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Comment 209 for Low Carbon Fuel Standard (lcfs09) - 45 Day.
First Name: Virginia
Last Name: Dale
Email Address: email@example.com
Subject: Great uncertainty surrounds Indirect Land-Use Change (ILUC) estimates; therefore ILUC fact
April 22, 2009 California Air Resources Board Headquarters Building Sacramento, CA 95812 REF: Great uncertainty surrounds Indirect Land-Use Change (ILUC) estimates; therefore ILUC factors should be excluded until better data and documentation are available and scientifically peer-reviewed Dear Board Members: I am writing to recommend that CARB reconsider the proposal to include indirect carbon emissions from land-use change (or Indirect Land-Use Change – ILUC – factors) in the Low Carbon Fuel Standard (LCFS) rule. A delay in adopting the ILUC component of the proposal for GHG emission calculation is warranted because current ILUC emission factors are theoretical estimates rather than science-based calculations. The ILUC implications of the LCFS are largely based on a global equilibrium model that is not capable of assessing impacts on indirect land use. Instead, natural resource extraction activities may very well be among the most significant factors contributing to the accelerated loss of natural habitat in the remaining forest zones of our planet. Based on my field work in the Brazilian Amazon, Panama, Guatemala and personal research in south and southeast Asia as well of review of numerous scientific studies, it seems that land-use change in developing countries is a combination of cultural, environmental, social, economic, political, and technological factors. Global market conditions often have a quite limited influence. In contrast to the model predictions, numerous studies suggest that improved prices and expanded market options for products, as expected under biofuel policies, reduce pressures for deforestation and provide tools and incentives to promote more sustainable land use. The ILUC estimates carry significant uncertainty because they are based on: (a) a model that was never validated or calibrated for the purpose of estimating land-use change; (b) input data for land use with degrees of uncertainty much larger in magnitude than the changes modeled, casting considerable doubt on the validity of results; (c) one set of modeling results when the same model produced wide-ranging results for indirect land-use change in response to minor adjustments in assumptions and inputs (and there is ongoing debate surrounding the accuracy and validity of many of those assumptions, factors and inputs) as documented in the papers published on the GTAP website and for CARB in the past 24 months; and (d) a hypothesis for indirect land-use change that does not meet the “rules of reason” tests established in US courts for indirect environmental impacts, exposing the LCFS rule to potentially serious implementation obstacles that could be avoided if the ILUC component were postponed until better data and analytical tools are developed. Examination of the land use and economic models show that there is not currently any accepted approach for calculating indirect land-use change impacts from U.S. biofuel production and policy. GTAP has not been calibrated or validated for making land-use change estimates. The GTAP modeling assumptions used to estimate ILUC do not come close to reflecting the conditions and forces that prevail in the areas where impacts are estimated to occur. Baseline land-cover and land-use data and other underlying assumptions for the modeling carry huge uncertainties, yet these uncertain inputs determine the results. The sensitivity of results is illustrated in part by the wide range of ILUC results reported among the GTAP reports issued on this topic in 2008 and 2009. Several US Court decisions have considered if and when indirect environmental impacts need to be incorporated under proposed government projects. The decisions can be assembled under “rules of reason” that help determine when indirect impacts should be incorporated. The basic question is, “Are the impacts (indirect land use change effects, in this case) reasonably certain to occur as a result of proposed action, or is the estimate (of ILUC) based on speculation?” There is a lack of consensus on this issue in the scientific community. But, several considerations from past court cases may help answer the “rule of reason” question: (a) Are estimated ILUC impacts speculative within the context of all the other events, circumstances and contingencies that exist to enable the effect (e.g. deforestation)? (b) Is the impact (loss of natural habitat/deforestation) inevitable, independent of the proposed action and the theorized indirect impacts? (c) Does the “precautionary principle” clearly favor one proposed action over another? (e.g. What are the impacts on land-use change and deforestation if less biofuels are accepted under LCFS due to the assumed ILUC factors?) (d) Is the estimated impact increasingly tenuous as inquiry extends outward from the core project area? (e) If there is a “reasonably foreseeable” indirect impact, does it occur in a remote locale that is not under direct U.S. control? (f) What is the “legally relevant cause” of the impact? (Is the ILUC impact isolated from the proposed action?) Thus it cannot be concluded that the estimated indirect impacts are caused by the proposed action. In the case of the California LCFS, rather than include ILUC factors at this time as proposed, we recommend that a more prudent approach would be to identify these as possible indirect impacts and recommend mitigations to limit the likelihood of negative effects. Such mitigations could include adherence to sustainable production standards that are developed and monitored by third parties. I applaud your pioneering efforts to establish a LCFS and support your initiatives to reduce emissions and improve welfare for present and future citizens. However the market-mediated land-use impacts hypothesized by GTAP and similar economic models are not merely inaccurate; they may indeed be estimating impacts that are opposite to what could be expected in the real world, particularly when biofuel production is backed by incentives for sustainable production, environmental legislation and enforcement. Much more work is needed to better understand the interactions among these factors, going beyond theories, to calibrate and validate models that reflect how behavior is impacted, and to better quantify the degree and direction of impacts from biofuels. Sincerely, Virginia H. Dale, PhD 212 Whippoorwill Drive Oak Ridge TN, 37830
Original File Name:
Date and Time Comment Was Submitted: 2009-04-22 11:37:55
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