A letter questioning the approach taken by the California Air Resources Board (ARB) which singles out biofuels for “indirect effects,” has been sent by a group of scientists to the State Governor Arnold Schwarzenegger, today (2nd March). The effect of the approach is to suggest that petroleum products result in lower carbon emissions than biofuels which, says the scientists, creates a very skewed playing field. A total of 111 scientists from research labs such as the National Academy of Sciences, UC-Berkeley, Sandia National Labs, Lawrence Berkeley National Lab and MIT signed the letter.

In the letter the scientists say: "As you are aware, ARB staff continues to push a regulation that includes an indirect land use change (iLUC) penalty for biofuels. To be clear, this effect is not the direct land conversion from growing crops for fuel. It is the alleged indirect, price-induced land conversion effect that could occur in the world economy as a result of any increase in demand for agricultural production. The ability to predict this alleged effect depends on using an economic model to predict worldwide carbon effects, and the outcomes are unusually sensitive to the assumptions made by the researchers conducting the model runs. In addition, this field of science is in its nascent stage, is controversial in much of the scientific community, and is only being enforced against biofuels in the proposed LCFS."

The scientists made two major compelling points:

   1. The science is far too limited and uncertain for regulatory enforcement

   2. Indirect effects are often misunderstood and should not be enforced selectively

Finally, the scientists pointed out the bias and inconsistency in ARB’s approach:

"Petroleum, for example, has a price-induced effect on commodities, the agricultural sector and other markets. Electric cars will increase pressure on the grid, potentially increasing the demand for marginal electricity production from coal, natural gas or residual oil. Yet, to date, ARB is proposing to enforce indirect effects against biofuel production only. This proposal creates an asymmetry or bias in a regulation designed to create a level playing field. It violates the fundamental presumption that all fuels in a performance-based standard should be judged the same way (i.e. identical LCA boundaries). Enforcing different compliance metrics against different fuels is the equivalent of picking winners and losers, which is in direct conflict with the ambition of the LCFS."

The questions raised by the scientists are underscored by the findings of two recent studies -- a recent study by Air Improvement Resource, Inc. (AIR) which found that, "The overall conclusion of this report is that 15 [billion gallons per year] of corn ethanol production in 2015/16 should not result in new forest or grassland conversion in the U.S. or abroad” and a peer-reviewed study published in Yale’s Journal of Industrial Ecology by researchers at the University of Nebraska who found, “corn ethanol emits 51 percent less greenhouse gas than gasoline."