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Environmental Working Group Prefers Keystone Pipeline to Low-Carbon Renewable Fuels. No, Really

In recent weeks the Environmental Working Group (EWG) and others have been promoting a study that suggests corn ethanol is worse for the climate than the controversial Keystone XL pipeline and gasoline produced from Canadian tar sands.  From our perspective, that’s like saying apple juice is worse for the human body than arsenic.

EWG’s claim is based on a misrepresentation of an outdated and discredited lifecycle greenhouse gas (GHG) emissions analysis conducted in 2009-10 by the Environmental Protection Agency (EPA). In that analysis, EPA assumed expansion of corn ethanol under the Renewable Fuel Standard (RFS) would induce indirect land use changes (ILUC). The ILUC theory suggests that using corn for ethanol will “divert” grain away from the animal feed market, and non-agricultural lands (including Amazon rainforest) will be converted to cropland to replace the grain “lost” to ethanol. The emissions associated with these theoretical land conversions (many of which hypothetically occur halfway around the world) are then assigned to corn ethanol for the purpose of determining the fuel’s lifecycle GHG emissions profile.

But hindsight, empirical data, and common sense have shown EPA’s estimates related to ILUC to be grossly exaggerated. Subsequent analyses conducted by Purdue University, the University of Illinois, Argonne National Laboratory, Oak Ridge National Laboratory, the European Commission, and a number of other public and private entities have shown that EPA greatly over-predicted ILUC emissions, possibly by 75% or more. In addition, a recent Iowa State University analysis of actual agricultural land use patterns over the past decade concluded that “…the primary land use change response of the world’s farmers from 2004 to 2012 has been to use available land resources more efficiently rather than to expand the amount of land brought into production. This finding is not necessarily new…however, this finding has not been recognized by regulators who calculate indirect land use.” In other words, real world data prove that the types of extensive ILUC predicted by EPA’s modeling exercise in 2009 simply haven’t occurred.

Thus, it is not surprising that Argonne’s latest analysis shows that the production and use of corn ethanol emits 34% less GHG emissions on average than extracting, refining, and consuming gasoline from conventional crude oil (see table from study below). When compared to the Canadian tar sands that would flow through the Keystone pipeline, corn ethanol reduces GHG emissions by 40% or more. And even though there is evidence to suggest ethanol expansion has not induced ILUC, the Argonne estimates conservatively include some emissions for hypothetical conversions of grassland to cropland.

 Lifecycle GHG results from Wang et al. (2012)

Even the California Air Resources Board (CARB)—certainly no friend to Midwest agriculture or corn ethanol—has determined that today’s grain ethanol reduces GHG emissions by 20-25% or more compared to gasoline consumed in the state (CARB estimates corn ethanol lifecycle emissions at 75 grams of CO2e per megajoule (g/MJ) compared to 100.5 g/MJ for gasoline). Don’t forget that CARB’s estimate includes an unjustifiably large penalty for purported ILUC emissions. Still, even with this handicap, CARB says grain-based ethanol has provided 60% of the requisite GHG reductions under California low carbon fuels requirements since 2010.

Meanwhile, the Union of Concerned Scientists recently acknowledged that early analysis suggesting that ethanol is worse than gasoline “…has not survived careful scrutiny.” UCS goes on to state that “…when ILUC emissions are combined with all other emissions – corn ethanol produced at an average Midwestern facility using natural gas as a source of process heat is 20% cleaner than gasoline, and the cleanest facilities are better still.”

While EPA has steadfastly refused to update its flawed ILUC analysis, the Agency clearly recognizes that corn ethanol produced today reduces GHG emissions by at least 20% compared to petroleum. EPA has approved petitions from more than 40 grain ethanol producers (representing more than 3 billion gallons of production) who have sought permission to expand their ability to generate RIN credits under the RFS. A precondition of gaining EPA approval is that the petitioner must demonstrate that the ethanol it produces today reduces GHG emissions by a minimum of 20% compared to 2005-era petroleum. EPA has concluded that the ethanol from these 40 facilities reduces GHG emissions by 20-29%. In other words, contrary to EWG’s rhetoric, we don’t need to wait until 2022 for corn ethanol to generate GHG savings relative to petroleum—it’s happening today, and has been happening for several decades.

Even the courts have weighed in on this issue. In 2012, the U.S. Court of Appeals for the District of Columbia dismissed a petition for review of EPA’s final RFS regulation filed by a handful of EWG cronies (the National Chicken Council, Friends of the Earth, and National Wildlife Federation; the latter two eventually pulled out of the case). The groups essentially argued that certain corn ethanol plants that were “grandfathered” under the RFS—and thus exempt from the GHG reduction requirement—would not be able to demonstrate a 20% GHG reduction in the absence of the exemption. In dismissing the petition for review, the judge disagreed and stated that modern grain ethanol facilities could easily show that they today “meet the emissions-reduction requirement.”

By recently proposing to reduce 2014-2016 federal renewable fuel standards below the levels established by Congress in 2007, EPA would in fact be encouraging greater use of dirtier sources of petroleum—like tar sands and tight oil from fracking—and less biofuel. Even the most extreme fringe environmental groups should know this is bad decision for the climate and for the American consumer. Who would have thought a group supposedly “dedicated to protecting human health and the environment” would side with Big Oil in the debates over Keystone XL and renewable fuels?

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