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Comment 128 for Low Carbon Fuel Standard (lcfs09) - 45 Day.
First Name: Gal
Last Name: Luft
Email Address: firstname.lastname@example.org
Subject: comments on LCFS/land use
One can argue the land use surcharge back and forth on a philosophic level and on the accuracy of the model. However, there are several fundamental problems with the way land use surcharge is applied. Generally speaking land use intensity is highly cyclical. It corresponds mainly a combination of demand and price for agriculture products. The report clearly stated the case for land use intensity increase with increased demand for bio-fuels. However, as seen recently, the price of agriculture commodities are only partially dependent on bio-fuel demand. In Q4 of 2008 we saw record production of ethanol but nonetheless corn and ethanol prices fell by 70%. This means that corn prices are more sensitive to oil prices than to demand from the biofuels industry. Put those two together, and the result is that as oil prices go up, commodity prices go up, corn prices go up and land use intensity goes up with it. Then we go through a period of oversupply with corresponding price reduction and land use intensity reduction. So to the extent that bio fuels offset the demand for oil and put a downward pressure on gasoline price, it moderates the increase in land use intensity. The second error I see in the analysis is in the accounting of GHG emissions from the conversion of cattle pasture to agriculture (corn) land. Most cattle pasture in the US is grass land. The cattle eats the grass and converts it to methane which is 23 times more potent then CO2. As corn becomes more expensive, feed become more expensive so meat production becomes less economical. It is logical that meat growers will then lease their land to corn growers. As I see the reality of corn expansion, brand new barren land is the last resort. The growers will first grow more corn on the land they already cultivate, then they will use land that was cultivated in the past but is now idle (because it was not profitable to cultivate). Then they would use cattle pasture that is more productive than barren land. As I said, the calculation of land use change from cattle pasture to corn is incorrect because it does not take into account the root system (corn has a much more robust root system which capture more CO2 than grass root system. Corn harvesting does not involve removing the roots from the ground.) and it only focuses on CO2 which misses the potent GH effect of methane gas. Add to this the GHG emission of meat processing, packaging, freezing and transportation and you will get huge savings in GHG emissions when converting cattle pasture to biofuels crop. The third error is ignoring the fact that the same market forces that increase the demand for corn ethanol and with it increase in land use intensity, will eventually find a cheaper alternative that will reduce the demand for corn ethanol and with it reduce the land use intensity: As land become more valuable and corn more expensive, corn ethanol will become more expensive too. This will further increase the effort to invest and produce ethanol from other sources such as cellulosic ethanol and ethanol from algae/seaweed. These new and cheaper sources will undermine the demand for corn ethanol which will reduce the demand for land eventually causing the land to revert back to its original use. This demand destruction is surly within the scope of the timeframe that the land use change surcharge applies to.
Original File Name:
Date and Time Comment Was Submitted: 2009-04-19 11:24:50
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