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Low Carbon Fuels Standard Revisions Urged by RFA

23 January 2013

US - More than two years have passed since the California Air Resources Board (CARB) committed to revise indirect land use change (ILUC) penalties assessed against certain biofuels as part of the state’s Low Carbon Fuels Standard (LCFS). Additionally, numerous peer-reviewed studies published since the LCFS was adopted show CARB grossly overstated the overall carbon intensity of corn ethanol.

Yet today, the agency still has not made a single change to the LCFS program’s ILUC estimates or direct carbon intensity values for corn ethanol, according to a letter sent by the Renewable Fuels Association (RFA) to CARB Chairwoman Mary Nichols.

“I am writing to again encourage CARB to honor its commitments to expeditiously revise the ILUC penalty factor assessed against corn ethanol and to utilise the ‘best available science’ when determining direct [carbon intensity, or CI] values,” wrote RFA President and CEO Bob Dinneen.

“Revising the direct and indirect CI values for corn ethanol would be much more than a mere academic exercise; rather, a continued failure to update these CI values will jeopardise the ability of regulated parties to reasonably comply with the LCFS program’s increasingly rigid CI standards in 2013, 2014 and beyond.”

Dinneen’s letter cites a number of reports and studies published in the past several years that clearly demonstrate CARB’s corn ethanol carbon intensity estimates are unjustifiably inflated. The most recent study, conducted by GREET model creator Michael Wang at Argonne National Laboratory and published in Environmental Research Letters, found the carbon intensity of average corn ethanol to be 62 grams of CO2-equivalent per megajoule (g/MJ), including possible emissions from ILUC. That’s 38 per cent lower than CARB’s current estimate of 99.4 g/MJ for average Midwest corn ethanol.

Specifically on the subject of ILUC, Mr Dinneen cites several recent papers and writes “...based on newer data and improved methodologies, the independent estimates of corn ethanol LUC produced since the LCFS was finalised have generally trended in the range of 8 to 15 g/MJ. This compares to CARB’s ILUC estimate for corn ethanol of 30 g/MJ.”

The letter continues, “Clearly, given the data and modeling results that have become available since the LCFS was adopted, CARB has no scientific basis or rationale to maintain its current CI scores for corn ethanol.”

Mr Dinneen's letter also reminds CARB that "...failure to revise corn ethanol direct and indirect CI values in a timely matter will greatly complicate compliance with the LCFS in 2013, 2014 and beyond." In order to fully offset the deficits generated on CARBOB, the ethanol blended into E10 must possess a CI value of 83.6 g/MJ or lower in 2013. In 2014, ethanol must have a CI value of 76.7 g/MJ in order to fully offset CARBOB deficits.

“Because of CARB’s inflated direct and indirect CI values, most Midwest corn ethanol—even ethanol from many of the plants that secured new pathways via Method 2A/2B—will not be viable for compliance this year or next,” according to the letter.

TheCropSite News Desk

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