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A Fair Accounting of Greenhouse Gases For All Potential Transportation Fuels

It is troubling--and, at the same time, sadly amusing--that an enterprising reporter at USA Today has done more homework on the possible indirect effects of increased renewable electricity generation than scores of analysts at the über environmental agency known as the California Air Resources Board (CARB). Chris Hawley's 1,800-word article in the June 17 edition of the newspaper says more about the significant secondary effects associated with the increased use of windmills for power generation than the thousands of pages of analysis performed by CARB for the state's recently adopted Low Carbon Fuels Standard (LCFS).

You may recall that the LCFS, adopted in April, requires California fuel providers to reduce greenhouse gas (GHG) emissions from transportation fuels by 10 percent by 2020. This necessitates that each transportation fuel be given a "carbon intensity score" that can be used by fuel providers to gauge the ability of different fuels to reduce GHG emissions relative to the high-carbon fuels being replaced (gasoline and diesel fuel). In determining the carbon intensity scores for a wide range of transportation fuels, CARB says it considered both direct GHG emissions associated with the production and use of the fuel as well as the indirect GHG effects that occur in the global marketplace as the result of the increased use of a particular fuel type. Think of these indirect emissions as the "ripple effects."

Here's the rub: CARB suggests the only fuels causing any indirect effects at all are crop-based biofuels. CARB suggests indirect GHG emissions should be charged to biofuels as the result of a macroeconomic construct known as indirect land use change. According to CARB's logic, a land use change occurs when farmland previously devoted to feed production is now used to produce biofuel crops, causing supplies of the displaced feed crops to be reduced. Then, the supply reduction causes prices to rise, which, in turn, stimulates increased feed production elsewhere in the world. If that production takes place on land formerly in non-agricultural uses, stored carbon is presumably released into the atmosphere from the land conversion and added to the biofuel's carbon intensity score.

So, under CARB's analysis, increasing the use of biofuels causes the indirect GHG effect of indirect land use change. But increased use of electricity from new windmills for electric vehicles, ramping up the use of natural gas for transportation, or using hydrogen as fuel for automobiles are assumed to have no indirect GHG or market-mediated effects. And by ignoring the tremendous indirect social, economic, and environmental costs of petroleum production and use, even oil itself is given a free ride in CARB's analysis. As a result of this biased, apples-to-oranges analysis, most biofuels available today are deemed by CARB to be slightly worse than gasoline or diesel in terms of GHG impacts.

Many stakeholders have vigorously challenged CARB's claim
that it made a fair attempt to characterize and quantify the indirect effects of other fuels. Yet, CARB has remained reticent to such assertions, despite the agency's repeated failure to provide evidence that it made any serious effort to investigate the indirect effects of all fuels evenly. CARB's draft LCFS regulation incredulously states that, aside from biofuels-induced indirect land use change, "No other significant indirect effects that result in large GHG emissions have been identified that would substantially affect the LCFS framework for reducing the carbon intensity of transportation fuels." At the April hearing where the regulation was adopted, CARB's deputy executive officer even had the audacity to suggest the hunt for indirect effects of other fuels was akin to the hunt for nuclear weapons several years ago in Iraq. "Actually, we looked for them," the official said, referring to indirect effects. "I was kind of like the search for the weapons of mass destruction."

After reading Hawley's article in USA Today, it is abundantly clear that one place CARB absolutely did not look for indirect effects is Mexico's Isthmus of Tehuantepec. According to Hawley, U.S. and European energy companies are racing to install thousands of wind turbines in this agricultural area to take advantage of low costs and high average wind speeds. Hawley writes that "Nearly every day, another tower rises out of the countryside."

And while the rapid escalation of wind turbines in the area promises to pad the coffers of multi-national energy companies, it is taking a toll on the local economy and environment. As Hawley writes, "...the energy gold rush has also brought discord, as building crews slice through irrigation canals, divide pastures and cover crops with dust."

The article documents in detail many of the negative consequences resulting from the rush to build more wind turbines in the area. Some of the most compelling passages are below.

To support the huge generators, crews built gravel roads 50 feet across, hammered in pylons and poured 1,200 tons of concrete for each tower. Pads of gravel 100 feet long and 50 feet wide were dumped onto sorghum fields and grazing land to support the cranes.

Farmer Salvador Ordaz now has two roads cutting through his 16 acres of pasture and says part of the land is unusable because of dust and blocked irrigation lines. He has had to cut his herd to 10 cows from 30. "When you think of windmills, you just think of this one tower," Ordaz said. "But it affects a lot more land than that."

"People are not thinking about the long term," [farmer Alejo] Giron said. "Those generators will be making millions of dollars for the company, and they will be limiting what you can do with your land for 30, 40 years."

Enter the debate over indirect effects. Who will make up for the lost sorghum production that resulted from the construction of the roads and gravel pads? Where will Ordaz's lost pasture and the resulting decreased beef production be offset? In keeping with California's line of logic, those lost resources must be made up for somewhere else in the world. Will it be in the Amazon River basin or the Nigerian jungle, at the expense of sensitive ecosystems? Will the new roads built by the energy companies that now dissect the isthmus lead to additional urban or industrial development, further squeezing out cropland and forcing it somewhere else? Should the carbon emissions associated with these activities be charged to the end use of the electricity generated by the windmills in question? These are the types of questions that biofuels were subjected to in the California LCFS development process, while CARB turned a blind eye toward all other fuels, including wind-generated electricity.

The wind towers being erected on the faraway isthmus in Hawley's article are the same type of windmills that the state of California assumes will spring up across the western U.S. to provide an abundance of power to the millions of electric vehicles that the state believes will be humming along its highways in the very near future (never mind the possible substantial indirect environmental effects associated with electric vehicle lithium-ion batteries). So far, the state has failed miserably in examining the potential direct and indirect impacts of electricity from those wind towers, or any other non-biofuels for that matter.

Hawley's article is an excellent reminder that every decision we make as consumers of energy has indirect effects. While those effects are difficult--if not impossible--to identify and quantify with any degree of acceptable certainty, there is no debate that they exist .

Complexity aside, if policymakers and regulators are compelled to assess the indirect effects of one fuel, they must commit to making serious evaluations of the indirect effects of all fuels.