110 scientists call on Gov. Schwarzenegger to eliminate bias in Low Carbon Fuel Standard

In California, more than 100 scientists and groups such as the New Fuels Alliance have called on Governor Arnold Schwarzenegger to eliminate biases in the state’s proposed Low Carbon Fuel Standard (LCFS).

“As you are aware, ARB staff continues to push a regulation that includes an indirect land use change (iLUC) penalty for biofuels. To be clear, this effect is not the direct land conversion from growing crops for fuel. It is the alleged indirect, price-induced land conversion effect that could occur in the world economy as a result of any increase in demand for agricultural production. The ability to predict this alleged effect depends on using an economic model to predict worldwide carbon effects, and the outcomes are unusually sensitive to the assumptions made by the researchers conducting the model runs. In addition, this field of science is in its nascent stage, is controversial in much of the scientific community, and is only being enforced against biofuels in the proposed LCFS.”

“ARB staff is proposing to enforce a penalty on all biofuels for indirect land use change as determined by a computable general equilibrium (CGE) model called GTAP. This model is set to a static world economic condition (e.g. 2006), then shocked with a volume of biofuel to create the perceived land conversion result. The modeling outcome is applicable to the set of assumptions used for that particular run, but is not particularly relevant when there is a shift in policy, weather, world economic conditions or other economic, social or political variables. For example, by definition, these models assume zero innovation, which means they could not have predicted the 500% increase in corn yields since 1940, the tripling of wheat yields since 1960, or the 700% increase in yield that can occur if farmers in developing countries adopt higher yield seed varieties and more efficient farming practices. This inability to predict innovation is not limited to agriculture; similar attempts to use economic equilibrium models in other emerging markets like telephony or computing would have been equally unsuccessful. ”

“As discussed, the model runs are unusually sensitive to the assumptions made by the modelers, which is why the iLUC modeling results published thus far differ by a factor of at least four, and under some scenarios, are actually zero for today’s biofuels. Even at this late stage in the LCFS process, the GTAP model runs still do not reflect basic on-the-ground realities .”

The full text of the latter is can be downloaded here, from Biofuels Digest’s Bioenergy Information Zone (BIZ), which contains dozens of free, downloadable reports and presentations on key aspects of biofuels.

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