 The Renewable Fuel Standard (RFS) in the 2007 Energy Bill is a key first step towards reducing global warming pollution from our nation’s transportation fuel. By setting global warming pollution standards for renewable fuels, the RFS has the potential to lower greenhouse gas pollution from cars and light trucks by as much as 6% in 2022, while displacing about 15% of America’s projected gasoline consumption. However, because the RFS does not regulate global warming pollution from existing biofuel producers, gasoline or other fuels in the rest of the transportation fuel market, it is only a first step. To protect the benefits of the RFS and build on them, we need a more comprehensive approach that covers the whole fuel market such as a low carbon fuel standard.
The 2005 RFS got renewable fuels going with big increases in the use of corn ethanol, but it didn’t make any promises about greenhouse gas reductions. The 2007 RFS breaks new ground because it counts carbon and makes carbon count:
- To qualify as renewable fuels under the 2007 RFS, fuels from new facilities1 must reduce global warming pollution by at least 20% as measured on a lifecycle basis. This means counting all the direct and indirect greenhouse gas emissions associated with growing, producing, distributing and using the fuels.
- The 2007 RFS begins a transition to second-generation renewable fuels that use energy and land more efficiently and take an even bigger bite out of greenhouse gas pollution. Corn ethanol’s contribution to the RFS is capped at 15 billion gallons a year in 2015. The remaining 21 billion gallons a year will be supplied by cellulosic ethanol (16 billion), advanced ethanol (4 billion) or biodiesel (1 billion). These fuels must reduce greenhouse gas pollution by 60% for cellulosic and 50% for advanced ethanol and biodiesel.
If everything goes according to plan, the avoided global warming pollution from the RFS fuels covered by global warming pollution standards will be about 100 million metric tons of CO2 a year by 2022.
Land Use, Global Warming Pollution and the RFS
Recent publications have called attention to the importance of properly accounting for land use changes caused by biofuels production. If forests are cleared and converted to farmland to grow biofuels, the emissions from clearing the forest can be large compared to the annual emissions reductions from the biofuels. The same thing can happen indirectly when corn is used to make ethanol instead of being used for food or animal feed. Farmers elsewhere respond to increased prices by clearing land to increase production, and some of this land comes from rainforest and other carbon rich land types. For more information on Indirect Land Use Changes see our fact sheet.
The good news is that legislators knew this was coming, and the RFS explicitly requires that lifecycle analysis include all significant contributions to global warming pollution, including direct and indirect land use changes. The next step is to make sure that the law is backed up with good regulations. EPA must implement the RFS in a way that ensures the lifecycle accounting methods capture all significant direct and indirect effects, including land use changes. It will also be important to establish a flexible framework that can be updated as lifecycle analysis methods improve.
The 36 billion gallons of fuel in the RFS is enough to offset 15% of US gasoline consumption, but because of the loophole for about 12 billions gallons of corn ethanol, only two thirds of this fuel, or 10% of total fuel consumption, is subject to limits on greenhouse gas pollution. If the indirect land use impacts of corn ethanol are as high as one recent estimate, the 12 billion gallons of corn ethanol will erode the potential benefits of the RFS. In 2022 the low carbon fuels in the RFS should reduce global warming pollution by 6%, but, including indirect land use changes, the extra emissions from the unregulated corn ethanol could increase overall pollution by 5%, wiping out most of the benefits of the regulated renewable fuels. Moreover, since the RFS does not require large volumes of low carbon fuels until the later years and relies on corn ethanol early on, the cumulative extra emissions from the exempt corn ethanol could be 2.5 times greater than the avoided emissions from low carbon fuels between now and 2022.
Counting Carbon for All Fuels
Outside the RFS, the global warming pollution of the rest of the fuel market remains unregulated. The fuel market is already migrating to more polluting fuels like tar sands, and liquid coal is on the horizon, with the potential for almost twice the pollution of gasoline on a lifecycle basis. Between the existing biofuels loophole in the RFS and the dirty fossil fuels in the rest of the market, global warming pollution from fuels could actually increase.
The way to protect the gains of the low carbon renewable fuels is to include the entire fuel system in a low carbon fuel standard. A low carbon fuel standard would require fuel providers to reduce global warming pollution per gallon of the fuels they sell on an average and energy-equivalent basis, but would leave it to the market to decide how to achieve these savings most efficiently. Because the standard is based on the full lifecycle of the fuel, it provides an incentive for reductions at any link of the fuel supply chain, whether from reduced fertilizer use, efficient land use, or use of renewable fuels to power the conversion process. By specifying the goal and allowing trading of credits, a low carbon fuel standard provides maximum flexibility for innovative approaches to meet the requirement in the most efficient way possible, without picking winners or favoring particular technologies.
For more information contact Jeremy Martin or Eli Hopson at 202-223-6133 |
