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EPA releases RFS2 proposed rule for public comment

Nathanael Greene

Posted May 5, 2009

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At a "press availability" today EPA Administrator Lisa Jackson released the agency's proposed rule (EPA factsheet) to implement the new renewable fuel standard, which requires the first ever federal lifecycle greenhouse gas performance standard (EPA factsheet) for biofuels. Put more plainly, EPA took the second step (Congress having taken the first in passing the law) towards requiring biofuels to actually be better than gasoline. This is a critical step towards getting biofuels right.

Here's what I said in a press statement we released today:

EPA has taken an important step towards getting biofuels right. Our economy and our planet can’t afford to burn any type of fuel that will only create more pollution, but through innovation we can develop  renewable fuels that are better than oil and will never run out. 

It is imperative that we develop biofuels the smart way, and we are encouraged that EPA Administrator Jackson has offered a science-based proposal to get this done. If we get the rules of the road right through policies such as this one, we can harness the ingenuity of America’s farmers, foresters, and entrepreneurs to create a new generation of biofuels that will help create jobs end our dependence on oil.

The opportunity to review EPA’s proposal will help ensure that biofuels don't mean using our most fragile forests for fuel and that biofuels provide real benefits. We plan to submit comments on what EPA has gotten right and what must be improved to make sure the outcome serves our environmental and energy needs.

As my statement make clear, NRDC looks forward to reviewing the proposed rule (here's actual proposed rule--1000+ pages--and here's regulatory impact analysis--850+ pages--both large PDFs) in detail and submitting comments on the parts that we think EPA has gotten right and those that we think need improvement. For instance based on an cursory initial review, it looks like EPA has done a good job on the scope of emissions—direct and indirect—that they have included. However, we have some initial concerns on how EPA appears to have accounted for those emissions over time.

EPA has also committed to a peer review process for their lifecycle emissions modeling. We believe that this is appropriate for such complex and cutting-edge science. We look forward to seeing the results from that process.

The Administrator made the announcement along with Secretaries Chu and Vilsack from DOE and USDA respectively. The three agency heads also announced a coordinated effort to encourage the development and deployment of advanced biofuels and to get more environmental benefits from biofuels in general. I understand that about $2billion $786 million dollars may have been put on the table by DOE for this and that Secrtary Vilsack promised to full fund biofuels related farm bill programs. This Reuters article provides some detail on a presidential memo establishing this coordinated effort. As I've written before NRDC has been calling for a strong focus of government support to advanced biofuels and to launching them in the best possible way.

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Asa WattenMay 8 2009 11:43 AM

Assuming the controversies over lifecycle modeling and ILUC are reasonably resolved, after a brief review of the proposed rule, what I’m most curios about is this the EPA’s net present value calculation for carbon emissions. Why 30 years and why a discount rate of 0%?

Low discount rates are good for looking at the NPV of carbon abatement financial decisions. We should value future generations similarly to how we value or own. But I’m not so sure the same argument applies to low discount rates for future carbon abatement.

From everything I have read, it is more important to reduce heat trapping gasses today than it is 30 years from now. How much should future emissions be discounted? I’m not sure, I’m not a climatologist. But I would love to find out.

Logic tells me that a discount rate for future carbon reductions is vital for policy decisions so that we don’t equally value abatement strategies that reduce GHGs in a century, after our climate has changed considerably, to strategies that reduce GHGs today.

On a related side note: as a supporter of sustainable biofuels, I’m very happy to see NRDC’s efforts to distinguish between biofuels and “biofuels done right.” Good work!

HarryMay 16 2009 09:37 PM

This is great analysis. Has a similar analysis been done on the draft "American Clean Energy and Security Act of 2009" in terms of its proposals regarding ethanol? The bill seems to have a lot of environmental support, but I'm concerned that the measures related to biofuels will further increase food prices with limited (at best) environmental benefit.

Thanks for all of your work!

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