Indirect land use change and biofuels: Mathematical analysis reveals a fundamental flaw in the regulatory approach

•Interactions between different biofuels are too large to be ignored.•The threshold values in RFS2 do not account for interactions between different biofuels.•The threshold values in RFS2 are therefore scenario-dependent and reflect value choices, not actual biofuel impacts.•Failure to account for such interactions is a mathematical and systematic flaw, and has nothing to do with uncertainty.•The regulatory agencies should correct such flaws in their analyses.

In the Renewable Fuel Standard (RFS2) program, the United States Environmental Protection Agency (U.S. EPA) has used partial equilibrium models to estimate the overall indirect land use change (iLUC) associated with the biofuel scenario mandated by the Energy Independence and Security Act of 2007 (EISA). For regulatory purposes, the U.S. EPA “shocks” (changes) the amount of each biofuel in the economic models one at a time to estimate the threshold values for specific biofuels (single-shock analysis). The primary assumption in the single-shock analysis is that iLUC is a linear process with respect to biofuels, i.e., that interactions between different biofuels are trivially small. However, the assumption of linearity in the single-shock analysis is not appropriate for estimating the threshold values for specific biofuels when the interactions between different biofuels are not small.Numerical results from the RFS2 program show that the effects of interactions between different biofuels are too large to be ignored. Thus, the threshold values for specific biofuels determined by the U.S. EPA are scenario-dependent and value choice-driven. They do not reflect real impacts of specific biofuels. Using scenario-dependent values for regulation is arbitrary and inappropriate. Failure to deal appropriately with interactions between different biofuels when assigning iLUC values to specific biofuels is a mathematical and systematic flaw; it is not an “uncertainty” issue. The U.S. EPA should find better ways to differentiate the contribution of one biofuel versus another when assigning iLUC values or find better means of regulating the land use change impact of biofuel production.