Biofuels and the Environment: Second Triennial Report to Congress
(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.
• 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)
Biofuel industry criticizes US EPA’s triennial report (Biodiesel Magazine)
How a Government Program to Get Ethanol from Plants Failed (E&E News/Scientific American)
EPA Report Misses the Mark on Biofuels Impact (Biofuels Digest/National Biodiesel Board)
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 Biodiesel Magazine: Representatives of the biofuels industry criticized the EPA’s report for failing to compare the lifecycle greenhouse gas (GHG) impacts of biofuel use with those of fossil fuels.
Emily Skor, CEO of Growth Energy, pointed out that all forms of power result in some “negative” environmental impact, from solar arrays to minerals used in batteries. “Without an accurate scientific assessment, this study looks more like something the oil industry would draft than a federal report. Farmers would be insulted, if they weren’t already outraged by the EPA’s actions to undermine ethanol use,” she said.
“The EPA went out of its way to avoid citing data on the negative environmental impact of petroleum, leaving no way to deliver an apples-to-apples comparison showing the vast environmental benefits of American-made biofuels,” Skor continued. “Amazingly, the agency completely side-stepped carbon emissions, where the latest federal science from the USDA demonstrates that ethanol delivers a 43 percent benefit over fossil fuels—with a carbon reduction rising to 50 percent by 2022. At the same time, advanced and cellulosic biofuels can curb emissions by 100 percent or more, according to the Department of Energy’s (DOE) Argonne National Laboratory. EPA even suggested that biofuels could be blamed for land use without any hard data, which would have shown that America’s farmers are producing more food and energy than ever before, and they are doing it on less cropland than was under cultivation in the 1930s. You cannot attribute a rise in land use to biofuels when land use isn’t rising.
“Thankfully, there are still accurate sources for environmental information, including the USDA, the Department of Energy, and clean energy leaders who have reported that ethanol helps keep our air free of volatile organic compounds, cancer-causing chemicals like benzene, and smog-forming pollutants,” Skor said. “Even the EPA admitted that while they offered ‘insufficient evidence to support a conclusion on the overall direction or magnitude,’ it’s fairly clear that America’s environmental goals under the Renewable Fuel Standard ‘could be achieved with minimal environmental impacts if best practices were used and if technologies advanced,’ just as the industry is doing today.”
Johannes Escudero, CEO of the Coalition for Renewable Natural Gas, noted that the renewable natural gas (RNG) industry currently provides more than 95 percent of the cellulosic biofuel used under the RFs and stressed the environmental benefits of RNG.
“It’s worth noting that EPA acknowledges it did not consider lifecycle greenhouse gas emission impacts of biofuel for this report, which is incongruous considering that a biofuel’s eligibility for the RFS is evaluated by considering its lifecycle GHG benefits,” he said. “EPA’s lifecycle analysis distinguishes renewable natural gas transportation fuel from all sources as among the biofuels with the most environmental benefit.”
“RNG production 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 and convert the methane into a fuel that is interchangeable with conventional natural gas,” Escudero said. “RNG is transported inter- and intra- state using existing natural gas pipeline infrastructure, and is used to fuel natural gas vehicles, such as municipal bus fleets and waste haulers.
“The production and utilization of RNG as a transportation fuel not only helps mitigate methane emissions, it also helps sequester carbon from certain sources,” he continued. “Replacing diesel engines with natural gas engines fueled by RNG achieves an 80 percent reduction in greenhouse gas emissions. RNG is already accepted in the marketplace and is a win-win if you are advocating for both a clean environment and clean economy today.” READ MORE
Excerpts from Biofuels Digest/National Biodiesel Board: EPA’s recently published Second Triennial Report to Congress on Biofuels and the Environment provides no meaningful conclusion on the net environmental benefits of the Renewable Fuel Standard (RFS). What EPA’s report unfortunately does provide, however, is fodder for political pundits wishing to attack the program through selective quotes and perpetuation of myths.
As EPA acknowledges, the report does not include a comparative assessment of biofuels and the environmental impacts of other transportation fuels, including fossil fuels. Nor does the report address lifecycle GHG benefits that were previously quantified by EPA.
A significant failure of the report is that EPA cannot separate impacts due to the RFS or biofuels from the impacts of other policy and market drivers. Those other drivers are stronger than the RFS, so it is inappropriate to report causality only to the RFS.
EPA also fails to recognize real trends in agriculture that have the opposite impact on conservation and biodiversity. For instance, the real trend in agricultural land use is that farmers are doing more with less, producing more food on fewer acres.
In 2015, USDA determined that the total area of managed farmland in the US had declined by 23 million acres compared to 2007. This parallels global trends where farmers worldwide were managing 60 million less acres in 2011 compared to 2004. During the same period, 19 million acres of previously unforested land returned or were converted to forests. Farmers are farming less land. This means more land is available for wildlife habitat if conservation policies are in place to recognize this opportunity.
EPA fails to recognize this net decrease in agricultural land. Instead, EPA focuses only on the increase in acres of cropland. These trends are related, but not necessarily due to biofuels. Farmers are optimizing their production to produce more protein per acre. Protein is the limiting factor in our food supply. While we have developed biofuels to utilize the excess fats and carbohydrate byproducts of protein production, all of the protein that farmers produce goes into the food supply. Crops produce more protein per acre than grass.
Congress has also de-funded conservation programs. The number of acres mandatorily disenrolled from the Conservation Reserve Program exceeds any increase in acres needed to satisfy RFS volumes.
Without considering these factors, which are far more influential than biofuels markets, EPA cannot correctly summarize the true trends in agricultural production.
When measured on a per-unit-of-food basis, one will find that modern agriculture has significant environmental benefits over past practices. With this realization, we can appreciate biofuels as a bonus benefit. When farmers grow protein to feed the world, they harvest more fats and carbohydrates than we can eat. These fats and carbs contain carbon-neutral solar energy. We will reap economic and environmental benefits when we use the solar energy in biofuels to supplement the fossil fuels needed to drive our economy. READ MORE