Urban Air Initiative, Energy Future Coalition Challenge EPA Data on Ethanol’s Lifecycle Emissions

April 11, 2016

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(Urban Air Initiative) Urban Air Initiative joined the Energy Future Coalition and the Governors’ Biofuels Coalition (GBC) in calling on the U.S. Environmental Protection Agency (EPA) to recognize an overwhelming body of new evidence showing fuel ethanol can reduce carbon emissions.

The EPA’s assessment of information on ethanol’s lifecycle emissions is inaccurate and outdated according to the Urban Air Initiative (UAI) and the Energy Future Coalition (EFC). The groups argue that contrary to EPAs 2010 Lifecycle Analysis report, the best available science shows that blending ethanol into gasoline has significantly reduced greenhouse gas emissions and other air pollutants.

The two organizations were joined by the GBC which represents 21 state governors supporting the development of cleaner burning fuels like ethanol. The groups filed a report requesting that the EPA correct its 2010 Lifecycle Analysis for future Renewable Fuel Standards (RFS) rules. The request for correction was filed under EPA’s Information Quality Guidelines by the law firm of Boyden Gray and Associates.

The request for correction came in response to an evaluation being done by the Office of the Inspector General (OIG) in regards to whether the EPA had updated lifecycle analyses supporting the Renewable Fuel Standard. UAI and EFC contend the reports the EPA relied on regarding greenhouse gas emissions and conventional air pollutants are woefully outdated.

“The lifecycle analyses that the EPA and the National Academy of Science relied on have been updated due to technological revolutions in agricultural production and biorefining as well as improved modeling. At every stage, corn ethanol results in less greenhouse gas emissions and air toxic pollution than gasoline,” said Urban Air Initiative President Dave VanderGriend. “As a result, the best available science demonstrates that blending ethanol into gasoline lowers emissions associated with climate change and improves human health. Ethanol’s benefits would be even greater if it were blended at higher levels.

The data-backed report UAI, EFC, and GBC submitted to the EPA covers a range of crucial considerations that make up the overall lifecycle assessment. In particular the report argues:

Land Use Change and related emissions are much less than estimated and improved yields means more corn on less land;
More efficient agricultural practices result in less nitrogen fertilizer per bushel;
The sequestration value of corn allows for the capture of carbon deep below ground;
Biorefineries producing ethanol and other co-products are significantly more efficient, using less natural gas and electricity while producing more products;
Petroleum based fuels–which biofuels are measured against– are becoming more energy intensive, making the gap between the two even greater.

“Agriculture practices and ethanol plant technology are evolving and improving every day”, said VanderGriend. “Ethanol lifecycle analysis was never an exact science but to be saddled with 5 year old data and assumptions fails to paint an accurate picture. We are growing more corn, with fewer inputs, on less land, and producing both feed and fuel. The carbon footprint of that fuel therefore is significantly undervalued in these studies.”

The report to EPA also notes that the carbon reductions would be even greater through higher ethanol blends since ethanol’s high octane would displace the most carbon intensive compounds in oil which are currently the source of octane.

“The benefits of ethanol go well beyond greenhouse gas emissions. The ‘traditional’ air pollutants like particulate matter, toxics, and NOx are also reduced,” said VanderGriend. “Higher ethanol blends provide even more benefits and we have the ability to protect public health through cleaner fuels.”

Under the Information Quality Guideline, the EPA is required to respond the request within 90 days. If you’d like a copy of the report, please email kim@urbanairinitiative.com. READ MORE and MORE (Ethanol Producer Magazine) Request for Correction of Information submitted on behalf of The Energy Future Coalition, Urban Air Initiative and Governors' Biofuels Coalition and Request for Correction of Information submitted by Steffen Mueller, PhD Principal Economist Energy Resources Center The University of Illinois at Chicago

Excerpt from Executive Summary of Request for Correction of Information submitted on behalf of The Energy Future Coalition, et al.: New evidence shows that GHG emissions from ethanol are lower than EPA predicted in its 2010 Lifecycle Analysis, and much lower than the lifecycle emissions of gasoline. In particular, new evidence shows that:

Increased demand for corn causes much less land-use change and related emissions than EPA predicted in 2010. This evidence includes improved economic models and newly available land-use data from periods of increasing corn ethanol production, which show significant increases in yield but no significant increases in forest conversion.
Improved agricultural practices and technologies are substantially reducing the carbon intensity of ethanol by increasing the ability of soil to capture and retain carbon deep below ground. This evidence includes updated science on soil organic carbon, which indicates that best tillage practices sequester more carbon in the soil than previously thought. In fact, the evidence suggests that many corn fields are net carbon “sinks,” capturing more carbon than land-use change and corn farming releases.
More efficient agricultural practices and technologies have also reduced the per bushel amount of nitrogen fertilizer applied to the corn crop and converted into the greenhouse gas nitrous oxide (N2O).
Biorefineries have become much more efficient, using less natural gas and electricity to produce each gallon of ethanol. Biorefineries are also producing new co-products that reduce the carbon intensity of ethanol. These include distillers’ grains, which is used as animal feed; corn oil, which replaces soy-based biodiesel; and other co-products that lower the carbon intensity of corn ethanol.
By contrast, petroleum-based fuels are becoming increasingly carbonintensive. As a result, the gasoline carbon intensity baseline should be significantly higher than EPA suggested, increasing the comparative benefit of ethanol.

Considered in light of this new evidence, the lifecycle GHG benefits of the RFS are much greater than EPA predicted. Indeed, blending the volumes of renewable fuel called for by the RFS through 2022 would result in substantial cumulative reductions in carbon emissions—the RFS has already prevented more than 354 million metric tons of GHG pollution, according to a recent conservative estimate, and it will result in even higher savings in the future.

EPA should also consider the following information when updating its lifecycle analysis:

Any initial CO2 emissions associated with the initial implementation of the RFS are now “sunk costs,” since corn ethanol has already reached the levels projected by the RFS. Thus, continued ethanol use is substantially less carbon-intensive than EPA suggested in 2010 and offers net GHG savings compared to the gasoline it displaces.
Other tailpipe emissions associated with conventional gasoline aromatic hydrocarbons (which ethanol can replace), produce non-GHG “climate forcing agents” such as black carbon that contribute to climate change, whereas ethanol reduces those emissions.
Ethanol’s pollution-reducing benefits could be even greater if it were used to produce higher-octane fuel blends, replacing toxic and carbon intensive fuel additives while allowing carmakers to increase vehicle fuel economy through next-generation engine design.

In light of this new evidence, EPA should correct its 2010 Lifecycle Analysis to conform to the best available science.

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Like EPA’s GHG analysis, the Agency’s 2010 Lifecycle Analysis and the 2011 Report to Congress also contain erroneous estimates of ethanol’s effect on emissions of non-GHG (or “conventional”) pollutants.

In particular, new evidence shows that:

The farming technologies that have increased yields and lowered carbon intensity have also reduced emissions of conventional air pollutants.
Improved control technologies and other innovations have lowered emissions from biorefineries.
U.S. gasoline is increasingly produced from “tight oil,” which does more damage to the nation’s air quality because it is produced domestically and because it produces higher air toxic emissions during
extraction and refining.
The negative health effects of aromatics—the octane additives in gasoline that are displaced by ethanol—are worse than previously estimated, increasing urban particulate matter and other air toxics.

The latest fuel effects studies also show that EPA erred in its estimate of tailpipe emissions from E10. In particular, new evidence shows that:

E10 reduces benzene, toluene, ethylbenzene, and xylene emissions.
E10 reduces particulate matter, especially in modern gasoline direct injection engines.
E10 also reduces dangerous polycyclic aromatic hydrocarbons, as well as secondary organic aerosols.
E10 has little or no effect on nitrogen oxides; in modern engines with oxygen sensors, E10 reduces nitrogen oxide emissions.
E10 does not increase volatile organic compound emissions. In fact, ethanol reduces these emissions when it is blended into gasoline in higher volumes.

In addition to the emissions reductions ethanol has already achieved, transitioning to gasoline blends with a higher ethanol content, such as E30, would significantly reduce lifecycle emissions and improve air quality. READ MORE