BIO addresses EPA indirect land use proposal

Web exclusive posted Nov. 5, 2008 at 11:53 a.m. CST

The Biotechnology Industry Organization held a journalists roundtable on Oct. 31 to address questions and concerns regarding the U.S. EPA's implementation of the renewable fuels standard enacted in the Energy Independence & Security Act of 2007 (RFS). The RFS will include a number of complex changes to the current RFS policy enacted in the Energy Policy Act of 2005, including the expansion of volume mandates and the establishment of three new renewable fuel categories.

Specifically the roundtable focused on one particular change � the determination of greenhouse gas (GHG) lifecycle emissions from the production of biofuels, including any indirect land use changes. It has already provoked a response from scientific experts and biofuel industry members.

The hour-long session, which was moderated by Brent Erickson, executive vice president of BIO's industrial & environmental section, included comments by four life cycle analysis and biofuel production experts who discussed the possible impacts on the industry, including issues concerning the accounting for international land use change and life cycle analysis for dedicated energy crops.

The purpose of the roundtable discussion was to provide supporters with background information of the EPA's forthcoming comment period regarding the proposed RFS changes. "BIO has some concerns with the methodology the EPA has employed, but in general, we support the production of biofuels in the most sustainable way possible," Erickson said. "All of BIO member companies are involved in efforts to establish voluntary sustainable criteria for biofuels production, and other types of production."

BIO would like the EPA to publish their methodology and let the scientific community and others comment on it, Erickson added. "Frankly, the science on indirect land use is very immature, and the models are not sufficiently developed. I think that is reflected both in the academic and private sector." According to Erickson, BIO strongly believes there are generally no accepted methods to address indirect land use change and there is no way to apply even current methods in any meaningful way.

Bruce Dale, a professor of chemical engineering and a former chair of the department of chemical engineering and materials science at Michigan State University, explained the difference between direct land use change and indirect land use change. "Those that are in the lifecycle community are able to do analyses on direct lifecycle changes," he said. "When talking about indirect land use, it involves instances such as diverting some corn to make ethanol, which takes the corn out of the marketplace � market forces will react to replace that corn through a series of models. For example, the effects of someone cutting down a Brazilian rainforest to use as feed to replace the corn that was not used in the animal feed market."

Analysts simply don't know how to handle these indirect effects, Dale said. "The EPA has been put in a difficult situation," he added. "We're not able to adequately asses the impacts. This is a very thorny issue and the science is not able to support these types of policy regulations."

Dr. Brian Davidson, chief scientist for systems biology and biotechnology at the Oak Ridge National Laboratory in Tennessee, said there are three questions surrounding indirect land use change analyses. "The first is, can we do it � the technology and cost question," Davidson said. "The second is can we do it enough to make an impact, and the third is can we do it forever."

"Talking about technology, we've really implemented what I call generation zero technology � the corn starch conversion in the United States and sugarcane in Brazil," Davidson said. "Generation types one, two and three technologies are all trying to get into the commercial market, pretty much at the same time, mostly cellulosic type conversion technologies. I believe that the answer to the technology cost question is going to be 'yes.' There are enough indicators showing that we will be able to get these problems solved and costs down."

In regards to impact, Davidson said there have been a number of studies done that suggest it is possible, with reasonable assumptions. "There has also been a good amount of plant and science research that is really just getting started, looking at biomass crops such as switchgrass and woody crops. Think about the progress we have made with corn agriculture, being able to grow it better, we can do similar things with plant science to these dedicated energy crops to make them more sustainable-not purely to improve yields-but also things like lowering water use."

"The third question-can we do it forever-this is really the sustainability question," Davidson said. "And here we get to the use of dedicated biomass feedstocks, which will be perennials that will require lower amounts of fertilizer and lower amounts of water input." Such perennials will have better energy and water carbon balances, but to date the models aren't strong enough to say how much and how far, he added. "Except we know it will be better," Davidson said. "We have to be careful in what regulations we set out for an industry that is just getting started, where there isn't enough information from actually having done it, to make any of these judgments."

Keith Cole, General Motors Corp.'s director of legislative and regulatory affairs, voiced the company's concerns with the new modeling and rules. "GM has invested in two advanced biofuel companies Mascoma Corp. and Coskata Inc. � those are relatively small investments, but our interest is driven in how the fuel pool interacts with vehicles � and particularly, as we look forward to a future where GHG emissions are likely to be the coin of the realm, and discussion will revolve around what are the lifecycle emissions around what vehicle versus another."

GM would like to see the industry get to a place where there are commonly accepted metrics for being able to compare greenhouse gas emissions, according to Cole. "Imagine comparing a gasoline-powered car to an ethanol-powered car, to a natural gas-powered car, to a plug in hybrid or electric vehicle. How do we compare the two or make tradeoffs about our own investments to satisfy our own regulatory standards? How does the country assess which technologies are making the most progress or having the most potential to make progress in the future?"

There are slight disagreements over data regarding direct land use change, Cole said, but there aren't any big fights over the methodology. "With indirect land use, there are major disagreements over data, and on how to tackle this. How far do you push out the causal relationships? We recognize this is an area where there is a lot of debate. There is a lot of money at stake, we know within the fuels community there is a lot more at stake, and it is going to draw a lot of attention."