March 14, 2023
Why can’t you trust an atom? Because they make up everything! …I bet I’m the only one here that appreciates a good science joke…Did you know that there are times when science and policy collide within the Renewable Fuel Standard (RFS)? Like nuclear fission, this collision of science and policy has the potential to energize the RFS, moving it forward. How does it do that? By the release of the “Biofuels and the Environment Third Triennial Report to Congress (the “Report”).
Under the Energy and Independence Security Act (EISA), EPA is required to report on the effects the RFS has on the environment, “including the impacts to date and likely future impacts to the nation’s air, land and water resources.” In essence, Congress wanted an update every three years to ensure that the body of law enacted to protect the environment is, well, protecting the environment. The Report is designed to build on the first two reports submitted to Congress, and uses data accumulated from the years 2005-2020.
While the Report analyzed all 17 types of biofuels, EPA chose to focus on the four categories of biofuels that dominated the market from 2005-2020. Those four categories include: (1) Ethanol from U.S. Corn, (2) biodiesel from U.S. soybean, (3) biodiesel from U.S. fats, oils, and greases (FOGs) and (4) imported ethanol from Brazilian sugarcane. The Report is not only compiled by EPA, but also has help from the Department of Energy, the Department of Agriculture, and the U.S. Geological Survey. Similar to the makeup of some chemical molecules…it was a group affair…Ba-Dum chhhh!
So, what did they find? After searching like the great electricity detective…Sherlock Ohms, EPA found that from 2013 to 2020, the RFS likely played a more prominent role in the domestic production of corn ethanol. EPA also found that the RFS has most probably encouraged domestic production and use of other biofuels such as biodiesel and renewable diesel, specifically since 2010; however, EPA noted that for those types of biofuels, there was insufficient information to quantify the “attributional effect” of the RFS program. In other words, EPA is pretty sure that the RFS contributed to an increase in the domestic production and use of biodiesel and renewable diesel, but without more information it’s difficult to make that distinct conclusion.
One of the reasons EPA can’t state anything conclusively is the existence of co-occurring factors. For example, as part of its conclusion that the results for biodiesel and renewable diesel were difficult to quantify, EPA noted that the reason for this was largely the lack of peer-reviewed studies and data that focused on biodiesel that control for key factors important in the biodiesel market such as the Biodiesel Tax Credit (BTC) and state incentive programs. In other words, it is unclear whether biodiesel and renewable diesel use increased because of the existence of the RFS or because of other factors, such as the BTC or other state incentive programs.
Now, after getting through all of the science, it’s time to make like a pencil and get to the point. Why should we care? The purpose of the RFS was to drive domestic production and use of biofuels. Since the reiteration of the RFS in 2010, which enacted more “robust” measures to ensure long-term growth, EPA has shown that it is likely that the RFS has potentially served its congressional purpose.
What happens now? EPA has published the draft, but accepted comments on the Report until the beginning of March. Wait, what? I thought this was science! There are many different ways science can be interpreted, particularly in the realm of policy. Allowing the public to comment on the Report may mean that some groups may see holes in the data or be able to provide EPA with missing information. Furthermore, most scientific reports go through a peer-review process so that errors in data can be found and addressed. While submitting the Report for public comment doesn’t entail quite as stringent a process as submitting scientific data for peer-review, it is functionally very similar. Many groups will be looking for holes in data, analysis, as well as conclusions, which may lead to a more accurate final Report.
So what does this mean for the future of the RFS? Hopefully, it means that it will make like a fungi and be given as mushroom to grow as possible….