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October 20, 2015

EPA’s Office of Inspector General Orders New Ethanol Emissions Study


In a memorandum dated October 15, 2015, the U.S. Environmental Protection Agency’s (EPA) Office of Inspector General (OIG) stated that it plans to begin preliminary research on the lifecycle impacts of EPA’s renewable fuel standard (RFS). 

The stated objectives from the memorandum are to determine whether EPA:  (1) complied with the reporting requirements of laws authorizing the RFS; and (2) updated the lifecycle analysis supporting the RFS with findings from the statutorily mandated National Academy of Sciences’ (NAS) 2011 study on biofuels entitled Renewable Fuel Standard, Potential Economic and Environmental Effects of U.S. Biofuel Policy (NAS Study), EPA’s 2011 Biofuels and the Environment: First Triennial Report to Congress (2011 Report), and any subsequent reports or relevant research on lifecycle impacts of biofuels.  OIG plans to perform this work within EPA’s Office of Air and Radiation and Office of Research and Development.               

The NAS Study makes the following key finding in terms of the environmental effects of increasing biofuel production:  “The environmental effects of increasing biofuel production largely depend on feedstock type, site-specific factors (such as soil and climate), management practices used in feedstock production, land condition prior to feedstock production, and conversion yield.  Some effects are local and others are regional or global.  A systems approach that considers various environmental effects simultaneously and across spatial and temporal scales is necessary to provide an assessment of the overall environmental outcome of increasing biofuel production.”  Further, “[a]lthough using biofuels holds promise to provide net environmental benefits compared to using petroleum-based fuels, the environmental outcome of biofuel production cannot be guaranteed without a landscape and life-cycle vision of where and how the bioenergy feedstocks will be grown to meet the [revised standards (RFS2)] consumption mandate.  Such landscape and life-cycle vision would contribute to minimizing the potential of negative direct and indirect land-use and land-cover changes, encouraging placement of cellulosic feedstock production in areas that can enhance soil quality or help reduce agricultural nutrient runoffs, anticipating and reducing the potential of groundwater overdraft, and enhancing wildlife habitats.”

EPA’s 2011 Report, actualized by the 2007 Energy Independence and Security Act, requires EPA to revise the RFS program to increase the volume of renewable fuel blended into transportation fuel from nine billion gallons per year in 2008 to 36 billion gallons per year by 2022.  It concludes that:  (1) the extent of negative impacts to date were limited in magnitude, and are primarily associated with the intensification of corn production; (2) whether future impacts are positive or negative will be determined by the choice of feedstock, land use change, cultivation, and conservation practices; and (3) realizing potential benefits will require implementation and monitoring of conservation and best management practices, improvements in production efficiency, and implementation of innovative technologies at commercial scales.  Biofuels compared included conventional and cellulosic ethanol and biodiesel.

More information on other biobased issues and RFS issues is available on Bergeson & Campbell, P.C.’s (B&C®) Biobased Products, Biotechnology web page and its Fuel and Fuel Additives web page.