The American Soybean Association (ASA) today reacted to the proposed rule for indirect land use and renewable biomass provisions in the U.S. Environmental Protection Agency’s (EPA) expanded Renewable Fuel Standard (RFS-2). The approach EPA has proposed to use for their proposed rule on RFS-2 implementation is significantly flawed, could make the RFS-2 goals unattainable and harms the competitive position of the U.S. soy biodiesel industry.

"ASA is particularly disappointed that EPA does not recognize the evidence that soy biodiesel use in the United States does not drive international land use change," said ASA President Johnny Dodson, a soybean producer from Halls, Tenn.

Under the Energy Independence & Security Act (EISA) of 2007, to be eligible for the new RFS-2, biodiesel must meet a 50% greenhouse gas (GHG) reduction relative to petroleum diesel. Under the existing GREET model (Greenhouse gases, Regulated Emissions, and Energy use in Transportation) used by the EPA and the U.S. Department of Energy, biodiesel achieves a 78% GHG reduction relative to petroleum diesel.

"When calculating the life cycle GHG impact of biofuels, the statute directs EPA to consider direct and indirect emissions, including indirect land use, of all stages of the fuel and feedstock production," Dodson said. "The primary area of concern and disagreement has emerged over the international indirect land use assumptions that EPA has proposed to use in conducting their updated life-cycle GHG analysis."

Indirect Land Use Change (ILUC) refers to the GHG emissions caused by land converted to crop production globally. Initial review of the EPA’s Propose Rule suggests that they have used land conversions to cropland that occurred from 2001-2004 and extrapolated that data into the future to estimate potential cropland expansions. The fact that little U.S. soy biodiesel was produced in the years 2001-2004 should provide indication that soy biodiesel does not drive land use change. Yet the EPA’s proposed rule would extrapolate these international land use changes and attribute future land use changes to U.S. biodiesel.

"The life-cycle greenhouse gas emissions for soy biodiesel that EPA has proposed are derived from faulty indirect land use assumptions, flawed analysis and misplaced penalties," Dodson said. We look forward to submitting comments and hope that more appropriate analysis and some common sense will prevail during the rulemaking process."

Biodiesel is the cleanest burning biofuel currently used in commercial markets. Biodiesel is a renewable and sustainable energy source that can play a significant role in our national efforts to increase our energy security and improve our environmental footprint. Biodiesel has also provided a significant market opportunity for U.S. soybean farmers and jobs and economic development for rural communities.