UCS Tells EPA: No More Food for Fuel

The Union of Concerned Scientists (UCS) is urging the Environmental Protection Agency (EPA) to reduce competition between food and fuel as it implements the Renewable Fuel Standard (RFS).

The science group submitted its recommendation late last week in comments on the agency's proposed biofuel mandate volumes for 2013. EPA's proposal calls for so-called "advanced" food-based biofuels such as biodiesel and sugarcane ethanol to make up for a shortfall in cleaner cellulosic biofuels made from non-food sources, including switchgrass and waste materials.

"The RFS was designed to promote renewable fuels that don't compete with food supplies," said Jeremy Martin, senior scientist with UCS's Clean Vehicles Program. "We can't afford additional strains on our food supplies, especially when the drought is expected to continue through 2013."

Markets for corn, sugar and vegetable oil are tight, Martin explained, and thus any expansion of mandates for any food-based biofuels will put pressure on food prices and accelerate agricultural expansion and deforestation.

When created in 2007, the RFS contained a 2013 goal of one billion gallons of cellulosic ethanol. While the industry is rapidly commercializing -- two commercial cellulosic biofuel facilities are starting up, and others are under construction - it is happening slower than anticipated due to the 2008 financial crisis, resulting in a revised goal of 14 million gallons that reflects current production capacity.

In its submitted comments, UCS urges EPA to adopt a more judicious administration of the RFS policy framework, with a mandate floor that grows to 20 billion gallons in 2022 plus whatever cellulosic biofuel production the industry is capable of producing.

"Cellulosic fuels still offer the best bet for replacing large amounts of oil without disrupting our food supplies," Martin said. "Along with vehicle efficiency and other technology, cellulosic fuels can help us to cut our projected oil use in half over the next 20 years."

Continuing to mandate production of 36 billion gallons of biofuels in 2022, despite the delayed scale up of cellulosic biofuels, will lead to serious environmental and economic consequences that are not in harmony with the climate, energy security, economic, and other goals of the RFS.

UCS research suggests there is enough non-food feedstock in the United States to meet the total 36 billion gallon biofuel target under the RFS, but that doing so will take longer than previously expected. Martin has written about the critical decisions facing EPA over the future of biofuels on UCS's blog, the Equation.

The comment period for the proposal ended Sunday, April 7. UCS also signed onto a shorter set of comments submitted jointly by several science, environmental and development organizations.