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BIO: EPA’s proposed backslide on RFS will increase greenhouse gases

By Brent Erickson
Executive Vice President; Head, Industrial & Environmental Section
The Biotechnology Industry Organization

I cannot remember an EPA rule that would actually cause environmental backsliding, but the recent proposed rule for the 2014 Renewable Fuel Standard (RFS) will if it is not changed. Any major change to the RFS’s statutory growth curve for biofuels requires an evaluation of the impact on the environment, energy security and the future commercialization of advanced biofuels.

EPA has positioned its proposed rule for the 2014 RFS as a “manageable trajectory” for future growth of the biofuel market, so the final rule must also include a full analysis of the impact on those and other factors. BIO recently published an analysis of the proposed rule’s impact on greenhouse gas emissions that should help inform EPA’s evaluation of the rule. We conclude that EPA’s proposal will increase greenhouse gas emissions above 2013 levels for many years to come.

BIO’s study – Estimating Greenhouse Gas Emissions from Proposed Changes to the Renewable Fuel Standard Through 2022 – was recently published in the Industrial Biotechnology Journal. The model we developed begins with Energy Information Administration (EIA) projections of fuel use from 2013 through 2022. EIA suggests that over the next decade fuel economy standards will continue to boost use of diesel fuel even while discouraging gasoline use.

We next calculated the percentages of blendstock for gasoline and diesel, ethanol, biodiesel, advanced and cellulosic biofuels that would be used each year under various scenarios –EPA’s newly proposed methodology, the statutory RFS rules, and a continuation of EPA’s past practice of setting the advanced biofuel volume obligation at the highest achievable production level.

The volumes of each blendstock were then assigned GHG emission scores – measured in metric tons of CO2 equivalent – and an annual total was tallied for each scenario. The greenhouse gas emission scores are drawn from the GREET1.2013 model, which includes an updated emissions profile for petroleum fuels, since the United States now relies more on marginal sources of petroleum – such as Canadian oil sands – than it did in 2007.

The primary finding of our study is that EPA’s proposed reductions in biofuel use in 2014 would automatically increase use of petroleum and increase the associated emissions of greenhouse gases. The reason is simple: In order to achieve lower emissions in 2014, compared to 2013, EPA must ensure an increase in biofuel use. The scenario in which EPA keeps the obligation at the highest achievable level decreased GHG emissions nearly as much as the statutory levels.

The second important finding is that if EPA’s proposal undermines development of advanced biofuels – as we expect it will – the United States will forego measurable reductions in greenhouse gas emissions over many years. Most of the future growth in the RFS is reserved for advanced biofuels, which are required to achieve at least a 50 percent reduction in greenhouse gases compared to petroleum gasoline or diesel produced in 2007. If we cut short growth of advanced biofuels and use petroleum instead, more and more of our fuel will likely come from Canadian oil sands and include more lifecycle carbon emissions.

So, if EPA continues to use the proposed methodology for setting the annual RFS obligations in future years, U.S. greenhouse gas emissions from transportation fuels will remain above the 2013 level for many years.

The third important finding of the study is that increased fuel efficiency standards may not by themselves achieve reductions in greenhouse gas emissions. In the short term, economic recovery is expected to unleash pent-up demand for transportation fuel. Diesel fuel emits more carbon during its lifecycle. And, if the petroleum used also emits more carbon over its lifecycle, the impact of decreased use could be offset significantly.

A combination of fuel efficiency and use of lower carbon fuels is needed to achieve year-over-year reductions in carbon emissions in the transportation sector.

We published this study as a contribution to EPA’s evaluation of its rule’s impact on climate change. We will ask EPA to incorporate the findings into its analysis of the final rule. EPA must also evaluate the impact of the final rule on energy security; future commercialization of advanced biofuels; sufficiency of infrastructure to deliver and use biofuel; costs to consumers; and job creation, rural economic development, and food prices.

We believe the negative environmental impact is one factor among many that should prompt EPA to change the draft RFS rule so it won’t hinder robust advanced biofuels development.