EPA Failure to Update Lifecycle Assessment Sells Ethanol Benefits Short

News out of EPA last week caught few in the biofuel sector unaware. The agency’s inspector general (IG) issued a report finding EPA had failed to comply with the statutory requirement to provide a report every 3 years to Congress on the impacts of biofuels.

EPA’s Office of Air and Radiation last provided a report to Congress in 2011, but has failed to provide any subsequent reports. Also, the IG found that the agency has not fulfilled the “anti-backsliding” requirements for the Renewable Fuel Standard (RFS), which are to analyze and address any negative air quality impacts the national biofuel blending requirement might produce.

The report notes that in 2010, EPA completed a comprehensive lifecycle analysis to determine greenhouse gas (GHG) reduction thresholds for biofuel eligibility under the RFS. Although not required to do so, EPA committed to update the analysis as lifecycle science evolves, but the agency has never developed a process to do so.

The IG’s findings underscore to some degree EPA’s seeming obliviousness to the wide and varied benefits that recent research has shown that ethanol and other biofuels offer in support of the Obama administration’s efforts to curb climate change. The agency simply hasn’t put the means in place to formally evaluate the latest research available.

Ethanol advocates have long called into question the data EPA has used in projecting the lifecycle analysis for ethanol and gasoline under the RFS, accusing the agency of consistently using outdated and inaccurate information that short sells ethanol’s performance as a cleaner, reduced-emission alternative in our nation’s transportation fuel supply.

Last April on behalf of the Energy Future Coalition, the Urban Air Institute and the Governors’ Biofuels Coalition, Boyden Gray and Associates PLLC submitted a formal Request for Correction of Information to EPA on the agency’s lifecycle analysis. The request detailed how EPA has long failed to assimilate new evidence demonstrating significant improvements that have been made in ethanol’s lifecycle GHG emissions.

The groups’ request takes on new weight, given that EPA has been called out from within the agency to update its findings. That update will reflect a wealth of evidence that shows the lifecycle GHG benefits of the RFS are much greater than predicted back in 2010, including improved economic models and newly available land-use data from periods of increasing corn ethanol production, which show significant increases in yield but no significant increases in land use change.

More recent data will also show improved agricultural practices and technologies that are substantially reducing the carbon intensity of ethanol by increasing the ability of soil to capture and retain carbon deep below ground. There is, in fact, strong evidence indicating that many corn fields are net carbon “sinks,” capturing more carbon than land-use change and corn farming releases.

The IG’s findings also come as EPA, the Department of Transportation and the California Air Resources Board are in the midst of a midterm evaluation of light-duty vehicle GHG emission standards and corporate average fuel economy standards for model years 2022-2025. The first formal step of the midterm evaluation process is the development of the Technical Assessment Report (TAR), a 1,200-plus-page document that measures the progress auto manufacturers are making in their pursuit of GHG standards targeted to meet 163 CO2 g/mi and fuel economy standards targeted to meet 54.5 mph by 2025.

A glaring omission from the TAR is any effort to consider fuel quality and octane pathways for meeting the very aggressive GHG and fuel efficiency targets that have been established since 2012. However, the IG report explains why the omission should not be that surprising, given that EPA has yet to take under consideration the work done by DOE’s national laboratories and others showing that major engine-efficiency and emission-reduction benefits can be derived from high-octane, low-carbon (HOLC) fuels, specifically blends of ethanol in the 25-40-percent range.

Somewhat encouraging are recent remarks from Chris Grundler, director of the EPA’s office of transportation and air quality, who said the agency will look at raising octane levels in gasoline as a pathway for achieving fuel efficiency targets. Ethanol is bound to be an element in those agency discussions. But those deliberations are not expected for several years and higher octane levels may not be put in place until after new fuel efficiency standards are established beyond 2025.

EPA and its fellow agencies are accepting comments on the TAR through Sept. 26. Meanwhile, the comment period for EPA’s proposals regarding biofuel blending levels is over, but the agency is not expected to finalize those proposals until Nov. 30.

Opportunities are there for stakeholders to make their voices heard, first by calling on EPA to accelerate its consideration of the readily available lifecycle analysis research from DOE and others before decisions are finalized on both the TAR and the RFS. 25x’25 urges renewable energy partners to reach out to lawmakers and ask them to call on EPA to comply with its due diligence obligations and consider all of the evidence that is critical to the agency’s evaluations.

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