Well its a better argument than the one's we faced with Food vs. Fuel. Its logical and seems to be more results oriented. Hopefully this is a fair debate that moves us beyond the bullet-statement and bumper sticker arguments around ethanol.
From OPISnet.com
BIOFUEL GROUPS CONTINUE TO OPPOSE INDIRECT LAND USE INCLUSION IN RFS
Industry sources continued this afternoon to sift through the voluminous 1,004-page notice of proposed rulemaking for the expanded renewable fuels standard (RFS) that U.S. EPA issued this morning, but it appears as though while biofuel advocates appreciate the establishment of the Biofuels Interagency Working Group, they still oppose EPA's inclusion of indirect land use (ILUC) in the agency's establishment of lifecycle greenhouse gas emissions.
As passed under the 2007 energy bill, the 36-billion gal/yr RFS is broken into four segments: a capped corn-based ethanol requirement of 15 billion gallons by 2015; 21 billion gallons of the overall mandate contains "advanced biofuels" by 2022, with 16 billion gallons of that amount, under the same timeframe, from cellulosic biofuel. For the fourth carve-out, up to 1 billion gallons by 2012 is required to be from biomass-based diesel.
Meanwhile, conventional biofuels would be required to emit 20% fewer lifecycle greenhouse gas emissions (GHG) compared to gasoline, while "advanced biofuels" would be required to emit 50% fewer lifecycle greenhouse gas emissions and cellulosic biofuel would be required to emit 60% fewer emissions.
In this morning's notice of proposed rulemaking, EPA included emissions from ILUC in its lifecycle requirements, much to the chagrin of the biofuels industry. Biofuel groups, agricultural academics and some lawmakers had asked EPA to delay the ILUC requirements until there was a generally accepted method for determining the regulation.
"If you look at the direct impact of ethanol, from the production of the grain to transportation to the facility to the process of making the ethanol to transporting that to market, there are significant benefits to ethanol over petroleum," about 61% lower than petroleum fuels on average, said Renewable Fuels Association President Bob Dinneen, speaking on a conference call with reporters earlier today. However, "there is so much uncertainty" when trying to factor indirect effects, he said.
Additionally, the proposed ILUC requirements are not being uniformly applied, since there is no similar provision for petroleum production, Dinneen noted. "You'll see no international indirect effect of petroleum applied. EPA should've looked at this when they were creating the baseline. They are willing to count the number of angels on the head of pin for biofuels, [and] they ought to give more than just a cursory look at petroleum production," he said.
But Dinneen said he was pleased EPA would specifically be soliciting scientific feedback and peer review on the ILUC proposal.
Similar comment came from other biofuel groups, including Growth Energy, POET, the American Coalition for Ethanol (ACE), Biotechnology Industry Association and Brazilian sugarcane trade association UNICA.
"As evidenced by the recent debate over the low carbon fuel standard in California, biofuels are greatly penalized by these preliminary calculations,"
said UNICA Chief Representative in North America Joel Velasco. "We know sugarcane ethanol has the lowest carbon emissions of any liquid biofuel produced today. California recognized as much in its low carbon fuel standard.
We are certain that when the EPA considers the best available data and research, these indirect land use effects from sugarcane cultivation in Brazil will be marginal at best," he added.
Meanwhile, the National Biodiesel Board said that a final EPA rule on indirect land use changes "that is based on questionable science and is structured in a manner that restricts the role of sustainable vegetable oils in the program will make it nearly impossible to meet the Advanced Biofuels goals established by statute," according to NBB Vice President of Federal Affairs Manning Feraci. "Hopefully, common sense will prevail in this process and the EPA will issue a workable final rule that is based on sound science and allows the U.S. biodiesel industry to make a positive contribution to the RFS2 program," he added.
Brian Jennings, executive vice president of ACE, said he was pleased that USDA Secretary Tom Vilsack will be co-chairing the Biofuels Interagency Working Group along with the heads of DOE and EPA. "I think this means ethanol remains at the table for the president's energy policies moving forward, despite the political desire of some to box ethanol out. I think the working group will ensure that fossil fuels are finally examined along with biofuels in these LCA [land use change] assessments," he added.
The Natural Resources Defense Council (NRDC), meanwhile, is pleased with the inclusion of the indirect land use provision. "We must develop biofuels the smart way, and we are encouraged that EPA Administrator Jackson has offered a science-based proposal to get this done," said NRDC's Nathanael Greene. "The opportunity to review EPA's proposal will help ensure that developing biofuels won't mean using our most fragile forests for fuel and that biofuels provide real benefits. We plan to submit comments on what EPA has gotten right and what must be improved to make sure the outcome serves our environmental and energy needs," he added.
While both the American Petroleum Institute and the National Petrochemical & Refiners Association were still reviewing the proposal, they are concerned with the availability of biofuels that will be needed under the RFS. "While NPRA looks forward to commenting more specifically on the proposed guidelines, the questions of commercial viability, product liability and the lack of adequate scientific review with regard to mandated increased quantities of ethanol remain unresolved," said NPRA President Charles Drevna. The association said it trusts "that EPA will seriously and transparently consider the concerns raised by fuel, public health, environmental, and engine manufacturing interests as it proceeds toward finalizing guidelines for RFS implementation."
Similarly, API spokesman Karen Matusic said it is "surprised and disappointed" that EPA, in relying on industry information, believes there are sufficient plans underway to build plants capable of producing 100 million gal of cellulosic ethanol in 2010 and are therefore not proposing to waive the requirement for next year. "The waiver criteria is not 'plans to build,' but is 'projected volumes of cellulosic biofuels production," she noted. "Information readily available to the government clearly shows that very little cellulosic biofuels will be produced in 2010," she added.
Meanwhile, anticipating that ILUC would, in fact, be included in EPA's proposed rule, U.S. Sen. John Thune (R-S.D.) introduced legislation last week that would direct EPA to only focus on the direct lifecycle greenhouse gas emissions in its regulation. Speaking on the conference call this morning, Dinneen said these and other congressional efforts are separate from EPA's peer review efforts and aren't likely to be withdrawn.
Once EPA's proposal is published in the Federal Register, the agency will begin to accept public comments for 60 days. Meanwhile, EPA plans to hold a workshop on June 10-11 at the Dupont Hotel in Washington, D.C., to present details of the lifecycle GHG analysis included in the proposal.
For more information on the proposal, visit:
http://www.epa.gov/otaq/renewablefuels/index.htm#regulations.
--Robert Gough, OPISnet
--Rachel Gantz, OPISnet
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