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Perspective: Indirect Land Use Change Analysis Is Not Life Cycle Analysis

Perspective by Professor Bruce Dale, Michigan State University

I have worked for over 30 years to develop cellulosic biofuels, so I am not particularly interested in corn ethanol. I am, however, very interested in using life cycle analysis (LCA) to show how the environmental performance of biofuels can be improved. Thus a recent life cycle study on corn ethanol plants caught my eye.

Plants built since 2004 reduce ethanol’s life cycle greenhouse gas (GHG) emissions by 50-60% compared to gasoline. These plants represent about 75% of current ethanol capacity and stand in stark contrast to older ethanol plants that achieved only about 20% GHG reductions.

The paper was published in the Journal of Industrial Ecology, one of the two “gold standard” journals for LCA research. The study is meticulous and detailed, and uses the most recent data available from real corn dry mills. While it represents a sort of “best case” set of scenarios for newer plants, it does show what is possible with corn ethanol.

Innovation and technological improvement (e.g., thermo-compressors for heat reuse, raw starch hydrolysis, collocating with animal feeding operations) dramatically improve the GHG emissions of these plants versus those built prior to 2004. Over time, the best case ought to become the norm. This study provides guidance to help make that can happen—which is precisely the purpose of LCA.

A recent blog criticized the paper for dealing only with direct GHG emissions, not those from so-called indirect land use change (ILUC) analysis. This criticism is uninformed.

The logic behind ILUC is that increased demand for corn for ethanol will lead, through increased prices, to more crops being planted elsewhere. The planting of these crops may cause land clearing and subsequent GHG release. Note that these hypothetical crops are not part of the actual biofuel life cycle. They are part of the life cycle of other products. ILUC theory proposes that these crops become part of the biofuel life cycle.

Why all this emphasis on LCA? Because the Energy Independence and Security Act of 2007 requires the use of life cycle methods to determine the GHG performance of renewable fuels. If LCA is to help us improve biofuel performance, we must use it within its limits.  LCA has strict standards regarding technical issues such as system boundaries and allocation. ILUC simply does not meet these standards; it goes well beyond the limits of LCA. Whatever else ILUC may be, it is not life cycle analysis.

Bruce E. Dale, Ph. D.
Distinguished University Professor
Dept. of Chemical Engineering & Materials Science
Rm. 3247 Engineering Building
Michigan State University
East Lansing, MI 48824


Raymond Bonnaterre

A just and very fair comment on a very good job!


The point of ILUC is to understand the net climate impacts of biofuels policies (by addressing relevant factors not included in LCA)- which cannot be determined through LCA.

Different tools for different purposes.

richard schumacher

In his final paragraph it sounds as though Professor Dale is arguing that we should use not the tool which gives the most comprehensive and complete answer, but instead the one which is legally mandated. I hope I'm mistaken, because that is not science and it does not serve truth.

A D Bryan

What Prof.Dale does not mention is that estimating the probability of land use change and quantifying the results of different scenarios is very difficult at this point. Nevertheless, given that the intent of LCA is to identify the relative impacts on greenhouse gas emissions from various alternatives so that we may chart the wisest course, it makes a folly of the process to include some impacts but ignore others. We must do our best to advance the science and evaluate all impacts while making the uncertainties clear.

David Ahlport

So basically what he's saying is that because something's damage is difficult to exactly quantify right now, we should legally just assume that the damage done is ZERO.

That's a rather irresponsible argument to make.

David Ahlport


Also apparently it seems that the concept of readdressing this issue with a "National Low Carbon Fuel Standard", i.e. A law written by the Obama Administration.

David Ahlport

Also apparently it seems that the concept of readdressing this issue with a "National Low Carbon Fuel Standard", i.e. A law written by the Obama Administration.


Actualy the point is its the life cycle problem of that OTHER product not biofuel.

Pascal Lesage

The comment above is based on a very narrow (attributional) vision of life cycle assessment, and ignores the work that has been piling up over the last decade on LCA methodology aimed at evaluating the environmental consequences of LCA (consequential LCA).

Given the question that is being addressed here, what is obviously important is to capture the environmental consequences of investment in corn ethanol, regardless of whether or not they occur within the (often arbitrarily defined) boudaries of the life cycle of ethanol per se.

This said, I have seen other comments made by Prof. Dale about the uncertainty associated with the models used to evaluate iLUC that were very well argued.

It seems that this uncertainty should encourage further research in determining iLUC and good uncertainty/sensitivity analysis, not the exclusion of this potentially extremely important issue.


Well my point is for a certain case. Such as say america starts using more of its food crops for fuel and that results in some other country growing more of its own food or more food for export. Its not america's ghg anymore at that point.

But say america turns 5 zillion tons worth of ghg co2 burping crops into fuel saving .5 grams of co2 in the process and then more americans grow more crops on new/formerly fallow fields and add 62 bajillion grams of co2 per year to the balance... Who needs to get the thwapping? The fuel grower or the new grower? Who upped america's co2 by 61.999999...5 bajillion grams per year? and maybe has to pay for that by planting 61 trillion trees and a shrubbery?

In this case however its rather simple. We lower our own co2 by making food into fuel and the increases in co2 elsewhere are elsewhere and that other countries ghg problem. Just because we were feeding the world when this ghg budget was started does not mean we have to keep doing so.

Bruce Dale

Dear Colleagues:
Thank you for your comments. I hope my response below is not too long and addresses most of your concerns and criticisms.

I have three fundamental objections to indirect effects analysis, of which indirect land use change is only one example. First, indirect effects analysis does not make the "polluter pay". It makes one person or organization responsible for someone else's pollution. I believe this is wrong in principle and tends to discourage rather than encourage environmentally responsible behavior.

Second, indirect land use change analysis in particular is very new and the results are highly variable. Recent work by my group combined with work by Dr. Lee Lynd's group at Dartmouth indicate that the "payback period" for land use change can be negative (not only no "carbon debt" but a credit instead) if: 1) productive use is made of standing forest biomass prior to the land change event and 2) better land management practices (reduced till and cover crops) are followed after the land conversion event. When different analyses give "payback periods" varying from -30 years (carbon credit) to +100 years (carbon debt) it seems to me that the tool is not ready yet for regulatory use.

Third, even if indirect land use change analysis were ready for use, there would not be any intellectual or ethical justification for applying indirect effects analysis selectively against biofuels. If we are going to properly compare all fuels, then we must look at the indirect effects of other transportation fuel pathways. Potential land use change is only one possible indirect greenhouse gas effect. For example, what are the indirect greenhouse gas effects of using more nickel for electric vehicles? What if new nickel mines must be opened in Africa, for example, to meet the additional demand for nickel? As far as I know, that question has not been addressed at all. It is not fair nor rational to assess indirect greenhouse gas effects against biofuels and not against other fuels.

I look forward to your thoughts.


Kit P

Thanks Professor Bruce Dale. LCA is an important tool along with other industrial ecology tools to reduce the environmental impact of producing the energy.

However, the intervenor industry is pretty much against everything that works. What about this what about that, too many unanswered questions?

What producers need is practical information that LCA provides. I have no problem considering iLUC but it would appear that it is being used a smoke screen.

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