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

ManagementOABA Annual Conference Wraps Up In Columbus
February 5, 2016
More than 300 Ohio AgriBusiness Association (OABA) members and industry professionals were on hand to engage in collaborative learning and Read More
Chesapeake Bay
StewardshipKeeping A Watch On Water Issues
February 2, 2016
During a down cycle in the market, it’s difficult to think about investing for the long term. For retail businesses, Read More
FertilizerFort Wayne 4R Farming Event Set For February 12
January 29, 2016
The Nutrient Stewardship Council will host a complimentary “4R Farming 4 Sustainability” educational workshop Feb. 12 in Fort Wayne, IN, Read More
Legvold Farm, Northfield, MN
LegislationASA Notes Progress, Urges EU To Improve Biotech Approval Process
January 29, 2016
The American Soybean Association (ASA) urged the European Commission today to continue its work in addressing delays in the approvals Read More
Top 100 Articles
Elburn Cooperative
CropLife 100Elburn Cooperative Members Vote To Join CHS
December 28, 2015
With 81% of eligible producers voting, 94% cast an affirmative ballot for Elburn Cooperative, a diversified agricultural retailer based out Read More
West Central Cooperative, Jefferson, IA
CropLife 100Farmers Cooperative-West Central Merger Approved
December 21, 2015
The members of Farmers Cooperative Co. (FC), Ames, IA, and West Central Cooperative, Ralston, IA, have both approved the merger Read More
Wheat Growers Innovation Center, Bath, SD
CropLife 100Wheat Growers Opens Innovation Center
December 21, 2015
Wheat Growers’ commitment in providing its farmer-owners with the latest in technological advancements now has a one-of-a-kind focal point, as Read More
CropLife 100ARA Selects The Andersons As 2015 Retailer Of The Year
December 9, 2015
The Agricultural Retailers Association today named Maumee, OH-based The Andersons as its Retailer of the Year for 2015. The award Read More
CPS Washington Court House John Deere Sprayer
CropLife 100Application Equipment Report: It Is Easy Being Green For Top 100 Ag Retailers
December 5, 2015
On The Muppets television show, Kermit the Frog is famous for singing a song about the troubles he encounters in Read More
Fertilizer Bin
CropLife 100Fertilizer Sales: Another Down Year For Top 100 Ag Retailers
December 4, 2015
In pure number terms, the fertilizer category still dominates all crop inputs/services among CropLife 100 ag retailers. In 2015, for Read More
Latest News
Soybean field
FungicidesFour Arysta Fungicide Formulations Given FIFRA Approval…
February 8, 2016
Arysta LifeScience North America recently announced the issuance of Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 2(ee) Recommendations for Read More
FungicidesAgri-Fos Systemic Fungicide Plus Receives EPA Registrat…
February 8, 2016
Vivid Life Sciences has announced the EPA registration of Agri-Fos Systemic Fungicide Plus, a highly concentrated active ingredient phosphite fungicide, Read More
Crop InputsBayer Contests EPA’s Decision On Valuable Insecticide F…
February 5, 2016
Crop Science, a division of Bayer, has announced it has refused a request by the Environmental Protection Agency (EPA) to Read More
Wheat Field North Dakota
Seed/BiotechSyngenta Wins Seed Fraud Suit Against South Dakota Grow…
February 5, 2016
Syngenta has obtained a $25,000 settlement from Paul and John Mayclin, Mayclin Farms, Plankinton, SD, in response to their Plant Read More
ManagementOABA Annual Conference Wraps Up In Columbus
February 5, 2016
More than 300 Ohio AgriBusiness Association (OABA) members and industry professionals were on hand to engage in collaborative learning and Read More
Crop InputsBayer To Contest EPA Flubendiamide Decision
February 5, 2016
Crop Science, a division of Bayer, announced today it has refused a request by EPA to voluntarily cancel the uses Read More
Syngenta
Seed/BiotechNot So Fast: ChemChina Syngenta Takeover Could Draw Nat…
February 5, 2016
State-owned China National Chemical Corp. (ChemChina), which plans to buy Swiss seeds and pesticide maker Syngenta, will promptly start preparations Read More
Rendering of Syngenta Seedcare Institute expansion
Seed/BiotechExpansion Of Syngenta’s North America Seedcare In…
February 4, 2016
As demand for seed treatment knowledge and products grows among farmers, retailers and others in the seed industry, Syngenta is Read More
Soybean Field
Industry NewsArysta LifeScience Strengthens Sales Team
February 4, 2016
Arysta LifeScience North America recently announced three new personnel additions: Jake Cook and Peter White are Territory Sales Managers for Read More
Davor Pisk Syngenta COO
Crop InputsSyngenta COO: Why ChemChina Offer Beat Monsanto’s
February 4, 2016
Syngenta Chief Operating Officer Davor Pisk says he is confident the proposed acquisition by ChemChina will ultimately help preserve choice Read More
Young corn plants in soil
Crop InputsKoch Biological Solutions Invests In Pathway Biologic
February 4, 2016
An affiliate of Koch Biological Solutions, LLC has acquired a minority equity position in, and entered into collaboration with, Pathway Read More
Crop InputsABG: China Signs Off On Monsanto’s Roundup Ready …
February 3, 2016
Monsanto Co. on Wednesday announced it plans to launch its Roundup Ready 2 Xtend soybeans in time for the 2016 Read More
Syngenta headquarters in Basel, Switzerland
Crop Inputs6 Things To Know About The ChemChina-Syngenta Deal
February 3, 2016
After months of rumors and speculation, Syngenta has announced that ChemChina has offered to acquire the Swiss-based company. “In making Read More
FertilizerPhosphorus: Is Band Or Broadcast Application The Better…
February 3, 2016
Is band or broadcast application the better method when it comes to phosphorus? The answer to this question depends mostly Read More
Syngenta Sign
Crop InputsChemChina Nearing Deal To Buy Syngenta For Record $43 B…
February 3, 2016
China National Chemical Corp. is nearing an agreement to buy Swiss pesticide-and-seeds-maker Syngenta AG for about 43.7 billion francs ($42.8 Read More
Herbicides2015 ASA Trials Demonstrate Valent Fierce XLT Herbicide…
February 2, 2016
Valent U.S.A. today announced that new Fierce XLT Soybean Herbicide ranks in the top tier among growers for length of Read More
Crop Protection Products in storage
Paul SchrimpfCrop Input Selling: Return Of The Price List
February 2, 2016
It was a good 15 years ago, shortly after I first started writing for this esteemed publication, that it all Read More
Potash storage at Growmark
FertilizerThe Phosphate And Potash Outlook For 2016
February 2, 2016
Like other commodities, prices of the leading plant nutrient products dropped sharply in 2015. At this writing, the price of Read More