Bias in California's Low Carbon Fuel Standard

California's Low Carbon Fuel Standard (LCFS) is a good initiative but it is flawed in its current form. Consider:

Ethanol is an alcohol with a fairly simple, universal formula regardless of how it is made. The great thing about all ethanol is that it is miscible in gasoline, oxygenates gasoline so that it burns more cleanly, and it is a renewable fuel whose carbon comes from the atmosphere, not from subterranean fossil deposits - so it is at least carbon neutral or "low carbon" compared with "high carbon" petroleum products.

When people talk about advanced biofuels like "cellulosic ethanol" they are not talking about the alcohol product, they are talking about the feedstock used to produce the ethanol and, to some extent, the process of its cultivation, harvest, and manufacture. Cellulose is the raw material but the product is the same.

The public doesn't discriminate a difference because neither do most reporters and their editors (see "Everyone Hates Ethanol?"). When "Ethanol" is painted as a "racket" in the Wall Street Journal it impacts all ethanol - "advanced" or not. Whether policy-makers understand the difference is irrelevant if they are unduly influenced by negative public opinion spawned by a misled press.

The indirect land use change (iLUC) issue is an example of a unscientifically proven theory that can kill a nascent industry before it starts to grow. The press and public opinion can sway policy-makers without regard for the truth. Investors and politicians become unwilling to stick their necks out. And then only the government or established energy giants can control the outcome.

Even though most "advanced biofuels" process developers think they are immune to the iLUC issue - because 1) they may not use corn or other cultivated crops as feedstock or 2) they may not need tilled soil to get feedstock - they should think again. The brush being used to paint "ethanol" is very broad and, by the way, the most successful independent ethanol investors have come from the corn ethanol industry.

Exciting innovations for producing biofuels will come from the first generation ethanol producers to create "advanced biofuels" - increases in yield per acre, no-till and advanced agronomic practices, reduction of fossil energy inputs, and the expanded use of cellulose residuals (starting with cobs and corn stover, and moving on to other crops). Unless, of course, bad policy saps or limits investment resources.

Growth Energy sent out an email appeal for fairness that appears to be lacking in a process that rewards scientific speculation and is biased against first generation success. If we start handicapping success, who will assume the considerable risks that come with this very expensive paradigm shift? How does that make us more economically independent and globally secure? And how does that speed us toward alternatives to the status quo?

Here is the action that Growth Energy solicited on the same day that CARB passed the LCFS:

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WE NEED YOUR HELP!

Below are some stories that have been published recently that we would like you to respond to. We need you to reinforce the message that ethanol is a clean, green renewable fuel that is available today to help us reduce our dependence on foreign oil. Please refer to the talking points below for additional messaging on this issue.

Fuels must clean up act, The Sacramento Bee
Air Resources Board moves to cut carbon use, The San Francisco Chronicle
California Fuel Move Angers Ethanol Makers, The New York Times
General Wesley Clark goes to battle for ethanol industry, Chicago Tribune
Editorial: California air board makes good decision to move away from corn-based ethanol, Contra Costa Times

Talking Points:

• Growth Energy supports efforts to move to a low carbon environment. Ethanol is a low carbon fuel and its inclusion in our nation's energy mix will help reduce green house gases. The latest research shows that ethanol reduces greenhouse gas emissions by up to 59 percent compared to gasoline.

• While Growth Energy supports the concept of a Low Carbon Fuel Standard (LCFS), it objects the California Air Resources Board's (ARB) staff report, which proposes unfair standards in calculating the carbon intensity of fuels. It would penalize ethanol by adding an "indirect land use change" penalty to biofuels.

• The theory of ILUC is built on the idea that American grain exports will plummet because of corn used for ethanol. One model estimates that corn exports will decrease by 62 percent and that soy exports will decline by 28 percent. Those assumptions have been proven to be false as you can read in our policy paper.

• The ARB only applies ILUC penalties to biofuels for land use, but doesn't take into account the indirect carbon effects of petroleum, including the protection our oil supply in the Middle East, or the increased carbon intensity from the characterization, storage, transport, and disposal of oil production waste products.

• The adoption of ILUC models in GHG measurements will slow advancements in second-generation biofuels and discourage corn-based ethanol producers from investing resources to reduce their carbon footprint.

• Not only will implementing ILUC theory not reduce carbon emissions, but it could lead to other calls for indirect market effects included in carbon calculations. For example, China has already called for the nations who buy its exports to pay for the carbon emissions related to the production of those exports. Such an arrangement would not be sustainable in any sort of cap and trade system.

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technorati bioenergy, biofuels, ethanol, cellulosic, legislation