I'm not alone in expressing such concerns. A paper whose authors include the original developer of the lifecycle analysis method that underpins the LCFS points out how such approaches can mislead policy makers. A recent World Resources Institute (WRI) report faults policies that promote biofuels and create an adverse "food vs. fuel" trade-off.
Among the objections to my criticism is that it is merely academic and fails to offer a constructive solution for the transportation fuel-related CO2 emissions that remain after improving vehicle efficiency and limiting travel demand.
|Governor Arnold Schwarzenegger signing AB 32 on Sept. 27, 2006 |
(Source: Getty Images via Zimbio)
The cornerstone of effective climate policy is sound and verifiable carbon accounting. Fuel policies defined using lifecycle analysis are neither sound nor verifiable, and the liquid fuels such policies classify as "low-carbon" have questionable merit.
Counting real carbon -- the physical substance that can be chemically measured in gas pumps, pipelines and tankers -- is straightforward. After combustion and in the form of CO2, it's what gets directly measured when cars are tested for emissions and fuel economy. Whether from tailpipes or smokestacks, real carbon is the basis for AB 32 as well as for the new federal Clean Power Plan. Tracking carbon carefully is the climate policy equivalent of the business dictum, "what gets measured, gets managed."
Chemically, the amount of carbon in liquid fuels varies only trivially. The notion that biofuels or other liquids billed as "low carbon" somehow reduce emissions from cars, trucks and jets is, quite literally, unreal. Burning such fuels does not change how much CO2 actually gets emitted. Any possible benefit can only be realized outside the transportation sector on productive land where an increase in net carbon uptake is achieved.
Because there's no practical way to capture carbon before it leaves a tailpipe, as long as liquid fuels are used it will be necessary to balance out their emissions by absorbing more CO2 from the air somewhere else. That means creating carbon offsets, and to be effective, such offsets must remove carbon from the atmosphere faster than it's already being removed. In carbon accounting parlance, the offset must be additional in the sense of increasing the rate of net CO2 uptake beyond whatever is already occurring.
In California, the AB 32 cap-and-trade program offers a correct framework for balancing fuel-related CO2 emissions. A necessary technical fix is to fully include, rather than omit, biofuel CO2 emissions in the cap. Moreover, carbon offsets should be expanded and embraced as a key mitigation mechanism for the transportation sector instead of viewed mainly as a way to contain costs.
Federally, the country still needs to forge a political consensus to control carbon. The RFS provides no shortcut in that regard; it is a road in the wrong direction as far as climate is concerned. Several policy options offer solutions for transportation fuels, including direct regulation, cap-and-trade or a carbon tax. Whatever choice is made, it is crucial that the policy is defined on the basis of sound carbon accounting and tied to an expansive CO2 removal program anchored in verifiable carbon offsets.
In short, a clear-eyed focus on tracking real carbon will reveal policies that are far more effective than those now in place but which are based on the low-carbon fuel fallacy.