An open letter to the EPA

Dear EPA officials,

I was quite excited by several headlines this weekend saying that a federal court decision had gone against the ethanol mandate. Ever since the ethanol mandate came into existence, the nation’s corn crop has been divided between food and gasoline. Considering the devastated corn crop from last summer’s drought, the rule forcing gasoline producers to maintain ethanol levels at ten to fifteen percent is expected to result in almost half of the corn crop ending up as ethanol. It would make a lot of sense for the rule to be relaxed this year, if not forever.

But then, I realized that it was only the cellulosic requirement – ethanol or biofuels that came from non-corn sources like agricultural waste and wood chips – that the court overturned. That is not a victory; it is a terrible defeat indeed.

While it was clear that ethanol from corn is definitely a bad idea, ethanol from cellulosic sources was still up for debate, and many research groups have been working to maximize the benefits from cellulosic ethanol. In particular, a pretty high-profile article published in Nature earlier this month highlighted the potential of some marginal lands in Michigan to produce cellulosic crops like switchgrass for advanced, or non-corn-based, ethanol.

Now, that is not to say that advanced ethanol would be better at mitigating greenhouse gases than corn ethanol. The only advantage that advanced ethanol has over corn ethanol is the fact that the sources for advanced ethanol are typically agricultural waste products. They are still limited by the same bottleneck – photosynthesis. Considering that ethanol has an energy content some thirty percent lower than that of gasoline, it is difficult to see greenhouse gas savings coming from the compulsory use of ethanol.

Additionally, now that the court has recognized that advanced ethanol production is not high enough to warrant its presence in the ethanol mandate, would a continued enforcement of the rule cause gasoline producers to turn almost entirely to corn to meet the requirement? That will put even more pressure on the corn supply.

Obviously, I think that the entire rule should be moot, at least for this year to protect the corn and the food supply. But I do understand the empowerment of being able to do something against climate change, and the ethanol mandate has certainly been somewhat of a band-aid on spewing greenhouse gases, albeit an incredibly tiny one. Furthermore, it is undeniable that the ethanol industry has several others linked to it as well, in particular, the enzymes industry that has generated a significant number of jobs and amount of revenue.

So what I think, especially after reading another article published in Environmental Science and Technology earlier this month, is that it might be a good idea to tailor the ethanol mandate. Although the authors strongly pushed for solar energy, right now, it is probably too cost-ineffective to implement rules for electric cars. The line that caught my attention in the article was ‘no single sun-to-wheels pathway has the lowest life cycle fossil fuel requirements everywhere.’

The United States is a very large country with very different resources in different locations. Maybe, instead of a one-size-fits-all solution, what’s needed is a harder look at each state or region’s resources and tailor the band-aid accordingly. Maybe the switchgrass belt, identified in the Environmental Science and Technology publication to be centered in Tennessee and extending to the bordering regions of Arkansas and Missouri, would be a good location to require a higher amount of advanced biofuels compared to others.

Some research groups have also been working on the development of algal biofuels. Although there has been some issues with water and fertilizer requirements, there may be locations where small-scale algal biofuels are ready to go. Small-scale solutions can be solutions too, even if just to keep the industry afloat until advanced biofuels are ready to completely take over the ethanol mandate from corn.

And it might even be possible to work on a program for the development of electric cars in the so-called solar belt, ranging from southern California, Nevada to Arizona and New Mexico. Point is, there are many solutions, and I completely agree with Obama’s ‘all-of-the-above’ energy strategy, but maybe they shouldn’t all apply to the entire country.

One thing should be clear. People should not have to pay more for food because others have to drive their cars, especially in times of economic hardship.

XiaoZhi Lim

Wilted corn in Texas. Image obtained from