BIO says EPA RFS rule inaction on causing an increase in GHG emissions

Increased greenhouse gas emissions equal to 4.4 million additional cars on US roads are likely as a result of EPA inaction on finalizing the 2014 Renewable Fuel Standard (RFS) rules, according to a new white paper issued by The Biotechnology Industry Organization (BIO). The white paper updates earlier BIO’s March 2014 study, “Estimating Greenhouse Gas Emissions from Proposed Changes to the Renewable Fuel Standard Through 2022.”That study demonstrated that if EPA reduced biofuel use under the RFS, as the agency proposed in November 2013, the United States would experience an increase in greenhouse gas emissions and forego an achievable decrease in emissions.

For the current analysis, the BIO team used the estimate of gasoline, diesel, ethanol and biodiesel use in 2013 and projections for 2014 in EIA’s September 2014 Short-Term Energy Outlook. The United States is now projected to use 2 billion gallons more gasoline and 0.5 billion gallons more diesel in 2014 than previously projected.

The authors developed two scenarios for 2014, the first based on EPA’s proposal from November 2013 and the second with estimated volumes based on a waiver of cellulosic biofuel and a corresponding increase in advanced biofuels.

For the second scenario, they further assumed that biodiesel would be used to meet a portion of the unspecified advanced biofuel mandate, over and above the biomass-based diesel mandate. They then modeled GHG emissions using the GREET1.2013 model.

The newly modeled estimates of GHG emissions are higher across the board than in the March 2014 analysis, due to the estimated changes in transportation fuel use for both 2013 and 2014. The BIO team concluded that it appears that it is no longer possible to achieve a year-over-year reduction in GHG emissions.

The reduced estimate of petroleum diesel use and increased biodiesel use for 2013 created a larger reduction in GHG emissions in 2013 than can now be achieved in 2014. And while gasoline and diesel use have been rising in 2014, in the absence of a final rule, oil refiners have blended ethanol and biodiesel only at rates consistent with EPA’s November 2013 proposal. They cannot now go back and blend at higher rates.

The update asserts that:

  • The “blend wall” should not be a consideration for setting the RFS, because the United States is using more transportation fuel in 2014 than previously projected.
  • Inaction on the 2014 RFS regulatory rule will lead to increased GHG emissions of 21 million metric tons CO2 equivalent.
  • The increased GHG emissions are equal to putting an additional 4.4 million cars on the road, or having current cars drive an additional 50 billion miles, or opening 5.5 new coal-fired power plants.

During the UN Climate Summit this week, the Obama administration is sure to promote the regulatory actions it has taken to reduce climate change emissions from stationary sources such as power plants. But regulatory inaction on the RFS has opened the door to an increase in greenhouse gas emissions from the transportation sector.

Last November, EPA proposed a steep reduction in the use of biofuels in order to avoid hitting the so-called blend wall—a proposal the administration still has not finalized. What the agency failed to consider is that demand for transportation fuel has been increasing—the United States is now using several billion gallons more gasoline and diesel than projected. The so-called blend wall is an invention of the oil industry and has simply been a red herring.

The administration must finalize the 2014 Renewable Fuel Standard using a methodology based on biofuel production and continue the program’s successful support for commercialization of advanced and cellulosic biofuels. The renewable fuel industry has already created hundreds of thousands of good jobs and boosted economic growth.