I received an email yesterday from Richard Plevin over at Berkeley:

I can only conclude from your post on Grist that you didn’t actually read our report. The implications that we are either unaware of the environmental issues surrounding biofuels, or that we dismiss them, are incorrect. Your post does a disservice to those reading it by suggesting this.

I encourage you to read our report.

Likewise, I could conclude that he didn’t read my post since he missed the gist, which was that all biofuels agrofuels being produced today may be as bad or worse than fossil fuels overall, and therefore the value of a system to rate their greenness or lack thereof is questionable. If they are worse than fossil fuels, what would be the point? The authors of the report are counting angels on the head of a pin.

His conclusion that my “post does a disservice to those reading it by suggesting this” is moot because it rests on the following strawman arguments: “…we are either unaware of the environmental issues surrounding biofuels, or that we dismiss them …”

However, he was right about me not reading the report. I was inferring what was in it. So I took up his offer to critique it and read all 71 pages. I hope this critique adds value to the agrofuel debate.

It turned out to be pretty much what I assumed — a biofuel mimic of existing schemes like USDA Organic, LEED, Forest Stewardship, the EPA green vehicle guide, and shade grown coffee certification. For example, the following is a borrowed idea that has landed 0.1 percent of the coffee market for Fair Trade products in the United States:

Using a green biofuels index in one of the implementations identified above would allow producers to differentiate their products and command higher prices by using environmentally superior practices.

All the above programs combined have barely made a measurable dent in the unsustainable juggernaut consuming the planet’s biodiversity and resources. People are going to use wood to build their homes and grow crops to eat, but do we really need to add to the planet’s burden by demanding that it grow fuel for our cars? Do we really “need” biofuels yet, if ever? The existing Prius fleet saves more gas annually than all the ethanol produced in America (2001 data). The first calls for moratoriums and bans are just starting to be heard. We need more research, not government funded industrialization and ratings systems for environmentally destructive fuels.

They are on the right track here:

… without appropriate information, incentives, and rules, the biofuels industry is likely to expand production in environmentally harmful ways. [From my perspective, this is a gross understatement. At present the industry is an environmental disaster that is expanding like a star gone nova].

The most coercive policy alternative is to simply forbid the production of fuel whose environmental index is below a prescribed level [BioD: again, from my perspective all existing biofuel production with the exception of biodiesel from recycled waste products already falls below that prescribed level].

… Where the risks of certain practices are extremely high, for instance in the loss of both tropical rainforest and peat soil carbon in the conversion of palm oil plantations in Indonesia, outright bans may be appropriate.

Coincidentally, they discuss at the end of the report what I would call the fatal flaw of all agrofuels: “leakage.” Some of us would not have read any further if it were at the beginning (the old counting angels on the head of a pin problem). I’ll just hand this over to the authors and hope they are wearing bulletproof shoes:

Leakage occurs when emissions increase in unregulated areas that counteract reductions in a regulated area. For example, under a regime that prohibits biofuels production on deforested land, producers could convert cropland to palm plantations while clearing rainforest to provide more cropland. Bauen, Howes, et al. (2005) recommend disallowing biofuels produced on recently cleared land from a regulated trading regime. However, this is not guaranteed to prevent leakage, as land is fairly fungible: Lands cleared more recently than, say, 10 years ago might be used for export markets where no restrictions apply, while land cleared more than 10 years ago would be used for regulated markets. Note that this can be a problem for domestically produced as well as imported biofuels, most notably if Conservation Reserve Program (CRP) or other grasslands are converted to row crops such as corn and soybeans.

… the displacement of current land uses by biofuel feedstock production can lead to more, or more intense, land use elsewhere, potentially driving a leakage of environmental impacts from the green biofuels production chain to other, unregulated, systems. These leakage effects of biofuels production are difficult to capture, even in the aggregate, as they require economic-agricultural-land use modeling that can isolate the effects of biofuels production from other economic variables. It is then even more difficult to allocate these aggregate effects to individual biofuel producers, as would be required under a green biofuels standard.

Spatial leakage:

Biomass produced in one location creates pressure on agriculture in other locations. Crops that are displaced by biofuels face extensive and intensive pressure elsewhere. These pressures may take the form of increased emissions from fertilizers and pesticides, or they may lead to habitat loss as production expands.

Temporal leakage:

It is difficult to capture all impacts caused by current biomass development because some impacts may be lost in temporal leakage. For example, biofuel producers wishing to avoid being charged the impacts of land clearing need only wait–by growing alternative crops — for a period of time before the biofuel crop is planted.

Eventually, like everyone else, they make the standard plea for government subsidization via one of its many and varied forms (see Note 1). Insisting that the government pick economic and environmental winners for us is a bad idea. Ag and biofuel subsidies aside, the hybrid car subsidies given out by our bumbling government were, as is typical, not only wholly unnecessary but counterproductive, providing fuel for anti-hybrid rhetoric.

The report also has some interesting inconsistencies. For example, they tell us:

… Other biofuels (such as biodiesel) are important, but we have chosen to focus on ethanol … Only current biofuel feedstocks and conversion pathways are discussed in this section.

Cellulosic ethanol refineries are in active development in many parts of the world. Several different processes, including acid hydrolysis, enzymatic hydrolysis, and gasification/fermentation, are in simultaneous development, and it is unclear which will succeed technologically and economically.

Having said that, they then went on to mention biodiesel over twenty times (excluding footnotes) and devised a rating system that includes futuristic rather than “current biofuel feedstocks and conversion pathways.” By acknowledging that “it is unclear which will succeed,” they also inadvertently acknowledge that none of the cellulosic conversion technologies may succeed.

“[C]urrent biofuel feedstocks and conversion pathways” means only those technologies that are presently being used to commercially mass-produce fuel in an economically competitive manner, not economically unproven technologies like bio-butanol, biomass-based Fischer-Tropsch diesel, algae based biodiesel and cellulosic ethanol. However, later in the report you find that the only “fuel conversion pathways” that would receive a gold rating per their scheme are futuristic, economically unproven technologies: cellulosic ethanol using switchgrass, wood, and agricultural wastes (see Note 2).

They have leaped into the future and wrapped a whole green rating scheme around something that does not exist yet, analogous to giving hydrogen fuel cells the gold sticker for being the best way to power electric cars. In addition, it has been pointed out many times on this blog and elsewhere that humanity already burned up its forests once and had to switch to coal. Using forests to make liquid fuels would be a very inefficient use of that wood’s stored energy. It would be far more efficient to displace coal by burning the wood directly (not to say I am promoting that) to generate electric power (URGE2).

The paper sure isn’t another Origin of Species. They pretty much borrow from every idea floating around out there:

Trading, a potentially important element of a green biofuels policy, introduces important flexibility into the market. Trading improves economic efficiency by allowing firms with poor performing assets (such as older, inefficient processing facilities) to compete in the biofuel market by purchasing credits from very green facilities, rather than face closure or very high retrofitting costs. The green facilities, of course, would see an additional revenue stream and might have sufficient incentive to improve their performance even more.

If you suspect that a rating system might be an expensive, complex, ineffective bureaucratic nightmare of entanglement, I’m with you. See Note 3 (bring some toothpicks for your eyelids).


Note 1:

… governments could require that heir agencies (and possibly their contractors) purchase only biofuels with a minimum green index rating. As purchase is a binary action (buy or don’t buy), any index used for this option must be one-dimensional in the end.

Expanding the scope of market intervention beyond government purchases, government could pay direct subsidies at varying levels according to an environmental index, or tax fuels according (most simply) to their net GHG emission. This policy is analogous to the current ethanol subsidy but could be much better targeted and more efficient in diverting the market to better fuels …

Note 2:

On the other hand, biofuels production can also have positive impacts on the environment. Converting row crops to perennial crops such as switchgrass, for example, reduces erosion, water consumption and chemical use while significantly increasing soil carbon.

Ethanol can be made from food crops such as corn and sugarcane; from numerous “cellulosic” feedstocks including purpose-grown poplar, willow, and switchgrass; or from agricultural residues, timber industry waste, and municipal solid waste — all with different environmental impacts.

One reliable study of potential domestic bioenergy production from agriculture and forestry and some of the cellulosic content of municipal solid waste (MSW) found that as much as 1.3 billion tons of cellulosic feedstocks may be technically available annually (Perlack, Wright, et al. 2005). This feedstock could theoretically produce enough biofuel to replace one-third of current gas consumption. While no commercial-scale cellulosic ethanol facilities are currently operating, several demonstration plants are in operation in the United States, Canada, and Europe, and several commercial-scale facilities are now planned.

Biomass systems involving longer-life and larger timber species, such as eucalyptus plantations, can be addressed under standards for plantation forests, such as the Forest Stewardship Council plantation certification (Forest Stewardship Council 2006). And forestry residues from FSCcertified forests can carry the certification level of the forest, as biomass residue harvest would necessarily be regulated under the forest certification.

However, the environmentally responsible use of biomass residues from conventional forests is not well defined at present (Richardson 2005). Forest thinning operations for forest health or fire fuel reduction, commercial thinning operations, commercial logging operations, and the processing of forest products all generate residues–but none of these sources have satisfactory environmental performance or certification systems. This is an outstanding research need.

Note 3:

The cost of measuring and verifying environmental performance will increase the cost of production, and uncertainties about the potential for higher prices for green biofuels can create fundamental impediments to participation by farmers, processors, and biofuel producers that would undermine the entire market, leading to potentially unacceptable market volatility and extreme peak prices. Thus, it is crucial to any measurement and verification process not only that cost and regulatory burden be reasonable, but also that the process be, and be seen as, feasible …

Biofuel producers must source feedstock and must plan, attain, and demonstrate the environmental performance of their facilities; suppliers, brokers, aggregators, and distributors must track and document appropriate data along the entire supply chain.

Enrollment, verification, and enforcement are established principles under many existing certification frameworks. For instance, the National Organic Program (NOP) requires consistent methodology among the 92 independent bodies accredited to certify organic producers.

Forest Stewardship Council’s chain-of-custody system includes a “Mixed” designation, under which producers of wood products may certify their product as partially certified according to the proportion of certified wood input that is used …