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August 26, 2016
On August 18, the Office of Inspector General (OIG) released a report detailing the Environmental Protection Agency (EPA)’s failure to adequately evaluate the environmental impacts of biofuels. Quantifying these impacts is especially crucial as Congress assesses the success of the Renewable Fuel Standard (RFS), which requires an increasing percentage of renewable fuels to be blended in the fuel supply.
The OIG review, announced in October 2015, addresses two areas pertaining to the RFS: 1) EPA’s lack of compliance with reporting requirements of the law, and 2) EPA’s failure to update its lifecycle analysis for biofuels. EPA is supposed to provide updated reports to Congress on the impact of RFS every three years, but hasn’t provided one since 2011. Additionally, EPA failed to complete the “Anti-Backsliding Analysis” to ensure that air quality is not worsened by the RFS. EPA has not updated its lifecycle analysis on the environmental effect of the RFS—while not legally required, it is something that EPA committed to do as updated science becomes available.
Results of the Report
The OIG concluded that “the EPA, Congress and other stakeholders lack key information on impacts needed for making science-based decisions about RFS.” This position is shared across the aisle, as illustrated in the June congressional hearing on RFS implementation. Many members expressed frustration at the lack of EPA reporting, which makes it difficult for them to evaluate the successes and failures of the RFS.
However, the EPA Office of Research and Development (ORD), which provided the last report, said that Congress didn’t really respond to it. ORD estimates that the first report cost $1.7 million. In recent years, EPA’s time, energy, and money have simply gone to other priorities.
The Inspector General Report provided four recommendations to EPA based on its findings: 1) Provide the required reports to Congress; 2) Complete and provide the anti-backsliding analysis; 3) Based on the anti-backsliding analysis, determine whether mitigation actions need to be taken; and 4) Develop criteria for deciding when the lifecycle emissions analysis needs to be updated.
EPA’s response to these recommendations is included in the OIG report. EPA agreed with the first recommendation and plans to complete the next triennial report by the end of 2017 (three years later than it should have been provided).
EPA also agreed with the second and third recommendations, but felt that complying would require significant time and resources. Steps required to complete these recommendations include, according to EPA, “development of baseline, current, and projected scenarios for how renewable fuels have and might be produced, distributed, and used to fulfill the RFS requirements, generation of emissions inventories, and air quality modeling, all of which are time-consuming and resource-intensive.” When pressed, EPA agreed to meet these requirements by no later than 2024.
In response to the fourth recommendation, EPA agreed to clarify the process they currently use to decide whether or not to update the lifecycle emissions analysis. However, the Inspector General does not push EPA to actually update it, and EPA has maintained that updating it is unnecessary.
Why Update the Lifecycle Emissions Analysis?
OIG describes lifecycle emissions as direct and indirect emissions “related to the full fuel lifecycle, including all stages of fuel and feedstock production, transportation, and use of finished fuel by the ultimate consumer.” EPA’s lifecycle analysis was completed in 2010 and has not been updated since. Though analyses have been completed for new biofuel sources, like cottonseed oil, the 2010 analysis remains EPA’s most recent for the major biofuels, particularly corn ethanol.
EPA’s Office of Air and Radiation (OAR) suggests, according to the report, that there would be “minimal utility in updating the 2010 analysis.” This is because approximately 80 percent of the biofuels blended with the gasoline supply today are “grandfathered” in to the RFS, meaning they don’t have to meet any additional greenhouse gas (GHG) emissions reduction requirements.
However, stakeholders on both side of the issue have long pushed for updated analyses, as both sides believe that the results of these analyses would support their position. In particular, those who support the RFS and expanded biofuel use point to newer science and updated data showing that the difference in GHG emissions between biofuels and traditional gasoline is even greater than initially thought.
Ideally, the anti-backsliding analysis will help to resolve some of these questions. Bob Dineen, president of the Renewable Fuels Association, said, “We are confident that once EPA conducts these required studies, they will show that biofuels like ethanol are significantly reducing greenhouse gas emissions, even above the threshold reductions.”
Author: Rebecca Chillrud
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