July 24, 2008

Redefining "renewable biomass" in EISA

As we strive to find sustainable alternatives to the demonstrably unsustainable fossil fuel paradigm the definition of "renewable biomass" is critically important. It is not just biofuels, biopower, or bioproducts that are (or are not) environmentally sustainable. Sustainability is a function, too, of the feedstock - and it may vary by region. Corn grown in the midwest might be sustainable while corn grown in California might not be for any number of reasons - water, pests, climate, topography, or soil to name a few. And that doesn't begin to address the question of economic sustainability which is determined by a host of other factors like capital availability, markets, infrastructure, ownership, manpower, and subsidies.

Bruce Dale of Michigan State University said at the 2008 California Biomass Collaborative "All biomass is local. And, as Tip O'Neil used to famously assert 'All politics is local.' So the obvious syllogism is that 'All biomass is political!'"

Funny if it wasn't so true.

Which is why it makes no sense for a federal definition of "renewable biomass" to be exclusionary (which is the way that it is as currently defined in the EISA law). It should be as inclusive as possible - allowing local considerations to determine what is environmentally and economically sustainable.

I think this is the inferred conclusion of an excellent "renewable biomass" testimony made today by Environmental and Energy Study Institute Senior Advisor Jetta Wong in her presentation at a hearing of the U.S. House of Representatives Committee on Agriculture Subcommittee on Conservation, Credit, Energy, and Research.

Here are some key points that she made in her summary and conclusion.

On December 19, 2007 the President and Congress took a huge step forward in trying to mitigate climate change and reduce our country’s reliance on fossil fuels by enacting the Energy Independence and Security Act (EISA, P.L. 110-140). EISA substantially increases the Renewable Fuel Standard (RFS), calling for the production by 2022 of 36 billion gallons of renewable fuel with specific targets for greenhouse gas reductions. Within the 36 billion gallon mandate, 21 billion gallons must come from advanced biofuels, which means renewable fuel other than ethanol derived from corn starch. Additionally, there is a carve-out within the advanced fuels mandate that 16 billion gallons of cellulosic biofuel be derived from ‘renewable biomass.’

This is an aggressive and ambitious RFS. It is laudable, but it stirs up a lot of difficult issues regarding the sustainability of biofuels. One of the biggest factors in determining if a biofuel is sustainable is the choice of feedstocks used to produce the renewable fuel. Unfortunately, the definition of ‘renewable biomass’ included in the law deems several feedstocks ineligible, including thinning materials and woody residues from federal forests, some woody feedstocks from private forests, and a wide array of feedstocks from municipal solid waste.

Key Points :
• Renewable fuels are important to our climate and energy security strategy. They are reducing our dependence on foreign oil, reducing the cost of gasoline at the pump, and if produced sustainably, reducing greenhouse gas emissions.
• Renewable fuel facilities provide a market for low-value material produced through forest management practices.
• Abundant sources of woody biomass in the west can increase the distribution of liquid transportation fuels across the country. This will help to meet the large fuel markets of the west while further securing our energy supply.
• Mill residue and other woody materials create complications (in terms of collection) and should be carefully considered during implementation.
• Municipal solid waste is a low-value feedstock that several companies are investigating. Confusing or varying definitions included in public law create risk, limit innovation, and ultimately reduce the use of a feedstock currently considered a problem.
• Production of renewable fuels from low-value materials, such as woody biomass and municipal solid waste, reduces the pressure to develop feedstocks on sensitive land.
• A variety of stakeholders overwhelmingly support a broadening of feedstocks that could be eligible for the RFS. Specifically, low-value woody biomass sustainably harvested from both federal and private lands should be included.

Cellulosic biofuels can be produced from a highly diverse array of feedstocks, allowing every region of the country to be a potential producer of this fuel. (Cellulose is found in all plant matter.) As a result, support for cellulosic biofuels has brought together a broad array of constituents including environmentalists, farmers, national security experts, industry, and religious leaders. Unquestionably, the production of renewable fuels needs to be done in a way that sequesters carbon and enhances natural resources, including soils, water supply and native habitats. Production of renewable feedstocks should not be deemed to be in competition with the goals of sustainable agriculture or forestry. In fact, there are opportunities for renewable fuel and energy production to aid conservation efforts and environmental sustainability beyond those associated conventional agriculture, forestry or fossil fuel production and consumption.

The wisest course of action would be to focus on feedstocks that do not compete for land resources, such as low-value forest residues and other waste materials. The RFS is a very aggressive mandate, but it is not an impossible one, as long as we do not exclude any of those feedstocks that can be produced sustainably and that meet important environmental and greenhouse gas emissions reductions. With conversion technologies still in development, we must keep our options open and strive to produce renewable fuels that meet objective and appropriate standards of sustainability. Fortunately, our nation possesses abundant and readily available feedstocks that satisfy this criterion.

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Anonymous said...


You make two very relevant points in this blog:

1) Sustainability is very much a function of feedstock. Range Fuels considers an abundant and sustainable source of renewable biomass as the primary reason for selecting a site to develop a biorefinery. Further, what is sustainable in Middle Georgia where planted pine plantations are plentiful is not the case in Mississippi, Arkansas, or North Carolina where commercial timber is primarily grown naturally.

2) The definition of "Renewable Biomass" needs to be as inclusive as the term sustainable will allow. Arbitrary and confusing restrictions such as those that are currently included in EISA only threaten to dramatically reduce the number of biorefineries that can be successfully developed and financed.

Ron Barmore
Director, Project Development
Range Fuels, Inc.

C. Scott Miller said...


You are at the point of execution for the paradigm shift from fossil to renewable fuels.

I think environmentalists should take heart that people like you are not only cognizant of their concerns and expending your best effort to make sustainability the key to your project's success. It is an ambitious goal.

There has to be some latitude, particularly during the critical next 5 years, to allow technologists to innovate at a commercial scale. It is the only way we will learn.

Otherwise we are stuck with the unsustainable status quo.

Thanks for taking the time to write.