As you, my loyal readers, sweating away your August with hopefully better things to do than read my dribblings, will almost certainly not recall through the haze of July's global warming induced thunderstorms, back on July 10th, I testified before the Energy and Public Works, subcommittee on Clean Air and Nuclear Safety. As is often the case, after the hearing I recently received some follow up questions for the record. This time they came from Senator Barbara Boxer and they are, not surprisingly, smart questions that many might be interested in. So, here they are along with my answers.
[I'll be on vacation for the next two weeks and won't be blogging, but I wish everyone a great rest of the summer full of better reading than this post and better than the winners of the the 26th annual Bulwer-Lytton Fiction Contest.]
Question # 1
What role does the RFS program play within our broader efforts to fight global warming?
If the environmental safeguards and minimum lifecycle GHG standards in the RFS are effectively and aggressively implemented the RFS will play two important roles in our efforts to stop climate change. First, the implementation of the biomass safeguards and lifecycle GHG standards are critical foundational tools needed to make sure biofuels are part of the solution and not part of the problem. The effective implementation of these tools will require the development of a lifecycle GHG accounting system and a claims tracking and verification system allowing regulators and the market to differentiate between good biofuels and bad. Without these tools, we will be unable to harness the competitive and innovative energies of the market to develop more sustainable and truly low-carbon biofuels. This would likely result in the deployment of biofuels that can make global warming worse and contribute to major non-climate environmental impacts like deforestation, biodiversity loss, and the decrease of ecosystem resilience and integrity.
Second, the RFS is overwhelmingly focused on requiring the development of second generation biofuels. Of the 36 billion gallons required under the RFS, 21 billion must be advanced biofuels and provide at least a 50 percent reduction in GHG emissions compared to gasoline. Of this 21 billion, at least 16 must be cellulosic biofuels and provide at least a 60 percent reduction. Unless Congress acts to encourage improvements and conversions of existing and under construction corn ethanol plants, the benefits of these advanced biofuels will be reduced by the emissions from these first generation fuels. Nevertheless, by driving the commercialization of these advanced fuels, the RFS will make a major contribution to our broader fight against global warming.
Question # 2
Will passing a broader global warming bill, such as Lieberman-Warner, help achieve the goals of the RFS program, and if so how?
A comprehensive, economy-wide carbon cap and invest policy that includes complementary policies such as a low-carbon fuel standard, as Lieberman-Warner did, would certainly help achieve the goals of the RFS program. Including transportation fuels under the capped emissions would provide a financial value to reduced emissions from these fuels and an incentive to shift to low-carbon fuels. However, it is important to realize that even relatively high values for carbon will not be sufficient to drive research, development, and adoption of low-carbon fuels. Simply too much capital inertia exists in the transportation fueling infrastructure for the price signal from the likely carbon prices to drive an orderly transition away from petroleum fuels. In other words, a carbon cap is necessary but not sufficient.
In addition to the cap, we need to use the revenues and value from auctioning and allocating carbon credits to drive innovation and we need complementary policies such as the low-carbon fuel standard. By reinvesting the value of the carbon credits in driving technological innovation in our economy, we can bring better fuels to market quicker, maintain our technological leadership in advanced fuels, and grow green, clean tech jobs. The low-carbon fuel standard is a technology neutral, performance based complement to market incentives for innovation. The standard requires steady improvement in the average performance from transportation fuels in a technology-neutral way that encourages the market towards best technologies.
Question # 3
Do you think we are in range of moving from mostly com ethanol to a substantial use of cellulosic biomass sources?
I think we are on the verge of this transition, but even once it starts, it is likely to take nearly a decade to complete and ultimately the proof will be in the pudding. There are at least a half a dozen projects that are vying to be the first to produce commercial quantities of cellulosic biofuels. On Wednesday, August 13, the major US corn ethanol producer announced that it would start producing the equivalent of about 20,000 gallons of cellulosic ethanol later this year. (See Reuters.)
But no amount of speculation or press releases will launch this transition nor would such a transition be inherently a good thing. Without safeguards, cellulosic and other second and third generation biofuels can lead to similar, if not identical, environmental and social impacts as conventional feedstocks. This is why we must continue to shift our fuels policies to a technology-neutral and performance basis. We need to make sure our policies drive the best technologies that really work and avoid picking “cellulosic,” as promising as the technology is. We must also be sure to impose the same environmental safeguards and performance standards on cellulosic fuels. While these fuels promise to make it easier to produce large quantities of biofuels with a smaller environmental impact, they are no guarantee of good performance.
How do you see this transition unfolding and what do you expect the timeframes will be?
If we maintain or improve our incentives and with a little luck, I think it is realistic to assume we will have at least two successful projects making cellulosic biofuels by early 2011 and at least one more operating by 2012. Not all of these will prove viable, but between additional first of a kind projects and one or two second iterations, we could easily have a fleet of four projects by 2013, seven by 2014, 14 by 2015, and sustained exponential growth for a few years after that. The average size of these project will probably start on the smaller size, say 30-50 million gallons and then grow to 100-250 million per plant.
Question # 4
What additional approaches, beyond biofuels policies, would be effective in addressing global land use changes and related greenhouse gas emissions issues?
Global land use change is driven by many factors. Thus a broad array of domestic and international policies is needed to comprehensively address the issue. We should begin, of course, with assiduously protecting our own intact ecosystems from further degradation. Critical actions include upholding laws and regulations like the Roadless Rule that protect our undeveloped national forests; providing increased funding for land-acquisition; encouraging sprawl reduction; supporting afforestation programs; and expanding the effectiveness and breadth of our agriculture conservation programs.
Ultimately, international agreements and treaties that prioritize preserving biologically diverse and carbon rich landscapes will be critical to addressing GHG emissions from land use changes. Given that these emissions make up 10 to 20 percent of anthropogenic GHG emissions, with or without biofuels, we need to find ways to reduce and ultimately reverse these changes if we are going to avoid catastrophic climate change. Our need to find low-carbon alternatives to petroleum fuels only makes this more urgent and more complicated.
Question # 5
How important will low carbon cellulosic and advanced biofuels be in achieving emissions reductions in the transportation sector?
NRDC’s modeling suggests that achieving about an 80 percent reduction in transportation sector GHG emissions by 2050 is eminently achievable, but will require significant contributions from all of the solutions of which we are currently aware. Improved vehicle efficiency, reduced driving through more livable communities and more use of mass transit and electrification of transportation will all need to play a critical role. However, even with all of these options deployed aggressively, we still forecast a need for about 20 percent further reductions from low-carbon fuels. In our modeling these low-carbon fuels need to provide at least an 80 percent reduction in lifecycle GHG emissions per gallon equivalent compared to gasoline. The only liquid fuels of which we are aware that have the potential to provide these reductions are advanced biofuels.
Getting the market place to deliver biofuels that provide this level of emissions reductions will be challenging. Biofuels are one of the few potential solutions to climate change that has the potential to actually increase emissions if not done carefully. This is why we believe it is so critical to continue to shift our biofuels policies to technology-neutral, performance based standards and incentives. This approach ensures that our policies only encourage technologies that move us in the right direction and let the market decide the best options.
Question #6
What tools do you recommend for evaluating and minimizing the potential environmental impacts, beyond lifecycle greenhouse gas emission impacts, of biofuels?
The environmental impacts and benefits of biofuels can go well beyond GHG emissions. At their best, biofuels could help us use water more efficiently, reduce water pollution, improve soil quality, and provide better protection for critical ecosystems than current agricultural and forestry land-uses. But without safeguards and performance based standards, biofuels carry grave risk to our lands, forests, wildlife, waters, soil and public health.
As noted above, the biomass safeguards established by EISA not only provide immediate amelioration of some of the greatest risks to our forests, grasslands, and important wildlife habitat, they also represent the foundation for future safeguards and incentives to address additional issues like water and soil conservation. Particularly considering the nexus between land-use change and GHG emissions, it is also important to emphasize the synergy between the biomass safeguards and the life-cycle GHG standards. The biomass provisions act as another safeguard against the clearing of native ecosystems like our imperiled grasslands, while also avoiding harm to our vulnerable wildlife, loss of old-growth forests, or the conversion of natural forests and degradation of our federal forests. It is critical that these safeguards are maintained and implemented aggressively and effectively.
Building on these safeguards, it is also imperative that global biofuels production move towards a credible and verifiable international sustainable certification standard. Already, significant progress toward such a standard has been made through the work of the Roundtable on Sustainable Biofuels. This effort, underway since 2007, is a multi-stakeholder effort - bringing together farmers, companies, non-governmental organizations, experts, governments, and inter-governmental agencies from around the world - to develop draft global standards for sustainable biofuels production and processing. After 12 months of consultation on its initial draft standard, the Roundtable has just released it next official draft for an additional six months of global consultation. This tool will assist consumers, policy-makers, companies, banks, and others identify biofuels that deliver on their promise of sustainability.
A third important step is to replace our other biofuels policies, like our current tax credits and tariffs, with a performance based, technology neutral incentive that will drive better environmental performance. One of the most critical areas to invest in is the identification, cultivation, and deployment of more sustainable feedstocks that do not induce direct or indirect GHG emissions, disrupt food supplies, and if produced properly have the potential to produce environmental co-benefits.
Finally, to achieve this potential, we cannot pursue biofuels in isolation. We need to increase the efficiency of our use of crop lands and forestry products and we need to encourage better environmental performance for all types of land-use. A critical set of tools across all types of land-use are better performance metrics and measurement tools. If we are going to require and incent better performance, we need to be able to define what that looks like on the ground and give farmers and foresters better tools to measure their performance. Then the market can develop innovations and find the best way to meet societies (more efficient) demands with the minimum impacts.
The most urgent needs are in being able to measure or model accurately consumptive water use, fertilizer runoff and volatilization, and soil quality. Using our current conservation payments to pay for more quantifiably better performance across these metrics and reforming our current morass of biofuels tax credits to pay for better performance in these areas would result in tax payers getting a lot more for their money than they do today.