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Environmental Groups Pressure EPA to Calculate Indirect Emissions

November 13, 2008
The latest salvos on the EPA’s rulemaking process for the Renewable Fuel Standard come from six major environmental groupsthe Environmental Defense Fund, National Wildlife Federation, Natural Resources Defense Council, Friends of the Earth, Union of Concerned Scientists, and Environmental Working Group – and academics at the University of California Berkeley.

In their letter to EPA Administrator Stephen Johnson, the environmental groups argue that delaying conclusions about which biofuels make the grade under the RFS until after the EPA has solicited comments on the rule “would encourage ventures that increase global warming pollution and will fail once the lifecycle accounting accurately and completely addresses the impact of land use changes.”

I have to disagree. Deciding which biofuels make the grade and which don’t before lifecycle accounting accurately addresses land use change risks discouraging investment in projects that might eventually have a beneficial impact on climate change emissions.

The groups further say, “We think that the inclusion of indirect effects will illustrate which second-generation feedstocks incur the least indirect land use changes.” However, since there are few second-generation feedstocks actually in production, the analysis of lifecycle emissions will be based on small-scale data. The indirect land use change emissions, particularly on a worldwide scale, will be purely hypothetical, since no large-scale markets currently exist for second-generation feedstocks. In fact, one of the stumbling blocks for the industry is the need to create the markets for harvesting second-generation feedstocks.

To decide which of these feedstocks “incur the least indirect land use changes” and to try presumptively to “distinguish promising approaches from dead ends” before data is gathered or the model proposed by the EPA is fully developed will undercut investment in second generation biofuels before they get off the ground.

The EPA’s “rigorous rule-making process that has drawn on the best available science,” as these groups put it, runs a great risk of appearing arbitrary by announcing premature conclusions about the land use change emissions calculation for biofuels.

Arguments about the food price impact of biofuels, some put forward by noted academics using the best available science, have ultimately been contradicted by evidence throughout the past year. While crop prices that reached highs during the summer and food prices that spurred riots in some corners of the world seemed to bear out the worst scenario put forward by respected researchers such as C. Ford Runge, the collapse of food prices in the past few months tends to support others who said that the price of oil was the main driver. See an earlier post for other arguments.

In a separate letter to Johnson, the group of academic experts led by University of California Berkeley’s Michael O’Hare put forward a series of arguments to refute the original letter from Bruce Dale et al. The Berkeley et al. academics sum up their argument so:

That some land will be brought from natural conditions into cultivation, with accompanying rapid carbon emissions from the existing vegetation, when ethanol demand is added to whatever other corn the world market would otherwise use, is an inference from absolutely foundational and uncontroverted elementary principles of human behavior, such as the law of demand. Exactly how large the effect is requires sophisticated predictive models and will never be as precise as measuring the specific gravity of ethanol, but to act as though the effect is nil is simply obscurantist and unscientific. No principle of law or regulatory practice or common sense dictates that the state must regard any uncertain value as zero.”

The problem with this is that there are other influences on land being “brought from natural conditions into cultivation” besides the demand for corn to produce biofuels, and current predictive models are not sophisticated enough to either measure the effect or to separate the various influences. But there is a principle of regulatory practice to point out. The regulatory action must provide the relief sought. Regulation of biofuels in the way sought by environmental groups ought to reduce greenhouse gas emissions from native land brought into cultivation. Since the EPA is not regulating deforestation around the world, there is little chance that will happen.

Robert C. Brown, director of the Bioeconomy Institute at Iowa State University, has a very cogent dissection of the environmentalists' arguments:

People in the developing world are finding it profitable to expand agriculture in their own countries rather than depend upon U.S. farmers to feed them. In some progressive circles, this might sound like a good thing - what we in the United States admiringly refer to as self-reliance.
“There is no scientific evidence indicating that deforestation is driven by biofuels production. Whereas the world has lost 500 million acres of rain forest in the past 10 years, the U.S. biofuels industry has diverted less than 20 million acres to ethanol production. Something else is responsible for the epidemic of deforestation.”