California Air Resources Board

Comments of the World Resources Institute on the LCFS Land Use Change Public Forum, November 6th, 2025.

The World Resources Institute (WRI) appreciates the depth of expertise brought together by CARB for the November 6th Land Use Change Public Forum. Based on the presentations at the Forum as well as previous research by WRI and others, we urge CARB to do all of the following:
1. Hold an additional Public Forum as soon as possible to “consider how best to mitigate any risks of harmful land use impacts or food market conflicts identified, for consideration in a future LCFS update” as called for in Board Resolution 24-14.
2. Revise the ILUC values assigned to fuels that make dedicated use of arable land based on either calculations of the average carbon cost of using cropland for biofuels or empirical analysis using modern econometric techniques.
3. Immediately limit the volume of fuels made from vegetable oils and animal fats to no more than current levels as an interim measure to fulfill CARB’s commitment that “biofuel production should not come at the expense of deforestation or food production.”

We elaborate briefly on each of these recommendations below.

1. The November 2025 Public Forum did an excellent job of reviewing the latest science on land use change related to transportation fuels, as called for by Board Resolution 24-14, but did not include an opportunity to consider how to mitigate the very substantial risks of harmful land use impacts and food market conflicts there were identified by multiple presenters. CARB must convene an additional public forum as soon as possible to full the Board’s directive.

2. Based on modern empirical econometric methods Dr. Berry presented clear evidence that the LCFS increases prices for agricultural commodities, which propagate internationally and lead to tropical deforestation. He and others cited the recent paper by Chen, Sexton, and Smith which shows that using vegetable oils for biofuel accelerates tropical deforestation and increases carbon emissions. These emissions from just Indonesia and Malaysia are so large that that biofuel made from vegetable oil have higher emissions than petroleum fuel. In addition, WRI’s own research has shown that when the average carbon losses on newly-converted cropland to replace food production diverted to biofuels are accounted for, biofuel made from crops grown on dedicated land has higher emissions than petroleum fuel. CARB should adopt either the approach of assigning to biofuels the average amount of carbon losses from converting native ecosystems to cropland to replace food production diverted to biofuels (which would be consistent with the attributional lifecycle analysis approach used for process emissions), or if an econometric approach is preferred, the empirical approach described by Dr. Berry to estimating the ILUC emissions for both vegetable oil based diesel and for ethanol made from cereals and sugars.

3. The empirical evidence presented at the November 2025 Forum shows that the LCFS is currently incentivizing the use of fuels that raise costs for California consumers while increasing, rather than decreasing greenhouse gas emissions, not to mention food insecurity and biodiversity loss. Given the preponderance of evidence that biofuels made from feedstocks grown on dedicated arable land do not reduce greenhouse gas emissions relative to fossil fuels, CARB should take immediate action to respond to this alarming information by adopting a “do no more harm” policy of limiting the use of fuels made from such feedstocks to no more than current levels while it thoroughly revises its approach to calculating the carbon intensity of these fuels.