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EPA Gets Input on Sustainable Biofuels

November 5, 2008
On Monday Oct. 27, the EPA’s Science Advisory Board held a workshop in Washington on “Looking to the Future.” The stated purpose of the workshop was “to stimulate SAB thinking about priorities for meeting critical environmental problems with an integrated approach to interdisciplinary science and research” and gather data on the net environmental implications of biofuels. A number of experts on biofuels and agriculture gave SAB presentations on land use change and other possible climate change emissions from biofuel production.
In their presentation, Dr. Bruce Dale of Michigan State University and Dr. Lee Lynd of Dartmouth noted that in calculating emissions from land use in a life cycle analysis, “a large range of outcomes is possible depending on whether or not land conversion is approached with the intent to minimize carbon debts.” In a study, they look at the variation in outcomes to an indirect land use change analysis such as Searchinger's. If the timber from cleared rainforests is used for furniture or paper instead of burned, as Searchinger assumed, or if land is managed with conservation tillage practices rather than conventional plow tillage, then "'carbon debt' from forest conversion is greatly reduced and may well be negative for some real systems," Lynd and Dale told the SAB. Further, "Production of biofuel from prairie grass on abandoned or marginal cropland repays the conversion carbon debt in less than a year with large carbon savings thereafter."
This is a point that David Tilman of the University of Minnesota, who also testified at the SAB meeting, would agree on, since he said, "Whether or not a given biofuel offers carbon savings and other environmental benefits relative to a fossil fuel depends on how the biomass crop is produced."
Outside of this official comment process, a number of groups have been petitioning EPA Administrator Johnson to take a different course on the rulemaking process. First, Bruce Dale and other academics sent a letter to Johnson asking him to delay inclusion of indirect land use in the rule for biofuels until better models could be constructed. Recently, the Clean Air Task Force, Environmental Working Group Action Fund, and Friends of the Earth sent a letter to Johnson responding to the Dale letter (See Environmental Groups Response Letter to EPA Administrator). Their argument: "Growing crops for energy in addition to food and feed requires the cultivation of additional land." This is precisely what remains unproven in the analyses.
The Biotechnology Industry Organization also sent a letter to EPA Administrator Johnson proposing that the EPA reveal its methodology for including indirect land use change so that the proposed rule's comment period could be used for refining the model before any conclusions are drawn about the impacts of specific biofuels (See BIO Letter to EPA Administrator Johnson).