November 6, 2008
BIO Urges EPA to Complete Sound Scientific Review Before Publishing Greenhouse Gas Emission Estimates for Biofuels
The U.S. Environmental Protection Agency must establish a sound, science-based model for measuring net greenhouse gas emissions related to biofuels production before releasing estimates that may understate the positive role biofuels play in reducing climate change emissions. The Biotechnology Industry Organization (BIO) today released a letter sent to EPA Administrator Stephen L. Johnson on Oct. 23, urging the agency to release and seek comment on the methodology it is using to estimate the life cycle greenhouse gas emissions of biofuels, particularly those attributed to international land use change, as called for in the Renewable Fuel Standard.
In the letter, BIO President and CEO Jim Greenwood writes, "Our members in the biofuels industry agree that consideration of direct lifecycle greenhouse gas emissions is essential to identifying truly sustainable transportation fuel solutions. BIO's member companies are confident that if the RFS rulemaking is conducted with adequate scientific rigor, advanced biofuels can meet these standards and provide substantial benefits for the global climate."The letter notes the difficulty the EPA faces in combining data from existing Life Cycle Assessment (LCA) tools that measure direct emissions with immature models that attempt to estimate indirect greenhouse gas emissions.
Greenwood then continues, "If the proposed rule contains numerical results from flawed models published prior to the maturing of modeling tools, it could have a range of perverse effects, including discouraging and chilling investment and curbing U.S. production and use of all biofuels. Without a more sophisticated understanding of international land use change variables and interactions, a rule risks discouraging production of biofuels that truly do reduce U.S. greenhouse gas emissions and contribute to energy security."
Brent Erickson, executive vice president of BIO's Industrial & Environmental Section, added, "The EPA's rulemaking on the Renewable Fuel Standard could set a precedent for future regulation of greenhouse gas emissions under any carbon capping, trading, or taxing legislation and possibly for international agreements. The EPA must get this rule right. Measuring emissions with LCAs is already very complex; trying to model indirect land use changes is unbelievably complicated, and good models do not yet exist to accurately measure land use changes and emissions. In the future many other industries or land use activities could legitimately be assessed the same indirect land use penalty being considered for U.S. biofuels, and that should be a wakeup call about why this rulemaking needs to be scientifically sound.
"The EPA in August determined that the Renewable Fuel Standard was not a significant factor in the rise of crop and food prices over the first half of 2008, despite well publicized claims to the contrary. Current commodity price data showing a high correlation between agricultural commodities and oil, which all rose and fell in price over the past year, clearly demonstrates that the EPA's decision was the correct one. The EPA should not rush to publish conclusions on greenhouse gas emissions only to be proven incorrect at a later date. We hope EPA will publish its modeling methodology and let scientists comment on its accuracy and validity before publishing numerical results.
"Many companies have been racing to develop next-generation cellulosic biofuels and deploy the technology to meet those requirements. There are currently more than 30 facilities across the United States planned, under construction, or beginning operation to pioneer production of advanced biofuels made from renewable resources such as corn stalks, grasses, wood chips, and even trash. The U.S. has invested more than $1 billion in continuing research and in building these facilities, and that investment has been matched by the industry. These facilities represent the first step toward building a large-scale biofuel industry that can meet growing U.S. transportation fuel needs. We need to ensure that we don't inadvertently derail this effort to commercialize truly sustainable biofuels technologies."
For more information and a copy of the letter, visit http://www.bio.org/ind/epa/ or contact Paul Winters, director of communications, at 202-962-9237 or firstname.lastname@example.org.
BIO supports the production of biofuels from all feedstocks. Biotechnology is helping to increase corn yields and convert corn starch and crop residues into biofuels more efficiently. With ongoing advances in biotechnology, biofuels can help America meet nearly half its transportation-fuel needs by the middle of this century.
The Advanced Biofuels & Climate Change Information Center presents the latest commentary and data on the environmental, greenhouse gas and other impacts of biofuel production. Drop in and add your comments, at http://biofuelsandclimate.wordpress.com/.
BIO represents more than 1,200 biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology products. BIO also produces the BIO International Convention, the world's largest gathering of the biotechnology industry, along with industry-leading investor and partnering meetings held around the world.
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