Brownfield Network
By Ken Anderson, Tom Steever and Bob Meyer
June 9, 2009

www.brownfieldnetwork.com

An Environmental Protection Administration hearing Tuesday on the proposed rulemaking for the Renewable Fuels Standard focused on the controversial theory called indirect land use change. Proponents of corn-based ethanol and soybean oil-based biodiesel say the proposed rules penalize those fuels for greenhouse gas emissions that result from land use changes around the world and years into the future.

Dr. Mark Stowers, vice president of science and technology for POET got right to the point in his testimony, saying the proposed rule is “flawed and has no basis in law or science.”

Models used by EPA in calculating indirect land use changes have severe problems and limitations, including “failure to make apples-to-apples comparisons with gasoline,” and an underestimation of corn and ethanol yields, he said.

Stowers urged EPA officials to visit a modern ethanol plant to “obtain real data about the industry, rather than relying on unproven models, hypotheses and assumptions,” Stowers testified.

The proposed rules also confound what will and will not qualify under the proposed rules as the raw materials from which to make renewable biodiesel.

Biodiesel “is the only game in town” when it comes to bio-based diesel, said Manning Feraci, vice president of federal affairs for the National Biodiesel Board, who was another of those who testified at the hearing.

National Biodiesel Board CEO Joe Jobe, in an interview at National Biodiesel Board Headquarters in Jefferson City, maintained that the EPA’s interpretation of RFS-2 will disqualify more than 60 percent of the feedstock for biodiesel, leaving only animal fats and restaurant grease that qualify as useable feedstock under the rule.

Jobe told Brownfield during the interview that biodiesel has about 80 percent less lifecycle CO2 than diesel fuel, except when indirect land use changes are applied.

“The EPA has interpreted this indirect emissions from land use changes decades into the future and carbon that’s created from decisions that may or may not be made on other continents and assign those backwards to U.S. biodiesel now,” Jobe told Brownfield.

That, says Jobe, takes biodiesel’s direct emissions benefits from 80 percent down to 22 percent, which is too low to suit the EPA. Jobe refers to the EPA interpretations as faulty science.

“They look at third and fourth iteration indirect emissions for biodiesel, but the EPA assumes that imported petroleum, foreign petroleum has no indirect emissions,” said Jobe. “They make no attempt whatsoever to look at indirect emissions for petroleum.”

Feraci told the group that while he recognizes the statute requires EPA to consider significant indirect emissions when calculating a renewable fuel’s emission profile, "It does not require EPA to rely on faulty data and to fabricate unrealistic scenarios which punish the U.S. biodiesel industry for wholly unrelated land use decisions in South America." Feraci cited as an example the assumption than an increase in biodiesel production would lead to an increase in soybean acreage in Brazil. The noted that from 2004 through 2008, while biodiesel production in the United States grew from 25 million gallons to 690 million gallons, soybean acreage in Brazil declined.

Feraci also took issue with the EPA methodology pertaining to nitrogen emissions from soybeans arguing that nitrogen fixed in the soil by soybeans should not be considered greenhouse gas emissions.

Feraci closed his testimony imploring the EPA to address the proposal’s glaring shortcomings.

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