Yesterday, 66 retired members of the U.S. armed forces and intelligence community wrote to California Governor Arnold Schwarzenegger to encourage him to fix the proposed Low-Carbon Fuels Standard (LCFS).
Numerous renewable fuel advocates have questioned the current LCFS proposal in California. The letter covers six specific areas that the co-signers believe the LCFS will negatively impact, if adopted in its current form. Specifically, the co-signers are concerned that applying the LCFS in its current state would penalize renewable fuels to the benefit of petroleum and other fossil fuels thereby failing to capture the potential environmental and energy security benefits such an effort holds.
As the ARB approaches a final set of rules and regulations, we would like to comment on the deep connection between our reliance on carbon based fuels and our national security. We applaud California’s leadership for being on the cutting edge of promoting cleaner fuel use, which we see as a critical component of bolstering American security. We are concerned, however, that the indirect land use change (iLUC) penalty for biofuels will have an adverse effect on our ability to develop alternative fuels. This in turn will prolong the United States’ reliance on fossil fuels and deepen the damage caused by both our reliance on oil and by climate change.
The letter concludes by saying that biofuels can and will play an important role in furthering our energy secutiry.
Having served in uniform ourselves, there is nothing we take more seriously than the safety and well-being of our country. We are calling on the state of California to lend us a hand in keeping America safe by enacting a fuel regulation that is unbiased and does not enforce indirect carbon effects against only one type of fuel. There is no silver bullet to the energy and security challenges we face, but biofuels have a crucial role to play. We hope California will continue to be a national leader in energy issues and allow biofuels to play that role.
The technical term is GIGO - Garbage In, Garbage Out - originally coined as computer jargon but now “commonly used to describe failures in human decision making due to faulty, incomplete, or imprecise data.”
Senator Charles Grassley (R-IA) is afraid that the Environmental Protection Agency could fall prey to the GIGO syndrome in trying to reach a conclusion on the inexact science of “indirect land use changes.”
“There are a number of assumptions that can affect the conclusions about indirect land use changes. With any model, if you put garbage in, you’ll get garbage out. I want to make sure that the EPA isn’t putting garbage in,” Grassley said on the Senate floor Monday.
I’m afraid the climate folks at the EPA are heading in the wrong direction on this. I don’t think they’re bad people, but I’m afraid they don’t understand how American agriculture works. I don’t think they’re aware of the significant crop yield improvements we’ve seen in recent years or the great potential over the next 20 years. I also don’t think they fully understand the benefit of valuable ethanol byproducts, which further reduce the effective land used for fuels production.
It defies common sense that the EPA would publish a proposed rulemaking with harmful conclusions for biofuels based on incomplete science and inaccurate assumptions. The EPA’s actions, if based on erroneous land use assumptions, could hinder biofuels development and extend America’s dependence on dirtier fossil fuels.
Grassley joined 11 other senators last week in a letter to EPA administrator Lisa Jackson, urging her to refrain from making a “premature ethanol emissions regulation” that would result in regulations which assume greater U.S. biofuels use would increase carbon dioxide emissions.
While the EPA is required by law under the Energy Independence and Security Act of 2007 to consider indirect land use changes, the fact is that what the legislation requires is currently impossible because there are no generally accepted methods for determining indirect land use - and there may never be. Maybe Congress and the administration should take a second look at this whole issue and consider putting it out with the garbage.
Several senators reintroduced legislation this week that would fix the flawed definition of renewable biomass in the Energy Independence and Security Act of 2007. The legislation has already been reintroduced in the House. However, it’s not likely Congress will move quite as fast on this issue as they did this week on “fixing” the AIG executive bonus boondoggle.
The definition of “Renewable Biomass” in the 2007 Energy Bill EXCLUDES any material removed from national forests and most private forestlands. Therefore, cellulosic ethanol derived from this feedstock does not count toward the expanded Renewable Fuels Standard (RFS), resulting in blenders and refiners having no incentive or requirement to purchase biofuels produced from these sources.
This is a problem, especially in the home states of two senators who are co-sponsoring the bill - Saxby Chambliss of Georgia and John Thune of South Dakota. You have companies like KL Process in Rapid City, SD using biomass from the Black Hills National Forest and Range Fuels of Soperton, GA that can make use of southeastern forest biomass.
“In a time when we should be seeking to source more of our fuel from domestic sources, we must ensure that the availability of feedstocks is expanding in order to meet the renewable fuels standard,” said Sen. Chambliss, Ranking Member of the Senate Agriculture Committee. “Unfortunately, the current RFS definition severely limits access to biomass from private forest lands. In Georgia alone, only 7.3 million acres would be eligible to contribute biomass for meeting the RFS, compared to 23 million acres that would be available under the definition applied to farm bill programs.”
The proposed legislation would change the definition of “Renewable Biomass” to more closely conform to earlier versions of the RFS and the 2008 Farm Bill. That would allow pre-commercial and post-commercial waste from national forests to be eligible feedstocks under the definition of “Renewable Biomass” and allows for waste materials to be removed from our public lands which will assist in reducing fire danger.
It’s simple - just fix it.
Geoff Cooper, RFA’s director of research, testified yesterday before the California Senate Committee on Transportation and Housing.
Invited by the committee, Cooper talked about the California Air Resources Board’s (ARB) recent proposal for carbon reduction. In essence, ARB’s proposal saddles biofuels with the carbon footprint attributed to what is called “land-use change.” Land-use change is when land that has been used for a specific purpose are used for another purpose.
Pointing out that gasoline production was left out of the land-use consideration, Cooper said in his testimony that ARB has “failed to apply its rules across all fuel technologies.”
The science on land-use is uncertain, and blaming biofuels for the full brunt of these carbon emissions is irresponsible. It isn’t supported by fact and might lead to harm the development of the biofuels industry.
After meeting with Brazilian president Lula da Silva for the first time last weekend, President Obama said the United States has “a lot to learn from Brazil” when it comes to “pursuing biofuels and developing them.”
“I think Brazil has shown extraordinary leadership when it comes to biofuels,” said Obama. “And this is an investment that Brazil has made for a very long time. My policies coming into this administration have been to redouble efforts here in the United States to pursue a similar path of clean energy development.”
No doubt, Brazil has been a leader in the development and use of ethanol through a multi-faceted approach that the United States can and should emulate.
For starters, Brazil has a minimum blend requirement for every gallon of gasoline to contain 20 to 25 percent ethanol. The U.S. ethanol industry is currently only asking for 15 percent ALLOWED, not required. There is also a requirement in Brazil for the government to purchase E100 fuel.
Brazil wants the United States to lift the 53-cent-per-gallon import tariff, which is designed to offset the value of the Volumetric Ethanol Excise Tax Credit, better known as the blenders’ credit, to prevent U.S. taxpayer money from supporting the use of foreign ethanol over domestically produced. However, no one mentions the fact that Brazil has an ad valorem tariff of 20 percent on ethanol imports – compared to the U.S. tariff which amounts to about 2.5 percent of the product value.
‘I know that the issue of Brazilian ethanol coming into the United States has been a source of tension between the two countries,” Obama said on Saturday. “It’s not going to change overnight, but I do think that as we continue to build exchanges of ideas, commerce, trade around the issue of biodiesel, that over time this source of tension can get resolved.”
Rather than just the lifting the tariff and importing more Brazilian ethanol, our nation should be following the example of Brazil by increasing the blend level allowed in gasoline and encouraging the production and use of more flex-fuel vehicles.