Leery of Indirect Land-Use Change
It would be easy for the biomass industry to just ignore the issue of indirect land-use change and leave it to the ethanol and biodiesel industries and the corn and soybean growers to deal with, but that wouldn't be prudent.
The truth is indirect land-use change could impact all land users, including biomass. In fact it should impact everyone. I'm not saying that I'm in favor of using indirect land-use change to regulate greenhouse gas emissions for renewable fuels, but if the U.S. EPA is going to make that leap it must do the same for everyone. If they aren't willing to do that then it should just be dropped.
I also have to wonder how this is going to play elsewhere. How can we expect other countries to regulate their own land use if they can just blame everything on biofuel feedstock producers in the United States?
I have to admit I don't know what the logic is behind the use of indirect land use change, but I would think that we could come up with a more sensible and equitable solution. Chances are if I don't understand it others won't either. Then all we have is another situation like we have with the tax code, where not even the people who wrote it can figure it out.
I totally agree that we need to protect the environment and I think we all know what can happen when it's left to chance. But let's be reasonable and fair.
I have found the Renewable Fuels Association Web site to be a helpful tool as I try to figure out the impact of indirect land-use change. The RFA has a nice, easy to read document called "Initial Thoughts on RFS2 Land Use Change Analysis" that you can see for yourself at
http://www.ethanolrfa.org/objects/documents/2387/rfs2_land_use_change_analysis.pdf.
I also read as much as I can from the proponents of indirect land use and when I find something that makes total sense to me I'll let you know. Maybe after the U.S. EPA holds its public workshop on life-cycle analysis during this 60-day comment period before it makes its final decision I'll get a better idea of just what's involved.