On Monday Renewable Fuels Association President and CEO Bob Dinneen addressed reporters about several events happening this week. On Tuesday a public hearing on the proposed rulemaking for the Renewable Fuels Standard is being held by the Environmental Protection Agency. Also, EPA is holding workshops on life-cycle analysis this Wednesday and Thursday.
Dinneen will be testifying at Tuesday's hearing and RFA VP of Research Geoff Cooper will be presenting at the workshops.
"While we generally applaud EPA's efforts to get the rule out and we are generally very grateful to EPA staff for the outreach effort that they have had with stakeholder," said Dinneen. "As virtually everyone knows we do have some very serious concerns with the proposal that we will be laying out tomorrow during the hearing, and during the workshops and most certainly in our comments we will be preparing for the end of July."
Most of RFA's concerns with the proposed rulemaking revolve around EPA's analysis of life-cycle. There is a tremendous amount of uncertainty and speculation associated with that analysis that renders the rule suspect.
"First and foremost the inclusion of international indirect effects," Dineen said. "We don't believe that the statute requires it; we don't believe that the Congress believed that the analysis of indirect effects should include international impacts; and we certainly don't believe that the science would support evaluating international impacts of a farmer's decision somewhere else in the world related to biofuels production."
Dineen said many of their comments will be focused on the fallacy of trying to determine international indirect effects associated with the biofuels industry. He also says they have concerns about the integration of life-cycle analysis models.
"EPA is using nine separate models and data sets to conduct its life-cycle analysis," Dinneen said. "None of those models were designed to work together; none of those models were designed to answer the questions that EPA is forcing it to ask and hopefully we will learn a lot more during the workshops on Wednesday and Thursday about that."
Dinneen also plans to testify on validation of life-cycle models, transparency of rulemaking and peer review of the proposal. He also plans to point out that the proposal has no indirect greenhouse emissions considered for oil.
"If you are going to have an apples-to-apples comparison of ethanol and petroleum," Dinneen said. "You need to be counting all the same things."