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Deal in the House moves climate bill, breaks the RFS

2009-06-24T23:50:08Z

Yesterday, Representatives Waxman and Peterson announced that they have reached a deal that secures Peterson's support for the climate bill. Outlines of the deal are still coming out, but it clearly implements a five year delay in accounting for emissions biofuels related to international indirect land-use change. During the delay, EPA and USDA are to commission a study on ILUC and how to account for it. After the study, ILUC would be part of the RFS enforcement again, but only if EPA and USDA can agree on a methodology. It also puts the USDA in a lead on ag related offsets and seeks input from the Administration on the appropriate roles for EPA and USDA, though Waxman and Paterson appear to have agreed to continue to negotiate on this issue after the House passes the bill to influence a Senate bill and conference. We're also worried that the deal will still be expanded to allow destructive sourcing of biomass from our most sensitive landscapes.

The climate bill is the most significant piece of environmental legislation every voted on by an order of magnitude just in terms of its scope and the amount of money that it will reinvest in lower-carbon technologies. (And all you loyal readers that care about stopping global warming should go to our action page and take action to support the bill.) Chairman Waxman is apparently doing what he feels necessary to move forward with putting the firm limit on carbon pollution this country urgently needs. The shame is that the biofuels industry made the price of progress a denial of science--a move that could lead to more dirty fuels and risks further undermining the public's confidence in biofuels.

NRDC strongly supports the requirement in current law to consider all the impacts of producing biofuels. If biofuels are to become an accepted part of our energy future, Congress should not gag EPA from telling the truth about which biofuels are climate winners and which are losers.

A delay in full lifecycle accounting combined with a weakening in the biomass sourcing safeguards poses a grave risk to forests and wild lands around the world. I wrote about this recently--we need to understand that we cannot add the demand for 36 billion gallon of biofuels to our landscape--a demand equal to our annual average timber harvest for the two decades--without huge costs unless we have serious safeguards.

Agricultural offsets can play an important part in our national climate protection strategy but EPA needs to be provided adequate authority to ensure that the offsets are of equivalent quality to emission reductions from covered emission sources.

In the meantime, it's time to recognize that the real threat to a robust biofuels industry is not a requirement for honest accounting and sustainable sourcing of biomass. The real threat is loss of public support for these programs due to well founded objections to fuels that without good rules of the road, lead to bulldozing of habitats, more water pollution, more smog forming pollution and, without truth in accounting, more global warming pollution too.

Calling on scientists and economists to help protect good science on biofuels

2009-06-23T20:52:42Z

As I've written about over the last few weeks (here and here), our ability to require biofuels to actually be better than oil is under intense attack in the context of the climate bill and also under the budget appropriations process.

The Union of Concerned Scientists is organizing a statement from scientists and economists in support of keeping our lifecycle analysis complete and based in the best science and analysis. In particular, we all need scientists and economists to weigh in in support of keeping emissions from indirect land-use in EPA's analysis and in our implementation of the Renewable Fuel Standard.

Here's the link and here's their message.

UCS is organizing a statement from scientists and economists on behalf indirect land use. If you are a scientist or economist with relevant expertise, please consider signing. If you know others who would be interested, please send this along to them.

I thought you might be interested in signing a national scientists' statement that calls for national biofuels policies to account for biofuel pollution from land use change and other major sources of carbon emissions. Please join in signing today at:https://secure3.convio.net/ucs/site/Advocacy?cmd=display&page=UserAction&id=1759

If state, regional, and national policies track emissions from "seed to tailpipe" they could play a significant role in reducing global warming pollution from transportation fuels and spur a whole new generation of cleaner fuels. But these standards must use the latest peer-reviewed research to account for all major sources of global warming pollution in order to be effective.

Land use change that occurs indirectly as agricultural land expands to accommodate biofuel feedstocks is a major category of biofuel pollution. Increased demand for biofuels pushes up commodity prices, which can induce farmers around the world to convert lands into agriculture. Some industries, however, have suggested that these indirect land use change emissions should be excluded from all biofuels policies. Several leading scientists have joined in an appeal to their colleagues to speak in a unified voice on the urgent need to account for all major sources of emissions from biofuels.

If you go to the URL below you can review the details and sign on:

https://secure3.convio.net/ucs/site/Advocacy?cmd=display&page=UserAction&id=1759

The National Scientists' Statement on Land Use Change and Biofuels is open nationally to Ph.D. professionals at universities and research institutions, who have expertise relevant to the scientific and economic dimensions of climate change or of land use change, including research related to biofuels, agriculture, forestry, and land use patterns.

Will the biofuels industry hang itself in the climate bill?

2009-06-18T20:06:15Z

Last week I wrote about the danger of industry-backed changes to the Waxman-Markey climate bill that could, perversely, incentivize deforestation and increase global warming emissions. Comparing the current bill language to the drastically weaker alternative advocated by Agriculture Committee Chairman Collin Peterson, House leaders face a relatively clear choice between bioenergy done right and bioenergy done wrong.

A Washington Post editorial yesterday reinforces the importance of that choice, arguing that "Congress must ensure that it does not give biomass suppliers incentives to produce a fuel that is barely better -- or that is perhaps worse -- than fossil fuels."

Last week, I told EPA the following at their public hearing on their proposed rule to implement the RFS (here's the full draft of my testimony, which I mostly but not entirely stuck to):

The 21 billion gallons of advanced biofuels demand alone will require an amount of biomass roughly equal to our annual average timber harvest for the past two decades (15.5 billion cubic feet of green wood).

Given current trends in deforestation around the world, the history of forest conversion by our timber industry, and even recent trends in CRP enrollment, it is impossible to imagine adding this much new demand for biomass to our lands and not creating new pressure for conversion of our natural forests and grasslands.

The laws of supply and demand are not laws of physics, but as capitalists, we believe they are the laws that govern our markets. Only your regulation can keep this new demand from having a huge negative impact.(emphasis added)

Now the biofuels industry is pushing to gut both the biomass sourcing safeguards and requirement for full accounting of the GHG emissions from biofuels. This means that while we force American's to buy three and a half times more biofuels than they do today, we'll have no ability to protect our most sensitive forests or wildlife habitat and no ability to know if we're getting something that's actually better than gasoline or diesel. Basically the biofuels industry wants to put the market in overdrive, take the safety railings off and then blind EPA.

If they succeed, the renewable fuel standard should be suspended at least until the situation is fixed. It will be the worst irony if the biofuels industry succeeds in turning the biofuels backlash into its own coffin, but that's what they're pushing Peterson to do.

Deutsche Bank's carbon counter is like watching a car crash in slow-mo

2009-06-18T20:05:47Z

This is morbidly fascinating to watch. Deutsche Bank has launched a carbon counter. I'm sure there are others out there, but FWIW, they claim their's is the first scientifically valid one.

Just in the time between when they took the screen shot below to advertise it, the count has gone up over 100,000,000 metric tons. It's like watching a car crash in slow motion, but we're in the car!

They also have a desktop widget so you can watch in dismay all through the day. Hopefully it will kick a few more of us in the pants and spurs us to action.

Bioenergy in the balance in the climate bill debate

2009-06-09T23:02:46Z

As often as deforestation is decried as a driver of global climate change, it’s hard to believe that anyone would propose more deforestation as part of a climate bill. But that’s what is about to happen in the House of Representatives as the Agriculture Committee takes a whack at the Waxman-Markey climate bill. Part of what’s at stake is what type of bioenergy--including transportation biofuels and electricity-producing biomass--the government supports.

The Waxman-Markey bill, in its current version, does something very important. It includes a set of biomass safeguards to ensure the federal government does not incentivize deforestation, destruction of protected federal forest lands, and increased global warming from biomass. Furthermore, it doesn't mess with the carefully constructed GHG standards established as part of the renewable fuel standard. (For more the safeguards and standards, see this factsheet.)

That’s important because the bill also creates a huge new demand for biomass to burn for electricity through its renewable electricity standard, or RES. And this is on top of the existing mandate for biomass based fuels--the renewable fuel standard (RFS). I estimate that these two policies combined with the price signal created by the cap itself could lead to a biomass demand equal to nearly twice our average annual timber harvest for the past two decades (15.5 billion cubic feet of green wood).

Absent biomass safeguards and the GHG standards, it is impossible to imagine that amount of additional demand would not drive deforestation, push destructive projects forward on federal lands, and contribute to global warming. The biomass safeguards and standards are an important balance to ensure the RES and RFS do what they're is supposed to do: fight global warming and provide truly renewable energy.

But now, thanks to influence from the timber industry and Big Ag, a fight is brewing.

Some members of Congress, led by Agriculture Committee Chair Collin Peterson, are trying to push policies that would weaken the bill’s forest safeguards and ignore the carbon pollution from destroying forests.

Peterson proposes to gut the Waxman-Markey biomass safeguards, opening areas that have been protected - including National Forest roadless areas, wilderness areas, National Monuments, and other protected federal lands - to biomass production. He also wants to weaken GHG standards for transportation biofuels that Congress already passed, back in 2007, requiring that biofuels prove they are better than fossil fuels when it comes to carbon emissions from all steps of fuel production and use.

If timber and agriculture interests and their congressional allies are successful in weakening the safeguards designed to ensure that we don’t burn irreplaceable forests for energy, the consequences for America’s federal forests will be disastrous and we will not achieve our pollution reduction goals. Combined the RES, RFS, and price signal of the cap itself could lead to GHG from biomass that would reduce the Waxman-Markey goal of a 17% reduction in emissions by as much as 6%.

Unfortunately, as House leaders strive to unify members and pass a landmark climate bill, these members’ voices are stronger than ever. But without safeguards and GHG standards, we will be unable to tell if our bioenergy policies are doing more harm than good. We could easily end up wining the climate fight only to have to start trying to put an end to newly blind bioenergy mandates and incentives.

EPA releases RFS2 proposed rule for public comment

2009-05-05T16:35:21Z

At a "press availability" today EPA Administrator Lisa Jackson released the agency's proposed rule (EPA factsheet) to implement the new renewable fuel standard, which requires the first ever federal lifecycle greenhouse gas performance standard (EPA factsheet) for biofuels. Put more plainly, EPA took the second step (Congress having taken the first in passing the law) towards requiring biofuels to actually be better than gasoline. This is a critical step towards getting biofuels right.

Here's what I said in a press statement we released today:

EPA has taken an important step towards getting biofuels right. Our economy and our planet can’t afford to burn any type of fuel that will only create more pollution, but through innovation we can develop renewable fuels that are better than oil and will never run out.

It is imperative that we develop biofuels the smart way, and we are encouraged that EPA Administrator Jackson has offered a science-based proposal to get this done. If we get the rules of the road right through policies such as this one, we can harness the ingenuity of America’s farmers, foresters, and entrepreneurs to create a new generation of biofuels that will help create jobs end our dependence on oil.

The opportunity to review EPA’s proposal will help ensure that biofuels don't mean using our most fragile forests for fuel and that biofuels provide real benefits. We plan to submit comments on what EPA has gotten right and what must be improved to make sure the outcome serves our environmental and energy needs.

As my statement make clear, NRDC looks forward to reviewing the proposed rule (here's actual proposed rule--1000+ pages--and here's regulatory impact analysis--850+ pages--both large PDFs) in detail and submitting comments on the parts that we think EPA has gotten right and those that we think need improvement. For instance based on an cursory initial review, it looks like EPA has done a good job on the scope of emissions—direct and indirect—that they have included. However, we have some initial concerns on how EPA appears to have accounted for those emissions over time.

EPA has also committed to a peer review process for their lifecycle emissions modeling. We believe that this is appropriate for such complex and cutting-edge science. We look forward to seeing the results from that process.

The Administrator made the announcement along with Secretaries Chu and Vilsack from DOE and USDA respectively. The three agency heads also announced a coordinated effort to encourage the development and deployment of advanced biofuels and to get more environmental benefits from biofuels in general. I understand that about ~~$2billion~~ $786 million dollars may have been put on the table by DOE for this and that Secrtary Vilsack promised to full fund biofuels related farm bill programs. This Reuters article provides some detail on a presidential memo establishing this coordinated effort. As I've written before NRDC has been calling for a strong focus of government support to advanced biofuels and to launching them in the best possible way.

EPA can move ahead with proposed RFS2 rule

2009-04-30T22:27:30Z

Thanks to the sharp eyes and quick reporting of Ben Geman at Greenwire (subscription required), we now know that OMB has finally released EPA's proposed RFS2 rule back to EPA. This means that once EPA addresses OMB's comments and the Administrator signs the proposed rule, it can go out for public comment. So an NPRM maybe middle of next week?

My understanding is that EPA's rule is intact complete with their proposed approach to measuring land-use emissions. As I've written about before, EPA came under intense pressure from factions of the biofuels industry during the OMB review process to gut or jettison the land-use emissions accounting.

Apparently, Administrator Lisa Jackson was unyielding in her commitment to proposing a complete rule and her support of all the hard work of her staff. What a difference and election makes, eh?

NRDC runs biofuels ads: if we're going to use them, let's do it right

2009-04-28T17:54:47Z

Starting today, we're running a series of print and internet ads trying to sharpen the distinction between biofuels done right and biofuels done wrong.

The animated web versions of the ads are running on the front page of Politico.com today. Check'em out! They'll also be in the Congressional Daily am print version today, the Congressional Quarterly Today print version on 4/29, and Politico print version on 4/29.

The ads direct people to our biofuels page on NRDC's web site. This page in turn encourages folks to take action to help get biofuels right and to check out our more detailed discussion of the potential and challenges for bioenergy on our new renewables section of the website, which I wrote about yesterday.

Why now? Because the debate about what kind of energy and environmental future we will have is happening now. Between the rules to implement the RFS2, implementation of the stimulus package, and the broader debate about climate policy, right now our country is deciding whether advanced biofuels will help us build green jobs, a stronger economy and a safer economy or divert investment to fuels that do more harm than good.

Check it out: new NRDC renewables site (with maps!)

2009-04-27T11:02:01Z

Today, NRDC is launching a new feature on our website (http://www.nrdc.org/renewables/) and I’d like to know what folks think of it. This new tool is designed to help regular people from farmers to politicians, financiers to reporters understand that renewables are here now and posed to become major players in our energy mix. This site will help you determine whether renewable energy systems such as wind turbines, anaerobic digesters, solar installations and biomass energy facilities make sense for you or your community, and to help you understand how legislation being debated right now could help you adopt one.

Of course, the resources available to you depend on your site specifications. That’s why the central feature of the new site is a mapping application. You can find your county on the appropriate map; select the different map layers to see current renewable energy sites and resource potential; and then read about the latest technologies to see which mix of energy opportunities might work for you and your community.

And if you live in Florida, Ohio, Nebraska, Pennsylvania, or Tennessee, you can get even more detail about what’s going on with renewables in your state. We’ve started with these five states because we had to start somewhere and these states are key battlegrounds in the debate about what sort of action our country should take to stop global warming. By being able to see actual projects and renewable resource potential in each state, we hope everyone—and especially the folks in these states—will realize that renewables and other solutions to global warming are not something that someone else somewhere else will be worrying about but really opportunities for all of us often right in our own backyards.

Now, more than ever, America needs the ingenuity and resilience of our farmers, builders, engineers and business people to meet the growing energy challenges shaped by the issues of global warming, national security and domestic job loss. Climate change threatens all of us with more unpredictable weather, stronger storms, more pests and diseases, and longer and more intense droughts. Reliance on foreign oil also puts us at the mercy of political affairs and currency exchange rates.

Fortunately, local action can make a difference. Each technology featured here can contribute to better air quality, reduce our reliance on fossil fuels, add good jobs to the economy and protect environmental values such as habitat and water quality. When these technologies are combined to use the by-products of one system as the input for another, the economic and environmental benefits are even greater. Across the country, we are poised to tackle these problems and reap the myriad benefits of homegrown power generation: clean energy can bring jobs back to America, enhance our national security, promote conservation practices and reduce harmful pollution. Working together, farmers, investors and policymakers can forge these connections to help build a sustainable future for America and the planet Earth as a whole.

This site was designed to show the enormous potential for new energy systems that reduce global warming emissions, protect critical environmental values and move the United States toward energy security. Please check it out. Poke around. Try the maps. And let me know if you think it’s cool or helpful or maybe even inspiring. And then check back in regularly. We’re going to be adding details on more states, more technologies, and more of the critical policies need to stop global warming and build our supply of clean, home-grown renewable energy.

More calls for EPA and OMB to put RFS rule out for public comment

2009-04-20T21:38:58Z

The pressure has been building on the Obama administration to release for public comment EPA's draft rule implementing the renewable fuel standard. EPA has had the draft ready since last October. Delay under the Bush administration was probably a good thing. Delay now simply threatens the EPA's ability to proceed with the renewable fuel standard at all.

While some have been putting behind-the-scenes pressure on OMB and EPA to drop land-use emissions from the critical lifecycle GHG standard in their draft rule, I wrote a few weeks ago about how enviros were calling for the administration to move ahead with the public comment period so the issues can be debated out in the open.

Over the last two week, three leaders in the House sent a similar letter and as did all (virtually all?) of the members of the Senate Environment and Public Works. NRDC and the Renewable Fuels Association even joined up to send a letter. If NRDC and RFA agree that the rule should be put out for public comment, it really make me wonder what the hold-up is.

On a tangentially related note, a good friend, who is one of the smarter people I know, recently addressed a few key issues related to the debate about GHG emissions from land-use change and biofuels. We were emailing about claims that if the US can simply maintain current export levels then biofuels won't have any impact on international land use. As usual for him, it is concise and insightful:

As to export level questions, when people bring up national export statistics, and suggest the [land-use change] effect stops at our border, they are implicitly changing the subject to answer an irrelevant question. If crop prices are affected by the level of crop use for fuel production -- and they most certainly are -- then so long as we have a world market for crops, farmers overseas will react to price changes.

The question of whether the US has capacity to make X billion gallons of biofuel without changing exports, or whether it is fair to "blame" US farmers for something that happens elsewhere are all besides the point.

The GHG accounting is not about fairness, or US export levels, it is just about overall GHG emissions. Congress might decide that a particular policy was an unjust or ineffective means to lower GHGs, but fudging the accounting will not solve the problem. If Congress wants corn ethanol regardless of the GHGs, it has the power to pass such laws (and it has through the grandfathering of corn in the RFS). But we need to protect the ability to measure the results of policies aimed at reducing GHG emissions, because without we will be operating in the dark.

To understand the GHG impacts of using biofuels we need to compare scenarios with different levels of biofuel use and look at the land use differences at the same point in the future. Yield's will increase with or without biofuel production, but regardless of yield increases, if a certain level of biofuels can be grown domestically, then a lower level would require less land. The extra land freed up would reduce pressure for land use conversion in the US and through price signals around the world. In the extreme case where land use conversion has fallen to zero, a lower level of biofuel would free up land for aforestation (intentional, by enrolling in CRP or by abandonment) [...] but we don't live in a world with zero land conversion, so that is hypothetical. The point is that in any of these cases the changes in land use associated with higher fuel use are likely to increase GHG emissions, and the ILUC calcs are a way to measure that.

LCFS is a critical climate policy

2009-04-06T13:22:24Z

On Friday, Kate Galbraith over at the NY Times wrote a blog post on a new study purporting to show that a low carbon fuel standard (LCFS) "cannot be efficient." Unfortunately, the authors missed the critical context for an LCFS, which is an economy wide carbon cap, and one has to read through some of the comments on Kate's post to get that. The full picture considered, the new article at best serves as a cautionary note on what could happen if we screw up our carbon cap and LCFS implementation.

As I see it, the study's three main points are: a) an LCFS alone will not necessarily drive down the transportation sector's GHG emissions; b) if the lifecycle GHG accounting is done wrong, it could actively drive up GHG emissions; and c) the GHG emissions reductions achieved under an LCFS may be expensive on a $/ton basis.

As the first comment on Kate's blog points out, the LCFS is not being done on its own but rather in the context of an economy wide carbon cap, where the GHG emissions from fuels are under the cap. This is critical for two reasons. First, it means that GHG emissions cannot go up if people simply drive more with low-carbon fuels then they do with high carbon fuels. California, which is implementing a LCFS as part of its state economy wide policy (AB 32), is setting a requirement of a 10% reduction in the average carbon intensity of transportation fuels. (See here for the latest testimony of NRDC's Roland Hwang on the CA LCFS.) So in theory if driver drove more the 10% more because of some sort of price shift caused by a LCFS, the transportation sector emissions would still go up. However, since emissions from the state's economy are capped, the total emissions will still go down. Of course CA is also moving to aggressively reduce transportation sector emissions by improving the GHG performance of vehicles and encouraging smart growth. And the same basic combined approach is envisions by USCAP, by the Climate Stewardship Act considered last year, and by the Waxman-Markey climate bill introduced last week.

Of course, a LCFS could still drive up GHG emissions if we implement it with incorrect lifecycle GHG accounting. In other words, if we set up the rule to encourage fuels that appear to have lower emissions when in actuality those fuels are responsible for more pollution. This might seem like a no-duh point, but its part of the reason that NRDC and many others have been working so hard to get the lifecycle GHG accounting right in CA and at EPA in the RFS rule. (Here's testimony that I gave last week at a hearing on the RFS before Sen. Carper's EPW subcommittee.) Getting these rules to include emissions from indirect land-use change is particularly important because emissions from ag and forestry are unlikely to be included under a domestic carbon cap or under international climate agreements for many years to come. This means that an economy-wide cap will not be able to act as a backstop to the LCFS. In other words, an LCFS with an inadequate accounting for emissions from indirect-land-use change could lead to "leakage" of emission from the regulated sectors of the economy to the unregulated sources of land-use emissions. But the bottom line is that CARB, EPA, the Northeast states and all the federal bills proposing a federal LCFS clearly intend to avoid this leakage by including emissions from land-use change.

So as part of the package of policies in which an LCFS is being pursued and the way that the lifecycle GHG emissions are currently being implemented, the policy will almost certainly drive down GHG emissions and cannot drive them up.

This leaves the cost issue, which is actually one of the main reasons to do a LCFS along with an economy-wide carbon cap. Low-carbon fuels are expensive to bring into the market and they take a long time to deploy given the very significant capital inertia we have as a result of all our vehicle and fueling infrastructure. In fact, if the only price signal the market sees is that of a carbon cap, it is highly unlikely that these fuels will be developed and deployed in a timely manner. More likely, we would run through our cheap and fast carbon reductions and then face very high carbon prices around say 2030 as we try to force the economy to change quickly. And who knows if we'll have the political backbone to stick with climate policies if we try to rely on carbon prices alone. I have likened this to approaching a stop light in a speeding car--apply the breaks soon enough you can come to a gradual halt, wait until the last minute to slam on the breaks and you're likely to go through the windshield. As Jeremy Martin from UCS points out in his thoughtful comment on Kate's post, a LCFS is explicitly a tool to get low-carbon fuels developed and deployed in a sustained, orderly manner so that their costs and carbon reduction costs more generally never have to spike.

(A renewable electric standard fits into the same category of complementary climate policies needed to sustain a supply of readily affordable carbon reduction. Check out NRDC's CAP2.0 initiative to learn more about these types of complementary policies.)

Enviros to EPA: move forward with biofuels GHG standard

2009-03-18T21:22:43Z

Today a group of 10 environmental organizations sent a letter to EPA Administrator Lisa Jackson urging her to put a proposed rule establishing GHG standards for biofuels out for public comment. The rule, which are part of the Renewable Fuel Standard, was supposed to be implemented by the end of 2008 has been delayed by OMB. At issue is how EPA proposes to measure the lifecycle GHG emissions from biofuels and specifically how the agency will include emissions from changes in land-use caused by some sources of biomass.

It's hard to underestimate the importance of this issue. At stake is our ability to move forward with any long-term biofuels mandates or market-based policies, such as CA's low-carbon fuel standard. If we intentionally blind ourselves to the full GHG impacts of different biofuel technologies, then we can't tell if we're fighting climate change or making it worse.

Here is a letter from a number of ag state Senators calling on EPA to effectively gut the GHG standard.

And here's the basics on this complicated topic:

Biofuels produced from biomass grown on productive lands compete with other uses of land. As forests and grasslands are cleared to meet the increased demand for land, the carbon stored there is released. Adding these emissions makes some biofuels responsible for more global warming pollution than gasoline or diesel. Fortunately, not all sources of biomass increase the demand for land; some are a byproduct of current practices and others can come from the integration of biomass and food production.

EPA is developing the rules for the Renewable Fuel Standard and CARB is developing the rules for the Low-Carbon Fuel Standard. In different ways, both policies are explicitly intended to encourage the use of biofuels as part of the solution to global warming. As part of this these regulators are developing tools to make sure that the biofuels that benefits from these policies actually produce reductions in greenhouse gas emissions.

In order to develop a full lifecycle accounting protocol that includes emissions from indirect land-use change, both regulators are relying on economic models. They use these models to look at the world first without the biofuels and then with them; the change in pollution is assigned to the biofuels. While the models are complex, both agencies have relied on the best peer-reviewed science and economics and will update their rules regularly overtime.

CA has benefited from a transparent and science-based rulemaking, and the CARB staff has proposed a final rule for the Low-Carbon Fuel Standard. CARB should adopt it without delay at the April board meeting.

EPA has developed a proposed rule and a long list of alternatives, but unfortunately the proposal is stuck at the Office of Management and Budget. The public comment period on a proposed rule as complicated as this is a critical part of ensuring a transparent and science-based final rule, and EPA should release its proposal for comment as soon as possible.

Salazar sez good things about Cape Wind, still needs to act

2009-03-10T17:15:19Z

According to this AP story from yesterday, Interior Secretary Salazar said that the Cape Wind project "makes sense." That's good news, but Secretary Salazar still needs to issue the record of decision for the project and give it a lease. In the AP interview, the Secretary also says:

The scientists tell me that when you look at the wind energy potential off the Atlantic it may be greater than we have onshore. But what we don't have in place at this point is the rules to move forward with energy offshore.

That's because the Bush administration sat on draft rules for ages. So finalizing the "Alternative Energy-Related Use" (AERU) rules quickly is another think the Secretary has to do.

NRDC, the Conservation Law Foundation and the Union of Concern Scientists made these points in this letter delivered to the Secretary yesterday.

Here's a key paragraph on the Cape Wind project:

Although we believe that the Final Environmental Impact Statement (FEIS) for Cape Wind, released by Minerals Management Service (MMS) on January 16, 2009,understates the considerable clean energy and climate benefits of the Project, it nonetheless reasonably reflects that the environmental benefits of the Cape Wind project will far outweigh the impacts. The FEIS provides a solid foundation on which MMS should move forward to issue a favorable Record of Decision (ROD) and grant Cape Wind a lease to construct and operate a 130-turbine wind energy facility on the OCS. We strongly urge that the Record of Decision also include reasonable monitoring, mitigation and adaptive management protocols (including those recommended in the FEIS), in order that the Project achieves clean energy benefits while ensuring the necessary ocean protection.

Here's a key paragraph on the AERU rules:

While the Bush Administration finally, and belatedly, released draft AERU regulations in 2008, those draft rules contained some fundamental flaws that should be corrected before the final rules are released. We recommend that the controversial alternative uses section of the regulations be put on hold while the renewable energy development section proceeds ahead swiftly. We further recommend the renewable energy regulations address key concerns reflected in the public record, including: (1) the inequitable proposed requirement for renewable energy projects to fund their environmental reviews, in a departure from longstanding practice with respect to oil and gas projects on the OCS; (2) the need to more meaningfully address adaptive management, including by establishing best practices for handling any unanticipated project impacts; and (3) the need to ensure adequate environmental review at all project stages.

Daniel Sperling on the Daily Show

2009-02-12T19:24:59Z

Watch it! It's funny. And it's about low-carbon transportation. Dan's a great guy and I love it when people and issues I care about are on the Daily Show. (Remember the Cape Wind piece?)

RES and cap and trade - better together

2009-02-11T20:52:37Z

Yesterday, the Senate Energy and Natural Resources Committee held a hearing on a federal renewable electric standard [webcast available here]. Predictably there was some moaning and misinformation that it would too expensive or hard, which Chairman Bingaman correctly labeled "a tyranny of low expectations." I also think the emphasis on energy efficiency and renewable energy in the economic recovery bill shows that legislators are finally getting the idea that these are sources of economic growth. (See this blog post by my colleague, Cai, about a critical renewable energy policy that's still being debated as part of the recovery bill.)

More intriguing was the push back from the ranking minority member Senator Murkowski, who according to this E&E article (subscription required) argued that we should prioritize a climate bill over a RES. "We need to ask ourselves what we are trying to achieve with this program," she said. "Is our aim simply to increase renewable energy production? Or is the goal to reduce greenhouse gas emissions?"

Now an uncharitable read of this might be that the Senator is using the climate argument simply to oppose the RES. A slightly more charitable read would be that she wants a climate bill instead of an RES. However, I'd like to believe that she was making the case that we need both an RES and a climate bill done together and done as fast as possible.

As I discussed yesterday on Public Radio's Marketplace, an RES is a critical part of our renewable energy policy, but as discussed in this NRDC policy brief, an RES is also a critical part of keeping the cost of a carbon cap and trade policy reasonable. Some, like the author of this Business Week article, mistakenly believe that under a carbon cap renewables don't provide any GHG benefits. While it's true that renewables will not reduce the cap, they are necessary to achieve the cap and to protect it from a political backlash that would accompany excessively high prices.

Our cap and trade policy needs a package of "companion" policies that ensure a steady flow of innovation and deployment of low-cost low-carbon technologies. That's why we need to do an RES and a carbon cap and trade bill together.