WASHINGTON, D.C. - In compliance with Section 204 of the Energy Independence and Security Act (EISA), the U.S. Environmental Protection Agency (EPA) is required to report to Congress every three years on the environmental and resource conservation impacts of increased biofuel production and use, including air and water quality, soil quality and conservation, water availability, ecosystem health and biodiversity, invasive species, and international impacts. On January 19th, EPA released a draft report which they described as "preliminary" and cautioned that "it is being circulated for comment on its technical accuracy and policy implications" and "does not represent…any Agency determination or policy."

While the report explicitly addresses "key uncertainties and unknowns" and urges caution in interpreting its preliminary conclusions, the qualitative assessments and findings will undoubtedly be cited by biofuel opponents seeking to slow or stop the expansion of biofuel production and use. In an effort to provide more context and balance to the authors' conclusions, RFA has analyzed the draft report in detail and plans to submit comments to EPA. RFA's initial comments on the report are provided below.

• The report fails to compare the potential environmental impacts of biofuels to the impacts of the petroleum fuels that they replace. The report acknowledges that biofuels required under EISA are "…expected to achieve a 138-million metric ton reduction in CO2 equivalent emissions by 2022 compared to continued reliance on petroleum-based fuels." But beyond this brief comparison of the GHG benefits of biofuels relative to baseline petroleum fuels, there are no comparisons to the impacts of petroleum fuels on water quality and quantity, air quality, soil quality, ecosystems and biodiversity, or international impacts. The relative impacts of one particular energy option simply cannot be fairly determined unless they are uniformly compared to the impacts of competing energy options. Indeed, the EPA authors themselves recognize that the qualitative assessments in the paper have little value when not viewed in context with other energy options. EPA states, "While this report provides a starting point for comparing the relative impacts associated with a range of different biofuel feedstock and production processes, it will also be useful to assess biofuel impacts in the larger context of the conventional petroleum fuels that are being displaced under the RFS2 mandates."

• There is a disproportionate focus on the potential hazards of expanded biofuels production, while many of the potential benefits are overlooked. In many cases, the report examines only the potential negative environmental impacts that could result from biofuels expansion. For example, the positive impacts of ethanol use on carbon monoxide, benzene, and other toxic emissions are largely overlooked. The relative environmental benefits associated with ethanol in the event of a spill or leakage are also discounted. As another example, only the potential environmental challenges of feeding co-products like distillers grains to livestock are discussed. The report ignores the ability of distillers grains to reduce an animal's lifecycle methane emissions, as well as other environmental and animal health benefits that result from feeding these co-products.

• Many of the potential negative environmental impacts discussed in the report stem from the unproven assumption that biofuels expansion will induce indirect land use change (ILUC). Despite the fact that there is tremendous disagreement in the scientific community about the occurrence and magnitude of ILUC, many of the potential negative impacts discussed in the EPA report are based on the notion that ILUC will occur in response to biofuels expansion. In particular, many of the potential negative domestic and international impacts on soil quality, air quality, ecosystems, and biodiversity stem from the authors' acceptance of the ILUC analysis performed by EPA for the RFS2. The report fails to acknowledge more recent research on ILUC that shows much smaller impacts than the EPA analysis. For instance, no mention is made of the work published by Purdue University in April 2010, which estimated possible ILUC emissions for corn ethanol at half of the level estimated by EPA. Further, there is no mention of recent empirical analyses conducted by the Department of Energy's Oak Ridge National Laboratory that found virtually no ILUC emissions could be attributed to corn ethanol expansion in the period from 2002-2008. In their discussion of key uncertainties, the authors do acknowledge that "Increased corn and soybean yields may offset the need for increased acres in production to achieve EISA goals in 2022." However, that cursory statement is not further explored and is substantially overshadowed by the paper's lengthy discussion of ILUC.

• The report doesn't properly recognize the significant technological advancements occurring in agricultural in recent years, nor does it incorporate the latest research on ethanol processing efficiencies. By glossing over the recent improvements in input efficiency and overlooking the accelerated rate of gain in productivity, the authors appear to be assuming that the future of agricultural productivity will behave like the past. The EPA report, and many of the papers it relies upon, suggest feedstock production increases resulting from biofuels expansion will be accompanied by linear increases in input usage. Farmers have already shown this is not the case, as chemical and nutrient inputs per unit of output have fallen dramatically in recent decades. Further, the paper's discussion of water and energy requirements for ethanol biorefineries disregards the latest research by the University of Illinois-Chicago, which shows substantial improvements in water and energy efficiency. The authors' discussion of GHG emissions from ethanol plants fails to mention that the CO2 emissions resulting from fermentation are carbon neutral and biogenic in nature (because the released CO2 was recently removed by the atmosphere by the growing feedstock).

• For most discussions of potential environmental impacts, the authors appear to assume that farmers and biofuel producers won't readily mitigate potential risks. Numerous best management practices, regulatory programs, technical guidance, and mitigation tools already exist to assuage the types of environmental and resource risks that EPA discusses in the paper. Indeed, as the authors acknowledge, "Many activities, processes, and products associated with the biofuel supply chain are already regulated, are subject to limitations, or are mitigated through various approaches, as discussed in these chapters." Yet, despite this recognition, the authors proceed to discuss potential environmental risks as if there no safeguards in place to mitigate them. Farmers and biofuel producers have a long history of effective compliance with regulations, implementation of BMPs, and rapid adoption of new technology to minimize or eliminate potential environmental risks.

• The report prominently cites several discredited studies. In discussing the potential soil quality impacts of biofuels expansion, the authors cite research by Timothy Searchinger. The Searchinger work on ILUC and carbon debts is generally viewed today as not credible and it was vigorously challenged by scientists in government, academia and industry. Similarly, the research by David Pimentel that is cited in the EPA report has been rejected by the scientific community on the grounds that it uses outdated assumptions and questionable methodology to reach its conclusions.

EPA's draft report needs substantial improvement before it can be submitted to Congress. The report should be reconstituted to provide lawmakers a more impartial assessment of the potential risks and benefits of biofuels expansion. Further, the preliminary report admittedly lacks the proper context to compare the attributes of biofuels to petroleum fuels and other energy options. Sound judgments on the risks and benefits of particular energy options simply cannot be made without an ability to compare those options using a consistent analytical framework. Finally, EPA should ensure that it is reviewing the most current data and information regarding feedstock and biofuels production processes.

SOURCE: Renewable Fuels Association