In comments submitted Wednesday to the California Air Resources Board, the Renewable Fuels Association continued to raise concerns regarding the indirect land use change (ILUC) analysis used for the state’s Low Carbon Fuels Standard. The comments were submitted in response to the release of final reports from the LCFS Expert Workgroup that was assembled to assist CARB in improving its ILUC analysis.

“While we continue to have concerns with the selective application of indirect greenhouse gas emissions penalties only to crop-based biofuels in the LCFS, RFA strongly agrees with CARB’s decision to adopt a new and improved modeling framework from Purdue,” said RFA Vice President of Research Geoff Cooper. The results of Purdue’s recent analysis reduce the ILUC penalty for corn ethanol from CARB’s current value of 30 grams/megajoule (g/MJ) to approximately 14 g/MJ. RFA urged CARB to consider the new Purdue work immediately after it was published in April 2010.

However, Cooper cautioned that “…while the new Purdue model is a major improvement over the version used by CARB for the LCFS, we believe a number of key enhancements are still needed before the model can be reasonably used for regulatory purposes.”

In general, the RFA agreed with many of the recommendations provided by the appointed experts on the workgroup to improve CARB’s ILUC analysis. “Overall, RFA believes the [workgroup] process was useful and advanced the understanding of the challenges associated with modeling ILUC,” according to RFA’s comments. “The subgroup reports are helpful in identifying and discussing a number of areas in CARB’s analysis that require improvement and/or modification. As described in these comments, we believe much work remains to be done to further improve and enhance the ILUC methodology used by CARB for the LCFS.”

Additionally, the RFA is calling upon CARB to conduct a workshop in the spring to inform stakeholders of its plans to incorporate the recommendations it has received from the expert workgroup. RFA’s complete comments can be read here.