CARB: Give Ethanol a Full Opportunity to Enhance Air Quality

Developments in California this week suggest a positive movement toward a more equitable policy for ethanol. The California Air Resources Board (CARB) held a workshop with staff and stakeholders this week to review materials that could – and should – lead to a reduction in the “penalty” the board imposes on ethanol use in the state.

The potential for relief in California is good news for all U.S. ethanol producers who have long suffered from the unfair and inaccurate demonization of their product in some circles as a menace to clean air. How many news stories on biofuels do you see that include a passing reference to the ludicrous claim that ethanol emits more greenhouse gases (GHGs) than gasoline?

Now, a state that imposes the strictest clean air standards in the nation is revisiting its five-year-old Low Carbon Fuel Standard (LCFS) ‑ a critical weapon in a broad arsenal the state uses to combat some of the nation’s dirtiest air – with an eye towards giving ethanol more of what it is due: recognition that it contributes to cleaner air.

The LCFS as adopted in 2009 drew strong criticism from not only the ethanol sector, but a wide array of scientists who said the board staff’s use of indirect land use change (ILUC) in calculating the impact ethanol had on greenhouse gas emissions was over-estimated, if not downright inappropriate, given the uncertainty of ILUC’s existence, much less the science community’s ability to measure it.

Indirect land use change is cited by biofuel critics who claim that the production of grains and other crops used to make biofuels here in the United States is leading to the displacement of sensitive acreage overseas to make up for the alleged loss of food production. With that displacement, the theory goes, comes the loss of carbon sinks and greater emissions.

Despite some broad opposition from scientists, CARB’s use of ILUC in establishing the LCFS virtually branded most corn ethanol as non-compliant. Board members later agreed to re-evaluate the degree to which it applied ILUC the standard, but it has been a slow process that has yet to respond to the evidence long in play showing land use change is, at best, an uncertain factor, if it is one at all.

EPA factored in ILUC when it modified rules in 2010 further implementing the expanded federal Renewable Fuels Standard (RFS). But after careful examination of the data, EPA scientists ruled the impact of ILUC was negligible, noting the forecasts that show advanced technology will significantly improve crop yields to a level that would discount ILUC if it did exist.

So while CARB finally appears ready to take some steps in upgrading its view of ethanol and the role it plays on air quality in the state, the sad case is that it looks like the board will not go far enough. It’s a shortcoming underscored in a letter to CARB leaders from 14 scientists, including five who served on CARB’s scientific review panel that advised during the development of the LCFS.

The scientists, a number of whom “continue to believe the use of point-estimate ILUC factors is inappropriate for the purposes of regulation,” say that “ILUC analysis continues to suffer from a relatively high degree of systematic and data uncertainty.” But they note that “the quality of both the models and input data chosen for use by CARB have substantially improved since the board formally adopted the LCFS.”

The scientists say the improvements have shown that corn ethanol ILUC-emission estimates are much lower than CARB’s current estimates for the LCFS, with the lower estimates attributable to “more robust data and enhanced understanding” of factors including the types of land most likely to be converted, the likely location of predicted conversions, crop yields, the impact on land use of animal feed co-products made during the production of ethanol, and improved land management practices, among others.

As a result, the scientists say that instead of the 20-percent reduction in carbon emission estimates from corn-based ethanol as proposed by CARB staff this week, the reduction should be at least 50-80 percent, demonstrating that ethanol from corn is responsible for reducing carbon emissions on a level with ethanol from sugarcane and with biodiesel – all of which emit far fewer GHGs than gasoline.

The scientists’ clear and demonstrable belief in the environmental benefits of ethanol is shared by the Obama administration, which has strenuously stated that biofuels, including corn ethanol, are a principal tool in the White House strategy to combat a changing climate. It’s a view that should be adopted by CARB – and policy makers at all levels, including those at EPA who have wrongly proposed to reduce the amount of ethanol and other biofuels to be blended in the nation’s fuel supply under the RFS in 2014. Ethanol deserves a fair opportunity to be a critical part of a national energy strategy that promotes jobs, enhances our security and improves the air we breathe.


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