Inside the Beltway: Constructive Advice on the Calculation of GHG Emissions
by Eric Washburn
The Obama Administration will need to make critical decisions in the coming months on 1) the lifecycle greenhouse gas emissions estimated by EPA for biofuels as part of the current rulemaking on the 36 billion gallon Renewable Fuels Standard, and 2) the method for determining lifecycle greenhouse gas emissions as part of a future low carbon fuel standard.
While I believe that recent efforts to ascribe greenhouse gas (GHG) emissions from land clearing in the tropics to American biofuels are scientifically indefensible, I also believe that we in the industry have an obligation to engage this issue constructively. In that spirit, here are some recommendations that we should consider offering to the Obama Administration to guide the future calculation of GHG emissions from biofuels:
First, before a lifecycle analysis is done by EPA, require that a neutral and objective assessment be undertaken to adequately sort out the impact that biofuels production in the U.S. will have on indirect emissions, particularly those related to land clearing in tropical countries. This should involve input from qualified scientists and economists throughout the country, including at the Departments of Energy and Agriculture.
The current projections of indirect GHG emissions are based on computer models that use old data on land clearing, collected under markedly different economic conditions, to predict land clearing in the future. An interagency process that develops better models, and tests the assumptions and outcomes of those models with real-world data under current economic conditions, should occur before any final lifecycle determinations are made.
Secondly, update the lifecycle analysis of petroleum annually to capture fluctuations in the carbon-intensity of petroleum, including the use of increasing amounts of Canadian tar sands and potentially coal-to-liquids.
Third, compare GHG emissions apples to apples; there should be an explicit requirement that lifecycle analysis include indirect emissions from petroleum as well as biofuels. EPA should be required to assess GHG emissions associated with the expenditure of energy and money made by the U.S. military and the militaries of other nations to protect access to world oil supplies in the Middle East and elsewhere, including all the strategically located bases, the use of the U.S. Navy to protect shipping lanes, and all the GHG emissions resulting from the related activities.
Finally, we must ultimately judge biofuels based upon comparisons of its lifecycle emissions with those of the fuel that would replace it, were biofuels removed from the fuel system.