Entrepreneurs speak out for good rules for biofuels
- Nathanael Greene
- Director of Renewable Energy Policy, New York City
- Blog | About
- Posted December 3, 2008 in Moving Beyond Oil , Solving Global Warming
Yesterday in California, a group of twelve developers and investors in next generation biofuels (including Vinod Khosla) released a letter to the California Air Resource Board supporting the development of rigorous GHG accounting for biofuels. While the letter supports CARB's inclusion of emissions from indirect land-use change caused by some biofuels, the letter goes further to call for some specific measures that could help chart a course forward on this tricky issue. By productively engaging to help make sure that California's low carbon fuel standard is both strict and encourages the development of the best biofuels technologies, this letter is an important addition to battling letters I've written about before.
As a little context to highlight how important this is: Yesterday yet another scientific article came out in the journal Conservation Biology quantifying how important it is to keep biofuels from leading to increased deforestation. The article calculates how long it takes to make up the carbon released from tropical forests through the avoided GHG emissions from petroleum fuel. The article finds that it would take 75 years worth of biofuels production for a typical tropical forest and 600 years for a forest with peat soils. While the article looks at the direct clearing of forests for biofuels, the same carbon calculus comes into play indirectly through land-use change.
That's why its so important that the entrepreneurs' letter starts off:
The undersigned endorse the California Air Resource Board’s (CARB’s) prioritization of an environmentally responsible approach to the Low Carbon Fuel Standard (LCFS) and indirect land-use change (ILUC).
Along with offering this support, the entrepreneurs calls on CARB to take a number of steps to ensure that the regulations provide clear direction to developers and investors about the performance of different technologies and practices, and provide this direction in a way that encourages innovative mixing and matching of options. Understandably, the next generation developers want to make sure that the most promising feedstocks, management practices, and conversion technologies will be carefully and specifically assessed by the regulators and not simply be treated like first generation technologies.
I think all the evidence suggests that both CARB and EPA are already moving to assess the most promising options and that they want to do more as they continue to develop their rules. However being sure to develop a menu of options based on specific proposals with input from the industry will be an important step to making sure the LCFS and RFS really work.
Specifically the letter says:
We believe the following items should be part of the LCFS and are at least partially addressed in the October draft of the LCFS:
(1) The use of a comprehensive evaluation system that promotes higher productivity, waste biomass utilization, non-food feedstocks, and increased soil carbon sequestration.
(2) A clear price signal for the carbon value attributed to various fuels, distinct from inherent fuel value.
(3) The encouragement of facility-specific certification for direct GHG measurement.
And the menu of options that the entrepreneurs want covered under the comprehensive evaluation are addressed in the following section:
1. Minimization of land impacts. The indirect land use measurement should incorporate a consideration of what the land in question is capable of providing and its prior use. The calculus should have the effect of encouraging land use in the following order:
i. No land used (e.g. forest waste, rice straw)
ii. Seasonal cover crop (e.g. sweet sorghum)
iii. Displaced fiber crop (e.g. cotton)
iv. Displaced forage crops (e.g. pasture)
v. Displaced animal feed (e.g. alfalfa)
vi. Displaced human/animal edible crop (e.g. corn, soy)
vii. Displaced human edible food (e.g. wheat, rice, vegetables)
2. Maximization of productivity. The combined effects of the ILUC and direct measurements should encourage the following:
viii. Production/acre – Reward improved productivity (in BTUs) per unit of land.
ix. Water efficiency – Reward the use of non-irrigated land and water reduction below prior use. We recognize that this may create a need to equate water usage and GHG production. Fortunately, in California, there are models for the embedded GHG effects of water utilization, and we assume that these or comparable models can be applied in the rest of the country where irrigation is used.
x. Land improvements – Reward practices that improve the carbon sequestration in soil, including non-till practices and biomass systems.
xi. Protein and electricity co-products – Rewards for the creation of protein/animal feed and electricity.
By embracing the challenge and importance of emissions from indirect land-use change and also helping regulators understand what the industry needs in the LCFS to be able to invest in the biofuels options that avoid and minimize these emissions, this letter is big news.
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Comments
Brooke Coleman — Dec 3 2008 05:41 PM
Nathaniel,
As one of the signatories to one of the "battling" letters, I think it makes sense to post a response.
The E2 letter is a thoughtful addition to the debate. We need to move the debate from healthy critique toward resolution. The principles proposed by the letter are constructive and largely helpful.
But something needs to be clarified. Your posts do not differentiate the letter signed by 25 advanced biofuel companies, myself, and Vinod Khosla from the other battling letters. The key points of difference are: (1) we do not advocate for "zero as the right ILUC answer;" (2) we raise largely technical questions about assumptions and metrics used in the modeling, which sticks to the science and remains productive; (3) we do not offer the argument that if there is uncertainty then we cannot move forward.
With specific regard to the LCFS situation, people seem to be missing a very basic but important point. By including indirect land use change in the biofuels "carbon score" the Air Resources Board is going outside of the system boundary used to judge other fuels in the regulation. The obvious result is that biofuels are judged through a different lens than the other fuels they are expected to compete with (e.g. natural gas, etc.) under the LCFS.
You can say that "indirect land use" is important, and everyone will agree with you (including the New Fuels Alliance). But it's inclusion in the regulation should not come at the exclusion of carbon emissions that might occur outside of the system boundary for other fuels. The importance of indirect land use notwithstanding, this creates a fundamental bias in the regulation.
The most obvious example of the double standard in the LCFS is between petroleum and biofuels. The biofuels carbon score is based on the average national U.S. biofuel gallon + domestic and foreign indirect land use change. The petroleum carbon score, on the other hand, is based on an assessment of the California gallon of fuel only. The petroleum number is not inhibited by national averages (which are dirtier). It also does not have attached to it ANY land use change, or any other leakage effects. The system boundary for petroleum is California. The system boundary for biofuels is the world.
Again, the core of our argument is not that ILUC science needs to be tossed out the window. It is that all fuels should be judged through the same lens in the LCFS. If you want to add what amounts to a "leakage penalty" to biofuels -- because indirect land use change is really leakage outside the default system boundary -- then we should not pretend that zero is the right number for leakage values for other fuels. Your principle of "zero is not the right answer" is a good one, but it should not be used selectively.
It is not enough to suggest that the land use footprint of petroleum is small. That is a possibly right answer to the wrong question. The land use of petroleum (e.g. destruction of lands for tar sands production) is a direct effect inside the petroleum system boundary that must obviously be included. It is not the corollary to biofuels paying a carbon price for someone else's land use (which is what indirect land use is).
The right question is this: what carbon emissions are likely to occur outside of the system boundary for all fuels under this regulation? What we need, if ARB wants to assign leakage values to fuels, is a comprehensive leakage assessment for all fuels. To date, CA has only done so for biofuels (and California has only funded leakage analysis of biofuels).
The leakage effects may be small for some, bigger for others, but certainly not zero. The problem with the E2 letter is that while proposing constructive solutions to many problems, it seems to implicitly support the idea that biofuels should be judged with a different system boundary than other fuels.
Correct me if I am wrong, but this does not send a good (or fair) price signal.
Nathanael Greene — Dec 5 2008 03:48 PM
Thanks for the comment, Brooke.
I recently heard a good classification for the different approaches to lifecycle analysis. The traditional approach of looking just at the direct impacts of a product can be call "attributional" LCA. This is basically an engineering approach. There can be lots of uncertainty, but this is the approach most of us are familiar with.
Once we start looking at the indirect emissions, we start shifting to "consequential" LCA. As the name suggests, this approach assesses the consequences of using a product. This approach is most commonly used in assessing policies and involves economic models. Again, there are uncertainties, but they of a different type.
To your point, as I've said before, I agree that since we're prepared to use consequential LCA for biofuels, we should be open to using a similar type of analysis for oil. I also agree with you that the reason to add in consequential analysis into our LCA (and as you know CARB is limiting its consequential analysis for biofuels just to the ILUC issue--the rest of their approach is pure attributional) is because of leakage. And I would argue that given the uncertainty inherent in economic modeling, that the potential for leakage should be large.
But before we argue about that last point, what is the source of leakage from petroleum fuels in the first place? As you point out, lands for tar sands is a direct emissions, and I agree that it should be included. To borrow your phrase, it's not enough to say we should include leakage--the models don't work that way. What is the indirect impact from petroleum that CARB should look at?
Brent Baker — Dec 5 2008 04:28 PM
Nathanael--If you want to measure the emissions of a tractor used to plow a biofuel crop field then you should also measure the emissions of every hummer used to secure an oil field in the middle east.
Brooke Coleman — Dec 9 2008 01:13 PM
Thanks for the thoughtful response Nathaniel. You make some good points.
I think “attributional LCA” works, because they are the carbon effects that can be attributed to the production and use of the fuel. “Consequential LCA” is still a little bit misleading, because it implies a set of carbon effects occurring as a consequence of producing and using the fuel.
In fact, the consequential LCA of one fuel is the attributional LCA of another product. For example, if 20 acres of biofuel feedstock production pushes 20 acres of cattle-feed production (e.g. corn) into grassland somewhere else, you are saying that the cultivation of the grassland is the consequential LCA of the biofuel. But it is more directly the attributional LCA of the cattlefeed, because that is the direct reason the grassland is cultivated. So one can call it the consequential LCA of biofuel, but did it happen as a consequence of biofuel or cattle, or both?
And with “causation” in mind, there are then an additional dozen or so variables that determine whether that 20 acres of grassland is converted to cattlefeed at all, including demand for meat, price of corn, cost of conversion, commodity prices, liquidity of farmer, etc. As paper after paper has pointed out, land use change variables are nested and synergistic. So in my opinion, “consequential LCA” implies single-factor causation, which is wrong. Further, biofuel production produces cattlefeed as a by-product, so that must be factored in as well.
To answer your question about petroleum, we cannot know before we take a hard look. To be clear, I said it is not enough to say the petroleum effects are small, because clearly they are not zero and may not be small. I encourage you to take a look at the book Curse of the Black Gold – 50 Years of Oil in the Niger Delta. Similar books detail the impacts of oil in other countries, like Ecuador. The obvious stuff: rainforest development from roads and exploration, military energy consumption for protection of resources and shipping lanes (and maybe even wars), destruction of sensitive carbon absorbing lands via oil spills and contamination. But consider also that Canadian tar sands oil producers are using roughly 25% of the available natural gas in the region to extract and cultivate oil sands into fuels. There is definitely a market-mediated effect there, and natural gas has its own set of indirect effects that should be attached to the fuel.
But the analysis requires more than just cherry-picking embedded impacts we think are visible by the naked eye. If we are going to expand the system boundary to include effects that may not be directly attributable to the fuel but happen as a consequence of using the fuel, the question is to what degree should we add the consequences of petroleum to the petroleum score? Should we add the massive amount of methane being released from permafrost melting, for example?
Even when you look at the root causes of rainforest degradation, many of them are attached to oil: poverty and subsistence farming, timber, higher commodity prices. In fact, on this last one, a cornerstone of the indirect land use change argument is that biofuels will drive up the demand and price for commodities like corn and soybeans, which will in turn cause people to plant more of these commodities on sensitive lands in response to revenue generation potential. But historically, corn and soybean prices track oil prices (see the last 12 months). If oil dependence is one of the true causes of soybean price increases, and soybean price increases cause rainforest development, should we attach a carbon penalty to oil too?
The consequential impacts of petroleum are immense and complicated. But what are we doing if we ignore the consequential impacts of petroleum in the LCFS while we add them (or at least the negative ones) for biofuels?
We are tilting the playing field. Even more. Right? Maybe this is why the oil industry does not seem unsettled at all by the proposed LCFS.
I appreciate the discussion, Nathaniel.