Comment Log Display

Via Electronic Mail


February 17, 2015

Mary Nichols and Board Members
California Air Resources Board
1001 “I” Street
P.O. Box 2815
Sacramento, CA 95812

Re: Low Carbon Fuel Standard 

Dear Chairman Nichols and CARB Board Members:
ActionAid USA, a nonprofit organization working with millions of
people around the world and the US to fight the causes of poverty
and injustice, applauds the California Air Resources Board’s (CARB)
proactive approach to climate change mitigation. However, as the
Board considers re-adoption of the Low Carbon Fuel Standard (LCFS),
we strongly urge it not to lower the indirect land use change
(ILUC) score for corn ethanol. 
Attached you will find a working paper by Timothy A. Wise and Emily
Cole of the Global Development and Environment Institute at Tufts
University, “Mandating Food Insecurity: The Global Impacts of
Rising Biofuel Mandates and Targets.” This paper studies the impact
of government biofuel mandates and estimates that mandates will
drive a 43% growth in demand for biofuels over the next decade.
This level of growth has extremely concerning implications for food
security, as well as land and water use. Further incentivizing the
use of corn ethanol, which undermines food security and has
questionable environmental benefits, would be step in the wrong
direction. 
Crop-based biofuels, particularly corn ethanol, undermine food
security around the world by driving up food prices and increasing
price volatility. 
This not only true for corn products people consume directly; corn
is one of the most popular feeds for animals, so an increase in the
price of corn also increases the price of meat and dairy products.
A 2012 study published by ActionAid estimated that US ethanol
expansion cost net corn importing countries $11.6 billion between
2006 and 2011. $6.8 billion of this additional cost was born by
developing countries. In fact, during fiscal year 2011, the U.S.
spent as much on food aid to Guatemala as the additional money
Guatemala paid to import corn at the increased prices. 

Corn ethanol also presents environmental concerns. 
In addition to the emissions from direct and indirect land use
change, corn ethanol undermines water quality. The nitrogen,
phosphorous and other chemicals applied to corn crops are washed
from those crops into drainage, local water supplies, rivers and
eventually oceans. This poisons the water, and in the case of
nitrogen, creates algae blooms that reduce the oxygen levels in the
water. The resulting dead zones kill fish and aquatic life or force
them to move elsewhere. In 2014, the dead zone in the Gulf of
Mexico was 5,052 square miles.   The impact of biofuel expansion on
water quantity should not be ignored. Corn uses more irrigated
water than any other crop in the US, even though the overwhelming
majority of corn is currently rain-fed. In recent years, irrigated
corn crops increased with the growth in corn production. Perhaps
not surprisingly, 87% of irrigated corn crops are grown in areas
already showing extremely high water stress.  Considering the water
demands of growing corn and the strain current corn production is
placing on water levels, policy makers should be cautious about
policies that encourage further demand. 

One other lesson to take from “Mandating Food Insecurity,” is that
government policies continue to profoundly shape the biofuels
industry. Government mandates have and will continue to drive
demand growth for first-generation biofuels, such as corn ethanol,
that undermine food security and hurt the environment. I strongly
urge the Board to ensure that the LCFS does not further incentivize
corn ethanol expansion. 
Thank you for your consideration and please do not hesitate to
contact us should you need additional information.  
Sincerely,

Kelly Stone
Biofuels Policy Analyst
ActionAid USA 
Kelly.Stone@actionaid.org


  “Fueling the Food Crisis: The Cost to Developing Countries of US
Corn Ethanol Expansion.” ActionAid USA. October 2012.
  http://water.epa.gov/type/watersheds/named/msbasin/zone.cfm
 
http://voices.nationalgeographic.com/2015/02/10/corn-remains-king-in-usda-irrigation-survey/