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Ethanol Groups File Suit Challenging Constitutionality of California Low Carbon Fuel Standard

25 December 2009

Two ethanol trade groups—the Renewable Fuels Association (RFA) and Growth Energy—have filed a complaint in Federal District Court in Fresno, California, challenging the constitutionality of the California Low Carbon Fuel Standard (LCFS). The two organizations are arguing that, as structured, the LCFS violates both the Supremacy Clause and the Commerce Clause of the US Constitution. The LCFS calls for at least a 10% reduction from 2006 levels in the carbon intensity (measured in gCO2e/MJ) of California’s transportation fuels by 2020. (Earlier post.)

The LCFS regulation also levies the calculation of Indirect Land Use Change (ILUC) effects against biofuels, against the opposition (earlier post) of the biofuels industry, and to the particular detriment of corn ethanol.

The Supremacy Clause (Article VI, Paragraph 2) establishes the Constitution, Federal Statutes, and treaties as “the supreme Law of the Land”, mandating that state judges be bound by them, even if state constitutions or laws conflict.

The Commerce Clause (Article I, Section 8, Clause 3) gives Congress the power to regulate commerce “with foreign Nations, and among the several States, and with the Indian Tribes”. The application of the Interstate Commerce Clause has been wrangled over in court since the early 1800s.

In a statement describing their action, the two groups said:

The LCFS contradicts the sound judgment of Congress when it passed the 2007 Energy Independence Security Act and singled out the importance of domestic ethanol for our nation’s environment, energy security, and economy. The LCFS erects new regulatory obstacles to ethanol, frustrates the federal Renewable Fuel Standard, and threatens the nationwide market for domestic ethanol. Because congressional policy cannot coexist with California’s regulation, the latter must give way to the former, the supreme law of the land.

Additionally, by closing California’s borders to corn ethanol from other states, the LCFS will change how corn is farmed and ethanol is produced all over the country. The Commerce Clause specifically forbids state laws that discriminate against out-of-state goods and that regulate out-of-state conduct.

The LCFS imposes excessive burdens on the entire domestic ethanol industry while providing no benefit to Californians. In fact, in disadvantaging low-carbon, domestic ethanol, the LCFS denies the people of California a genuine opportunity to clean their air, create jobs, and strengthen their economic and national security. One state cannot dictate policy for all the others, yet that is precisely what California has aimed to do through a poorly conceived and, frankly, unconstitutional LCFS.

Other RFA arguments against the LCFS. On 15 December, Bob Dinneen, RFA President and CEO, sent a letter to Mary Nichols, Chairwoman of the California Air Resources Board (ARB) and Susan Lapsley, Director of California’s Office of Administrative Law (OAL), arguing that because ARB failed to respond to significant comments submitted by RFA and other stakeholders, under the California APA, OAL must disapprove the LCFS.

(The OAL ensures that agency regulations are clear, necessary, legally valid, and available to the public. OAL is responsible for reviewing administrative regulations proposed by more than 200 state agencies for compliance with the standards set forth in California’s Administrative Procedure Act (APA), for transmitting these regulations to the Secretary of State and for publishing regulations in the California Code of Regulations.)

Other complaints cited by the RFA in the letter were several issues that the RFA said ARB staff effectively failed to address in the FSOR (Final Statement of Reasons); and that although ARB has cast 2010 as only a “reporting year”, the reporting compliance mechanisms such as forms and formats are not provided in the rule, meaning that entities who need to begin keeping the records for reporting in May do not know what information must be collected in what format starting in January 2010.

I bring these matters to ARB’s attention so that ARB can direct its staff to withdraw the package to address these inadequacies. If ARB does not withdraw the rule to fix these deficiencies, OAL must return the rule to ARB—as was done to the Phase 3 Reformulated Gasoline regulations after OAL determined ARB had failed to respond to comments.

—Letter from Bob Dinneen

“Significant comments” to which ARB did not respond, according to Dinneen, were:

  • Direct Lifecycle GHG Emissions. The RFA charged that ARB ignored the comments of stakeholders stating that the agency’s GREET (Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation) model assumptions overestimated fossil energy use on farms and at ethanol plants. RFA provided reports from Argonne National Laboratory (where the GREET model was created and is maintained) and Christianson & Associates showing that ethanol plants consume less fossil energy than assumed by ARB.

    Further, wrote Dinneen, several commenters referenced the article by Liska et al. in the Yale Journal of Industrial Ecology that showed lower direct carbon intensity values than the GREET model values used by ARB. (Earlier post.) The Liska et al. analysis found direct lifecycle GHG emissions associated with the production of corn ethanol are in the range of 37.5 to 48.1 grams of carbon dioxide-equivalent per megajoule (gCO2e/MJ), compared to ARB’s range of 47.4 to 75.1 gCO2e/MJ.

  • NERA Studies on Timing of GHG Releases. Dinneen charged that ARB made no attempt whatsoever in the FSOR to respond to the reports by NERA Economic Consulting submitted by RFA on the issue of timing of GHG emissions. The NERA papers suggested that ARB examine an additional method (social cost of carbon) for accounting for emissions over time. Using the method recommended by NERA, the emissions from indirect land use change that CARB attributes to corn ethanol would be reduced by 24% (from 30 gCO2e/MJ to 22.9 gCO2e/MJ).

  • Treatment of Ethanol Co-Products in Analysis. RFA and many other stakeholders, including a number of university animal scientists, provided comments to ARB stating that the agency undervalued ethanol co-products—primarily distillers dried grains with solubles (DDGS)—in its Global Trade Analysis Project (GTAP) analysis and did not account for the fact that DDGS partially replaces soybean meal.

  • Reduced Methane Emissions from Decreased Enteric Fermentation. RFA submitted comments indicating that if ARB was going to penalize corn ethanol for price-induced indirect GHG effects that worsen the carbon score of ethanol, then credit should be given for price-induced GHG effects that reduce GHG emissions

  • GTAP Model Elasticity Governing Yields on Newly-Converted Lands (Productivity With Respect to Area Expansion). ARB used central values for the elasticity that governs yield with respect to area expansion. This is an important parameter in the GTAP model and has a significant effect on the final ILUC (indirect land use change) results. Dinneen said that ARB effectively guessed at what this value should be because there was no good empirical data or reference to guide the agency’s use of this elasticity.

    RFA and several other stakeholders obtained data that would help ARB select a more appropriate value for this elasticity. RFA submitted a report to ARB from Informa Economics. Many other stakeholders, including UNICA (the Brazil sugar cane association) and Monsanto, also provided data to ARB. All of this data showed that ARB should use an elasticity value closer to 1.0, rather than ARB’s median value of 0.59.

  • Carbon Derating Factor. In response to RFA’s comment that ARB did not correct its analysis to reflect the impact of ARB’s own assumption on carbon storage in building products, ARB states that it made an error due to “miscommunication.” Dinneen says that the ILUC emissions estimates in the look-up table were never adjusted to account for ARB’s own assumption in the ISOR that not all the carbon in the cleared woody material is released to the atmosphere during the year following the clearing—i.e., since some of the wood is used for building material, it continues to sequester carbon after the clearing event.

  • Certain Land Types Omitted From GTAP Model. RFA commented that ARB’s GTAP model does not include idle cropland and Conservation Reserve Program (CRP) land. This forces the model to immediately “reach” overseas when it looks for land to convert to crops. RFA has repeatedly requested that ARB and Purdue add CRP land, idle cropland, and cropland pasture to the model’s land inventory since the Summer of 2008.

  • Yield Improvements. Dinneen said that ARB received dozens of comments regarding the insufficient treatment of crop yields in the land use change analysis. One peer reviewer stated that ARB’s treatment of yield leads to overstated ILUC emissions. If ARB had used proper yield values, as recommended by stakeholders and peer reviewers, Dinneen said, the ILUC penalty for corn ethanol would have been approximately 11-15% lower.

  • Indirect GHG Effects Associated With Other Fuels. Several commenters, particularly the New Fuels Alliance (NFA), made repeated comments that the LCFS sets up an unlevel playing field by not examining the indirect, price-induced GHG effects of other fuels. Only one mention is made of the Lifecycle Associates study commissioned by NFA to examine indirect petroleum effects, Dinneen said, charging that ARB mischaracterizes the findings of that study.

    One of the study’s main conclusions is that “[t]he GHG impact of petroleum estimated herein ranges from 90 to 120 g CO2e/MJ (grams of CO2 equivalent emissions per megajoule (MJ) of gasoline fuel consumed), depending on the source of the petroleum and to what extent indirect emission impacts are included.” The upper end of this range is 25% higher than the figure used by ARB for the carbon intensity of gasoline, Dinneen pointed out.

Overall, Dinneen wrote, if current data and information had been “properly” incorporated into ARB’s analysis, the ILUC penalty for corn ethanol would have been in the range of 4-11 gCO2e/MJ, rather than the current estimate of 30 gCO2e/MJ. Under those results, corn ethanol would generally offer a 25-30% GHG reduction benefit relative to gasoline, rather than the current finding that corn ethanol offers little or no GHG savings compared to gasoline. Such GHG savings, Dinneen said, would allow regulated parties to utilize corn ethanol for LCFS compliance for the first several years of the policy.

ARB’s blatant disregard for current data and information related to the lifecycle GHG emissions associated with corn ethanol resulted in significant overestimation of the carbon intensity of corn ethanol. ARB’s faulty analysis will have real and significant impacts on US corn ethanol producers and the ability of regulated parties to comply with the LCFS. By the 2012 timeframe, most sources of corn ethanol will not help regulated parties achieve the mandatory GHG reductions under the program. Thus, regulated parties will quickly phase out their use of corn ethanol.

—Letter from Bob Dinneen

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December 25, 2009 in Climate Change, Emissions, Fuels, Policy | Permalink | Comments (11) | TrackBack (0)

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Use methanol, there are no land usage issues, it is made from natural gas and in the future renewable methane and synthesis gas.

CARB Rules Fraudulent

California ARB is corrupt, and their Low Carbon Fuel Standard is distorted by false information – information that’s been deliberately miscalculated, underestimated, overestimated, misrepresented, and based on false assumptions. CARB is trying to block the interstate trade of ethanol, in order to protect the California petroleum industry. That’s a violation of Federal Law. Their agenda was to make the footprint of petroleum look much better than it actually is, and to make that of ethanol look much worse than it actually is.

Ethanol burns much cleaner than gasoline, which contains a long list of carcinogens and neurotoxins, including the killer Benzene. Not only that, ethanol is derived from “recycled” carbon, whereas petroleum is derived from “newly mined” carbon that accumulates in the atmosphere. This should be integrated into their carbon scores. The CO2 emitted from an ethanol burning vehicle is Not the same as the CO2 emitted from a gasoline burning vehicle.

The biggest provider of American crude oil is Canada. Most of that is extracted from energy intensive Canadian Tar Sands, which consumes over twice the amount of fossil fuel energy to produce, compared to a conventional oil well. Millions of acres of trees and vegetation are deforested in the process. CARB uses old oil industry data and totally ignores the impact this has on the current carbon score of petroleum based fuels. Same thing for imported oil that’s shipped thousands of miles from foreign countries, burning dirty bunker fuel and diesel fuel, a major cause of black carbon soot.

CARB also made the blatant false assumption that the U.S. corn crop would keep expanding, displace foreign vegetation, and be the main cause of deforestation in other countries. The fact is, this year’s corn crop produced 10% more corn on 3 million fewer acres than last year. And corn yield per acre is expected to increase 5% per year and double by 2030. No need to increase corn acreage. Domestic soy acreage actually displaced millions of acres of corn this year, and sorghum now provides 15% or more of the feedstock used for ethanol, on lands not suitable for corn. The byproducts of corn ethanol are also increasing and becoming more valuable. To get the correct carbon score of corn ethanol, the inputs must be distributed fairly across all the co-products – fuel, distillers grains feed, corn oil, cobs and stover, etc.

Acreage fluctuates from year to year. That’s no cause for alarm. It keeps supply and demand in balance. If more acreage was put into corn, it wouldn’t necessarily displace other crops, it would be grown mostly on farmlands that are not being used. The fact is, the U.S. only uses 1/3 of its arable land. Assuming that foreign crops would take up the slack of displaced cropland is a false assumption. That’s Not happening, and it’s Not expected to happen.

These false assumptions were caused when CARB deliberately embraced the unproven indirect land use theory, which is not supported by the facts on the ground. The actual causes of deforestation are timber taking, cattle ranching and subsistence farming, not biofuels. Another cause of deforestation and black carbon soot in numerous developing countries is cutting trees for cooking, heating and lighting. In response, India and Nigeria are developing sorghum and cassava based ethanol micro-refineries, a low cost solution for deforestation that is several times more efficient. The ethanol is mixed 50-50 with water to run clean burning stoves and lanterns. It’s ironic that misinformed environmentalists blame ethanol for deforestation, when in some parts of the world, it’s actually helping to reduce respiratory disease, infant mortality, and black carbon soot from burning trees.

Indirect land use change is unfolding as a scandal, possibly even premeditated by CARB and the EPA to restrict biofuels and protect the petroleum industry. Something that was set-up to go into the rulemaking - An unproven, unscientific theory, concocted by an Attorney-Lobbyist-Political Activist and hypothetical computer models that were Not based on fact. The theory also falsely projects that corn ethanol acreage will be doubled in the near term. That is simply Not based on fact. We may take a larger share of the starch from the same number of acres – the same land producing more and more bushels per acre every year. But that won’t require more corn acreage. And even if we ever did increase corn acreage, the land would be derived from unused domestic lands. No other crops would be displaced, and no foreign lands would be involved. Again, indirect land use change is based on false assumptions and twisted computer modeling that is not supported by the facts on the ground or even realistic projections.

Renewable Fuels Association and Growth Energy experts have done their own analysis, and they have already uncovered sizeable discrepancies and errors in proposed CARB and EPA rule making that won’t hold up in court. EPA has already issued a press release stating that there were “serious uncertainties” in their preliminary set of rules - RFS2. And now, California will also be forced to re-do their Low Carbon Fuel Standard under close scrutiny. Court proceedings would not only expose CARB incompetence, it may also expose fraud, misrepresentation, and a deeper investigation showing pay-offs. California is facing a huge budget deficit as it is, something like $35 billion, and a multibillion dollar suit against CARB is the last thing the state needs – especially one that the Renewable Fuels Association and Growth Energy are likely to win.

The RFA is a lobbying organization out of control. Peer reviewed studies along with the researchers who author them are publicly attacked by these organizations. Somebody needs to somehow put them back in the bottle they sprang from, ditto for Growth Energy.

They also tend to attract internet nutballs like a sweater collects lint.

http://biodiversivist.blogspot.com/2009/12/question-for-arianna-huffington.html

http://biodiversivist.blogspot.com/2009/10/myth-of-american-farmer.html

Benzene in gasoline and diesel is a SERIOUS problem that has yet to be fully addressed. We may start to see that more than 50 years of spewing the stuff into our environment has caused more problems than have been accounted for.

It is kind of like the tobacco industry, they claimed no health hazards and then when the evidence was there they said that it was not their product that caused the problems. When there is BIG money on the line you can expect some response to make sure than big money continues to come in, no matter what.

The RFA is the fraudster in this instance, not CARB (though CARB has its problems).  No less a biofuels advocate than Robert Rapier has analyzed the EROI claims of ethanol and found that the accounting is wrong.  If you use the numbers correctly, you get EROI barely over 1:1.  Therefore, it doesn't matter if CARB's land-use model is wrong; RFA's energy numbers are wrong, and we would be better off growing switchgrass to burn in gas turbines and using the saved natural gas to run cars than turning corn and NG into ethanol at 50% efficiency.

Robert Rapier’s numbers are wrong. They’re based on old information and old studies – up to 5 years old. The industry has evolved since then. For the last wave of new ethanol plants, the Energy Return On Input (EROI) for corn ethanol is 1.5 to 1.8 and higher. This is before we had a record corn yield per acre, up 10% over last year. That lowers the inputs further for producing the corn and increases the amount of fuel per acre. So this year, EROI can be as high as 2 to 1. That doesn’t include exploiting the cobs and stalks, as Poet has begun to do, which will increase the return further. And that doesn’t include ethanol refineries that are also extracting corn oil, from the ethanol byproducts.

Get the most accurate and up to date facts available. See: “UNL Research: Corn Ethanol Emits 51 Percent Less Greenhouse Gas Than Gasoline”. This study was funded by the U.S. Department of Agriculture and the North Central Bioeconomy Consortium. Researchers used the highly advanced “Biofuel Energy Systems Simulator”, or BESS, to make their calculations. Professor- Director, Ken Cassman - Ph.D., Agronomy and Horticulture; Nebraska Energy Sciences Center, conducted the study. It is the best study available.

http://ianrnews.unl.edu/static/0901220.shtml

The industry will evolve further. The most advanced corn ethanol refinery is being built in central New York, a game changer. See “Bion Environmental Technologies Plans Closed-Loop Livestock and Ethanol Production Facility in Schroeppel, NY” (Biofuels Journal). This integrates corn ethanol with onsite livestock feeding. Bion takes the next step - mitigating and exploiting the adjacent livestock manure. They developed a system for collecting the manure, in order to extract methane for CHP plant production power and surplus electric power to the grid. Bion also plans to extract nitrogen-phosphorous-potassium (N-P-K) from the digester residues, and recycle them as a localized fertilizer replacement. So they are mitigating the methane GHG that would have been emitted by the manure. They’re using the methane to displace the fossil fuel that would normally be used for refinery production power. They’re displacing fossil fuel based fertilizer that would have been shipped long distances burning fossil fuels. And the waste heat component of the CHP will be exploited to distill the ethanol. They will also produce surplus electric power for the local grid, which will displace more fossil fuels. Bion’s system dramatically increases the efficiency of corn ethanol and also improves the carbon footprint. The return on corn ethanol, integrated with livestock feeding, manure, biogas and CHP power is expected to be over 5 to 1 and very profitable.

EP you are no authority on corn ethanol, and neither is Robert Rapier. CARB is a disgrace to the State of California.

Corn is not the way for E85, but cellulose ethanol might be. I favor E10 and M85. We can make methanol from biomass and/or natural gas. It can be made anywhere from the natural gas in the pipelines. We can fill those pipelines with renewable methane made from biomass close to the source of the biomass.

Robert Rapier's numbers are taken straight from the government; he just corrected their accounting.  The fact that funny accounting was required to make ethanol look good is proof that it's a boondoggle.

In other news, Yahoo is reporting that biodiesel production has cratered due to expiration of the $1/gallon tax credit.

California has long been violating the interstate commerce constitutional pohibitions. Coal fired power plants cannot sell their power to california even with extortionary prices to the california consumers initiated by deregulations. Special laws about cars sold in california is another example. ZEVs were a very good idea but hybrid was better as demonstrated by Prius and others.

California should bite the bullet and ration gasoline and diesel and natural gas and electricity and food if it really wants to reduce CO2.

California gets most of its hydro-electricity from out of state, and a new wind farm is being built in Utah to pretend that California is trying to help the world reduce its CO2.

CARB is still trying to ignore the fact that hydrogen fuel cells will not be operating in many cars ever, and in fact any hydrogen fuel cells should be operated instead in a stationary situation to use the heat in a cogeneration system to charge batteries for plug in hybrids whilst providing heat or cooling to a building and to use their high efficiency 24 hours a day instead of a few hours commuting.

Diesel and other engines can now get efficiencies nearly as good as fuel cells at far less cost, and the slightly lower efficiency is more than compensated for by useful heat recovery.

Capstone Turbines have less efficiency, but total carbon release is lower when employed in combined cycle operation, and they are built to produce less smog than any engine and can be run all the time without many repairs.

The price multiplication of corn in the past few years, and the acute misery caused to the low income inhabitants of Mexico and other countries because of it, has made corn ethanol a world product subject to speculative investment by rich oil speculators with much money to hide and is no longer an ethical product to be produced. Ethanol from any source is a food that can also be made into other foods.

One hundred percent of the CO2 from burning ethanol in automobiles comes from the corn plant and was taken from the air. An equal amount of CO2 is released in the fermentation process from the corn starch. There is much more CO2 released from the corn when the byproducts are used as feed and the stalks and leaves decompose. The fact that all the CO2 comes initially from the air is misinterpreted by some as making the ethanol carbon neutral.

If one uses an estimated figure that two units of ethanol CO2 takes only one unit of fossil CO2 to produce, and also factors in that it is estimated that one unit of gasoline CO2 takes less than one and a half units of crude CO2 to produce, then it still can be shown that to reduce total CO2 release, corn fields should be turned over to growning trees that are never used for fuel, and 100 percent more fossil fuel should be burned to add to the fuel then not burned to produce ethanol.

Trees may not take as much CO2 out of the air as corn plants do but they only have to take out less than half as much, since three to four times as much CO2 is in the whole corn plant as there is in the ethanol produced from it.

The above figures cannot be proven true but the result seems to indicate that ethanol from plants is too costly now in terms of CO2 release when alternate non fuel growth on the land is factored into the equations.

The reality of renewability and sustainability vanishes when simple calculations show that all crop land and all forest lands of California or the US cannot meet the current demand for energy.

According to some reports, natural gas is now more available due to advanced drilling methods and new places discovered that can use these methods. Natural gas is a much lower CO2 fuel than ethanol, but it is a mistake to make cars powered solely with natural gas. In fact cogeneration to charge plug-in-hybrids is even more CO2 efficient than any fuel burning car. Natural gas can be made into methanol for times when liquid fuel is needed, but there is also a simple process to make methanol into gasoline. Corn can be made into natural gas much more cheaply and easily than it can be made into ethanol.

During many flights over california, not one standard large wind turbine has been seen in any city, and whilst most californians would object to a square mile of pristine desert land being devoted to nuclear power plants and used fuel storage areas, many square miles are being proposed for solar mirrors.

Solar parabolic stirling units of high efficiency are available in sizes suited for houses and factories where power is used and almost none is lost in transmission, but california or its power companies are not supporting Infinia to produce them in quantity. But massive areas in the desert are proposed to be used for much more inefficient solar mirrors. The small parabolic units can also be used as cogeneration units.

It is known how to make any area in california into developed houses. This was done with LA by piping water from the Owens valley to the area and then from the Colorado river and other places. Developments for wealthy or even the poor can be made anywhere in california, since cheap reverse osmosis units can take water from the ocean and supply hundreds of gallons to a house for less than the price of a bottle of water from a machine. Pumping the water can be done cheaply enough as well. The water may not be cheap enough to run a farm, but it is cheap enough for a house. Very efficient sewers should be used so that the water can be used for house and yard plants after very cheap filtering.

Instead of allowing large areas to be used for solar energy at a cheap price, the US government should lease the area to developers at a price similar to the price paid in recently developed areas near LA. The water that now goes to LA from the Colorado can be easily diverted to the Mojave instead. LA can get replacement water from the Pacific. Eventually Owens valley can be rejuvenated a bit.

Perpetual income could go to the US government and to the county and state. Due to reverse osmosis and water pumps, there are no unihabitable areas in all of california any more. All the water a house needs in a day can be delivered for the price of a six pack. ..HG..

California is more out of control each year on almost all energy issues.

The lunatic fringe claims the RFA is "analogous to the NRA, which is currently fighting to keep lead bullets legal in Arizona even though they are poisoning California condors".

Corn ethanol is not a long term part of the solution to oil imports - cellulose ethanol is part of the solution.
In the mean time, corn ethanol can help preserve farm land and farms. The rise in corn prices has already abated, partly in response to lower oil prices due to a multitude of factors including, in a small way, corn ethanol.

The study in the Journal of Industrial Ecology by Liska et al. referenced in both this article and several postings (e.g., Aureon Kwolek) is one in a **series** of articles on corn ethanol (see www.wiley.com/go/cornethanol).

The series starts with the aforementioned article by Liska and colleagues (2009) that presents the Biofuel Energy Systems Simulator (BESS). BESS is a model developed at the University of Nebraska as a more updated alternative than the widely used GREET (Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation) model developed by the U.S. Argonne National Laboratory. Using BESS, Liska and colleagues estimate around 50% lower GHGs than gasoline for corn-ethanol—a twofold larger reduction than reported in some previous studies.

Plevin (2009a) critically compares the BESS and GREET models, exploring where differences arise and proposing improvements to both and estimating a much less dramatic improvement of corn-ethanol's greenhouse gas impacts than Liska and colleagues. A rejoinder from Liska and Cassman (2009a) accepts some of the modifications suggested by Plevin (2009a) while simultaneously raising several new issues that further reduce the estimate of GHGs attributable to corn-ethanol relative to gasoline. The scientific debate is put in context by a fourth article, an editorial by Anex and Lifset (2009a).

Plevin (2009b) takes issue with the response from Liska and Cassman in a letter to the editor which, not surprisingly, prompts a letter back (Liska and Cassman 2009b). The editors (Anex and Lifset 2009b) once again summarize and contextualize the debate in a postscript.

Because of the timeliness of this topic—and the high quality of the analyses—the articles are being made available for free download. You can obtain copies of the articles from www.wiley.com/go/cornethanol.

The Journal of Industrial Ecology is an international peer-reviewed bimonthly owned by Yale University, headquartered at the Yale School of Forestry & Environmental Studies and published by Wiley-Blackwell.

Sincerely,
Reid Lifset
Editor-in-chief
Journal of Industrial Ecology

References

Liska, A. J., H. S. Yang, V. R. Bremer, T. J. Klopfenstein, D. T. Walters, G. E. Erickson, and K. G. Cassman. 2009. Improvements in Life Cycle Energy Efficiency and Greenhouse Gas Emissions of Corn-Ethanol. Journal of Industrial Ecology 13(1): 58-74. DOI: 10.1111/j.1530-9290.2008.00105.x

Plevin, R. 2009a. Plevin, R. 2009. Modeling corn ethanol and climate: A critical comparison of the BESS and GREET models. Journal of Industrial Ecology 13(4): 495-507 DOI: 10.1111/j.1530-9290.2009.00138.x

Liska, A. and K. Cassman. 2009a. Response to Plevin: Implications for life cycle emissions regulations. Journal of Industrial Ecology 13(4): 508-513. DOI: 10.1111/j.1530-9290.2009.00146.x

Anex, R. and R. Lifset. 2009a. Assessing Corn Ethanol: Relevance and Responsibility. Journal of Industrial Ecology 13(4):479-482. DOI: 10.1111/j.1530-9290.2009.00152.x

Plevin, A. 2009b. Comment on "Response to Plevin: Implications for Life Cycle Emissions Regulations" Journal of Industrial Ecology 13(6). DOI: 10.1111/j.1530-9290.2009.00174.x

Liska, A. and K.G. Cassman. 2009b. Responses to "Comment on 'Response to Plevin: Implications for Life Cycle Emissions Regulations'" and "Assessing Corn Ethanol: Relevance and Responsibility" Journal of Industrial Ecology 13(4). DOI: 10.1111/j.1530-9290.2009.00187.x

Anex, R. and R. Lifset. 2009b. Post Script to the Corn Ethanol Debate: Reaching Consensus? Journal of Industrial Ecology 13(6). DOI: 10.1111/j.1530-9290.2009.00188.x

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