Science Based Comments Being Prepared on RFS NCGA gearing up for comment period. Published on: May 27, 2009 Tweet Post to Your Wall. Email Story RSS Permalink Print Now that the U.S. Environmental Protection Agency has opened a 60-day comment period for proposed changes to the Renewable Fuel Standard, the National Corn Growers Association is formulating a comprehensive response. NCGA is working with industry allies to provide a set of science-based comments that underscore the importance of corn ethanol for its economic, environmental and energy benefits. "These proposed regulations for implementing the federal Renewable Fuel Standard need to be based on sound science and the best data available," said NCGA President Bob Dickey. "One of the biggest concerns is the emphasis on indirect land use changes in determining the possible greenhouse gas and climate change effects of biofuels. That rule assumes, wrongly, that producing more ethanol requires diverting more acres to corn from other crops, triggering a global shift in acreage." Further, the proposed rule restricts what will be considered a renewable biomass. In order to prove that corn they harvest and deliver meets the above definition, the EPA has proposed that corn farmers must provide documentation to verify that the crop was produced on qualifying land. The EPA will accept comments through July 27.