Regulating carbon emissions from indirect land use change (ILUC): U.S. and California case studies

As lifecycle emissions accounting becomes more widely used in policy, it is important to understand how it has been applied. This paper analyses policy-making for two U.S. fuel regulations-the federal Renewable Fuel Standard (RFS) and the California Low Carbon Fuel Standard (LCFS)-that were pioneering not only in using life cycle assessment (LCA) in performance-based environmental regulations, but especially for including emissions from indirect land use change (ILUC). The case studies in this paper focus, in particular, on the decision to include ILUC in lifecycle emissions accounting. Tracing the development of these policies shows the key role of environmental policy entrepreneurs in advocating for ILUC emissions accounting during policy formulation. Moreover, it highlights a paradox in the use of science: although ILUC policy proponents were motivated by best available research, they were also politically enabled by scientific uncertainty and lack of understanding. Understanding this political dimension of decision-making is valuable for scholars as well as practitioners facing similar decisions.