Share This!
Text SizeAAA Share Email

EPA Implementation of the Renewable Fuel Standard

Let the Science Guide Biofuels Policy

Biofuels as Part of a Smart Bioenergy Initiative
The Union of Concerned Scientists began its Smart Bioenergy Initiative—a guide to sustainable development of bio-based energy and fuels—to show that the use of biofuels like ethanol and biodiesel can reduce our dependence on gasoline and help move us to a clean energy future. But not all biofuels are created equal, and today’s food-based biofuels, such as corn ethanol, deliver few if any benefits to our warming climate.

Biofuels have the potential to play a role in a low-carbon future, but only if scientifically sound policies are put in place to track the “seed to tailpipe” emissions of the fuels produced and to encourage the production and use of lower-carbon fuels.

Conventional Biofuels Industry Seeks to Muffle the Science
Tracking biofuel emissions is a developing science, but the most recent peer-reviewed studies indicate that land use change—when forests and grasslands are converted to cropland for biofuel production—is a significant source of emissions, and must be taken into account in any policy development. The conventional ethanol industry, led by lobbyist associations such as Growth Energy, have been attempting to use the fact that the global warming impact of land use and biofuels is still a developing science as a reason to leave any mention of it from today’s biofuels policy.  Further, Growth Energy has attempted to inject politically charged language into what should be a scientific debate.  A recent Growth Energy press release on the subject states that “Indirect land use change theory uses speculative models and incorrect assumptions in an attempt to blame American farmers for deforestation in Brazil.”
A Victory for Sound Science in California
Leading scientists have already rejected this attempt to undermine the best available science. In April, more than 175 leading scientists and economists from actoss the nation, including two Nobel Prize winners, called upon California leaders to ensure that they include indirect land use change in the lifecycle analyses of heat-trapping emissions from biofuels and other transportation fuels for the proposed California Low Carbon Fuel Standard (LCFS). The effort was a successful one, as the regulation, which likely will serve as a model for other states and the federal government, requires fuel producers to reduce "lifecycle" heat-trapping emissions from gasoline and diesel fuels by 10 percent by 2020.

Biofuels Industry Flexes Lobbying Muscle on Federal Policy
While the conventional biofuels industry lost the battle in California, they have turned their energies to changing federal biofuels policies. The federal Renewable Fuel Standard (RFS) passed as part of the 2007 Energy Bill. By setting global warming pollution standards for renewable fuels and including a full lifecycle carbon tracking system, the RFS has the potential to lower global warming pollution from cars and light trucks by as much as 6 percent in 2022, while displacing about 15 percent of U.S. projected gasoline consumption.

The RFS requires fuels be judged by the total amount of global warming pollution produced over their full lifecycle, including indirect land use change. The Environmental Protection Agency (EPA) recent proposed rules for the implementation of the RFS attempt to determine the global warming pollution from biofuels production and include emissions from indirect land use change. The biofuels industry is working to remove these emissions from the analysis as part of the rulemaking process and has enlisted Congressman Colin Peterson (D-MN), the Chairman of the House Agriculture Committee, to introduce H.R. 4209, a bill designed to strip indirect land use considerations from the RFS by law.

If the biofuels industry is successful, it could appear that conventional biofuels produce substantially less heat-trapping emissions they actually do. That is why the EPA should forge ahead with an RFS rule that does account for all sources of global warming pollution. UCS is now working with a number of noted experts in the field, Drs. Tom Lovejoy, Stuart Pimm, William Schlesinger, Pamela Matson, and Daniel Kammen (see biographies under Related Resources) to craft a National Scientists' Statement on Biofuels and Land Use. This statement and citizen comments to the EPA hopefully will help convince both the EPA and Congress to let sound science guide biofuels toward being part of a climate solution.

Ethanol Industry Seeks to Increase Use Before Low Carbon Policies are Put in Place
The EPA’s draft global warming pollution regulations for biofuels, as part of the federal RFS, are completed, and their methodology could play a crucial role in determining the most scientifically sound path to a lower-carbon fuel future. As we seek to transition to lower-carbon fuels, the EPA is doing important analysis to understand which biofuels deliver the biggest climate benefits, and the Department of Energy (DOE) is testing cars, boats, and lawnmowers to determine the public health impacts of increasing the amount of ethanol blended into conventional gasoline from the current 10 percent limit.

But, again, interests in conventional biofuels have been pushing the EPA to modify their results or delay implementation of important parts of their methodology. The ethanol industry is trying to preempt the science with its request for permission to increase the ethanol blend to 15 percent before the studies are completed.

The federal Clean Air Act has clear guidelines for what data is required to approve higher blends, and the EPA has been coordinating with the DOE to obtain this data. They expect to complete testing in 2010 that could be used to support a determination on a request for higher blends at that time. The ethanol industry’s petition requires the EPA to make a determination before the data is available, subverting the science-based agency process.

The EPA should therefore reject the E15 petition as a premature, unnecessarily piecemeal approach, and instead focus its energies on developing a comprehensive implementation plan for the RFS that will ensure that increased use of biofuels helps to reduce global warming pollution, while protecting air quality and public health.

More than 11,000 UCS activists sent comments to the EPA asking that they reject this waiver request by the industry. As of June 19, no final decision had been made by the EPA on this waiver request.

Powered by Convio
nonprofit software