RFA: Renewable Fuels Standard Overestimates Potential Emissions

Further analysis of EPA’s Renewable Fuels Standard (RFS) reveals more errors in the agency’s calculation of corn ethanol and other biofuels’ carbon intensity, according to new analysis by the Renewable Fuels Association (RFA). In a letter to EPA sent on August 4, the RFA points out that “according to [EPA’s] own analysis, EPA grossly overestimated potential emissions from land use change (LUC) attributable to the [greenhouse gas] lifecycle of corn ethanol and other biofuels.”

Correcting this error, as RFA points out in its letter, would greatly increase the greenhouse gas reduction benefits offered by ethanol under EPA’s calculations. “Correcting this miscalculation reduces net LUC emissions (international and domestic) assigned to corn ethanol by 62% from 28.4 grams of CO2-equivalent/mega joule (g/MJ) to 10.8 g/MJ. Such a reduction in LUC emissions means overall lifecycle GHG emissions for 2022 average corn ethanol would be 38% less than baseline gasoline emissions, rather than the 21% estimate finalized by EPA.” The RFA still maintains that the inclusion of LUC impacts, particularly international impacts over which the U.S. has no control, is flawed policy and that EPA misinterpreted the intent of Congress when it passed the RFS.

In a blog post on the letter, RFA vice president of Research and Analysis Geoff Cooper writes, “Despite the fact that real-world data and events have disputed the ILUC theory at every turn, EPA’s final rule for the RFS2 institutes a net LUC penalty (domestic and international) against corn ethanol of 30 kg CO2e/mmBTU (or 28.4 g CO2e/mega joule). This represents nearly 40% of the total GHG intensity of corn ethanol as estimated by EPA. When LUC emissions are excluded, EPA found corn ethanol from a natural gas dry mill reduces GHG emissions by 50% compared to gasoline. With LUC emissions, that benefit falls to around a 20% reduction.”

This overestimation occurred as a result of the questionable methodological choice EPA made to isolate the LUC impacts of individual biofuels by increasing their production one at a time and holding all other biofuels at constant levels. More appropriately, the RFA notes, if EPA felt compelled by the statute to penalize biofuels for ILUC, it should have based those penalties on modeling that simultaneously increased production for all biofuels in accordance with the RFS requirements.

“Attempting to isolate the potential impacts of individual biofuels results in significantly exaggerated estimates of the overall lifecycle GHG intensity of corn ethanol and other biofuels,” the RFA wrote. “Because the EISA requires increasing volumes of various biofuels simultaneously, EPA should have based its LUC estimates on the scenario results that simulated concomitant increases in the various biofuels required by the [RFS].”

While the RFA letter relates specifically to EPA’s calculation of greenhouse gas emissions, the flaws in EPA’s modeling together with the inclusion of LUC impacts are symptomatic of a larger concern about attempts to limit emission from vehicles by unfairly penalizing biofuels.

(Source: Renewable Fuels Association)

Topics: ,

Leave a Reply

Management Stories
ManagementMACA 2014: The State Of The Agricultural Industry, And Then Some
October 9, 2014
The trade association’s annual gathering featured speakers from across agriculture and beyond. Read More
StewardshipA Multi-Layered Approach To Water Quality
October 6, 2014
Illinois event highlights research and technology designed to better monitor and improve water quality — and the benefits of cooperative, coordinated effort. Read More
StewardshipMichigan Agriculture Leaders On Toledo Water Ban: We Want To Be Part Of The Conversation
August 8, 2014
Leaders of Michigan agricultural organizations said Thursday that the government should not have a “knee-jerk reaction” based on last weekend’s water ban in Toledo due to fertilizer run-off in Lake Erie. Read More
ManagementRussia Bans U.S. And EU Ag Product Imports In Ukraine Sanctions Battle
August 7, 2014
Russian President Vladimir Putin has banned the import of agricultural goods from countries that have imposed sanctions on Russia. Read More
Top 100 Articles
Milan Kucerak, president/CEO, West Central
CropLife 100West Central Cooperative And Its New President Are A Match Made In Deviation
June 29, 2015
To appreciate just how unique West Central Cooperative is in the world of ag retail, an observer need only consider Read More
Winter Wheat
CropLife 100South Dakota Co-op Member Owners Vote No On Unification
June 26, 2015
The Boards of Directors for North Central Farmers Elevator (NCFE) and Wheat Growers (WG) have announced that member-owners have voted Read More
CropLife 100The Andersons Acquires South Dakota Plant Nutrient Manufacturer Kay-Flo
May 20, 2015
The Andersons, Inc., ranked No. 22 on the CropLife 100, has purchased Kay Flo Industries of North Sioux City, SD. “This Read More
CropLife 100North Central Farmers Elevator, Wheat Growers Unification Approved By Board, Still Awaits Member Approval
May 13, 2015
The Boards of Directors for North Central Farmers Elevator (NCFE) and Wheat Growers (WG) have voted to approve the Unification Read More
CropLife 100AgGateway’s Barcoding Initiative Progressing Nicely
May 8, 2015
According to legend (or Wikipedia), the first step towards modern bar codes came back in 1948, when Bernard Silver, a Read More
CropLife 100Pinnacle Agriculture Acquires Minnesota Retailer
April 14, 2015
Pinnacle Agriculture Holdings, LLC, ranked No. 6 on the CropLife 100,  has successfully acquired Liebl Ag, LLC in Ada, MN.  Read More
Latest News
The McGregor Co. fertilizer loadout
Retail FacilitiesThe McGregor Co. Partners With Kahler Automation To Cre…
June 30, 2015
Kahler Automation helped The McGregor Co. expand its Clarkston, WA, operation with unstaffed loadout technology that enables customers to pick Read More
Dry and Liquid Plant
Retail FacilitiesKahler Automation Helps CHS Dakota Ag Cooperative Build…
June 30, 2015
CHS Dakota Ag Cooperative in Mooreton, ND, wanted a liquid/dry blender system that could meet the needs of its customers Read More
Crop InputsLand O’Lakes, United Suppliers To Merge Crop Inpu…
June 29, 2015
Land O’Lakes, Inc. and United Suppliers, Inc. of Ames, IA, today announced their intent to merge their crop inputs businesses. Read More
FungicidesHelena To Distribute Unique Summit Agro Fungicide
June 29, 2015
RANMAN 400 SC fungicide, the only fungicide with a FRAC group 21 designation, is now part of the innovative Summit Read More
Eric SfiligojIARC Targets 2,4-D In Latest Report
June 29, 2015
The International Agency for Research on Cancer (IARC) has struck again. Earlier this year in March, this agency of the Read More
Milan Kucerak, president/CEO, West Central
CropLife 100West Central Cooperative And Its New President Are A Ma…
June 29, 2015
To appreciate just how unique West Central Cooperative is in the world of ag retail, an observer need only consider Read More
EquipmentCase IH Launches New Precision Air 5 Series Carts
June 29, 2015
Case IH recently introduced its new Precision Air 5 series air carts, developed to get the most from every plant’s Read More
InsecticidesVestaron Biopesticide Approved In California
June 29, 2015
Vestaron Corporation, a developer of insect control products derived from naturally occurring peptides, today announced that its VST-006330-EP biopesticide has received Read More
InsecticidesValent’s Zeal SC Miticide Receives EPA Approval
June 29, 2015
Valent U.S.A. Corporation announced today that Zeal SC Miticide has been registered by EPA with a new liquid formulation that Read More
Retail FacilitiesUnited Prairie Increased Plant Productivity With Junge …
June 29, 2015
Since 1979, Junge Control continues to provide ag retailers with highly accurate fluid and dry ingredient measuring, mixing and tracking Read More
Winter Wheat
CropLife 100South Dakota Co-op Member Owners Vote No On Unification
June 26, 2015
The Boards of Directors for North Central Farmers Elevator (NCFE) and Wheat Growers (WG) have announced that member-owners have voted Read More
ManagementAsmark Training Center Visit & A Merger No Go
June 25, 2015
CropLife Editor Eric Sfiligoj talks about a visit to the Ford B. West Training Center and the failure of the Read More
Crop InputsWinField: Here’s What We’re Seeing So Far T…
June 25, 2015
One of the most important things you can do throughout the season to help increase yield potential is to ensure Read More
Valent, Commodity Classic 2015
Industry NewsValent Garners FFA Honor
June 23, 2015
Valent U.S.A. Corporation today announced it has been named a 5-star member of the National FFA Foundation. This includes an Read More
Nester Ag intern Brad Nester
Crop InputsOhio NRCS’ New Conservation Practice Standard For Gypsu…
June 22, 2015
Ohio farmers wishing to use gypsum to improve soil quality now have access to technical information and possible financial assistance Read More
Industry NewsWest Central Creates New Executive Team
June 22, 2015
West Central Distribution, LLC officially announced the development of an executive team comprised of Dale Engan, chief executive officer; Michael Read More
MicronutrientsVerdesian Life Sciences Invests In People, Agricultural…
June 22, 2015
In mid-February, the USDA released its new 10-year agriculture projections. While the numbers are new, the theme was consistent. The Read More
Young corn plants
Crop InputsStudy: Crop Rotation Has Positive Impact On Soil Microb…
June 22, 2015
A study authored by Michigan State University (MSU) Department of Plant, Soil and Microbial Sciences assistant professor Lisa Tiemann is Read More