Questions and responses on RFS testimony

House Science Committee Hearing on the RFS, November 3, 2015
(photo credit: Michael A. Waring) 

Following the recent hearing on the Renewable Fuel Standard (RFS) held by the House Science Committee, the subcommittee chairs asked me to respond to some questions for the record, following up on my testimony at the hearing. Here are the questions and an abbreviated version of the answers, summarizing my full written response. 

In his testimony, Mr. Coleman referenced cellulosic ethanol that is "129 times better than gasoline on carbon emissions." Based on your research, is this a reasonable claim?

No, that is not a reasonable claim. Such assertions are based on paper studies of hypothetical ethanol production methods. There is indeed a literature on the subject that applies lifecycle analysis (LCA) to proposed cellulosic ethanol production methods and projects that the resulting systems would not only fully offset tailpipe CO₂ emissions but also offset other CO₂ emissions such as those from fossil-based electricity generation.

However, as pointed out in my testimony (and in papers explained elsewhere on this blog), the LCA methods used to justify such claims are scientifically incorrect. Moreover, the cellulosic processing methods involved remain speculative as far as any meaningful commercial-scale operation is concerned. In short, claims of biofuels that achieve a more than 100% reduction in carbon emissions are rooted in flawed analysis of fantasy fuels. 

During member questions, Mr. Coleman claimed that considering prior land use on cropland converted to corn as a result of the RFS was an inappropriate way to examine the impact of the RFS on carbon emissions. Do you agree? Why or why not?

No, I do not agree. In fact, failing to consider prior land use results in a serious error in carbon accounting. See "Bringing Biofuels Back to Earth" for an explanation of why it is crucial to include prior land use and its carbon uptake when analyzing biofuels.

Mr. Coleman also asserted that the structure of the Clean Air Act, carbon accounting, and the nature of agriculture markets discount your method of carbon emissions analysis. Is he correct? Why or why not?

No, he's not correct. As part of the Clean Air Act (CAA), the RFS requires EPA to account for lifecycle GHG impacts but does not specify exactly how that should be done. The CAA gives EPA discretion on how to implement its provisions and it does not a priori "discount" or otherwise forbid any particular method for evaluating the lifecycle GHG emissions impacts of fuels. 

Asserting that the "nature of agricultural markets" discounts my analysis is nonsense. Markets can be assessed by any number of carbon accounting methods; some will have integrity and others may not, just as is the case for accounting methods applied to financial markets. My work points out the lack of environmental integrity in how fuels-oriented LCA methods account for carbon flows tied to agricultural markets. 

Was there anything else discussed at the hearing that you would like to correct for the record?

Yes. I take issue with many other aspects of Mr. Coleman's testimony; here are some points and counter-points: 

He said that the RFS has been effective in "breaking the oil monopoly." It's true that the world oil market is subject to manipulation at times by a "clumsy monopoly," as the late MIT economist Morris Adelman termed OPEC. Nevertheless, the fact that oil is the largest source of commercial energy in both the United States and worldwide is not a result of monopoly power; it is a result of the incredibly high value that consumers and global economies place on petroleum products. Moreover, advances in petroleum production have resulted in lower prices and a large savings for consumers that have nothing to do with the RFS. 

As for the claim that "We need the RFS because we can't get shelf space," if biofuels were competitive products they would readily find space in the fuels market. The real problem is that neither ethanol nor biodiesel have true economic or environmental value. 

During the hearing, Mr. Coleman said that I use a "provocative" carbon accounting approach that is "not well supported. And it's called additionality." That statement simply underscores his lack of knowledge about carbon cycle science and Intergovernmental Panel on Climate Change (IPCC) guidelines, which include a section on "Baselines and Additionality."

Finally, Mr. Coleman pointed out that my findings are at odds with those of agencies that have analyzed the issue. But that's the point: my research challenges the prevailing wisdom. I'm not alone among scientists who are uncovering serious errors in government-sponsored biofuels analyses. Scientific progress involves a sometimes painful process of questioning assumptions, and that is what is underway now on the topic of the RFS and similar policies to promote biofuels.