The corn ethanol lobby is shocked—shocked, it says—that the United States government has declined to list the Renewable Fuel Standard (RFS) as one of the measures the country will rely on to reduce greenhouse gas emissions over the next decade. According to the ethanol lobby, the RFS, which required Americans to use almost 16 billion gallons of biofuels in 2014, is “the most successful US climate-energy policy ever enacted.” In reality, the policy is flooding the US fuel market with corn ethanol and other old, outdated, and underperforming biofuels, while failing to deliver on its promise of modern biofuels that may (or may not) help reduce the transportation sector’s negative impact on global climate change.

US INDC: Biofuels Are Not Part of the Solution

According to the United States’ official submission to the United Nations Framework Convention on Climate Change detailing its greenhouse gas reduction goal (known as the Intended Nationally Determined Contribution, or INDC), it “intends to achieve an economy-wide target of reducing its greenhouse gas emissions by 26%-28% below its 2005 level in 2025 and to make best efforts to reduce its emissions by 28%.”

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Source: U.S. Cover Note INDC and Accompanying Information (2015)

The US INDC contains a list of “domestic laws, regulations, and measures relevant to implementation” of the 26-28% reduction target, which it characterizes as “fair and ambitious.” The list includes measures that are already in place, like existing fuel economy standards for light- and heavy-duty vehicles; energy conservation standards for buildings, appliances, and other equipment; and regulatory approvals that are facilitating a transition away from the use of particularly potent hydrofluorocarbons (HFCs). The US list also includes measures under development: GHG reductions from new and existing fossil fuel-fired power plants; tighter fuel economy standards for heavy-duty vehicles; standards to reduce methane emissions from landfills and the oil and gas sector; additional measures to phase out HFCs; and stronger energy conservation standards.

Notably, the INDC makes no reference whatsoever to the RFS or to biofuels. “Is this purposeful omission indicative of a larger shift in biofuels policy support in the US?” asks the ethanol lobby. If so, there are plenty of reasons to justify the shift.

Why No Reference to RFS and Biofuels? Simply Put, Biofuels Are Part of the Problem

One of the reasons that the RFS is not listed in the INDC is that numerous analyses have shown that the lifecycle greenhouse gas emissions for conventional biofuels like corn ethanol are as high or higher than those for regular gasoline. Two recent studies reinforce the US government’s apparent concern about the RFS:

  • In an analysis conducted for the World Resources Institute, Searchinger and Heimlich (2015) wrote that “most modeling studies analyzing the greenhouse gas implications of using crops for biofuels find little or no emissions reductions so long as they estimate the conversion of forests and grasslands to replace the forgone food production.” When studies attribute significant net emissions reductions to biofuels, it is usually because they make one or more of the following assumptions—each of which is problematic at best: that food production will decline as biofuel production increases, and that countries will not implement subsidies or other measures to counteract that effect; that future increases in crop yields will outpace the historical precedent; and that biofuel crops will be grown on degraded land and therefore will not displace existing food production.
  • DeCicco and Krishnan (2015) highlight another defect found in many of the lifecycle emissions analyses of biofuels. Lifecycle analyses like the widely-used GREET model give the crops that are used to make biofuels a CO2 reduction credit because the crops absorb carbon from the atmosphere. DeCicco and Krishnan point out that in most cases, the land used to grow biofuel feedstocks would be growing crops—and absorbing carbon—regardless of whether a market for biofuels exists, so no credit is warranted. After accounting for this error, the researchers analyzed the net emissions for corn ethanol made at a new ethanol refinery and found that, “at best, corn ethanol production fails to reduce CO2 emissions relative to petroleum gasoline, and even that result depends on the gain in cropland carbon uptake that occurs with a large shift from growing soybeans to growing corn.” Once the farms that supply the refinery have completed their shift from soy to corn, “then the increase in GHG emissions due to ethanol production would be significantly higher.”

Moreover, it would be irresponsible of the United States—or any other country—to claim a specific reduction in its national GHG emissions level if the claim is based on the modeled performance of biofuel mandates. Plevin et al. (2015) reviewed the lifecycle models that EPA, California Air Resources Board, and the European Union use to measure the extent to which biofuel policies contribute to increased emissions from land use change around the world. The researchers found the model outputs are highly uncertain and tend to underestimate the emissions associated with indirect land use changes (ILUC), “suggesting that no single point estimate should be taken as representative of actual ILUC emissions intensities, even for a single well-defined scenario.”

The US Government Knows that Cellulosic Biofuels Will Not Be a Factor by 2025

In theory, the RFS mandates all kinds of biofuels, including 16 billion gallons of cellulosic biofuel per year by 2022. In practice—when you strip away the rhetoric and look only at the results—the RFS is fundamentally a corn ethanol mandate and will continue to be a corn ethanol mandate well beyond 2025 (the compliance deadline for the INDCs). Of the 103 billion gallons of biofuel that Americans were required to consume under the RFS from 2006 through 2014, 93 billion gallons have been corn ethanol (90%).

Some of the RFS’s proponents have characterized the RFS as a trade-off: in order to get the “good stuff” (cellulosic biofuels and other more advanced biofuels that may offer improved environmental performance), we have to accept the bad stuff (corn ethanol and other conventional first-generation biofuels). But if that’s the deal Congress struck, then we’re getting fleeced. On one hand, the US agricultural sector is growing record amounts of corn, and the volume of ethanol being made from that corn each year exceeds the volume that can be safely blended into the country’s gasoline mix. On the other hand, actual cellulosic biofuel production in 2014 amounted to less than 2 percent of the volume that Congress had targeted for the year.

The US Energy Information Administration doubts that the supply of cellulosic biofuel will increase much between now and 2025. While discussing EIA’s biofuels forecast in the AEO2013 Early Release, EIA Deputy Administrator Howard Gruenspecht reported that cellulosic biofuel production would miss the 16 billion gallon target that Congress set for 2022—by about 15 billion gallons:

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A subsequent briefing by Michael Cole of EIA’s Office of Petroleum, Natural Gas & Biofuel Analysis reinforced Gruenspecht’s basic message: cellulosic biofuel will not play a meaningful role in the US liquid fuel mix until at least 2030.

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No one knows yet whether cellulosic biofuels can live up to the expectations—or even EPA’s projections—concerning their lifecycle GHG emissions. The low net GHG levels that are reportedly achievable when cellulosic biofuels are produced in small batches may become unachievable when production scales up by two or three orders of magnitude. Either way, it is abundantly clear that very little cellulosic biofuel will be available in the United States (or anywhere else, for that matter) in 2025. Cellulosic biofuels, in other words, are irrelevant to the INDC.

Dither Locally, Act Globally?

The debate around the eventual fate of the RFS—should we adhere to the status quo, reform the policy, or repeal it?—continues to drag on in Congress. It is encouraging, though, to see that the Obama Administration recognizes that one of the false narratives used to sustain the RFS domestically—i.e., that the policy has reduced US GHG emissions—is not fit for international travel.

Clean Air Task Force