RFA asks EPA to revise outdated GHG analyses of corn, sugarcane

By Holly Jessen | December 05, 2012

The Renewable Fuels Association announced Dec. 3 that it had sent a letter to the U.S. EPA concerning the obsolete lifecycle analyses of corn and sugarcane ethanol for the renewable fuel standard. “There have been literally dozens of new studies and modeling improvements since EPA finalized the RFS2 almost three years ago,” said Bob Dinneen, RFA president and CEO. “Overwhelmingly, these new reports and data show that the corn ethanol process is far less carbon intensive than assumed by EPA. Corn ethanol is offering real and significant GHG savings today. Meanwhile, the carbon intensity of crude oil production continues to worsen, as we drill farther and deeper than ever before and get more of our energy from marginal crude sources like tar sands.”

The seven page letter, which included references and charts, was addressed to Lisa Jackson, administrator of the EPA. In it, RFA pointed out that the science of lifecycle GHG analysis have happened in the last three years, since RFS2 went into effect, and urged the EPA to update its GHG analyses. “In the pre-amble for the RFS2 final rule, EPA acknowledged that lifecycle GHG analysis is an evolving science, and that updates to the agency’s analysis would be undertaken as better data and methodologies became available,” RFA said in the letter, adding that the agency also recognized that periodic reassessments may also be needed as the efficiency of biofuel production increases and new technologies are implemented.

Looking at improved modeling and better data shows that corn ethanol today produces less GHG emissions and is more efficient than EPA had previously assumed would be the case in 2022, RFA said. On the other hand, recent research showed that sugarcane ethanol production actually has worse than originally estimated GHG lifecycle emissions. And, although the EPA assumed virtually no land use change emissions for Brazilian ethanol, harvested sugarcane area has grown 55 percent since 2006.

The RFA considers it imperative that EPA recognize new science and data. First, the agency needs to retain an “active and relevant role” in the discussion about GHG emissions from biofuels. Updating it would also help inform the public and shape future biofuel policies. It would also provide a more fair comparison between corn ethanol and sugarcane ethanol. Finally, it would help ease the EPA’s workload as it reduced a backlog of new pathway petitions.