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Ethanol Producers Group Calls for Congress to Repeal International Indirect Land Use Provision in RFS2

Tom Buis, CEO of Growth Energy, responded to the publication of the Environmental Protection Agency (EPA) peer review study of the proposed international land use change (ILUC) provision in the Renewable Fuel Standard (RFS2) rule (earlier post) by calling for Congress either  to repeal the ILUC provision or to require a review by the National Academy of Sciences.

The Renewable Fuel Standard (RFS-2) defined within the Energy Independence and Security Act of 2007 requires biofuels to meet specified life-cycle greenhouse gas emission reduction targets to qualify. The law specifies that life-cycle GHG emissions are to include “direct emissions and significant indirect emissions such as significant emissions from land use changes, as determined by the Administrator.

Depending upon the assumptions and boundary conditions set in the ILUC evaluation, the result can dramatically increase the calculated GHG footprint of a biofuel—especially corn ethanol—far offsetting the presumed greenhouse gas benefits of its use. (Earlier post.)

Growth Energy is an association of US ethanol producers.

According to Buis, the peer review underscores Growth Energy’s position that there is no universally-accepted scientific model for measuring indirect land use changes.

We need to stop this nonsense. This is the most bizarre concept I have ever seen. EPA’s peer review proves that too much uncertainty about the economic modeling, data and science exists to allow this to ever become regulation. Even the peer review committee could not agree. That’s why we need Congress to act today to pass legislation either repealing this flawed concept, or adopting the provision recently passed by the House of Representatives to require a thorough review by the National Academy of Science [sic].

—Tom Buis

The Growth Energy stance reflects an increasingly sharp response by the ethanol industry to the impending incorporation of indirect land use change effects in the lifecycle assessment for biofuels, both in the California Low Carbon Fuel Standard and in the US Renewable Fuel Standard. 

Shortly before the EPA’s release of the peer review, the Renewable Fuels Association released a statement calling suggestions by EPA and CARB officials that biofuels are the only type of fuel that cause any noticeable indirect, market-mediated impacts “a laughable assertion”.

In only singling out biofuels in their analyses of indirect effects, both EPA and California have overlooked the enormous secondary impacts of our continued dependence on oil.

“Every single energy decision we make carries with it indirect economic, social, and environmental impacts,” said RFA President Bob Dinneen. “While the indirect, ripple impacts of our dependence on petroleum fuels are often well hidden, to ignore them altogether is irresponsible policy and questionable science.”

Accompanying the statement was a picture of oil wells burning in Iraq in 1991. The RFA followed that up later in the week with a second statement asserting that CARB and EPA failed to evaluate indirect petroleum GHG emissions related to reconstruction of Iraq and protection of the US oil supply. This was accompanied by a picture of convoys entering Iraq from Kuwait.

If we are going to count the angels on the head of a pin when it comes to GHG emissions from biofuels, then we mustn’t ignore the significant outlay of resources to secure and protect our supplies of oil. If only those vehicles were running on Iraq’s abundant solar energy. But, they are all powered by fossil fuels, just like the destroyers and other sea vessels needed to protect the free flow of oil. All that combustion of fossil fuels must certainly come at an environmental price.

—Bob Dinneen



"If we are going to count the pin headed angels when it comes to GHG emissions from biofuels then we mustn’t ignore the significant outlay of resources to secure and protect our supplies of oil."

Well... yes. But considering the microcephalics running EPA's CO2 findings - we should not be surprised.

Aureon Kwolek

indirect land use change theory - junk science

The Renewable Fuels Association (RFA) says its experts are “unable to confirm and replicate” EPA science on indirect land use change theory. That’s because it can’t be scientifically proven and probably never will be. Upon request by the RFA, for the Food and Agriculture Policy Research Institute’s (FAPRI) model, the EPA was unable to release the actual model. That ought to tell you something. They don’t have one. The “peer review” itself could not agree on preliminary modeling. Even if there was a working model, if you put false assumptions in, you’re gong to get false conclusions out. Yet the EPA is trying to force indirect land use change theory into their regulations, while it remains unproven and highly controversial.

Followers of indirect land use change theory claim that an acre of biofuel displaces an acre of food, which must then be grown somewhere else, on deforested land - FALSE. Our corn crop is the same number of acres planted this year that was in cultivation 60 years ago. Since then, the yield per acre keeps going up, so we are not displacing other crops to grow more corn. Technology is getting much more out of the same acreage.

What biofuel critics omit, is that a biofuel crop also produces food. A 150 bushel acre of corn ethanol produces 450 gallons of fuel from the grain, plus 400 gallons of fuel from the corn cobs and stover biomass, plus 20 gallons of corn oil, plus 50 bushels of high protein livestock feed – used to produce dairy products, meat, poultry, fish, and farm-raised “seafood”.

For soy, only 1/5 of the soybean is extracted for the oil, and that can go to food or fuel. The other 75% is high protein soy meal, which is also fed to livestock to produce food. Glycerin is a byproduct of biodiesel production that is being purified and made into value-added products also. And soybeans naturally enrich the soil by fixing nitrogen, displacing nitrogen fertilizer. All of these factors need to be evaluated and credited accurately to the lifecycle of biofuels. The EPA fails to do so.

Even 70% of the oil extracted from a palm-oil plantation in Indonesia is used for human consumption, not biofuels.

The demand for food is going to keep going up, as world population increases. If you see land being deforested in Africa, The Amazon, or Indonesia, the majority of it is being used for subsistence farming and livestock grazing, not biofuels or “replacement crops”. That’s after lumber companies and paper pulp companies have stripped the timber. A percentage of deforested land lays abandoned and unused for years afterwards. It’s a false assumption to claim that American corn based ethanol or American soy based biodiesel is causing deforestation in foreign countries. The facts on the ground prove otherwise.

In “Deforestation Debunked”, Jackie Helling says an Amazon study conducted earlier this year, by the Soybean Work Group (GTS), “showed that of 630 samples of deforested areas since July 2006, only 12 had gone to soybeans and 200 to cattle. The remaining 418, or 70 percent, were unused - indicating that the main reason for cutting down trees was for timber and land grabbing.”

Rainforest deforestation has been going on for decades, long before the recent expansion of biofuels.

In the U.S. and many other countries, there is no shortage of food and no shortage of land, as biofuel critics would have you fear. We will have a large corn crop and a sizeable surplus this year, because foreign acreage of competing grain crops increased significantly. So do we now blame this expansion of foreign grain crops for deforestation? No – because, for the most part, that would be a false assumption.

In the U.S., we only use one third of our arable land. And in many other places, including Russia, Africa, South America, and Australia, there is also a surplus of arable land. With the exception of densely populated countries like India and China, we have many years to go, before we need to be concerned about different crops competing against each other for arable land. And yields per acre continue to go up every year.

Hypothetically, if indirect land use change was actually happening, expansion of a sugar crop in India could have caused it. Expanding rice or cassava in China could have caused it. A new palm oil plantation in Indonesia could have caused it. A new jatropha grove in Africa may have caused it. A new cattle pasture in Argentina may have caused it. An apple orchard in New Zealand could have caused it, and so on.

Deforestation is Not automatic proof that biofuels are the cause. Yet a lawyer, a lobbyist, an environmental activist, a biofuels critic, the mastermind of indirect land use change theory, is steering EPA computer modeling to blame biofuels. That’s junk science.


Great post Aureon. You are well informed.


Of course Dinneen is going to cobble together a critique of any science that does not support corn ethanol. He is literally paid to do so. It's his job. It's like being the head of marketing for any given product.

This is called cherry picking your science (uncritical acceptance of any science supportive of corn ethanol and automatic rejection of any science that does not). The concept of land displacement is pretty straightforward:

richard schumacher

Who pays Kwolek's salary, I wonder? Is he the global-warming denier, or the New Age novelist? Fortunately, policy will be decided by people who do not believe that every possible acre of arable land must go under the plow.


It is really amazing to see what interested parties are willing to say and do when they are looking at their pocket book and/or are well paid to do it.

Of course, all direct and indirect factors must be considered when switching from fossil to alternative fuel sources. Oherwise, we may latter find out that some alternative fuels are even worse for humanity than current fossil fuels.

Destroying tropical forests to produce alternative fuels may very be one process to avoid.

Using edible grains to produce ethanol for our gas guzzlers is certainly not a very wise decision.

It seems that our addiction to oil and oversized gas guzzlers has progressively made many of us less than perfect and reduce our capacity to see the difference.


ILUC isn't a theory anymore than climate change is. Like climate change, most researchers accept it's reality, they simply, and predictably, quibble over how to best model and measure it based on each researchers personal predilections and biases. The journal Science, does not publish junk science, especially multiple times.

By labeling researchers who have found evidence of crops displacing carbon sinks as "followers" of indirect land use change, Kwolek is suggesting that anyone accepting what common sense (backed by a growing body of evidence) suggests, are followers of some kind of irrational cult. I would think that corn ethanol enthusiasts would better fit that pejorative. If I choose to only plant tomatoes in my backyard garden next summer my wife will have to buy her lettuce at the grocery store. That's just common sense.

Biofuel enthusiasts don't seem to disagree that biofuels displace crops. That's real hard to deny. The argument appears to boil down to this: All crops displaced by biofuels are being grown on land that has already been cleared of its carbon sinks and biodiversity. They only deny that those displaced crops are exacerbating the clearing of carbon sinks for new, more fertile, and therefore more profitable arable crop land.

The problem is that we can't force farmers around the world to only use degraded land anymore than we can force American corn farmers to do so for corn turned into ethanol.

Researchers of course understand that and that is why they are looking for evidence that new cropland is being created where carbon sinks were sitting. They are not looking for biofuel crops per se but crops in general to verify that farmers do indeed prefer clearing forests and grasslands over trying to farm degraded land.

So now it comes down to what the researchers are finding. The argument continually shifts as one defense of corn ethanol after another falls, as the argument about global warming has shifted.


It really has little to do with "researchers findings." It has only to do with understanding that corn, cellulosic and algal-based ethanol/biodeisel are all necessary interim steps in achieving the only real goal on the table - energy independence.

Opponents of ethanol are in the service or pay of big oil, OPEC or CCP. The American public is not bamboozled by these phony "land use" excuses to keep big oil fat and happy. Ethanol demonstrated in Brazil, is a viable path toward breaking the foreign oil addiction and domestic energy independence. Anyone who claims otherwise betrays their underlying agenda to marxist central planning.


The dog-eared argument that corn ethanol is a necessary evil needed to usher in a version of alcohol that will be cheaper does not even make sense. What village cobbler would welcome a competitor who can fix shoes faster and cheaper? If a cheaper way to make ethanol ever arrives, and it may never arrive, the corn ethanol lobby will begin efforts to kill it.

And it was our government who decided that ethanol would be the biofuel of choice, not the free market. It also makes little sense that they favored a fuel that gets 60% fewer miles per gallon than a biodiesel.

And without radical improvements in transport efficiency, energy independence isn't even a remote possibility.


Biodiversivist raises a good point. The Cello punitive award will raise the level of due diligence on biofuel startups. The expectation that any cellulosic technology will go from zero to full production is unrealistic. EPA wanted Cello to contribute more than half the RFS - unrealistic. However, a village cobbler might not welcome a faster, cheaper competitor - or he might adopt the new methods. Most corn ethanol companies will expand to cellulosic production or go BK.

And there are operations making progress. Range Fuels, another cellulosic startup with major financing has hired AMEC engineering with years of oil and gas background to help complete their first plant in Soperton GA.

Coskata remains on track for their “semi-scale” commercial demonstration in Madison, Pennsylvania this year, after opening a pilot-scale facility in Warrenville, Illinois more than a year ago. And they're negotiating a 50Mgy facility in Florida with US Sugar.

Either way, the use of corn ethanol over the next ten years to wean us off a portion of foreign oil will provide jobs/income to farmers and pave the way to alternative liquid fuels. A not so "evil" proposition.

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