Biofuels Industry Wants Exemption from Climate Cap and Trade

Date: October 23, 2009

Source: News Room

The biofuels industry is urging Congress to exempt the sector from climate cap-and-trade legislation over fears the fuels could face "double jeopardy" through regulation under both the bill's greenhouse gas (GHG) cap and additional GHG reduction requirements under EPA's renewable fuels standard (RFS). The RFS would require biofuels to prove they emit less GHGs over their lifecycle than conventional petroleum. So far, the House-passed Waxman-Markey climate bill would regulate GHGs from combusted fuel without exempting biofuels that are blended with conventional fuels. Biofuels industry groups and supporters sent a letter (Oct. 1) to Senate Environment & Public Works Committee Chairwoman Barbara Boxer (D-CA) warning that failure to exempt biofuels under a cap-and-trade climate law "would impose a double GHG compliance obligation on biofuels. This regulatory burden could cripple deployment of advanced biofuels, which already face substantial commercialization challenges."

The biofuels industry is also fighting EPA's draft RFS over its accounting for indirect land use impacts of biofuels because some fuels, including corn ethanol and soy biodiesel, would fail to qualify for RFS credit if the land use impact is included. The industry has harshly questioned EPA's modeling methods to assess the land use impacts.

To address these concerns, the industry groups are floating a so-called clarifying amendment to the Waxman-Markey climate bill. Their amendment would exempt the biofuel component of blended fuels from the cap-and-trade provisions and seeks the creation of additional emissions allowances for producers that invest in bio-based products, fuels and process in order to incentivize the industry.

Letter to Barbara Boxer:

October 1, 2009

The Honorable Barbara Boxer
Chair, Senate Committee on Environment and Public Works
112 Hart Senate Office Building
Washington, DC 20510

Chairman Boxer:

We, the agricultural, bioenergy and forestry communities of the United States, are writing to urge you to ensure that comprehensive climate legislation adequately recognizes and incentivizes the extensive benefits biomass and the production of biofuels can provide to address global climate change. Climate change legislation to date has placed much focus on stationary sources of CO2 emissions. The transportation fuel sector is equally important when it comes to CO2 reductions, and biofuels can help play a key role in reducing direct CO2 emissions from the transportation sector.

Biofuels, unlike petroleum-based fuels, recycle atmospheric carbon. Fossil energy use takes carbon that has been stored for millions of years in the earth and releases it into the atmosphere through combustion. Biofuels made from plant matter, on the other hand, remove carbon from the atmosphere through photosynthesis prior to combustion. In some cases, biomass production can sequester more carbon in the soil than is released into the atmosphere. Biofuels should therefore not be treated in the same manner as fossil fuels under any climate change cap and trade legislation. Rather, biofuels should be recognized for their unique role in helping attain a low carbon future.

H.R. 2454 appropriately recognizes biofuels' role in mitigating climate change by limiting the obligation of transportation fuel tailpipe emissions to petroleum-based fuels - though the bill does leave some ambiguity as to whether the biofuels component of fuel blends is obligated. Some recent reports suggest that you may be considering also placing emissions from combustion of biofuels under the cap. We urge you not to pursue this approach.

Biofuels are mandated by the federal Renewable Fuel Standard (RFS) to achieve substantial lifecycle greenhouse gas (GHG) improvement compared to petroleum-based fuels. The GHG performance standards contained in the RFS ensure the climate benefit of future biofuels production. Any effort to place tailpipe emissions of biofuels under the CO2 cap would therefore impose a double GHG compliance obligation on biofuels. This regulatory burden could cripple deployment of advanced biofuels, which already face substantial commercialization challenges. It could also result in protracted regulatory implementation, which will only further delay the commercialization of the low carbon biofuels technologies needed to achieve the greatest GHG reductions in the transportation sector.

To achieve necessary greenhouse gas reductions, our economy must transition to cleaner and sustainable energy resources, and Congress can help. We request that the Senate bill not subject biofuels to double jeopardy in GHG regulation. Instead, your legislation should clearly and unambiguously state that biofuels, including the biofuel component of fuel blends, are not obligated under the emissions cap and are therefore a preferred alternative to fossil carbon-based fuels. We also request that you consider allocating bonus allowances and/or credits to advanced biofuels development programs, and to biofuels that are deemed carbon negative on a lifecycle basis, to incentivize and reward the additional climate benefits that these technologies would provide.

We are concerned that without adequate distinction, advanced biofuels will inadvertently be treated the same as their high-CO2 emitting fossil energy counterparts, removing the incentive for fuel blenders to adopt low-carbon biomass-based fuels. We cannot achieve a low carbon future without advanced biofuels and other biobased products. We strongly urge you to value the vital contribution that these solutions can make to the nation's climate goals by considering the above recommendations.

Sincerely,

Biotechnology Industry Organization

25x'25

Governors' Biofuels Coalition

Clean Fuels Development Coalition

Growth Energy

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