Sustainability Issues in Biomass Feedstock Production: A Policy Perspective - Engineering and Science of Biomass Feedstock Production and Provision - page 229

9.2.1 The United States

9.2.1.1 Federal Policies

Historically, US biofuels policy has relied primarily on corn as an ethanol feed-
stock. Although corn ethanol has served as an engine for rural development, the
environmental implications of conventional corn production [ 4 ] were largely unad-
dressed in government energy policy until the enactment of the Energy Independence
and Security Act of 2007 (EISA) [ 5 ]. In order to satisfy the mandatory blending
levels of “renewable fuels” into transportation fuels, now, for the fi rst time, all bio-
fuels qualifying for EISA's Renewable Fuel Standard (RFS) had to achieve a certain
level of GHG reductions and be derived from certain renewable sources. In addition,
the 2008 Farm Bill established the fi rst supply-side incentive for renewable biomass
through creation of Biomass Crop Assistance Program (BCAP) [ 6 ]. The program
conditions payments on whether the biomass was produced under a conservation
plan [ 7 ]. At the state level, California is in the process of developing biomass sus-
tainability standards to accompany its broader GHG reduction agenda embedded in
programs such as the low-carbon fuel standard (LCFS) [ 8 ]. The following sections
provide, in greater detail, the meaning of these sustainability provisions.

The US Renewable Fuel Standard

EISA increased the mandatory blending of renewable fuels to 36 billion gallons by
2020. Each category of qualifying fuel (renewable fuel, cellulosic ethanol, biomass-
based diesel, and advanced biofuels) must meet minimum threshold GHG emissions
reductions [ 5 ], and obligated parties under RFS must source renewable fuels from
“renewable biomass” [ 5 ]. “Renewability” in the statute focuses on land conversion
prohibitions [ 5 ], limits on biomass sourcing from nonfederal forests, and absolute
bars against harvests from old-growth or late-succession forests and forests with
ecological communities with a certain global or state ranking [ 5 ]. The environmental
protection agency (EPA) is implementing a plan [ 9 ], in response to several instances
of Renewable Identifi cation Number (RIN) fraud [ 10 ], for quality assurance through
independent third parties. EPA notes that the Quality Assurance Program will also
verify that feedstocks are from “renewable biomass” and meet land-use restrictions.
EISA requires the US EPA to report triennially on the environmental impacts of
the RFS [ 5 ]. In February 2011, it issued its fi rst triennial report of the environmental
impacts of the RFS [ 11 ]. EPA acknowledges in its report studies that confi rm com-
modity crop production in the Mississippi watershed results in harmful nitrogen
pollution. It concludes, however, that the effects of biomass cropping are yet to be
fully understood due to the dearth of scientifi c research. Perhaps most signifi cantly,
EPA indicates in the triennial report that it will apply lifecycle analysis (LCA) in the
next triennial report (2014) to determine the full range of environmental effects
within the RFS supply chain. What methodology and data EPA will use, however,
remain unclear.