Today a group of 10 environmental organizations sent a letter to EPA Administrator Lisa Jackson urging her to put a proposed rule establishing GHG standards for biofuels out for public comment. The rule, which are part of the Renewable Fuel Standard, was supposed to be implemented by the end of 2008 has been delayed by OMB. At issue is how EPA proposes to measure the lifecycle GHG emissions from biofuels and specifically how the agency will include emissions from changes in land-use caused by some sources of biomass.
It's hard to underestimate the importance of this issue. At stake is our ability to move forward with any long-term biofuels mandates or market-based policies, such as CA's low-carbon fuel standard. If we intentionally blind ourselves to the full GHG impacts of different biofuel technologies, then we can't tell if we're fighting climate change or making it worse.
Here is a letter from a number of ag state Senators calling on EPA to effectively gut the GHG standard.
And here's the basics on this complicated topic:
Biofuels produced from biomass grown on productive lands compete with other uses of land. As forests and grasslands are cleared to meet the increased demand for land, the carbon stored there is released. Adding these emissions makes some biofuels responsible for more global warming pollution than gasoline or diesel. Fortunately, not all sources of biomass increase the demand for land; some are a byproduct of current practices and others can come from the integration of biomass and food production.
EPA is developing the rules for the Renewable Fuel Standard and CARB is developing the rules for the Low-Carbon Fuel Standard. In different ways, both policies are explicitly intended to encourage the use of biofuels as part of the solution to global warming. As part of this these regulators are developing tools to make sure that the biofuels that benefits from these policies actually produce reductions in greenhouse gas emissions.
In order to develop a full lifecycle accounting protocol that includes emissions from indirect land-use change, both regulators are relying on economic models. They use these models to look at the world first without the biofuels and then with them; the change in pollution is assigned to the biofuels. While the models are complex, both agencies have relied on the best peer-reviewed science and economics and will update their rules regularly overtime.
CA has benefited from a transparent and science-based rulemaking, and the CARB staff has proposed a final rule for the Low-Carbon Fuel Standard. CARB should adopt it without delay at the April board meeting.
EPA has developed a proposed rule and a long list of alternatives, but unfortunately the proposal is stuck at the Office of Management and Budget. The public comment period on a proposed rule as complicated as this is a critical part of ensuring a transparent and science-based final rule, and EPA should release its proposal for comment as soon as possible.