Biofuels and the Environment: Second Triennial Report to Congress

July 02, 2018

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(Environmental Protection Agency) This report is the second of the U.S. Environmental Protection Agency’s (EPA’s) triennial reports to Congress required under the 2007 Energy Independence and Security Act (EISA). EISA Section 204 calls for EPA to report to Congress on the environmental and resource conservation impacts of the Renewable Fuel Standard (RFS) program, specifically air and water quality, water quantity, ecosystem health and biodiversity, soil quality, invasive species, and international environmental impacts (hereafter referred to as the Section 204 statutory impacts).
Consistent with how EPA conducted the first Section 204 report, EPA has chosen in this assessment to focus on the Section 204 statutory impacts and not to expand the scope of the report beyond the factors explicitly enumerated in the law. As a result, some environmental impacts are not discussed in this report. Lifecycle greenhouse gas emissions impacts of biofuel use, for example, are addressed as part of the RFS program and are not included in this report. Furthermore, this report does not include a comparative assessment of the impact of biofuels on the environment relative to the impacts of other transportation fuels or energy sources, including fossil fuels, for every environmental endpoint. For example, the environmental impacts of growing corn, refining ethanol from that corn, and burning that ethanol in an internal combustion engine has a different environmental impact than drilling for oil, refining gasoline, and burning that in an internal combustion engine. EPA recognizes that a fully comprehensive assessment of the benefits and impacts of biofuel production and use would be broader than what is represented by this report, but conducting such an evaluation is beyond the scope of this study.

This report updates the findings of the first Report to Congress, published in 2011, with respect to environmental and resource conservation impacts, and, together, the two reports are intended to address the Section 204 statutory impacts since the passage of the EISA. The primary conclusions of the 2011 Report included the following two findings: (1) the environmental and resource conservation impacts of biofuel production and use as delineated in Section 204 of EISA were, on balance, negative; and (2) EISA’s goals could be achieved with relatively minimal adverse environmental impacts if existing conservation and best management practices were widely employed, concurrent with advances in technologies that facilitate the use of second-generation feedstocks. The 2018 Report reaffirms the findings of the 2011 Report and reflects the current understanding about biofuel production using data gathered through May 2017. The 2018 Report also reviews data on U.S. land use and the scientific literature through April 2017.

Major Findings
• Data from observations made since the 2011 Report indicate that the biofuel production and use conditions that led to the conclusions of that report have not materially changed.
• Substantial volumes of cellulosic and advanced biofuels have not been produced as anticipated by EISA. The Section 204 statutory impacts anticipated as a consequence of large-scale use of feedstocks other than corn and soybeans have therefore not occurred.
• Corn grain and soybeans remain by far the dominant feedstocks for biofuel production. Biofuel production associated with large-scale cultivation of corn and soybeans contributes to the adverse environmental and resource conservation impacts of the type listed in EISA Section 204, though we caution that this report does not evaluate the net effects of displacing petroleum or other energy sources with biofuels.
• There has been an observed increase in acreage planted with soybeans and corn between the decade leading up to enactment of EISA and the decade following enactment. Evidence from observations of land use change suggests that some of this increase in acreage and crop use is a consequence of increased biofuel production mandates.
• It is likely that the Section 204 impacts associated with land use change are, at least in part, due to increased biofuel production and use associated with the RFS. However, at this time we cannot quantify with precision the amount of land with increased intensity of cultivation nor confidently estimate the portion of crop land expansion that is due to the market for biofuels.

Likely Future Impacts
Section 204 of EISA also requires that the triennial report identify likely future impacts. We interpret the requirement to address “likely futures” as encompassing near-term future impacts presuming current technologies and rates of market penetration, and current policy and market dynamics. Thus, where this report discusses likely future impacts, it is addressing anticipated changes over the next three to five years. This report finds that there are some indications of growth in cellulosic ethanol production, primarily from corn stover, but that large-scale production at levels approaching the original EISA targets is not likely to be reached in the next few years. Available data suggest that current trends using corn starch and soybeans as primary biofuel feedstocks, with associated environmental and resource conservation impacts, will continue in the near term. READ MORE

EESI Statement: EPA Report on Biofuels’ Environmental Impacts Misses the Forest for the Trees (Environmental and Energy Study Institute)

Shining a light on ethanol and your gas tank (One News Now)

RNG to Provide Future RFS Environmental Benefits (Biomass Magazine/Coalition for Renewable Natural Gas)

Excerpt from Environmental and Energy Study Institute: On June 30, EPA released its second triennial report to Congress, which outlines the state of research of any potential negative environmental impacts of biofuels production, including land use change, air quality, water quality, biodiversity, soil quality and invasive species from producing biofuels for the Renewable Fuel Standard. Despite the careful consideration of these topics within the report, EPA paints an incomplete picture, at best, as they fail to draw any comparisons between biofuels and their main competitor – petroleum. While considering potential environmental impacts of renewable energies, one must consider the alternative as well.

It is very unfortunate that EPA chose not to consider the greenhouse gas as well as other environmental and health impacts of petroleum extraction and refining in their assessment. Despite the overwhelming evidence that fossil fuels are the main threat to our climate, as well as causing irreparable harm to our water, air, and health, EPA decided not to draw any comparisons between the two fuel choices in their literature review.

While biofuels production must absolutely be done in a way that minimizes the impact to the environment, the plain truth is that most evidence-based research finds that biofuels are still a better choice for our environment, health, and air quality as compared to fossil fuels. Additionally, farmers are leading the charge to implement conservation practices and better manage land in the face of increasing demand for food, feed, fiber and biobased compounds, including biofuels.

While petroleum products continue to get dirtier and worse for the climate, the biofuels industry has continually improved the greenhouse gas footprint of conventional ethanol, which is capped at 15 billion gallons under the RFS. Additionally, cellulosic fuels, such as those sourced from crop residues, food wastes, and manures, have the potential to greatly reduce wastes and deal with methane emissions, a potent greenhouse gas with as much as 36 times the warming potential of carbon dioxide. The volumes produced of these cellulosic fuels continue to grow year-over-year and represent a tremendous success of the RFS. READ MORE

Excerpt from Biomass Magazine/Coalition for Renewable Natural Gas: Reason 1: EPA’s report doesn’t assess life cycle GHGs. Although rogue GHGs present the world’s largest environmental challenge, EPA acknowledges that the report didn’t consider life cycle GHG emission impacts of biofuel. EPA states that it determined not to expand the scope of the assessment beyond the explicitly enumerated requirements in the law, which does not require GHG life cycle analysis.

Excluding GHG life cycle analysis when analyzing environmental impact is incongruous, especially considering that advanced and cellulosic biofuels, by definition, must have lifecycle GHG emissions that are at least 50 or 60 percent less, respectively, than the baseline life cycle GHGs.

In reality, the fastest-growing segment of the RFS is cellulosic biofuel, including renewable natural gas (RNG). RNG facilities easily meet the law’s 60 percent GHG emission savings threshold. According to RNG project analysis using the GHGs, Regulated Emissions, and Energy Use in Transportation (GREET) Model by Argonne National Labs, RNG facilities regularly capture, destroy and displace GHG emissions to realize 70 to 300 percent lifecycle GHG emissions savings.

As such, a life cycle assessment of the RFS would result in findings that show substantially greater environmental benefit.

Reason 2: Land use impacts from crop-based biofuels are largely sunk costs. EPA’s report attributes a significant amount of the program’s undesirable environmental impacts to land-use changes related to crop-based biofuels. Critics using the report to add fuel to their argument for RFS repeal focus attention on conventional, crop-based fuels that have historically provided growth to the program. However, they neglect the law’s requirement that program growth beyond 2014 must come from advanced and cellulosic biofuel.

From 2005 to 2014, the RFS spurred the rise of the modern corn ethanol industry. Historic analysis may provide an intellectual exercise that properly informs future policy decisions, but regret over sunk costs should not color an environmental analysis of how the program is performing today. A cost-benefit environmental analysis of the RFS moving forward is far more helpful. EPA should ask what fuels are growing at the highest rate, and what impact do they have on the environment?

While a majority of biofuels used in the RFS have thus far been in the conventional category (i.e. corn ethanol), trends show that the annual growth rate of cellulosic biofuels is now outpacing other fuels categories by more than double, and corn ethanol by nearly 20 times. Cellulosic biofuel’s 30 percent growth rate continues with the 2018 volume standard of 288 million gallons and EPA’s proposed 2019 standard of 381 million gallons.

The RNG industry provides over 95 percent of the cellulosic biofuel used in the RFS program.
With more than 50 RNG production facilities under construction or having reached stages of substantial development, the RNG industry is primed to meet EPA’s projected growth.

Reason 3: Continued future growth of RNG will yield increased overall environmental benefit from the RFS. RNG facilities capture methane emissions that would otherwise be flared or escape into the atmosphere from waste streams at landfills, wastewater treatment facilities and anaerobic digesters. They convert methane into a fuel that is interchangeable with conventional natural gas, and can fuel natural gas vehicles including passenger buses, 18-wheelers and refuse trucks.

EPA’s life cycle analysis distinguishes RNG transportation fuel as among the biofuels with the most environmental benefit. As discussed above, by definition, in being eligible for the cellulosic biofuel category of the RFS, RNG derived from the organic content in wastewater, MSW in our landfills, and from dairy and farm waste results in life cycle GHG benefits of 60 percent or more, compared to the diesel fuel baseline.

Utilization of RNG as a transportation fuel not only helps mitigate methane emissions, it helps sequester carbon from certain sources. Under California’s Low Carbon Fuel Standard, the California Air Resources Board finds the reduction in carbon emissions from using RNG transportation fuel derived from organic waste in landfills and wastewater to be comparable to the carbon intensity of electric vehicles. RNG from dairy waste results in a carbon intensity score around negative 200, by far making it the lowest-carbon fuel available. READ MORE