by Joanna Schroeder (DomesticFuel.com) The House and Energy Commerce Committee has released its third white paper on the Renewable Fuel Standard, “Greenhouse Gas Emissions and Environmental Impacts.” Executive Vice President of the American Coalition for Ethanol (ACE), Brian Jennings, responded with written comments that included but were not limited to feedback on the RFS role on the environment, agricultural sustainability and tailpipe emissions.
“…petroleum represents the most harmful source of transportation fuel while renewable fuels such as ethanol represent the safest. Recent crude oil spills have killed fish, animals, and plant life. Ethanol, on the other hand, is derived from plant life and ethanol coproducts are fed to fish and livestock. At the same time ethanol’s lifecycle greenhouse gas (GHG) emissions and production efficiencies are dramatically improving, extracting and processing crude oil into gasoline is becoming more expensive, inefficient, and destructive to the environment,” wrote Jennings. (Read ACE’s full comments here.)
The Renewable Fuels Association (RFA) responded to seven questions proposed in the white paper by proposing 10 questions of their own.(Read RFA’s full comments here.) READ MORE and MORE (WKZO.com)
RFA's 10 questions:
1. What are the environmental effects of oil exploration, including seismic surveys, drilling and well logging, deployment of marine platforms, and infrastructure development? Please discuss among other issues the potential environmental effects resulting from disturbing ecologically sensitive areas including wetlands and tundra, loss of natural vegetation, functional habitat loss, reduced populations and densities of birds and animals, perforations in cap rock formations, air and groundwater contamination from disposal of drill cuttings, structural impacts on marine life, seabird mortality from collision, oiling, incineration by flame, hydrologic alteration through long term surface water mining for ice roads, and decline in aquatic macro invertebrate density and taxonomic diversity due to siltation.
2. What are the environmental effects of oil extraction, including fracturing, pumping, and additional infrastructure establishment? Please include a discussion about the potential health and environmental effects associated with chemicals used in fracturing, alteration of groundwater flow and quality, surface and subsurface contamination from improperly abandoned wells, seismic events, bird fatalities in produced water ponds, fires from terrestrial oil spills, loss of saltmarsh vegetation from oil spills, air pollution from flaring, permanent depletion of subsurface deposits of petroleum, loss of wetlands or habitat, species decline, and animal avoidance.
3. What are the environmental effects of crude oil distribution, including transportation (ocean tanker, rail and/or truck) and pipeline? Please discuss specifically the potential effects of marine oil spills, aquatic and shoreline biological effects of spills, land clearing for pipeline construction, disturbance of remote areas such as the North Slope tundra and Ecuadorian Amazon, and the biological effects of spills.
4. What are the environmental effects of gasoline production at the refinery? Please discuss specifically among other things the potential impacts of air pollution from refining, water pollution, soil pollution, petroleum coke and radioactive solid waste streams due to buildup of naturally occurring radioactive materials.
5. What are the environmental effects resulting from gasoline distribution, including transportation, pipeline shipment and storage? Please discuss specifically the air pollution from trucks and rail, gasoline spills, freshwater spills from pipeline ruptures leading to fish kills and species fragmentation, the toxicity of spills to terrestrial plants and soils, evaporative emissions from storage facilities, and leaking of underground storage tanks and associated groundwater contamination.
6. What are the environmental and public health effects of gasoline use, including fuel blending, fuel dispensing and driving? Please discuss specifically the potential environmental and health effects of tailpipe pollutants from gasoline combustion, spills and evaporation at retail locations, leaking underground storage tanks and associated groundwater contamination. Also, please discuss specifically the impact on gasoline toxicity, aromatics content generally and the
level of benzene, toluene and xylene specifically resulting from reduced ethanol use under a scenario where the RFS didn’t exist.
7. What are the GHG emissions impacts of increased unconventional oil production from Canadian oil sands, tight oil from fracking, thermally enhanced oil recovery, and gasoline production, distribution and use? Please discuss specifically the direct and indirect emissions, such as land use change and methane releases, resulting from unconventional oil production.
8. How has the composition of gasoline and resulting emissions changed since 2005? Please discuss specifically the toxicity, ozone-forming potential and carbon profile of today’s marginal gallon of gasoline (unconventional tight oil and oil sands) relative to the 2005 baseline fuel used by EPA for RFS comparison and compliance.
9. What are the GHG and other environmental impacts of our dependence on imported oil and the national security implications of that dependence? Because 40% of our oil imports come from OPEC nations, please address specifically the emissions of the Fifth Fleet that protects international oil shipping lanes from the Persian Gulf, the emissions attributable to the transportation, re-supply and training of ground and air forces staged in the region to keep
stability amongst oil producing states, and the GHG emissions attributable to the burning of oil fields and deliberate spills following the Gulf War.
10. Do current lifecycle analysis tools and models fully capture the environmental and carbon effects of oil exploration, extraction, processing, transportation and combustion? Please discuss how existing analytical tools can be improved. READ MORE
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