By Richard A. Kessler
The biofuels industry expects a federal government review to conclude this month of the US Environmental Protection Agency’s lifecycle analysis for the proposed rule to implement expansion of the renewable fuels standard, or RFS2.
As part of that study, one key issue is whether the agencies coordinated by the White House Office of Management and Budget (OMB) will endorse EPA’s May 2009 finding that the 2010 cellulosic biofuel volume mandate for 100 million gallons should remain unchanged.
Industry officials agree that the mandate, set by Congress in the 2007 Energy Independence and Security Act EISA), cannot be met after last year’s economic crisis delayed construction of commercial-scale projects, and upgrading of pilot-scale and demonstration plants to that status. Technological hurdles have also contributed to the sector slowdown.
While private estimates vary, production this year of more than 40 million gallons of cellulosic biofuels is unlikely. EISA requires EPA by 30 November each year to determine the amount of cellulosic ethanol that will be available the following calendar year. If forecast volume is less than the EISA yearly mandate, EPA is obliged to cut the mandated volume to the projected amount.
With this in mind, EPA’s Office of Transportation and Air Quality (OTAQ) in October hinted that the agency would review additional information which could change the May finding, which the industry supports..
“The Iowa Renewable Fuels Association believes strongly that any action to reduce an RFS volume requirement must be taken only as a last resort,” IRFA president Denny Mauser said in a letter several months ago to OTAQ director Margo Oge.
Mauser added if EPA concludes that reducing the cellulosic mandate is necessary then it should raise the 200 million gallon mandate for other advanced biofuels by an equivalent amount. He notes there is advanced biofuels production capacity to do this.
“Any adjustment to the cellulosic requirement should not impact the overall volume requirement of the renewable fuels standard schedule,” he concludes.
While not confirming that EPA will reduce the 2010 cellulosic biofuel mandate, an agency official who requested anonymity left open that possibility in comments to Recharge.
EISA amended earlier legislation to include separation of the renewable fuel volume requirements into four categories: advanced biofuel, biomass-based diesel, cellulosic biofuel and total renewable fuel.
It also increased the volume of renewable fuel required from 9 billion gallons to 36 billion by 2022.
Congress deliberately set aggressive mandates for cellulosic biofuel in an effort to promote a promising new domestic fuel source from materials such as switchgrass and woody biomass. They may be unrealistic, at least until a biomass supply chain, sufficient investment capital and technology is in place.
The cellulosic volume mandate rises to 250 million gallons in 2011, 3 billion in 2015, 10.5 billion in 2020 and 16 billion in 2022.
“EISA was very successful in getting cellulosic ethanol moving,” says Chris Thorne, spokesman for Growth Energy, an advocacy group for ethanol based in Washington, DC. He says EPA could help spur its development by raising the ethanol blend level in gasoline from 10% to 15%, which would create demand for billions of gallons of additional ethanol.
EPA has delayed a decision on the so-called “blend wall,” citing a need for more time to analyze US Transportation Department test results of E15 fuels on vehicle engines. The automotive industry and small engine makers allege that higher ethanol blends damage engine components and anti-pollution devices such as catalytic converters.
The US Energy Department has disbursed hundreds of millions of dollars in grants and other funding for biofuels development under President Barack Obama, with more to come, in an effort to jump-start a commercial cellulosic ethanol industry. But much of the money has gone to projects that won’t be online before 2012.
EISA yearly mandates for cellulosic biofuel and advanced biofuel in gallons:
2010 100,000 200,000
2011 250,000 300,000
2012 500,000 500,000
2013 1,000,000 1,750,000
2014 1,750,000 2,000,000
2015 3,000,000 2,500,000
2016 4,250,000 3,000,000
2017 5,500,000 3,500,000
2018 7,000,000 4,000,000
2019 8,500,000 4,500,000
2020 10,500,000 4,500,000
2021 13,500,000 4,500,000
2022 16,000,000 5,000,000
