Nathanael Greene's Blog: Curbing Pollution

The light bulb, the cocktail party, and you

2008-06-26T23:12:43Z

Years ago, when I was young, I spent most of my time working on energy efficiency technology policy. Now I spend most of my time working of renewables, but from time to time, my colleagues forget and ask me questions that are way over my head. And so it was that I was recently pressed to provide our board with simple answers to all the questions they might possible get asked at a cocktail party.

One of the issues that everyone asks about is mercury in compact fluorescent. I wrote one of my early blogs about it, and spent a good chunk of my talk for the board focusing on it. My main message on CFLs and mercury is that if you care about mercury pollution, one of the best things you can do is use more CFLs. But if after using a CFL, we can recycle it, that's even better. So I was happy to see this story that Home Depot is going to start to take CFLs back for recycling.

NRDC's real expert on bulbs and all energy efficient appliances is Noah Horowitz and I encourage you to read more about him and his great work here and here. Now Noah is one of those incredibly smart people that have the ability to make very complicated topics comprehensible. And he helped me do that with bulbs for the board. So without further ado, here's the presentation I gave at NRDC's most recent board meeting.

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More about PA coal ethanol plant proposed on top of school

2008-05-20T11:27:24Z

Last week I wrote about a corn ethanol plant would use waste coal for process energy and has been proposed for a small town in Pennsylvania. As I mentioned in that post, the proposed site for the ethanol plant, being developed by Sunnyside Ethanol, is right next door to the town's school. Turns out it's the combined elementary and high school and by right next door, I meant abutting.

Unfortunately, the questions remain. Why would anyone want to build an ethanol plant that can't comply with the new GHG standards in the renewable fuel standard and why would anyone finance such a project? I've got some meetings in the works with experts involved in the finance side and hope to have answers soon.

Pam Sheeder, the fearless leader of the local group (Citizens for a Clean Curwensville) fighting the project sent me these two pictures to help show just how close the project is to the town's school.

More to the southeast:

A coal powered ethanol plant and a test of the new RFS

2008-05-14T18:55:01Z

In a little town in central Pennsylvania, a company called Sunnyside Ethanol, LLC (owned by Consus Ethanol, LLC) wants to build an 80 million gallon per year corn ethanol refinery that would get its heat and power from a waste coal boiler. The project would stand about 150 yards from the town's high school and a stone's throw from half a dozen houses. Waste coal, in case you don't know, is the stuff that's not good enough to burn in a regular coal plant. Needless to say, it's pretty nasty stuff.

This local news TV clip gives some good basics and introduces Pamela Sheeder, a local mother and leader of Citizens for a Clean Curwensville. (If you watch the video, take note that while the project has an air permit, it hasn't started construction. Also, what do you want to bet the borough council president doesn't have children at the high school.) These two articles introduce the only local councilman, Samuel Ettaro who has stood up against the project to ask the important questions.

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Now those of you who have been reading my blog or the popular press may think, what a sec, are the lifecycle GHG standards in the new RFS supposed to stop this sort of a project? Others who read this recent Inside EPA article (subscription, but here's the first paragraph in case: [1]) about how most of the growth in the corn ethanol industry is grandfathered and thus exempt from these standards may think, so this is one of the projects that squeaked through. No disrespect, but both groups are wrong.

The RFS establishes criteria for fuel that can be used by the oil companies to comply with the standard. The law requires that all renewable corn-based ethanol used to comply with the RFS “produced from new facilities that commence construction after the date of enactment of this sentence, achieves at least a 20 percent reduction in lifecycle greenhouse gas emissions compared to baseline lifecycle greenhouse gas emissions.” In other words, if someone want to make substandard fuel, they're allowed, but you got to wonder who is going to buy it.

As to the grandfathering provision embedded in the language above, it exempts fuel produced at existing facilities and facilities that commenced construction on or before December 19th, 2007, from the 20% greenhouse gas reduction requirement. The US Environmental Protection Agency is responsible for implementing the RFS and has not promulgated a definition for “commenced construction” in this context. The definitions that EPA has used elsewhere when implementing air pollution regulations generally require a project to have all of its permits, and to either have made large, irrevocable, construction-related financial commitments or to have begun actual on-site construction.

The project in question doesn't have local land-use or building permits, reportedly doesn't have title to the land, may not even have all of its financing lined up, and certainly hasn't broken ground. In other words, there's no way under any existing regulatory definition of "commence construction" that this project is anything other than a new project. Therefore, its ethanol is going to have to meet the 20% reduction requirement gasoline to be considered “renewable fuel.”

Now a legal eagle among my loyal readers will point out that EPA is allowed to lower the 20% requirement to 10%. But this facility is using waste coal to convert corn into ethanol. Even under traditional lifecycle analyses this combination can't come close to a 10% reduction and the definition of lifecycle GHG emissions in the RFS goes beyond the traditional approaches in very important ways. While EPA is in the process of developing the regulation to implement the lifecycle definition, nevertheless, I find it extremely unlikely that ethanol from a facility that uses waste coal for process energy would be able to meet this lifecycle emissions requirement for the following two reasons:

· Traditional lifecycle analyses have estimated that ethanol refined at a facility using coal for process energy produces more greenhouse gas emissions than gasoline over both fuels’ lifecycles. NRDC’s internal calculations historically have suggested that using combined heat and power can improve this balance, but only to the point of making the ethanol just slightly better than gasoline. The figure below comes from a peer reviewed journal article authored by one of the foremost authorities on the lifecycle greenhouse gas emissions of ethanol, Michael Wang from Argonne National Laboratory. As this figure suggests, according to traditional lifecycle assessments, unless a coal-fire ethanol refinery is not drying its distiller grains, the ethanol produced would not comply with the minimum standards in the RFS.

-Studies published in Science earlier this year have shown that emissions from land-use changes caused direct and indirectly by the growing of crops in order to make biofuels can dominate the lifecycle emissions and have been either ignored or significantly under estimated in traditional lifecycle analyses. While the assessment of emissions from land-use changes caused indirectly by biofuels is at very early stages, the definition of lifecycle GHG emissions in the Energy Independence and Security Act explicitly requires EPA to include these emissions. Even if the values suggested in the Science articles prove to be off significantly, including emissions from land-use change will make it all but impossible for ethanol produced at a facility that uses coal for process energy to meet the standards in the RFS.

So if the project is not going to be exempted and will have to meet the GHG standards but by virtue of using waste coal doesn't have a chance in hell of complying with those standards, why is it being built? And just as interestingly, who is financing it and where's the due diligence? Or is there a market for substandard, uncertified ethanol? And if there is what does that say about the need for ethanol incentives?

If you have any answer, I'm all ears. This is one project that no one should be interested in building or paying for. We have to wake up the financial community towns like Curwensville don't get stuck with half baked, fully polluting dinosaurs like Sunnyside Ethanol.

[1] From Inside EPA article:

Despite draft modeling showing that coal-fired ethanol plants will exceed the energy law's lifecycle greenhouse gas (GHG) standard, agency officials say that few existing facilities will be subject to the GHG standard because facilities exempted from the standard by Congress will likely be able to provide almost all the fuel needed to meet the law's 15-billion gallon corn ethanol mandate.

Two articles on ethanol, EPA, and air quality; one conclusion: forget midlevel blends

2007-08-14T05:18:35Z

On Friday, InsideEPA.com (subscription required) ran two interesting articles on ethanol and air quality. The headline for the first is "Agency Models Used To Predict Biofuels Emissions Rely On Outdated Data." The news here is as bad as it sounds. Not only is EPA's data outdated, but we know that it is no longer accurate. The data is based on gasoline blend stocks that are no longer used and on a mix of vehicles that are no longer on the road. Furthermore, we know that there are sources of emissions that were not measured in the testing used to calibrate EPA's models. Specifically, we now know that low blends of ethanol gasoline causes the fuel mixture to permeate through the fuel lines leading to increased evaporative emissions off of the fueling system. In its regulatory impact analysis for its rules implementing the renewable fuel standard, EPA basically speculated that these inadequacies in the data where counter balanced by others such as improvements in emissions controls in the vehicle stock.

We knew about these problems back in 2005 when the existing renewable fuel standard was being contemplated and that's part of the reason that we pushed for a requirement that the EPA update its model. But as the article notes:

The RFS does require EPA to update the model, but the agency has yet to find the budget money to do so, sources say.
One environmentalist says it would cost $20 million to $50 million for the updates.
An EPA source notes the vehicle testing program “is dependent on resources” and that Congress, which has taken steps to significantly boost the use of ethanol in fuel, has not appropriated the money for EPA to update the models.
For example, the source says EPA is not performing any testing on permeation of VOCs or any other ethanol emissions impacts. Instead, the agency relies on data from outside researchers, such as from California officials who suggest that ethanol permeation is likely to boost VOCs.
Critics also say the lack of adequate data may stall important new tailpipe emissions standards and technology control requirements that can help offset the expected increase in ozone-forming emissions and air toxics from the increased use of biofuels.

The title of the second article is "EPA Testing Plan Could Clear Path For Compromise On Ethanol Blends," and the article starts off by stating:

EPA air office officials are launching extensive new emissions tests of various blends of ethanol in conventional gasoline, including a 15-percent blend that has emerged as a potential compromise between the existing 10-percent cap and ethanol backers who support a 20-percent blend that industry sources fear could harm engines and negatively impact air quality.

So now I have to scratch my head. EPA has resources to test these midlevel ethanol blends, but not enough resources to do the testing necessary to update its models to protect against the impacts that we know will occur from the existing low level blends?!?

I've written before (here) about how CA has updated its model to require further reformulation of the gasoline blend-stock if oil companies want to use higher blends than CA has traditionally allowed. These models are important tool for protecting public health and CA's update suggests that we can virtually eliminate the air quality penalty from low blends. (See Unlocking the Promise of Ethanol for a slightly dated, but still helpful short explanation of the air quality issues.)

I've also written before (here) about how midlevel blends are a distraction from shifting away from use biofuels as an additive to using them as an alternative to oil. While high blends such as E85 get away from air quality problems of low-blends, they're not a panacea. Without good testing data and rules to capture any potential air quality benefits and protect against any unexpected increase in toxics, there is little reason to believe that high blends would be much better or worse gasoline. (The environmental reason to worry about biofuels is as part of the solution to global warming.)

In the end, the punch line I take away from these articles is that once again it appears that short-term interests in midlevel blends are drawing away resources from addressing both the real near-term and long-term challenges facing getting biofuels right. Let's test E10 and update EPA's models to mitigate the impacts we know we face today and let's test E85 so that we can avoid impacts in the future, but let's not waste time and money testing mid-level blends.

In a rush to produce, Ohio invites ethanol to pollute

2007-07-26T02:39:33Z

Put this in the category of cutting off your nose to spite your face: Yesterday, Ohio EPA proposed allowing ethanol plants to pollute more not because it's good for the environment but explicitly because it's good for business. With this brave leap backwards, Ohio takes the lead in the race to the bottom. And the fact that the ethanol industry let Governor Strickland and OEPA do this in its name suggests a perverse desire to shed their green image and invite public backlash. Or maybe it just suggests good old fashion greed.

The story is here (subscription required), but the back story starts early this year when at Senator Thune's urging US EPA proposed to allow ethanol plant to pollute twice as much before coming under federal air regulations. They did this by ruling that ethanol plants, which by law have to mix a small amount of gasoline with their ethanol so that it's toxic to humans, are actually food processing plants not chemical refineries. Needless to say, NRDC submitted comments, and, after EPA finalized their rule, we asked them to reconsider, and now we're suing them.

Time and the court will tell if this totally unsupported, totally bone headed, and patently illegal rule stands or falls, but one thing is clear is that the whole thing is a self-inflicted black eye for the ethanol industry at a time when ethanol's green-cred is being questioned every day.

Don't worry some of my friends in the industry said. Just because the fed's raise the pollution levels doesn't mean the states will follow. States can't set looser standards than the feds, but they can, and many do, set stricter standards forcing polluters into federal permitting at lower levels. And this is where Ohio steps in to grab the lead anchor. Ohio is weakening its standards right to the federal levels.

According to the article, Ohio is behind in the ethanol race with no operating plants and a wimpy seven under construction. If they all come on line, they'll have the capacity to produce 350 million gallons per year.

"This is being proposed in order to be more competitive in the ethanol marketplace," spokeswoman Linda Fee Oros is quoted saying in the article. Now it's not clear if she's a governor's spokeswoman or an OEAP spokeswoman, but aren't air regulations supposed to protect the public health not drive economic development?

I believe that to stop and reverse global warming, we need to make biofuels work as part of a package that includes more efficient vehicles, smart growth, and plug-in hybrids. These weaker air regulations are first and foremost bad for public health, but they're also bad for the industry, and in the end that makes it that much hard to solve global warming.

Biofuels equals water pollution? Depends on how you look at it

2007-06-22T06:07:41Z

An interesting article in Environmental Science and Technology today connecting fertilizer use, water pollution, and agricultural subsidies. Much has been made about how the increased demand for corn to make ethanol will drive increased use of fertilizer and as a result increase water pollution. As I discussed here, this impact is likely to be particularly acute because of the demand for corn is growing so fast. The WRI report I linked to in my earlier post, both showed this impact through detailed modeling and also suggested an important set of near-term policies that could help including measures such as requiring nutrient management plans in watersheds that are already overloaded and encouraging much broader use of riparian buffers.

The problem of fertilizer use and water pollution is also a prime example of another challenge facing biofuels and agricultural policy more broadly--different stakeholders use different metrics and as a result see the problem differently and the ideal metrics are very hard to measure accurately and affordably.

Take for example nitrogen. The environmental community generally focuses on pounds applied per acre and point out how this number has been going up for corn for the last 30 plus years. As in the ES&T article above, the greater total application is linked to greater fertilizer runoff into streams and rivers and cumulative impacts like the hypoxic zone in the Gulf.

Farmers on the other hand tend to focus on pounds applied per bushel of yield and point out that this number has been going down for 30 plus years. From this perspective, if agricultural practices and technologies hadn't gotten significantly better over time and society still wanted the same amount of corn that we consume today, we would be cultivating a lot more acres and using much more total fertilizer.

Both perspectives are correct, but both miss the point to some extent. What really matters is the amount of runoff (and oxidization if you care about global warming) not the amount applied, but measuring this from specific farm is expensive to do accurately. We now certain practices such as nutrient management plans and riparian buffers reduce runoff, but the models, which are relatively affordable, can't tell us accurately how much pollution is reduced from specific practices on specific acres of land under real weather conditions.

This is no excuse for in action; we should take the steps WRI and other nutrient managers recommend. But we should also spend some time and money getting much better at developing affordable and accurate tools for measuring the actual performance of farmer. If we're all looking at the problem from the same perspective, there's a much better chance that can agree on the regulations and incentives needed to fix it.

Truth and laughter re: mercury and compact fluorescent light bulbs

2007-05-12T00:12:48Z

Back on April 30, the Washington Post ran an article titled "Fluorescent Bulbs Are Know to Zap Domestic Tranquillity - Energy-Savers a Turnoff for Wives." The articles was emailed around here within NRDC's Air&Energy program and provoked a hail storm of emails some agreeing, some bemoaning the sexist slant of the article, some arguing that there is no discernable difference in the quality of light between a good compact fluorescent and a regular old incandescent. I promise you that only people that care very deeply about saving energy could spent that much time emailing about one article.

In the interest of full disclosure, I'll admit that there are certain lights in my home that my wife as put off limits for CFLs. But I've been slowly winning her over as I've learned more about how to buy the right CFLs. Turns out that different CFLs emit different color light and if you want a dim moody light, you have to go for a very low watt CFL. Even for an energy geek like myself, it's hard after a life time of buying 40, 60, or 100 watt bulbs to accept that 5, 10, and 15 will do the trick. I found this article from Popular Mechanics to be helpful.

In some sort of strange coincidence, that same day here in the office we showed a promotional vedio for Relight New York, an effort by high school students to fight global warming and raise awareness of energy efficiency by giving CFLs to low income families here in the city. Yours turely did a little interview to help the inspirational effort along, some of which can be seen in the WNBC story here. I was glad to be able to help, but I'll confess working with high school students made me feel old.

In all the hubbub, someone circulated the story about a Maine woman who broke a CFL in her room, called around to find out how to clean it up, was told that CFL's contain murcury, and was eventually given an estimate of $2000 to have a haz-mat team come in and clean it up. Of course the article goes on to point out that she could alternatively just use her vacum and that the level of murcury, while high over the remains of the CFL, posed no health threat unless the woman kept her face within 3 feet of the remains for a very long time. But that didn't stop the right wing talkers from claiming that CFLs are going to kill us all and how this was an other example of how environmentalists are misguided or maybe even evil.

Turns out that CFL's contain about 5mg of murcury compared to a thermometer which contains about 500-3000 mg. Also by reducing the amount of electricity that we waste and thereby reducing the amount of coal that we burn, CFL's avoid much more murcury pollution than they could ever cause even if they were all disposed of improperly.

Now it turns out (see here and here) that Wal-Mart (irony is not the right word for what I feel writing that, more like hope), is going to make the CFL decision even easier. Working with their suppliers in a way that only Wal-Mart ca, they're going to reduce the murcury in the CFLs that they sell by about one-third.

As my colleague and friend Noah Horwitz is quoted as saying about this move: "People concerned about the environment and their health can buy these CFLs with a clear conscience."

Bottom line, we should all dispose of our old CFLs at loc