The American Soybean Association (ASA) has submitted comments to the House Agriculture Subcommittee on Conservation, Credit, Energy and Research regarding the impact of the indirect land use and renewable biomass provisions in EPA’s expanded Renewable Fuel Standard (RFS-2).
ASA sees numerous potential flaws in the approach EPA is using for indirect land use changes in its proposed rule. Further, there are numerous factors that ASA believes refute the possibility that significant international indirect land use change would result from the relatively small increase in U.S. biodiesel production called for under the RFS-2.
"The approach EPA has used in its proposed rule on RFS-2 implementation is significantly flawed and would do unnecessary and irreversible harm to the competitive position of the U.S. soy biodiesel industry," says ASA President Johnny Dodson, a soybean producer from Halls, TN. "EPA’s projections of indirect international land use changes resulting from a quite small increase in biodiesel production are built on faulty assumptions, flawed analysis, and misplaced penalties."
ASA included a detailed list of the flaws in EPA’s assumptions in its comments to the Subcommittee. These comments are available here.
When calculating the life cycle GHG impact of biofuels, the statute directs EPA to consider direct and indirect emissions, including indirect land use, of all stages of the fuel and feedstock production. The primary area of concern and disagreement has emerged over the international indirect land use assumptions that EPA has proposed to use in conducting their updated life cycle GHG analysis.
Land use change has been going on around the world for many years, long before biodiesel was produced in the U.S. The EPA analysis uses land converted to cropland from 2001-2004 and extrapolates that into the future. Since there was very little U.S. soy biodiesel produced from 2001-2004, it is illogical how EPA justifies attributing future land conversion to soy biodiesel.
"It was not the intent of Congress for soy biodiesel to be excluded from the RFS-2," Dodson says. "If soy biodiesel is excluded, the biomass-based diesel schedule under RFS-2 cannot be achieved. There are simply not enough of other biodiesel feedstocks to produce the amount of biodiesel called for in the RFS-2."
ASA believes EPA must use the rulemaking process to correct and improve the life cycle analysis that will ultimately be used to implement the RFS-2 program.
The biodiesel industry is creating valuable green jobs and making a positive contribution to the economy. In 2008 alone, the U.S. biodiesel industry supported over 51,000 jobs, added over $4 billion to the nation’s Gross Domestic Product (GDP) and generated over $866 million in tax revenue for federal, state and local governments.
"ASA looks forward to working with Congress and coordinating with industry partners and the academic and scientific community to provide the information to demonstrate that U.S. soy biodiesel is the cleanest burning biofuel available today, and is not responsible for international land use changes," Dodson says.