The effectiveness and efficiency of regulatory and other policy approaches intended to reduce the greenhouse gas emissions from transportation fuels can hinge on the fuel life-cycle analysis (LCA). Emerging regulation has raised urgent questions about both definition and evaluation of life-cycle emissions, and the effectiveness, efficiency and equity of regulatory approaches which use such analyses. This paper focuses on the LCA for transportation fuels from unconventional hydrocarbon sources and associated regulatory issues and implications, and examines these in the context of experience gained in the study of conventional hydrocarbon sources, biofuels, electric vehicles, and other alternatives. Critical issues arise in the regulatory use of life-cycle emissions analysis when comparing different types of fuels, for different types of vehicles, including: 1. Uncertainty in life-cycle emissions – Differences in estimates of the life-cycle emissions for one fuel can exceed the differences in estimates for different fuels; boundaries, accounting, aggregation and accuracy of LCA are each critical and determining issues in its application in regulations. 2. Flexible pathways – In order to incentivize innovation in fuel production, many pathways (with the ability to be altered) are needed to map production from each individual agent, who will each have their own process. 3. Energy security – Regulation to lower the life-cycle emissions is often also intended to improve energy security (e.g. by increasing supplies of indigenous biofuels); however, in the case of unconventional sources of oil such regulations may aggravate energy security. For complex policies, such as those involving LCA – especially where there are international ramifications – much broader dialogue is needed to improve the policy’s effectiveness, efficiency and ultimately credibility.
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