ARB in new territory with low-carbon fuel standard

Ethanol, long viewed as a sound fuel alternative for an atmosphere tainted by gasoline and diesel exhaust, is now getting second, critical look in a fierce, two-pronged dispute that mixes science and politics. Once again, California’s Air Resources Board is breaking new ground and is at the heart of an air-quality debate with national and international implications.

The ARB’s potential impact on what is being described as indirect land use also is being examined. This, as much as carbon emissions, is fueling the debate.

The crux of the issue is the Low Carbon Fuel Standard, a policy pushed by Gov. Arnold Schwarzenegger to cut carbon emissions – greenhouse gases – in the use and production of fuel. It would encourage the development of alternative fuels, including some biofuels, hydrogen and electricity, and require conventional fuel producers to track – and reduce – the carbon in their products.

The ARB will unveil its regulation governing the Low Carbon Fuel Standard, or LCFS, next month in Sacramento. Last week, the board issued a report on the proposed regulation.

The goal is to eliminate 16 million metric tons of carbon emissions from the air over the next decade. It requires “a 10 percent reduction in the carbon content of all passenger vehicle fuels sold in California” by 2020, according to the governor’s original executive order.

A key part of the debate is ethanol, a pure alcohol that in California and others states has been used as an additive to gasoline to cut down pollutants. The ethanol industry has been financially crippled by the recession, plunging gasoline prices and a glut on the market of the grain used to produce ethanol. The industry sees the looming California regulation as a kick at the industry when it’s down.

While ethanol is clean-burning when measured at the tailpipe, the production and distribution of ethanol entails emissions of climate-changing greenhouse gases, some experts say. That means regulators must consider, in the words of ARB Chairwoman Mary Nichols, the “cradle-to-grave life cycle” of fuels, including ethanol and other biofuels, in order to assess their true impact on the atmosphere. Other environmentalists agree.

“The key focus here is that we need to pay attention to the carbon emissions and air-quality emissions of the entire cycle. We can’t just say biofuels are good, we have to say what kind of  biofuels are good. The data show that if we want to achieve real greenhouse gas emissions, we should be looking at cellulosic grass, rice straw, not crop-based fuels,” said Bonnie Holmes-Gen of the American Lung Association. “We have to look at the pathway of the fuel – is it from a waste crop or is it from corn?”

For environmentalists and state regulators, that difference is crucial: If a fuel, such as ethanol, springs from corn, the carbon emissions associated with producing that corn – the fuel for the harvesting equipment, the fertilizer, the fuel used to generate the power for a farm, for example – must be included. The carbon emissions from a waste crop – wood chips, for example – presumably would be less.

Part of the life-cycle of the fuel is the emissions stemming from conversion of land to produce the crop that feeds the fuel. For example, if an acre of forest is cut down so that the land can be used to grow a biofuel crop, the loss of that forest must be calculated in determining the fuels’ greenhouse gas emissions.

The inclusion of this land change, or indirect land-use, in the debate over the LCFS has scientific partisans – on both sides.
Can a regulation written in California truly reflect land-use changes in Brazil? Many scientists are skeptical, and contend that the methodology and underpinning of the proposed rule is vague and uncertain.

Deforestation, for example,  “is currently occurring in places like Brazil, Indonesia and Russia as a direct result of logging, cattle ranching and subsistence farming,” but not biofuel production, said a letter to the ARB signed by 111 scientists allied with the New Fuels Alliance, a pro-ethanol industry group.

Ethanol producers and grain growers are deeply angry, viewing the ARB’s rule as a selective slap at their industry and no other. They note that their industry is suffering, that they got into the business in the first place because of earlier encouragement from the government and that the air-quality benefits of ethanol over gasoline are profound. At least five ethanol production facilities have closed in California.

The ARB’s proposed regulation “would only penalize biofuels and not other fuel types, including gasoline,” noted the industry group. Growth Energy. The co-chairman of the group is retired General Wesley Clark, who said it “would not only be bad science, but also bad policy.”

 By including the land-use changes, the ARB “is proposing to enforce a penalty on all biofuels for indirect land use change…” the March 2 letter added. “It is clear that indirect effects should not be enforced against only one fuel pathway. Petroleum, for example, has a price-induced effect on commodities, the agricultural sector and other markets. Electric cars will increase pressure on the grid, potentially increasing the demand for marginal electricity production from coal, natural gas or residential oil.” Among the 111 signatories was Blake Simmons, a ranking scientist at the Sandia National Laboratories.

In response, a group of scientists refuted the contentions of Simmons and others. According to a group led by Michael O’Hare, a professor at UC Berkeley’s Goldman School of Public Policy, there is a certain level of potential uncertainty, but that the government has “long regulated vehicle and stationary source emissions… Engineered product systems such as biofuels produced on arable land carry risks to human health and Earth’s climate; those risks are uncertain, but a variety of methods are available for their estimation.”
The ARB’s pending regulation will be the first in the nation to attempt to cut emissions based on the entire production cycle of the fuel, from its inception to its combustion. The regulation will consider the emissions involved in extracting and transporting the fuel, and of converting it from one form to another.

It will consider the land that is used to produce the fuel, such as ethanol: If forests that capture carbon emissions are cut down to grown grains used for ethanol, for example, the impact of those emissions will count against ethanol.

The goal of the LCFS, cutting 16 million metric tons by 2020, could result in replacing the current burning of one in every five gallons of gasoline or diesel fuel with biofuels, hydrogen fuel cells or electricity, which in California is generated by natural gas or by hydroelectric dams.

“This is expected to replace 20 percent of our on-road gasoline consumption with lower-carbon fuels, more than triple the size of the state’s renewable fuels market, and place more than 7 million alternative fuel or hybrid vehicles on California’s roads (20 times more than on our roads today),” Schwarzenegger noted earlier.