Today I testified before the Massachusetts Advanced Biofuels Task Force on what the state should do to promote biofuels. Here's my testimony, which boils down to encouraging them to adopt technology-neutral, performance-based policy and ideally adopt a low-carbon fuel standard. I was proceeded at the hearing, by Dr. Dan Sperling and proceeded by Jonathan Lewis from the Clean Air Task Force. All three of us touched on the importance of the lifecycle greenhouse gas emissions accounting and certification protocol being developed by CARB (here's CARB's LCFS page) and EPA.
My written testimony was 19 pages long and I only had 8 minutes to speak, so of course I had to summarize, but here's what I wrote (for more thoughts on the letter mentioned below see this recent post):
A recent letter in Science does a particularly good job of showing how complicated but important these indirect land-use impacts can be. The letter explains how increased demand for corn to make ethanol is reducing domestic production of soy beans and thus driving up the production of soy beans in Brazil. Policies such as the biodiesel mandate being contemplated in Massachusetts would great similar pressures on Brazilian soy farming. The letter details how increased Brazilian soy farming leads directly and indirectly to clearing of Brazilian rainforests:
Some Amazonian forests are directly cleared for soy farms. Farmers also purchase large expanses of cattle pasture for soy production, effectively pushing the ranchers farther into the Amazonian frontier or onto lands unsuitable for soy production. In addition, higher soy costs tend to raise global beef prices because soy-based livestock feeds become more expensive, creating an indirect incentive for forest conversion to pasture. Finally, the powerful Brazilian soy lobby is a key driving force behind initiatives to expand Amazonian highways and transportation networks in order to transport soybeans to market, and this is greatly increasing access to forests for ranchers, loggers, and land speculators. [Footnotes not included.]
Not all biomass material leads to increased demand for new agricultural lands and not all lands brought into production are rainforests. Nevertheless, it is important to understand the scale of impact that greenhouse gas emissions from these indirect land-use changes can have. Looking at a number of estimates, new very efficient corn ethanol refineries should be able to produce about 420 gallons of ethanol from an average acre of corn. Putting aside emissions from land-use change, this ethanol would reduce greenhouse gas emissions by about 37 percent per gallon or about 2,500 pound worth of CO2 per acre each year. Now, according to another article in Science, one acre of tropical rainforest if cleared and used to grow crops will release about 655,000 pounds worth of CO2 over 30 years or an average of nearly 22,000 pounds per year. In other words, if the conversion of an acre of corn from food and feed to fuel resulted indirectly in the conversion of just one-tenth of an acre of rainforest all the greenhouse gas emissions benefits of the ethanol would be whipped out for the first 30 years.
Of course, there are many more types of land being converted to agriculture than just rainforests. And the marginal impact of land-use changes here in the United States on land-use in the rest of the world is extremely hard to predict with economic equilibriums and agricultural and trade policies all interacting in complex ways. But to ignore these indirect emissions is to assume they are zero, which could easily lead to the government subsidization of fuels that are worse for global warming than gasoline or diesel.
Here's what I had to say about the EPA and CARB processes:
In December of last year, President Bush signed into law the Energy Independence and Security Act of 2007 (EISA07), which included a major increase in the renewable fuel standard and groundbreaking GHG performance standards and safeguards for renewable fuels. Specifically, the expanded RFS requires the oil companies to use 36 billion gallons of ethanol (or the equivalent of other renewable fuels) by 2022. Over their full lifecycle, all of these renewable fuels must provide at least a 20 percent reduction in greenhouse gas emissions compared to petroleum fuels. The new RFS also requires that at least 22 billion gallons of the 36 billion total be “advanced biofuels,” which are basically defined as not being ethanol from corn. These advanced biofuels must provide at least a 50 percent reduction. Of the advanced biofuels, at least 16 billion must be from cellulosic feedstocks and at least 1 billion must serve as an alternative to petroleum diesel. The advanced biofuels from cellulosic feedstocks must provide at least a 60 percent reduction in GHG emissions.
The RFS also establishes clear parameters for sustainable sourcing of biofuels feedstocks that guard against the loss of native forests and prairie, and protect threatened, imperiled, and endangered species, and public lands. While additional safeguards such as conservation standards to preserve soil and water quality are needed, the RFS contains critical safeguards necessary to protect our natural resources.
Under the EISA07, EPA is directed to promulgate regulations to implement these GHG performance standards and the environmental safeguards by the end of 2008. Perhaps the most complicated part of this is developing the accounting protocol to measure and certify the lifecycle greenhouse gas emissions of different renewable fuels. Fortunately, EPA has a head start in this effort. Early in 2007, President Bush directed EPA, in coordination with other federal agencies, to promulgate regulations to reduce US gasoline use by 20 percent within 10 years and to do so in a way that complied with the federal court ruling that CO2 is a pollutant. Before the passage of the EISA07, EPA was track to issue a notice of proposed rulemaking to implement the so called 20-in10 executive order around the end of 2007. As part of these draft rules, EPA had done significant work developing a lifecycle accounting methodology.
The California Air Resource Board is also developing an accounting protocol as part of the low-carbon fuel standard and is on a similar schedule as EPA. The LCFS was the first measure announced after the signing of the landmark AB32 Global Warming Solutions Act, and is the world’s first global warming pollution standard for fuels. Governor Schwarzenegger’s executive order implementing the LCFS directs CARB to develop a regulation for oil companies and other providers of vehicle fuels sold in California to reduce emissions of carbon dioxide and other global warming pollutants by 10 percent by 2020. CARB is scheduled to adopt the LCFS at the end of 2008.
A LCFS is a better approach to encouraging innovation among fuels and reducing global warming pollution than an RFS. A LCFS is technology-neutral allowing any type of low-carbon fuel to compete in reducing the average GHG intensity of fuels including electricity. Furthermore, while the new RFS provides a minimum level of lifecycle GHG performance, the LCFS encourages the best performance. Finally, a LCFS discourages high-carbon fuels such as liquid coal, oil shale, and tar sands. An RFS has no impact on these more polluting fuels.
In a related matter, yesterday Dr. Alex Farrell from UC Berkeley, who is under contract to advise CARB on developing the LCFS regulations, posted a spreadsheet with some "crude upper limit" estimates of the land-use related GHG emissions. I haven't had a chance to digest these, yet, but it's clear that these emissions have the potential to be huge. (Here's Alex's memo explaining the basics of his spreadsheet.)
It's becoming increasing clear that getting a clearer read on these emissions and figuring out how to incorporate them into the California and federal regulations is one of the ultimate challenges for biofuels policies.