How EPA Renewable Fuel Standard Threatens the Environment

Earlier this year, the federal Environmental Protection Agency (EPA) announced the final version of the advanced renewable fuel standard, known as RFS2. The new standard sets greenhouse gas emission performance standards for the nation’s transportation fuels. Requirements for annual volumetric use of renewable fuels more than double in a decade, from 13 billion gallons in 2010 to 36 billion gallons in 2022.

The environmental science community, however, is amassing strong indications that, in their current form, biofuels have significant potential to impact the environment negatively in a number of ways – ironic, since a main selling point of the biofuels push is to combat climate change stemming from automotive fuel greenhouse gas emissions.

Concerns have been raised over these renewable fuel standards promoting the conversion of marginal land to corn production as the demand for corn increases. This land conversion would tend to increase overall application of agricultural chemicals in the environment, exacerbate water quality problems common in areas of intense agricultural production, and limit ecosystem diversity. Beyond corn grain as a source for ethanol production, “first-generation” cellulosic ethanol production is most likely to come in large part from corn stover – the parts of the plant normally left in the field after harvest. Unfortunately, removal of corn stover from the land surface accelerates soil erosion, depletes soil organic carbon, and reduces subsequent yields.

It’s not just in the United States that concerns are growing over the current renewable fuel policies. The European Union’s Renewable Energies Directive mandates that by 2020, 10 percent of transport fuels come from renewable sources. A report issued last month by the European Commission (EC) pointed out that no more than 5.6 percent of the transport fuel can safely come from first-generation biofuels without “real risk” to the environment.

Experts believe that contrary to the optimism in the EC report, because second-generation transportation fuel or alternate power sources are not expected to be widely available by 2020, the 10 percent mandate means that more than 5.6 percent will have to come from first-generation biofuels. Of course, vital issues beyond the environmental are in play here. Remember that U.S. corn production goes not only to fuel, but food.

In a recent report analyzing the potential impact of adverse (though not extremely unusual) weather conditions on U.S. corn production, University of Illinois researchers explain that mandating a certain amount for use as a fuel will exacerbate problems for food supply when weather conditions create disruptions in the supply of corn. Biofuel mandates are purely a function of demand, with no consideration for supply. The researchers point out that to accommodate fluctuations in supply due to uncontrollable factors like weather, the mandates should have more flexibility – allowing other options when supply is inadequate. But that flexibility does not exist in the current policy.

The RFS2 illustrates the dangers of government regulators dictating a policy to a single issue to the exclusion of other important considerations. In the focus on greenhouse gas emissions, the mandates within RFS2 put other environmental systems at risk. More generally, in a recent op-ed in the Seattle Times, climate scientist John M. Wallace argued that by framing every environmental policy debate in terms of global warming, we run the risk of creating short-sighted policy that ignores critical concerns for many environmental systems – water quantity and quality, air quality, soil degradation, and vegetation cover.

Climate change and greenhouse gases are important issues but should not trump all other environmental and agricultural considerations. The RFS2 has already been signed into law, and time will tell what the impact of this regulation really is.

As its name proclaims, the EPA exists to “protect” the environment. If its new renewable fuel standard turns out to harm the environment, as scientists predict, the EPA should revise or rescind the RFS2. In the meantime, the public should demand a more comprehensive consideration of the environment in the development of high-impact policy.

Nothing contained in this blog is to be construed as necessarily reflecting the views of the Pacific Research Institute or as an attempt to thwart or aid the passage of any legislation.

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