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Perspective: Shoddy Environmental Bookkeeping—Biofuels and Indirect Land Use Change

Perspective by Professor Bruce Dale, Michigan State University

Until early last year, it was widely accepted that biofuels such as ethanol significantly reduce total greenhouse gas (GHG) emissions compared to gasoline. Then, a high-profile study using indirect land use change (ILUC) analysis suggested biofuels may have worse GHG performance than petroleum-based fuels. An uproar resulted in the related academic and business communities. Today, the issue is still far from resolved.

The basic idea behind ILUC is that biofuels use crops that might otherwise go to traditional uses, such as animal feed. The world agricultural system responds to this “loss” by replacing the production. During this replacement process, new lands might be cleared for agriculture, resulting in very large GHG releases (e.g. from burning tropical forests). This hypothetical GHG release is called the “carbon debt”. This “ah-hah moment” was embraced by critics of biofuels.

What is important to understand here is that ILUC is not based on the actual biofuel supply chain. If land is cleared to produce a given biofuel, then that effect is already included in the biofuel’s lifecycle GHG emissions. Instead, the GHG emissions from land use changes are actually due to making other products. ILUC proposes that these GHG emissions be counted as part of the biofuel life cycle.

This is shoddy bookkeeping. To put it mildly, ILUC analysis is difficult and depends on numerous assumptions. Varying these assumptions can change the resulting “carbon debt” from negative (net GHG release) to positive (no net GHG emissions). Instead of focusing on the technical details, however, let’s consider two market examples and one policy example of indirect effects analysis. These illustrate the controversial premise behind indirect effects analysis, of which indirect land use analysis is just one example.

Let’s say an automaker makes more battery-powered electric vehicles, thus using more nickel for the batteries. To be environmentally accountable, the GHG effects of mining that nickel are charged against the vehicle. Fair enough, you think? Not so. The automaker has taken some nickel off the market. By indirect effects, the automaker is now also responsible for the GHG emissions of a hypothetical new mine to make up for the nickel it used. The automaker therefore is “charged” twice, once for the nickel it uses in the batteries, and again for the replacement nickel someone else will use.

Take another marketplace example. Battery-operated vehicle use rises, and therefore electricity consumption rises. Although renewable electricity sources exist, the electricity “lost” for other uses by increased transportation demand must be replaced. Indirect effects analysis concludes that a new coal-burning power plant will supply the lost electricity, with a huge resulting GHG release. The battery-operated vehicle is therefore charged twice for GHG emissions, once for the electricity it actually uses, and again for the new electricity that someone else will use.

Finally, let’s look at a policy example. Congress decides to protect environmentally sensitive lands currently in crop production by offering financial incentives to farmers not to farm these lands. Environmentalists and farmers rejoice. Everyone is happy, right? Not so fast. By removing these lands from crop production, Congress has “caused” the world agricultural system to replace the lost crops. Replacing these lost crops results in large GHG releases, just like biofuel production supposedly did.

This is the logic of indirect effects analysis. The polluter does not pay. Those who actually create the additional pollution are not held accountable for their actions. Someone else is left to foot the carbon bill—twice. Talk about shoddy bookkeeping.

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



Can someone direct me to the high profile study discussing ILUC's mentioned in the first paragraph, I'd be interested in reading it.

This sounds similar to the seemingly backwards logic that if you want to protect forests you should buy more lumber and paper because that will raise demand for wood products and increase prices, which means people will more likely plant trees instead of food crops on cleared land. But then, the supply of food crops will diminish due to the forests being planted, putting pressure on clearing further virgin forest land for food production. It's all a very convoluted interconnected chain of events when you have limited land for producing things people need. The bottom line is, there are too many people on this planet and all the efficiency gains in the world aren't going to save us if population growth doesn't stop.


I do not support corn nor soy bio fuels. The cellulose from crop waste is more than enough to go on. We do not need to use more land nor food crops. NO the land does NOT need all the biomass, only half. Let's stop the circular arguments. We need to get on with alternatives now, before it is much too late.


I agree with the comments about population growth Mark...and also stop the sanctuary cities in America, create a stronger border, and create more incentives for ecosystem preservation (land trusts, conservation programs). Tell the Brazilians to stop the clearing of the rainforest!


I most certainly agree with the good professor. I've long said that the carbon cost of producing some biofuels far outweigh any advantage of having portable fuel.

I go one step farther: The carbon cost of wind-farms will never break even over their lifetime. Several schools and universities have proven this over and over.

Some things are acceptable when better alternatives are not available. Right now we have not found all possible alternatives and should be doing a "Moon shot" effort.

I am personally convinced that diesel fuel from Algae is the place to put our development money.


We are currently adding a net 220,000 mouths per day, every day. It's more than the entire population of California, Texas and New York combined, per year. I'm 42, by the time I retire the world will be approaching 10 Billion. For referrence, there was just 3 billion people when I was born.

You better look around now, because in two more decades, there won't be much open land left.


The failing of indirect land use is that it forgets that if you DONT go corn biofuel your going something else wich also again changes the ghg picture.

If we werent producing corn biofuels the world would have to be replacing the oil we would be using.

Roger Davis

Sorry Prof. Dale, but the logic of some of your arguments here escapes me.

Assuming you are talking about biofuel which is a diversion from the food supply (as opposed to forestry waste, algae grown in the desert, etc.) it's essentially the same thing whether the biofuels producers themselves clear a new plot of land to grow corn, or take the corn from an existing plot and thereby force those of us who enjoy eating to clear a new plot ourselves to make up for what you've removed from the food supply. Your arguments provide exactly zero explanation of why these two scenarios should be treated differently. In both cases, a new plot of land is cleared, the same amount of fuel is produced, and the same number of people continue eating. And more importantly, in both cases the clearing of the new plot is directly caused by the new biofuel production.

Your argument about nickel for EV batteries is similarly opaque. Exactly where do you think the nickel comes from? AFAIK it's not brought by fairies, but does in fact come from a mine. If you are going to make a GHG comparison between an EV and an ICE you have to account for anything required by one that is not required by the other. That means comparing the GHG for the EV's nickel against the GHG for the oversized engine, etc. of the ICE. Certainly I agree that the EV should not be charged twice for its nickel, but you are saying that it should not even be charged once:

"To be environmentally accountable, the GHG effects of mining that nickel are charged against the vehicle. Fair enough, you think? Not so."

Disclaimer -- I am a big supporter of EVs, and a serious detractor of biofuels diverted from food.

Your comments about electricity consumption for EVs are less problematic to me but overly simplistic. I agree that it is grossly unfair for an analyst to blindly assume that the EV's electrons will come from coal. On the other hand it would be stupendously naive to assume that none of them will, especially in the short term. I believe that there is enough renewable resource out there to eventually supply our EV transport needs as well as our more traditional electrical needs, but it's quite likely that peak oil will force us to increase coal consumption in the near term. Is this a reason to abandon EV's? Absolutely not, as oil is nearly done for and biofuels can never meet the demand, but we shouldn't delude ourselves about what is likely to happen in the near term.


Ignoring ILUC is bad accounting too.  If you radically increase the demand for biomass, it's got to come from somewhere.  If a million acres of rainforest are cleared, it doesn't matter if the land grows sugar cane for fuel ethanol or soybeans to feed cattle because American corn went to make ethanol instead; it is the increment in net demand that is responsible, not the particular use of any given plot.

There is also the fact that certain areas have already been cleared.  They are a "sunk cost" in carbon terms.  It doesn't mean that clearing new areas has no cost, and reforesting land yields a carbon bonus.

What [I]LUC analysis indicates is that some courses of action are far better than others.  The productivity of most all plants is so low that we would be fools to try to feed our petroleum habit with fuels derived from them.  We're far better off using e.g. solar PV over existing roofs and pavement to supply energy, because the energy yield per unit area is far higher and we can make do with land that's already been converted.


I agree with EP and I would like to add; it's not a matter of "if" ILUC should be included in LCA but "when" it should. Sure you don't want to assign a double charge to one stakeholder over another but if you are trying to decide on which path the country, as a whole, should take, a decision that includes all the stakeholders as one, you have to look at LCA with ILUC.

Kit P

LCA is part of a systematic approach that producers of the societies needs use to accomplish production with less environmental impact. Farmer is places Iowa with clean air making ethanol by minimizing the impact on their environment.

Then you have Southern California loons like E-P and SJC who do not produce anything and insist on living with too many other folks so that their POV impacts air quality. They want EVs. No body is stopping the loons from having EVs and cleaning up their air.

The loons who never get anything done want Iowa farmers to consider what happens in Brazil. Go figure. Some body explain why environmental failures who live in a cesspool are against productive people taking care of their environment.


Kit P,

Take your ranting and spewing insults somewhere else. Personal attacks are prohibited here, or didn't you read the terms. Shut the heck up or I will see if I can get you banned permanently.


The comedy never stops!

Then you have Southern California loons like E-P
Furthest west I've ever lived for more than a week was Austin, Texas.  Home is Michigan, center of the US auto industry (in which I've spent about half my working life).
who do not produce anything
Well, if you don't count CARS and their components, or heavy vehicles, or aircraft subsystems....
and insist on living with too many other folks so that their POV impacts air quality.
Waitaminnit, isn't Twit P the one who drives almost exclusively very short hauls in his ICE car, so that his catalytic converter probably takes half his journey to get to light-off temperature?  What's that doing to his local air quality?

It is to laugh, really.

Kit P

“What's that doing to his local air quality?”

Nothing! My air quality is good. My POVs have pollution controls because they are standard equipment needed for California cities not because they are needed where I live. I do not have a proble with reducing emissions, just those who do not understand environmental impact.

“Home is Michigan, center of the US auto industry (in which I've spent about half my working life).”

Interesting choice of words. How long have you been part of productive society being paid as an engineer? How long did you go to school in California?

I have to give E-P credit. I did not think he would last winter in Michigan. E-P did you figure the importance of 4wd and ground clearance yet?

As an adult, I worked two years in Michigan after working in Spain before moving to California. The air quality was good where I lived in Michigan too. This was not always the case. Before joining the navy I lived in big Midwest cities. Snowing gray was normal. Where I lived in Spain the air qulaity was also good. However, cities like Madrid had a terrible pollution because they were behind the US in switching to catalytic converters.

When I moved to California, I chose a place to live that was above the smog. All told, I have been in and out of California since 1960. The point is that I am qualified to label folks by training and experience.

First there is clueless in California. Do not get mad at me, I did not coin the term. If you move to a cold climate have to ask me what my ice scraper is, you are clueless.

Then there is a subspecies that I call California loons. You wear flip flops and can not image why solar power can keep a family from freezing to death when it is 30 below in the middle of the night.

This is what I want you to do E-P. Get out of the city and drive over to Indiana or Ohio and find a Ethanol plant in a small town. Tell them you are an engineer trained in California and you think ethanol is stupid. Report back what you learn.


"You wear flip flops and can not image why solar power can['t] keep a family from freezing to death when it is 30 below in the middle of the night."

Well winters in Maine can get pretty harsh and I know of one solar powered family that hasn't froze to death;
I also have a solar powered buddy in Alaska - but he doesn't have a web-site.

Kit P


Usually you do better research.
From the web site:

“Solar is more expensive than a conventional home, but...”

No really!If you look at the picture of the house you will see an example of extravagant wasteful living. It is none of by business but it is certainly what I call protecting the environment.

No or no loon?

Loon says, “how we harvest FREE energy from the sun!”

Kit check loon's facts, Loon produces $550 of electricity per year which would result in a payback period of 36 years assuming no maintenance, no interest.

IMO, only a loon would call that free.

And why have they not frozen to death.

Loon says

“A 2 kW system will likely not power your full home unless you've done significant load reduction (gas/propane water heater, dryer and cooking stove) and have installed energy efficient appliances.”


“Propane provides any necessary backup as well as gas for cooking and clothes drying.”

While loon talks about somebody else's heating bill, he neglects to mention his own cost.

For the record, when I lived in that part of the country; I heated with a wood boiler as did my neighbors. Location appropriate renewable energy.


"Usually you do better research."

It's not my research that's the problem, it's your ideology. It prevents you from seeing the point.

Kit P

You are close ai_vin when you talk about my ideology which includes LCA to make better location environmental choices. If fact I would suggest that we share the same ideology.

However, ILUC is about blowing smoke. It is not making location specific choices. When I lived in California, I built a house with many of the features of the house in Maine. When I lived where it got to 40 below, I used a wood boiler for heat.

Maybe you do have much personal experience with California loons. When I built my house in 1986, looney regulations dictated that I build a Michigan house with few windows to save money. It included a passive solar and thermal mass. I had a friend with who did something similar and called it a Monterey. He has problems with the loons too. To resolve my problem, I had the my architect label my south facing windows solar collectors and provided 37 pages of alternate calculations. When I took my plans back into the county, they were approved.

The point here is that loons want regulation to tell people in other places what to do. The loons think the whole world is polluted because they live in a cesspool of their creation. I have lived where E-P and and SJC have lived and reject that life style. If they want to live where it is polluted fine with me.

It is a case of BYOB.


Of course this entire discussion is predicated on acceptance of the idea that the 10-15% component of GHG (CO2) is a "pollutant." Since just 3-4% of that CO2 is man made (e.g. resulting from land use issues)- it is apparent that GHG is not the correct concern for the Professor.

The real concern, voiced by MarkBC, is population. The Professor disingenuously attempts to frame his argument as an environmental one - when his real concern is population and consumption of resources. Given that GHG and global warming arguments garner increasing disfavor - it is high time that the AGW faction come forward and, like MarkBC, state their real fears: population. Better get it out in the open before the window is lost to the crash of AGW.

While there is little credibility left from the AGW debacle - population is a REAL concern. But the damage done may be irreversible. Only by starting now to state clearly what the real issue is - do any environmental concerns stand a chance. The hill is long and steep - since anything offered by AGW factions will summarily dismissed.

Unfortuantely, the bed has been made.


We are all biased. The author of this post loves the concept of biofuels and is trying to make an argument for them. All any of us have are the strengths of our arguments. I find his argument extremely weak.

Common sense suggests that if you put an area of arable land the size of Indiana into our gas tanks, as we did last year, that this will send a price signal to farmers around the globe to plant more. The new science simply verifies that this indeed is what happens.

This link summarizes much of that science:


This link is my attempt to put the magnitude of the probem into perspective with graphics instead of numbers:


It may be a moot argument (without even more government support) as biofuels do not appear viable economically. Last summer they were going bankrupt because of the high price of their feed stock (food). The price of oil was also at an all time high and in theory this is when they should have been most profitable. Now, with oil prices low, they are still going bankrupt.

Here is a death watch for refineries:




Oh, and as far as using conservation reserve land, read this recent research paper:


Land set aside to grow fallow would have…

"..a greater net GHG savings than having the same plots under corn ethanol production for at least four decades"

Kit P

“We are all biased.”

Which is why we use LCA to evaluate performance of project that are required to pass regulatory requirements.

Interesting choice of words. How long have you been part of productive society being paid as an engineer?
Essentially all of my working life.
How long did you go to school in California?
I have never gone to school in California.  I have done things like walking a mile across campus in 20-below conditions and didn't consider myself special.
I have to give E-P credit. I did not think he would last winter in Michigan.
So far I've weathered all but three of them here (and one of those was in Rochester, NY, which I didn't think was notably different).  I find it most amusing that a Californian is complaining about the weather way the heck over here, when I'm not.
E-P did you figure the importance of 4wd and ground clearance yet?
I have never owned a 4wd vehicle and drove a Dodge Daytona turbo through 7 Michigan winters (also once through Donner Pass in a snowstorm).  People who "need" SUVs are wussified.
This is what I want you to do E-P. Get out of the city and drive over to Indiana or Ohio and find a Ethanol plant in a small town. Tell them you are an engineer trained in California and you think ethanol is stupid.
Why would I lie?  I've already had the "ethanol is stupid" argument, and proved to my satisfaction that it is impossible to get people to understand something when their livelihoods depend on not understanding it.  Kind of like you, actually.
Kit P

Sorry E-P, you sure come across as a California surfer dude.

Like I said, I always find it interesting when someone refuses to answer a simple question.

How many days have you been working as an engineer? It is okay to be inexperienced.

Except for some extension courses and the Navy, I have not gone to school in California.

“I have done things like walking a mile across campus in 20-below conditions and didn't consider myself special.”

Well no E-P, that would not make you special. That was normal. Where I grew up, walking to school was normal. The farthest for me was 7th grade and 30 below was normal. I also had 10 years work experience before getting my engineering degree and 30 years since.

“Why would I lie?”

Not asking you to lie, I am asking you to open your mind the possibility that there are numerous good engineering choices.

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