Comment Log Display

The production of crop-based biofuels uses too much land, water and
harmful chemicals to justify the subsidies it receives.  We at
Climate Action California (CAC) support removing corn ethanol and
biomass-based diesel from california's LCFS program.  This could
help to reduce the amount of corn and soybeans produced by
monoculture farming in the US, and increase the amount of rural
land set aside for conservation or for organic or diversified
farming. These changes could help to mitigate the climate,
groundwater and biodiversity crises our rural areas are currently
facing. 

The outsized negative effects of federal and state subsidies for
crop-based biofuels are highlighted below.

1. Crops grown for the production of ethanol (corn) and biodiesel
and renewable diesel (soybeans) cover about 20% of the entire
cropland acreage in the US. According to the USDA's 2017 Census of
Agriculture (results from the 2022 Census are not yet available)
320 million acres of cropland were harvested in 2017. Over half of
the harvested acres were planted in either corn (almost 91 million
acres) or soybeans (90 million acres). According to the USDA's
Economic Research Service 45% of corn harvested in the US is used
to produce ethanol and about 21% of soybeans harvested in the US is
used to produce biofuels. Hence, about 41 million acres are being
used annually to grow corn to produce ethanol and 19 million acres
to grow soybeans for biodiesel or renewable diesel, suggesting that
60 million acres, almost one fifth of cropland, is being used to
grow crops for biofuels. 

2. Corn and soybeans grown to produce biofuels are major
contributors to the pollution of ground and surface water.  

Fertilizers are responsible for substantial ground and surface
water pollution. The Farm Bureau estimates that about half of the
fertilizer (nitrogen, phosphate and potash) consumed annually in
the US is used to grow corn, another 10% is used to grow soybeans.
This suggests that 22% of the all the fertilizer used on crops in
the US is used for corn to produce ethanol, and over 2% is used for
soybeans to produce biofuels, i.e. almost one fourth of synthetic
fertilizer use in the US is used on crops grown to produce
biofuels. 

In addition, recent USDA NASS Chemical Use Surveys showed that corn
farmers applied almost 2 pounds of herbicides per acre in 2021 and
soy farmers almost 1.5 pounds of herbicides per acre in 2020. Corn
and soy have traditionally been the greatest users of pesticides
per acre (including insecticides and fungicides as well as
herbicides). 

3. Corn and soybeans grown to produce biofuels are major
contributors to nitrous oxide greenhouse gas emissions.

According to the EPA nitrogen fertilizers (synthetic and organic)
are responsible for the majority of US nitrous oxide (N2O)
emissions (which have a 100 year GWP of 265).  On average, corn
uses 246 pounds of fertilizer per acre of which 143 pounds (almost
60%) is nitrogen fertilizer, according to the USDA NASS
Agricultural Chemical Use Survey of 2021, while soybeans use 70
pounds of fertilizer per acre of which only 5.5 pounds (8%) is
nitrogen fertilizer, according to the USDA NASS Agricultural
Chemical Use Survey of 2020. 

4. Corn and soybeans grown to produce biofuels are major
contributors to the unsustainable withdrawal of water from US
aquifers. 

The 2017 Census of Agriculture reported that 54 million acres of
cropland were irrigated in 2017. (See Historical Census Table 1:
2017 and earlier years, NASS, USDA) The crop with the most
irrigated acreage was corn which accounted for 12 million acres of
irrigated cropland. Soy acreage was second with 9 million acres
irrigated. This suggests that 5.4 million acres of corn were
irrigated to produce ethanol and 1.9 million acres of soy were
irrigated to produce biofuels; or 13.5% of total irrigated acreage
was used to produce biofuels.  Increasingly, the source of water
for irrigation is groundwater rather than surface water. As
droughts are forecast to increase, the US will need to rely more on
irrigation for both corn and soybeans. The Ogallala-High Plains
Aquifer extends from South Dakota to Texas and provides water for
eight states, but it is being depleted at an unsustainable rate.
Irrigation is responsible for 90% of Ogallala groundwater
withdrawals. 

5. The production of ethanol, biodiesel and renewable diesel from
corn and soybeans are also major users of water. The production of
ethanol is more water intensive than the production of gasoline,
requiring 3 gallons of water for every gallon of ethanol produced,
compared to 2-2.5 gallons for gasoline. Most ethanol producers are
located in the Midwest and rely on the Ogallala-High Plains Aquifer
for their water needs.

6. Corn and soybeans grown to produce biofuels are major
contributors to the worsening biodiversity crisis in rural areas. 

The massive use of corn and soy output for biofuel production in
the US has fostered a monoculture system of farming in the US which
has degraded soils and eliminated complex insect, bird and plant
communities. Not only has this monoculture system reduced soil
fertility it has reduced the ability of the ground to absorb water
either for crops or aquifer recharge. Since corn and soy farmers do
not require pollinators to produce their crops, the loss of bees
and other pollinators in rural areas has not been a large concern
to them, but has been a problem for other farmers. Crop-based
biofuels and the monoculture they have encouraged have contributed
mightily to the destruction of nature in our rural areas. 

7. Corn and soybeans grown to produce biofuels have been
responsible for increasing global food prices in developing
countries.

Corn, soybeans, ethanol, biodiesel and renewable diesel, like
gasoline and diesel, are commodities that are widely traded in
global markets. Corn and soybean oil prices influence the prices of
their close substitutes which tend to be interchangeable for animal
feed and human food.  A 2008 World Bank study attributed the rapid
increase in internationally traded food prices from 2002 to 2008 to
EU and US policies that resulted in large increases in the
production of corn ethanol and soy biodiesel. The IMF index of
internationally traded food commodity prices increased 130% over
this period. From 1/2005-6/2006 maize (corn) prices almost tripled,
wheat prices increased 127%, soybean oil prices increased 192% and
other vegetable oil prices increased by similar amounts. The World
Bank study concluded that 70-75% of the increase in food commodity
prices from 2002-2008 was due to the rapid increase in crop
quantities used to produce biofuels over this period. Needless to
say, the increase was devastating for the poor in developing
countries who spend half their household income on food.

More recently, as renewable diesel production in the US has rapidly
grown, soybean oil prices have increased rapidly. According to
Statista global soybean oil prices almost doubled from 2020 to
2022. The American Enterprise Institute recently attributed the
large increase in all vegetable oil prices to the recent growth in
renewable diesel production in the US. There is no doubt about the
existence of a clear and substantial the link between crop-based
biofuel production and higher food prices . 

8. Almost all gasoline in the US is E10 (10% ethanol). Recently,
the average content of ethanol in gasoline reached 10.5%. If the
federal volume mandate for conventional renewable fuel (corn
ethanol) and inclusion of corn ethanol in California's LCFS program
were eliminated, it is difficult to estimate what blend rate for
ethanol would result. By 2006-2007 ethanol had mostly replaced MTBE
as an oxygenate for gasoline. The Clean Air Act requires that an
oxygenate be added to gasoline to reduce carbon monoxide emissions
in the winter in areas where carbon monoxide levels tend to
increase. Hence even without a mandate ethanol would be added to
gasoline as an oxygenate and because it increases the octane level.
Nevertheless, in 2006 the RFS required that 4 billion gallons of
ethanol be added to the almost 140 billion gallons of gasoline
consumed for a blend rate under 3%.  European drivers use mostly
E5. It costs more to produce a gallon of ethanol than a gallon of
gasoline. Thus, over time it seems reasonable to assume that more
than half the land (21 million acres) harvested for corn to produce
ethanol could become available for conservation or for growing
crops for food or feed. 

9. Much petroleum diesel fuel sold in the US contains at least 1%
biodiesel because its lubricating properties prolong the expected
life of some engine parts. However, the average biodiesel content
of petroleum diesel is well under 5% and biodiesel producers
struggle to make a profit without the federal blender's credit of
$1.00 and additional state credits like California's Low Carbon
Fuel Standard (LCFS) credit. Should the federal government end its
biomass-based diesel volume mandates and its blenders credit and
vegetable oils for biodiesel and renewable diesel be removed from
California's LCFS program, one would expect substantial reduction
in soybean acreage planted for biofuels in the US.  

10. It is important to remove both corn ethanol and soy-based
biodiesel and renewable diesel from California's LCFS at the same
time. If only corn is removed, industrial corn farmers may just
switch production to soybeans for renewable diesel or biodiesel.
This would not solve any of the soil degradation, biodiversity
crisis, water pollution or groundwater supply problems to which
these biofuel crops have contributed. 

11. We find CARB references to tallow and used cooking oil (UCO) as
waste products misleading. Tallow is used as cooking oil and as an
ingredient to soap, candles, salves, and lubricants. Used cooking
oil is used as an animal feed and to make soap. Using tallow and
UCO to produce biodiesel or renewable diesel requires the
substitution of vegetable oils in the production of these other
products. When this occurs, more crops must be grown.

The global supply of tallow and UCO tends to grow very slowly.
Also, it is relatively easy to disguise vegetable oil as UCO and
practically impossible to set up and enforce certification programs
that ensure this is not occurring. Providing larger credits for UCO
and tallow creates incentives for this type of fraud. We recommend
that the LCFS adopt measures similar to ones the EU has adopted to
deal with these problems: institute caps on the amount of UCO
eligible for biofuel credits and ban edible tallow. Also
noteworthy, is the EU's goal of reserving all UCO and tallow for
sustainable aviation fuel by 2030.     
  
12. We recommend that CARB thoroughly study the EU-commissioned
Global Biosphere Management Model (Globiom model) which led the EU
to cap targets for crop-based biofuels at 2020 levels. The Globiom
report concluded that "palm and soy based biodiesel have LUC (land
use change) emissions that exceed the full life cycle emissions of
fossil diesel" even before adding direct emissions for soy or palm
based biodiesel. This is because soybeans and palm are often grown
in the tropics and this is where most new agricultural land is
being developed. Vegetable oils are traded on global markets. When
soy oil prices double the way they have since 2020, largely because
of the expansion of renewable diesel production in the US, soybean
producers, especially in Brazil (the largest producer of soybeans)
and neighboring South American soybean producers increase their
efforts to create new farmland. Clearly the assumptions and
structure of the GTAP model that CARB is using to calculate LUCs
associated with vegetable oil-based diesel is very different from
those of the Globiom model. 

13. We think the approach used in a recent PNAS study which used
actual land observations, biophysical models and partial
equilibrium analysis is more appropriate  for analyzing the effects
of crop-based biofuels on greenhouse gas emissions than the
emissions factors, trade model and general equilibrium approach
CARB is currently using.  We note that this recent PNAS study on
the environmental outcomes of the US Renewable Fuel Standard found
that even modest changes in land use in US agriculture from
2006-2016 resulting from crop changes for increased biofuel
production had considerable negative environmental effects. As a
result, the study found the carbon intensity of corn ethanol to be
definitely no less than gasoline and more likely 24% higher. It is
impossible to have confidence in the carbon intensity numbers
developed by CARB for crop-based biofuels because of the long
standing disagreement over whether these carbon intensities are
greater or lower than those of fossil fuels. The methodology used
by CARB to calculate the carbon intensities  of crop-based fuels
does not help. Consider the many environmental problems of
monoculture corn and soy farms in the US for which the federal RFS
and California state LCFS share responsibility. It is time to
remove crop-based biofuels from California's LCFS.