EPA challenged on its ethanol lifecycle analysis

WASHINGTON, April 21, 2016 - On behalf of the Energy Future Coalition, the Urban Air Institute and the Governors’ Biofuels Coalition, Boyden Gray and Associates PLLC recently submitted a formal Request for Correction of Information to EPA on the agency’s lifecycle analysis for ethanol and gasoline under the federal Renewable Fuel Standard (RFS), according to 25x'25, which also supports the request.

Ethanol advocates have long called into question the data EPA has used in projecting the lifecycle analysis, notes 25x’25. “The agency has consistently used outdated – thus inaccurate – information that underrates ethanol’s performance as a cleaner, reduced-emission alternative in our nation’s transportation fuel supply,” says 25x’25, a group pushing for 25 percent of U.S. energy to be supplied by renewables by 2025.

Here are some of the groups’ assertions and details of their request:

• EPA has failed to assimilate new evidence demonstrating significant improvements that have been made in ethanol’s lifecycle greenhouse gas (GHG) emissions, therefore the agency should update its findings to reflect that the lifecycle GHG benefits of the RFS are much greater than predicted. For example, says 25x’25, data cited by the groups’ request show increased demand for corn causes much less land-use change and related emissions than EPA predicted in 2010. The evidence includes improved economic models and newly available land-use data from periods of increasing corn ethanol production, which show significant increases in yield but no significant increases in land use change.
•  Improved agricultural practices and technologies are substantially reducing the carbon intensity of ethanol by increasing the ability of soil to capture and retain carbon deep below ground. Evidence includes updated science on soil organic carbon, which indicates that best tillage practices sequester more carbon in the soil than previously thought. The evidence suggests that many cornfields are net carbon “sinks,” capturing more carbon than land-use change and corn farming releases, says 25x’25. These more efficient agricultural practices and technologies have also reduced the per-bushel amount of nitrogen fertilizer applied to the corn crop and eventually converted into the greenhouse gas nitrous oxide (N2O), the request states.
• Biorefineries have become much more efficient, using less natural gas and electricity to produce each gallon of ethanol, the groups point out. Biorefineries are also producing new co-products that reduce the carbon intensity of ethanol, including distillers grains, which is used as animal feed; corn oil, which replaces soy-based biodiesel; and other co-products that lower the carbon intensity of corn ethanol.

By contrast, petroleum-based fuels are becoming increasingly carbon intensive, the request states. As a result, the gasoline carbon intensity baseline should be significantly higher than EPA suggested, increasing the comparative benefit of ethanol, the groups say.

The groups submitting the request say they hope their appeal, coupled with an ongoing evaluation by the EPA Inspector General into EPA’s treatment of ethanol’s GHG and air quality effects, will compel EPA to update its analysis and report its findings to Congress.

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