A Data with Destiny

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We have known for two years that the renewable fuel standard (RFS) would require biomass-based diesel, but there has been a great deal of uncertainty about how the program would treat the multitude of biodiesel feedstocks. The National Biodiesel Board has labored tirelessly for the past 24 months to ensure that sound science was the basis of discussion, and show all sustainable feedstocks are indeed viable alternatives to imported petroleum.

When it was enacted in December of 2007, RFS ignited hope to provide the needed backstop for the fledgling biodiesel industry. Under the RFS the initial volume requirement for 2009 was a mere 500 million gallons-nearly 200 million gallons less than the amount of U.S. biodiesel produced in 2008. This "under-sizing" of the RFS was quite intentional. The tax credit was intended to be the economic driver, while the RFS was intended to be a safety harness for the biodiesel industry when energy markets crash, as they did in 2008.

Ushering in this new RFS was a rollercoaster of optimism and disbelief. The statute's requirement that biomass-based diesel reduce greenhouse gas emissions by 50 percent compared to petroleum seemed an easy hurdle. Longstanding life-cycle analysis showed biodiesel reduces carbon emissions by at least 78 percent. The provisions in the statute ensuring no direct land use change occurs for the production of biodiesel threatened to present a mountainous paperwork burden, but there remains no real concern among U.S. biodiesel producers that land use change would be necessary at all to meet the modest volume goals of the RFS.

Disbelief may not be strong enough to describe the reaction among American farmers and biodiesel producers when it became clear that emissions penalties were set to be levied against U.S. producers for the actions of cattle ranchers and illegal loggers in South America. The emissions from land-clearing activities in distant countries are linked to biodiesel only through spurious economic modeling.

Being held accountable for indirect effects, over which the industry has no control, that are caused directly by our competitors was a difficult pill to swallow. Adversity, however, is no stranger to the biodiesel industry. This challenge was met, like many others, with a do-or-die-trying attitude and a quest for better scientific data. NBB was prepared to seek this data because of funding support from NBB members, the United Soybean Board and the Minnesota Soybean Growers Association. NBB enlisted help from experts in the fields of feedstock production, economic modeling and life-cycle analysis.

NBB's strategy to achieve equitable, practical, information-based implementation of the RFS was multi-faceted. One of these important facets was working to ensure all sustainable feedstocks would be eligible for the program. This meant rehabilitating flawed life-cycle modeling to show that, even with the inclusion of indirect emissions for biodiesel only and the dubious assumption that petroleum has no indirect impacts, biodiesel provides a substantial GHG benefit over petroleum.

NBB's team of experts provided in-depth, detailed analysis of the direct and indirect life-cycle modeling. Their research identified several errors or oversights in EPA's initial rules. Examples of these errors include failure to adopt the most recent guidelines from Intergovernmental Panel on Climate Change on N2O emissions for soybeans and failure to give emissions credit for glycerin, which is a valuable coproduct of biodiesel production.

NBB members also participated in the quest for better data, which included the largest survey ever of U.S. biodiesel producers. This survey measured actual energy use and proved that modern producers use significantly less energy than previous models had assumed. The survey also showed that biodiesel producers are implementing processes to reduce water consumption and to sell more glycerin to high-grade markets.

Providing sound scientific data and unbiased information proved very fruitful in terms of improvements to the proposed rule. The EPA and its hard-working staff certainly gave the impression that they were trying to make the rule as good as it could be.

The volume of scientific evidence that proves biodiesel's benefits over petroleum continues to mount. That doesn't mean our challenge is over. NBB will continue to be engaged in the development of better data on life-cycle emissions and indirect land use so that consumers and policy makers can rest assured that their support for clean, renewable, domestic fuel does not have unintended consequences anywhere in the world.

Don Scott, technical and regulatory engineer, NBB