WASHINGTON — The Renewable Fuels Association (RFA) has submitted comments to the California Air Resources Board (CARB) pertinent to CARB’s draft indirect land use change (ILUC) analysis.
Geoff Cooper, RFA’s senior vice president, notes in his submission that RFA is greatly concerned by many aspects of the draft.
Cooper writes, “….several of the assumptions and methodological approaches chosen for CARB’s draft analysis run counter to the recommendations of the Expert Work Group (EWG). In particular, the values selected by CARB for key GTAP elasticities are in conflict with values recommended by EWG and well-known agricultural economists. More generally, CARB’s draft analysis lacks sufficient justification for certain judgment calls made by staff with regard to important model parameters.
“… the results of CARB’s draft analysis are in conflict with the results of recent independent ILUC studies. As described in a recent letter to CARB Chair Mary Nichols from 14 scientists and researchers (including CARB-appointed Expert Work Group members), the corn ethanol ILUC results from CARB’s draft analysis are significantly higher than estimates from recent peer-reviewed scientific analyses…. We believe CARB should explain and justify the divergence of its draft results with estimates from other recent studies.”
RFA’s comments contain thorough technical analysis and recommendations related to key modeling parameters in CARB’s analysis, such as crop yield elasticities and emissions factors, which would help CARB bring the current draft up to speed with current ILUC science.
Price yield elasticity is perhaps the single more important factor for CARB to correct in its draft. Not only does CARB ignore the recommendations of its own expert working group, its range “is inconsistent with recently estimated long-run elasticity values from the literature, confuses short-term versus long-term responses, and ignores the effect of double-cropping. Additionally, CARB appears to misrepresent the results from some price-yield elasticity studies.”
RFA believes “a range of 0.14-0.53 is scientifically justified, properly recognizes that the price-yield effect occurs primarily over the medium or long term, and appropriately incorporates the effect of double-cropping.”
Read the RFA Comment Letter in full here.