From:	Eric Brooks [brookse@igc.org]
Sent:	Friday, July 06, 2012 3:41 PM
To:	Gravanis Ruth; Wald, Johanna; Buerkle, Rachel
Cc:	Fish, Monica
Subject:	Public Comment To All SF Environment Commissioners On Biofuels (for 
July 9 Meeting)
Attachments:	Biofuels_ILUC_Analysis_EU.pdf; Tallow_Biodiesel_Report_AEA.pdf; 
GHG_Emissions_From_Shale_Gas_April_2010.pdf

Hi Johanna, Ruth, and Rachel,

Please read these comments and attachments, and also forward them as public 
comment to all SF Dept of Environment commissioners and staff. 
These are extremely important to your July 9 discussion item on biofuels (item 
5 on the Environment Commission agenda). Note: I have also copied Monica Fish 
on this email but she is out of town and therefore cannot forward it herself.

Hello SF Environment Commissioners and staff,

I have just read with interest, but also deep concern, your staff's report on 
biofuels.

The report was very troubling in that, though it did indicate that there are 
problems with using various biofuels, and did touch very briefly on land use 
change issues, it did not have a more up to date and critical analysis based 
on new European evidence compiled in the last few years showing widespread 
dramatic problems with biodiesel and other biofuel mandates. This new 
information and analysis is now indicating that biodiesel made and used in 
high volumes from any feedstock -including- animal tallow, causes, across the 
board, far more environmental problems and greenhouse gas emissions than the 
petroleum diesel that it is meant to replace. Finally, your staff's report 
also, in its discussions of biomethane, unfortunately completely fails to 
assess methane's most important impact on the atmosphere - that of methane 
leakage, a problem which makes the increased production of biomethane as a 
fuel source highly questionable.

(Note: for detailed basic fundamentals on why all biofuels are nearly always 
highly destructive, see http://biofuelwatch.org.uk/ )

More specifically and importantly for your biofuels discussion item this 
coming week, please note the attached reports and my comments about them 
below, which are vital to making educated decisions about biofuels.

BIOFUELS In General (European Mandates)

See the summary on page 21 of the attached document 
'Biofuels_ILUC_Analysis_EU' which is very recent, and is the first report of 
its kind to comprehensively examine Indirect Land Use Change
(ILUC) impacts of biofuels for the European Union. It states clearly that 
greenhouse gas emissions will increase dramatically due to biodiesel and other 
biofuel mandates and use.

BIODIESEL (Especially Animal Tallow Based Biodiesel)

In relation to animal tallow, which is mentioned in your staff's report as a 
preferred feedstock for biodiesel, please note that reliance on animal tallow 
and 'yellow grease' as biodiesel feedstocks will not solve
-any- of the ILUC problems generated by crop feedstocks like soy and palm oils 
for one key reason - nearly all tallows and yellow grease are
-already- used to make other products like soaps, cosmetics, paints, animal 
feed and pet foods. None of these greases are actually 'waste' as is often 
deceptively claimed by biodiesel advocates. The reason this scenario will 
generate the same ILUC problems as crop fuel feedstocks is obvious; once 
tallow and yellow grease are being used for diesel production, these other 
non-fuel product industries will be forced to then turn to crop oils for the 
fat sources that they -must- have to produce their products, and hence the 
exact same ILUC problems will be triggered, and at minimum, at the same scale. 
And the problems triggered could in fact become even worse if many of these 
industries were to make the very likely choice of switching to palm oil which 
has incredibly damaging climate impacts that are worse than fossil fuel 
impacts.

For proof of this reality, see attached an analysis done for the UK government 
on possible impacts of tallow biodiesel production in Britain entitled 
'Tallow_Biodiesel_Report_AEA'. Note on page VI (page 6 of the
pdf) the executive summary makes clear that all rendered tallow is currently 
used. None of it is landfilled. (Some biodiesel advocates have falsely claimed 
that these fats would otherwise be landfilled.)

For local validation of this as a fundamental condition here in the Bay Area, 
I personally called the Darling International rendering plant in San Francisco 
and verified that likewise, all of its rendered tallow is used by current 
industries. None of it is landfilled.

In light of this, the only biodiesel production which makes environmental 
sense is our far smaller scale local Greasecycle program, which legitimately 
processes into biodiesel, local wastes that would clog sewer systems, but 
which cannot replace more than 1% of local petroleum diesel uses.

BIOMETHANE

As I stated above, your staff's analysis unfortunately completely missed the 
most important impact of both biomethane and natural gas production and use; 
the problem of methane leakage.

Please see the attached two page report 
'GHG_Emissions_From_Shale_Gas_April_2010'. Note that even though the primary 
purpose of this paper is to show how much worse than coal, fracked shale gas 
can be, the report also covers basic emissions comparisons between methane and 
other liquid vehicle fuels, and the analysis makes clear that a switch to 
methane as vehicle fuel would be of very questionable benefit when compared to 
other vehicle fuels, due to the leakage problem. Therefore, while it may a 
very good idea to capture and burn methane already being produced by our 
wastewater processing operations (in order to reduce the higher impact of that 
methane as a greenhouse gas by burning it into lower impact CO2), it would be 
a mistake to purposely -increase- methane by ramping up its production via the 
wastewater program, or by increased processing of other feedstocks like yard, 
food or agricultural wastes. This would trigger the problem of too much of 
this increased methane leaking into the atmosphere thereby simply exacerbating 
the climate crisis.

It is for all these cited reasons, that I strongly urge the City to completely 
abandon all pursuit of large scale biodiesel, biomethane, and other biofuel 
use strategies and mandates, as a failed and inherently environmentally 
destructive model; and to instead more heavily promote a transition to far 
more widespread electric mass transit and rail, along with electric car shares 
and taxis, for both personal transportation and local shipping; at the same 
time putting a much stronger effort into building a local renewable 
electricity infrastructure via methods like Community Choice to provide clean 
power for these new transportation systems.

Thank you for your careful consideration of these comments,

Eric Brooks
415-756-8844