Action Aid International USA * Clean Air Task Force * Conservation International * Conservation Law Foundation * Defenders of Wildlife * Ecology Center Environmental Working Group * Environment America * Environment Northeast Friends of the Earth * Fresh Energy * League of Conservation Voters * League of Woman Voters of the United States * National Audubon Society * National Wildlife Federation * Natural Resources Defense Council * The Nature Conservancy * Sierra Club * Southern Alliance for Clean Energy * Union of Concerned Scientists * The Wilderness Society
Representative Henry Waxman
2204 House Rayburn Building
Washington, DC 20515
Representative Joe Barton
2109 House Rayburn Building
Washington, DC 20515
May 19, 2009
Dear Representative,
On behalf of our millions of members and activists, we are writing to express our opposition to any attempt to weaken the Renewable Fuel Standard's definition of life-cycle greenhouse gas emissions of biofuels and exclude emissions from indirect land-use change.
In December 2007, Congress agreed to include greenhouse gas emissions from indirect land-use change as part of the assessment of the full lifecycle emissions of biofuels. Since then, scientific research has demonstrated the wisdom of Congress' decision. This research continues to demonstrate that biofuel policies, like the Renewable Fuel Standard, would accelerate global warming if the policy shifts farmland or forests from food and fiber production to biofuels feedstock production. Such shifts increase the demand for land and thus encourage farmers and foresters around the world to convert forests, wetlands, grasslands, and other natural areas into farmland until supply meets demand again. As land is cleared for farming or grazing, enormous amounts of soil - and plant-carbon are released into the atmosphere.
Including emissions from indirect land-use change is the only tool we have to direct the biofuels industry towards sources of biomass that do not cause such a shift. Including these emissions in the life-cycle assessment of greenhouse gases from biofuels is therefore critical to protecting forests and native ecosystems from the consequences of increased biofuels production. In addition, by discouraging shifts in land from food and fiber production, considering emissions from indirect land-use change helps keep biofuels from contributing to food price spikes.
Our organizations are adamantly opposed to any provision that would weaken the greenhouse gas emission standards in the Renewable Fuels Standard. Weakening the standards would contradict the best and most recent science available; this science has been painstakingly analyzed by experts at EPA and incorporated into proposed regulations implementing the Renewable Fuel Standard. All parties concerned have the opportunity now to comment on EPA's proposed rule and weigh in on the integrity of the science - this is the appropriate venue for addressing concerns. Last month, regulators in California confirmed that emissions from indirect land-use are indeed significant and chose to include them in their life-cycle assessment of greenhouse gas emissions from biofuels. The analysis supporting the approved rule in California and the proposed EPA rule together suggest that emissions from indirect land-use alone are equal to between 30% and 60% of gasoline's emissions.
The scale and significance of these emissions clearly overwhelms the uncertainty as to their exact value. Removing them is the equivalent of assuming these emissions don't exist, which is not only bad for the climate, but it will also mislead investors and developers.
Last month more than 170 scientists, including a number of Nobel Laureates wrote to the California Air Resources Board:
President Obama has called for the restoration of scientific integrity in federal policy-making. We now ask that you heed the President's call and oppose any provision that would exclude indirect land-use change emissions in the life-cycle assessment of biofuels.
Sincerely,
| Karen Hansen-Kuhn Policy Director Action Aid International USA |
Rob Sargent Energy Program Director Environment America |
|
Armond Cohen Executive Director Clean Air Task Force |
Emily M. Bateson Deputy Director Environment Northeast |
|
Manuel J. Oliva Director, U.S. Climate Policy Conservation International |
Sandra Schubert Director of Government Affairs Environmental Working Group |
|
Seth Kaplan Vice President for Climate Advocacy Conservation Law Foundation |
Michael Noble Executive Director Fresh Energy |
|
Noah Matson Vice President for Land Conservation Defenders of Wildlife |
Erich Pica Domestic Programs Director Friends of the Earth |
|
Charles Griffith Clean Car Campaign Director Ecology Center |
Tiernan Sittenfeld Legislative Director League of Conservation Voters |
|
Judy Duffy Advocacy Chair League of Woman Voters of the United States |
Ann Mesnikoff Director, Green Transportation Campaign Sierra Club |
|
Joseph Mendelson III Director, Global Warming Policy National Wildlife Federation |
Jennifer Rennicks Federal Policy Director Southern Alliance for Clean Energy |
|
Mike Daulton Legislative Director National Audubon Society |
Michelle Robinson Director, Clean Vehicles Program Union of Concerned Scientists |
|
Franz Matzner Acting Legislative Director Natural Resources Defense Council |
Mike Francis Acting Vice President, Public Policy The Wilderness Society |
|
Robert L. Bendick Director, U.S. Government Relations The Nature Conservancy |
Individual: Deepak Rajagopal University of California – Berkley |
CC: House Environment and Commerce Committee
1 Letter addressed to Mary D. Nichols, chairman of the California Air Resources Board from 177 scientists on April 21, 2009.
