Both Massachusetts and New York City are considering a mandate that heating oil contain an increasing percentage of biodiesel. The resulting mix, known as bioheat, has some air quality benefits but, like most biofuels, can either be good for the environment or bad depending on how the feedstock is produced and how the fuel is refined.
I took a broadly negative stance on the idea of a bioheat mandate early this year when I testified in front of the MA Advanced Biofuels Taskforce arguing that such an approach tried to pick winners and failed to ensure any really environmental benefit. The situation has become more complicated since then. While the MA ABT has recommended to go ahead with a mandate, it also recommended adopting a low-carbon fuel standard, and it was this latter idea that the political leadership of the state focused on.
In NYC, where there's actual legislative language being kicked around, there have been various attempts to incorporate general and vague reference to sustainability standards. More importantly the idea of the mandate is linked to requirements for wider use of low-sulfur diesel and requiring oil-fired boiler to update their air pollution permits. These additional requirements could make a big reduction in air pollution from this very dirty family of boilers.
Unfortunately, as this article details, there's a rush to try push the bioheat mandate through that's putting these benefits at risk by not requiring bioheat to actually produce less global warming pollution than regular heating oil.
Both the California Air Resource Board and US EPA are in the midst of developing the accounting protocol to measure the full lifecycle GHG emissions of different biofuels. The recently passed renewable fuel standard requires all biofuels from new facilities to produce at least 20% fewer GHG emissions than gasoline or diesel and biodiesel would have to comply with the advanced biofuels standard of a 50% reduction.
So why would MA and NYC adopt a bioheat mandate that didn't at least require the biodiesel being used to make the bioheat to meet the renewable fuel standard GHG levels? Do we really want local markets for substandard biofuels--biofuels that are not good enough for the rest of the country--biofuels that may actually make global warming worse?
I can understand that some developers might be worried that they won't comply with the RFS standards, but why would the City Council or MA legislature want to do something supposedly to fight global warming that might actually make it worse? Why wouldn't they simply require their respective environmental agencies to start implementing the mandate as soon as the lifecycle accounting protocol becomes available next year? At this point, they probably couldn't start the mandate until winter of 2009 at the earliest and 2010 is more realistic. So we're talking a year delay in when the mandate kicks in and the bill could be passed today.
My recommendation to MA and NYC are simple:
- Have the mandates go into effect as soon as either CA or EPA promulgates lifecycle GHG accounting protocol;
- Require all biofuels used to make bioheat be at least compliant with the 50% reduction requirement in the RFS (personally, I think we could shoot a little higher, but let's at least not be substandard); and
- Don't specifically require biodiesel, which is a very specific type of biofuel--instead open the mandate to any diesel alternative that meets all relevant health and performance specifications;