Ways and Means Should Include Job Creation of Advanced Biofuels and Bioproducts in Green Jobs Leg

On Wednesday, April 14 the House Ways and Means Committee will hold a hearing on Energy Tax Incentives Driving the Green Job Economy. The focus of the hearing is to examine the effectiveness of current energy tax policy and identify additional steps that the Committee can take to ensure continued job growth in this area while at the same time advancing national energy policy focus on a discussion of current and proposed energy tax incentives. Witnesses for this hearing have not been announced and we do not know how much of the hearing will focus on transportation fuels however, energy tax incentives for biofuels and biobased products should be a significant area of focus for this round of green jobs legislation. These technologies are ready to deploy and create near term job opportunities.

Industrial biotechnology is the key enabling technology for producing biofuels and biobased products like bioplastics and renewable chemicals to aid in reducing our dependence on foreign sources of oil, thereby reducing greenhouse gas emissions. They also have the ability to crate jobs, jobs that are currently moving overseas due to their reliance on petroleum as a feedstock or more favorable economic or political environments.

The United States has invested considerable amounts of taxpayer dollars to try to revive our economy. Too often, though, the resulting jobs are being created overseas, as other countries invest in green technology deployment. As a result, the opportunity to improve our economic competitiveness is lost. The United States is a leader in the research and development of green technologies, but to maintain that lead we must invest in the companies that are putting that green technology to work in our economy. These industries have shed hundreds of thousands of domestic jobs over the past two decades, as petroleum producing countries have attracted more capital investment. For example, U.S. chemical and plastics companies have increased capital investment outside the United States by 32 percent over the past decade, while increasing investment within U.S. borders by only 2 percent.

The Renewable Fuel Standard (RFS) enacted as part of the Energy Independence and Security Act of 2007 sets the minimum level of renewable fuel that must be produced and blended into the US transportation fuel supply at 36 billion gallons by 2022. 21 billion gallons of that requirement must be cellulosic or advanced biofuels. Direct job creation from the advanced and cellulosic biofuels volumes in the RFS could reach 29,000 by 2010, rising to 190,000 by 2022. Total job creation could reach 123,000 in 2010 and 807,000 by 2022. Jobs will be across many sectors of the economy. Some projected job creation sectors are: labor/freight, mixing and blending machine operators, shopping/receiving/traffic clerks, truck drivers, chemical equipment/technicians, chemical plant/system operators/electrical, sales etc.

The Ways and Means Committee can aid in accelerating this job creation by incentivizing biorefinery construction here in the United States. In 2008 Congress enacted a cellulosic biofuels production tax credit and enhanced depreciation for advanced biofuels facilities as part of the 2008 Farm Bill, both of which are scheduled to expire on December 31, 2012. Due to an overall downturn in the worldwide economy, this tax credit has not yet been utilized by cellulosic biofuels producers. This credit needs to be extended now in order to signal to investors that a plant being constructed this year, will have certainty in the availability of that tax credit once the plant begins to produce the advanced biofuel. A tax credit that expires before or shortly after production begins, does not create economic security for a yet to be built advanced biofuel biorefinery looking for funding. Furthermore, capital costs for construction of next generation biorefineries, which utilize renewable biomass to produce next generation biofuels and biobased products, are a substantial barrier to commercialization. Congress should provide an investment tax credit to help accelerate construction of next generation biorefineries and speed deployment of next generation fuels, chemicals and products.

Historically, the U.S. chemicals and plastics industry was the envy of the world. At its peak in the 1950s, the industry was responsible for over 5 million domestic jobs and a $20 billion positive trade balance for the United States. Jobs associated with the industry were typically among the highest paid in U.S. manufacturing. However, the petro-chemicals and plastics industries are now hemorrhaging jobs overseas. Conversely, biobased products and chemicals production, like domestically produced biofuels, will stay in the U.S., in close proximity to their biomass feedstocks. Total US employment in the chemicals industry declined by over 20% in the last two decades and is projected to decrease further. The US is a world leader in industrial biotechnology with a wide range of companies pioneering new, renewable pathways to traditional petroleum-based chemicals and plastics.

The potential job creation from bio-products is immense. Consider that the nascent biobased products industry employed over 5,700 Americans at 159 facilities in 2007 and every new job in the chemical industry creates 5.5 additional jobs elsewhere in the economy. Currently the biobased products portion represents only about 4 percent of all sales for the industry. Congress should create targeted production tax credits that can help them to expand their share of the market and grow additional domestic jobs. With an industry with the potential to grow by over 50% per year, bio-products can form the basis for a strong employment growth engine for the US.

Clearly commercializing the advanced biofuels and biobased products industries is an integral solution to creating high caliber domestic green jobs in the United States that will catapult this country to be a leader in successful high tech, sustainable technologies. BIO will be urging the Ways and Means Committee through written comments to recognize that innovations such as these are some of the most promising sources of green jobs and economic growth for the future.

Industrial and Environmental Biotech Weekly Blog Roundup

In industrial biotechnology this week the Wall Street Cheat Sheet says algae is the next great thing.

“Algae could be the most promising candidate yet for the future of the biofuels industry.

Although algae-based fuels won’t be commercially available for several years, algae offers several advantages over other first-generation renewable fuels, such as corn and soybeans. For example, algae grows faster, requires less resources, can be used as jet fuel, can use existing distribution systems, and absorbs carbon dioxide and other greenhouse gasses.”

The post closes with,

“All of this syncs up neatly with a White House concerned with climate change and looking to develop “green energy” technologies with long economic coattails.

While it may be too early to call algae the clear winner in the biofuels race, at least for now, the future of algae-based biofuels looks bright.”

The Biofuels Digest

writes about BIO’s recent Pacific Rim Summit,

“In Hawaii, at the BIO Pacific Rim Summit, Joule Biotechnologies announced that it has achieved direct microbial conversion of CO2 into hydrocarbons via engineered organisms, powered by solar energy.

Joule’s Helioculture process mixes sunlight and CO2 with highly engineered photo synthetic organisms, which are designed to secrete ethanol, diesel or other products.

However, unlike algae and other current biomass-derived fuels, the Helioculture process does not produce biomass, requires no agricultural feedstock and minimizes land and water use. It is also direct-to-product, so there is no lengthy extraction and/or refinement process.”

Sounds interesting, guess we’ll have to stay tuned.

Yesterday the DOE and the USDA announced,

“projects selected for more than $24 million in grants to research and develop technologies to produce biofuels, bioenergy and high-value biobased products. Of the $24.4 million announced today, DOE plans to invest up to $4.9 million with USDA contributing up to $19.5 million. Advanced biofuels produced through this funding are expected to reduce greenhouse gas emissions by at least 50 percent compared to fossil fuels.”

From Pacific Rim Summit: Specialty Crops, Renewable Feedstocks & Sustainability

This panel on the second day of the Summit consisted of Richard Gustafson from the University of Washington, Gillian Madill, an independent consultant representing views of the environmental NGO community and John Sheehan, from the Institute on the Environment at the University of Minnesota.

While Mr. Gustafson and Mr. Sheehan gave informative talks on lifecycle assessment modeling and sustainability issues, Ms. Madill lit up the room with her talk titled, “Environmental Concerns with Energy Biotechnologies.” Ms. Madill started the conversation with the assertion that the environmental community and the biofuels community have the same goal, to supply energy in a new way that preserves the environment and our earth. Renewable energy and technology are tools to get to that end.

The environmental community has several valid concerns over widespread biofuels production. They see biofuels as a transition technology on our way to an energy future less dependent on liquid fuels, some would say zero liquid fuels. Zero because of the belief that no biofuels are carbon neutral. The question asked by environmental groups is, Why incentivize an unsustainable industry? Some concerns raised by Ms. Madill on behalf of the environmental community include deforestation of sensitive lands such as rain forests, environmental degradation, incorporation and containment of genetically engineered crops and organisms and intellectual property protection.

The biofuels industry plans to be a sustainable industry, but it is a new industry on the verge of commercialization with a formidable competitor. Ms. Madill’s point was that the environmental community and industry, while striving for some common goals, are currently at odds.

As I expressed to Ms. Madill, at the heart of this debate is the fact that most of the controversy centers around land use and protecting sensitive ecosystems. If biofuels went away tomorrow, other industries would compete for those same sensitive areas. After all, solar and wind farms require significant acreage as well, not to mention building schools or highways or the new grocery store that just opened in your neighborhood. Any industry that has a footprint will at some point, one can only assume in a future low carbon world, be mandated to quantify their lifecycle assessment, including land use and potentially indirect international land use, as biofuels are today.

My suggestion would be to partner to serve the common goal, protection of our vital and sensitive areas and resources which are important and treasured by all.

Weekly Industrial and Environmental Bio Blog Roundup

This week we start off with a little Road Music, From Bluegrass to Switchgrass, from our colleagues at the Biofuels Center of North Carolina. They’ve put together a nice set of bluegrass pieces. To listen visit their web site.

Gas2.0 announces this week that BP could start selling biofuels in 2010, writing that,

“BP has partnered with Verenium to bring a commercial-scale cellulosic ethanol facility online next year to start bringing alternative fuels to a gas”

Wednesday, according to the Government Monitor,Tom Vilsack announced,

“the publication of nine additional BioPreferred product categories which will now be eligible for Federal procurement preference.”

Making, “more Than 1,000 Biobased Products Eligible For Federal Procurement,” the Monitor reports.

You can find USDA biopreferred on Twitter, http://twitter.com/BioPreferred and on the Web at: www.biopreferred.gov.

So what’s the deal with this conversation on whether or not biofuels are carbon friendly? We at BIO have certainly have had a lot to say on the matter and you can find all our opinions on our biofuels page.

However, our opinions aside, the folks at the journal Science, where the initial study and follow-up policy paper were published say that they are giving us the inside story, by holding a moderated conversation between Tim Searchinger and John Sheehan—kind of interesting, take a look for yourself.

That’s all for this week. See you next week!

Industrial and Environmental Biotech in the Blogosphere

This week we start off with a United Nations report that urges caution on biofuels. Green Inc, a New York Times blog writes,

“The study concluded that whether a biofuel is climate-friendly or not depends largely on whether it is based on crops or production residues. Biofuels of the latter category were generally considered beneficial for the environment, and generating electricity locally from waste materials was found — in most cases — to be more energy efficient than converting biomass to liquid fuels.”

This paper was also written about in the blog, Futurism Now, the post called, Biofuels Will Increase Global Warming According to Study

They explain,

“That is because the land required to plant fast-growing poplar trees and tropical grasses would displace food crops, and so drive deforestation to create more farmland, a powerful source of carbon emissions.”

Not so fast, check out the Sustainable Production of Biofuels.

And biofuels continues to be the topic of the week. The biofuel review writes this week about a report from the Imperial College of London. The report has an upbeat tone about the future of biofuels and The biofuel review ends their post with a quote from Clare Wenner, Head of Renewable Transport at the Renewable Energy Association that says,

“Imperial College London has verified the results which show that these fuels can be produced in a sustainable way. With the right legislative framework, including the implementation of environmental rules under the Directive, it will be possible to limit indirect land use effects. Land will always be used for food and fuel, and the overall balance of these impacts could be positive as far as food is concerned. In fact, it seems likely that wheat-based biofuels production will not affect the amount of wheat exported by the EU as a whole.”

Then it’s more biofuels from Creamer Media’s Engineering News

According to Engineering News,

“Pretreatment and gasification technologies are on the verge of making second-generation biofuels a commercial reality, according to new analysis from Frost & Sullivan, entitled ‘Worldwide Market Analysis of Second Generation Biofeedstock.”

Engineering news interviewed Frost & Sullivan senior research analyst Phani Raj Kumar Chinthapalli,

“The use of second-generation biofuels is expected to reduce 
the emission of greenhouse gases (GHG), particularly carbon 
dioxide (CO2), from combustion engines by 80% to 85% in comparison with conventional fossil fuels. The lifecycle emissions for second-generation biofuels are in the negative range, which implies consumption of CO2 rather than emission.”

That’s it for this week, see you next week.

Environmentalists Want to “Stick” It to Farmers

Jason Hill of the University of Minnesota’s Institute on the Environment wrote recently in the St. Paul Pioneer Press, asking why the Waxman-Markey climate change bill should treat agricultural emissions differently from energy and transportation emissions, with a “carrot-and-stick approach, one in which fossil fuels suffer the stick while agriculture feasts upon the carrot.” Hill’s primary objection to the bill is the amendments added by Rep. Collin Peterson (D-Minn.), which exempt agriculture and forestry from carbon caps but provide credits for carbon sequestration that farmers can trade on the market. They also would postpone implementation of the EPA’s analysis of international land use change.

Writes Hill, “Peterson’s amendment is essentially nothing more than a slick accounting trick, one meant to portray biofuels produced in this nation in a better light while making the carbon footprint of agriculture in developing countries look worse.”

This is a bizarre statement, turning even the theory of indirect land use change on its ear. The original calculation of indirect land use change put forward by Searchinger et al held that “when farmers use today’s good cropland to produce food, they help to avert greenhouse gasses from land use change.” Further, in the context of international negotiations for a climate change treaty to replace the Kyoto Protocol, the ILUC theory is clearly an attempt to shift accounting of carbon emissions in developing countries onto U.S. biofuels.

Calculations of land use change by current models are completely contradicted by agricultural trade and production numbers, making the models appear to be nothing more than accounting tricks. The model projections look nothing like real outcomes because they rely on several false premises and double count certain sources of emissions. The greatest fallacy of the ILUC theory is that worldwide agricultural productivity has already reached a natural limit and cannot respond to increased demand in any other way than clearing of rainforests. The main premise of the theory – that biofuels have been introduced into a static worldwide agricultural system and therefore are the primary cause of shifting agricultural production – is an assumption that can’t be supported by data.

Using USDA’s modest assumption for growth in yields of U.S. corn over the life of the Renewable Fuel Standard, a simple calculation shows that corn productivity can keep up with demand to produce the conventional biofuel portion of the RFS. This assumes continuation of 2016 to 2018 USDA projections for 2022 – constant total planted acreage of 90.5 million acres, increase of 75 million bushels per year for fuel ethanol, and increase of 1.8 bushel per acre per year yield improvement:

In fact, USDA currently projects a corn yield of 159.5 bushels per acre for this year. And USDA projections from January 2009 show that inclusion of biofuels will stabilize land use, in terms of the acres planted to the eight major crops:

Beyond this, and despite a report) that deforestation in Brazil increased in June, the deforestation rate in Brazil continues to decline. Responding to the Agence France-Presse report, Mongabay noted, “Deforestation in the Brazilian Amazon typically peaks during the June-August dry season when ranchers and farmers burn forest to clear land for development.”

A group of scholars – that includes Hill – recently called for a focus on real solutions to climate change. The world needs economic growth, energy and food. We should not premise our search for solutions on the false notion that these three necessities are in direct competition with each other.

The Facts of Life on Waxman-Markey

You take the good, you take the bad, you take them both and there you have … the Peterson amendment to the Waxman-Markey bill, formally known as H.R. 2454, the American Clean Energy and Security Act (ACES). According to Grist contributor Meredith Niles, there are a number of positive inclusions in the amendment that were advocated by environmental groups.

The good aspects, according to Niles, are those that will encourage improved agricultural practices. The bad part of the amendment is that the USDA – the agency whose mission is to promote both domestic agriculture (to keep it from moving overseas) and food safety – will oversee the implementation of these positive aspects.

Niles laments that “industrial agriculture interests are overtaking environmental interests in a bill that, again, is fundamentally meant to reduce greenhouse gas emissions.” No doubt, the agricultural interests have a similar lament about implementation of the Renewable Fuel Standard, which was intended to reduce reliance on oil. There is an interesting comment to Niles’ article by ecoplasm, who says, “Selecting ‘scientific’ analytical tools to meet some influence group’s desired result was a hallmark of the past administration’s EPA, hopefully not this one’s.”

A Scientific American assessment of the Waxman-Markey (Peterson) bill shows how much the “science” of indirect land use change has been affected by the rhetoric from environmental NGOs. The article asks, “Should Domestic Ethanol Producers Pay for Deforestation Abroad?,” and states plainly, “the question is not whether there are indirect impacts but rather how big they are.” The reality is that this assumption about indirect land use change – that it will inevitably occur – is built into the model EPA uses to measure it. It’s a perfect example of selecting a ‘scientific’ analytical tool to achieve an influence group’s desired result.

The Peterson amendment proposes a study by the National Academies on indirect land use change. No doubt, another example of carefully selecting an analytical tool. The 2007 EISA bill also contains a provision for the National Academies to study the issue, though funding for the study has never been authorized.

The science on indirect land use change will continue to develop (is currently continuing to develop). The real issues will be whether there are any positive moves toward reducing greenhouse gas emissions once all the politics are done.

Don’t Worry, Be Happy

The EPA has released its long-awaited proposed rules for the Renewable Fuel Standard, including calculations of the lifecycle greenhouse gas emissions for various biofuels. Unlike California, the EPA is proposing to “discount” the greenhouse gas emissions of both biofuels and the baseline petroleum gasoline. The discount rate that EPA uses for most of the calculations it presents is 2 percent over 100 years, although it also proposes using a 0 percent discount rate and a 30-year time span and is taking comments on other combinations. Biofuel critics immediately decried the use of the 100-year timeframe because the resulting calculation produces a better outcome for biofuels.

Denver Post columnist Vincent Carroll writes:

But the mere fact that it would consider measuring ethanol’s carbon impact over 100 years — or should we say guessing at it? — is evidence enough of the ethanol lobby’s stature.”

And the Washington Post’s Juliet Eilperin and Steve Mufson report:

The EPA raised the possibility of computing greenhouse gas costs over a 100-year period instead of a 30-year period. The longer time frame would make the benefits of corn-based ethanol seem greater while discounting the initial costs, such as the loss of untilled land, over time. For example, the EPA said corn-based ethanol is 16 percent better than regular gasoline if its costs are calculated over 100 years, but 5 percent worse over 30 years.
‘EPA has left open the option that an exception to good science could be made in the case of a favored special interest,’ said Frank O’Donnell, who heads Clean Air Watch.”

Both biofuel supporters and detractors should be wary of these calculations and of the precedent they could set. It’s abundantly clear that few people understand what the numbers mean.

The timeframe being discussed is for application of a “foregone sequestration” penalty — the number of years that converted land is considered to be foregoing its preferred use for carbon sequestration as forest or grassland. This penalty is added over and above the initial assumed release of carbon from conversion of the land (and note that there is no comparable penalty for not leaving petroleum carbon “sequestered” underground). Under normal circumstances, industry would prefer a short timespan – fewer than 30 years. After this period, the land would be considered agricultural land rather than former forest and would no longer accumulate a carbon penalty.

The choice of a discount rate is intended to measure present day valuations of costs and benefits over time. So, what are the costs and benefits of reducing greenhouse gas emissions that EPA is discounting? In the analysis, it is the cost of converting forest and grassland to agricultural land in order to obtain the benefit of reducing greenhouse gas emissions from transportation in the future – the “payback”. What the EPA should have measured, though, is the cost of converting our petroleum-based system of transportation to a biomass-based one versus the benefits of reducing greenhouse gas emissions.

The results in the EPA’s proposed rule are skewed by two indefensible assumptions. First is the assumption that the baseline for greenhouse gas emissions from petroleum should be discounted. The law requires establishment of a baseline for gasoline in 2005. To apply a discount rate assumes that the baseline will improve by some rate of change over time. And since petroleum is not assessed a foregone sequestration penalty, the cost of taking carbon from well below ground and putting it into the air is essentially free.

A positive discount rate says that future reductions in greenhouse gas emissions are less important to Americans than the present day costs. Since EPA applies the discount to the petroleum baseline, it is in effect saying that Americans will care less and less about reducing greenhouse gas emissions over time if it means that they have to change their driving habits today. In other words, don’t worry, keep using petroleum and be happy.

Second is the assumption that biofuels are causing land conversion around the world and that the land conversion is always and everywhere accomplished by burning the ground cover and immediately releasing massive amounts of carbon. This unfounded and unproven assumption skews the results of the analysis to the point that the application of a highly unfavorable discount rate appears to benefit the industry and draws the wrath of environmental advocates.

But the reaction from O’Donnell and Carroll shows that biofuel opponents will decry any outcome as politics trumping science — unless it’s their politics that trump science.

Controversy on Discounting Greenhouse Gas Emissions

On March 13, Sens. Tom Harkin (D-Iowa) and Charles Grassley (R-Iowa) along with 10 others sent a new letter to EPA Administrator Lisa Jackson urging “EPA to refrain from including any calculations of the ILUC components in determining life-cycle GHG emissions for biofuels at this time.” The new letter referenced a letter sent in November to then-Administrator Stephen Johnson, which was signed by four of the current 12 signers as well as then Sen. (now Interior Secretary) Ken Salazar.

The latest letter argues that quantification of indirect land use change is difficult because there are many factors that affect it. Current models do not take into account the many causes of land use change or their overlapping effects. California’s recently proposed rule on the life cycle accounting shows how difficult it can be. While California’s Air Resources Board staff use modeling that relies on an assumption that use of land to grow crops for biofuels will push agricultural production to other countries and that this effect can be estimated through use of a general equilibrium market model, they acknowledge that the prediction is inconsistent with actual trade data.

The Senators wisely say,

It is possible that future domestic and international climate change policies will include major provisions restricting land use changes. Indeed, that may be the most appropriate and effective way to reduce GHG emissions associated with land use changes.”

The group also raises the issue of the use of a discount rate in the analysis of the reductions of greenhouse gases attributed to both biofuels and gasoline. (See earlier post on discounting.)

Michael J. Roberts, and Agricultural Resource Economist at North Carolina State University, makes a case for setting the discount rate at zero:

I have no idea how much we should spend reducing GHG emissions because I have no idea how costly reductions would be, the costs should warming occur, or how GHG affects all the possibilities. But I think a low discount rate, in the ballpark of zero, should be used when weighing current expenditures to future expected benefits.”

So how costly might reducing GHG emissions through use of advanced biofuels be? Sandia National Laboratories’ 90 Billion Gallon Biofuel Deployment Study suggests that the infrastructure costs of developing a large-scale advanced biofuels industry are essentially equivalent to those of drilling for more oil in U.S. onshore locations such as ANWR and the Rockies.

Use of a discount rate of any sort in the EPA rule seems highly inappropriate. It is well-noted that the choice of a discount rate can greatly affect the outcome of a cost-benefit comparison. But consider that the Renewable Fuel Standard requires biofuels to achieve a percentage reduction in greenhouse gas emissions compared to a gasoline baseline. The use of a discount rate on both biofuels and the gasoline baseline arbitrarily closes the gap between the two, understating both the costs of gasoline and the benefits of biofuels.

California Proposes Numbers for Indirect Land Use Change Emissions

California issued a staff report last week for its “Proposed Regulation to Implement the Low Carbon Fuel Standard.” As expected, the rule proposes a measure of indirect land use change emissions for select biofuels – corn and sugarcane ethanol and soy biodiesel. The report defines the assumptions behind the analysis – in a word, that use of existing crops for biofuels reduces supplies, increases prices, and thereby induces agricultural expansion:

Land use change effects occur when the acreage of agricultural production is expanded to support increased biofuel production. Lands in both agricultural and non-agricultural uses may be converted to the cultivation of biofuel crops. Some land use change impacts are indirect or secondary. When biofuel crops are grown on acreage formerly devoted to food and livestock feed production, supplies of the affected food and feed commodities are reduced. These reduced supplies lead to increased prices, which, in turn, stimulate the conversion of non-agricultural lands to agricultural uses. The land conversions may occur both domestically and internationally as trading partners attempt to make up for reduced imports from the United States. The land use change will result in increased GHG emissions from the release of carbon sequestered in soils and land cover vegetation.”

In addition to releases of 90 percent of above-ground carbon in the first year, and 25 percent of below-ground carbon over a period of 30 years, the ILUC penalty calculated by California says, “The carbon that would have been sequestered in the lost cover vegetation is also included in the total emissions value.”

A letter signed by more than 100 researchers and biofuel company executives and sent to California Gov. Schwarzenegger on March 2 calls the analysis being conducted by California “unusually sensitive to the assumptions made by the researchers conducting the model runs.” It also points out that the concept of an indirect effect is only being proposed for biofuels, even though, “Petroleum, for example, has a price-induced effect on commodities, the agricultural sector and other markets.”

California’s analysis does account for the direct land use change effects of oil drilling – within California. However, despite an acknowledgment that, “The cost of energy appears to have been the largest contributor” to the recent sharp increase in corn prices, the report does not analyze the possible indirect land use effect of that oil price shock.

Further, the report indicates that the evidence one would expect to see of indirect land use change caused by using corn for biofuels is lacking:

The model predicts, for example, that the expanded use of domestic corn for the production of ethanol will reduce U.S. corn exports. That prediction appears to be inconsistent with the actual trade data appearing in Appendix C. Those data show that the production of corn, soybeans and wheat in the United States has generally been on the increase over the last decade. Exports meanwhile have remained relatively steady. In the case of corn, production increases have been sufficient to supply the ethanol industry while maintaining export levels.”

So, despite any inconvenient contrary evidence, California’s Air Resources Board concludes precisely what it assumes from the beginning – that Midwest corn ethanol emits more CO2 than California gasoline.

Dr. Robert Brown of the Iowa State University Bioeconomy Institute gave an interview to Brownfield Network to discuss the letter sent by the academics. Dr. Brown notes that California is formulating policy on conjecture — not even a testable hypothesis. Listen to the entire interview here.