Image via creative commons.

Dirty electricity isn’t renewable fuel

by Sarah Lutz, climate campaigner

Renewable Fuel Standard 101

This would be the right choice for communities, for the climate, and for a future that runs on truly sustainable EVs.

Increasing the air, water, and soil pollution around frontline communities, in the name of transitioning away from fossil fuels, is wildly inconsistent with the tenants of Environmental Justice.

  • Wood Biomass: At the smokestack, wood biomass is one of the dirtiest sources of energy, producing more carbon and toxic pollutants than even coal. Many biomass plants burn whole trees, tires, and treated lumber such as creosote railroad ties, resulting in ozone and PM2.5 precursors, including nitrogen oxides, volatile organic compounds, heavy metals, and particulate matter. The supply chain for wood biomass results in additional particulate matter, nitrogen oxides, carbon monoxide, and volatile organic compounds. Sourcing wood for incineration and wood pellet production has led to clear-cutting hardwood forests, driving a loss of biodiversity and leaving surrounding communities at increased risk of flooding.
  • Factory farm gas: The liquefied manure management system commonly used by factory farm operations monetizes football field-sized lagoons of manure, which contain high concentrations of nitrogen, phosphorus, pathogens, and heavy metals. These operations expose surrounding communities to harmful concentrations of ammonia, hydrogen sulfide, and volatile organic compounds. This toxic air pollution results in increased cases and severity of respiratory illnesses, as well as nausea, headaches, and other health conditions. The ammonia and hydrogen sulfide emissions from industrial animal facilities have been linked with higher rates of infant mortality and decreased life expectancy. Expansion of factory farm gas will require building out a network of pipelines. Much of the proposed expansion in the southeast of the US would cross fragile ecosystems, such as wetlands in North Carolina, that provide important flooding protection and clean water to nearby communities.
  • Landfill Gas: Monetizing the collection of landfill gas creates the perverse incentive to increase the amount of methane that these landfills would otherwise release, collecting this gas requires abandoning best practices that would normally minimize air pollution. In fact, the IPCC found that as much as 80 percent of the methane generated at landfills escapes into the atmosphere. This methane pollution is compounded by the EPA’s unwillingness to enforce hazardous air pollutants emissions controls on landfills through the Clean Air Act. Communities in the airshed of over 1,000 municipal solid waste landfills breathe dangerous and unlawful volumes of ethyl benzene, toluene, and benzene. Leachate from landfills can carry nitrate, phosphate, ammonium, and oxides into surrounding groundwater. Odor, dust, noise, windblown litter, vermin, and insects plague nearby communities and keep their property values low. Increasing demand for landfill gas through the RFS will further embed these harms.

Who Benefits? Dirty Energy Interests

  • Factory Farmers: The American Biogas Council represents companies that capture methane from garbage dumps and factory farms. Filings show that the trade association has been lobbying both the EPA and Congress around, “ …issues related to the RFS and biogas’ role in the cellulosic category including the electric pathway.” Similarly, the National Milk Producers Federation has declared in its filings that it had “Supported [the] RFS Electricity Pathway to make biogas eligible as a renewable fuel” in lobbying Congress, the EPA, and the US Department of Agriculture. Large, industrial dairy operations with methane digesters are one of the likeliest beneficiaries of an electric RFS.
  • Tree killers: The trade association representing burning woody biomass for electricity has been equally active. In January, filings show that the Biomass Power Association engaged the lobbying firm MGV LLC to advocate around, “Issues related to biomass and other biofuels; issues related to the RFS including the electric pathway; Issues related to recycling organic waste and renewable biofuels.” The Biomass Power Association also reported lobbying directly on the “Renewable Fuel Standard.” In theory, the registered lobbyist is a separate firm called C. Annand LLC, but this would seem to be an entity run by the Biomass Power Association’s current Executive Director, Carrie Annand, a former staffer for the House Energy and Commerce Committee.
  • Charging Stations: Lobby disclosures from Electrify America, a subsidiary of Volkswagen, show a pattern of interest in the RFS electrification pathway since at least 2019. The company was originally created by Volkswagen in the wake of its diesel emissions scandal, when 11 million Volkswagen cars were fitted with cheat devices that allowed them to cheat emissions tests while producing up to 40 times the legal amount of pollution. In its settlement, Volkswagen agreed to spend $2 billion nationwide on clean car infrastructure and created Electrify America to spearhead this investment. Now, this subsidiary has been lobbying for years on the RFS electrification pathway, admitting in lobby filings that it sought to use must-pass spending legislation to force the EPA into approving an electric RFS. Another company, ChargePoint Holdings, which owns one of the largest EV charging networks, has also been lobbying Congress on the RFS. It is reasonable to assume that an EV charging network’s interest in the RFS would be the electrification pathway.

Where will Administrator Regan fall on Environmental Justice?



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