Repeal Indirect Land Use Clause

July 8, 2009

BY Tom Buis

When Congress expanded the renewable fuel standard (RFS2), its goal was to promote the expansion of biofuels in order to increase our energy and national security by providing an alternative to foreign oil, creating new green-collar jobs and protecting the environment. However, one clause threatens to derail the progress America's ethanol producers have been making toward the production of cleaner, greener, more efficient biofuels. A half-baked theory that is not based on sound science, called indirect land use change, could be used by the U.S. EPA in the calculation of ethanol's greenhouse gas (GHG) emissions.

The RFS2 lays out several requirements for reductions in GHG emissions in biofuels. For corn ethanol from new refineries, a reduction of 20 percent compared with gasoline emissions is required. Cellulosic ethanol must have a 60 percent reduction. Under the Energy Independence and Security Act of 2007, Congress gave the EPA the authority to calculate the direct and indirect effects of biofuels under RFS2. We fully support measuring the direct effects of biofuels. We already know that the latest life cycle analysis, the agreed-upon method of GHG calculation among academics, shows that the ethanol industry is currently producing a fuel that is as much as 59 percent lower in direct-effect life cycle greenhouse gas emissions compared to gasoline. In the future, ethanol produced from cellulose has the potential to cut GHGs by up to 86 percent compared to gasoline—if this new theory doesn't halt progress in its tracks.

Including the highly controversial indirect land use change theory in the calculation of ethanol's carbon intensity leaves new corn ethanol plants unable to make the 20 percent reduction in GHG emissions. But indirect land use change theory uses speculative models and incorrect assumptions in an attempt to blame American farmers for deforestation in Brazil. It is also directly contradicted by real-world data, which shows that deforestation in the Amazon declined sharply just as American biofuels production doubled. We can't base government policies on theories that aren't backed up with real-world evidence.

Land use decisions involve many factors that have nothing to do with renewable fuels, including changes in currency, monetary policy, export needs, productivity gains, and weather.

Furthermore, the EPA does not examine the indirect effects of petroleum. According to a recent study, the carbon emissions that result from protecting the oil supply in the Middle
East could alone double the carbon footprint of foreign oil. This is just one of the many potentially significant indirect effects of fossil fuels that deserves further analysis, but is not being weighed by the EPA. Apart from all the flaws with the science, it is unfair to penalize American biofuels producers and farmers for land use decisions in other countries that they have no control over.

We're keeping our eye on the policies being developed inside the Beltway because they will have such a profound effect on our industry. We should support including the direct, measurable effects of biofuels in GHG calculations, including direct land use change. But as far as indirect effects go, the science clearly isn't ready for primetime.

Take advantage of the fact that your member of Congress will be home this month and tell your representative that the indirect land use change component of the Energy Independence and Security Act of 2007 needs to be repealed. Let's let America's ethanol producers lead the way in providing an alternative to foreign oil by increasing our national security, keeping jobs and money here at home, and protecting our environment.

Tom Buis is the CEO of Growth Energy. Reach him at TBuis@GrowthEnergy.org or (402) 932-0567.

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