In a co-signed letter, the U.S. Ethanol Coalition, along with the Great Plains Institute, the Low Carbon Fuels Coalition, the National Biodiesel Board and the Canadian Oilseed Processors Association, have recommended that the California Air Resources Board recognize the climate benefits of agricultural practices in the California Low Carbon Fuel Standard. CAOT Board Member Ron Alverson submitted separately comments to CARB in response to requests for land-use change information.
Alverson draws CARB’s attention to the recent research paper “Biofuel Impacts of Food Prices Index and Land Use Change”, which he says shows “there is land use change related to land use change soil from biofuel feedstock, and that’s a positive, not a negative.” Alverson also explains how the food price index has the highest correlation with the price of crude oil, not biofuel. highlighted the discrepancies between model predictions and observed data, Alverson urges CARB to revise its assumptions predicting the impact of biofuels on food prices and indirect land use change.
This feedback complements the letter co-signed by the CAE, which provides principles for carbon intensity (CI) accounting at the farm level, originally developed under the job from the Midwestern Clean Fuels Initiative.
“…CARB would play a leadership role in promoting carbon-smart farming practices in all locations that grow feedstock for LCFS fuel pathways, accumulate knowledge on the short- and long-term effectiveness of various SCS [soil carbon sequestration] strategies and accelerate the achievement of California’s aggressive decarbonization goals,” the letter read.
Quantifying greenhouse gas (GHG) emissions for biofuel feedstocks from agricultural practices and assigning corresponding CI scores leads to major policy benefits, including:
- Compensate farmers, on a purely voluntary basis, for climate-smart agricultural practices; and
- Help achieve scale faster and deliver significant short-term GHG emission reductions compared to private programs with less attractive carbon prices for farmers.
The guiding principles outlined in the group letter to achieve these and other benefits include:
- On-farm conservation measures should be voluntary, not mandatory.
- Continuous improvements in climate-smart agricultural practices should be encouraged.
- Protocol design must strike a balance between accuracy and cost to farmers and growers. CARB should develop practice verification strategies that minimize costs where possible while ensuring results.
- GHG lifecycle assessment, including assessment of climate-smart scoping practices, should be non-proprietary, transparent, verifiable, and replicable.
Stakeholders are actively leveraging USDA funds to establish a quantification and verification protocol that could support CARB’s inclusion of on-farm carbon benefits. Comments quote Regional Conservation Partnership Program (RCPP) led by ACE in South Dakota, and broader efforts to replicate the program design to increase the scientific robustness of key soil models in various regions that could be used to access LCFS markets.