Biofuels Policy & Regulatory Issues

Applying Greenhouse Gas Emissions Lifecycle Assessment

Jennifer L. ChristensenWISE Intern 2009

August 5, 2009

Agenda

IntroductionRenewable Fuels PotentialLegislative HistoryEISA Lifecycle GGE CriteriaLifecycle Assessment MethodologiesLifecycle Assessment ApplicationEPA Proposed Rule IssuesEPA RecommendationsFederal Government

Recommendations

Introduction What is the current global environmental crisis?

Global warming and climate change What can we do about it?

Reduce Greenhouse Gas Emissions (GGE) Capitalize on GGE reduction potential in

transportation sector▪ 29% of total U.S. GGE in 2006

Renewable Fuels PotentialCurrent Transportation Fuel:

Gasoline & Diesel▪ Non-renewable: Fossil Fuel

Feedstock▪ Significant Environmental Impacts

Alternative Transportation Fuel: Biofuels

▪ Renewable: Biomass Feedstock▪ Fewer Potential Environmental Impacts

Legislative History Energy Policy Act (EPAct) of 2005

Created Renewable Fuel Standard (RFS)▪ Mandated volumes maximizing at 7.5 billion gallons in 2012▪ Failed to address sustainability issues regarding increased

biofuel production

Energy Independence and Security Act (EISA) of 2007 Modified RFS program

▪ Increased mandated volumes to 36 billion gallons in 2022▪ Addressed sustainability issues

▪ Defined renewable biomass▪ Defined four biofuel categories depending on lifecycle GGE

thresholds

EISA Lifecycle GGE Criteria

Lifecycle GGE Baseline: 2005 average of gasoline and diesel transportation

fuels

Biofuel Category

Feedstock Definition

Lifecycle GGE Reduction

CriteriaConventional Corn-based ethanol New: 20%

Preexisting: None

CellulosicDerived from

cellulose, hemicellulose, or

lignin60%

Biomass-based Biodiesel _ 50%

Advanced Anything other than conventional 50%

Lifecycle Assessment MethodologiesDeveloped to assess the

environmental impacts of a product or process from “cradle-to-grave”

Included phases: Primary or

direct Secondary or

indirectSource: “Biomass Program,” United States, Department of Energy, Energy Efficiency & Renewable Energy, 2009, 29 July 2009 <http://www1.eere.energy.gov/biomass/>.

Lifecycle Assessment ApplicationEnvironmental Protection Agency

(EPA) Applied four steps of lifecycle

assessment Issued proposed rule in May 2009

Goal Definition & Scoping

InventoryAnalysis

Impact Assessme

ntInterpretati

on

Source: United States, Environmental Protection Agency, Office of Research and Development, National Risk Management Research Laboratory, Life Cycle Assessment: Principles and Practice, By Scientific Applications International Corporation, May 2006: 4, 29 July 2009 <http://www.epa.gov/ORD/NRMRL/lcaccess/pdfs/600r06060.pdf>.

Standardization Issues

General Lifecycle Assessment Standards: International Organization for Standardization

(ISO)▪ ISO 14040:2006

Biofuel Specific Lifecycle Assessment Standards: None; however,

▪ Global Bioenergy Partnership▪ Roundtable on Sustainable Biofuels▪ ISO committee for sustainable bioenergy

Scoping Issues Biofuels Pathway:

Mandated inclusion of significant indirect emissions▪ Indirect land use change

Compared future scenarios in 2022▪ Reference Scenario: Business-as-Usual▪ Control Scenario: EISA 2022 mandate volume

Analyzed marginal impact of increased biofuel production

Petroleum Baseline Pathway: Mandated 2005 average for gasoline and diesel

▪ Direct emissions, but not indirect emissions Did not analyze impact of increased biofuel

production on petroleum market

Equity Issues Fuel Equity

Inconsistent application of lifecycle assessment methodologies

Trade Equity American farmer vs.

International farmer

Commodity Equity Inconsistent mandates

across commodity markets

Source: Zia Haq, personal interview, 24 July 2009.

Modeling Issues

Direct Emissions: Depend on scientific models

▪ Relatively straightforward▪ Argonne National Laboratory’s GREET model

Indirect Emissions: Depend on economic, as well as

scientific models▪ Unprecedented need to simulate changes in

domestic and international agricultural sector▪ Utilized a piecemeal approach of preexisting

models

Federal Government Recommendations Regarding RFS lifecycle GGE

criteria: Change petroleum baseline from

2005 average to allow for marginal comparison

Streamline other incentive programs to fund second and third generation biofuels

Regarding future policy decisions: Utilize lifecycle assessment methodologies

to make better rounded policy decisions Request National Academies of Science to

conduct report on this utilization

EPA RecommendationsRegarding EISA final rule:

Issue a statement addressing equity issue of comparing marginal biofuel impacts to average petroleum impacts

Continue to include indirect emissions in biofuel pathways according to scientific reasoning

Enhance modeling capability to reduce uncertainty▪ Use scientific judgment on model assumptions▪ Guard against preconceived policy initiatives to define

certain assumptions

EPA Recommendations

Regarding future application of lifecycle assessment methodologies: Partner with national & international

stakeholders Partner with fellow agencies

▪ Department of Energy & U.S. Department of Agriculture

Partner with American National Standards Institute to develop international standards

Questions

Other Issues: Time Horizon & Discount Method

Source: United States, Environmental Protection Agency, Office of Transportation and Air Quality, Assessment and Standards Division, Draft Regulatory Impact Analysis: Changes to Renewable Fuel Standard Program May 2009: 405, 28 July 2009 <http://www.epa.gov/otaq/renewablefuels/420d09001.pdf>.