The Limitations of the EPA’s RFS2 program

By Simon Bird, Environmental Accountant at AgRefresh

The US national policy for biofuels has been advancing at a fast and furious pace. Every day new research fights for our attention, heralding technological advances or new impact assessments. A successful national biofuel promotion program would be fluid, allowing for the incorporation of this new research and would promote the development of increasingly sustainable technologies and practices. However, the EPA’s RFS2 program is a static being that will not allow for changes to be incorporated easily, whether great technological leaps or incremental improvement in feedstock production. The program additionally flattens the playing field among the diverse range of fuels, removing any incentive for fuel producers to reduce impacts or move to less environmentally-damaging feedstocks or processes.

This is a result of the EPA’s focus on mandated volumes, and forcing all fuels into one of four set thresholds based on the EPA’s own analysis of national data, instead of the biofuel producers individual processes. If instead the EPA would allow fuel producers to utilize existing LCA software systems, they would be able to conduct full carbon assessments of their fuels, incorporating the entire lifecycle of the product and any indirect effects. The producers’ LCA would then be used to give the fuel a carbon label, which biofuel distributers or users would use to keep under a mandated carbon cap. A system like this would give biofuel producers and feedstock producers a real market-based incentive to improve their processes and reduce the carbon intensities of their biofuels. In this system the “grandfathering” of existing ethanol refineries using coal as a fuel source would no longer be an issue, the marketplace would quickly drive biofuel producers to much less carbon intensive fuel production technologies and fuel sources.

One example of the negative effects of the static nature of this legislation is that Congress mandated that the baseline for GHG emissions reductions be the year 2005. The result is that the GHG emissions of future biofuels are being compared against the historic GHG emissions level of petroleum fuels, a far cry from an “apples to apples” comparison. The mixture of petroleum fuels used in the US is constantly changing, and in future years will become increasingly carbon intensive as oil becomes scarcer and more energy is required for extraction and processing. A low carbon fuel standard using carbon labeling wouldn’t lock the country into using an arbitrary metric such as GHG reductions from petroleum in a historic year, but would compare all individual sources of fuel on an “apples to apples” basis every year.

A well designed low carbon fuel standard using a carbon labeling system would give the program flexibility to adjust to changing research and incentives to reduce the carbon intensity of fuels in comparison to the EPA’s RFS2. This would result in the movement to more sustainable feedstocks, and the incremental improvement in feedstock production methods and biofuel refining technology.

Simon Bird
AgRefresh Environmental Accountant
802.859.0099, ext. 6

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