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Stunningly Trivial Emission Reductions from the Renewable Fuel Standard Program: More MAGICC–this time from EPA

By -- May 8, 2009

On May 5, 2009, EPA Administrator Lisa Jackson signed a proposed rule to implement changes in the federal Renewable Fuel Standard (RFS) program required by the 2007 Energy Independence and Security Act (EISA).

Congress created the RFS–commonly known as the ethanol mandate–in the 2005 Energy Policy Act. The leading rationale then was energy security. It was supposed to reduce our dependence on foreign oil. EISA increased the size of the mandate from 7.5 billion gallons a year in 2012 to 36 billion gallons a year in 2022.

In addition, EISA established greenhouse gas (GHG) reduction standards that fuels must meet in order to qualify as “renewable.” Arguably, this was the first regulatory global warming policy that Congress ever enacted. Well, how much global warming will it avert? Answer: Too little for scientists to detect even if the new mandates are enforced throughout the 21st century.

EPA’s proposed rule for implementing the EISA RFS weighs in at a hefty 549 pages. The accompanying draft regulatory impact analysis spans 822 pages. Those seeking to avoid eye strain and somnolence may consult two handy Fact Sheets that EPA has posted on its Web site.

A general Fact Sheet gives much of the big picture:

  • EISA increases the 2005 Energy Policy Act RFS for 2008 from 5.4 billion gallons to 9 billion gallons, and then annually increases the required volume until it reaches 36 billion gallons in 2022.
  • Starting in 2009 (hey, that’s now!), refiners, blenders, and importers must supply 0.5 billion gallons of biomass-based diesel fuel and 0.6 billion gallons of advanced biofuel.
  • Starting in 2010, the motor fuel industry must supply 0.1 billion gallons of cellulosic ethanol.
  • By 2022, industry must supply 16 billion gallons of cellulosic ethanol, at least 1 billion gallons of biomass-based diesel, and 21 billion gallons of advanced biofuel [by my count, that’s 38 billion gallons–2 billion more than the EISA total].
  • EISA also establishes first-ever GHG reduction standards for renewable fuels. To qualify as renewable, corn ethanol (if made in facilities built after Dec. 19, 2007) must achieve a 20% GHG reduction compared to petroleum fuels in 2005; biomass diesel and advanced biofuel must achieve a 50% reduction; and cellulosic ethanol must achieve a 60% reduction.
  • EISA allows EPA discretion to adjust these targets downward by as much as 10%; EPA proposes to qualify biofuel as advanced if its GHG emissions are 40% lower than petroleum fuel.

A second Fact Sheet explains how EPA calculates the GHG emissions profile of renewable fuels compared to petroleum fuels. The Agency employs a “life-cycle analysis.” EPA examines not only the GHGs released when fuels are combused but also the GHGs released due to production and transport of feedstocks, land-use changes associated with energy crop production, and production, blending, and distribution of fuels.

The most controversial feature of EPA’s analysis–the part that provoked House Agriculture Committee Chairman Collin Peterson (D-MN) to accuse EPA being “in bed with the oil industry”–is the inclusion of indirect emissions from land-use changes. Recent scientific research (ably summarized here) projects that as corn-ethanol manufacture increases, farmers will expand production into forest and grasslands to make up for the grain stocks diverted from food to auto fuel. As a result, substantial amounts of carbon stored in soils and trees could be released. 

EPA attempts to calculate how long it will take for the displacement of petroleum by renewable fuels to “pay back” the carbon dioxide released by land conversions linked to energy-crop production. EPA estimates that over a 30-year period, corn ethanol could achieve a life-cycle GHG reduction of as much as 26% compared to petroleum fuels, but could also increase GHG emissions by as much as 34%. It mostly depends on whether the factory’s electricity comes from natural gas or coal. About 62% of Minnesota’s electricity comes from coal; which suggests that much of the State’s ethanol might not qualify as “renewable” under EPA’s proposal. No wonder Peterson is hopping mad!

However, perhaps the most significant big-picture aspect of EPA’s proposal is not discussed in either of the Fact Sheets–namely, how much climate protection will the RFS provide? How much atmospheric warming and sea-level rise will it avert?

EPA discusses this on pp. 348-349 of the proposed rule. EPA estimates climate impacts to 2200 using two models: MiniCAM (Mini Climate Assessment Model), which calculates global emissions based on assumptions about how population, land-use, technology, and economies will change in different regions of the world; and MAGICC (Model for the Assessment of Greenhouse Gas-Induced Climate Change), the simple climate model Chip Knappenberger used in two recent posts to calculate potential global warming reductions from the Waxman-Markey bill.  

The potential climate protection benefits of the RFS are stunningly trivial, as can be seen in the table below.

Climate Sensitivity

                           1.5                   2                    3                  4.5                 6

Change in global mean surface temperature (degrees Celsius)

2030           0.000             0.000           -0.001         -0.001         -0.001

2050         -0.001             -0.001          -0.001          -0.001         -0.002

2100         -0.003             -0.004         -0.005          -0.006         -0.007

2200        -0.003              -0.004        -0.006           -0.008         -0.009

Change in global mean sea-level rise (centimeters)

2030       -0.002              -0.002         -0.003          -0.003           -0.003

2050      -0.012               -0.014          -0.017           -0.020          -0.022

2100     -0.045               -0.052          -0.063           -0.074           -0.082

2200   -0.077               -0.091           -0.114            -0.143            -0.172

In EPA’s analysis, by 2050, the RFS averts 0.001ºC of warming and 0.0012 centimeters of sea-level rise in a low-sensitivity climate, and 0.002ºC of warming and 0.022 centimeter of sea level rise in a high-sensitivity climate. Even by 2200, the RFS averts only o.oo9ºC of warming and 0.172 centimeters of sea-level rise in a high-sensitivity climate.

As climate protection, the RFS is a bust. It’s chief value has always been as corporate welfare for agribusiness. And now, as Chairman Peterson’s fulmination indicates, the RFS may not even produce a bumper crop of pork!


  1. Tom Tanton  

    Essentially the same controversy surrounded the California Air Resource Board’s adoption of their “Low Carbon Fuel Standard” albeit for a tad different regulatory goal: so now ethanol is the wayward, whilst less than a year ago it was the favored. The twisting machinations to explainthe shift illustrates the truly bizzare nature of CARB’s rule making. While I agree with them (and with EPA) that life cycle analysis is (theoretically) the correct approach, unless it’d done fairly and completely across ALL fuels it can be (and likely is) worse than not using lca to begin with. It also smacks of intentional favoritism and/or discrimination. Equally bad is the use of “average” numbers (such as for crop/land use changes) as that perpetuates the “good” subsidizing the “bad”–there’s just way too much diversity to calculate these numbers except on an individual gallon basis and the tracking of THAT is horrendously complex.


  2. Ed Reid  

    Stunningly trivial indeed; and, to 3 insignificant figures!


  3. rbradley  


    And methanol was the fuel de jure at one point of the California Energy Commission back in the 1980s, if memory serves.


  4. Tom Tanton  

    Rob, yes methanol had its day in the CEC sun–but natural gas and electricity did as well. Fickle is as fickle does…


  5. Cooler Heads Digest 8 May 2009 | GlobalWarming.org  

    […] Stunningly Trivial Emission Reductions from the Renewable Fuel Standard Program Marlo Lewis, MasterResource.org, 8 May 2009 […]


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