Why Wait Until 2016 to Reform the RFS?
Reform of the RFS is already long overdue. Since 2007, when Congress and President George W. Bush significantly expanded the RFS by requiring Americans to use 36 billion gallons of biofuel per year by 2022, the Clean Air Task Force (CATF) and other organizations have analyzed the policy’s negative impacts on climate change, global food security, habitat preservation, and water quality. Two major problems stood out almost from the very start. First, the RFS would soak the country in environmentally damaging corn ethanol. Second, the legislation was ill suited to push the development of transportation fuels that can meaningfully reduce greenhouse gas emissions. By the time the Environmental Protection Agency began its pothole-filled effort to implement the expanded RFS, it had become obvious the law was a lemon.
The RFS is better at generating problems than it is at delivering solutions. The program’s main achievement to date—shepherding an enormous scale-up in corn ethanol consumption—has pushed up food prices in the US and around the world and increased GHG emissions, air pollution, water pollution, and habitat destruction. While Congress had good intentions to reduce global climate change with passage of the RFS, the vast majority of fuel produced and consumed in accordance with the program has had the opposite effect. Analyses by EPA and the National Research Council showed that corn ethanol made between 2010 and 2015—in other words, nearly 90% of total biofuel production to date under the RFS—does not achieve the minimum 20% GHG emissions reduction required by Congress in 2007. Worse, CATF’s review of the EPA data found that US corn ethanol production is actually increasing, not decreasing, GHG emissions. Using 40% of the US corn crop for fuel has also led to record corn and food prices in recent years, record corn plantings, and resulting impacts on other commodity crop markets and land use change in both the United States and other countries as more land must be brought into production to grow displaced food.
Meanwhile, the RFS has failed to jumpstart the production of cellulosic biofuels produced from environmentally beneficial feedstocks that do not compete with food markets, such as agricultural residues. It’s been clear for some time now that the policy’s ambitious (read: wildly unrealistic) annual consumption targets are not, in themselves, enough to overcome the various economic, logistical, and technological challenges that are delaying the development of advanced, climate-friendly biofuels. Not coincidentally, the president of the Advanced Biofuels Association just announced that the trade organization would support reform efforts because “[t]he Renewable Fuels Standard—the very tool that was created to foster our industry—has become one of the greatest obstacles to continued development of the advanced and cellulosic biofuel industry….”
Confronted with these problems, EPA and members of Congress have proposed scaling back not only the corn ethanol mandate but also the overall RFS mandate. CATF supported EPA’s fall 2013 proposal, which the Agency has yet to finalize. In addition, CATF has opposed the classification of biobutanol made from corn kernels as an “advanced” biofuel, which would only further exacerbate competition between food and fuel markets and increase GHG emissions as native grassland, wetlands, pasture, and other carbon-rich land is converted to additional corn production.
Long-overdue reforms are needed in order to reduce the threats that the RFS poses to climate and the broader environment. Since the RFS was expanded in 2007, we’ve watched corn ethanol production march upward, almost in spite of the environmental damage it wreaks, the historic drought in 2012, and the diminishing capacity of the US gasoline market to accommodate more ethanol. We’ve watched as the development of cellulosic biofuel and other types of potentially climate-beneficial transportation fuel has languished. In the face of these failures, we hardly need a presidential election to tell us it’s time to go back to the drawing board on biofuels.
