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Indirect land use in RFS2 bugging corn-based groups

By ANN HINCH
Assistant Editor

WASHINGTON, D.C. — Last week’s announcement of a finalized renewable fuels standard (RFS) may be one of the few times a U.S. Environmental Protection Agency (EPA) announcement has brought cheers from several American farm groups – even while arousing concerns about indirect land use calculations.

“By raising the volume of biofuels available for our nation’s transportation fuel supply, the administration is building on the strong bipartisan efforts that began years ago to provide a homegrown solution to the energy challenges facing our nation,” said Bob Stallman, American Farm Bureau (AFB) president.

“We will be analyzing the rule in its entirety, but we are optimistic about the overall direction of support it offers renewable fuels.”
President Obama made three announcements on Feb. 3 relative to biofuel. One was about the RFS (also known as RFS2, updating the Congress-mandated RFS from 2007). Another was to unveil the first report from the Biofuels Interagency Working Group he created last year, co-chaired by the heads of the USDA, EPA and the U.S. Department of Energy, laying out a strategy for meeting the RFS (see article below).

The third announcement is a proposed rule for the USDA Farm Service Agency’s Biomass Crop Assistance Program (BCAP), created by the 2008 farm bill. BCAP financially helps with collection, harvest, storage and transportation of biomass, as well as conversion of land to grow it.

The rule would establish a “select geographical area” where the BCAP would fund up to 75 percent of the cost of establishing growth of a biomass crop, and annual payments for up to 15 years of its production.

The USDA and Commodity Credit Corp. are accepting public comments for 60 days regarding this proposal, which may be read in its entirety online (including instructions for submitting comments) at www.fsa.usda.gov/Internet/FSA_File/bcap_prm_on_public_display_ofr.pdf
RFS2 a mixed bag for corn

Under RFS2, total renewable fuels produced in the United States should be at least 36 billion gallons in 2022, escalating to that point annually from now; the mandate for 2010 is 12.95 billion gallons.

Of the 2022 total, cellulosic biofuel – little of which is being made now – should make up 16 billion gallons. Including this, the “advanced biofuel” requirement will be 21 billion gallons, which limits corn ethanol (not considered advanced) to 15 billion gallons.
To compare, according to the Renewable Fuels Assoc. (RFA), in 2008 the United States produced 9 billion gallons of corn ethanol.
This is the good part for many farm groups reacting positively to last week’s news on the RFS2, including the National Corn Growers Assoc. (NCGA), RFA, AFB, American Soybean Assoc. and National Biodiesel Board.

“EPA was right to recognize that ethanol from all sources provides significant carbon benefits compared to gasoline,” said RFA President Bob Dinneen.

He added that according to EPA’s modeling, corn-based ethanol achieves a 21 percent greenhouse gas (GHG) reduction compared to gasoline “when dubious ideas of international indirect land use change are included.” Without it, corn-based ethanol achieves a 52 percent GHG reduction.

The RFA added the EPA adjusted some of its assumptions and modeling from its proposed rule “to more accurately reflect the carbon profile of grain-based ethanol in the U.S.”

“These necessary corrections ensure that all grain-based ethanol will be eligible to meet the requirements and achieve the stated goals of the RFS, though continue to shortchange grain-based ethanol’s climate contributions,” stated Dinneen.

The RFS2 does now require biofuels to justify their GHG emissions reduction impact. “A significant aspect of the RFS2 program,” stated the EPA, “is the requirement that the lifecycle GHG emissions of a qualifying renewable fuel must be less than the lifecycle GHG emissions of the 2005 baseline average gasoline or diesel fuel that it replaces.”

Indirect land use figures into “lifecycle GHG emissions.” This means biofuels processes must factor in if they are actually contributing to GHG emissions by using feedstocks which require land to be cleared/burned to be produced. Biomass, cellulosic and other advanced biofuels are required to meet a reduction of 50-60 percent based on type. Corn-based biofuel’s reduction is minimum 20 percent.

Corn and ethanol groups are upset with this requirement. NCGA President Darrin Ihnen said the idea of international indirect land use is being applied only in the case of corn ethanol.

“This is the perfect example of bad science being applied unfairly,” he charged. “Removing the impacts from the international indirect land use theory means that corn ethanol actually provides a 52 percent reduction in greenhouse gas emissions, compared to gasoline. The EPA is not considering similar indirect impacts of petroleum-based fuels, so why are they so stringent when it comes to green, renewable corn ethanol?”

The AFB’s Stallman had similar remarks in his statement: “Continuing to utilize indirect land use changes to calculate GHG emissions is unfair to domestic biofuels. Using it as a measurement of biofuels’ carbon impact is still highly controversial and scientifically unproven.

“We will continue our efforts with policymakers on both sides of the aisle and in the administration to assure that biofuels live up to their enormous potential,” he said.

2/10/2010