RFA: EPA Overestimates ILUC Emissions
The Renewable Fuels Association (RFA) has sent another letter to the Environmental Protection Agency (EPA) regarding what they call errors in the calculations of biofuels’ carbon intensity under the Renewable Fuels Standard (RFS2). In the August 4th letter, RFA writes, “according to [EPA’s] own analysis, EPA grossly overestimated potential emissions from land use change (LUC) attributable to the [greenhouse gas] lifecycle of corn ethanol and other biofuels.”
The result of correcting this error, says RFA, is that it would greatly increase the greenhouse gas reduction benefits offered by ethanol under EPA’s calculations.
“Correcting this miscalculation reduces net LUC emissions (international and domestic) assigned to corn ethanol by 62% from 28.4 grams of CO2-equivalent/mega joule (g/MJ) to 10.8 g/MJ. Such a reduction in LUC emissions means overall lifecycle GHG emissions for 2022 average corn ethanol would be 38% less than baseline gasoline emissions, rather than the 21% estimate finalized by EPA.”
Regardless of RFA’s analysis, they still maintain that the inclusion of LUC impacts, particularly international impacts over which the U.S. has no control, is flawed policy and that EPA misinterpreted the intent of Congress when it passed the RFS.
In a recent blog post discussing their letter to EPA, Geoff Cooper, RFA’s Vice President of Research and Analysis, writes, “Despite the fact that real-world data and events have disputed the ILUC theory at every turn, EPA’s final rule for the RFS2 institutes a net LUC penalty (domestic and international) against corn ethanol of 30 kg CO2e/mmBTU (or 28.4 g CO2e/mega joule). This represents nearly 40% of the total GHG intensity of corn ethanol as estimated by EPA. When LUC emissions are excluded, EPA found corn ethanol from a natural gas dry mill reduces GHG emissions by 50% compared to gasoline. With LUC emissions, that benefit falls to around a 20% reduction.”
RFA says that this overestimation occurred as a result of the questionable methodological choice EPA made to isolate the LUC impacts of individual biofuels by increasing their production one at a time and holding all other biofuels at constant levels. More appropriately, the RFA notes, if EPA felt compelled by the statute to penalize biofuels for ILUC, it should have based those penalties on modeling that simultaneously increased production for all biofuels in accordance with the RFS requirements.
RFA notes that these problems are endemic of larger concerns regarding attempts to limit emissions from vehicles by unfairly penalizing biofuels.
You can read RFA’s letter to the EPA here and read Cooper’s comments regarding this issue here.





One year ago at the
“They’re something we just have to have if we’re ever going to get to the point where customers can choose to use gasoline or ethanol in whatever blends they want,” Lamberty said. He adds that blender pumps could become very important for marketers, if EPA approves some mixed level of blending ethanol for gasoline, such as 15 percent only for certain vehicles. “If they have a blender pump, they can use any combination,” he said.
The president of the 


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It’s August in the nation’s capitol and the climate is hazy, hot and humid with a chance of afternoon thundershowers, which
Despite the few legislative days left on the Congressional calendar, Dinneen says he remains hopeful that the blenders tax credit for ethanol will be extended in some form for some length of time before it expires at the end of the year. However, he remains very frustrated with delays in getting E15 or at least E12 approved in the interim by EPA. “EPA continues to be one of the most dysfunctional agencies in the federal government,” Dinneen says. “One wishes that the agency had been as diligent in studying the blow out preventers that BP was using in the Gulf of Mexico.”
Harkin says they talked with the officials about the importance of moving to E15, the need to mandate the manufacturing of flexible fuel vehicles and the installation of pumps that provide for high ethanol fuels and loan guarantees for biofuel pipelines. “We all agree that we must reduce our dependence on foreign oil, and that this will require a multi-pronged strategy, including more efficient use of transportation fuels and expanded use of alternatives to petroleum-based fuels,”
The cane crush in Brazil so far this year is running about 20 percent ahead of last year, which is not necessarily good news according to the
Meanwhile, here in the U.S., ethanol production was up 14,000 barrels per day in May, according to the