Yesterday in California, a group of twelve developers and investors in next generation biofuels (including Vinod Khosla) released a letter to the California Air Resource Board supporting the development of rigorous GHG accounting for biofuels. While the letter supports CARB's inclusion of emissions from indirect land-use change caused by some biofuels, the letter goes further to call for some specific measures that could help chart a course forward on this tricky issue. By productively engaging to help make sure that California's low carbon fuel standard is both strict and encourages the development of the best biofuels technologies, this letter is an important addition to battling letters I've written about before.
As a little context to highlight how important this is: Yesterday yet another scientific article came out in the journal Conservation Biology quantifying how important it is to keep biofuels from leading to increased deforestation. The article calculates how long it takes to make up the carbon released from tropical forests through the avoided GHG emissions from petroleum fuel. The article finds that it would take 75 years worth of biofuels production for a typical tropical forest and 600 years for a forest with peat soils. While the article looks at the direct clearing of forests for biofuels, the same carbon calculus comes into play indirectly through land-use change.
That's why its so important that the entrepreneurs' letter starts off:
The undersigned endorse the California Air Resource Board’s (CARB’s) prioritization of an environmentally responsible approach to the Low Carbon Fuel Standard (LCFS) and indirect land-use change (ILUC).
Along with offering this support, the entrepreneurs calls on CARB to take a number of steps to ensure that the regulations provide clear direction to developers and investors about the performance of different technologies and practices, and provide this direction in a way that encourages innovative mixing and matching of options. Understandably, the next generation developers want to make sure that the most promising feedstocks, management practices, and conversion technologies will be carefully and specifically assessed by the regulators and not simply be treated like first generation technologies.
I think all the evidence suggests that both CARB and EPA are already moving to assess the most promising options and that they want to do more as they continue to develop their rules. However being sure to develop a menu of options based on specific proposals with input from the industry will be an important step to making sure the LCFS and RFS really work.
Specifically the letter says:
We believe the following items should be part of the LCFS and are at least partially addressed in the October draft of the LCFS:
(1) The use of a comprehensive evaluation system that promotes higher productivity, waste biomass utilization, non-food feedstocks, and increased soil carbon sequestration.
(2) A clear price signal for the carbon value attributed to various fuels, distinct from inherent fuel value.
(3) The encouragement of facility-specific certification for direct GHG measurement.
And the menu of options that the entrepreneurs want covered under the comprehensive evaluation are addressed in the following section:
1. Minimization of land impacts. The indirect land use measurement should incorporate a consideration of what the land in question is capable of providing and its prior use. The calculus should have the effect of encouraging land use in the following order:
i. No land used (e.g. forest waste, rice straw)
ii. Seasonal cover crop (e.g. sweet sorghum)
iii. Displaced fiber crop (e.g. cotton)
iv. Displaced forage crops (e.g. pasture)
v. Displaced animal feed (e.g. alfalfa)
vi. Displaced human/animal edible crop (e.g. corn, soy)
vii. Displaced human edible food (e.g. wheat, rice, vegetables)
2. Maximization of productivity. The combined effects of the ILUC and direct measurements should encourage the following:
viii. Production/acre – Reward improved productivity (in BTUs) per unit of land.
ix. Water efficiency – Reward the use of non-irrigated land and water reduction below prior use. We recognize that this may create a need to equate water usage and GHG production. Fortunately, in California, there are models for the embedded GHG effects of water utilization, and we assume that these or comparable models can be applied in the rest of the country where irrigation is used.
x. Land improvements – Reward practices that improve the carbon sequestration in soil, including non-till practices and biomass systems.
xi. Protein and electricity co-products – Rewards for the creation of protein/animal feed and electricity.
By embracing the challenge and importance of emissions from indirect land-use change and also helping regulators understand what the industry needs in the LCFS to be able to invest in the biofuels options that avoid and minimize these emissions, this letter is big news.