EPA Ready to Release Rules for RFS

EPA Ready to Release Rules for RFS

The White House Office of Management and Budget has completed its review of the EPA’s rules for the Renewable Fuel Standard, which will contain the lifecycle analysis for U.S. fuels. Reuters and the Des Moines Register have reported on the significance of the rule, though EPA has not made clear when the rule will be published in the Federal Register, beginning the comment period.

The rule, much like California’s Low Carbon Fuel Standard (CARB), will include an estimate of carbon emissions from indirect land use change attributed to biofuels. The estimates are based on economic modelling that is based on circular reasoning — the models automatically assume that biofuel feedstock production by definition causes a shift in agricultural crop production.

An analysis by John Sheehan of SheehanBoyce LLC makes the point clearly:

The CARB/GTAP and Searchinger models for land use change are, in a way, based on circular reasoning. They set up conditions such as fixed pre-biofuels land demand (in the case of GTAP) and constant yield (in the case of Searchinger), which make it almost impossible to avoid indirect land use changes.”

A previous analysis by Thomas Darlington of Air Improvement Resource Inc. raised the exact same point, saying:

The model is therefore answering the question “What are the land use changes if all the ethanol increase is shouldered in one year (in this case, 2001)?” However, we would submit that this is not the correct question to answer. The real question is how much new land is converted either domestically or internationally if the 13.25 bgy ethanol increase is phased in from 2001 through 2015?”

Both analyses make the point that indirect land use change effects can be measured more accurately by dynamic models that account for crop production yield and demand changes.

An analysis prepared by the New Fuels Alliance further points out that while CARB and EPA have extended lifecycle analysis for biofuels by including a risk assessment of their economic impacts, both agencies are relying on existing estimates of the lifecycle emissions of petroleum fuels.

Considering the magnitude of the GHG emissions associated with petroleum fuels, the calculation of the indirect GHG effects including the appropriate fate or coke, residual oil and the demand for fuel oil for crude transport would be appropriate.”

The New Fuels Alliance points out that “Road building in forested areas causes relatively small direct emissions, however the roads are often a magnet for subsequent deforesting activities, providing access to previously inaccessible land.” This is a point made earlier on this blog.

The New Fuels Alliance analysis stops short of conducting a general equilibrium analysis of the economic impact of petroleum, but points out that there is an existing model for doing so. CARB had claimed that they simply did not know how to do such an analysis for oil.

EPA should use the comment period that will begin when they publish their rule in the Federal Register to investigate better models for analyzing the indirect effects of both biofuels and oil.