Biofuel Producers Give EPA an Earful on Renewable Fuel Standard

The proposed revisions to the National Renewable Fuel Standard program, commonly called RFS-2, are required by the Energy Independence and Security Act of 2007. They will apply to domestic and foreign producers and importers of renewable fuels.

The revisions establish new volume standards for cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel that must be used in transportation fuel each year.

The revised requirements also include new definitions and criteria for both renewable fuels and the feedstocks used to produce them, including new greenhouse gas emission thresholds for renewable fuels.

And the law requires the EPA to consider indirect greenhouse gas emissions when calculating a renewable fuel's emission profile. Called emissions from indirect land use change, these are greenhouse gases that would have been absorbed by forests or other vegetation on lands that are cleared to grow biofuel crops.

Cornfields are the source of most of today's ethanol. (Photo by Scott Bauer courtesy USDA)

An ethanol industry representative told the hearing that the EPA is making a mistake in the methods it is using to calculate emissions from indirect land use change.

Bob Dinneen, president and CEO of the Renewable Fuels Association, the trade association of the U.S. ethanol industry, said, "There is simply no evidence that biofuel production in the U.S. has significant influence over land use decisions in other countries, and we have deep concerns regarding the EPA's methodology."

"According to EPA's own analysis," Dinneen testified today, "typical corn ethanol reduces greenhouse gases 61 percent compared to gasoline when all the emissions directly related to the supply chain are accounted for. But when 'guesstimated' international indirect land use change emissions are tacked on, EPA suggests that same gallon of ethanol only offers a 16 percent greenhouse gases reduction."

Dinneen said there is too much "uncertainty" and no widely accepted methodology for analyzing indirect effects. "The EPA is using nine separate models and data sets to conduct its full fuel cycle analysis, many of which were not initially designed to conduct this type of analysis or work together," he said.

He said the ethanol industry objects to the EPA's analysis of indirect greenhouse gas emissions from land use change under EPA's lifecycle analysis because it "fails to make an apples-to-apples comparison between biofuels and petroleum."

National Corn Growers Association Ethanol Committee Chairman Steve Ruh said his organization is pleased that the EPA has "validated what our industry has long known – that when in direct comparison to gasoline, ethanol significantly reduces greenhouse gas emissions."

But EPA's current proposal has caused "great apprehension" among corn growers, said Ruh, because of its "potential to place onerous and unnecessary regulations on agriculture producers."

The EPA has failed to take into account the modern agricultural practices and biotechnology that are allowing farmers to produce more new corn than has been required for the incremental increase in ethanol production each year, said Ruh.

Steve Ruh, far right, of the National Corn Growers Assn. testifies at the EPA hearing on the renewable fuel standard. (Photo courtesy NCGA)

"On my own farm for example," Ruh said, "I currently out produce my grandfather's production twofold and my father's production by 50 percent, this is on the same land that has been in my family for three generations."

"Averaged over the past nine years, a time when ethanol production grew dramatically," he said, "for every bushel required for the increased ethanol market, 2.89 “new” bushels were grown on the same acres, thus requiring no additional acres be brought into production for the purpose of ethanol."

Ruh says yields will likely grow more than two percent a year through 2022 - when the 2007 Energy Act requires 36 billion gallons of biofuels production.

RFS-2 for the first time requires a renewable component in U.S. diesel fuel, and provides a schedule for the use of biomass-based diesel that increases from 500 million gallons in 2009 to one billion gallons in 2012.

To qualify for the program, renewable fuel must reduce greenhouse gas emissions by 50 percent compared to the conventional diesel fuel it is replacing, and the EPA Administrator has the authority to reduce the greenhouse gas emission target to 40 percent.

Manning Feraci of the National Biodiesel Board, the national trade association for the industry, said "Because the proposed rule relies on dubious land use assumptions and inaccurate data, the EPA's proposed rule restricts feedstock for low-carbon diesel replacement fuel to only animal fats and restaurant grease. Vegetable oils account for more than sixty percent of the feedstock that is available to meet the RFS-2 Biomass-based Diesel targets, and the RFS-2 volume goals simply cannot be met if vegetable oils are disqualified from the program."

"We recognize that statute requires the EPA to consider significant indirect emissions when calculating a renewable fuel's emission profile," he said. "This does not require the EPA to rely on faulty data and to fabricate unrealistic scenarios that punish the U.S. biodiesel industry for wholly unrelated land use decisions in South America."

"Make no doubt about it," said Feraci, "this is what the EPA's proposed rule does. Biodiesel produced from domestically produced vegetable oils are disqualified from the Biomass-based Diesel program, making it all but impossible to meet the volume goals established by statute."

Copyright Environment News Service (ENS) 2009. All rights reserved.