CATF & Achten comments:

Chris--

In response to your request (below) for input regarding additional literature or data that should be 

included in the analysis of the lifecycle GHG emissions of jatropha-based biofuels, the Clean Air Task 

Force strongly encourages EPA and RTI to bolster consideration of all production-related land use 

change emissions in the final report.

As a general matter, a full assessment of GHG emissions from land use changes -- especially indirect 

land use change -- that are connected to policy-driven increases in biofuel production must be part of 

every lifecycle analysis conducted to determine RFS eligibility. This is more than just a legal requirement, 

it's an essential part of developing a fuller understanding of the net environmental impact associated with 

potentially eligible biofuels. Numerous studies have shown that lifecycle analyses that fail to account for 

ILUC emissions aren't just incomplete, they are dangerously misleading.

The September 2012 draft report recognizes the need to examine land use impacts. The papers cited in 

the draft report indicate that jatropha grown on good farmland fares much better than jatropha grown on 

marginal land (an intuitively obvious point that is nonetheless often ignored), and that jatropha typically 

requires significantly more water and fertilizer than was previously thought in order to achieve commercial 

yields. "Research demonstrates that marginal lands typically produce poor yields and that the highest 

yields come from more productive lands and more intensive production practices," the authors write in the 

intro. "This is consistent with historical experience with production of other crops, but means that jatropha 

production is more likely to compete for land used to produce alternative crops than was originally 

anticipated." (p1-1)

It was discouraging, then, to find that only one of the papers cited in the draft report looks explicitly at 

ILUC. I connected with the author of that paper, Dr. Wouter Achten of KU Leuven in the Netherlands, to 

ask if he had any feedback on the draft report and/or any suggestions on additional resources that EPA 

and RTI should consider. Dr. Achten, who is copied here, wrote the following:

I had a quick look at the references used in the report, I didn’t take the time (yet) to get into the 

conclusions drawn from the studies brought together. Concerning the completeness of the literature 

overview, I can make some more suggestions (see list of papers below).Concerning the completeness of 

the literature overview, I can make some more suggestions (see list of papers below).

ILUC is not all that easy, an is indeed not often included in global warming potential quantifications, 

however, Lapola et al. have done a very relevant study in Brazil (see attach, although the main paper 

does not focus on Jatropha the supporting information contains information on the LUC and ILUC 

Jatropha can trigger in Brazil and what kind of impacts that can have). Further it is worthwhile to take a 

look at 3 other studies in which the direct land use change is considered (in quite different ways and on 

different scales) (Achten et al. 2012, Bailis & McCarthy 2011 and Romijn 2011).

Concerning LCA studies... there are actually several more. The first 3 I list I used myself to compare my 

results with, but one can actually find more (and more recent) (when I do a quick search), but I have no 

insight in their quality.

[...]

Impact quantification of land use change (not necessarily incorporated in LCA method, but linked with 

LCA results)

Lapola, D. M., R. Schaldach, J. Alcamo, A. Bondeau, J. Kock, C. Koelking, and J. A. Priess. 2010. 

Indirect land-use changes can overcome carbon savings from biofuels in Brazil. Proceedings of the 

National Academy of Sciences of the United States of America 107:3388–

3393. http://dx.doi.org/10.1073/pnas.0907318107
Title: Carbon impacts of direct land use change in semiarid woodlands converted to biofuel plantations in 

India and Brazil

Author(s): Bailis, Rob; McCarthy, Heather

Source: GLOBAL CHANGE BIOLOGY BIOENERGY Volume: 3 Issue: 6 Pages: 449-460 DOI: 

10.1111/j.1757-1707.2011.01100.x

Achten,W.M.J., et al., Global greenhouse gas implications of land conversion to biofuel crop cultivation in 

arid and semi-arid lands eLessons learned from Jatropha, Journal of Arid Environments 

(2012), http://dx.doi.org/10.1016/j.jaridenv.2012.06.015

Romijn, H. A. 2011. Land clearing and greenhouse gas emissions from Jatropha biofuels on African 

miombo woodlands. Energy Policy 39:5751–5762

Dr. Achten also suggested several additional studies that do not take land use change into account:

Ou, X. M., X. C. Zhang, S. Y. Chang, and Q. F. Guo. 2009. Energy consumption and GHG emissions of 

six biofuel pathways by LCA in (the) People’s Republic of China. Applied Energy 86:S197–

S208.http://dx.doi.org/10.1016/j.apenergy.2009.04.045

Title: Life cycle assessment of village electrification based on straight jatropha oil in Chhattisgarh, India

Author(s): Gmuender, Simon Michael; Zah, Rainer; Bhatacharjee, Somnath; et al.

Source: BIOMASS & BIOENERGY Volume: 34 Issue: 3 Pages: 347-355 DOI: 

10.1016/j.biombioe.2009.11.006 Published: MAR 2010

Title: Life cycle assessment for the production of biodiesel: A case study in Malaysia for palm oil versus 

jatropha oil

Author(s): Lam, Man Kee; Lee, Keat Teong; Mohamed, Abdul Rahman

Source: BIOFUELS BIOPRODUCTS & BIOREFINING-BIOFPR Volume: 3 Issue: 6 Pages: 601-612 

 DOI: 10.1002/bbb.182 Published: NOV-DEC 2009

Title: Environmental Impacts of Jatropha curcas Biodiesel in India

Author(s): Gmuender, Simon; Singh, Reena; Pfister, Stephan; et al.

Source: JOURNAL OF BIOMEDICINE AND BIOTECHNOLOGY Article Number: 623070 DOI: 

10.1155/2012/623070 Published: 2012

 

Dr. Achten passed along copies of three of the papers (Achten et al (2012), Lapola et al (2010), and Ou 

et al (2009)); those three are attached here. If you cannot locate the other articles listed above, please let 

me know.

I want to thank EPA and RTI for the work that you are doing on this subject, and also for seeking 

feedback early in the process. If there is anything else that the Clean Air Task Force can do to help EPA 

in its analysis of jatropha-based fuels, please let me know.

Best regards,

Jonathan

---

Jonathan Lewis

Senior Counsel - Climate Policy

Clean Air Task Force

18 Tremont Street, Suite 530

Boston, MA 02108

office: +1 (617) 624-0234 x153
mobile: +1 (617) 894-3788

www.catf.us

jlewis@catf.us