The Disconnect Between EPA's Proposed Rule and the Rest of the Administration's Transportation Strategy

In this episode, Dan Lashof of the World Resources Institute discusses the trajectory of biofuels since the early 2000s and the implications of new biofuel standards recently proposed by the US EPA.

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David Roberts

My fellow olds will recall that, back in the 2000s, biofuels were an extremely big deal in the clean-energy world, one of a tiny handful of decarbonization solutions that seemed viable. Biofuels — and the many advanced versions thereof allegedly on the horizon — dominated discussions of climate change policy.

Much has changed since then. Principally, it has become clear that electrification is the cheapest path to decarbonization for most sectors, including the transportation sector. The Biden administration has explicitly put electrification at the center of its transportation decarbonization strategy.

Biofuels, in the meantime, have gone exactly nowhere. Advanced biofuels remain almost entirely notional, old-fashioned corn ethanol remains as wasteful as ever, and new scientific evidence suggests that the carbon costs of biofuels are much larger than previously appreciated.

It's not clear if anyone has told the EPA. For the first time in 15 years, the agency is on the verge of updating biofuels production mandates first established by the Energy Independence and Security Act of 2007, and its proposed standards do not appear cognizant of these recent developments, or of the administration's larger transportation strategy.

To discuss the latest developments in biofuels and the EPA's puzzling blind spot, I talked to Dan Lashof, director of the World Resources Institute. We discussed how biofuels have developed since the early 2000s, the lack of progress in advanced biofuels, and the stakes of EPA's coming decisions.

Alright then. Dan Lashof. Welcome to Volts. Thank you so much for coming.

Dan Lashof

Really happy to be here.

David Roberts

I've been wanting to do an episode on biofuels forever because I often just pause to think, whatever happened to biofuels? Because old people like you and I will recall way back in the day, in the early times, biofuels used to be a very big deal. They used to be the top line item, the sort of the hot subject of conversation, and it's really flipped since then. So maybe just to start, let's use our little time machine squiggly squiggly fingers, time machine, go back to say 2005 to 2010, the early 2000s, and just sort of tell us what was the state of the decarbonization conversation then and what role did biofuels play in it?

Dan Lashof

Right, well, back then, Tesla hadn't built its first car. Photovoltaics cost ten times or more what they do today. And the big fight was to prevent hundreds of new coal plants from being built. So the idea that we would replace gasoline with electricity seemed far-fetched at best. And a lot of environmental advocates were focused on fighting coal. There was some discussion of alternative fuels, but when you looked at the transportation sector, biofuels seemed like one of the best options out there. And then there was this idea, there was a debate about corn ethanol from the beginning, right?

David Roberts

Corn ethanol goes back. I mean, I kind of want to distinguish between corn ethanol and kind of biofuels. The larger category, like corn ethanol, goes back farther than the rest of this stuff. Right?

Dan Lashof

Right, but back then we weren't making much of it, right? So in 2007, there was about 6 billion gallons of corn ethanol being produced, which is about 4% of gasoline consumption back then. And there was a debate about it. A lot of that debate was like about net energy balance. Remember that one?

Does it take more energy and fertilizer and tractor fuel and trucking than is in the fuel? I think that debate sort of missed the point, and it was gradually shifting to, well, we don't really care about BTUs, we care about carbon and what's its net carbon impact.

David Roberts

And I feel like the limitations of corn ethanol were around even then, which is why I remember so much buzz around cellulosic biofuels.

Dan Lashof

Yeah, right. At that time, there was new research that seemed very exciting. I was convinced that that was the future of biofuels. Right. We were going to make ethanol not from grain, not from the corn kernels, but from corn stalks, maybe from some perennial grasses like ...

David Roberts

Switchgrass.

Dan Lashof

Yeah, right. And that was going to be awesome because you wouldn't be competing with food as much, and it was supposed to be cheaper because you weren't ... as waste material or the yields were higher. So that was going to take over.

David Roberts

Yeah. Wow. We were so young then. And so then this is the sort of political atmosphere in which came the Energy Independence and Security Act of 2007, which, among its other sort of puzzling features in retrospect, was a big bipartisan energy bill passed in part to address emissions and I guess just wasn't the poison that it is now, I guess. But so part of that bill was about biofuels and setting those standards. So just tell us kind of what we did about biofuels in that bill.

Dan Lashof

To set the stage. The big political driver really was concerned about imported oil, which was peaking. It actually peaked in 2005, but it was about the same level through 2005, '06, '07.

David Roberts

Right. Because this was before the fracking revolution changed all that.

Dan Lashof

Right. And fuel economy standards for automobiles had been stagnant for a long time. So the bill had three main components. One was reform of the fuel economy standards, actually setting them on a size basis, which allowed the auto companies to kind of accept it, and then setting a target to increase them to 35 miles per gallon.

David Roberts

Is that when the light truck loophole made its way into ...

Dan Lashof

No, that was already there. This was actually designed to help address that by saying it did leave trucks and cars separate, but it said, we're going to base the fuel economy for a manufacturer based on the mix of sizes of vehicles they make. So if they make bigger cars, they don't have to hit the same level, but it reduced the sort of clip effect between a truck and a car. So it actually allowed more of these crossovers, but it also allowed unlocking an increase in the standards which had been stuck. So that was a big component. And one of the things that environmentalists were most excited about in that bill, there was also a set of energy efficiency provisions, appliance standards and other things.

And then the third big piece was the Renewable Fuel Standard.

David Roberts

And did the Renewable Fuel Standard exist prior to this or was it developed for this bill.

Dan Lashof

It did exist. I think it was first passed in 2005, but it was relatively modest. And then in the 2007 bill, well, there was this buzz about cellulosic ethanol. The thought was set a long term trajectory of increasing uses of biofuels and make sure that by 2022, most of that was supposed to be cellulosic ethanol.

David Roberts

Right.

Dan Lashof

So the standard ramped up to 36 billion gallons of total biofuels by 2022. That was the target of that 21 billion gallons was supposed to be advanced biofuels, either cellulosic ethanol or other biofuels made from something other than corn.

David Roberts

Right. And this suffice to say did not happen. It did not play out that way. So maybe sort of take us forward from 2007 to what happened to actual production of actual biofuels. Like how has the industry developed in the 15 years since then?

Dan Lashof

Well, so the corn ethanol industry grew as expected up to about 15 billion gallons which was sort of what it was supposed to be capped at subtracting 36 - 21 is 15. So that was what corn ethanol was supposed to provide. Right, they did that. Cellulosic ethanol not so much. The actual gallons of cellulosic ethanol produced in 2022 were zero. Literally zero.

David Roberts

Wait, say that, say again.

Dan Lashof

There was no cellulosic ethanol produced in 2022. There had been a couple of demonstration plants, none of them were actually operating in 2022. There was a little bit of what was considered cellulosic biofuel, about less than a billion gallons of biofuel equivalent. That mostly came from landfill gas, which was considered cellulosic. Because ...

David Roberts

Weird,

Dan Lashof

Most of what's in a landfill is woody stuff that's decaying and making methane. So if you capture that and use it in a CNG vehicle, that's considered part of this.

David Roberts

But the whole infrastructure of wild hopes about switchgrass and waste products and all of this, it came to literally nothing.

Dan Lashof

It came to literally nothing so far. Now, there's still some true believers, it's still right around the corner, kind of like. But the thing that did happen and there's about 5.6 billion gallons of the total biofuel produced in 2022 is something other than corn ethanol.

David Roberts

What is that stuff?

Dan Lashof

Most of that is bio-based diesel and that's a couple of different things. So some of that is from waste oils. So like used cooking oil.

David Roberts

Yes. I remember so much talk about used cooking oil.

Dan Lashof

So there's a little bit of that, but a lot of it is biodiesel or so called renewable diesel made from oil crops like soybeans or palm oil, which is imported and a huge problem or other oil crops.

David Roberts

Now, are those in the renewable fuel standard like or do those have a category of their own in the, in the standards?

Dan Lashof

There is a category of bio-based diesel. It's required to produce a billion gallons in 2022, and it exceeded that. But it also counts as part of this larger advanced biofuel category.

David Roberts

Yeah. You mentioned before the call that in terms of land use, that biodiesel is now rivaling corn ethanol.

Dan Lashof

Yeah, this actually shocked me when I looked into it. So we use about 30 million acres of land to produce corn that goes into making ethanol. We use another 30 million acres of prime US farmland producing soybeans that goes into biodiesel wild. And we hear much less about that, partly because it actually produces much less fuel. It's overall much less efficient.

David Roberts

Oh, the diesel process.

Dan Lashof

Yeah, it takes a lot more land per gallon of diesel than you get per gallon of ethanol because corn is not that great. No, corn is not great, but the biodiesel is even worse. And when you think about the global market for oil crops so palm oil, for example, is a major driver of deforestation around the world.

David Roberts

Right.

Dan Lashof

And that's totally fungible with soybeans and canola and other oil crops. So if we're diverting soybeans to make biodiesel in the US. That means somebody else is probably producing palm oil and may well be deforesting the rainforest to do it.

David Roberts

So the amount that was set for advanced biofuels in 2007 for 2022 just isn't being met. It's not as much biofuel as that legislation anticipated.

Dan Lashof

Yeah, so the law allowed EPA to waive the requirement if it determined that the supply just couldn't meet the number and set a level that they concluded could be met by the industry. And so that's what they've been doing consistently every year for the advanced biofuels requirements.

David Roberts

I guess I knew on some level that things had not panned out the way we hoped in 2007. But the notion that the whole hype about advanced biofuel came to literally nothing and all we basically did is just keep growing corn ethanol and biodiesel like we were before, with all the flaws. I mean, we already knew about the flaws, some of the flaws then. Speaking of the flaws, tell us about what we — insofar as you can I'm sure there's a lot, and it's difficult to summarize — but tell us what we've learned about the environmental and carbon impacts of biofuels that we didn't know when we passed this law in 2007.

Dan Lashof

Well, I'd say there's two main things. First, we know that there's a much better way to eliminate emissions from passenger vehicles. So, like I said, we didn't really believe, at least I didn't really believe, electric cars were going to be a thing back then. Now, that's clearly the way we get rid of emissions from the road. And if you do the calculation, it takes 300 acres devoted to corn ethanol powering an internal combustion engine car to move it as far as one acre of land dedicated to solar photovoltaics, to power an EV 300 to 1. And we can put solar farms in the desert and not just on actual farms.

So it's just like a completely different landscape in terms of what are the pathways.

David Roberts

Yes. And as I point out to people, solar has only gone in one direction and cellulosic biofuel has also only gone in one direction, which is nowhere. At a certain point, you got to learn from trajectories.

Dan Lashof

So that's the first thing. There's a much better way. The second thing is, I think the key conceptual shift is really, and it hasn't been incorporated into policy yet, is that land is scarce. We need to focus on the overall use of land and not just land use change. So the way I think about this is if we want to achieve net zero emissions globally by 2050 and feed 10 billion people and protect biodiversity, how do we optimize the way we use land to do all of that?

David Roberts

Right.

Dan Lashof

And if we dedicate an acre to producing biofuels, we can't use that same acre to have an old growth forest that is storing carbon in the trees and providing biodiversity.

David Roberts

Right. So for any given acre of land, if you use it for one thing, part of the cost is the opportunity cost of not using it for something else that would have absorbed more carbon.

Dan Lashof

Yeah, exactly. And of course, the opportunity cost is a pretty familiar concept in other contexts. Right. We know that if we spend $1,000 on a vacation this summer, we can't invest that money to pay for travel when we retire.

David Roberts

Right.

Dan Lashof

But for some reason, that it hasn't really been built into the way people think about land. I think there's still this notion that there's going to be a lot of spare land out there, we can reclaim land, but when you do the math, it just doesn't add up.

David Roberts

Well, about the math, though, how confident are we that we know and understand all the ins and outs? Do we have a ranking of land uses by carbon absorption? Do we have a clear sense of that ranking?

Dan Lashof

I mean, I think that's a good question. So if you've got a old forest, the best thing to do from both a carbon point of view and a biodiversity point of view is protect it.

David Roberts

Right.

Dan Lashof

Keep the carbon in the trees, keep the birds and bees flying around. And anytime you use land for something other than feeding people, it's going to put more pressure on those remaining old forests. So that's one way to think about it.

David Roberts

Right. Because I'm thinking all these land use arguments, as you well know, are frequently deployed against renewables as well. There's an opportunity cost for food production. There's even some people who say there's an opportunity cost, like whatever, put a nuclear plant, get more power for less area. There are opportunity cost for putting mirrors. So this question of the highest, best use of land from a purely carbon perspective cuts a lot of ways.

Dan Lashof

Yeah, that's true. And we have not really done a full kind of optimization of land use for achieving decarbonization. That's something I'm actually hoping to work on over the next couple of years. I think it's badly needed. There's some work that's been done that points in that direction, but not a fully integrated analysis. But to give one example, yes, there are issues around land use for renewables and certainly legitimate conflicts over how people want to see their community or their landscape look. But NREL did a study of what it would take in terms of land to get to 100% clean electricity grid by 2035, which is the Biden administration goal.

And they looked at the total amount of land that you had to dedicate to wind/solar transmission lines. That amount is smaller than the amount of land we're using for biofuels today. And those biofuels are supplying less than 10% of our transportation energy. So there's no comparison in scale.

David Roberts

Yes. Got it. So even if we don't have perfectly tuned, fine-grained distinctions here, there are plenty of crude distinctions we can make. Some of the cases are obvious, more obvious than others. And so given this new way of seeing biofuels, this sort of opportunity cost of lands carbon opportunity cost, and I assume we probably learned more stuff about biofuels in the interim in terms of the amount of energy in versus out and all this. So how do biofuels look now relative to how we thought about them then? I'm going to guess that based on our new knowledge, they look worse.

But how much worse? Like corn ethanol, for instance.

Dan Lashof

Yeah so ...

David Roberts

Not good. Not good.

Dan Lashof

No, I mean in terms of energy in versus energy out, actually, the ethanol industry has gotten more efficient. If you're ignoring the land problem, it's starting to look, you know, it looks okay. I mean, it doesn't get you to zero by anybody's calculation. But if you ignore the land issue, 30-40% reduction relative to gasoline is plausible. But once you take the carbon opportunity cost of land into account, then anytime you're dedicating an acre to grow fuel rather than either food or forests, you're going to lose. And you're going to lose it's not close it's by factors two, three or more.

David Roberts

That's true of any crop, any kind of fuel across the board.

Dan Lashof

Yeah, just because that opportunity cost is so large.

David Roberts

Interesting. So let's take this knowledge then and gallop here into 2022, I guess we're in 2023 now.

So tell us first of all, why is EPA revisiting these standards? I guess they decided in 2007 that they could see exactly 15 years into the future of biofuel demand, but no further. Was it always built into the law that 15 years, and then we'll start revisiting it.

Dan Lashof

Exactly. So Congress specified exact volume targets for every year through 2022. And again, it gave EPA the ability to adjust those if it concluded it wasn't feasible, which is what they had to do on the advanced biofuel side. But starting in 2023 ...

David Roberts

Wait, can I pause? Before we get into the change in the line, I want to ask one question about the volume thing, because it also strikes me as kind of crazy, like how gasoline performs with ethanol in it. Depends on the level of ethanol in it, right. The percentage of ethanol. And there's been a lot of arguing about how much ethanol you can blend into gasoline. But if you're specifying volumes of biofuel, you can't specify volumes of total gasoline demand that's going to fluctuate out of your control. So if demand goes way up, then the same volume looks like a smaller percentage, and if gasoline demand goes down, then the same volume looks like a larger percentage.

David Roberts

It just seems like specifying volumes is a bizarre way to approach this question, especially 15 years in advance, when you have no idea what total demand for gasoline is going to be. So you really have no idea what percentage of the total these volumes are going to be. Am I crazy, or is that just a weird way to approach this issue?

Dan Lashof

That's correct. What EPA actually does under the law when they set the targets, is they look at the volume target. They project how much gasoline will be consumed, and then the actual requirement on refineries is a percentage. So they convert the volumes into percentage when they implement it. But they've only been doing that sort of one or two years in advance. Or actually, sometimes they get to the end of the year, and then they do it looking backwards, which is a little weird, too. So then in a year like 2021, when the Pandemic shrunk demand for gasoline, it was actually the percentage requirement that was binding, and the volume was much less than what EPA had originally projected.

So that's how they implemented. But it's still a strange way to write the law. I totally agree with that.

David Roberts

The reason I ask is, it seems to me, sitting here in 2023, that the next 15 years of gasoline demand are even more difficult to forecast than they were in 2007. There's more going on. There's more forces converging from different directions. There's a lot of it's a really open question. So if you're specifying a volume, that just seems crazy. Are they doing that again? Are they going the volume direction again?

Dan Lashof

They are, but again, they convert it to percentage, and they're only looking three years. Their current proposal looks three years in advance, not 15 years in advance.

David Roberts

Got it. Okay, well, let's back up. Just tell us what's going to happen. What is EPA doing in 2023 about this? Now that these original volume standards are over, the time period is over, what's EPA going to do?

Dan Lashof

Right. So EPA has this broad discretion now, and so they proposed a rule to set the volume targets for three years, 2023 through 2025. But they basically ignored all these changes that we've just been talking about and sort of blithely went forward as if nothing has changed. And they've proposed to increase the amount of biofuel required each year, not by a huge amount, but by some. And they've said, okay, the amount of conventional corn ethanol that would be implied by these requirements is going to stay constant at about 15 billion gallons. But because of what you said, that's a huge problem.

Right. So if we're actually on a trajectory to meet our climate goals, we've got to electrify the fleet. And that means gasoline consumption over the next 20 years should go down by about 80%, according to at least some scenarios. So the current standard gasoline is blended 10% ethanol, and 15 billion gallons is already more than you can absorb at 10% of current gasoline demand.

David Roberts

Is that true? What happens if there's too much if there's too much corn ethanol and you can't blend it all in? What do they do with it?

Dan Lashof

So some states allow up to 15% ethanol.

David Roberts

Right.

Dan Lashof

And the original theory was we were going to have flex fueled vehicles that would use 85% ethanol.

David Roberts

You still see those around sometimes.

Dan Lashof

Yeah. The auto companies got credit towards meeting their CAFE standards.

David Roberts

Right.

Dan Lashof

Producing those even if they never saw a drop of E85, right. So there are a few of those vehicles around, but they're just using 10% ethanol or maybe 15% ethanol, depending on where they're fueling up. So you can maybe absorb a little bit more than 10%. But basically, by setting the requirement at a level that is more than 10% of gasoline demand, what EPA effectively has done is forced more biodiesel, because that you can substitute for diesel in the freight sector. And as we discussed, that's even worse than corn ethanol.

David Roberts

Well, you mean because they're holding corn ethanol steady and increasing the overall amount of biofuels, and we now know that cellulosic is going to be 0% of that, then all the remainder has to be biodiesel, doesn't it?

Dan Lashof

Most of it will be. I mean, again, there's some what's called renewable natural gas. So if you harvest landfill gas or dairy digesters, you can produce some fuel that way.

David Roberts

But most of the increase will come from biodiesel.

Dan Lashof

Most of the increase is biodiesel. And again, the way the law is written, it doesn't actually specify corn ethanol. It specifies conventional biofuels. So you could use biodiesel to satisfy part of that. Right. Now, this is the so called 10% "blend wall", ethanol "blend wall". That's about 14 billion gallons.

David Roberts

Got it.

Dan Lashof

And it's going down every year.

David Roberts

Wait. why?

Dan Lashof

Well, because gasoline consumption is going down.

David Roberts

Right?

Dan Lashof

And it's already going down because cars are getting more efficient under the fuel economy standards, particularly the ones that the Obama administration promulgated. And as we get more and more electric vehicles on the road, it's going to go down faster.

David Roberts

Given what we've learned about biofuels and given how they performed since 2007, what on earth is EPA doing? I guess I'm just wondering, what are the political forces, as you see them, that are pushing to keep this Frankenstein alive when it basically looks like we should just we'll talk about future uses for biofuels later and there might be something to that. But in terms of shoving corn ethanol into gas tanks, it just seems like the whole enterprise is kind of silly. So what's keeping it alive? What's propping it up? Because EPA looks like they're just, like, going forward, like you said, as if they've learned nothing.

And yet we know they have learned stuff. So what is going on? I guess I'm asking.

Dan Lashof

Well, I think there are a couple of things. Obviously, politically, you have this now incumbent ethanol industry. Companies like ADM that make a lot of money making ethanol, and they're in Midwest states that don't necessarily have a lot of people, but have two senators each.

David Roberts

But are no longer going first in the Democratic primary lineup. I wonder if that's going to change anything.

Dan Lashof

It may make a little bit of difference, but Iowa is not the only state. It's not the only state where ethanol is produced, so they still have a lot of sway. Also, I think that this idea of the carbon opportunity cost of land really has not been absorbed by policymakers at this point. So there's still, in their minds, an active debate about, oh, maybe it's 20% better than gasoline, maybe it's 40% better than gasoline. There's some studies which say that it's a little worse than gasoline, but there hasn't been an acceptance yet of this view of land as fundamentally scarce and something that you really have to be much more intentional about how you use it.

David Roberts

Well, the ethanol lobby is obviously one thing, and of course, corn state senators are, of course, one thing. I think you and I will recall when John McCain was running, what was it like the first time he ran? He was very bravely standing up against ethanol and then just got pilloried and caved on it later, as I recall. Am I making all that up? It's had such a grip on politics.

Dan Lashof

Yeah, that sounds right. And certainly I think both Obama and Clinton who were running in the primaries during the time the 2007 bill was written, were staunch supporters of ethanol. So, yeah, there's been this bipartisan support for it across the board. One notable exception has been Senator Diane Feinstein of California has always rallied against ethanol.

David Roberts

Interesting.

Dan Lashof

But to no effect.

David Roberts

And what about fossil fuel companies? Like, where are they on this whole thing? Where are they throwing their influence?

Dan Lashof

Historically, they opposed ethanol mandate. They were kind of outmaneuvered when the RFS was first done because you had both environmentalists who supported the overall law, whether they focus on the RFS or not because of the fuel economy standards and kind of the farm state senators and representatives supporting it because of the ethanol piece. So that's actually a fight they lost. Now it's a little challenging because both the fossil fuel lobby and the ethanol industry feel threatened by electric vehicles. And so there are cases where they're actually teaming up to fight electrification, which is definitely a toxic mix.

David Roberts

And isn't there some overlap of plastics and biofuels now that the fossil fuel industry might be? Because I know fossil fuel industry has big hopes for plastic to help them survive in a post fuel world. Isn't there some sort of like biofuels made out of plastics? Or am I groping here? What am I talking about?

Dan Lashof

Well, there are ways to make plastic substitutes from biomass. So you see some compostable forks that are made from cornstarch, for example. I don't think a big market compared to the ethanol market. So I don't know that that's a big player. I think from the fossil fuel industry point of view, they definitely are looking at plastics as their get out of jail free card. As oil demand for automobiles goes down, they're looking to divert both natural gas and petroleum into a huge number of new petrochemical plants to produce plastics and other things. So yeah, that's a real issue.

David Roberts

But returning to here to Biden so there was never, I guess, really a road through biofuels to zero carbon. I mean, maybe people waved their hands at it like super-future cellulosic, whatever, but in the 15 years since, we have not progressed down that road, hardly even a single step. And yet here the EPA is sort of acting like, yeah, that's still our thing on transportation. We're still going to labor away at biofuels and try to sort of marginally reduce the impact of gas. Meanwhile, you have over on the other side of the Biden administration, Biden himself the bills he's passed, his own transportation secretary on and on, being very explicit that their transportation strategy is electrification. So why isn't the right hand talking to the left hand here? What is this Janus-faced transportation strategy?

Dan Lashof

Yeah, it's a huge disconnect. I mean, right as EPA was proposing this renewable fuel standard continuation, the administration published a transportation decarbonization strategy which, as you said, absolutely focused on electrifying certainly all the passenger cars for freight. It's some combination of battery trucks and hydrogen fuel cell trucks. The one place they point to biofuels and we can talk about this more is with respect to aviation fuel.

David Roberts

Yeah, I want to get to that. In a second because that seems like a big piece of this. But just in terms of, well, a. why? I guess no one really knows why. I mean, maybe it's just path dependence, maybe it's just lobbying, maybe like EPA is not meeting with Pete Buttigieg enough. But what would you recommend, what would WRI recommend that EPA do in this situation if it had read its own administration's transportation plan? What would renewable fuel standard setting look like in light of sort of sane response to Biden's electrification push?

Dan Lashof

Right. So it's important to point out that right now we have a proposal from EPA. It's not a final rule. And so part of what we're trying to do is point out this disconnect between this proposed rule and the rest of the administration's climate strategy and transportation strategy. So hopefully it'll have an impact. We'll see. So what we recommended is setting much lower volume targets for renewable fuels going forward that are based on the amount of fuel that you can produce from biomass waste. So this is the key distinction that we're trying to make. It's one thing, the carbon opportunity cost, if you're dedicating an acre of land to produce biofuels, is high.

But there are some genuine waste resources and a lot more work needs to be done to figure out how substantial they really are. But they're not 36 billion gallons. But there are certainly significant amounts of things like corn stover, which is what's left over after you harvest the corn. You've got wheat hulls, in orchards you trim them every year, so there's woody biomass there, there's waste in the pulp and paper industry that they currently burn to make electricity, which there's much better ways to make zero carbon electricity. So there's those resources and then there's this huge amount of biomass which is starting to be pulled out of the Western Forest to reduce the risk of catastrophic wildfires.

And what happens to that now is mostly it's either left to decay at the edge of the forest or it's actually burned in a pile.

David Roberts

Either of those produce greenhouse gases, don't they?

Dan Lashof

Right, exactly. Well, you're taking carbon that was in the forest, but that had the risk of going up in flames at any point and turning into CO2. You're kind of speeding up the conversion to CO2, but hopefully reducing the risk of catastrophic fires. You look at what would happen to the biomass if you didn't use it for biofuels. And if the answer is that carbon was going to go back into the atmosphere quickly, that's a biomass resource that it makes sense to use.

David Roberts

So WRI's recommendation is that basically standards be required or volumes be required only for waste biofuels?

Only for volumes that could be produced with waste biofuels. And that essentially the conventional corn ethanol should not be viewed as achieving any greenhouse gas reductions. Now, it's important to say that doesn't mean that the ethanol market is going to disappear overnight.

Yeah. I was going to ask, are you here proposing that we basically abandon both the corn ethanol and the soybean-biodiesel markets? Because I would be all for that, but those are big, powerful players. It's not a small thing to propose abandoning them.

Dan Lashof

Yeah, well, this is definitely not going to be an easy push right. To the administration, for sure. But I think it's really important to lift up farmers in this transition. So if we eliminated the Renewable Fuel Standard overnight, the gasoline suppliers would still probably and according to EPA's analysis, they would still blend 10% ethanol into gasoline because ...

David Roberts

Really? Why?

Dan Lashof

Well, they need it to provide oxygen and octane. So one of the other factors that we haven't talked about that was going on during the early 2000s is gasoline used to contain this thing called MTBE.

David Roberts

Right, I remember.

Dan Lashof

Which was the way in which they got octane, and that created a lot of groundwater contamination. California banned it in 2002, new York banned it in 2004, and other states were moving to ban it. And so the sort of chemical function that MTBE was playing in gasoline got replaced by ethanol.

David Roberts

Got it. So they do need some kind of additive?

Dan Lashof

Yeah, there may be other things out there, but I think for now the expectation is they would still blend 10%, which would mean as we phase down gasoline consumption, as we electrify vehicles, a gradual phase down of ethanol demand.

David Roberts

Of course.

Dan Lashof

But not an overnight elimination. So I think that's the first thing to note. The second thing to note is US farmers in particular are really good at growing food. And we need that food. The world needs it more than ever.

David Roberts

Right. Isn't global food demand supposed to double? That's the statistic I always see by 2040 or 50 or whatever.

Dan Lashof

Yeah, I mean, you got a population that's going to go from about 8 billion to about 10 billion. But then also as people get richer, they eat more meat, for better or for worse. Often for worse. But in low-income countries, actually increasing protein consumption is important from a health perspective. And that means you need more animal feed. So the total amount of grain that's needed goes up by much more than the population.

David Roberts

So the contention here is that farmers would be okay if we abandoned or started ramping down our current biofuel production. Farmers would not simply be cast out onto the street.

Dan Lashof

I mean, I think this needs more work to look at what that transition is like. But like I said, corn prices right now are very high. The renewable fuels mandate probably contributed some to that, but corn prices have also been very volatile and that volatility didn't go away with the Renewable Fuel Standard. So being a farmer is still really tough and we need to recognize that. I think we have to look at a whole range of alternative or complementary income sources that we need to boost the rural economy. And that can include wind and solar revenue, right.

And it can include using biomass waste like corn stover to produce hydrogen or other carbon benefits, which we can talk about more. And then there's an opportunity to increase fertilizer production more locally using clean hydrogen. Right now, all the fertilizer that's being used, almost all of it in the US. Is being produced from natural gas, and then this CO2 just goes into the atmosphere. So if you've got sources of clean hydrogen, whether it's from electrolysis using renewable electricity, or if it's from biomass waste with carbon capture, one thing you can do with that hydrogen is make fertilizer that could be more distributed than the big fossil fuel based fertilizer plants that we currently have.

David Roberts

Interesting. And so when you say EPA should set volumes based on what can be met with waste, what does that mean numerically? Like, right now? It was 36 billion in 2022. Is that right?

Dan Lashof

That was the original law.

David Roberts

Right. And they're proposing for 2025.

Dan Lashof

Less than that, let's see, because, yeah, we never got to 36, we got to 21. And they're proposing a modest increase from that. And we're talking about the waste being more on the order of less than 10 billion gallons.

David Roberts

So, ballpark, you're recommending that they cut the volume requirements for biofuels roughly in half, or a little bit more than in half, down to what could be met through waste?

Dan Lashof

Right.

David Roberts

And aren't you also encouraging them to use a shorter time period, shorter than three years?

Dan Lashof

Right. Well, in general, I think having a little bit of a runway setting a standard for several years out makes sense. But in this case, what we said was, look, things have changed since 2007. You really need to rethink this policy and how it fits into the administration strategy. So to give yourself some time to do that rather than setting a target.

David Roberts

They had 15 years. This is what's bizarre about this. It's like they woke up yesterday morning, they're like, oh, we have to do this thing again. None of this stuff is a secret. What we're talking about, the biofuels performance, is not a secret. It's weird to me that they seem to be kind of sleepwalking into this.

Dan Lashof

That's a fair point. I don't have an explanation for that. But given where we are, we thought one of the things that we could suggest to give the administration a little more time to rethink this would be to start with only one year standard, and then hopefully the next phase, they would more fully account for the changes, particularly in electric vehicles going forward.

David Roberts

Is it in law that they have to set standards every so often, or is this going to be like setting new standards every year or two years or three years forever? Or how does it work going forward?

Dan Lashof

They have to set standards for each year, but they can choose to set it for one year at a time, or three years at a time, or five years at a time? That's up to the EPA at this point.

David Roberts

A slight side question, but I would like a little bit of international context here. Like, are other countries that have been sort of doggedly pursuing biofuels all this time, despite all the trends heading in the other direction, are they a big dominant industry? And question in other countries, what's the international take on biofuels right now?

Dan Lashof

Well, the one country that has probably the most significant ethanol industry other than the US is Brazil.

David Roberts

Right.

Dan Lashof

And they make ethanol from sugar cane, which is more efficient than corn. But I think it's still subject to similar carbon opportunity cost problems.

David Roberts

Do you think it still fails the land test?

Dan Lashof

I think so. I haven't actually done that calculation, but I think it's a similar issue. And then the other issue where biofuels are used not for transportation, but there actually have been a significant part of the European renewable mandate.

David Roberts

Yeah, biomass for electricity, right?

Dan Lashof

Well, yeah, electricity and co generation plants. So they're using wood pellets, some of which come from the US southeastern forest. A bunch of them come from Romania. Scientists have been raising concerns about this for a long time.

David Roberts

That's very controversial, too, right? Biomass in Europe's standard.

Dan Lashof

Right. And they've been supposedly tightening their requirements so that it's supposed to be like waste. So if you talk to the wood pellet industry, they'll say, oh, no, we're not harvesting trees, we're using these biomass waste. But there was an investigative report a few months ago that looked at Romania where it's very clear that biomass pellets that were labeled as coming from waste were actually big trees that had been harvested and chopped up. So there's a huge problem there.

David Roberts

Interesting.

Dan Lashof

This all comes back to this unfortunate notion that biomass is inherently carbon neutral, because after all the carbon in the biomass that came from the air through photosynthesis so putting it back to the air, that shouldn't be a problem.

Right. But the problem is, of course, that's true of fossil fuels also, right?

David Roberts

True.

Dan Lashof

There's a time issue that you have to take into account. And so this notion of the carbon-debt, if you harvest forest to produce energy, has not been factored into a lot of these standards.

David Roberts

It sounds like over there, it's probably more of a forestry-industry shenanigans thing than a farming industry shenanigans thing.

Dan Lashof

Yeah, it is. But then I think around the world, there's also various places where biodiesel is being used and promoted through policy, where you've got a palm oil industry in Indonesia, for example, and other places where that's been promoted. So there is a global aspect to this that also needs a lot of attention. And I think what the US does sets a precedent that other countries look to. So it's another reason why we really have to get this right, but nobody.

David Roberts

Else is dumping corn into gas tanks specifically.

Dan Lashof

Not at these volumes, no.

David Roberts

And really, why would you? Okay, I wanted to leave a little bit more time for this, but just sort of by way of wrapping up. I think we can agree, for reasons we've discussed, that biofuels in personal transportation are silly. We're electrifying, we're on the way, there's just no point anymore in — I guess you could make an argument for gas. Cars are going to be around a while longer and at least you can marginally reduce the impact of gas. But given what we know about the carbon opportunity costs and all that, it's not even clear that's helpful.

So in personal transportation, biofuels are silly, I think, but there are, as people are constantly saying, areas we don't know how to decarbonize yet. And so I wonder if you were sort of canvassing, what are the plausible positive uses of biofuels in the world? We're heading toward a decarbonized world. What are they still good for?

Dan Lashof

Right, so I think there's a couple of use cases that could make sense, but again, really depending on taking the carbon opportunity cost into account and really focusing on waste feedstock. So one is aviation. Of all the sectors that people have said are hard to abate, aviation really is hard to abate. And I don't think we know what the long term answer is there, but certainly whatever biomass resources we have that are truly beneficial to use for fuel, replacing jet fuel with so called sustainable aviation fuel, that's one possibility that could make a lot of sense.

David Roberts

Pausing on that, I mean, I saw a calculation on Twitter, so take this for what it's worth, but if you're comparing the volumes necessary to, say, replace 10% to 15% of gasoline volume and the volumes necessary to replace total aviation fuel volume, they're not way off from one another. So in other words, if biofuels really, if we're really setting out to replace all bunker fuel, not just jets use, but has other uses too, with biofuels, that's going to be a lot of biofuels still.

Dan Lashof

That's right. And I don't think there's enough waste to supply the whole aviation sector, but it can supply a meaningful part of it. So that's one use. What we do with the rest of the aviation ...

David Roberts

Fly less, Dan.

Dan Lashof

Fly less. That could be a thing. I don't know that that's very likely, but it would be good. They're short haul aviation. There's electric planes, which ...

David Roberts

Trains!

Dan Lashof

... really cool. Trains would be a lot easier for short haul. And people are talking about hydrogen. I don't know if that's going to be a thing for aviation. The solution there, quite frankly, might be that's the one place left where you would actually burn petroleum and then compensate for those emissions with direct air capture.

David Roberts

Right.

Dan Lashof

I don't love that solution, but right now I don't have a better answer for aviation. So that's a tough one. The other thing for biofuels, and this figures prominently in a lot of decarbonization scenarios, such as the Princeton Net-Zero study is making hydrogen by gasifying biomass and then capturing the CO2. And if you put the CO2 underground, the net effect could actually being a negative emission fuel.

David Roberts

Right. It's similar to BECCs. Right. Similar to burning biomass.

Dan Lashof

Right. It's a form of BECCs. But instead of making electricity, where we have lots of options of better ways to make electricity, if you make hydrogen, you're competing with electrolytic hydrogen, which in the long run is probably cheaper. But if you account for the benefit of actually removing carbon from the atmosphere this way so if you're using, for example, corn stover, there's several hundred million tons of corn stover produced every year in the US. Given how much corn we're producing now, now a third of that corn is currently being produced for ethanol. So maybe that declines somewhat, but there's still going to be a lot of corn stover.

David Roberts

So you take the corn stover, you gasify it and you get CO2 and hydrogen, you bury the CO2, you use the hydrogen to make fuels. Is that the idea?

Dan Lashof

Right. Use hydrogen to make fuels, or use it to make fertilizer or use it to make steel, whatever you're going to use hydrogen for. That makes sense.

David Roberts

That is such a long chain of conversions. It's just like you're losing so much along the way there. It's hard for me to believe that that's going to end up being the best we can do. But I don't have any other ideas either.

Dan Lashof

Yeah, I mean, there are a few companies that are trying to commercialize it. Like I say, it's not a large source of the total hydrogen. So if you look at Net-Zero study or others and say, what does the energy system look like in 2050? We're using a bunch of hydrogen. Most of that comes from electrolysis, some of it in these studies comes from this biomass pathway. But it's actually a significant share of the net carbon removal because every ton of corn stover that you convert to hydrogen plus CO2 is actually producing 1.8 tons of CO2. And so a couple hundred million tons of carbon removal potentially from doing this.

And if you value both the hydrogen and the carbon removal, it starts to look like a sensible thing to do.

David Roberts

Right. But aviation and maybe hydrogen, those are sort of like the biofuels of the future. That's more or less what we can think of to do with them.

Dan Lashof

And then I think the other thing is to substitute for plastics made from petroleum. That could be another ...

David Roberts

Is that ever going to I mean, I feel like that's been right around the corner almost as long as cellulosic biofuels. Is that a thing that's really going to happen?

Dan Lashof

Not as long as natural gas is super cheap and they keep producing more of it. Right. So, I mean, it's hard to compete, but if you're trying to squeeze the last ton of fossil carbon emissions out of the system, then it starts to look like a plausible thing to do.

David Roberts

Interesting. Okay, well, this is substantially more than I've thought about biofuels in many, many years. Thank you for coming on it and catching us up. And I guess if we're just sort of taking away the main takeaway here, it's just that EPA should, like, read Biden's Transportation Decarbonization Strategy.

Dan Lashof

That would be a good start.

David Roberts

All right. Dan Lashof, World Resources Institute. Thank you for coming on and catching us all up.

Dan Lashof

Alright. Thanks.

David Roberts

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