Indirect land use change impacts of biofuels

The indirect land use change impacts of biofuels, also known as ILUC, relates to the unintended consequence of releasing more carbon emissions due to land-use changes

Land Use, Land-Use Change and Forestry

Land use, land-use change and forestry is defined by the United Nations Climate Change Secretariat as "A greenhouse gas inventory sector that covers emissions and removals of greenhouse gases resulting from direct human-induced land use, land-use change and forestry activities."LULUCF has impacts...

around the world induced by the expansion of croplands for ethanol

Ethanol fuel

Ethanol fuel is ethanol , the same type of alcohol found in alcoholic beverages. It is most often used as a motor fuel, mainly as a biofuel additive for gasoline. World ethanol production for transport fuel tripled between 2000 and 2007 from 17 billion to more than 52 billion litres...

or biodiesel

Biodiesel

Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol....

production in response to the increased global demand for biofuels.

As farmers worldwide respond to higher crop prices in order to maintain the global food supply-and-demand balance, pristine lands are cleared to replace the food crops that were diverted elsewhere to biofuels production. Because natural lands, such as rainforest

Rainforest

Rainforests are forests characterized by high rainfall, with definitions based on a minimum normal annual rainfall of 1750-2000 mm...

s and grassland

Grassland

Grasslands are areas where the vegetation is dominated by grasses and other herbaceous plants . However, sedge and rush families can also be found. Grasslands occur naturally on all continents except Antarctica...

s, store carbon in their soil and biomass as plants grow each year, clearance of wilderness for new farms translates to a net increase in greenhouse gas emissions. Due to this change in the carbon stock of the soil and the biomass, indirect land use change has consequences in the GHG balance of a biofuel.

Other authors have also argued that indirect land use changes produce other significant social and environmental impacts, affecting biodiversity, water quality, food prices and supply, land tenure

Land tenure

Land tenure is the name given, particularly in common law systems, to the legal regime in which land is owned by an individual, who is said to "hold" the land . The sovereign monarch, known as The Crown, held land in its own right. All private owners are either its tenants or sub-tenants...

, worker migration, and community and cultural stability.

History

The estimates of carbon intensity for a given biofuel depend on the assumptions regarding several variables. As of 2008, multiple full life cycle

Life cycle assessment

A life-cycle assessment is a technique to assess environmental impacts associated with all the stages of a product's life from-cradle-to-grave A life-cycle assessment (LCA, also known as life-cycle analysis, ecobalance, and cradle-to-grave analysis) is a technique to assess environmental impacts...

studies had found that corn ethanol

Ethanol fuel in the United States

The United States became the world's largest producer of ethanol fuel in 2005. The U.S. produced 13.2 billion U.S. liquid gallons of ethanol fuel in 2010, and together with Brazil, accounted for 88% of that year's global production...

, cellulosic ethanol

Cellulosic ethanol

Cellulosic ethanol is a biofuel produced from wood, grasses, or the non-edible parts of plants.It is a type of biofuel produced from lignocellulose, a structural material that comprises much of the mass of plants. Lignocellulose is composed mainly of cellulose, hemicellulose and lignin...

and Brazilian sugarcane ethanol

Ethanol fuel in Brazil

Brazil is the world's second largest producer of ethanol fuel and the world's largest exporter. Together, Brazil and the United States lead the industrial production of ethanol fuel, accounting together for 87.8% of the world's production in 2010. In 2010 Brazil produced 26.2 billion litres Brazil...

produce lower greenhouse gas emissions than gasoline

Gasoline

Gasoline , or petrol , is a toxic, translucent, petroleum-derived liquid that is primarily used as a fuel in internal combustion engines. It consists mostly of organic compounds obtained by the fractional distillation of petroleum, enhanced with a variety of additives. Some gasolines also contain...

. None of these studies, however, considered the effects of indirect land-use changes, and though land use impacts were acknowledged, estimation was considered too complex and difficult to model. A controversial paper published in February 2008 in Sciencexpress

Science (journal)

Science is the academic journal of the American Association for the Advancement of Science and is one of the world's top scientific journals....

by a team led by Searchinger from Princeton University

Princeton University

Princeton University is a private research university located in Princeton, New Jersey, United States. The school is one of the eight universities of the Ivy League, and is one of the nine Colonial Colleges founded before the American Revolution....

concluded that such effects offset the (positive) direct effects of both corn and cellulosic ethanol and that Brazilian sugarcane performed better, but still resulted in a small carbon debt.

After the Searchinger team paper, estimation of carbon emissions from ILUC, together with the food vs. fuel debate, became one of the most contentious issues relating to biofuels

Issues relating to biofuels

There are various social, economic, environmental and technical issues with biofuel production and use, which have been discussed in the popular media and scientific journals...

, debated in the popular media

Mass media

Mass media refers collectively to all media technologies which are intended to reach a large audience via mass communication. Broadcast media transmit their information electronically and comprise of television, film and radio, movies, CDs, DVDs and some other gadgets like cameras or video consoles...

, scientific journal

Scientific journal

In academic publishing, a scientific journal is a periodical publication intended to further the progress of science, usually by reporting new research. There are thousands of scientific journals in publication, and many more have been published at various points in the past...

s, op-ed

Op-ed

An op-ed, abbreviated from opposite the editorial page , is a newspaper article that expresses the opinions of a named writer who is usually unaffiliated with the newspaper's editorial board...

s and public letters from the scientific community

Scientific community

The scientific community consists of the total body of scientists, its relationships and interactions. It is normally divided into "sub-communities" each working on a particular field within science. Objectivity is expected to be achieved by the scientific method...

, and the ethanol industry, both American and [Brazilian. This controversy intensified in April 2009 when the California Air Resources Board

California Air Resources Board

The California Air Resources Board, also known as CARB or ARB, is the "clean air agency" in the government of California. Established in 1967 in the Mulford-Carrell Act, combining the Bureau of Air Sanitation and the Motor Vehicle Pollution Control Board, CARB is a department within the...

(CARB) set rules that included ILUC impacts to establish the California Low-Carbon Fuel Standard that entered into force in 2011.

In May 2009 U.S. Environmental Protection Agency

United States Environmental Protection Agency

The U.S. Environmental Protection Agency is an agency of the federal government of the United States charged with protecting human health and the environment, by writing and enforcing regulations based on laws passed by Congress...

(EPA) released a notice of proposed rulemaking

Notice of proposed rulemaking

A notice of proposed rulemaking is a public notice issued by law when one of the independent agencies of the United States government wishes to add, remove, or change a rule or regulation as part of the rulemaking process. It is an important part of United States administrative law which...

for implementation of the 2007 modification of the Renewable Fuel Standard (RFS). EPA's proposed regulations also included ILUC, causing additional controversy among ethanol producers. EPA's February 3, 2010 final rule incorporated ILUC based on modelling that was significantly improved over the initial estimates.

The UK Renewable Transport Fuel Obligation

Renewable Transport Fuel Obligation

The Renewable Transport Fuel Obligation in the United Kingdom is a requirement on transport fuel suppliers to ensure that 5 percent of all road vehicle fuel is supplied is from sustainable renewable sources by 2010...

program requires the Renewable Fuels Agency

Renewable Fuels Agency

The Renewable Fuels Agency was a UK Government non-departmental public body, created by the Department for Transport to implement the Renewable Transport Fuel Obligation or RTFO. The Agency ceased to exist at midnight on the 31st March 2011...

(RFA) to report potential indirect impacts of biofuel production, including indirect land use change or changes to food and other commodity prices. A July 2008 RFA study, known as the Gallager Review, found several risks and uncertainties, and that the "quantification of GHG emissions from indirect land-use change requires subjective assumptions and contains considerable uncertainty", and required further examination to properly incorporate indirect effects into calculation methodologies. A similarly cautious approach was followed by the European Union

European Union

The European Union is an economic and political union of 27 independent member states which are located primarily in Europe. The EU traces its origins from the European Coal and Steel Community and the European Economic Community , formed by six countries in 1958...

. In December 2008 the European Parliament

European Parliament

The European Parliament is the directly elected parliamentary institution of the European Union . Together with the Council of the European Union and the Commission, it exercises the legislative function of the EU and it has been described as one of the most powerful legislatures in the world...

adopted more stringent sustainability criteria for biofuels and directed the European Commission

European Commission

The European Commission is the executive body of the European Union. The body is responsible for proposing legislation, implementing decisions, upholding the Union's treaties and the general day-to-day running of the Union....

to develop a methodology to factor in GHG emissions from indirect land use change.

Studies and controversy

Before 2008, several full life cycle

Life cycle assessment

("Well to Wheels" or WTW) studies had found that corn ethanol

Ethanol fuel in the United States

reduced transport-related greenhouse gas emissions. In 2007 a University of California, Berkeley

University of California, Berkeley

The University of California, Berkeley , is a teaching and research university established in 1868 and located in Berkeley, California, USA...

team led by Farrel evaluated six previous studies, concluding that corn ethanol reduced GHG emissions by only 13 percent. However, 20 to 30 percent reduction for corn ethanol, and 85 to 85 percent for cellulosic ethanol

Cellulosic ethanol

, both figures estimated by Wang from Argonne National Laboratory

Argonne National Laboratory

Argonne National Laboratory is the first science and engineering research national laboratory in the United States, receiving this designation on July 1, 1946. It is the largest national laboratory by size and scope in the Midwest...

, are more commonly cited. Wang reviewed 22 studies conducted between 1979 and 2005, and ran simulations with Argonne's GREET model

GREET Model

GREET is a full life-cycle model sponsored by the Argonne National Laboratory...

. These studies accounted for direct land use changes. Several studies of Brazilian sugarcane ethanol showed that sugarcane as feedstock reduces GHG by 86 to 90 percent given no significant land use change. Estimates of carbon intensity depend on crop productivity, agricultural practices, power sources for ethanol distilleries and the energy efficiency of the distillery. None of these studies considered ILUC, due to estimation difficulties. Preliminary estimates by Delucchi from the University of California, Davis

University of California, Davis

The University of California, Davis is a public teaching and research university established in 1905 and located in Davis, California, USA. Spanning over , the campus is the largest within the University of California system and third largest by enrollment...

, suggested that carbon released by new lands converted to agricultural use was a large percentage of life-cycle emissions.

Searchinger and Fargione studies

In February 2008 Searchinger concluded that ILUC affects the life cycle assessment

Life cycle assessment

and that instead of saving, both corn and cellulosic ethanol increased carbon emissions as compared to gasoline by 93 and 50 percent respectively. Ethanol from Brazilian sugarcane performed better, recovering initial carbon emissions in 4 years, while U.S. corn ethanol required 167 years and cellulosic ethanol required a 52 years payback period. The study limited the analysis a 30 year period, assuming that land conversion emits 25 percent of the carbon stored in soils and all carbon in plants cleared for cultivation. Brazil, China

China

Chinese civilization may refer to:* China for more general discussion of the country.* Chinese culture* Greater China, the transnational community of ethnic Chinese.* History of China* Sinosphere, the area historically affected by Chinese culture...

, and India

India

India , officially the Republic of India , is a country in South Asia. It is the seventh-largest country by geographical area, the second-most populous country with over 1.2 billion people, and the most populous democracy in the world...

were considered among the overseas locations where land use change would occur as a result of diverting U.S. corn cropland, and it was assumed that new cropland in each of these regions correspond to different types of forest

Forest

A forest, also referred to as a wood or the woods, is an area with a high density of trees. As with cities, depending where you are in the world, what is considered a forest may vary significantly in size and have various classification according to how and what of the forest is composed...

, savanna

Savanna

A savanna, or savannah, is a grassland ecosystem characterized by the trees being sufficiently small or widely spaced so that the canopy does not close. The open canopy allows sufficient light to reach the ground to support an unbroken herbaceous layer consisting primarily of C4 grasses.Some...

or grassland

Grassland

based on the historical proportion of each converted to cultivation in these countries during the 1990s.

Summary of Searchinger et al. comparison of corn ethanol and gasoline GHG GHG GHG can be an abbreviation for:* Greenhouse gas* George H. Goble, inventor of multi-CPU Unix systems, refrigerants, and winner of the 1996 Ig Nobel Prize in Chemistry.* Marshfield Municipal Airport in Marshfield, Massachusetts.... emissions with and without land use change (Gram Gram The gram is a metric system unit of mass.... s of CO₂ Carbon dioxide equivalent Carbon dioxide equivalent and Equivalent carbon dioxide are two related but distinct measures for describing how much global warming a given type and amount of greenhouse gas may cause, using the functionally equivalent amount or concentration of carbon dioxide as the reference.- Global warming... released per megajoule of energy in fuel)
Fuel type (U.S.)	Carbon intensity	Reduction GHG	Carbon intensity + ILUC	Reduction GHG
Gasoline	92	-	92	-
Corn ethanol	74	-20%	177	+93%
Cellulosic ethanol	28	-70%	138	+50%
Notes: Calculated using default assumptions for 2015 scenario for ethanol in E85. Gasoline is a combination of conventional and reformulated gasoline.

Fargione and his team published a separate paper in the same issue of Sciencexpress claiming that clearing lands to produce biofuel feedstock created a carbon deficit. This deficit applies to both direct and indirect land use changes. The study examined six conversion scenarios: Brazil

Brazil

Brazil , officially the Federative Republic of Brazil , is the largest country in South America. It is the world's fifth largest country, both by geographical area and by population with over 192 million people...

ian Amazon

Amazon Rainforest

The Amazon Rainforest , also known in English as Amazonia or the Amazon Jungle, is a moist broadleaf forest that covers most of the Amazon Basin of South America...

to soybean

Soybean

The soybean or soya bean is a species of legume native to East Asia, widely grown for its edible bean which has numerous uses...

biodiesel

Biodiesel

Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol....

, Brazilian Cerrado

Cerrado

The Cerrado, is a vast tropical savanna ecoregion of Brazil, particularly in the states of Gioas and Minas Gerais...

to soybean biodiesel, Brazilian Cerrado to sugarcane ethanol, Indonesia

Indonesia

Indonesia , officially the Republic of Indonesia , is a country in Southeast Asia and Oceania. Indonesia is an archipelago comprising approximately 13,000 islands. It has 33 provinces with over 238 million people, and is the world's fourth most populous country. Indonesia is a republic, with an...

n or Malaysian lowland tropical rainforest

Tropical rainforest

A tropical rainforest is an ecosystem type that occurs roughly within the latitudes 28 degrees north or south of the equator . This ecosystem experiences high average temperatures and a significant amount of rainfall...

to palm

Oil palm

The oil palms comprise two species of the Arecaceae, or palm family. They are used in commercial agriculture in the production of palm oil. The African Oil Palm Elaeis guineensis is native to West Africa, occurring between Angola and Gambia, while the American Oil Palm Elaeis oleifera is native to...

biodiesel, Indonesian or Malaysian peatland tropical rainforest to palm biodiesel, and U.S. Central grassland

Grassland

to corn ethanol. The carbon debt was defined as the amount of released during the first 50 years of this process of land conversion. For the two most common ethanol feedstocks, the study found that sugarcane ethanol produced on natural cerrado lands would take ~17 years to repay its carbon debt, while corn ethanol produced on U.S. central grasslands would result in a repayment time of ~93 years. The worst-case scenario is converting Indonesian or Malaysian tropical peatland rainforest to palm biodiesel production, which would require ~420 years to repay.

Criticism and controversy

The Searchinger and Fargione studies created controversy in both the popular media

Mass media

and in scientific journal

Scientific journal

s. Wang and Haq from Argonne National Laboratory claiming: the assumptions were outdated; they ignored the potential of increased efficiency; and no evidence showed that "U.S. corn ethanol production has so far caused indirect land use in other countries." They concluded that Searchinger demonstrated that ILUC "is much more difficult to model than direct land use changes". In his response Searchinger rebutted each technical objection and asserted that "... any calculation that ignores these emissions, however challenging it is to predict them with certainty, is too incomplete to provide a basis for policy decisions."

Another criticism, by Kline and Dale from Oak Ridge National Laboratory

Oak Ridge National Laboratory

Oak Ridge National Laboratory is a multiprogram science and technology national laboratory managed for the United States Department of Energy by UT-Battelle. ORNL is the DOE's largest science and energy laboratory. ORNL is located in Oak Ridge, Tennessee, near Knoxville...

, held that Searchinger et al. and Fargione et al. "... do not provide adequate support for their claim that bioufuels cause high emissions due to land-use change", as their conclusions depends on a misleading because more comprehensive field research found that these land use changes "... are driven by interactions among cultural, technological, biophysical, economic, and demographic forces within a spational and temporal contest rather than by a single crop market". Fargione et al. responded in part that although many factors contributed to land clearing, this "observation does not diminish the fact that biofuels also contribute to land clearing if they are produced on existing cropland or on newly cleared lands". Searching disagreed with all of Kline and Dale arguments.

The U.S. biofuel industry also reacted, claiming that the "Searchinger study is clearly a 'worst case scenario' analysis ..." and that this study "relies on a long series of highly subjective assumptions ..." Searchinger rebutted each claim, concluding that NFA's criticisms were invalid. He noted that even if some of his assumptions are high estimates, the study also made many conservative assumptions.

Brazil

In February 2010 Lapola estimated that planned expansion of Brazilian sugarcane and soybean biofuel plantations through 2020 would replace rangeland

Rangeland

Rangelands are vast natural landscapes in the form of grasslands, shrublands, woodlands, wetlands, and deserts. Types of rangelands include tallgrass and shortgrass prairies, desert grasslands and shrublands, woodlands, savannas, chaparrals, steppes, and tundras...

, with small direct land-use impact on carbon emissions. However, the expansion of the rangeland frontier into Amazonian forests, driven by cattle ranching would indirectly offset the savings. "Sugarcane ethanol and soybean biodiesel each contribute to nearly half of the projected indirect deforestation of 121,970 km² by 2020, creating a carbon debt that would take about 250 years to be repaid...."

The research also found that oil palm

Oil palm

would cause the least land-use changes and associated carbon debt. The analysis also modeled livestock density increases and found that "a higher increase of 0.13 head per hectare in the average livestock density throughout the country could avoid the indirect land-use changes caused by biofuels (even with soybean as the biodiesel feedstock), while still fulfilling all food and bioenergy demands." The authors conclude that intensification of cattle ranching and concentration on oil palm are required to achieve effective carbon savings, recommending closer collaboration between the biofuel and cattle-ranching sectors.

The main Brazilian ethanol industry organization

UNICA, Brazil

UNICA , the Brazilian Sugarcane Industry Association, is a lobbying organization of producers of sugarcane and ethanol fuel. UNICA members are responsible for more than 50% of all ethanol produced in Brazil and 60% of overall sugar production....

(UNICA) commented that such studies missed the continuing intensification of cattle production already underway.

California LCFS

California carbon intensity values for gasoline, diesel and fuels that substitute them (gram Gram The gram is a metric system unit of mass.... s of CO₂ equivalent Carbon dioxide equivalent Carbon dioxide equivalent and Equivalent carbon dioxide are two related but distinct measures for describing how much global warming a given type and amount of greenhouse gas may cause, using the functionally equivalent amount or concentration of carbon dioxide as the reference.- Global warming... released per MJ of energy produced)
Fuel type	Carbon intensity	Carbon intensity + land-use changes	Intensity change respect to 2011 LCFS
Midwest corn ethanol Ethanol fuel in the United States The United States became the world's largest producer of ethanol fuel in 2005. The U.S. produced 13.2 billion U.S. liquid gallons of ethanol fuel in 2010, and together with Brazil, accounted for 88% of that year's global production...	75.10	105.10	+10%
California gasoline Gasoline Gasoline , or petrol , is a toxic, translucent, petroleum-derived liquid that is primarily used as a fuel in internal combustion engines. It consists mostly of organic compounds obtained by the fractional distillation of petroleum, enhanced with a variety of additives. Some gasolines also contain...	95.86	95.86	+0.2%
CARB LCFS 2011 for gasoline	-	95.61	-
California diesel (ULSD Ultra-low sulfur diesel Ultra-low-sulfur diesel is a term used to describe diesel fuel with substantially lowered sulfur content... )	94.71	94.71	+0.2%
CARB LCFS 2011 for diesel	-	94.47	-
California ethanol	50.70	80.70	-16%
Brazilian sugarcane ethanol Ethanol fuel in Brazil Brazil is the world's second largest producer of ethanol fuel and the world's largest exporter. Together, Brazil and the United States lead the industrial production of ethanol fuel, accounting together for 87.8% of the world's production in 2010. In 2010 Brazil produced 26.2 billion litres Brazil...	27.40	73.40	-23%
Biodiesel Biodiesel Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol.... (B100) Midwest soybeans⁽¹⁾	26.93	68.93	-27%
Renewable diesel Midwest soybean Soybean The soybean or soya bean is a species of legume native to East Asia, widely grown for its edible bean which has numerous uses... s⁽¹⁾	28.80	68.93	-27%
Cellulosic ethanol Cellulosic ethanol Cellulosic ethanol is a biofuel produced from wood, grasses, or the non-edible parts of plants.It is a type of biofuel produced from lignocellulose, a structural material that comprises much of the mass of plants. Lignocellulose is composed mainly of cellulose, hemicellulose and lignin... (farmed trees Tree farm A tree farm is a privately owned forest managed for timber production. The term tree farm is also used to refer to plantations and to tree nurseries.-American Tree Farm System:... )⁽¹⁾	2.40	20.40	-79%
Compressed natural gas Compressed natural gas Compressed natural gas is a fossil fuel substitute for gasoline , diesel, or propane/LPG. Although its combustion does produce greenhouse gases, it is a more environmentally clean alternative to those fuels, and it is much safer than other fuels in the event of a spill... (bio-methane)	11.26	11.26	-88%
Note: the complete lifecycle analysis for these fuels and others evaluated are available at CARB's website (see Lifecycle Analysis). (1) Preliminary values of fuels not included in the 2009 LCFS ruling and subject to refining.

On April 23, 2009, California Air Resources Board

California Air Resources Board

(CARB) approved the specific rules and carbon intensity reference values for the California Low-Carbon Fuel Standard (LCFS) that take effect January 1, 2011. CARB's rulemaking included ILUC. For some biofuels, CARB identified land use changes as a significant source of additional GHG emissions. It established one standard for gasoline and alternative fuels, and a second for diesel fuel and its replacements.

Controversy

The public consultation process before the ruling, and the ruling itself were controversial, yielding 229 comments. ILUC was one of the most contentious issues. On June 24, 2008, 27 scientists and researchers submitted a letter saying, "As researchers and scientists in the field of biomass to biofuel conversion, we are convinced that there simply is not enough hard empirical data to base any sound policy regulation in regards to the indirect impacts of renewable biofuels production. The field is relative new, especially when compared to the vast knowledge base present in fossil fuel production, and the limited analyses are driven by assumptions that sometimes lack robust empirical validation." The New Fuels Alliance, representing more than two-dozen biofuel companies, researchers and investors, questioned the Board intention to include indirect land use change effects into account, wrote "While it is likely true that zero is not the right number for the indirect effects of any product in the real world, enforcing indirect effects in a piecemeal way could have very serious consequences for the LCFS.... The argument that zero is not the right number does not justify enforcing a different wrong number, or penalizing one fuel for one category of indirect effects while giving another fuel pathway a free pass."

On the other side, more than 170 scientists and economists urged that CARB, "include indirect land use change in the lifecycle analyses of heat-trapping emissions from biofuels and other transportation fuels. This policy will encourage development of sustainable, low-carbon fuels that avoid conflict with food and minimize harmful environmental impacts.... There are uncertainties inherent in estimating the magnitude of indirect land use emissions from biofuels, but assigning a value of zero is clearly not supported by the science."
Industry representatives complained that the final rule overstated the environmental effects of corn ethanol, and also criticized the inclusion of ILUC as an unfair penalty to domestic corn ethanol because deforestation in the developing world was being tied to U.S. ethanol production. The 2011 limit for LCFS means that Mid-west corn ethanol failed, unless current carbon intensity was reduced. Oil industry representatives complained that the standard left oil refiners with few options, such as Brazilian sugarcane ethanol, with its accompanying tariff. CARB officials and environmentalists counter that time and economic incentives will allow produces to adapt.

UNICA welcomed the ruling, while urging CARB to better reflect Brazilian practices, lowering their estimates of Brazilian emissions.

The only Board member who voted against the ruling explained that he had a "hard time accepting the fact that we're going to ignore the comments of 125 scientists", referring to the letter submitted by a group of scientists questioning the ILUC penalty. "They said the model was not good enough ... to use at this time as a component part of such an historic new standard." CARB advanced the expected date for an expert working group to report on ILUC with refined estimates from January 2012 to January 2011.

On December 2009 the Renewable Fuels Association

Renewable Fuels Association

The Renewable Fuels Association is an American lobbying organization which promotes policies, regulations, and research and development initiatives that will lead to the increased production and use of ethanol fuel...

(RFA) and Growth Energy, two U.S. ethanol lobbying groups, filed a lawsuit challenging LCFS' constitutionality

Constitutionality

Constitutionality is the condition of acting in accordance with an applicable constitution. Acts that are not in accordance with the rules laid down in the constitution are deemed to be ultra vires.-See also:*ultra vires*Company law*Constitutional law...

. The two organizations argued that LCFS violated both the Supremacy Clause

Supremacy Clause

Article VI, Clause 2 of the United States Constitution, known as the Supremacy Clause, establishes the U.S. Constitution, U.S. Treaties, and Federal Statutes as "the supreme law of the land." The text decrees these to be the highest form of law in the U.S...

and the Commerce Clause

Commerce Clause

The Commerce Clause is an enumerated power listed in the United States Constitution . The clause states that the United States Congress shall have power "To regulate Commerce with foreign Nations, and among the several States, and with the Indian Tribes." Courts and commentators have tended to...

, jeopardizing the nationwide ethanol market.

EPA Renewable Fuel Standard

U.S. Environmental Protection Agency Draft life cycle Life cycle assessment A life-cycle assessment is a technique to assess environmental impacts associated with all the stages of a product's life from-cradle-to-grave A life-cycle assessment (LCA, also known as life-cycle analysis, ecobalance, and cradle-to-grave analysis) is a technique to assess environmental impacts... GHG emissions reduction results for different time horizon Time horizon A time horizon, also known as a planning horizon, is a fixed point of time in the future at which point certain processes will be evaluated or assumed to end. It is necessary in an accounting, finance or risk management regime to assign such a fixed horizon time so that alternatives can be... and discount rate approaches (includes indirect land use change effects)
Fuel Pathway	100 years + 2% discount rate	30 years + 0% discount rate
Corn ethanol Ethanol fuel in the United States The United States became the world's largest producer of ethanol fuel in 2005. The U.S. produced 13.2 billion U.S. liquid gallons of ethanol fuel in 2010, and together with Brazil, accounted for 88% of that year's global production... (natural gas Natural gas Natural gas is a naturally occurring gas mixture consisting primarily of methane, typically with 0–20% higher hydrocarbons . It is found associated with other hydrocarbon fuel, in coal beds, as methane clathrates, and is an important fuel source and a major feedstock for fertilizers.Most natural... dry mill)⁽¹⁾	-16%	+5%
Corn ethanol (Best case NG DM)⁽²⁾	-39%	-18%
Corn ethanol (coal Coal Coal is a combustible black or brownish-black sedimentary rock usually occurring in rock strata in layers or veins called coal beds or coal seams. The harder forms, such as anthracite coal, can be regarded as metamorphic rock because of later exposure to elevated temperature and pressure... dry mill)	+13%	+34%
Corn ethanol (biomass Biomass Biomass, as a renewable energy source, is biological material from living, or recently living organisms. As an energy source, biomass can either be used directly, or converted into other energy products such as biofuel.... dry mill)	-39%	-18%
Corn ethanol (biomass dry mill with combined heat and power)	-47%	-26%
Soybean Soybean The soybean or soya bean is a species of legume native to East Asia, widely grown for its edible bean which has numerous uses... -based biodiesel Biodiesel Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol....	-22%	+4%
Waste grease biodiesel	-80%	-80%
Sugarcane ethanol Ethanol fuel in Brazil Brazil is the world's second largest producer of ethanol fuel and the world's largest exporter. Together, Brazil and the United States lead the industrial production of ethanol fuel, accounting together for 87.8% of the world's production in 2010. In 2010 Brazil produced 26.2 billion litres Brazil...	-44%	-26%
Cellulosic ethanol Cellulosic ethanol Cellulosic ethanol is a biofuel produced from wood, grasses, or the non-edible parts of plants.It is a type of biofuel produced from lignocellulose, a structural material that comprises much of the mass of plants. Lignocellulose is composed mainly of cellulose, hemicellulose and lignin... from switchgrass Switchgrass Panicum virgatum, commonly known as switchgrass, is a perennial warm season bunchgrass native to North America, where it occurs naturally from 55°N latitude in Canada southwards into the United States and Mexico...	-128%	-124%
Cellulosic ethanol from corn stover Corn stover Corn stover consists of the leaves and stalks of maize plants left in a field after harvest and consists of the residue: stalk; the leaf, husk, and cob remaining in the field following the harvest of cereal grain.” Stover makes up about half of the yield of a crop and is similar to straw...	-115%	-116%
Notes: (1) Dry mill (DM) plants grind the entire kernel and generally produce only one primary co-product: distillers grains with solubles (DGS). (2) Best case plants produce wet distillers grains co-product.

The Energy Independence and Security Act of 2007

Energy Independence and Security Act of 2007

The Energy Independence and Security Act of 2007 is an Act of Congress concerning the energy policy of the United States...

(EISA) established new renewable fuel categories and eligibility requirements, setting mandatory lifecycle

Life cycle assessment

emissions limits. EISA explicitly mandated EPA to include "direct emissions and significant indirect emissions such as significant emissions from land use changes."

EISA required a 20% reduction in lifecycle GHG emissions for any fuel produced at facilities that commenced construction after December 19, 2007 to be classified as a "renewable fuel"; a 50% reduction for fuels to be classified as "biomass-based diesel" or "advanced biofuel", and a 60% reduction to be classified as "cellulosic biofuel". EISA provided limited flexibility to adjust these thresholds downward by up to 10 percent, and EPA proposed this adjustment for the advanced biofuels category. Existing plants were grandfathered

Grandfather clause

Grandfather clause is a legal term used to describe a situation in which an old rule continues to apply to some existing situations, while a new rule will apply to all future situations. It is often used as a verb: to grandfather means to grant such an exemption...

in.

On May 5, 2009, EPA released a notice of proposed rulemaking

Notice of proposed rulemaking

for implementation of the 2007 modification of the Renewable Fuel Standard, known as RFS2. The draft of the regulations was released for public comment during a 60-day period, a public hearing was held on 9 June 2009, and also a workshop was conducted on 10–11 June 2009.

EPA's draft analysis stated that ILUC can produce significant near-term GHG emissions due to land conversion, but that biofuels can pay these back over subsequent years. EPA highlighted two scenarios, varying the time horizon and the discount rate

Discount rate

The discount rate can mean*an interest rate a central bank charges depository institutions that borrow reserves from it, for example for the use of the Federal Reserve's discount window....

for valuing emissions. The first assumed a 30 year time period uses a 0 percent discount rate (valuing emissions equally regardless of timing). The second scenario used a 100 year time period and a 2% discount rate.

On the same day that EPA published its notice of proposed rulemaking, President Obama signed a Presidential Directive

Presidential directive

Presidential Directives, better known as Presidential Decision Directives or PDD are a form of an executive order issued by the President of the United States with the advice and consent of the National Security Council...

seeking to advance biofuels research and commercialization. The Directive established the Biofuels Interagency Working Group, to develop policy ideas for increasing investment in next-generation fuels and for reducing their environmental footprint.

The inclusion of ILUC in the proposed ruling provoked complaints from ethanol and biodiesel producers. Several environmental organizations welcomed the inclusion of ILUC but criticized the consideration of a 100 year payback scenario, arguing that it underestimated land conversion effects. American corn growers, biodiesel producers, ethanol producers and Brazilian sugarcane ethanol producers complained about EPA's methodology, while the oil industry requested an implementation delay.

On June 26, 2009, the House of Representatives approved the American Clean Energy and Security Act

American Clean Energy and Security Act

The American Clean Energy and Security Act of 2009 was an energy bill in the 111th United States Congress that would have established a variant of an emissions trading plan similar to the European Union Emission Trading Scheme...

219 to 212, mandating EPA to exclude ILUC for a 5-year period, vis a vis RFS2. During this period, more research is to be conducted to develop more reliable models and methodologies for estimating ILUC, and Congress will review this issue before allowing EPA to rule on this matter. The bill failed in the U.S. Senate.

On February 3, 2010, EPA issued its final RFS2 rule for 2010 and beyond. The rule incorporated direct and significant indirect emissions including ILUC. EPA incorporated comments and data from new studies. Using a 30 year time horizon and a 0% discount rate, EPA concluded that multiple biofuels would meet this standard.

EPA's analysis accepted both ethanol produced from corn starch

Ethanol fuel in the United States

and biobutanol

Butanol fuel

Butanol may be used as a fuel in an internal combustion engine. Because its longer hydrocarbon chain causes it to be fairly non-polar, it is more similar to gasoline than it is to ethanol...

from corn starch as "renewable fuels". Ethanol produced from sugarcane

Ethanol fuel in Brazil

became an "advanced fuel". Both diesel produced from algal oils

Green diesel

Green diesel, also known as renewable diesel, is a form of diesel fuel which is derived from renewable feedstock by using biomass to liquid or vegetable oil refining technologies. Based on its feedstock it could be classified as biodiesel; however, based on the processing technology and chemical...

and biodiesel

Biodiesel

Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol....

from soy oil and diesel from waste oils, fats, and greases fell in the "biomass-based diesel" category. Cellulosic ethanol

Cellulosic ethanol

and cellulosic diesel met the "cellulosic biofuel" standard.

The table summarizes the mean GHG emissions estimated by EPA modelling and the range of variations considering that the main source of uncertainty in the life cycle analysis is the GHG emissions related to international land use change.

U.S. Environmental Protection Agency United States Environmental Protection Agency The U.S. Environmental Protection Agency is an agency of the federal government of the United States charged with protecting human health and the environment, by writing and enforcing regulations based on laws passed by Congress... Life cycle Life cycle assessment A life-cycle assessment is a technique to assess environmental impacts associated with all the stages of a product's life from-cradle-to-grave A life-cycle assessment (LCA, also known as life-cycle analysis, ecobalance, and cradle-to-grave analysis) is a technique to assess environmental impacts... Year 2022 GHG emissions reduction results for RFS2 final rule (includes direct and indirect land use change effects and a 30 year pay back period Time horizon A time horizon, also known as a planning horizon, is a fixed point of time in the future at which point certain processes will be evaluated or assumed to end. It is necessary in an accounting, finance or risk management regime to assign such a fixed horizon time so that alternatives can be... at a 0% discount rate Discount rate The discount rate can mean*an interest rate a central bank charges depository institutions that borrow reserves from it, for example for the use of the Federal Reserve's discount window.... )
Renewable fuel Pathway (for U.S. consumption)	Mean GHG emission reduction⁽¹⁾	GHG emission reduction 95% confidence interval⁽²⁾	Assumptions/comments
Corn ethanol Corn ethanol Corn ethanol is ethanol produced from corn as a biomass through industrial fermentation, chemical processing and distillation. Corn is the main feedstock used for producing ethanol fuel in the United States and it is mainly used as an oxygenate to gasoline in the form of low-level blends, and to a...	21%	7–32%	New or expanded natural gas Natural gas Natural gas is a naturally occurring gas mixture consisting primarily of methane, typically with 0–20% higher hydrocarbons . It is found associated with other hydrocarbon fuel, in coal beds, as methane clathrates, and is an important fuel source and a major feedstock for fertilizers.Most natural... fired dry mill plant, 37% wet and 63% dry DGS it produces, and employing corn oil fractionation technology.
Corn biobutanol	31%	20–40%	Natural gas fired dry mill plant, 37% wet and 63% dry DGS it produces, and employing corn oil fractionation technology.
Sugarcane ethanol Ethanol fuel in Brazil Brazil is the world's second largest producer of ethanol fuel and the world's largest exporter. Together, Brazil and the United States lead the industrial production of ethanol fuel, accounting together for 87.8% of the world's production in 2010. In 2010 Brazil produced 26.2 billion litres Brazil... ⁽³⁾	61%	52–71%	Ethanol is produced and dehydrated in Brazil prior to being imported into the U.S. and the residue is not collected. GHG emissions from ocean tankers hauling ethanol from Brazil to the U.S. are included.
Cellulosic ethanol Cellulosic ethanol Cellulosic ethanol is a biofuel produced from wood, grasses, or the non-edible parts of plants.It is a type of biofuel produced from lignocellulose, a structural material that comprises much of the mass of plants. Lignocellulose is composed mainly of cellulose, hemicellulose and lignin... from switchgrass Switchgrass Panicum virgatum, commonly known as switchgrass, is a perennial warm season bunchgrass native to North America, where it occurs naturally from 55°N latitude in Canada southwards into the United States and Mexico...	110%	102–117%	Ethanol produced using the biochemical process.
Cellulosic ethanol from corn stover Corn stover Corn stover consists of the leaves and stalks of maize plants left in a field after harvest and consists of the residue: stalk; the leaf, husk, and cob remaining in the field following the harvest of cereal grain.” Stover makes up about half of the yield of a crop and is similar to straw...	129%	No ILUC	Ethanol produced using the biochemical process. Ethanol produced from agricultural residues does not have any international land use emissions.
Biodiesel Biodiesel Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol.... from soybean Soybean The soybean or soya bean is a species of legume native to East Asia, widely grown for its edible bean which has numerous uses...	57%	22–85%	Plant using natural gas.
Waste grease biodiesel	86%	No ILUC	Waste grease feedstock does not have any agricultural or land use emissions.
Notes: (1) Percent reduction in lifecycle GHG emissions compared to the average lifecycle GHG for gasoline or diesel sold or distributed as transportation fuel in 2005. (2) Confidence range accounts for uncertainty in the types of land use change assumptions and the magnitude of resulting GHG emissions. (3) A new Brazil module was develop to model the impact of increased production of Brazilian sugarcane ethanol for use in the U.S. market and the international impacts of Brazilian sugarcane ethanol production. The Brazil module also accounts for the domestic competition between crop and pasture land uses, and allows for livestock intensification (heads of cattle per unit area of land).

Reactions

UNICA welcomed the ruling, in particular, for the more precise lifecycle emissions estimate and hoped that classification the advanced biofuel designation would help eliminate the tariff.

The U.S. Renewable Fuels Association

Renewable Fuels Association

(RFA) also welcomed the ruling, as ethanol producers "require stable federal policy that provides them the market assurances they need to commercialize new technologies", restating their ILUC objection.

RFA also complained that corn-based ethanol scored only a 21% reduction, noting that without ILUC, corn ethanol achieves a 52% GHG reduction. RFA also objected that Brazilian sugarcane ethanol "benefited disproportionally" because EPA's revisions lowered the initially equal ILUC estimates by half for corn and 93% for sugarcane.

Several Midwestern

Midwestern United States

The Midwestern United States is one of the four U.S. geographic regions defined by the United States Census Bureau, providing an official definition of the American Midwest....

lawmakers commented that they continued to oppose EPA's consideration of the "dicey science" of indirect land use that "punishes domestic fuels". House Agriculture Chairman Collin Peterson

Collin Peterson

Collin Clark Peterson , is the U.S. Representative for , serving since 1991, and the ranking member of the House Agriculture Committee. He is a member of the Democratic-Farmer-Labor Party and is the dean of the Minnesota congressional delegation.The district, Minnesota's largest and most rural...

said, "... to think that we can credibly measure the impact of international indirect land use is completely unrealistic, and I will continue to push for legislation that prevents unreliable methods and unfair standards from burdening the biofuels industry."

EPA Administrator Lisa P. Jackson

Lisa P. Jackson

Lisa Perez Jackson is an American chemical engineer currently serving as the Administrator of the Environmental Protection Agency . Previously, she worked at the New Jersey Department of Environmental Protection for 6 years, first as an assistant commissioner and later as commissioner...

commented that the agency "did not back down from considering land use in its final rules, but the agency took new information into account that led to a more favorable calculation for ethanol". She cited new science and better data on crop yield and productivity, more information on co-products that could be produced from advanced biofuels and expanded land-use data for 160 countries, instead of the 40 considered in the proposed rule.

Europe

As of 2010, European Union and United Kingdom regulators had recognized the need to take ILUC into account, but had not determined the most appropriate methodology.

UK Renewable Transport Fuel Obligation

The UK Renewable Transport Fuel Obligation

Renewable Transport Fuel Obligation

(RTFO) program requires fuel suppliers to report direct impacts, and asked the Renewable Fuels Agency

Renewable Fuels Agency

(RFA) to report potential indirect impacts, including ILUC and commodity price changes. The RFA's July 2008 "Gallager Review", mentioned several risks regarding biofuels and required feedstock production to avoid agricultural land that would otherwise be used for food production, despite concluding that "quantification of GHG emissions from indirect land-use change requires subjective assumptions and contains considerable uncertainty". Some environmental groups argued that emissions from ILUC were not being taken into account and could be creating more emissions.

European Union

On December 17, 2008, the European Parliament

European Parliament

approved the Renewable Energy Sources Directive (COM(2008)19) and amendments to the Fuel Quality Directive (Directive 2009/30), which included sustainability criteria for biofuels and mandated consideration of ILUC. The Directive established a 10% biofuel target. A separate Fuel Quality Directive set the EU's Low Carbon Fuel Standard, requiring a 6% reduction in GHG intensity of EU transport fuels by 2020. The legislation ordered the European Commission

European Commission

to develop a methodology to factor in GHG emissions from ILUC by December 31, 2010, based on the best available scientific evidence.

In the meantime, the European Parliament defined lands that were ineligible for producing biofuel feedstocks for the purpose of the Directives. This category included wetland

Wetland

A wetland is an area of land whose soil is saturated with water either permanently or seasonally. Wetlands are categorised by their characteristic vegetation, which is adapted to these unique soil conditions....

s and continuously forest

Forest

ed areas with canopy cover of more than 30 percent or cover between 10 and 30 percent given evidence that its existing carbon stock was low enough to justify conversion.

The Commission subsequently published terms of reference for three ILUC modeling exercises: one using a General Equilibrium model; one using a Partial Equilibrium model and one comparing other global modeling exercises. It also consulted on a limited range of high-level options for addressing ILUC to which 17 countries and 59 organizations responded. The United Nations Special Rapporteur on the Right to Food and several environmental organizations complained that the 2008 safeguards were inadequate. UNICA called for regulators to establish an empirical and "globally accepted methodology" to consider ILUC, with the participation of researchers and scientists from biofuel crop-producing countries.

In 2010 some NGOs accused the European Commission of lacking transparency given its reluctance to release documents relating to the ILUC work. In March 2010 the Partial and General Equilibrium Modelling results were made available, with the disclaimer that the EC had not adopted the views contained in the materials. These indicate that a 1.25% increase in EU biofuel consumption would require around 5000000 hectares (12,355,258.2 acre) of land globally.

The scenarios for varied from 5.6-8.6% of road transport fuels. The study found that ILUC effects offset part of the emission benefits, and that above the 5.6% threshold, ILUC emissions increase rapidly increase. For the expected scenario of 5.6% by 2020, the study estimated that biodiesel production increases would be mostly domestic, while bioethanol production would take place mainly in Brazil, regardless of EU duties. The analysis concluded that eliminating trade barriers would further reduce emissions, because the EU would import more from Brazil. Under this scenario, "direct emission savings from biofuels are estimated at 18 Mt , additional emissions from ILUC at 5.3 Mt (mostly in Brazil), resulting in a global net balance of nearly 13 Mt savings in a 20 years horizon. The study also found that ILUC emissions were much greater for biodiesel from vegetable oil and estimated that in 2020 even at the 5.6% level were over half the greenhouse gas emissions from diesel.

As part of the announcement, the Commission stated that it would publish a report on ILUC by the end of 2010.

Certification system

On June 10, 2010, the EC announced its decision to set up certification schemes for biofuels, including imports as part of the Renewable Energy Directive. The Commission encouraged E.U. nations, industry and NGOs to set up voluntary certification schemes. EC figures for 2007 showed that 26% of biodiesel

Biodiesel

Biodiesel refers to a vegetable oil- or animal fat-based diesel fuel consisting of long-chain alkyl esters. Biodiesel is typically made by chemically reacting lipids with an alcohol....

and 31% of bioethanol

Ethanol fuel

used in the E.U. was imported, mainly from Brazil

Brazil

and the United States

United States

The United States of America is a federal constitutional republic comprising fifty states and a federal district...

Reactions

UNICA welcomed the EU efforts to "engage independent experts in its assessments" but requested that improvements because "... the report currently contains a certain number of inaccuracies, so once these are corrected, we anticipate even higher benefits resulting from the use of Brazilian sugarcane ethanol." UNICA highlighted the fact that the report assumed land expansion that "does not take into consideration the agro-ecological zoning for sugarcane in Brazil, which prevents cane from expanding into any type of native vegetation."

Critics said the 10% figure was reduced to 5.6% of transport fuels partly by exaggerating the contribution of electric vehicle

Electric vehicle

An electric vehicle , also referred to as an electric drive vehicle, uses one or more electric motors or traction motors for propulsion...

s (EV) in 2020, as the study assumed EVs would represent 20% of new car sales, two and six times the car industry's own estimate. They also claimed the study "exaggerates to around 45 percent the contribution of bioethanol—the greenest of all biofuels—and consequently downplays the worst impacts of biodiesel."

Environmental groups found that the measures "are too weak to halt a dramatic increase in deforestation". According to Greenpeace

Greenpeace

Greenpeace is a non-governmental environmental organization with offices in over forty countries and with an international coordinating body in Amsterdam, The Netherlands...

, "indirect land-use change impacts of biofuel production still are not properly addressed", which for them was the most dangerous problem of biofuels

Industry representatives welcomed the certification system and some dismissed concerns regarding the lack of land use criteria. UNICA and other industry groups wanted the gaps in the rules filled to provide a clear operating framework.

External links

Amendments to the European Renewable Energy Sources Directive (approved December 17, 2008.
CARB: Detailed California-modified GREET pathway for U.S. corn ethanol (February 27, 2009, version 2.1)
CARB: Detailed California-modified GREET pathway for Brazilian sugarcane ethanol (February 27, 2009, version 2.1)
CARB: Proposed Regulation to Implement the Low Carbon Fuel Standard (approved April 23, 2009)
EPA's Renewable Fuel Standard Program (RFS2): Regulatory Impact Analysis for RFS2 (February 2010)
Ethanol and Land Use—Renewable Fuels Association position regarding ILUC (see pages 20–21)
Global Trade and Environmental Impact Study of the EU Biofuels Mandate by the International Food Policy Institute (IFPRI) March 2010
Growing Better Biofuels—The Nature Conservancy position on biofuel production
Indirect land use impacts of biofuels (Bioenergy Wiki)
Renewable Fuel Standard Program (RFS2): EPA Notice of Proposed Rulemaking (published on May 26, 2009)
RFA: Gallagher review, addendums, and responses
Timothy D. Searchinger biofuel writings on ILUC (Woodrow Wilson School)
Towards Sustainable Production and Use of Resources: Assessing Biofuels by the United Nations Environment Programme
United Nations Environment Programme
The United Nations Environment Programme coordinates United Nations environmental activities, assisting developing countries in implementing environmentally sound policies and practices. It was founded as a result of the United Nations Conference on the Human Environment in June 1972 and has its...

, October 2009.

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