RFS Reactions Mixed
February 8, 2010 Depending on the biofuel of choice, industry reviews vary on EPA’s Final Rule for the Renewable Fuel Standard (RFS2). The new RFS includes indirect land use change (ILUC) requirements and also requires more biodiesel in the biofuels mix.
RFS2 implements the long-term renewable fuels mandate of 36 billion gallons by 2022 established by Congress. RFS2 requires biofuels production to grow from last year’s 11.1 billion gallons to 36 billion gallons in 2022, with 21 billion gallons to come from advanced biofuels. Agriculture industry organizations worked hard to educate EPA and policymakers on correcting flaws in the original RFS2 Proposed Rule issued in 2009.
In a written statement, the Renewable Fuels Association (RFA) applauded EPA’s efforts, calling RFS2 “a workable program that will achieve the stated policy goals of reduced oil dependence, economic opportunity, and environmental stewardship.”
But it’s the use of ILUC to determine greenhouse gas emission (GHG) levels that concerns RFA. The new RFS2 requires that some renewable fuels must achieve greenhouse gas emission (GHG) reductions — compared to the gasoline and diesel fuels they displace — in order to be counted towards compliance with volume standards.
RFA president Bob Dineen expressed concern that while EPA recognized that ethanol from all sources provides significant carbon benefits compared to gasoline, grain-based ethanol’s climate contributions are being “shortchanged” with the inclusion of ILUC.
“According to EPA’s modeling, corn-based ethanol achieves a 21 percent greenhouse gas (GHG) reduction compared to gasoline when dubious ideas of international indirect land use change (ILUC) are included,” RFA’s statement said.
RFA contends that without ILUC, corn-based ethanol achieves a 52 percent GHG reduction. Cellulosic ethanol achieves GHG reduction of 72 percent to 130 percent depending upon feedstock and conversion process. All GHG reductions for ethanol exceed those mandated by the RFS2.
“Disappointingly, however, EPA continues to rely on oft-challenged and unproven theories such as international indirect land use change to penalize U.S. biofuels to the advantage of imported ethanol and petroleum,” Dineen said.
According to the Dow Jones newswire, EPA says that some 12.95 billion gallons of biofuels will have to be added this year, as required by law. Some 6.5 million gallons must come from cellulosic ethanol. And 1.15 billion gallons must come from biomass-based diesel over the two years through 2010.
The Dow Jones newswire also reports that the mandate to use 1.15 billion gallons of biodiesel in 2010 could inject new life into the ailing industry. U.S. biodiesel producers were crippled by the lack of implementation of legislative requirements to produce more biodiesel; by the end of 2009, the industry was operating at 15 percent of its capacity. Total industry capacity — mostly built during the pre-recession rush to produce renewable fuels — is about 2.7 billion gallons a year.
The American Soybean Association (ASA) says RFS2 provides a positive outcome for biodiesel and soy biodiesel.
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