Fuel For Thought
October 2020

United States National Wildlife Federation slams the RFS

▪ United States National Wildlife Federation slams the RFS

The National Wildlife Federation is calling out the EPA on the environmental impacts of the RFS.  The letter references both the air quality impacts of higher RVP and also the water pollution impacts of increased fertilizer use to grow corn. The draft underneath is a copy of the letter US NWF President and CEO Collin O’Mara sent to EPA’s Acting Administrator Andrew Wheeler earlier in the year: 

“Dear Administrator Wheeler: 

As of April 15, 2020, the U.S. Environmental Protection Agency (“EPA”) had before it waivers to the renewable volume obligation (“RVO”) of the federal Renewable Fuel Standard (“RFS”), requested by the Governors of Louisiana, Oklahoma, Pennsylvania, Texas, Utah, and Wyoming. These waiver requests are based upon a demonstration of “severe economic harm” as referenced in Section 211(o)(7) of the Clean Air Act (“the Act”). This provision of the Act also authorizes the EPA to waive the RVO in whole or in part based upon environmental harm inflicted by the RVO. We support the requests made by the Governors and assert environmental harm as an independent basis upon which the Agency must grant relief. 

The RFS currently requires about 19 billion gallons of fuel derived from plants to be blended into gasoline. The overwhelming majority of that fuel is corn ethanol, and today 40 percent of the corn produced in the United States goes into our gas tanks. 

We and others have repeatedly urged your agency to invoke the environmental harm waiver or use its general waiver authority to reduce blending requirements through formal comments and testimony during the annual RVO-setting process. We now take this opportunity to restate our concerns in light of the pending request for relief. 

Habitat Destruction 

It has been more than 10 years since the RFS was created, and in that time there have been mounting reports on a variety of aspects linked to the growing demand for corn and soybeans to produce fuel, documented in your agency’s comprehensive report to Congress in 2018 that outlined the negative environmental impacts of biofuel production. The report laid out in detail how the additional crop demand led farmers to plant millions of new acres – primarily of corn – and how that meant less wildlife habitat and water filtration, and more application and erosion of chemical fertilizers that end up polluting our waterways. While the report declined to draw a direct connection between observed land use change and the RFS, subsequent research establishes that the policy is directly responsible for a substantial portion of this conversion and the related, negative environmental impacts. 

In 2008-2012, 7.3 million acres of land were converted into cropland, of which grasslands accounted for 77 percent of all conversion. The conversion of these native prairies impacts cherished wildlife populations such as waterfowl, prairie chickens, and monarch butterflies and many others through habitat loss, degradation, or fragmentation. Higher RVOs places on these habitats in even greater danger, amounting to a threat of severe environmental damage. 

Land conversion directly destroys important habitats for local and migratory species such as the monarch butterfly. Monarchs migrate throughout the Midwest and rely on a single plant to breed—the milkweed. The milkweed, along with other nectar plants, such as asters and goldenrod, grows abundantly in native grasslands in the Great Plains and Midwest. Native prairie is disappearing faster than any other ecosystem in North America, which is directly contributing to the precipitous decline in monarch butterfly populations. 

Water Quality 

The expansion of row crop agriculture affects aquatic wildlife and human health through agricultural runoff. Runoff pollution occurs when storms send large amounts of water laced with sediment, chemical fertilizers, and pesticides into nearby rivers, lakes, and streams. The added chemicals cause algae to grow rapidly, sometimes producing toxins that are poisonous to humans. When the algae die and decay, it consumes all of the oxygen in the surrounding area, resulting in a dead zone where aquatic wildlife either relocate or perish. As corn fields continue to expand, the intensity and occurrence of annual algal blooms in the Great Lakes have increased, and the dead zone in the Gulf of Mexico continues unabated. 

A University of Wisconsin analysis looking at the Ogallala Aquifer showed that conversion of land into irrigated agriculture accelerated once the RFS spurred a jump in ethanol production. An increase in water use followed. The average amount of irrigated fields in the seven years following creation of the RFS was 9.75 percent higher than the average in the 7 years prior to the program. The year with the most irrigated land in the 7 post-RFS years saw 7.1 percent more irrigated land than the highest year pre-RFS. 

But even in states where agricultural expansion is relatively low, such as in Maryland, excess chemical runoff is impacting aquatic species. For example, in the Chesapeake Bay Watershed, corn plantings expanded by an estimated 340,000 acres from 2002 to 2012. The impact of the additional corn acres in Maryland equates to an additional nine million pounds of nitrogen and 200,000 pounds of phosphorus from fertilizer delivered to the Bay, in contradiction of state and federal efforts to limit these pollutants. 

Global Climate Change 

Amid record-setting wild fires out West, recent climate assessment sounding the alarm about threats from rising global temperatures, and predictions that 2020 could set yet another global temperature record, new research from the University of Wisconsin finds that the federal corn ethanol mandate is contributing to climate change, with land conversion from 2008-2012 releasing as much carbon into the air as 36 coal-fired power plants. 

Air Quality 

As higher RVOs have pushed increasingly larger percentages of ethanol per gallon of fuel, and as the EPA has allowed for summertime use of these higher blends, the RVO has also directly undermined public health. As the Agency is well aware, blending ethanol in gasoline makes the fuel emit more of the gases Page 3 that form smog, and smog makes health issues like asthma worse – especially for the young and the elderly. That’s why the Act restricted the level of ethanol in gasoline to 10 percent of fuel during the summer months, and has made the EPA’s embrace of E-15 during the summer troubling from a legal and public health perspective. 


In short, the corn ethanol mandate has led to the loss of important wildlife habitat, particularly in regions critical for monarch butterflies, ducks and other ground-nesting birds, and many other species— threatening outdoor recreation opportunities as well as the economy. The mandate has also resulted in deteriorated water quality and harmful algal blooms in important surface waters as a result of increased farm runoff. Increasing mandated blending levels increases the potential for further land conversion, presenting a marked threat to the battle against global climate change, with its consequent catastrophic effects on human health and the environment. Higher blends of ethanol necessitated by unrealistic RVOs diminish public health. 

In light of the clear and present danger to the environment, we join with the Governors of six states in asking for a waiver to the RVO.”

▪ API welcomes U.S. EPA’s final rule streamlining fuel quality regulations

The American Petroleum Institute (API) welcomed the release of the U.S. Environmental Protection Agency’s (EPA) final Fuels Regulatory Streamlining Rule, released on 15-October 2020. This final action streamlines and modernises the U.S. federal government’s existing fuel quality regulations. 

API represents all segments of America’s oil and natural gas industry, with more than 600 members producing, processing and distributing most of the nation’s energy. 

The purpose of this action is to update EPA’s existing gasoline, diesel, and other fuel quality regulations to help reduce compliance costs for industry as well as EPA, while improving overall compliance assurance and maintaining environmental performance. 

In this action, EPA has streamlined its existing fuel quality regulations in 40 CFR part 80 by deleting expired provisions and eliminating redundant compliance provisions (e.g., duplicative registration requirements that are required by every EPA fuels program). 

The EPA has also removed unnecessary and out-of-date requirements, and replaced them with a single set of provisions and definitions in 40 CFR part 1090 that apply across all gasoline, diesel, and other fuel quality programs currently under 40 CFR part 80.

“We support EPA’s efforts to modernise its regulations while maintaining the stringency of existing environmental performance standards,” API Vice President of Downstream Policy Ron Chittim. “Removing outdated and duplicative regulations will strengthen oversight and accountability, provide needed certainty for the regulated community and make fuel distribution more efficient in the marketplace.”

The final rule provides an important update to EPA’s fuel quality regulations while maintaining the stringency of existing environmental standards, including:

Removing outdated and duplicative gasoline and diesel fuel regulations and consolidating regulations for EPA’s various fuel programs into a set of rules for regulated entities.

Establishing a vapour pressure limit to distinguish Reformulated Gasoline (RFG) in summer months. In the 25 years since the RFG program was created, new EPA programs have improved gasoline quality and environmental performance to the point that vapour pressure is the only characteristic that distinguishes RFG and non-RFG gasoline in summer months.

Removing location specific gasoline distribution requirements in the non-summer seasons by formally acknowledging all winter gasoline meets Reformulated Gasoline (RFG) standards.

Establishing the National Fuel Sampling Program that will monitor the quality of motor fuels distributed at gasoline stations and ensure they meet the same strict environmental performance standards required as when those fuels left the refinery.

For our readers’ reference, a copy of the final Fuels Regulatory Streamlining Rule can be found under this link.

▪ Life-cycle emissions from the production of electric vehicles

Reference our latest “In Conversion”-issue with Dr Tilak Doshi, the following article has been found in the Forbes newsletter publication on 02-August 2020. The article comprises the author’s view on electric vehicles, their life-cycle emissions and other production-related issues, making this a critical contribution to obtain a complete picture of the topic: 

The Dirty Secrets of ‘Clean’ Electric Vehicles

The widespread view that fossil fuels are “dirty” and renewables such as wind and solar energy and electric vehicles are “clean” has become a fixture of mainstream media and policy assumptions across the political spectrum in developed countries, perhaps with the exception of the Trump-led US administration. Indeed the ultimate question we are led to believe is how quickly can enlightened Western governments, led by an alleged scientific consensus, “decarbonize” with clean energy in a race to save the world from impending climate catastrophe. The ‘net zero by 2050’ mantra, calling for carbon emissions to be completely mitigated within three decades, is now the clarion call by governments and intergovernmental agencies around the developed world, ranging from several EU member states and the UK, to the International Energy Agency and the International Monetary Fund.

Mining out of sight, out of mind

Let’s start with Elon Musk’s Tesla. In an astonishing achievement for a company that has now posted four consecutive quarters of profits, Tesla is now the world’s most valuable automotive company. Demand for EVs is set to soar, as government policies subsidize the purchase of EVs to replace the internal combustion engine of gasoline and diesel-driven cars and as owning a “clean” and “green” car becomes a moral testament to many a virtue-signalling customer.

Yet, if one looks under the hood of “clean energy” battery-driven EVs, the dirt found would surprise most. The most important component in the EV is the lithium-ion rechargeable battery which relies on critical mineral commodities such as cobalt, graphite, lithium, and manganese. Tracing the source of these minerals, in what is called “full-cycle economics”, it becomes apparent that EVs create a trail of dirt from the mining and processing of minerals upstream.

A recent United Nations report warns that the raw materials used in electric car batteries are highly concentrated in a small number of countries where environmental and labour regulations are weak or non-existent. Thus, battery production for EVs is driving a boom in small-scale or “artisanal” cobalt production in the Democratic Republic of Congo which supplies two thirds of global output of the mineral. These artisanal mines, which account for up to a quarter of the country’s production, have been found to be dangerous and employ child labour.

Mindful of what the image of children scrabbling for hand-dug minerals in Africa can do to high tech’s clean and green image, most tech and auto companies using cobalt and other toxic heavy metals avoid direct sourcing from mines. Tesla Inc. TSLA -1.2% struck a deal last month with Swiss-based Glencore Plc to buy as much as 6,000 tons of cobalt annually from the latter’s Congolese mines. While Tesla has said it aims to remove reputational risks associated with sourcing minerals from countries such as the DRC where corruption is rampant, Glencore assures buyers that no hand-dug cobalt is treated at its mechanized mines.

There are 7.2 million battery EVs or about 1% of the total vehicle fleet today. To get an idea of the scale of mining for raw materials involved in replacing the world’s gasoline and diesel-fuelled cars with EVs, we can take the example of the UK as provided by Michael Kelly, the Emeritus Prince Philip Professor of Technology at the University of Cambridge. According to Professor Kelly, if we replace all of the UK vehicle fleet with EVs, assuming they use the most resource-frugal next-generation batteries, we would need the following materials: about twice the annual global production of cobalt; three quarters of the world’s production lithium carbonate; nearly the entire world production of neodymium; and more than half the world’s production of copper in 2018.

And this is just for the UK. Professor Kelly estimates that if we want the whole world to be transported by electric vehicles, the vast increases in the supply of the raw materials listed above would go far beyond known reserves. The environmental and social impact of vastly-expanded mining for these materials — some of which are highly toxic when mined, transported and processed – in countries afflicted by corruption and poor human rights records can only be imagined. The clean and green image of EVs stands in stark contrast to the realities of manufacturing batteries.

Zero Emissions and All That

Proponents of EVs might counter by saying that despite these evident environmental and social problems associated with mining in many third world countries, the case remains that EVs help reduce carbon dioxide emissions associated with the internal combustion engines run on gasoline and diesel fuels. According to the reigning climate change narrative, it is after all carbon dioxide emissions that are threatening environmental catastrophe on a global scale. For the sake of saving the world, the climate crusaders of the richer nations might be willing to ignore the local pollution and human rights violations involved in mining for minerals and rare earths in Africa, China, Latin America and elsewhere.

While one might question the inherent inequity in imposing such a trade-off, the supposed advantages of EVs in emitting lower carbon emissions are overstated according to a peer-reviewed life-cycle study comparing conventional and electric vehicles. To begin with, about half the lifetime carbon-dioxide emissions from an electric car come from the energy used to produce the car, especially in the mining and processing of raw materials needed for the battery. This compares unfavourably with the manufacture of a gasoline-powered car which accounts for 17% of the car’s lifetime carbon-dioxide emissions. When a new EV appears in the show-room, it has already caused 30,000 pounds of carbon-dioxide emission. The equivalent amount for manufacturing a conventional car is 14,000 pounds.

Once on the road, the carbon dioxide emissions of EVs depends on the power-generation fuel used to recharge its battery. If it comes mostly from coal-fired power plants, it will lead to about 15 ounces of carbon-dioxide for every mile it is driven—three ounces more than a similar gasoline-powered car. Even without reference to the source of electricity used for battery charging, if an EV is driven 50,000 miles over its lifetime, the huge initial emissions from its manufacture means the EV will actually have put more carbon-dioxide in the atmosphere than a similar-size gasoline-powered car driven the same number of miles. Even if the EV is driven for 90,000 miles and the battery is charged by cleaner natural-gas fuelled power stations, it will cause just 24% less carbon-dioxide emission than a gasoline-powered car. As the sceptical environmentalist Bjorn Lomborg puts it, “This is a far cry from ‘zero emissions’".

As most ordinary people mindful of keeping within modest budgets choose affordable gasoline or diesel-powered cars, experts and policy advisors the world over have felt compelled to tilt the playing field in favour of EVs. EV subsidies are regressive: given their high upfront cost, EVs are only affordable for high-income households. It is egregious that EV subsides are funded by the average tax-payer so that the rich can buy their EVs at subsidized prices. 

The determination not to know or to look away when the facts assail our beliefs is an enduring frailty of human nature. The tendency towards group think and confirmation bias, and the will to affirm the “scientific consensus” and marginalize sceptics, are rife in considerations by the so-called experts committed to advocating their favourite cause. In the case of EVs, the dirty secrets of “clean energy” should seem apparent to all but, alas, there are none as blind as those who will not see.

▪ India's coal investment deeply troubling: UN

Referring to the above article, the following newswire addresses the concerns raised on Asian nations, ignoring CO2 and other pollution from mining for power generation. The report was found in Singapore’s Straits Times on 29-August 2020. 

UN chief urges Delhi to end fossil fuel subsidies; India set for first commercial coal mine auction

The United Nations chief yesterday called India's growing investment in coal "deeply troubling" and warned that expanding fossil fuel subsidies is "a human disaster and bad economics" that only means more deaths and rising healthcare costs.

UN Secretary-General Antonio Guterres' remarks, made during an online lecture held by The Energy and Resources Institute in Bangalore, come as India prepares to hold its first commercial coal mine auction in October. The government has said auctioning 41 coal blocks is part of India's stimulus for economic recovery from Covid-19. But climate change activists and states with coal reserves have opposed the auctions. India's major coal investor Adani Group will sit out the auction.

Mr Guterres said it makes "no commercial sense" to double down on domestic coal and open up coal auctions. As the cost of renewables falls, and 39 per cent of coal plants become uncompetitive - some 60 per cent could become so in 2022 - the world's largest investors are increasingly abandoning coal, he added.

India is the world's third largest emitter of greenhouse gases after China and the United States.

Coal provides about half of India's commercial primary energy supply and is the dominant fuel for power production. It accounts for 80 per cent of all industrial emissions.

India has committed to making clean renewable energy 40 per cent of its energy mix by 2040 and last year, its spending on solar energy surpassed that on coal-fired power generation for the first time.

"Yet, here in India, subsidies for fossil fuels are still some seven times more than subsidies for clean energy," said Mr Guterres. Many Indian coal plants are financially distressed, and ready to be overtaken by renewables and clean coal plants.

The UN chief spoke of India's role in staving off the threat of climate change. This meant "ending fossil fuel subsidies, placing a price on carbon pollution and committing to no new coal after 2020," he added.

Twenty top business leaders from India have signed a statement asking the government to accelerate the move away from coal, support electric vehicles, and pioneer "green industrialisation".

India's central bank, in its latest annual economic outlook, said the impacts of climate change would be the severest and India would need an appropriate framework to manage financial risks from worsening and erratic weather conditions. India was hit by eight cyclones last year while floods have already devastated three states this year.

Experts expect coal to dominate the power economy at least until 2030. They say that after years of stitching together a clean coal policy, India has undone these plans.

On May 21, it reversed a January 2014 notification that required thermal power plants to use coal with less than 34 per cent ash content. New rules allow power plants to use low-grade Indian coal that produces more fly ash, as long as they meet emissions norms and control pollution.

Senior researchers Kanchi Kohli and Manju Menon wrote in a Centre for Policy Research report: "By refusing to remedy the governance problems of coal use ... the environment ministry has put on the line the lives of the poorest people residing in the country's coal enclaves."

Mr Guterres had this advice for India: "Do not bail out polluting industries. End fossil fuel subsidies."

▪ UAE's ADNOC to explore clean energy expansion, CEO says

Abu Dhabi National Oil Company (ADNOC) will look at expanding into clean energy, with investments in hydrogen an area of interest for the oil producer, chief executive officer Sultan al-Jaber said at the recent Energy Intelligence Forum. "We are pursuing hydrogen as a potential new venture as part of clean energy and clean technology strategy," al-Jaber told the forum. 

Hydrogen has long-been touted as a potential clean fuel as it only emits water vapour but it has failed to gain traction, mainly because of historically high production, transportation and storage costs. But the oil company expects that hydrocarbons will remain at the core of its business. "By 2030, oil and gas will remain at the heart of ADNOC's business model," al-Jaber said. He said that even in the most fast-pace energy transition scenarios, the world would continue to get more than half of its energy needs from oil and gas for many decades to come. The company is also sticking to its strategy of reaching an oil production capacity of 5 million barrels per day by 2030, al-Jaber said. He said that the oil market had "clearly tightened," and he remained cautiously optimistic, adding that it was still important to keep a close eye on the new COVID-19 movement restrictions and their impact on economic recovery.

▪ Tougher emissions target could spur Japan refiners' shift to clean energy

Japanese oil refiners may accelerate efforts to make cleaner fuels such as hydrogen if the government sets a more ambitious goal to achieve zero emissions by 2050, the head of the Petroleum Association of Japan (PAJ) said in early October. "If the government upgrades its 2050 carbon emission goal to zero from an 80% reduction now, refiners may speed up their efforts to make cleaner energy, using more renewable energy and hydrogen," PAJ President Tsutomu Sugimori told a news conference. According to a newswire published by Nikkei, the Japanese government will pledge to reduce greenhouse gas emissions to net zero by 2050. 

Sugimori, who is also chairman of Eneos Holdings Inc, Japan's biggest oil refiner, said gasoline demand is gradually recovering from a slump caused by the COVID-19 pandemic earlier this year, although long term it will be on a downtrend due to a falling and ageing population. Eneos, formerly JXTG, unveiled last year its long-term strategy with an assumption that domestic oil demand would halve by 2040, or fall 2% annually. Sugimori said demand could now decline more rapidly as a result of the pandemic. "It depends on how much demand we see after the pandemic, but the expected drop in domestic oil demand may be faster than we had anticipated," Sugimori said. "To reflect such a possibility, refiners will need to think about their production capacity and structure," he said, without elaborating. He also said that Japanese refiners' kerosene output and an inventory build by users and dealers are on track in October to meet winter demand, adding that whether or not Japan needs to import kerosene this winter will depend on temperatures.

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