Ethanol Standards: Why Federal Policy Is Crazy | Harry de Gorter and David R. Just | Cato Institute: Commentary: "The EPA's sustainability standard is based on 'life-cycle accounting' (LCA), a 'well to wheel' measure of greenhouse gas emissions in the production of gasoline and a 'field to fuel tank' measure for ethanol production. While attractive in theory, LCA fails to recognize that if incentives are given for ethanol producers to use relatively 'clean' inputs (e.g., natural gas and land previously used for soybean cultivation), the 'dirtier' inputs (e.g., coal and land previously dedicated to rainforests) that might otherwise have been used will simply be used by other producers to make products not covered by the sustainability standard.
In short, sustainability standards reshuffle who is using what inputs with no net reduction in national emissions. LCA measures are therefore misleading and may not measure the actual greenhouse gas emissions saved by ethanol production."
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