May 5 2009
Today, the U.S. Environmental Protection Agency (EPA) released its proposed rule for implementation of the Renewable Fuels Standard (RFS) as signed into law as part of the Energy Independence and Security Act of 2007. The proposed rule details all aspects of RFS implementation, including calculations of greenhouse gas emissions for all fuels covered by the standard.
“EPA has done yeoman’s work in developing the framework upon which the expanded Renewable Fuels Standard (RFS) will be implemented,” said Renewable Fuels Association President and CEO Bob Dinneen. “The success of the RFS to the nation’s economic, environmental, and energy well-being is too important to risk getting wrong. We commend EPA staff for the hard work they have put into this rulemaking and look forward to working with them to improve upon the analysis in the months to come.”
One area in which the RFA will engage EPA is over the issue of lifecycle greenhouse gas emissions related to the production and use of ethanol. EPA analyzed both direct
GHG emissions, which are those associated with the biofuels supply chain, as well as highly uncertain emissions assumed to occur through indirect impacts. The Notice of Proposed Rulemaking from EPA on the RFS concludes that grain-based ethanol reduces direct GHG emissions by more than 60% compared to gasoline. (Calculations based on data found on page 591 of the proposed rule.)
“EPA has reconfirmed the fact that when directly compared to gasoline, ethanol significantly reduces greenhouse gas emissions,” said Dinneen. “This apples-to-apples comparison reaffirms the substantial greenhouse gas reductions offered by ethanol calculated in numerous studies including one done recently for the International Energy Agency.”
The RFS, as passed in the Energy Policy Act of 2007, requires specific GHG reductions for the various renewable fuels included in the regulation. Specifically, corn starch ethanol must reduce GHG’s by 20%, advanced biofuels and biodiesel by 50%, and cellulose-based ethanol by 60% when compared to gasoline. Direct emission calculations show that all fuels meet that requirement.
EPA has also attempted to calculate indirect emissions that occur as a result of purported land use changes and other factors occurring domestically as well as internationally. The controversial notion of indirect land use changes impacts, including those happening outside the U.S., are thought to greatly reduce ethanol’s GHG benefit. The RFA welcomes the debate over these issues.
“We welcome an open and robust science-based discussion of the indirect impacts of all fuels,” said Dinneen. “The science of market-mediated, secondary impacts is very young and needs more reliance on verifiable data, and less reliance on unproven assumptions. Done correctly, such an analysis will demonstrate a significant carbon benefit is achieved through the use of ethanol from all sources.”
Initially, the RFA has identified some key areas in which more work will be needed, including:
- The value of feed co-products
- Future crop yields
- Accuracy of satellite land cover imagery
- Carbon stock rates associated with various land types
- Indirect GHG impacts from other fuels
- Various methods for time accounting of GHG releases
- Praising the creation of the Biofuels Interagency Working Group, Dinneen issued the following statement:
“President Obama is making clear once and for all that biofuels are critical to the nation’s economic, environmental and energy strength. Investments in biofuels, like ethanol, are creating green jobs here at home, reducing America’s foreign oil dependence, and helping to meet our environmental goals. We are confident that this working group will further spur the momentum generated by America’s existing biofuels industry and deliver the promising next generation of biofuel technologies that are so close to commercialization.
“America’s ethanol industry faces an unprecedented set of opportunities as well as challenges. Revolutionary new technologies that turn once thought of waste materials into renewable fuel are very close at hand. These technologies will create the kind of economic and green job opportunities, as well as provide cleaner solutions to petroleum use, that President Obama desires. Yet, uncertainty remains for many of these technologies as unproven science and questionable logic are being used to penalize existing biofuel producers for carbon emissions occurring halfway around the globe for reasons that may have little, or nothing, to do with US biofuel production.
“The RFA fully supports the steps President Obama is taking and pledges to work with this administration to realize the full potential of a robust and diverse American biofuels industry.”