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Renewable Fuel Standard 2.0

I have heard that some people are worried that renewable fuel standards or low-carbon fuel standards or simple market forces favoring biofuels will "cause people to rip up sustainable soybean fields and turn them into big switchgrass plantations." And that EPA is proposing elaborate new laws saying that farmers and foresters cannot grow biofuel crops on land previously used for other purposes. Is this true and what do you think about all that? – Lisa N., Wilton, CT

The RFS already has such delineation and the recently proposed RFS2 goes further.

The U.S. Environmental Protection Agency (EPA) announced in Feb 2008 that it is raising the renewable fuel standard (RFS) for 2008 to comply with the Energy Independence and Security Act, which President Bush signed in December 2007. The RFS requirement will continue to ratchet up each year until it reaches 36 billion gallons in 2022, of which 11 billion gallons must come from cellulosic, non-food ethanol.

In Oct 2009, the Government Accountability Office (GAO) said that to meet the RFS, domestic biofuels production must increase significantly to achieve the RFS's 36-billion-gallon requirement in 2022. 

To address these concerns, GAO has proposed amendments to the RFS, known as the RFS2.

RFS2 would:

  • require a significant expansion of the escalating volumes of renewable fuels required each year (to reach 36 billion gallons by 2022);
  • divide the volume requirements into four categories of renewable fuels (“conventional biofuel,” “advanced biofuel,” “biomass-based diesel,” and “cellulosic biofuel”);
  • require that each of these mandated volumes of renewable fuels achieve certain minimum thresholds of greenhouse gas (GHG) emission performance;
  • significantly change the definition of renewable fuels;
  • expand the types of fuels subject to the standards to include diesel and certain nonroad fuels;
  • and include specific types of waivers and EPA-generated credits for cellulosic biofuels.

The proposed RFS2 program would increase the cellulosic biofuel mandate from 250 million to one billion gallons by 2013, with additional yearly increases to 16 billion gallons by 2022.

The GHG targets for renewable fuels call for a 20 percent reduction of GHG emissions relative to petroleum fuels for general renewable fuels, a 50 percent GHG reduction target for advanced biofuels and biomass-based diesel, and a 60 percent target for cellulosic ethanol. 

All biofuel facilities that were built or under construction before December 19, 2007, are grandfathered in and will not be required to meet the minimum 20 percent GHG threshold.  Biodiesel produced in that category would be added to corn ethanol production to meet the 15 billion gallon RFS for conventional biofuels in 2015 and beyond.

I support the EPA proposals in general, but I have some concerns. First, the RFS should embrace all types of liquid and gas biofuels used for transportation as long as they meet environmental compliance, which include all the alcohols such as butanol, and also dimethyl ethers, and biogas.

I am adamantly against the rules on consequences of land substitution for the biofuels industry unless they are universally applied to other industries such as mining, waste storage, residential sprawl construction and even parking lots. Our society and environment tolerate intense emissions, including greenhouse gases, from these “land switchovers” that far exceed biofuels in many cases.

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Volume 18, Issue 4


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