pros and cons for the LCFS and RFS from the perspective of the environmental groups

Introduction

            The increasing concerns associated with climate change and energy security played an instrumental role in justifying the inception of biofuel policies in the U.S. In order to address the climate these concerns, the Energy Independence and Security Act of 2007 set for the biofuel subsidies and mandates as well as an the Renewable Fuel Standard (RFS), which is an upper bound on the greenhouse emissions per gallon of biofuel, especially for biodiesel and ethanol.[1] California adopted another policy to supplement the federal policy, the Low Carbon Fuel Standard (LCFS), which dictates that the greenhouse gas emission per gallon of fuels will be a particular percentage that is relatively lower that the baseline gasoline. This paper compares the pros and cons for the LCFS and RFS from the perspective of the environmental groups.

A Brief Summary of RFS and RFS

            The RFS refers to a federal biofuel policy that requires biofuels to be blended into the United States transportation fuel. The RFS was first established under the Energy Policy Act of 2005 and expanded later under the Energy Independence and Security Act of 2007. The RFS had the primary objective of driving the production of alternative fuels to gasoline in order to lessen the US’ reliance on foreign oil and reduce greenhouse gas emissions.[2] On the other hand, the LCFS was enacted with the primary objective of reducing the carbon intensity in the transportation fuels when compared to traditional petroleum fuels such as diesel and gasoline. Examples of low carbon fuels under the LCFS include alternative fuels and cleaner fossil fuels.[3] The main objective of implementing the LCFS is to reduce carbon dioxide emissions arising from fuel-powered automotives taking into consideration the entire lifecycle in order to lessen the carbon footprint associated with transportation.

A common characteristic of both LCFS and RFS is that the greenhouse gas emissions of biofuels are calculated by using life cycle analysis (LCA), a method that takes into consideration the greenhouse gas emissions in the entire supply chain of biofuel production including the change of feedstock into a fuel, transport of the gasoline from the fields to the plant as well as fertilizers’ production. As a result, biofuels produced from fertilizers using coal energy results in more greenhouse gas emissions than biofuels produced from natural gas.[4] The primary difference between LCFS and RFS is that the LCFS expands the greenhouse gas emissions from biofuels to include the emissions resulting from indirect land-use change (ILUC) linked to the production of biofuels.  Indirect land use change refers to the change of land from its existing production to crop production as a method to address the surge in food prices. For instance, the change from tropical forests to food production such as soybeans is likely to lead to considerable greenhouse gas emissions that are likely to take several years to recapture. The aspect of ILUC points out the worry that the production of biofuel will result in deforestation, which will increase the amount of greenhouse gas emissions. The inference from this observation is that the production of biofuels will cancel out the reductions in greenhouse gas emissions arising from using biofuels.[5]

Renewable Fuel Standard (RFS) from the Perspective of Environmental Groups

            It is apparent that the aspect of renewable energy is a significant concern for environment groups; as a result, the implementation of the RFS resulted in divergent views from environmentalists, especially with regard to whether the RFS actually achieves its primary objective of reducing greenhouse gas emission. This section analyses the pros and cons of RFS from the perspective of environmental groups.

Pros of RFS

            The first notable merit of the RFS is that it addresses the concerns associated with climate change owing to the fact that agricultural-based biofuels tend to emit relatively lower quantities of direct greenhouse gases when compared to fossil fuels when these biofuels are processed, harvested and produced under the correct conditions. The underlying argument is that the RFS mandate to encourage the consumption of biofuels is an effective approach to tackle the climate change issue.[6] The RFS sets forth the guidelines that guarantee that the biofuels are favorable for climate change; in this regard, RFS requires that biofuels can only qualify for the renewable fuel standard only if they attain at a minimum of 20% reduction in the lifecycle GHG emissions when compared to gasoline. It is undeniable that biofuels emit GHG during the growing of the crop that makes the biofuel and refining the crop to produce the biofuel. However, reducing these emissions from crops for biofuels can be achieved by modifying how the crop for the biofuel is grown, the efficiency of the processing facility, and the how far the crop is transported. According to the RFS, life cycle GHG emissions include the emissions resulting from production, transport delivery, and the utilization of the biofuel.[7] The definition of lifecycle GHG emission also incorporates direct emissions emanating from fuel production facilities operated by biomass, coal and/or natural gas, and indirect emissions from internal and domestic land use changes because of the increase in demand for biofuels. The underlying argument is that the RFS is favorable for climate change if the production process and consumption of biofuels are done appropriately.[8] The Environmental Protection Agency estimates that when the RFS is implemented fully in 2022, the extended use of biofuels will reduce yearly GHG emissions by 138 million metric tons, which is the same as removing about 27 million automotives of the road.

The second merit of the RFS from an environmental perspective is that it guarantees the environmental benefits associated with renewable biofuels; for instance, most biofuels are biodegradable, non-toxic and generated from renewable feed stocks. The principal argument is that the RFS establishes the policies needed for an environment friendly biofuel production process. These environmental benefits are unique to renewable biofuels only; the fact that biofuels are biofuels are made from renewable feed stocks translates to the view that effective implementation of the RFS will enhance the sustainability of biofuels in the United States. It is undeniable that renewable biofuels are relatively environment friendly when compared to low carbon fuels and cleaner fossil fuels in terms of toxicity and environmental pollution. Therefore, increased production of biofuels is likely to result in a clean environment and eliminate potential sources of environmental pollution emanating from the so called “low carbon fuels”. Biofuels have the potential of creating a completely clean environment when compared to low carbon fuels.[9]

Cons of the RFS from the perspective of Environment Groups

            Despite the aforementioned environmental benefits, there are a number of deficiencies of RFS to guarantee that biofuel production does not result in environmental degradation. The first demerit of RFS is that does not protect water, soil and air. The RFS does not have standards that ensure that air quality, soil health and waterways are not degraded.[10] Most of the EPA-approved biofuels, both advanced and traditional, made from feed stocks are been proved to be extremely invasive, increase soil erosion, water pollution and deforestation. Common feed stocks such as sugar cane and soy are increasing the rates of deforestation. In addition, the increased demand for biofuels has increased the competition for land between food crops and popular feed stocks whereas domestic feed stocks such as algae and miscanthus grass are characterized by invasive qualities that are likely to threaten biodiversity and pollute waterways.[11]

The second demerit of the RFS stems from the GHG loophole for corn. The RFS has a principal provision that exempts almost all domestic corn ethanol from satisfying the 20% greenhouse gas emission reduction standard requirement for renewable fuels. In addition, the RFS focuses on biofuels and ignores other potential alternatives.[12] The EPA approximates that about 14.8 billion gallons of corn ethanol will be excluded from this standard regardless of the fact that EPA’s data points out that, in reality, corn production generates more green house gas emissions than the traditional gasoline. The use of corn ethanol as stipulated in the RFS will increase the green house gas emissions. Regardless of the fact that, EPA estimations reveal that corn ethanol will result in reduced greenhouse has foot print in future, the facilities involved in the production of corn ethanol are producing relatively more GHG emissions than gasoline. On average, the corn ethanol produced in the United States results in 36% more GHG emissions than the traditional gasoline. It is only in the final years of implementation of the RFS that the corn ethanol is likely to be better marginally than gasoline.[13]

The third demerit of the RFS stems from the GHG “escape hatch”. The EPA can opt to reduce the GHG requirements under the RFS in case the industry fails to make sufficient amounts of biofuels that are commercially viable and meet these standards. However, the National Academy of Sciences recently revealed that cellulosic and advanced biofuel industry cannot meet their mandates because of the high costs. Consequently, EPA could opt to lower the standards stipulated in the RFS, the challenge is that this will result in the use of environmentally degrading fuels to meet the mandate.[14]

Low Carbon Fuel Standards from the Perspective of Environmental Groups

            Contrary to emphasizing on the use of biofuels, the LCFS focuses on lowering the carbon intensity, which is an area of concern for environmentalists. The LCFS provides for allowable carbon intensity for the providers of transportation fuels

Pros of LCFS

            The first merit of the LCFS from an environmental perspective is that it adopts a holistic approach to address the climate change issue; this stems from the fact that LCFS does not only emphasize on low carbon fuels but also takes into consideration the role of alternative fuels in addressing the issue of climate change. This is in contrary with the RFS, which places emphasis on biofuels only and disregards the prospects of alternative fuels in helping to tackle the issue of climate change. On a broader scale, the implementation of the LCFS is an incentive for energy producers to place emphasis on efficiency and adopt methods that can be helpful in reducing carbon. Fossil fuels are cause a direct emission of the GHG; in this regard, the LCFS crafts a standard through which carbon producers can reduce the amount of carbon in their fuels. This is a direct cut on carbon emissions on the atmosphere.[15] The LCFS will considerable reduce the global warming pollution and will establish a growing and sustainable market for cleaner fossil fuels. With a well designed LCFS, fuel producers should strive at reducing the life cycle emissions of the fuels they produce basing on the average-per-gallon basis. Instead of focusing on a given technology, fuel producers have the discretion to choose how they meet the mandates.

The second merit of the LCFS is that the insertion of indirect emissions is vital in guaranteeing the effectiveness of LCFS in addressing a number of environmental concerns. It is apparent that the any fuel policy that disregards the indirect impacts of biofuels and or alternative fuels production can result in diverse outcomes that may appear to be lessening emissions in the United States fuel sector, but in reality, they tend to increase the global warming pollution on a worldwide scale.[16] In this regard, the LCFS takes into account all the contingencies by integrating ILUC in its life cycle analysis. This helps in protecting against the supply of high carbon fuels. In this regard, the LCFS established an incentive to utilize clean fuels and an equivalent disincentive for using polluting fuels. Under this standard, fuel suppliers are supposed to produce low carbon fuels or buy credits from other suppliers to meet the standard. As a result, dirty fuels will be compelled to pay a substantial price for the higher degrees of pollution. The outcome is that the LCFS establishes a control mechanism for the development of clean fuels, which is needed to tackle the climate change problem.[17]

Cons of LCFS

            The primary challenge for the LCFS relates to the curbing of “leakage” or “shuffling”. In this regard, fuel producers will devise the easiest way of acting in response to the new LCSF standard requirements. The fuel producers are likely to shuffle sales and production as a measure to counter the relatively low carbon standards, which will not produce any net change regarding GHG emissions. For instance, a company that produces low-cellulosic GHG biofuels in New York can opt to divert its fuel to markets in California and divert the high-carbon corn ethanol in other markets. In this regard, environmental regulators are tasked with the challenge of taking into account the possibility of shuffling; something that LCSF fails to take into account. However, this problem can only be addressed if all states adopted the same fuel policy. Variants in fuel policies are likely to create loopholes in ensuring that fuel producers meet their mandates as required. In the end, the LCFS does not provide a guarantee that it will cut GHG emissions, which is its core objective.[18]

Conclusion and Recommendation

            From the above analysis of the pros and cons of LCFS and RFS, this paper recommends the use of LCFS; this is because LCSF is more holistic and addresses a number of limitations in the RFS such as the significance of alternative fuels in averting global climate change. It is apparent that LCFS seeks to drive the production of a broader array of fuels including biofuels. Fundamentally, the standards are almost the same with the exception that LCFS considers the viability of other alternatives. In this regard, this paper advocates for the adoption of the LCFS. Therefore, with regard to addressing a myriad of environmental issues resulting from fuels, the LCFS is the most effective and holistic approach.

 

 

 

Bibliography

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McMa hon, Kate, and Victoria Witting. Corn ethanol and climate change: How the Renewable Fuel Standard mandates the consumption of biofuels that contribute to climate change. Washington: Friends of the Earth, 2012.

 

Schnepf, Randy, and Brent Yacobucci. “Renewable Fuel Standard (RFS): Overview and Issues.” Congressional Research Service, 2012: 1-26.

 

Sperling, Dan, and Sonia Yeh. “Low Carbon Fuel Standards.” Issues in Science and Technology, 2009: 57-66.

 

Tyner, Wallace. Renewable Fuel Standard: Potential Economic and Environmental Effects of the US Biofuel Policy. The National Academies, 2012.

 

Union of Concerned Scientists. Benefits of a Low Carbon Fuel Standard: Performance Based, Technology-Neutral PolicyTo Reduce Emissions from Transportation Fuel. Cambridge, MA: Union of Concerned Scientists, 2012.