By Tim Rudnicki, Esq
Minnesota State Agencies’ opaque, top-down approach to future fuels in the transportation sector is very disappointing and dangerous. The Minnesota Pollution Control Agency (MPCA), Environmental Quality Board (EQB) and Department of Commerce are among several branches of State Government either participating in or using the Climate Solutions and Economic Opportunities (CSEO) project to create a new greenhouse gas (GHG) emission reduction policy. By its own reckoning, the MPCA determined in 2013 that the combination of increased vehicle efficiency as well as biofuels helped to significantly reduce GHG emissions in the transportation sector. Now, even with Governor Dayton’s repeated call for efforts to significantly increase the amount of biofuel available to consumers, the MPCA denies ethanol any future role in reducing GHG emissions.
What new finding led the MPCA to reverse its position on the positive role biofuels have played? More importantly, what finding led the MPCA to set a predetermined policy outcome which (1) rejects the future role of ethanol and (2) caps biofuel use at E10 rather than embrace the more significant role biofuels, such as E15 and higher blends, can play in further reducing GHG emissions in the future?
In an attempt to understand the MPCA and CSEO positions on and reasoning about biofuels, the Minnesota Bio-Fuels Association (MBA) launched repeated agency information requests over a two month period of time. Eventually MBA was provided with a spreadsheet. The spreadsheet contains inaccurate information and assumptions about Minnesota’s petroleum replacement law, transportation fuel use and questionable lifecycle GHG calculations. MBA’s follow up information requests to agencies were met with advice from a project facilitator to participate in a webinar session which purportedly was to allow for information exchange. Instead, the webinar was limited to accepting written participant questions which were screened by the Environmental Quality Board.
The lack of transparency in the CSEO process was especially evident as the CSEO presenter attempted to over simplify and compartmentalize complex social, economic and environmental issues. One written question read to the CSEO presenter asked: by what amount can E15 reduce GHG emissions compared to E10 (regular unleaded gasoline)? Without any explanation regarding the variables in the equation, the CSEO presenter provided the answer - zero.
This lack of transparency by CSEO regarding models, variables and assumptions is at odds with the rest of the scientific community. And this flawed CSEO process threatens to derail the progress Minnesota is making as it reduces GHG emissions in the transportation sector. With respect to biofuels such as ethanol, there exists a vast body of knowledge and scientific information about the entire GHG lifecycle for ethanol including, for example, upstream and downstream emissions associated with growing renewable ingredients, biorefining and actually using biofuels, such as E15, in motor vehicles.
What are the facts? What does science tell us, rather than an opaque agency top-down process, about E15 (15% ethanol, 85% gasoline)? As reported on February 16, MBA checked with Dr. Steffen Mueller, principal research economist at the University of Illinois at Chicago, about E15’s potential to reduce CO2 emissions. He informed us that a gallon of E15 saves 1.26 g of CO2 equivalent (CO2e) per megajoule over regular E10 (gasoline that contains 10 percent ethanol). CO2e includes carbon dioxide, nitrous oxide and methane. Further, according to Mueller, should all 2.4 billion gallons of gasoline consumed annually be converted to E15 from E10, CO2e savings in the state would total 358,000 metric tons annually. Using the U.S. Environmental Protection Agency’s greenhouse gas equivalencies calculator, this would amount to eliminating 75,368 passenger vehicles from Minnesota’s roads annually.
To the MPCA, EQB and Energy Division in the Department of Commerce we ask, what part of the science do you question? Let’s have that conversation with scientists, not project facilitators. How many more meetings do we need to have in an attempt to more fully inform the CSEO process when the process is actually closed to the facts and science? Given the GHG emission reductions called for in Minnesota law and knowing E15 can be part of the solution by immediately reducing GHG emissions, when will Minnesota State Agencies reject the flawed CSEO process and allow the science on biofuels and GHG emission reduction to enter into the analysis?
As always, you can direct your questions to me This email address is being protected from spambots. You need JavaScript enabled to view it.