The U.S. Environmental Protection Agency should implement new rules for the Renewable Fuel Standard (RFS) in a timely manner that is consistent with the goals of achieving energy security and addressing climate change priorities.
The Biotechnology Industry Organization (BIO) has thanked Senators who sent a letter to EPA Administrator Johnson urging the agency to publish and seek comment on the methodology it is using to estimate the life cycle greenhouse gas emissions of biofuels, particularly those attributed to indirect land use change, as called for in the Renewable Fuel Standard.
The letter was submitted on Friday, Nov. 14, 2008, and signed by Sens. Christopher Bond (R-Mo.), John Thune (R-S.D.), Ken Salazar (D-Colo.), Charles Grassley (R-Iowa), Norm Coleman (R-Minn.), and Ben Nelson (D-Neb.). The letter states:
"The methodology ultimately used by EPA in crafting this program will have a significant impact on the overall success of the program, and the science and methodology employed by EPA should be subject to thorough public and academic review.
Likewise, the premature publication of specific greenhouse gas (ghg) emissions calculations based on incomplete ILU [indirect land use] assumptions could undermine the ultimate success of RFS-2 and be detrimental to U.S. biofuels producers and farmers, as it will undermine investor confidence and further deprive the industry of the investment capital it will need to meet the renewable targets established in RFS-2."
Brent Erickson, executive vice president of BIO's Industrial and Environmental Section, stated, "The EPA's rulemaking on the Renewable Fuel Standard could set a precedent for future regulation of greenhouse gas emissions under any carbon capping, trading, or taxing legislation and possibly for international agreements.
The EPA must get this rule right. In the future many other industries could legitimately be assessed the same indirect land use penalty being considered for U.S. biofuels, and that should be a wakeup call about why this rulemaking needs to be scientifically sound.
"Good models do not yet exist to accurately measure land use changes and emissions. If the proposed rule contains numerical results published prior to the maturing of modeling tools, it could have a range of perverse effects, including discouraging and chilling investment and curbing U.S. production and use of all biofuels. Without a more sophisticated understanding of international land use change variables and interactions, a rule risks discouraging production of biofuels that truly do reduce U.S. greenhouse gas emissions and contribute to energy security.
"Our members in the biofuels industry agree that consideration of direct lifecycle greenhouse gas emissions is essential to identifying truly sustainable transportation fuel solutions. BIO's member companies are confident that if the RFS rulemaking is conducted with adequate scientific rigor, advanced biofuels can meet these standards and provide substantial benefits for the global climate."
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