BIO asks EPA to maintain flexibility in life-cycle analysis for RFS

Posted June 9, 2009, at 3:25 p.m. CST

Large uncertainties in calculating international land-use change effects and associated greenhouse gas emissions remain in the U.S. EPA's life-cycle assessment of biofuels for the renewable fuel standard (RFS). The Biotechnology Industry Organization today asked the EPA to maintain flexibility to adjust and update the RFS regulations and the life-cycle assessments of biofuels as the science matures. BIO submitted its comments at a public hearing on the Renewable Fuel Standard held by the EPA in Washington today.

Brent Erickson, executive vice president of BIO's Industrial and Environmental Section, released the following statement:

"The Renewable Fuels Standard will be a critical tool to accelerate commercialization of advanced biofuels. As EPA's preliminary analysis shows, advanced biofuels have the potential to help reduce atmospheric carbon dioxide by providing net carbon sequestration, while enhancing energy security and revitalizing rural economies.

"Deployment of these advanced technologies depends critically on both the continued growth and evolution of first-generation biofuels and on fair, consistent, flexible, and reliable regulatory support from the federal government. EPA's proposal to impose speculative indirect land use change penalties on biofuels despite gross scientific uncertainty destabilizes both of these foundations and risks chilling investments in next-generation technologies.

"The EPA's own analysis makes clear that the infancy of the science makes the determination of international impacts highly uncertain at best. Furthermore, EPA's proposed approach to classifying biofuels into a limited number of rigid, pre-determined categories limits the industry's ability to innovate, since practice and process improvements are not recognized or rewarded.

"BIO asks that EPA regulations be flexible and include room to be adjusted over time as the science improves, and that the agency limit the use of its methodology to the narrow task of determining which alternative fuel paths meet the statutory standards for cellulosic and advanced biofuels."