On Friday the public comment period on the Renewable Fuels Standard regulations that have been put forth by the Environmental Protection Agency will close. The Renewable Fuels Association held a press call on Thursday to outline their concerns about the proposed rule and discuss the comments they are submitting.
"While the greenhouse gas reductions is certainly one of the very important goals of the RFS, it's not the sole purpose," said RFA President Bob Dinneen. "Reducing America's dependence on foreign oil was part of the Energy Security Act. Providing economic opportunity and job creation and supporting rural communities, those were all equally important goals of the Energy Independence and Security Act. We're a bit concerned that EPA appears to be ignoring those objectives as it pursues greenhouse gas reductions based on unproven theory."
Dinneen says that is the most fundamental objection to what EPA has put forward. Specifically RFA is submitting comments on several issues, especially their belief that international indirect land use change simply should not be included.
"EPA is overreaching in interpreting Congressional intent when it comes to the indirect impacts of the RFS," Dinneen said. "Congress did not intend to penalize America's ethanol producers for decisions made by farmers and governments in other countries."
Dinneen also cited a recent report that calculated that 2.2 million acres is all the land that would be needed by 2022 to meet the RFS mandate. To put that in perspective, that is one-half of 1% of U.S. cropland, one-tenth of 1% of world cropland, six one-hundredths of 1% world arable land, which Dinneen says is certainly not enough to have meaningful impact on greenhouse gases across the globe.
Dineen strongly believes that if EPA properly calculates the direct effects and indirect effects that the greenhouse gas benefits of ethanol are going to be demonstrated. Removing the international land use change alone shows ethanol reduces greenhouse gas emissions by 60% compared to gasoline, and that's using EPA's own analysis.
"I think it is important to recognize that all fuels come with indirect effects," Dinneen said. "The RFA is going to urge the EPA to reconsider the indirect impacts of other fuels, specifically petroleum. As more of our oil is coming from marginal sources such as Canadian tar sands, the greenhouse gas profile of oil and gasoline is only going to worsen, and our greenhouse gas profile is only going to get better with new technologies and new feedstocks."