A few quick hits:
Murky money: Alaska Senator Lisa Murkowski hinted broadly yesterday that she’d probably oppose a move by Senate Majority Leader Harry Reid to meld energy and climate change legislation into a single package for a vote on the Senate floor. The Alaska Republican spoke at a Platts Energy Forum, as reported by today’s BNA Daily Environment Report. It looks as if Murkowski hopes to slow the action down. I don’t know if this has anything to do with it, but Murkowski just received a tidy $4,500 campaign contribution from Duke Energy last month, according to Federal Election Commission records. (We’re tracking Duke’s campaign contributions, if you want more. Amazing how much money this company is giving to the leading opponents of congressional action on global warming!)
Murkowski is in big demand on the speaking tour these days; she’s also speaking this morning to the Bipartisan Policy Center.
“Cut a goddam deal:” The center’s head, our old friend, Jason Grumet, had a very colorful quote yesterday during a separate panel discussion by the center. As reported by E&E PM, he urged law makers to”cut a goddamn deal” on global warming. “The orthodoxy that we are bringing to this discussion is amazing to me."
Rebellion in the ranks? As the dealmakers chat, I want to make sure to note this very interesting commentary in The Huffington Post by our friend, John Passacantando: http://www.huffingtonpost.com/john-passacantando/joe-lieberman-to-turn-cli_b_175540.html
It’s a different take on the latest antics of Senator Joe Lieberman, who is acting these days more like a senator from Ohio than Connecticut. Lieberman, whose effort at global warming legislation last year became something of a fiasco, still seems to think it’s necessary to bribe coal-burning power companies such as Duke.
Farm-state follies: Finally, from yesterday’s E&E PM, pressure from farm-state senators on the EPA to break the law in an effort to raise corn prices. (No, that’s not exactly how they phrased it, but that’s the underlying dynamic. See the letter, below.) It is really discouraging that special-interest politics are at the root of such missives, which then are cloaked in misleading verbosity. If you want to explore further this issue of “indirect” emissions from land-clearing, check in with my friends from the Clean Air Task Force. www.catf.us
March 13, 2009
The Honorable Lisa P. Jackson
U.S. Environmental Protection Agency
Ariel Rios Building
1200 Pennsylvania Ave., NW
Washington, DC 20460
Dear Administrator Jackson:
In a letter to Administrator Johnson in November several of us recommended that the
EPA not include calculations of indirect land use change (ILUC) effects as contributors
to life-cycle greenhouse gas (GHG) emissions for biofuels in the forthcoming Notice of
Proposed Rulemaking (NOPR) for implementation of the updated Renewable Fuels
Standard (RFS-2) enacted in the Energy Independence and Security Act (EISA) of 2007
(P.L. 110-140). This letter repeats that recommendation and expands on its basis.
Under RFS-2, various biofuels must meet specified life-cycle GHG emission reduction
targets to qualify. The law specifies that life-cycle GHG emissions are to include “direct
emissions and significant indirect emissions such as significant emissions from land use
changes, as determined by the Administrator.” Thus, for example, if increased production
of a specific type of biofuel in the United States can be shown to cause a shift in land use,
the immediate and future greenhouse gas emissions resulting from that land use change
are to be included in the life-cycle GHG emissions for that biofuel when determining
whether it is eligible to be counted towards the RFS-2 mandate.
We understand that EPA has developed a methodology for calculating the indirect land
use change components of the life-cycle GHG emissions for various biofuels and intends
to include results of that methodology in its proposed rulemaking for the RFS-2. We also
understand that, according to EPA’s methodology, the ILUC components contribute
substantially to the life-cycle GHG emissions for several biofuels, including corn ethanol,
sugarcane-based ethanol, and soy-based biodiesel. Indeed, according to EPA’s current
ILUC calculations, existing soy-based biodiesel production may not count towards the
biodiesel mandate in RFS-2.
EPA acknowledges that quantification of the ILUC components of life-cycle GHG
emissions for biofuels is very difficult at this time. Many factors drive land use changes.
Quantifying land use changes resulting from biofuels production needs to take into
account these other factors, such as population growth, economic growth that drives
demand for land-based food, feed and fiber production, urbanization, extracting lumber
or mineral resources, and, of course, the very different and rapidly evolving land use
policies of the United States and other nations. Not only are the land use impacts of these
factors difficult to quantify; there is considerable uncertainty about predicting their future
magnitude and effects. There also is an unresolved debate about how present and future
GHG emissions should be compared, specifically whether a discount rate should be
applied to future GHG emissions, and if so, what might be an appropriate discount rate
for future GHG emissions.
An additional complication for the EPA methodology is that it cannot foresee or model
future land use restrictions that might result from future national or international
agreements or policies. Because land use changes such as deforestation can result in very
large GHG emissions, it is possible that future domestic and international climate change
policies will include major provisions restricting land use changes. Indeed, that may be
the most appropriate and effective way to reduce GHG emissions associated with land
use changes. At the same time, these land use restrictions in future international climate
change policies are a major factor whose effects cannot be quantified until they are
adopted. And yet, ignoring them introduces a major uncertainty into quantifying the
ILUC components of life-cycle GHG emission calculations for biofuels today.
Given the complexity and uncertainty of this issue as well as what we believe are basic
analytical limitations, we urge EPA to refrain from including any calculations of the
ILUC components in determining life-cycle GHG emissions for biofuels at this time.
The premature publication and use of inaccurate or incomplete data could compromise
the ability to formulate a sound approach to implementing this life cycle GHG emissions
requirement in the future. And the resultant rulemaking confusion could seriously harm
our U.S. biofuels growth strategy by introducing uncertainty and discouraging future
investments. Instead, EPA should move forward in a manner that allows for public
review and refinement of the methodology that is ultimately used to calculate the
contributions to GHG emissions associated with ILUC.
Thank you in advance for your consideration of these recommendations.
Senator Tom Harkin
Senator Charles Grassley
Senator Kit Bond
Senator Sam Brownback
Senator Bob Corker
Senator Kent Conrad
Senator Tim Johnson
Senator Claire McCaskill
Senator Ben Nelson
Senator Pat Roberts
Senator Jon Tester
Senator John Thune