Advanced Biofuels USA Comments on CA Waiver Review
A public hearing concerning this reconsideration was held on March 5, 2009, beginning at 9:30 a.m. Deadline to submit written comments was April 6, 2009. READ MORE.
Advanced Biofuels USA Executive Director, Joanne Ivancic, attended the hearing. Click Here for her testimony. Click Here for the Advanced Biofuels USA Press Release.
While the U.S. Supreme Court has clearly stated that the Environmental Protection Agency (EPA) has the regulatory authority to issue CO2 control regulations under the Clean Air Act, and California took the lead in regulating ozone (smog) causing pollutants in the 1950s, it is very important that any motor vehicle CO2 control waivers issued to California or other states properly account for all related CO2 production. This is especially important since new vehicle technologies including plug-in hybrids and advanced biofuels produced from low nutrient input non-food biomass will be coming to market in the near future. Therefore, EPA should strongly consider the following in their waiver determination process.
1. CO2 Emissions from Plug-In Hybrid Vehicles (PHEVs) and Electric Vehicles
It is extremely important that CO2 produced in the course of producing electricity to charge plug-in hybrid or electric only vehicles be properly accounted for in Clean Air Act mandated emission inventories. Even more important, they must be apportioned to, and therefore controlled at, their actual place of use. If not, California could claim plug-in hybrids used in Los Angeles are “emission-free” while the electricity and CO2 produced to charge them comes from a new or expanded coal-fired power plant on an Indian reservation, (where the Clean Air Act does not apply), in New Mexico. This would result in additional CO2 being emitted into the earth’s atmosphere without any record of these emissions having occurred, subverting the goal of controlling Green House Gas emissions.
EPA should ensure that any CO2 regulations or waivers include the following:
a. All electricity and CO2 generated from coal or other non-renewable fueled power plants used to charge plug-in hybrid or electric only vehicles must be accounted for in Clean Air Act mandated state emission inventories.
b. Quantities of electricity and CO2 used for charging batteries must include energy losses (and CO2 production) incurred in electrical production, step-up/step-down transformers, and long-range transmission, (totaling approximately 60%+ of total electrical production, USNAS).
c. Calculations must be uniform for all waiver and non-waiver states.
d. Plug-in Hybrid battery charging electrical CO2 emissions must be included, along with on-board combustion CO2 emissions, in point-of-use state mobile source emission inventories no matter where the electricity is produced.
e. Electric only vehicle charging electrical CO2 emissions must be included in point-of-use mobile source state emission inventories no matter where the electricity is produced.
2. Uniform Calculations for Advanced Biofuels CO2 Emissions
With the potential of CO2 emission or fuel economy waivers being granted to California and the New England/Mid Atlantic States, there is the possibility of at least three different standards and, more important, three different methods of calculating Green House Gas emissions. Therefore, it is important to have a single uniform method (or formula) for making these calculations. In establishing this formula, the following technical issues must be addressed.
a. A uniform standard for the conversion of CO2 emissions from plug-in, electric only (see above) and conventional hybrids to miles per gallon (MPG) that is equal (not equivalent) to the MPG of internal combustion equipped vehicles. (Without this, marketing claims and false science will take over.)
b. A uniform standard (or algorithm) for the calculation of CO2 emissions and MPG for biofuels, in addition to existing standards for corn-ethanol or soybean oil biodiesel, that can account for: a) increased energy content per gallon, b) decreased CO2 emissions during fuel production, and c) increased MPG of new fuel mixtures. (Without this, significant regulatory barriers to the use of new biofuels, which would decrease CO2 emissions without affecting food production and costs, would be created.)