In formal comments submitted to the California Air Resources Board, the National Corn Growers Association (NCGA) pointed out significant flaws in the organization's proposed low carbon fuel standard that can severely harm the domestic biofuels industry and increase reliance on foreign oil.

California's proposal, which will be decided in hearings this week in Sacramento, fails in several ways, NCGA President Bob Dickey said. For example, it ignores the great growth in corn production per acre, or yield, that is expected to take place in the coming decade. Many agricultural economists and agronomists have shown that new technologies introduced over the next few years will provide significantly higher yields during this timeframe. With the use of new technologies which allow desirable traits and genes to be identified and deployed much more quickly, annual yield increases may average 2.5 percent or greater into the future.

"Using yield data updated only through last year, the proposal's analysis through 2015 assumes no growth in yield," Dickey said. "This is like assuming we will all use the same computer and same technology in 2015 that we're now using."

Because of the lack of forward vision in anticipating the contribution of further productivity, corn farmers are concerned that the methodology used to model corn yields is logically flawed and does not go far enough in considering observed yield increases and projected improvements.

Further, the proposal being considered by the Air Resources Board also factors in emissions resulting from indirect land use, the belief that as ethanol production expands, acreage which is not currently in crop production will need to be shifted to growing crops. As yields increase, this acreage shift is not necessary.

In 2009, field corn acres are projected to decrease for the second year in a row, and productivity continues to increase. To claim that the increase in corn demand (some 2 billion bushels) during the last four years is the primary driver in land conversion is overstated. Land use change is a function of greater economic variables such as population growth, increased wealth of developing nations and energy commodity prices, specifically oil. To account for land use change in only biofuels, independent of the effects of oil price and world food consumption practices have on land use is negligent.

The ultimate effect of the low carbon fuel standard would be devastating, Dickey said.

"America's corn growers are eager to play a central role in the decarbonization of transportation fuel," Dickey concluded in the written comments. "However, if adopted as currently proposed, the standard will uniformly dissuade the production and use of all forms of biofuels that utilize land and undercut what is a tremendous opportunity to spur economic growth in agricultural communities and reduce carbon emissions with American farming."