(April 28, 2010)  Washington – A recently completed state-of-the-art analysis from Purdue University concludes that the California Air Resources Board (ARB) overestimated the indirect land use change (ILUC) impact of grain-based ethanol by a factor of two in developing its Low Carbon Fuels Standard (LCFS) one year ago.

In a letter sent today to ARB Chair Mary Nichols, the Renewable Fuels Association pointed out this dramatic conclusion and reminded ARB of its promise to review and incorporate new science as it becomes available. In the letter, RFA President Bob Dinneen wrote:

“New research conducted and published by Purdue University using the Global Trade Analysis Project model (GTAP) concludes that land use change emissions potentially associated with corn ethanol expansion are likely less than half of the level estimated by the California Air Resources Board (ARB) staff for the LCFS. While we continue to have grave concerns about including highly uncertain and prescriptive indirect emissions penalties in the LCFS (for instance, we do not believe ARB has the authority to account for ILUC consistent with the Commerce Clause of the U.S. Constitution), we write to point out the new Purdue findings because we believe ARB has committed itself to consider and respond to critical developments like these.”

The research was conducted by the same department and many of the same researchers at Purdue University that conducted extensive ILUC modeling under contract to ARB for the LCFS regulation. The GTAP model used by Purdue was deemed by ARB to be the most accurate and was the basis for the LCFS. In finalizing this regulation, ARB committed to reviewing and incorporating new science.

Indeed, ARB has stated, “…the GTAP is the best available tool for estimating the global land use change impacts associated with expanded biofuel production. When and if the Board is made aware of a better estimation tool, it can direct staff to utilize that tool (emphasis added).”

“We believe that the Board, given its commitments, must direct the staff to adopt the new Purdue results and use the new, improved GTAP model from this point forward until such time that even better tools are available,” wrote Dinneen. “Because regulated parties under the LCFS will imminently be making decisions about 2011 fuel purchases and related logistics, the Purdue ILUC value should be adopted in the LCFS look-up table immediately so that regulated parties have the certainty they need to make purchasing and logistical decisions for the upcoming 2011 LCFS compliance cycle.”

Such overestimations by ARB staff are not unique to the LCFS. Just last week at its April Board meeting, ARB staff acknowledged that its previous estimates of off-road diesel emissions related to the off-highway diesel rule were “too high.” New analyses from third parties and ARB itself showed the original off-road emissions inventory may have been overestimated by ARB by 140-400%.

“Time is of the essence,” Dinneen wrote. “Adopting the Purdue ILUC value immediately would greatly enhance the ability of regulated parties to meet their greenhouse gas reduction obligations in the early years of the LCFS, ultimately minimizing fuel cost impacts to the state’s consumers.”

The new Purdue research also reflects the scientific community’s rejection of the initial paper that brought the ILUC issue to the front burner in February 2008. Since then, the estimated emissions purportedly occurring from ILUC penalty have fallen by nearly 90%.