By ANN HINCH
Assistant Editor

WASHINGTON, D.C. — Three issues seem to be at the heart of debate about the U.S. Environmental Protection Agency’s (EPA) Notice of Proposed Rulemaking on the federal Renewable Fuel Standard (RFS): fairness of comparison between biofuel and petroleum on indirect land use, questionable accuracy in predictions about international land-use changes and how much of that can reasonably be ascribed to biofuel production.

Not surprisingly, the primary source of these challenges comes from the U.S. biofuel sector and those who support the industry. They argue that calculating greenhouse gas (GHG) – namely, carbon – emissions likely to result from land-use changes to create more feedstock for biofuel facilities is not being applied similarly to petroleum production.

Further, they point out such changes (i.e., clearing forestland or disturbing fallow grassland for production) will come from the need for more food for an increasing global population. They also question the EPA’s accuracy in being able to predict land-use changes in other countries.

Background

On May 5, the EPA put forth its Notice to lay out a strategy for the nation’s increased use of renewable fuels through 2022, as mandated by Congress’ Energy Independence and Security Act of 2007 (EISA). According to Administrator Lisa Jackson, “each year EPA calculates a percentage-based standard that refiners, importers and blenders of gasoline and diesel must ensure is used in transportation fuel. For the first time, some renewable fuels must achieve (GHG) emission reductions compared to the gasoline and diesel fuels they displace.

“Refiners must meet the requirements to receive credit toward meeting the new standards. The thresholds for new categories would be 20 percent less (GHG) emissions for renewable fuels produced from new facilities, 50 percent less for biomass-based diesel and advanced biofuels, and 60 percent less for cellulosic biofuels.”

The EPA has a 60-day period during which anyone may submit comments on this proposal. In conjunction, last week President Obama created the Biofuels Interagency Working Group (see related article) and on May 6, the House Agriculture Subcommittee on Conser-vation, Credit, Energy and Research had a hearing on the indirect land use calculations the EPA presented.

Indirect land use

The EPA solicited some scientific models and created others to try to calculate the impact U.S. biofuel production might have on land use not just in the United States, but also in other countries – and what land-use change might mean for increased GHG emissions. One modeler was the Center for Agricultural and Rural Development (CARD) at Iowa State University in Ames.

Director Dr. Bruce Babcock told the House subcommittee CARD has worked with the EPA to help determine if different biofuels meet its GHG reduction thresholds. He explained CARD has a model it has used for 25 years to analyze land-use changes based on global farm and trade policies. “The basic reason and the prime motivator is a higher price for corn,” he said of increasing biofuel.

Higher prices spur production of more corn worldwide, he said, which may come from creating more space for cropland or growing fewer other crops. Converting forest or grass land stirs up its organic material, oxidizing carbon into the atmosphere through plowing and burning. “If it comes from forests, that’s terrible, because it releases more carbon emissions,” Babcock said.

His center provided a model and the EPA fed that data into its own model. Despite knowing land-use changes may occur as a result of more biofuel production, he explained it’s difficult to predict where that might be, or how much.

“I don’t think we have the ability … (to know) where that land is likely to come from,” Babcock said. “Our original model did not and could not predict where it would come from.”

He said predicting overseas land use is difficult because the data necessary to understand are not always as readily available as in the U.S., nor as good in quality. Even here at home, models may not be accurate – he pointed to one that figured more U.S. forestland would be cleared to grow more corn for ethanol, but over the past few years, instead, that has come from reducing Conservation Reserve Program land and double-cropping soybeans after wheat.

Babcock said when he testified before the subcommittee, the overall feeling of legislators seemed to be against calculating indirect land use in biofuel impact. “But, they are Congress,” he said, pointing to the 2007 EISA, in which Congress directed the EPA to account for the lifecycle emissions of different biofuels – including indirect land-use changes.

Rep. Brad Ellsworth (D-Ind.), who serves on the subcommittee, is one of those who object to the proposed rule as it stands. In a statement, he said, “I am deeply concerned about the EPA’s proposed rules; these provisions would inhibit the development of advanced renewable fuels that are critical to America’s energy independence.

“Our policies should be focused on bolstering the biofuel industry, not hamstringing it with unnecessary red tape.”

Various representatives of that industry voiced similar objections at the hearing. Nick Bowdish, general manager of Platinum Ethanol – a 110 million-gallon-per-year corn-based ethanol plant in Arthur, Iowa – said the critical issue is that while the EPA has calculated indirect effects such as land use in the lifecycle emissions for various biofuels, it has not done the same for petroleum.

While petroleum emissions are calculated “from well to wheel,” he said the EPA has gone beyond “from field to wheel” for biofuel, giving it a lesser advantage than it would have if petroleum production emissions were calculated the same way.

He also said prospective land-use changes are being unfairly weighted to biofuel instead of spread across other factors. U.S. corn alone does not go mostly for ethanol, he said – some is used in high-fructose syrup for human consumption, and at least half goes to livestock.

“You’re not performing a comparison at all,” Bowdish said. “You have corn on this side of the table, and grapefruit on the other side.”

Manning Feraci, vice president of federal affairs for the National Biodiesel Board, added, “Sound science and common sense dictate that a fair, honest evaluation of international land use decisions account for substantial factors completely unrelated to biofuels production, such as forestry, subsistence farming and cattle ranching.”

Bowdish also said the EPA is comparing biofuel of the future to petroleum of 2005. In the last five years, he said the energy needed to produce the same volume of corn ethanol has decreased 25 percent and will continue to drop, while mining harder-to-reach crude will increase its “carbon footprint,” since this likely means extracting more from tar sands and coal.