RELEASE: California Support for Crop-Based Biofuels Undermines Clean Fuels Program

Berkeley, CA — December 10, 2025 — The Breakthrough Institute has submitted formal comments to the California Air Resources Board (CARB) urging the agency to strengthen its approach to assessing and mitigating land-use change under the state’s Low Carbon Fuel Standard (LCFS). The comment responds to CARB’s November 6 public forum on biofuels and land-use change.

The Breakthrough Institute commends CARB for taking steps to limit the LCFS program’s contribution to harmful land use impacts. However, CARB’s estimates of land-use change rely on outdated modeling frameworks and must be updated to reflect the best available scientific and economic evidence.

Recent empirical studies—leveraging satellite imagery, econometric techniques, and improved datasets—show that biofuel-induced land-use change is larger and more carbon-intensive than previously understood, with emissions often exceeding those of petroleum-based fuels. Three analyses released just this year found that:

• Corn ethanol has caused more than twice as much land use change in the U.S. as CARB assumes in its carbon-intensity estimates.

• Soy-based biodiesel and renewable diesel have led to twenty-three times more land-use change in the U.S. than CARB projected.

• Soy and other vegetable oil-based diesel have driven deforestation in Indonesia and Malaysia, generating emissions that nearly exceed CARB's 2026 benchmark, indicating these fuels should not qualify for credits.

BTI’s comment urges CARB to undertake a systematic reassessment of land-use-change emissions, incorporate new estimates using rigorous scientific methods and data, and otherwise reduce the risk that it is underestimating land-use change. For example, CARB should consider the full distribution of land-use-change estimates across models rather than continuing to rely on a single model.

“California’s LCFS has been a pioneering climate policy, but its credibility depends on ensuring that carbon intensities reflect the best available science,” said Dan Blaustein-Rejto, Director of Food and Agriculture at The Breakthrough Institute. “The evidence is clear: crop-based biofuels contribute far more to land conversion and associated emissions than CARB previously estimated. Updating CARB’s methods is essential to maintaining the integrity of the LCFS and avoiding unintended environmental harms.”

You can read the full comment HERE.

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Media Contact:

Dan Blaustein-Rejto

Director of Food and Agriculture

dan@thebreakthrough.org