© 2012 International Council on Clean Transportation
Comments of the ICCT on EPApalm oil pathway NODA
Author: Dr Chris MalinsDate: 27 April 2012
The ICCT believes that the EPA’s initial analysis o the carbon intensity o palmoil biodiesel production is an important contribution, and we are supportive othe overall methodology. However, there are several points on which we believethere is room or improvement in the analysis – we would urther anticipate thatthe overall result o adopting such improvements would be to increase the carbonintensity value proposed or palm oil biodiesel.
It seems likely that 2022 yield predictions are too optimistic. We wouldrecommend that serious consideration be given to the credibility o thecurrent values, and suggest that 4.7 tCPO/ha and 4.8 tCPO/ha or Indonesiaand Malaysia respectively might be considered the upper bounds on theappropriate assumption or the 2022 value, i one is optimistic about continu-ation o recent trend yield growth. Without that optimism, values not morethan 4.5 tCPO/ha might seem reasonable, and thus we suggest that it wouldbe appropriate or the EPA to adopt a value around 4.5 tCPO/ha as thecentral estimate. While current government initiatives exist to boost palmyields, we see no reason to believe that even i these initiatives work yieldincrease will grow substantially above the trend rate.
The GEOMOD approach to land use prediction is undamentally awed ascurrently applied to oil palm. While it has some prima acie appeal comparedto MODIS data as previously used, we show that the predictions are so out osync with what is generally expected by industry analysts, and with analysiso historical trends, that the approach should be abandoned or this pathway.With additional work, a uture iteration may represent a useul addition or