RFA submits comments to CARB insisting they use real-world data for LCFS

In California, the Renewable Fuels Association (RFA) submitted comments on Monday calling on the California Air Resources Board (CARB) to revise its Low Carbon Fuel Standard (LCFS) re-adoption proposal to reflect recent scientific advances and new empirical data regarding the actual impacts of biofuels on global land use patterns.

In comments submitted to CARB Chairwoman Mary Nichols, RFA noted that while steps have been taken to slightly improve the program in the re-adoption proposal, RFA remains “deeply concerned by several aspects of the proposal,” noting that CARB’s inclusion of a flawed indirect land use (ILUC) change analysis “threatens the long-term durability of the LCFS program.”

RFA points to the central role that grain-based ethanol has played in LCFS compliance over the past four years, noting that nearly 60 percent of all LCFS credits were generated by ethanol. Yet, despite the vital importance of grain ethanol to the program, the proposed ILUC penalty assessed against corn ethanol “will make the use of most grain ethanol infeasible for compliance as early as 2016.”