Evidence Shows EPA Should Boost Lifecycle GHG Benefits of Ethanol

Ethanol advocates have long called into question the data EPA has used in projecting the lifecycle analysis for ethanol and gasoline under the federal Renewable Fuel Standard (RFS). The agency has consistently used outdated – thus inaccurate – information that underrates ethanol’s performance as a cleaner, reduced-emission alternative in our nation’s transportation fuel supply.

Last week, Boyden Gray and Associates PLLC submitted, on behalf of the Energy Future Coalition, the Urban Air Institute and the Governors’ Biofuels Coalition, a formal Request for Correction of Information to EPA on the agency’s lifecycle analysis.

The request details how EPA has failed to assimilate new evidence demonstrating significant improvements that have been made in ethanol’s lifecycle greenhouse gas (GHG) emissions and calls on the agency to update its findings to reflect a wealth of evidence that shows the lifecycle GHG benefits of the RFS are much greater than predicted.

For example, data cited by the groups’ request show increased demand for corn causes much less land-use change and related emissions than EPA predicted in 2010. The evidence includes 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.

Also cited are 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. This evidence includes updated science on soil organic carbon, which indicates that best tillage practices sequester more carbon in the soil than previously thought. In fact, the evidence suggests that many corn fields are net carbon “sinks,” capturing more carbon than land-use change and corn farming releases.

These more efficient agricultural practices and technologies have also reduced the per-bushel amount of nitrogen fertilizer applied to the corn crop and eventually converted into the greenhouse gas nitrous oxide (N2O), the request states.

Biorefineries have become much more efficient, using less natural gas and electricity to produce each gallon of ethanol, the groups point out. Biorefineries are also producing new co-products that reduce the carbon intensity of ethanol, including distillers’ grains, which is used as animal feed; corn oil, which replaces soy-based biodiesel; and other co-products that lower the carbon intensity of corn ethanol.

By contrast, the request points out that petroleum-based fuels are becoming increasingly carbon intensive. As a result, the gasoline carbon intensity baseline should be significantly higher than EPA suggested, increasing the comparative benefit of ethanol.

The groups submitting the request hope their appeal, coupled with a an ongoing evaluation by the EPA Inspector General into EPA’s treatment of ethanol’s GHG and air quality effects, will compel EPA to update their analysis and report their findings to Congress.

As a member of the Ag-Auto Ethanol Work Group – a coalition of agriculture interests, auto manufacturers and supply chain members intent on helping federal regulators understand the advantages high octane, low carbon (HOLC) liquid transportation fuels ‑ 25x’25 is helping to widely disseminate this information about ethanol’s improved GHG-reducing benefits. The work group aims to educate policy makers, administration officials and the public at large about the benefits that higher ethanol blends ‑ ranging from 25 percent ethanol (E25) to E85 ‑ can provide in raising octane ratings, making gasoline burn cleaner and reducing greenhouse gas emissions.

Next month, DOE is expected to release a study produced by their national labs which details the fuel efficiency and performance gains of HOLC transportation fuels. Those findings will be underscored by recent data from DOE’s Energy Information Administration (EIA) that U.S. consumers are buying more “premium” (higher-octane) blends at the pump (from nearly 8 percent of gasoline sales to almost 12 percent year over year last September alone), principally because of higher sales of newer, more efficient vehicles that require or recommend high octane fuel.

25x’25 calls on all biofuel stakeholders to take an active role in sharing with policy makers, regulators and the public these facts supporting the benefits of ethanol. Take advantage of social media and your organizational networks to drive home the key point that HOLC fuels that incorporate higher ethanol blends are a critical pathway to compliance with the nations’ fuel-efficiency and GHG-reduction targets.

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