RFA Says Californian Low Carbon Fuels Plan Likely to Fail

California’s efforts to reduce the carbon intensity of the state’s transportation fuels are admirable, but the state’s goals, as outlined in the proposed Low Carbon Fuels Standard (LCFS), are unlikely to be achieved because of the policy’s inherent bias against low-carbon biofuels, says the Renewable Fuels Association (RFA).

In written comments to the California Air Resources Board (CARB) in advance of its April 23 hearing on the LCFS, the RFA outlined four areas of CARB’s Initial Statement of Reasons (ISOR) concerning that LCFS that are particularly troubling to conventional and next generation ethanol producers (Note: Last week, 12 advanced and cellulosic ethanol companies and RFA members here warned CARB that its current proposal would undermine the development of next generation ethanol technologies.).

RFA’s primary concerns with the LCFS include:

Insufficient Land Use Change Analysis
According to RFA comments, CARB’s efforts to calculate indirect land use change (ILUC) allegedly occurring due to expanded U.S. ethanol production need further refinement and validation. Notably:

• The model CARB relies upon, known as GTAP, is not a mature model for estimating land use changes
• The biofuels “shock” implemented in GTAP is inconsistent with USDA projected crop yields. That is to say, CARB is not sufficiently accounting for increased crop yields in the U.S. as a result of new technologies.
• Insufficient GTAP feed co-product land use credits result in overestimation of land use changes
• Other GHG benefits of co-products are ignored (or “still being evaluated”)
• Missing land sets in the GTAP database result in extra forest land being converted
• The analysis does not consider relative costs of converting different land types, resulting in overestimation of forest land converted
• RFA’s comments include more realistic outcomes using the GTAP model when less pessimistic assumptions are used. With respect to ILUC calculations, the RFA recommends that CARB’s analysis be refined assuming a more balanced and less pessimistic set of assumptions influencing the overall ILUC emissions.

Direct Emissions
Recent analyses of the direct emissions of corn ethanol production included in the Journal of Industrial Ecology as well as those published by the International Energy Agency (IEA) suggest that ethanol reduces greenhouse gas emissions between 30 and 59%. Yet, CARB’s analysis relies primarily on data collected between 2001 and 2006. The RFA recommends CARB use more current assessments and projections through 2010 for estimating the direct energy intensity of ethanol production.

Food versus Fuel
In its grain market analysis, CARB fails to properly account for the livestock feed co-product called distillers grains (DDGS). As one-third of every bushel of grain entering an ethanol biorefinery is returned to the livestock feed market, proper credit needs to be given to this important co-product. In addition, the aforementioned assumptions for crop yield improvements are far too conservative. The RFA recommends that CARB reassess its evaluation of these criteria to include the important contributions of DDGS as well as the expected increases and trend-line yield improvements of U.S. crops.

LCFS Baseline
CARB is using California Reformulated Gasoline, or CaRFG, with 10% corn ethanol as its baseline fuel. As such, ethanol, unlike any other regulated fuel, is being forced to compete in part against itself. The RFA recommends CARB use a non-ethanol-blended fuel (as it has done in its biodiesel and diesel analysis) as the baseline fuel.

Comments by the RFA and other biofuels supporters can be found at CARB’s website.