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Back in 2007, EPA issued a regulation known as the Renewable Fuel Standard (RFS), requiring billions of gallons of corn ethanol to be blended into the U.S. gasoline supply. This mandate is a continuation of the U.S. biofuel policy, and has been celebrated by environmentalists and GW alarmists as a way of reducing greenhouse gases and lowering our dependence on supposedly dangerous foreign oil.

In October of 2011, the Competitive Enterprise Institute and ActionAid USA petitioned EPA to review its position on the impact of its RFS mandates on world hunger. Since a large portion of available farmland is being used to grow corn for ethanol instead of for food, this lowers the food supplies drastically and in turn drives up prices. Our petition was based on the Data Quality Act, which enables anyone to seek correction of data that has been disseminated by a federal agency. The request argued that the information in EPA’s regulatory analysis and on the agency’s website incorrectly downplayed the impacts of the U.S. mandates on world hunger. To support this claim, CEI and ActionAid cited several studies showing that higher food prices from biofuel mandates have caused malnutrition in developing countries, resulting in nearly 192,000 excess deaths annually.

Not being in much of a hurry to examine if whether it might be partly responsible for such carnage, EPA exceeded its 90-day response deadline-three times. Fourteen months would pass before they finally, in December of 2012, denied the petition.

This delay is particularly ironic since the Obama administration and EPA frequently have complained about the slow pace of Congress, issuing executive orders and fuel economy regulations with the slogan “We Can’t Wait.” Apparently, when it comes to assessing whether their policies are killing people, they can.

EPA claimed that assessing deaths due to biofuel programs was beyond the scope of its analysis, which apparently only focused on the incremental effects of the U.S. biofuel mandate. CEI and ActionAid USA filed a request for reconsideration on March 11, providing new evidence of the policy’s devastating effects on food prices and global hunger. A copy of the request is appended to the end of this post. Given EPA’s alleged “global leadership” role and the fact that people in developing countries spend up to 80 percent of their income on food, the new request shows that the U.S. mandate alone has far-reaching negative implications that EPA should address.

The request was fittingly filed during the Government in the Sunshine Week, a national initiative to promote the importance of open government. However, given EPA’s notorious lack of transparency on other matters, we wonder what effect our request will have on the agency whose motto is “protecting people and the environment.” We have an in-house joke that EPA ought to take that slogan and insert the phrase “but not in that order” to the end of it.

On Sunday, the New York Times ran a story about how ethanol mandates are driving up child malnutrition and hunger in Guatemala.  That country now has the fourth-highest rate of child malnutrition in the entire world (higher than in most war-torn African countries):

With its corn-based diet and proximity to the United States, Central America has long been vulnerable to economic riptides related to the United States’ corn policy. Now that the United States is using 40 percent of its crop to make biofuel, it is not surprising that tortilla prices have doubled in Guatemala, which imports nearly half of its corn.

In a country where most families must spend about two thirds of their income on food, ‘the average Guatemalan is now hungrier because of biofuel development.’. . .Roughly 50 percent of the nation’s children are chronically malnourished, the fourth-highest rate in the world, according to the United Nations.

The American renewable fuel standard mandates that an increasing volume of biofuel be blended into the nation’s vehicle fuel supply each year to reduce carbon dioxide emissions from fossil fuels and to bolster the nation’s energy security. Similarly, by 2020, transportation fuels in Europe will have to contain 10 percent biofuel.

Ethanol and biofuel mandates have shrunk the amount of land used for producing food in countries like Guatemala:

Recent laws in the United States and Europe that mandate the increasing use of biofuel in cars have had far-flung ripple effects, economists say, as land once devoted to growing food for humans is now sometimes more profitably used for churning out vehicle fuel.  In a globalized world, the expansion of the biofuels industry has contributed to spikes in food prices and a shortage of land for food-based agriculture in poor corners of Asia, Africa and Latin America because the raw material is grown wherever it is cheapest.

Many small farmers in Guatemala have been displaced, leaving their children hungry and physically stunted:

in rural areas, subsistence farmers struggle to find a place to sow their seeds. On a recent morning, José Antonio Alvarado was harvesting his corn crop on the narrow median of Highway 2 as trucks zoomed by.  “We’re farming here because there is no other land, and I have to feed my family,” said Mr. Alvarado, pointing to his sons Alejandro and José, who are 4 and 6 but appear to be much younger, a sign of chronic malnutrition.

In 2008, a Washington Post editorial by two prominent environmentalists described how ethanol mandates have harmed the environment and spawned hunger across the world.   In “Ethanol’s Failed Promise,” Lester Pearson and Jonathan Lewis observed that “Turning one-fourth of our corn into fuel is affecting global food prices. U.S. food prices are rising at twice the rate of inflation, hitting the pocketbooks of lower-income Americans and people living on fixed incomes.  .  .Deadly food riots have broken out in dozens of nations in the past few months, most recently in Haiti and Egypt. World Bank President Robert Zoellick warns of a global food emergency.” Moreover, they noted,

food-to-fuel mandates are leading to increased environmental damage. First, producing ethanol requires huge amounts of energy — most of which comes from coal. Second, the production process creates a number of hazardous byproducts. . .Third, food-to-fuel mandates are helping drive up the price of agricultural staples, leading to significant changes in land use with major environmental harm. Here in the United States, farmers are pulling land out of the federal conservation program, threatening fragile habitats. . .Most troubling, though, is that the higher food prices caused in large part by food-to-fuel mandates create incentives for global deforestation, including in the Amazon basin. As Time Magazine reported this month, huge swaths of forest are being cleared for agricultural development. The result is devastating: We lose an ecological treasure and critical habitat for endangered species, as well as the world’s largest ‘carbon sink.’ And when the forests are cleared and the land plowed for farming, the carbon that had been sequestered in the plants and soil is released. Princeton scholar Tim Searchinger has modeled this impact and reports in Science magazine that the net impact of the food-to-fuel push will be an increase in global carbon emissions — and thus a catalyst for climate change.

In Human Events, Deroy Murdock chronicled how rising food prices resulting from ethanol forced starving Haitians to literally eat dirt (dirt cookies made of vegetable oil, salt, and dirt), and fueled violent protests in unstable “powder kegs” like Pakistan and Egypt.

The Obama Administration has forced up the ethanol content of gasoline, heedless of the fact that ethanol makes gas costlier and dirtier, increases ozone pollution, and increases the death toll from smog and air pollution. Ethanol mandates also result in deforestation, soil erosion, and water pollution.  By driving up food prices, they have fueled Islamic extremism in Afghanistan, Egypt, Yemen and other poor countries in the Middle East.

The Obama Administration persists in supporting ethanol mandates despite widespread criticism from experts across the political spectrum.  The legislation in Congress that it backed in the name of fighting global warming contained ethanol subsidies, even though ethanol subsidies have been linked to famine, hunger, food riots, and political unrest in poor countries.  That “cap-and-trade” legislation contained so many special-interest giveaways that it would have fleeced American consumers without helping the environment, even while driving industry overseas to countries with less environmental protections.  (In 2008, Obama admitted that “under my plan of a cap and trade system, electricity rates would necessarily skyrocket.”)

Although harvesting season for corn is ongoing, there isn’t much hope from the Agriculture Department for a strong season. We know that production levels are already down 13 percent from 2011. Adding to the hurt caused by this year’s devastating drought on corn is the Renewable Fuel Standard (RFS). Under the Clean Air Act the RFS requires that in 2012, refiners sell 13.2 billion gallons of corn ethanol – this number equates to roughly 4.7 billion bushels of U.S. corn.  Corn estimates were down to 10.8 billion bushels last month; right now that means that at least 40 percent of corn production is being forced into the ethanol market.

The decline in corn production is already leading to rising prices in various farming sectors — cattle, swine, poultry — that use corn as feed. These economic effects will be intensified by the diversion of corn supply by ethanol requirements. This has prompted Congress, National Associations, and now individual state Governors to urge the EPA to permit a waiver for ethanol requirements in 2012-2013 under the Renewable Fuel Standard.

In Governor Deal’s August 20th letter to EPA Administrator Lisa Jackson describes the importance and scale of the livestock agriculture to the Georgia economy:

As Georgia’s largest industry, agriculture accounts for over 15.7 percent of the state’s economy in terms of sales and output and represents 11.2 percent of the state’s value added production. Georgia agriculture has an annual impact of $68.9 billion on the state’s economy and provides 380,000 jobs to citizens of the state.  Poultry and livestock are critically important components of the state’s economy, representing over 50 percent of Georgia’s farm gate value, while broilers alone account for over 40 percent of farm gate value. From a national perspective, Georgia ranks first in broiler production and third in value of eggs produced. For Georgia, the poultry industry alone accounts for over $20 billion in annual economic impact, and an estimated 98,000 jobs depend on poultry directly or indirectly.

He also points out the grueling effects the Renewable Fuel Standard will have on not only Georgia, but the whole country coupled with this drought:

According to the University of Georgia, the state’s poultry producers are spending $1.4 million extra per day on corn due to the drought and the upward pressure on corn prices caused by the demand created by the RFS for ethanol. This translates to over $516 million per year if these market conditions continue. These additional input costs are not sustainable, and I urge you to consider all options available to the agency to provide some relief in the coming year.

The ultimate impact on consumers in Georgia and throughout the United States in the form of higher food prices must also be fully considered. A recent analysis confirmed that food inflation, particularly for those food categories most impacted by grain costs, has risen much faster than overall inflation since 2005. The reality of this current crisis is that consumers will have to pay more for protein and other food items, or they will simply not be able to afford certain food items.

As I have outlined, Georgia is experiencing severe economic harm during this crisis, and important economic sectors in the state are in serious economic jeopardy. This harm is precisely of the type, character and extent that Congress envisioned when it granted EPA authority to waive RFS applicable volumes in both the original RFS enacted in 2005 and in the substantial revisions made to the law in 2007 by the Energy Independence and Security Act.

Other states such as; Arkansas, Texas, North Carolina, and others have also filled letter with Administrator Jackson.

On August 20th the EPA opened a 30 day comment period for the public on the waiver requests specifically from the Governors of Arkansas and North Carolina. This week, the comment period was extended another 30 days. After the comment period ends, EPA is afforded time to consider the public’s input. As a result, EPA won’t have to make a decision until after the election. How convenient.

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