Testifying on implementing the RFS

I went to Washington, DC yesterday and testified before the U.S. Senate Committee on Environment and Public Works, Subcommittee on Clean Air and Nuclear Safety. EPW has jurisdiction over the renewable fuel standard and this was their first oversight hearing on the implementation process. Here's my testimony, you can watch me testify here (I go on around 1 hour and 38 minutes in) and my oral statement is below.

With much help from my colleague Franz Matzner, I focused on making the case for protecting key environmental safeguards in the RFS and proactively addressing the food vs fuel debate through reforming the biofuels tax credits and import tariffs by making them performance based and technology neutral. The standing-room only hearing got testy at times. In his oral statement Scot Faber, the witness from the grocers and livestock industry basically claimed that the only thing Congress can do to address world hunger and food prices is to repeal the RFS. As I pointed out during the questioning, this is a dangerous abdication of responsibility for the richest country in the world. Instead, we need better food aid, ag trade policy, the environmental safeguards in the RFS, and reformed tax credits.

Here's my oral statement:

Mr. Chairman, members of the committee, thank you for the chance to share my views regarding biofuels and the Renewable Fuels Standard. My name is Nathanael Greene. I’m the director of renewable energy policy for the Natural Resources Defense Council.

At NRDC, we believe that biofuels produced following environmental safeguards, processed efficiently and used in efficient vehicles can reduce our dependence on oil, reduce emissions of global warming pollution, contribute significantly to a vibrant farm economy, and avoid impacting food prices.

However, pursued without adequate safeguards and standards, large-scale biofuels production carries grave risks to our lands, forests, water, wildlife, public health and climate.

As of late, this potential for biofuels to be destructive has captured the headlines. Without a doubt, concerns about food availability and global warming pollution require proactive measures. Both concerns should be addressed head on through agricultural trade and food aid policies and by adopting an economy-wide, cap and trade policy for greenhouse gas emissions. They should also be addressed proactively through our biofuels polices.

The most important step that Congress must take is make sure that EPA aggressively and effectively implements the safeguards in new Renewable Fuel Standard. The latest research confirms Congress’ foresight in crafting the RFS to do the following three things:

1) First, set minimum lifecycle greenhouse gas emissions standards for all biofuels from new facilities with the vast majority required to be from renewable cellulosic biomass with lifecycle emission of at least 60 percent less than gasoline.

2) Second, define lifecycle greenhouse gas emissions to include the all the emissions including specifically both the direct and indirect emissions from land-use change. Accounting for emissions from land-use change is the most important step to producing low-carbon biofuels and taking biofuels out of the food price equation. It is by increasing the competition for arable land that biofuels face the greatest risk of increasing global warming pollution and disrupting food supplies.

3) Third, encourage production of plentiful feedstocks—including woody-biomass—while ensuring mandate does not drive the destruction of old-growth forest, native grasslands, and imperiled ecosystems, or the degradation of our federal forests.

The effectiveness of the RFS depends entirely on EPA’s implementation of these critical provisions. Congress should make sure EPA is fully funded and monitor EPA’s progress closely to ensure that science rather than politics drives the resulting regulations.

The second proactive step Congress should take at this point is to replace the various existing biofuels tax credits and import tariffs with a single, technology-neutral, performance-based credit.

The existing biofuels tax credits and import tariffs are blunt, volume based policies that try to pick winners solely based on feedstocks. In doing so, these policies provide equal incentives to biofuels that cause negative environmental impacts and food displacement as to biofuels that use the most beneficial practices and technologies and have no impact on food supplies.

It is time to use these tax dollars in a better way. I recommend that we use the performance based tax credits and import tariffs to encourage water efficiency, reduced water pollution, better soil management, enhanced wildlife management, and avoid food price disruption. With the RFS mandate in place, we should require better environmental performance for our money.

New crops and conversion technologies are developing rapidly that will make it easier to produce lots of biofuels with a smaller environmental footprint and without impacts on food prices, but technologies are not a guarantee of good environmental performance. Just because we can do it right does not mean that we will.

We need to shift our tax policies so that they pay for performance and defend the environmental safeguards in the RFS to guide the market so that innovation and competition will drive biofuels to provide the greatest benefits.

Thank you again for this opportunity.