleum based fuels.

There are so many things wrong with this paper that I had a hard time deciding where to begin. I’ll dive right in with the authors’ assessment of the number of acres used to produce corn in our country (they use yield numbers from 2001 when yield numbers for 2009 are already available).

They argue that land is going to need to be converted to crops and that this land will come from virgin land such as tearing down a forest. They also assume that current cropland will be converted to produce corn (most commonly away from soybeans). What they don’t factor is is this: In 2009, American farmers produced 13.2 billion bushels of corn, similar to the production numbers reported in 2007. The difference –this yield was produced using 7 million, yes million, less acres of land.

The ethanol industry was quick to respond. Tom Buis, CEO of Growth Energy commented, “The truth is, indirect land use is a heavily disputed theory in the scientific community that has yet to be proven. The theory of ILUC employs no empirical evidence and it is unfair to single out one industry – corn ethanol – as the culprit behind poor environmental practices in other countries.”

Buis continued, “Even when ILUC is included in lifecycle analysis for corn ethanol, the Environmental Protection Agency qualifies it as a low carbon fuel that is 20 percent cleaner than gasoline. Excluding ILUC, ethanol from corn is 59 percent cleaner and can play a significant role in cleaning the air, creating U.S. jobs and securing our national and economic defense.”

What Growth Energy failed to mention is that the paper was written with the help of several organizations including California Air Resources Board and The Energy Biosciences Institute, which was funded by $500 million from oil company BP in 2007 and at the time the largest single research “contribution” in the record books. Also participating was our “best friend forever” Timothy Searchinger. Searchinger is a lawyer by trade and is no more qualified to conduct a study on indirect land use than I, a blogger. So what we really have here is yet another biofuels “study” funded by Big Oil. (And have I mentioned lately that Big Oil is still funding a campaign to discredit global climate change?)

The authors do cede that the concept of indirect land use is largely “uncertain and clearly requires additional analysis,” which brings me to the million dollar question, If indirect land use is so uncertain, then why are we creating policy based on unsound science? Oh, I forgot, our country doens’t make policy decisions on sound science. And that my friends is one reason why our country is in this big energy mess.

In this edition of the Domestic Fuel Cast, we hear from National Biodiesel Board Vice Chairman Gary Haer with Renewable Energy Group, who spoke at the National Biodiesel Conference and Expo, and President and CEO of the Renewable Fuels Association, Bob Dinneen, talking from the National Ethanol Conference in Orlando, Florida, and get their thoughts on RFS2.

It’s an interesting conversation, and you can hear more of it below.

You can also subscribe to the DomesticFuel Cast here.

I’m attending the meeting and had a chance to visit with National Corn Growers Association CEO, Rick Tolman, seen here addressing one of the conference meetings. NCGA is a founding member of the U.S. Grains Council.

Rick, who worked for USGC for many years, says that NCGA considers the Grains Council their international trade partner. The two organizations have a very strong working relationship. He says one of the things he’s really happy to hear discussed here at this meeting is how well exports of DDGS have been due to the efforts of the Grains Council. That’s good news for corn growers for whom the production of ethanol is so important right now. He says that the Grains Council is looking at other value added products they can promote for export too.

Since Rick is here instead of attending the National Ethanol Conference which gets underway today I asked him what’s going on in the ethanol industry from a corn growers perspective. He says there is a whole list of challenges and opportunities for ethanol. He says that with the final rule making on the RFS-2 it has improved the regulations but also created some challenges. It has given more optimism for growth of the business he says but the EPA is still giving a big penalty to ethanol for indirect land use change. He says it’s “tying an anvil around the ankle of the industry and trying to move forward and compete.” NCGA will continue to work with EPA to remove the unfair part of the new rules.

By the way, Cindy is attending the National Ethanol Conference so you’ll be seeing her coverage here on Domestic Fuel once the meeting gets going. The opening general session will be tomorrow morning.

You can listen to my interview with Rick here:

The standard requires that biofuels will have to reduce greenhouse gas emissions compared to the gasoline and diesel fuels they displace and grow in production from last year’s 11.1 billion gallons to 36 billion by 2022, with 21 billion gallons to come from advanced biofuels. It’s expected to replace more than 328 million barrels of non-renewable petroleum a year and reduce greenhouse gas emissions more than 138 million metric tons annually when fully implemented.

While admitting it might not be perfect, RFS-2 is being welcomed by representatives of the ethanol and biodiesel industries.

In this edition of the Domestic Fuel Cast, we’ll here from EPA Administrator Lisa Jackson, Secretary of Agriculture Tom Vilsack, as well as Tom Buis with Growth Energy, the Renewable Fuels Association‘s Matt Hartwig, and the National Biodiesel Board‘s Michael Frohlich.

They all have interesting takes on what the new standard will bring in the short and long terms, and you can here what they have to say here: DFCast-2-04-10.mp3

During a recent interview before the delay was announced, AFBF president Bob Stallman said the agricultural organization opposed the climate change bill that was passed by the House, despite provisions included that were beneficial to agriculture. “That bill we believe will downsize American agriculture by at least 20 percent,” he said. “Long term it reduces our ability to produce food.”

Stallman says that AFBF is also opposed to the controversial concept of indirect land use change to determine the lifecycle greenhouse gas emissions of biofuels. “That issue is an attempt by the environmental community to remove the use of corn ethanol from the Renewable Fuel Standard,” Stallman said. “We’re opposed to that. Number one, there is no science, it’s pure speculation. And how you can say that an acre producing corn ethanol here is going to change a specific acre in a specific country is nonsense.”

Listen to an interview with Stallman here.

The Global Renewable Fuels Alliance (GRFA) is calling on delegates to the United Nations Framework Convention on Climate Change Conference in Copenhagen December 7-18 “to seize the historic opportunity to recognize the environmental importance of biofuels and begin to develop strategies to ensure that biofuels play an even greater role in meeting global climate change objectives.”

GRFA released an position paper this week summarizing greenhouse gas (GHG) reduction strategies in the transportation sector that take advantage of the verifiable emission reductions available from biofuels. “With transportation responsible for 25% of the world’s GHG emissions and rising, it is critical that biofuels form the core of any future mitigation strategy in this important sector,“ said GRFA spokesman Bliss Baker. “Adopting sustainable biofuels programs can deliver real GHG reductions while reducing a crippling reliance on imported fossil fuels for many developing nations.”

GRFA outlines several actions to be recommended at the conference, including the adoption by governments of biofuels-friendly policies in the transport sector, and that policies take into account the increasing efficiency of global biofuels production in developing policies as opposed to relying on out-of-date data and outdated arguments. They also urge all governments to base an indirect land use change (ILUC) policy on transparent and unequivocal scientific evidence only.

GRFA also continues to call on the World Bank, the United Nations and other international bodies to increase investment in the agricultural sector of developing nations and to support expanded biofuels production in these regions.

Read the GRFA position paper here.

Novozymes is one of the dozens of companies speaking out against the article and its conclusions. Suggestions that the increased use of fuel produced from biomass will automatically lead to increased deforestation globally ignores existing science, continued technological advances, and numerous international policies and principles under development to regulate biofuels, say experts at Novozymes.

“We need to make smart energy choices that support a low-carbon energy future,” said Adam Monroe, president of Novozymes North America. “Jumping to quick conclusions about deforestation may ruin one of our best chances for addressing climate change and establishing a sustainable, secure energy supply.”

Because of the potential value that biofuels have as part of a low-carbon society, dozens of scientists have challenged the credibility of economic models used to estimate the values of GHG emissions projected from ILUC.

“Clearly, the direct and indirect environmental impacts of the world’s energy supply need further study, but there needs to be a level playing field to ensure that biofuels, bioelectricity and, most importantly, fossil fuels are all judged by the same criteria when measuring emissions. There should be a full accounting of the carbon emissions of all fuels, not just biofuels,” said Monroe.

“Fixing a Critical Climate Accounting Error”, authored by recognized ethanol-detractor Timothy Searchinger, argues that biofuels and other bio-based energies should be accountable for the biogenic tailpipe and “smokestack” CO2 emissions that are absorbed by growing feedstocks and carbon emissions that could result from land clearing. The authors claim that existing and proposed regulations, such as the so-called U.S. cap and trade bill, create an accounting loophole that will lead to increased deforestation.

The Renewable Fuels Association says the authors propose an unnecessary and impossible system that would trace actual flows of carbon. “The real issue is not accounting tactics, but whether biofuels reduce GHG emissions compared to continued petroleum use. There is clear and substantial evidence that they do.” RFA noted in a statement.

Growth Energy CEO Tom Buis says that doing what the article suggests “would give an indirect benefit to oil – they’re saying it’s OK to pump oil out of the ground and use trees to absorb the carbon. But that does nothing to address our country’s dependence on expensive and carbon-intensive fossil fuels like oil, extracted from overseas oil fields or tar sands, where emissions are three to five times the rate of normal crude oil production.”

Brian Jennings, Executive Vice President of the American Coalition for Ethanol (ACE) notes that “Searchinger is not a scientist, economist, or agronomist who has taken the time necessary to study whether his theories about land use and biofuels are validated by on-the-ground measurements. He’s an attorney who appears to have a political ax to grind against biofuels. New technology makes corn ethanol more efficient and sustainable each and every day, while future sources of oil get less efficient and more harmful to the environment.”

In this edition of the Domestic Fuel Cast, you’ll hear how Jobe believes the information that biodiesel now produces 4.5 units of energy for every unit of energy spent on it will prove to the EPA and skeptics that biodiesel is truly one of the greenest fuels out there. He says the information couldn’t come at a better time and was included with the NBB’s comments about the RFS-2.

Jobe adds that the NBB will be showing off biodiesel’s green, sustainable nature with a Greenfest in the board’s hometown of Jefferson, Missouri at Riverside/Ellis Porter Park this Thursday evening, October 22nd from 4-8. He says Jefferson City boasts several users of biodiesel, including the Missouri Department of Transportation, which uses a blend of 20 percent biodiesel (B20) in all of its diesel vehicles. Plus, the city itself burns B20 in its city buses. Fire trucks, ambulances, and hybrid and flex-fuel vehicles will also be on hand for the JC Greenfest, as well as demonstrations from Linn State Technical College and Lincoln University. They’ll even have live music from national recording artist Emily Richards

To hear more of my conversation with Jobe, listen to the latest DF Cast here: DFCast-10-19-09.mp3

You can also subscribe to the DomesticFuel Cast here.