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The Renewable Fuel Standard (RFS) specifies the use of biofuels in the United States and thereby guides nearly half of all global biofuel production, yet outcomes of this keystone climate and environmental regulation remain unclear. Here we combine econometric analyses, land use observations, and biophysical models to estimate the realized effects of the RFS in aggregate and down to the scale of individual agricultural fields across the United States. We find that the RFS increased corn prices by 30% and the prices of other crops by 20%, which, in turn, expanded US corn cultivation by 2.8 Mha (8.7%) and total cropland by 2.1 Mha (2.4%) in the years following policy enactment (2008 to 2016). These changes increased annual nationwide fertilizer use by 3 to 8%, increased water quality degradants by 3 to 5%, and caused enough domestic land use change emissions such that the carbon intensity of corn ethanol produced under the RFS is no less than gasoline and likely at least 24% higher. These tradeoffs must be weighed alongside the benefits of biofuels as decision-makers consider the future of renewable energy policies and the potential for fuels like corn ethanol to meet climate mitigation goals. 

In their recent contribution, Scullyet al(2021Environ. Res. Lett.16043001) review and revise past life cycle assessments of corn-grain ethanol’s carbon (C) intensity to suggest that a current ‘central best estimate’ is considerably less than all prior estimates. Their conclusion emerges from selection and recombination of sector-specific greenhouse gas emission predictions from disparate studies in a way that disproportionately favors small values and optimistic assumptions without rigorous justification nor empirical support. Their revisions most profoundly reduce predicted land use change (LUC) emissions, for which they propose a central estimate that is roughly half the smallest comparable value they review (figure 1). This LUC estimate represents the midpoint of (a) values retained after filtering the predictions of past studies based on a set of unfounded criteria; and (b) a new estimate they generate for domestic (i.e. U.S.) LUC emissions. The filter the authors apply endorses a singular means of LUC assessment which they assert as the ‘best practice’ despite a recent unacknowledged review (Malinset al2020J. Clean. Prod.258120716) that shows this method almost certainly underestimates LUC. Moreover, their domestic C intensity estimate surprisingly suggests that cropland expansion newly sequesters soil C, counter to ecological theory and empirical evidence. These issues, among others, prove to grossly underestimate the C intensity of corn-grain ethanol and mischaracterize the state of our science at the risk of perversely affecting policy outcomes.