Twenty-three scientists (a different 23 from this 23) sent similar letters to the EPA and USDA and the California ARB calling on these regulators to "stay the course" in terms including emissions from land-use change in the assessment of emissions from biofuels. As I wrote about yesterday and over the weekend, these letters are part of an ongoing political struggle (well summarized by Stephen Powers in today's WSJ) over whether EPA will comply with the RFS law and include emissions from land-use change induced by biofuels. ARB is dealing with same technical challenge.
Having written a lot about this recently, I'll just touch on one point not covered by the scientists' letter to ARB. This letter focuses on responding to the New Fuel Alliance's letter to ARB. As Brook Coleman from NFA reiterated in his comment to my weekend post, one of the advanced biofuels industry's major concerns is that the idea of indirect or economically mitigated emissions is not being equally applied across all fuels. In personal communications, Brook has also made the important point that in the context of a purely performance based policy such as the LCFS, even small differences in the carbon intensity of fuels will be reflected in their relative value in the market.
I certainly agree that the concept of economically mitigated impacts needs to be applied evenly, but I also think that they need to be included carefully and only when they have a reasonable chance of being large. The complexity and, yes, uncertainty of putting a value on this type of impact means that we have to be wary of the slippery slope that lies between trying to avoid major unintended indirect consequences from our policies and trying to be omniscient.
Certainly, just less than two years ago, most of us had not thought through the land-use impacts of biofuels, so we should be humble and open to the idea that other fuels have similarly potentially large indirect impacts. So, for now I'm unconvinced that any other potential economically mitigated emissions are worth trying to quantify, but I'll remain eager to hear a compelling case for doing so.