Given that there is absolutely no substance contained in NRDC’s response to the new IHS-CERA report on the NESCAUM economic analysis of a low carbon fuel standard, we had to scratch our heads as to what kind of response we wanted to send. Perhaps the best response is to simply say that there’s not a lot of “there” there, unless ad-hominem attacks and name-calling are considered substantive, scientific critiques of public policy.
One thing is for certain, based on the changes to the language (LCFS to CFS) it does appear that LCFS has become a four letter word.
First let’s clear the air on the ad-hominem attacks. Consumer Energy Alliance is a non-partisan, non-profit group with more than 300,000 individual members nationwide and over 170 member organizations. We support the thoughtful utilization of our all types of energy resources. We advocate policies that create jobs, not destroy them, and aim to keep energy costs reasonable for consumers. We look at science, and publically available data as we determine which policies we will support and those that we will oppose.
So when we receive a report from a reputable source like IHS-CERA, we take it seriously. Especially when the report is based on public data from the Environmental Protection Agency (EPA), the National Highway and Traffic Safety Administration (NHTSA), the Department of Energy (DOE) and the California Air Resources Board (CARB).
For example: EPA’s own fact-finding efforts show that NESCAUM’s assumptions are extremely optimistic.
According to a recent report by the National Science Academies Research Council, the biofuels industry will not be able to meet the cellulosic ethanol requirements in the RFS program, and that changes to the program are necessary. The RFS cellulosic biofuel standard for 2011 was originally 250 million gallons nationally and the 2012 national requirement for cellulosic biofuels is 500 million gallons. However, as of July 2011, no cellulosic ethanol has been commercially produced yet and EPA has only identified 3.6 to 15.7 million gallons of potential cellulosic biofuel capacity nationally for 2012.
Cleary, we are nowhere close to meeting national biofuels mandates under the RFS2. Adding additional volume requirements under an LCFS would present a whole new demand shock to the system – which flies in the face of NESCAUM’s assertion that we can expect cellulosic ethanol and biodiesel to be available in massive quantities and cost less than gasoline and diesel. We agree with IHS-CERA that basing an LCFS economic analysis on this kind of unrealistic scenarios is both unscientific and useless.
NRDC also asserts that CEA’s opposition to a Low-Carbon Fuel Standard is based entirely on industry greed at the expense of the consumer, security, economy and environment. We respectfully disagree. In fact, our opposition is based on the fact that an LCFS would actually penalize North American energy supplies such as Canadian oil sands or Mexican heavy crude, make us more reliant on unstable and hostile governments, increase prices for consumers and eliminate American jobs
To date, biofuels represent only 1.8% of our National Energy portfolio. Although we strongly support the development of advanced biofuels such as cellulosic ethanol and renewable diesel and increased use of alternative fuels such as electricity and natural gas, hoping that renewables and alternatives replace tradition fuels like gasoline and diesel in the short-term does not make it a reality. The infrastructure, technical know-how and alternative fuel supplies simply do not exist today and are not projected by EPA, DOE, CARB or anyone else other than NESCAUM to be available in sufficient quantities to meet the carbon reduction goals of an LCFS within 10 years.
NRDC also claims that an LCFS will reduce carbon intensity by eliminating the use of high carbon fuels such as Canadian oil sands. However, an LCFS does not provide the intended environmental response and actually increases our global carbon footprint as a result of “crude shuffling.” According to study by Barr Engineering, a nationwide LCFS would increase global GHG emissions by 19 million metric tons annually.
“Crude shuffling,” replaces Canadian crude with other foreign sources, increasing the amount of GHGs involved in transportation of the crude oil overseas and negating the desired reduction factor of an LCFS. Furthermore, increased fuel prices will strain businesses and put more American jobs at risk.
A June 2010 report by Charles River Associates found that between 2.3 and 4.5 million American jobs would be lost under an LCFS. The price of gasoline and diesel fuel would increase by up to 170% over 10 years and our GDP would decrease between 2 and 3%. On top of all this, we will be forced to send greater sums of money overseas for crude oil, reducing our domestic energy security. We won’t use less energy because there is a LCFS; we’ll just obtain it elsewhere.
While NRDC would like to say our industry is “once again saying ‘no’ to change,” their recent blog overlooks the fact that America’s energy producers are some of the most innovative and creative members of our society. When it comes to changes in our fuels policies that will hurt American consumers and cost American jobs while doing nothing to aid the environment, CEA is happy to say no.
