Governors' Biofuels Coalition

DOE’s Advanced Research Projects Agency-Energy (ARPA-E) late last month unveiled its long-awaited programmatic environmental impact statement (PEIS) for the so-called Engineered High-Energy Crop (EHEC) Programs which is intended to provide financial assistance by DOE or other federal state agencies for “confined field trials” to evaluate the viability of biofuels feedstocks, according to a Jan. 16 Federal Register notice.

The draft EIS concludes that EHEC programs could generate “net energy savings and greater soil carbon sequestration” as lands are converted to cultivate the crops, and that the climate change impacts could be “locally or regionally beneficial.” The document, however, also acknowledges in general terms that cultivation of biofuels crops constrain water resources in areas that may face water challenges in the wake of global climate change.

The draft PEIS examined several possible sizes for field trials including field trials as small as five acres and as high as 15,000 acres.

It also acknowledges a number of concerns identified during the scoping process including calls for rigorous screening and other protocols in all field trials to manage risk; concerns over potential indirect impacts on water quality, wetlands, and other resources; and potential for crop cultivation to displace land used for food production.

The notice formally announces a Feb. 17 public meeting in Washington DC on the issue, as well as Feb. 24 and Feb. 26 web-based public hearings.

DOE will accept public comments on the draft PEIS until March 17.

The review comes amid ongoing concerns from environmental groups who have objected to approving or developing new fuel feedstocks to aid compliance with EPA’s renewable fuel standard without adequate safeguards to avoid invasive species risks — even if those crops are intended to curb greenhouse gases (GHGs).

ARPA-E’s program envisions efforts to develop engineered high energy crops for specific use as fuel feedstocks, an effort that the draft PEIS says would help support efforts to meet biofuel targets in the the 2007 energy law, including for advanced biofuels with a lower carbon content.

“Biofuel engineering utilizes novel processes or alternative pathways to optimize the plants for energy capture and conversion, thus allowing more energy (fuels or fuel precursors) to be stored, absorbed, converted, and extracted,” according to the draft document.

A main component of the proposed programs would be providing financial assistance to conduct field trials to test the effectiveness of EHECs in the Southeastern United States, specifically in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee and Virginia, according to the Register notice.

Invasive Species

Environmental groups have already raised concerns during the scoping process for the environmental review over whether adequate precautions are in place to prevent spread of invasive species.

The National Wildlife Federation, Environmental Law Institute, Southern Alliance for Clean Energy and other groups in joint 2013 scoping comments call for discussion of several alternatives to mitigate endangered species risks, including consideration of mandatory management measures to reduce the risk that crops from field trials would become established in the wild.

They also discussed possible insurance bonds or other financial assurance mechanisms as ways to ensure funds are available to eradicate potential invasive species after the end of the projects.

Sources familiar with the concerns say groups are still reviewing the draft PEIS, but are likely to revisit their invasive species concerns over that issue in their pending comments to the department.

It is less clear whether groups will engage on the GHG implications of the programs, which are essentially research efforts, even as questions persist over the lifecycle impacts of widespread deployment of biofuels generally.