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Volume XIII, Number 39

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NASEM Finds More Research Necessary to Improve Methods for Estimating Life Cycle of GHG Emissions of Low-Carbon Transportation Fuels

The National Academies of Sciences, Engineering, and Medicine (NASEM) announced on October 19, 2022, the release of a report finding that life cycle assessments (LCA) of transportation fuels are valuable tools for measuring environmental impacts, but uncertainties remain in the current models and further research should be conducted to strengthen their reliability. The report recommends ways to improve models, increase reporting and transparency, perform targeted verification of emissions, and other avenues that will better inform policymaking for reducing greenhouse gas (GHG) emissions from transportation fuels. According to NASEM, LCAs have been increasingly applied in the development of transportation fuel policy to estimate and help reduce GHG emissions from fuels such as electricity, biofuels, synthetic fuels, and hydrogen. NASEM states that the report finds that there is no single LCA method capable of answering all questions related to the climate impacts of a transportation fuel, and that both attributional LCA (ALCA) and consequential LCA (CLCA) have important roles to play. CLCA, which considers the consequences of a policy or decision, such as the market effects of production changes, should be used to understand wide-ranging impacts of proposed changes on net GHG emissions. ALCA, which assigns portions of observed environmental impacts from human activities to specific goods and services, can be used to attribute emissions in well-defined supply chains and help identify opportunities to reduce carbon intensity throughout that supply chain. Hybrid methods that use a combination of process-based and economic input-output methodologies can also be useful in some circumstances. In all cases, modelers should provide transparency, justification, and sensitivity or robustness analysis for modeling choices.

NASEM notes that the report contains a number of other findings and recommendations for assessing the emissions of specific transportation fuels and their feedstocks, including the following for biofuels:

  • Study of land use changes from biofuels has been the topic of intense study over the last decade. Substantial uncertainties remain on key components of the models used to assess the impacts. More research into this area should be supported; and

  • Biofuel production facilities typically produce additional products. The distinction between what qualifies as a co-product, byproduct, or waste can be unclear, creating uncertainty in LCA models.

©2023 Bergeson & Campbell, P.C.National Law Review, Volume XII, Number 306
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About this Author

Lynn Bergeson, Campbell PC, Toxic Substances Control Act Attorney, federal insecticide lawyer, industrial biotechnology legal counsel, Food Drug Administration law
Managing Partner

Lynn L. Bergeson has earned an international reputation for her deep and expansive understanding of the Toxic Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), European Union Registration, Evaluation, Authorization and Restriction of Chemicals (REACH), and especially how these regulatory programs pertain to nanotechnology, industrial biotechnology, synthetic biology, and other emerging transformative technologies. Her knowledge of and involvement in the policy process allows her to develop client-focused strategies whether...

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Carla Hutto, Bergeson Campbell PC environmental law regulatory analyst,Toxic Substances Control Act law attorney
Regulatory Analyst

Since 1996, Carla Hutton has monitored, researched, and written about regulatory and legislative issues that may potentially affect Bergeson & Campbell, P.C. (B&C®) clients. She is responsible for creating a number of monthly and quarterly regulatory updates for B&C's clients, as well as other documents, such as chemical-specific global assessments of regulatory developments and trends. She authors memoranda for B&C clients on regulatory and legislative developments, providing information that is focused, timely and applicable to client...

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