The biofuels group Growth Energy called out the California Air Resources Board on Friday, claiming that Growth Energy found documents the board did not disclose when ruling on California's low-carbon fuel standard. Growth Energy stated the Air Resources board should allow the public to comment on those documents that were not released during the rule-making on the low-carbon standard. Growth Energy stated that the documents and some comments from ARB consultants "cast doubt on ARB conclusions and others that appeared to influence ARB's assumptions."

The state's low-carbon fuel standard applies the theory of indirect land-use change to transportation fuels in the state. In doing so, ARB basically reduced the viability of using fuels such as ethanol from corn or Midwest biodiesel. The board assigned a carbon penalty to domestic biofuels as a result. Ethanol supporters have been highly critical of the decision, particularly given as many as 15 other states could opt to follow California's low-carbon fuels standard.

Growth Energy has been one of the biggest critics of indirect-land use. Tom Buis, CEO of Growth Energy, stated the documents uncovered by the group show that ARB made its decision based on assumptions rather than analysis.

“Even more disturbing are the omitted comments from ARB consultants that contradict the conclusions reached by ARB staff regarding the carbon intensity of ethanol," Buis stated.
In the letter, Growth Energy notes that Thomas Hertel, professor at Purdue University and the senior member of ARB’s advisory team for the Global Trade Analysis Project, called ARB’s use of the GTAP results in the regulation “rather arbitrary,” and “much less defensible” than an alternative he supported.
Also omitted from the public rulemaking file was a PowerPoint presentation from Hertel to ARB stating that the GTAP model “is better suited to generating insights and ranges of results than to generating specific numbers,” yet ARB used GTAP to generate a specific ILUC number for ethanol.

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