Clif's Writings

In summary, here are the five areas of concern:

1. LCFS could delay the transition to zero emissions transportation and prolong our dependency on carbon emitting liquid fuels.
2. There isn’t enough cropland to make biofuels practical.  We hoped that algae would yield tens of thousands of gallons per acre.  But these hopes haven’t panned out.
3. The catastrophic, unanticipated effects of “land use conversion” are not being adequately addressed – even in the newly updated CARB models.
4. The purported health benefits of biodiesel are dubious.  Zero emission vehicles are far more healthy.  
5. Success in addressing climate change means getting to net zero global anthropogenic CO2 emissions.  LCFS doesn’t get us anywhere close.

It would be really helpful to hear your thoughts.  Sorry this is so long.  I’ve actually condensed it from a much larger body of notes!  But, as you say, some of these issues are like six dimensional chess.

Thanks for all your great work on this important issue.

Clif

1. LCFS will delay the transition to zero emissions transportation and prolong our dependency on carbon emitting liquid fuels.

When consumers and businesses purchase new internal combustion engine cars, SUV’s, pickup trucks, large delivery vehicles, long haul trucks, and aircraft, it creates a new generation of CO2 polluting vehicles that will be on the road (or in the air) for decades.  When the biofuels industry invests in feedstock supply, transportation, refining, and distribution they will be highly incentivized to maintain and grow their business.  It will be in their interest to have a large fleet of internal combustion engine (ICE) vehicles burning their fuel.  Further investment in ICE vehicles and biofuels infrastructure will slow the transition to zero emissions transportation.  

To see this dynamic playing out, look at the billions of dollars in subsidies given to US farmers to produce corn for ethanol.  The ethanol industry is here to stay, despite serious questions about whether ethanol provides any net positive for climate or the environment. 

Instead, we should adopt policies that transition as quickly as possible to a zero emissions transportation sector (e.g. electric cars, trucks, ships, and even aircraft coupled with 100% clean energy generation and storage).

2. The original theory behind biofuels was that algae would yield tens of thousands of gallons per acre (otherwise, there isn’t enough cropland to make it work).  But our hopes for algae didn’t pan out.

Back in 2005, I met with the CEO of Imperium Renewables (Martin Tobias) and visited their refinery just off the Duwamish.  At that time, Imperium was an early stage, mission driven startup intent on addressing climate change by producing liquid fuels that over their full lifecycle emitted little or no CO2 into the atmosphere.  The basic idea is the plants grown to create the vegetable oil would absorb the same amount of CO2 emitted when the fuel is burned.  So these fuels would be carbon neutral.  Today, we call this “lifecycle carbon intensity” (CI) where the lower the CI, the better.  A CI of zero means no net CO2 is emitted over the lifecycle of the fuel.

The big problem that Martin readily acknowledged was that using the traditional crops grown in Washington State (like corn, soybeans, or canola/rapeseed) as the feedstock didn’t make sense.  These crops require cropland to produce the vegetable oil that is then refined to make biodiesel.  If you do the math, the amount of cropland required is staggering and completely impractical.  In 2017, we consumed about 240 billion gallons of liquid fossil fuels in the US (source EIA).   There are about 339 million acres of cropland in the US (source USDA).  Canola (aka rapeseed) produces about 127 gallons of vegetable oil per acre each year (source).  So a quick calculation reveals that if we used canola to produce the 240 billion gallons of fuels we burn every year, it would require about 1,884 million acres of land.  This is over five times the available cropland!  And it assumes we don’t grow any other crops.  So, we’re not even in the ballpark here.  Clearly, Canola wasn’t going to be a practical solution. 

What Martin and many others were betting on at the time was that the ultimate feedstock for biofuels would be algae (aka cyanobacteria) that was genetically modified and capable of producing 5K, 10K, … maybe even 30K or more gallons per acre.  And this algae could be grown on unused land rich in sunlight so it wouldn’t require converting cropland.  But in the intervening 12 years, and despite hundreds of millions of dollars of investment, this hasn’t come to pass.    Attempts to get these yields have failed and the outlook isn’t hopeful.

Also, in the intervening years, other problems have emerged.  In most gasoline powered cars, no more than 10-15% of the fuel can be ethanol or the engine will be damaged (known as the blend wall).  For diesel cars, B20 (80% petroleum diesel and 20% biodiesel) has become the most common biodiesel blend because higher levels of biodiesel turn to sludge at cold temperatures.  So, today, the vast majority of “biofuels” are actually fossil fuels with a small percentage of plant based fuel added. 

3. The catastrophic, unanticipated effects of “land use conversion” appear to not be adequately addressed – even in the newly updated CA program.

Perhaps the biggest unanticipated problem with biofuels is what is called “Indirect Land Use Conversion”.  It sounds technical, but you can get a clear and visceral understanding of it from reading this article published in the November 20, 2018 New York Times “Palm Oil Was Supposed to Help Save the Planet.  Instead it Unleashed a Catastrophe.”   (copy without paywall here).  The short version is that around the same time Martin was getting Imperium renewables going, a lot of other people started to believe that biofuels were a good thing.  Many states and nations adopted policies to encourage their use (including California’s Low Carbon Fuels Standard).   And the demand for plant based oils surged.

Unlike Canola (at 127 gallons/acre), palm plantations can produce roughly 600 gallons of oil per acre – far more than any other known crop.  Since these palm plantations require a tropical climate, places like Indonesia had a big incentive to clear tropical rainforest, plant palm trees, and export the resulting oil – all in the service of a cleaner environment.  The result was, from the article, “NASA researchers say the accelerated destruction of Borneo’s forests contributed to the largest single-year global increase in carbon emissions in two millenniums.”  This, in my opinion, ranks as one of greatest ecological disasters on record.  The small benefits of mixing biofuels into our petroleum fuels were vastly outweighed by the wholesale destruction of tropical rainforests.  There is no known technology for reversing the CO2 that was released.   2018 global emissions were the highest on record.  There is no reversing this destruction of what had been pristine old growth habitat.  And it was all done in the name of protecting our climate.  This is nothing short of a complete disaster.

I was at a climate meeting in December where Joe Fitzgibbon (WA House of Representatives Environment Chair) talked.  I like Joe.  He is smart, high energy, and committed to turning the corner on climate.  Among the measures he was promoting was a Low Carbon Fuel Standard similar to California’s here in Washington.  I asked Joe about the unanticipated destruction of the Indonesian rain forest.  Joe assured me that California had recently updated their carbon intensity calculations to factor in this “indirect land use change”.  Yes, CARB (California Air Resources Board) didn’t get it right the first time.  But Joe thought that they’d figured it out and we could use what they’d done to confidently move forward with LCFS here in WA.

I was curious.  And wondered about all the other states and countries who may not have “gotten it right” and were continuing to drive the demand for palm oil and, indirectly, the destruction of the rainforest and the massive release of CO2 into the atmosphere.  So I dug into the CARB website.

In 2007, Governor Schwarzenegger enacted the California LCFS.  In 2009, the California Air Resources Board started to discuss the effects of Indirect Land Use Changes (ILUC) in calculating the carbon intensity of different fuel pathways.  In 2015, they updated their Carbon Intensity model to include the effects of ILUC.  You can read a detailed description of their ILUC methodology here.   

This is complicated stuff.  But, for context, the way the carbon intensity calculations work is, if fuel comes from a renewable source (e.g. canola, switchgrass, palm trees) it is considered equivalent to zero vehicle tailpipe emissions.  When you burn biofuels, there is definitely carbon coming out of the tailpipe, just like a regular gas or diesel car.  But the theory is that growing additional crops to produce more biofuel will absorb the same amount of carbon that is released.  So, over the life cycle of the fuel, no carbon is emitted.  In other words, the carbon intensity of the fuel pathway is zero.  

But in the real world, there are many other sources of carbon emissions related to producing biofuels.   CO2 and other greenhouse gases are released during farming, crop transport, oil extraction, oil refinement, and from the kind of land use changes we’re seeing in Indonesia.  So, in the California LCFS program, there is a great deal of effort put into analyzing “fuel pathways” to determine the total carbon intensity.  California uses the CA-GREET system (originally developed at Argonne National Labs) to do this analysis.  There are currently 540 fuel pathways with assigned carbon intensities that have been certified by CARB (I pulled them from the website and put them in a spreadsheet).  This represents a monumental effort, involving almost a decade of work.  Joe Fitzgibbon mentioned that roughly 1000 state employees are involved in administering the program.  And the process to evaluate and certify fuel pathways is steadily evolving – CARB is now working on the fifth or sixth version of their CA-GREET process. 

As I dug deeper, rather than feeling more confident in the CARB program, I had more questions, and a sinking feeling that were many ways to game this system.   Here are a few:

• The model used to calculate ILUC has, like every model, inputs that significantly affect the outputs.  For instance, when determining the ILUC for a particular feedstock, one input is the assumed production increase for that biofuel over 2004 levels (also known as the “shock”).  For canola or palm biodiesel, the production increase was 400 million gallons above 2004 levels.  This might sound like a lot.  But it amounts to 0.68% of diesel consumed in the US (0.4 billion of the 60 billion gallons consumed each year) – a tiny fraction that would have essentially no effect in reducing CO2 emissions.  So, yes, you could imagine that at this small level, the land use effects might not be that dramatic.  But what if, for instance, the model assumed a production increase that actually would significantly reduce CO2?  You could imagine that negative impacts from land use changes would be substantially greater.  Why did they make an assumption of such a small production increase? 
• In order to accurately assess the ILUC of palm oil, you need to make assumptions about how much peatland is converted to palm plantation. It turns out the percentage of peatland being converted to palm plantations has been increasing steadily.  But the ILUC for palm oil is set as a static number at 71.4 gCO2/MJ.  How can it be a fixed number when the environmental impact is clearly on a worsening trendline?
• Oddly, the CARB ILUC analysis calculates the impact of land use changes from palm oil (which we know are severe from the NY Times article).  But palm oil is not included in any of the 540 fuel pathways. Why are there no certified pathways based on palm oil?  Does this mean that palm oil products are banned in CA (if so, I could find nothing about it on the web)?  Or does it mean that palm oil biofuels are “off the LCFS books”.  If someone in California is burning palm based biodiesel, will anyone in the supply chain have paid for the high ILUC of palm oil?   It seems unlikely. 
• With complexity, and big money at stake, there are going to be people trying to game the system.  Does CARB really know what’s happening on the ground?  For example, some of the certified pathways include used cooking oil from India as well as Hong Kong and Singapore. What do we know about this “used cooking oil”? Might it be palm oil? Who is over there in Southeast Asia verifying the sources? The “certified carbon intensity” of these Southeast Asian sources ranges from 16.89 – 27.8 (compared to 99 for gasoline, 102 for petroleum diesel). So it is considered to be really clean (well below the average of 49.9).  Selling biodiesel made from Southeast Asian used cooking oil is worth a lot in terms of LCFS credits (now trading for $120-198 / MT).  Could it be possible that palm oil based products are making their way into the California market through the trojan horse of “used cooking oil” from Southeast Asia and generating credit dollars to boot? 
• Of the 540 certified pathways on the CARB site, only 3 were from sources in Washington State.  If we create an LCFS program here in Washington, are we going to need to analyze and certify a large number of additional pathways?  Are we going to trust California’s certifications?  Joe mentioned that, even though CA had 1000 people administering their LCFS program, we could do it with just a couple here in Washington because we can take advantage of all their work.  But given the constant state of flux in the CARB procedures and the lack of pathways based in Washington, is this realistic?  

So, after digging in, I found it much harder to share the confidence that Joe Fitzgibbon had displayed.  Rather than feel that “California figured it out and we just need to follow their lead”, I felt that California’s system was complex, full of loopholes, in flux, and probably quite difficult to maintain.  The only thing that was crystal clear was the tragedy in Borneo and the fact that 2018 saw more CO2 dumped into the atmosphere than any year on record, in part because of the mass clearing of rainforest to plant palm trees for biodiesel.  In other words, Indirect Land Use Conversion. 

4. The purported health benefits of biodiesel are dubious.  Clearly, zero emission vehicles are far more healthy.  

The Pacific Sound Clean Air Agency is currently studying implementing a Clean Fuel Standard here in Washington.  They published a summary of public comments on December 4, 2018.  Among the many comments in favor of a Clean Fuels Standard, a significant number were related to public health and equity (other areas of support were CO2 reduction, economic growth, and feasibility).  I was surprised to see so many comments assuming that burning biofuels would improve public health.  Did people realize that most biofuels would be mixed into a fuel that was mostly fossil fuel based?   In other words, that the product they would buy and use in the cars would be mostly fossil fuel?  

A recent paper from the National Institutes of Health  provides a survey of the existing scientific literature on the health impacts of biodiesel versus petroleum diesel.  While it does say that, in some respects the tailpipe emissions from biodiesel are healthier (e.g. less sulphur), it also mentions that in other respects they are worse (smaller particulate matter that will embed deeper into lung tissue).   There is absolutely no clear finding that these emissions are somehow “healthy”.  To assume that burning biofuels is going to be a benefit to low income communities is dubious, if not outright misleading.

The reality is that tailpipe emissions from biodiesel are harmful to human health.  They create smog, respiratory illness, and certainly dump CO2 into the atmosphere that causes warming over time.  To really clean up our air from transportation, we need to move to zero emissions technologies.

5. The “successful” California program has not been able to hit it’s already modest targets and has lowered them instead.

I often hear that the California LCFS program has been “successful”.  I’m not sure what this means.  The original program set out to reduce by a modest 10% the carbon intensity of California’s transportation fuels by 2020 (over 13 years).  This strikes me as a fairly modest goal.  And it isn’t even attempting to reduce the overall CO2 being emitted – just the intensity of the fuel.

But the California LCFS program did not reach its modest targets and, in 2016, decided to lower them:

“On March 6, 2018, CARB released its Proposed Amendments to the Low Carbon Fuel Standard. Included in these proposed amendments are near-term changes in percent reductions of CI from 2010 levels. Instead of the originally proposed 7.5% reduction in 2019 and a 10% reduction in 2020, CARB is proposing a less ambitious 6.25% reduction in 2019 and 7.5% reduction in 2020.”  (source:  https://stillwaterassociates.com/lcfs-101-an-update/)

Success in the fight against global warming means limiting global average temperature increases to 1.5℃.  This, in turn, means getting to net zero global anthropogenic CO2 by 2055.  Supporting a biofuels industry that, at best, may reduce the carbon intensity of liquid fuels by 10% (and at worst may actually destroy habitat and increase emissions) seems like a poor policy choice.