RFS2 Requirements Announced

RFA urges EPA to reevaluate modeling of lifecycle GHG.

Published on: Nov 30, 2010

The EPA has announced its Renewable Fuels Standard requirements for 2011. The total RFS2 requirement for the coming year will remain at 13.95 billion gallons. Of that amount 12.6 billion gallons will be starch-based ethanol and the other 1.35 billion gallons will be a combination of biodiesel and other advanced biofuels. There is also a 6.6 million gallon requirement for cellulosic biofuels, which is lower than the targets established when the RFS2 became law.

Renewable Fuels Association President and CEO Bob Dinneen says the reduced standard for cellulosic biofuels reflects the difficulties cellulosic biofuel technologies have encountered in obtaining capital for full commercialization. But that's why he believes EPA should have kept ambitious cellulosic biofuel targets, to stimulate the investment needed to finish commercialization.

Meanwhile, RFA says it's time for the EPA to reevaluate its modeling of lifecycle greenhouse gas emissions under the Renewable Fuels Standard. They are concerned with the highly uncertain analysis of emissions from hypothetical indirect land use changes assumed to result from biofuels expansion under the RFS2. Purdue University and Department of Energy analyses have demonstrated problems with the ILUC studies performed by the California Air Resources Board and EPA. In response, the state of California recently refined its ethanol greenhouse gas emission calculations for the state's Low Carbon Fuels Standard and RFA is urging EPA to consider similar changes.

According to a letter to EPA Administrator Lisa Jackson, the proposed changes to the California LCFS analysis are likely to result in substantially lower indirect land use change values, meaning EPA's analysis for the RFS2 will be inconsistent with the latest science being adopted by CARB.

Specifically, RFA says adjusted treatment of crop yields on newly converted land, treatment of carbon sequestration in harvested wood products and the effect of higher prices on crop yields are among the factors the EPA should re-consider to ensure the RFS2 is based on the most up-to-date science and available data.