The pressure has been building on the Obama administration to release for public comment EPA's draft rule implementing the renewable fuel standard. EPA has had the draft ready since last October. Delay under the Bush administration was probably a good thing. Delay now simply threatens the EPA's ability to proceed with the renewable fuel standard at all.

While some have been putting behind-the-scenes pressure on OMB and EPA to drop land-use emissions from the critical lifecycle GHG standard in their draft rule, I wrote a few weeks ago about how enviros were calling for the administration to move ahead with the public comment period so the issues can be debated out in the open.

Over the last two week, three leaders in the House sent a similar letter and as did all (virtually all?) of the members of the Senate Environment and Public Works. NRDC and the Renewable Fuels Association even joined up to send a letter. If NRDC and RFA agree that the rule should be put out for public comment, it really make me wonder what the hold-up is.

On a tangentially related note, a good friend, who is one of the smarter people I know, recently addressed a few key issues related to the debate about GHG emissions from land-use change and biofuels. We were emailing about claims that if the US can simply maintain current export levels then biofuels won't have any impact on international land use. As usual for him, it is concise and insightful:

As to export level questions, when people bring up national export statistics, and suggest the [land-use change] effect stops at our border, they are implicitly changing the subject to answer an irrelevant question. If crop prices are affected by the level of crop use for fuel production -- and they most certainly are -- then so long as we have a world market for crops, farmers overseas will react to price changes.

The question of whether the US has capacity to make X billion gallons of biofuel without changing exports, or whether it is fair to "blame" US farmers for something that happens elsewhere are all besides the point.

The GHG accounting is not about fairness, or US export levels, it is just about overall GHG emissions. Congress might decide that a particular policy was an unjust or ineffective means to lower GHGs, but fudging the accounting will not solve the problem. If Congress wants corn ethanol regardless of the GHGs, it has the power to pass such laws (and it has through the grandfathering of corn in the RFS). But we need to protect the ability to measure the results of policies aimed at reducing GHG emissions, because without we will be operating in the dark.

To understand the GHG impacts of using biofuels we need to compare scenarios with different levels of biofuel use and look at the land use differences at the same point in the future. Yield's will increase with or without biofuel production, but regardless of yield increases, if a certain level of biofuels can be grown domestically, then a lower level would require less land. The extra land freed up would reduce pressure for land use conversion in the US and through price signals around the world. In the extreme case where land use conversion has fallen to zero, a lower level of biofuel would free up land for aforestation (intentional, by enrolling in CRP or by abandonment) [...] but we don't live in a world with zero land conversion, so that is hypothetical. The point is that in any of these cases the changes in land use associated with higher fuel use are likely to increase GHG emissions, and the ILUC calcs are a way to measure that.