The Energy Independence and Security Act of 2007 requires the EPA to assess the environmental impacts associated with biofuels every three years and report its findings to Congress. The EPA released its first draft report in February for reviewing purposes and conducted a peer review meeting in March to evaluate the report, which is to be presented in its final form to Congress mid-year. Prior to the meeting, the EPA said peer review panel members would be scientists specializing in a variety of areas, including renewable fuels, environmental science and biofuel conversion technology, among other disciplines. However, industry experts who offered oral testimony at the hearing were disappointed to see the panel did not include a single member of the biofuels industry or anyone with expertise in areas such as greenhouse gas emissions, which could provide valuable insight into some of the report’s conclusions.
“I don’t understand how that happened,” said Bruce Dale, professor of chemical engineering at Michigan State University. “The EPA almost always includes representatives of the affected industries in their reviews. The whole point of these environmental analyses is to try to help us choose between alternatives. You don’t do this stuff in a vacuum.” Dale was able to deliver five minutes of testimony at the hearing, which he used to point out the absence of any comparative analysis between biofuels and petroleum in the report. Without that comparison, the report is of no use to policymakers who may be unfamiliar with the comparative negative environmental impacts of fossil fuels and biofuels, he said. “In my point of view, unless society is going to stop using fuels, it doesn’t help us to point whatever warts, real or imagined, that biofuels have, unless they’re going to be compared to petroleum,” he said. For example, he said, the report evaluates water problems associated with biofuels production, but fails to mention water problems associated with oil production. “It’s as if the Deepwater Horizon didn’t blow up and didn’t contaminate the Gulf of Mexico, or like almost every gasoline station in every city in the country doesn’t have a leaky storage tank,” he said.
Steffen Mueller, principal economist at the University of Illinois at Chicago Energy Resources Center, also offered oral testimony at the hearing. He was disappointed none of the 20 members of the expert working group convened by the California Air Resources Board last year to study the life cycle analysis of biofuels were invited to sit on the EPA’s panel. “I know they [the EPA] hired an outside consultant to convene this panel, but I think they could have done better,” he said. “I did not understand why they didn’t tap into researchers that had looked at greenhouse gas emissions from corn ethanol production, because all of the concepts, including coproduct analysis, land use modeling, everything has been discussed on the greenhouse gas side. Furthermore, none of the EPA’s internal people that look at greenhouse gas emissions from corn ethanol even showed up to the hearing or sat on the panel.”
Mueller was a member of CARB’s expert working group and focused his testimony to the EPA on the fact that the report does not take into account the displacement value of animal feed coproducts associated with corn ethanol. “Co-producing feed should be an environmental credit across all indicators because this is feed that does not need to be grown separately,” he said. He also commented on the inadequate comparison made in the report between existing corn ethanol facilities and theoretical cellulosic ethanol plants. The report appears to assume unlimited capital funds for cellulosic facilities, he said, which is unrealistic. Additionally, if corn ethanol plants had access to unlimited funds, they could afford to make the facilities as environmentally friendly as possible.
The concern among industry experts now is that there is not enough time for adequate changes to be made to the report before it is presented to Congress. The report is meant to influence policy related to biofuels and, if delivered in its current form, policymakers who review the report are likely to receive the impression that corn ethanol and soybean-based biodiesel negatively impact the environment, Dale said. “It will reinforce the view that we can go on using and importing petroleum with no bad consequences, but if we implement biofuels horrible things will happen,” he said. To the EPA’s credit, Dale said, the agency agreed to include comparative analyses between petroleum and biofuels in its next three-year report, “but we needed them now.” Mueller said he is not optimistic that many edits will be made to the draft in response to testimony delivered at the hearing or input from the panelists. “I think the report may stand as it is due to time pressure to get it out,” he said. “My concern is that the numbers, which are negative for corn ethanol, will be around for the next three years.”
According to the EPA’s Peer Review Plan, the panel’s review of the report is expected to be completed by April 21. "The EPA is committed to fully considering all comments it has received, including those comments (written and oral) offered by the biofuels industry," the agency said in a statement. "We believe we can achieve this and still deliver a final report by June 30." The draft report can be viewed at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=217443.
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