RFA: Oregon DEQ shouldn’t single out ethanol

By Ann Bailey | October 22, 2015

The Renewable Fuel Association has written the Oregon Department of Environmental Quality a letter expressing displeasure with the state’s proposed amendments for its Oregon Clean Fuels Program.

The association has been an enthusiastic supporter of carbon fuel programs using fair, consistent and scientifically robust methods to evaluate, for all fuels, the lifecycle carbon intensity (CI), said the Oct. 21 letter written by Geoff Cooper, senior vice president of RFA. The RFA was surprised and disappointed, then, to learn that the recently proposed rule includes the addition of  what the organization sees are subjective penalty factors for “hypothetical indirect and use charges (ILUC), for select biofuels, but no direct penalty for any other fuel types,” the letter said.

“Moreover, the ILUC factors, DEQ is proposing to incorporate are entirely arbitrary and have nothing to do whatsoever with the expected actual carbon impacts of CFP implementation in Oregon for the 2015-2016 timeframe,’’ Cooper wrote.

The RFA recommends that the Oregon Department of Environmental Quality excludes indirect effects from the OCFP’s carbon intensity scoring framework until there is broad scientific agreement on the beset methodology for estimating the indirect effects of all fuels, Cooper wrote. Consensus and agreement on the proper methods hasn't been achieved

The success of the clean fuels program ultimately depends on strong support and backing from industry and stakeholder groups which would be affected. While the RFA supports low carbon fuel programs based on fair principles, sound science and consistent analytical boundaries, it can’t support what the DEQ’s proposal. It introduces “concepts that lack scientific integrity and balance into the regulatory framework,” he wrote, such as applying ILUC to biofuels but no other fuels, and creates “stakeholder division and controversy.”