Consequential Life Cycle Analysis: Use for Warning, Not for Rule-Making
by Dev Shrestha and Jon Van Gerpen, Bioediesel Education Program, University of Idaho
In a recent Tech Note, we clarified the differences between attributional life cycle analysis (ALCA) and consequential life cycle analysis (CLCA). Briefly, ALCA is a “business-as-usual” scenario analyzing current practices, and does not include indirect effects such as indirect land use change. CLCA analyzes potential changes in a system, and can include indirect effects.
In the Tech Note, we explained why the Environmental Protection Agency came out in 2009 and 2010 with two sets of dramatically different numbers for greenhouse gas emissions of soy biodiesel. In May of 2009, the EPA said that soy biodiesel achieved a 22% reduction of greenhouse gases over petro-diesel. In February of 2010, the EPA raised this number to 57%. The Tech Note points out that changing the assumptions of a consequential life cycle analysis can dramatically change the results.
Some have suggested that inherent uncertainties in consequential life cycle analysis demonstrate its lack of scientific rigor. These people suggest that CLCA should not be used to calculate the effects of indirect land use change.
We think that if it is used carefully, there is a place for CLCA in the process of making decisions about environmental options. However, it is important to emphasize the appropriate use of consequential life cycle analysis. Consequential life cycle analysis should not be used for regulatory purposes, to pass judgment on certain biofuels, or to prevent certain biofuels from being able to participate in government mandates such as the RFS2 program. Instead, CLCA should be used as a warning system.
Currently, many people do not realize how uncertain and variable a consequential life cycle analysis can be. For example, the incorporation of indirect land use change into CLCA typically requires models to forecast economic interactions between countries. These economic interactions are very difficult to estimate. This kind of consequential LCA is similar to such challenging activities as predicting the performance of the stock market.
People may take the numbers from a consequential life cycle analysis as though these numbers were set in stone, and compare numbers from one CLCA to another CLCA without understanding what was involved in deriving these numbers. Then, they use the numbers to pass judgment on a particular fuel, saying that, for example, biodiesel from a particular feedstock is “bad” or “good” based on these numbers.
The main thing to understand is that it may not be appropriate to compare numbers from two consequential life cycle analyses to decide which is “better.” For example, a consequential LCA for soybean biodiesel production is often compared to a consequential LCA for algae biodiesel, which is not yet commercially produced. This is not necessarily a valid comparison, because there are so many unknowns related to the indirect land use changes from soy biodiesel. There are also unknowns associated with the production of algae biodiesel, since no commercial production exists. A consequential life cycle analysis of algae biodiesel is based on a hypothetical production scenario from smaller model plants, theoretical process kinetics, and upscaled laboratory data.
If people conclude from this that algae biodiesel is better, this may not be a valid conclusion, because the CLCA numbers for both soy biodiesel and algae biodiesel are derived very differently based on different sets of assumptions. Instead of comparing two perhaps highly unreliable CLCAs to decide which is “better,” policy makers should use each CLCA separately to assess the potential benefits and drawbacks of each. If an option looks promising based on a CLCA, policy makers might cautiously proceed to support it and re-evaluate the scenario as more reliable numbers are available.
Two CLCAs can be appropriately compared when they both deal with the same system, with a single variable changed. For example, a CLCA for soy biodiesel based on one level of soy yield can be compared to a CLCA for soy biodiesel based on a different soy yield. This kind of comparison can help policy makers understand the potential impact of their decisions.
Just as it may not be appropriate to compare two CLCAs to decide which is better, it also may not be appropriate to compare numbers from an attributional LCA to a consequential LCA. While the EPA included indirect effects in the biofuels life cycle analysis, they did not include indirect effects in the petroleum fuels life cycle analysis. The EPA states that they considered including indirect land use change caused by the development of Canadian tar sands, but decided that this land change would have a “negligible” effect on overall GHG emissions, and therefore did not include it (p. 467, Renewable Fuel Standard Program Regulatory Impact Analysis). The EPA also did not consider other indirect effects such as oil spills. Therefore, an attributional LCA of petroleum-based fuels is being compared to a consequential LCA of biofuels, with potentially misleading results.
The problem is, Congress has mandated that the CLCA for soy biodiesel (and biodiesel from other feedstocks) be compared to the ALCA for petroleum diesel. The EPA is endeavoring to comply with this law. We think the law should be changed to take out the requirement to incorporate indirect land use change into the biofuels analyses. The ALCA for biodiesel should be compared to the ALCA for petroleum diesel.
However, we don’t want to inadvertently harm the world’s forests and grasslands by ignoring potential threats. So, how can we avoid this? A consequential life cycle analysis for a biofuel should be used as a warning about possible outcomes, rather than a tool to kill policies or technologies not favored by the analyst. Results of consequential LCA should always be posed as “if-then” statements. “If we do this, then we need to take some action to ensure that the undesirable consequences don’t happen.”
If consequential LCA were seen as a source of warning signals rather than the final word on the energy and environmental impact of a particular course of action, it would gain more support and credibility. Indirect land use change arguments, which are inherently based on consequential LCA, rather than being seen as obstacles to progress, would be seen as triggers for actions to monitor and protect sensitive lands around the world. It would be more effective to take steps to directly protect the world’s rainforests and other sensitive lands, instead of relying on the elimination of biofuels mandates to somehow indirectly save the forests.
In a recent Tech Note, we clarified the differences between attributional life cycle analysis (ALCA) and consequential life cycle analysis (CLCA). Briefly, ALCA is a “business-as-usual” scenario analyzing current practices, and does not include indirect effects such as indirect land use change. CLCA analyzes potential changes in a system, and can include indirect effects.
In the Tech Note, we explained why the Environmental Protection Agency came out in 2009 and 2010 with two sets of dramatically different numbers for greenhouse gas emissions of soy biodiesel. In May of 2009, the EPA said that soy biodiesel achieved a 22% reduction of greenhouse gases over petro-diesel. In February of 2010, the EPA raised this number to 57%. The Tech Note points out that changing the assumptions of a consequential life cycle analysis can dramatically change the results.
Some have suggested that inherent uncertainties in consequential life cycle analysis demonstrate its lack of scientific rigor. These people suggest that CLCA should not be used to calculate the effects of indirect land use change.
We think that if it is used carefully, there is a place for CLCA in the process of making decisions about environmental options. However, it is important to emphasize the appropriate use of consequential life cycle analysis. Consequential life cycle analysis should not be used for regulatory purposes, to pass judgment on certain biofuels, or to prevent certain biofuels from being able to participate in government mandates such as the RFS2 program. Instead, CLCA should be used as a warning system.
Currently, many people do not realize how uncertain and variable a consequential life cycle analysis can be. For example, the incorporation of indirect land use change into CLCA typically requires models to forecast economic interactions between countries. These economic interactions are very difficult to estimate. This kind of consequential LCA is similar to such challenging activities as predicting the performance of the stock market.
People may take the numbers from a consequential life cycle analysis as though these numbers were set in stone, and compare numbers from one CLCA to another CLCA without understanding what was involved in deriving these numbers. Then, they use the numbers to pass judgment on a particular fuel, saying that, for example, biodiesel from a particular feedstock is “bad” or “good” based on these numbers.
The main thing to understand is that it may not be appropriate to compare numbers from two consequential life cycle analyses to decide which is “better.” For example, a consequential LCA for soybean biodiesel production is often compared to a consequential LCA for algae biodiesel, which is not yet commercially produced. This is not necessarily a valid comparison, because there are so many unknowns related to the indirect land use changes from soy biodiesel. There are also unknowns associated with the production of algae biodiesel, since no commercial production exists. A consequential life cycle analysis of algae biodiesel is based on a hypothetical production scenario from smaller model plants, theoretical process kinetics, and upscaled laboratory data.
If people conclude from this that algae biodiesel is better, this may not be a valid conclusion, because the CLCA numbers for both soy biodiesel and algae biodiesel are derived very differently based on different sets of assumptions. Instead of comparing two perhaps highly unreliable CLCAs to decide which is “better,” policy makers should use each CLCA separately to assess the potential benefits and drawbacks of each. If an option looks promising based on a CLCA, policy makers might cautiously proceed to support it and re-evaluate the scenario as more reliable numbers are available.
Two CLCAs can be appropriately compared when they both deal with the same system, with a single variable changed. For example, a CLCA for soy biodiesel based on one level of soy yield can be compared to a CLCA for soy biodiesel based on a different soy yield. This kind of comparison can help policy makers understand the potential impact of their decisions.
Just as it may not be appropriate to compare two CLCAs to decide which is better, it also may not be appropriate to compare numbers from an attributional LCA to a consequential LCA. While the EPA included indirect effects in the biofuels life cycle analysis, they did not include indirect effects in the petroleum fuels life cycle analysis. The EPA states that they considered including indirect land use change caused by the development of Canadian tar sands, but decided that this land change would have a “negligible” effect on overall GHG emissions, and therefore did not include it (p. 467, Renewable Fuel Standard Program Regulatory Impact Analysis). The EPA also did not consider other indirect effects such as oil spills. Therefore, an attributional LCA of petroleum-based fuels is being compared to a consequential LCA of biofuels, with potentially misleading results.
The problem is, Congress has mandated that the CLCA for soy biodiesel (and biodiesel from other feedstocks) be compared to the ALCA for petroleum diesel. The EPA is endeavoring to comply with this law. We think the law should be changed to take out the requirement to incorporate indirect land use change into the biofuels analyses. The ALCA for biodiesel should be compared to the ALCA for petroleum diesel.
However, we don’t want to inadvertently harm the world’s forests and grasslands by ignoring potential threats. So, how can we avoid this? A consequential life cycle analysis for a biofuel should be used as a warning about possible outcomes, rather than a tool to kill policies or technologies not favored by the analyst. Results of consequential LCA should always be posed as “if-then” statements. “If we do this, then we need to take some action to ensure that the undesirable consequences don’t happen.”
If consequential LCA were seen as a source of warning signals rather than the final word on the energy and environmental impact of a particular course of action, it would gain more support and credibility. Indirect land use change arguments, which are inherently based on consequential LCA, rather than being seen as obstacles to progress, would be seen as triggers for actions to monitor and protect sensitive lands around the world. It would be more effective to take steps to directly protect the world’s rainforests and other sensitive lands, instead of relying on the elimination of biofuels mandates to somehow indirectly save the forests.
