Ethanol From Sugarcane Already Meets California Low Carbon Fuel Standard

Sugarcane ethanol's carbon intensity is even lower than initially calculated by the California Air Resources Board (CARB), according to comments submitted today by the Brazilian Sugarcane Industry Association (UNICA). CARB is scheduled to vote on the first-of-its- kind Low Carbon Fuel Standard (LCFS) on April 23-24. The objective of the LCFS is to reduce by 10% the carbon intensity of all transportation fuels in California by 2020.

"Sugarcane ethanol has a verifiable reduction in greenhouse gases of 90% compared to gasoline. Sugarcane ethanol will easily meet the LCFS, not just in 2020 but today," said Marcos Jank, UNICA's President & CEO, following submittal of a 25-page letter to the California regulator.

As part of broader climate change regulations, CARB is calculating the carbon intensity of all fuels used in the state. It has determined that the carbon intensity of gasoline is about 95 grams of carbon dioxide per megajoule (gCO2/MJ), meaning that gasoline must reduce its carbon intensity to 86 gCO2/MJ by 2020 to meet the LCFS.

Additives such as biofuels will help gasoline meet the 10% reduction target, since some biofuels, like sugarcane ethanol, have much lower carbon intensity than gasoline. While preliminary CARB calculations indicate that sugarcane ethanol has a carbon intensity of 27 gCO2/MJ, the submission by UNICA points out that CARB failed to account for basic elements of sugarcane production and ethanol processing that directly affect that result. These include expanding mechanization of the cane harvest, increasing cogeneration and significant, ongoing reduction of pre-harvest field burnings.

"Any realistic evaluation of carbon emissions from sugarcane farming in Brazil must reflect the strict policies being implemented and action already taken to phase out sugarcane burning, increase mechanical harvesting and expand cogeneration output," said Joel Velasco, UNICA Chief Representative in North America. "Time and again, analysts have confirmed that sugarcane ethanol achieves about a 90% reduction in greenhouse gas emissions compared to yesterday's gasoline. And that's not even comparing with tomorrow's gasoline, which will certainly come from more carbon intensive sources."

UNICA's letter also addresses the controversial calculations resulting from so-called indirect land use change impacts from sugarcane expansion. The letter supports numerous comments from stakeholders and mentions specifically a letter by 111 Ph.D. Scientists which states that the science used to determine such impacts is quite limited, highly uncertain and open to misuse, through selective enforcement of such impacts. UNICA's letter urges CARB to revisit the methodologies utilized in land use change modeling.

"If CARB is determined to push forward with ILUC quantifications, we are asking that the best available data and research be considered before rushing to conclusions. If they want to project indirect land use changes in the future, they must start by accurately representing the dynamics of Brazilian agriculture today. We are confident that a thorough and scientific analysis will conclude that indirect land use change from sugarcane cultivation in Brazil is marginal at best, as we endeavor to demonstrate in our letter," said Velasco, who will be in Sacramento for the CARB vote on the LCFS next week.

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