Indirect Land Use Change (ILUC) Discussion Revived: Provides Hope for Progress on Biofuels

In 2009 the California Air Resources Board (CARB) mandated that by 2020, California fuel producers and suppliers must reduce the carbon intensity (CI) of produced fuels 10 percent, relative to 2010 levels. These reductions are met by blending or replacing high-carbon fuels. In California, each fuel type is assigned a CI score that is measured in grams of carbon dioxide (CO2) equivalent per megajoule (g/mj), and CARB measures CI based on both direct and indirect emissions. The indirect emission calculation includes the Indirect Land Use Change (ILUC) metric, a measurement of the unintended consequences to land-use change globally from the use of biofuels. While images of clear cutting are powerful and the loss of critical forest is certainly deeply troubling there are many causes of deforestation and land use change: timber demand, livestock grazing, mining, urban sprawl, and global food and subsistence methods. The contribution of U.S. biofuels production to global land use change is still not well understood. But, for every gallon of ethanol not blended into our fuel supply, we instead rely on a gallon of gasoline, which has a host of environmental and public health impacts.

Several scientists pointed out to CARB in 2009 that indirect emissions are difficult to quantify. At the time, the models were not sophisticated enough to include indirect emissions from biofuels. The biofuels industry and many scientists also worried that the ruling would unfairly penalize crop-based biofuels, since all fuel sources have immeasurable indirect effects. Despite these concerns, CARB adopted an ILUC penalty of 30 g/mj for corn ethanol. According to CARB, the CI of corn ethanol is approximately 60 to 70 g/mj and the CI of gasoline is 99.2 g/mj. After the ILUC penalty is applied, corn ethanol’s CI is only marginally better and in some cases, worse than gasoline. This ruling has essentially locked Midwest corn ethanol producers out of the California fuel blending market for the last five years.

In the past few years since the CARB ILUC debate, scientists have collected more data, refined the models and retested the original ILUC hypothesis. The end result of this is a much clearer understanding of biofuels and indirect land use, in addition to fuller understanding of the carbon footprint of petroleum, which only continues to grow. On March 6, 14 scientists and researchers sent a letter to CARB, presenting new evidence in favor of dramatically reducing the ILUC penalty on corn ethanol. Drawing from 15 scientific studies, the researchers assert that corn ethanol ILUC impacts are most likely in the range of 6-15 g/mj, which is 50 to 80 percent lower than CARB’s current penalty. Significantly, these scientists still feel that regulating ILUC is misguided, given the complexities of assessing it, stating “many of us continue to believe the use of point-estimate ILUC factor is inappropriate for the purposes of regulation.”

On March 11, CARB met to discuss proposed revisions to the Low Carbon Fuel Standard (LCFS), including a possible reduction of the ILUC penalty. Included in the proposal is a new model for calculating CI, the Greenhouse Gases Regulated Emissions and Energy Use in Transportation model (GREET), developed by Argonne National Laboratory. Additionally, they propose a reduction in the CI ILUC penalty for corn-based ethanol, from 30 g/mj to an average of 23.3 g/mj for 2014, a 20 percent reduction. The CI for soy biodiesel, sugarcane ethanol, canola biodiesel and sorghum ethanol would also be reduced. While the biofuels industry and many advocates say all of the proposed CI assessments are still too high, it’s a start. CARB also states that it is now working with scientists to further improve their ILUC assessment.

What happens in California will likely serve as a national model. The Renewable Fuel Standard (RFS) has not been perfect, but progress is beginning to accelerate. As of early 2014, the first advanced cellulosic plants are being built and advanced biodiesel is commercially available. E85 is available at more fueling stations than ever before. Corn is reaching greater yields, with far fewer inputs and on less land. Additionally, the 2014 Farm Bill ties crop insurance to mandatory conservation programs for the first time. Detangling the complicated web of ILUC is an important step in bringing biofuels to market, not least of all because it became a well-trodden argument against biofuels. New tools have been developed to monitor forests in real-time, such as the World Resources Institute’s (WRI) Global Forest Watch, in addition to ongoing research at major universities and national laboratories. While deforestation is still a major global concern, there is new hope as deforestation is beginning to slow. Brazil will meet its goal of 80 percent reduction in deforestation by 2020, and the United States has increased its total percentage of forested land since 2010. Forests provide incalculable benefits, and the threats of climate change, population growth, growing demand for food and water have brought increased attention to the value of forests as refuge for plants and animals, carbon sinks, watershed protection and even human refuge from the demands of modern life. Forestry products and biofuels are not diametrically opposed to healthy forests; rather these diverse goals can all support healthy forests if thoughtful management practices are applied. Supporting diverse feedstocks, pushing for better conservation methods and providing regulatory certainty for sustainable biofuels will continue to move the United States towards a lower-carbon, more sustainable future.