Now more than ever, time for EPA to act on biofuels
- Nathanael Greene
- Director of Renewable Energy Policy, New York City
- Blog | About
- Posted November 8, 2008 in Moving Beyond Oil , Solving Global Warming
Hard to believe that my last post was more than a month ago. Things have been happening so fast and furiously of late that it feels just like yesterday and also like years ago. Now that the election is over, we have a historic opportunity and challenge in moving our economic and environmental policy forward, but we also face a real risk of the Bush administration in its last flailing gasps derailing foundational policies that we will need to chart our way forward. This is especially true in the area of biofuels.
The renewable fuel standard is far from a perfect policy tool, but it does include groundbreaking lifecycle GHG standards and renewable biomass sourcing safeguards. The lifecycle emissions accounting especially is a fundamental tool that we need to get right if we are to have any hope of knowing if the biofuels we're developing are part of the climate solution or part of the problem.
Recently there have been a spate of articles (e.g. this and this) about how EPA is coming under political pressure to ignore a major source of GHG pollution--emissions from changes in land-use induced by biofuels. Much of this pressure has come in the form of letters from industry groups (Bio's letter, Soybean Growers' letter) and a few academics. Even the Brazilian government has sent a letter. Some would have EPA simply ignore these emissions--also known as emissions from indirect land-use change (ILUC). Others would have EPA only propose a method for calculating these emissions and not any draft values.
So far these letters have been met by two countervailing letters from environmental groups. One is from the Clean Air Task Force, Environmental Working Group, and Friends of the Earth and is general; the other is from Conservation International, Defenders of Wildlife, and the National Wildlife Federation and addresses some technical issues.
On Monday, EDF, FOE, UCS, NWF, and NRDC will send EPA (and cc USDA) another letter making the following points:
- By law EPA must include the emissions from ILUC (this post has the specific language)
- ILUC is real and big for certain sources of biomass, and thus EPA must include these emissions to ensure that biofuels produce real GHG benefits instead of increased pollution
- EPA has been engaged in a rigorous rule making process that has drawn on the best available science and economics and the rule will continue to improve through the notice and comment process
- There is ample biomass that incurs little or no ILUC emissions to launch the advanced biofuels industry and comply with the RFS requirements
These arguments are also being played out to OMB, where industry and environmental groups have made their case, and out in California where the Air Resource Board is wrestling (here's ARB's website on the LCFS) with exactly the same challenge in terms of developing a lifecycle GHG accounting protocol. (The letter debate to CARB started this summer as I've written about before.)
In many ways, it's this letter to CARB, signed by many in the advanced biofuels industry under the auspices of the New Fuels Alliance, that I find most disturbing. The letter freely mixes good points that could serve as helpful, constructive input into a good ILUC accounting with philosophical arguments for ignoring emissions from ILUC and misleading claims about the science, scale, and importance of including these emissions. The letter really deserves a post all its own, but let me just address a few examples of the type of arguments made:
- The letter makes a good point that accounting for ILUC should take particular care to assess the impacts of some of the most promising ways of minimizing and avoiding these emissions so that we can identify the best paths forward for the industry.
- The letter make much of the uncertainty surrounding precise estimates of the ILUC emissions from different sources of biomass, but uncertainty is not an excuse for inaction. This same argument has been made by opponents of action on global warming and has put our world at great peril. The science and economics are certain enough for a high degree of accuracy about the relative scale of these emissions and CARB and EPA are drawing on the best science and modeling.
- Finally the letter spends a lot of time making claims of injustice and risk because indirect emissions from petroleum have not been included in CARB's draft. While certainly economically mitigated emissions for all fuels should be included, to the best of my knowledge no one has done any analysis to suggest any such source of emissions related to petroleum is large or even presented a logic for how such a source might be large. Heck, I want to believe, but I can't think of a source (not saying much, I'll readily admit) and we should not ignore now what we know can be large because we might in the future come up with one.
Two last points: one, as I've said before the first and best way to deal with ILUC emissions is to regulate them directly. We need an international cap on GHG emissions that includes emissions from land-use change. And when we get one, we should stop regulating these emissions from biofuels. At that point those emissions will be capped and any increase caused by biofuels will have to be offset elsewhere in the system. But let's be honest, such an agreement is years away and in the meantime the biofuels industry will invest billions of dollars (I hope) in facilities and feedstocks. Federal and state mandates and incentives should be spent making sure these investments have the greatest chance of providing real benefits and surviving under such a future cap.
And two, I continue to believe that the advanced biofuels industry is missing an opportunity to distinguish themselves in the eye of the public and investors from the first generation industry by not embracing ILUC accounting. The news has been full of articles about the first generation of ethanol investment struggling. If enough of the industry keeps insisting to regulators that it can't survive if the emissions from ILUC are part of the criteria for public support, eventually everyone is going to believe them and that will spell the end of public support, investment and one of the industries main reasons for being.
It's time for industry leaders to stop trying to convince EPA and CARB to ignore ILUC emissions and to start signing on to letters that say "Yes we can, and here's how."
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Comments
Jim Bullis — Nov 9 2008 05:17 PM
I feel it necessary to suggest that your focus on biofuels is not likely to lead to much progress on global warming, and it would be better to seriously address a
major crisis in development in connection with the bailout of the automobile industry.
This can be understood by looking at the GM plan linked below. It shows a kind of thinking that is in dangerous opposition to climate progress. It is not really disguised, though at a glance it seems benign enough.
The link below shows a plan that needs to be carefully read:
http://fastlane.gmblogs.com/PDF/presentation-sm.pdf
After reading this, then think about how the 25-50-100 billion and change that we are about to hand to Detroit to “retool” to build “high efficiency” cars.
When the plug-in Yukons, or whatever SUVs, are cruising on coal, we can all feel proud of our support for the auto industry. (See sarcasm dripping from this sentence.)
A campaign to insist on real fuel efficiency in response to aid, where this real fuel efficiency would require complete rethinking of personal cars, could solve much of the global warming and oil dependency problems, while setting up our industrial capacity with products that could make USA an world industrial leader again.
Brooke Coleman — Nov 10 2008 04:46 PM
Nathaniel,
As one of the primary authors of the New Fuels Alliance letter I appreciate the opportunity to respond.
First and foremost, we continue to appreciate your role in developing good biofuels policy. In many cases, you have asked for and promoted a more robust and nuanced debate about biofuels. That said, it is my personal belief that this post does not inform the ongoing debate.
Pitching the debate around indirect land use change (ILUC) as a classic industry versus environmentalist smack down where critics of ILUC are associated with profiteering global warming deniers is unfair and counterproductive and conveniently allows your readers to ignore the substance of the criticism (as well as the credentials of the critics).
Please consider the 30 signatories. They are the leaders of the advanced biofuel industry you have praised as our best hope to reduce the carbon intensity of liquid fuels in the near term. There are others. 25 respected scientists from some of the nation’s leading bioenergy laboratories and universities have weighed in. Michael Wang, author of the model being used in California for the LCFS, recently asserted that while ILUC must be studied, “conclusions regarding the GHG emissions effects of biofuels based on speculative, limited land use change modeling may misguide biofuel policy development.” There is a substantive conversation happening here.
Instead of giving merit to the debate, and its participants, you frame it as between those who want to include a real GHG impact and an industry that wants to ignore a real GHG impact. This is too simplistic. Here is some more detail:
1) Our letter does not ask for an omission, it asks for a much closer inspection of “an addition” that is not being applied to other fuels. To date, all fuel pathways under the LCFS are penalized for their direct effects. Biofuels, however, are penalized for their direct and indirect, market-mediated effects. Enforcing indirect effects has never been done before and CARB’s numbers are all over the place, depending on the assumptions adopted by staff. You can imagine why biofuels producers of all types are concerned about the approach, and are asking for a closer look. Unlike the RFS, a performance-based standard like the LCFS must judge all fuels through the same lens, or risk picking winners and losers. Right now the LCFS does not pass this basic test.
2) We raise questions about the merits of enforcing indirect effects from a public policy perspective. This does not mean we are advocating for "inaction." Imagine being required to offset the carbon impact of every flight you take. Now imagine being required to pay for the carbon footprint of the person who cannot sit where you are sitting on the plane. Should you pay for the carbon footprint of the other traveler or should he/she? Your response, to your credit, is to acknowledge the problem; that “the first best way to deal with ILUC emissions is to regulate them directly.” In other words, to each his own; if cattle or timber or food production results in rainforest clearing, and they pay for it, biofuels wont need to pay for their carbon footprint. But until then biofuels should? It should not be disturbing that we want to discuss that proposal more closely.
Perhaps the most baffling part of the environmental community’s position on ILUC is their disregard for the potential indirect effects of other fuels. It is a basic proposition that if California regulates one fuel more stringently than another in a performance standard they are tipping the playing field. Perhaps this is why the oil industry now cares so much about the indirect effects of (bio)fuels (wink wink). The LCFS is supposed to establish a level playing field.
You say it is hard to imagine indirect effects for other fuels. That is hard to believe. It is not difficult to imagine greater dependence on tar sands petroleum if biofuels are not used. It is not difficult to imagine greater nickel mining for car batteries, or natural gas/coal use for grid-dependent electric and plug-in hybrid electric vehicles. There is a natural gas boom going on right now in your own state. We just witnessed the economically-mediated impacts of oil dependence, as spiking oil prices drove up the price of everything from food, to home heating to many consumer products. No doubt there will be more wood burning with higher heating oil prices. Oil clearly drove up soybean prices, which by your argument caused planting in Brazil. Why have you not advocated for adding that to the oil equation? Saying these impacts are small without offering data is not compelling.
We understand the need for resolution. Getting to yes is everyone’s goal. But the biofuels industry does not need a lecture about how it should be communicating with EPA and CARB. It needs the environmental community to get beyond the mantras of big bad industry and big bad agriculture so that we can have a substantive debate about the likely impacts of the currently proposed LCFS and the science behind it. Neither of us should be for protecting the oil industry’s market share, and we look forward to resolving this issue.
Sincerely,
Brooke Coleman
New Fuels Alliance