EPA seeks comments on sugar beet GHG analysis

The U.S. EPA is seeking comments on its analysis of upstream greenhouse gas (GHG) emissions attributable to the production of sugar beets for use as a biofuel feedstock. The agency’s notice considers a scenario in which non-cellulosic beet sugar is extracted for conversion to biofuel, while the remaining beet pulp is used an animal feed coproduct. Depending on the type and efficiency of the fuel production process technology used, the EPA said it anticipates biofuels produced from sugar beets could qualify as either renewable fuel or advanced biofuel. A 30-day comment period will officially open following publication of the analysis in the Federal Register.

Within its notice, the EPA notes it received petitions from Green Vision Group, Tracy Renewable Energy and Plant Sensory Systems requesting that it evaluate the GHG emissions associated with biofuels produced using sugar beets as feedstock.

The notice focuses on the EPA’s analysis of the GHG emissions associated with feedstock production and feedstock transportation associated with sugar beets when used to produce biofuel, including significant indirect impacts. Overall, the EPA estimates the GHG emissions associated with the production and transportation of sugar beets for use as a biofuel feedstock are approximately 45 kilograms of CO2-equivalent per wet short ton.

The largest region for sugar beet production in the U.S. is the Red River Valley of western Minnesota and eastern North Dakota. In total, the crop is grown at agricultural scale across five regions of the country, including 11 states. Since the mid-1990s, sugar beets have accounted for approximately 55 percent of U.S. sugar production.

Within its notice, the EPA explains that sugar beets are included in the U.S. sugar program, which is designed to support domestic sugar prices through loans to sugar processors. The program also includes a marketing allotment that sets the amount of sugar that domestic processors can sell in the U.S. for human consumption, and provides quotas on the amount of sugar that can be imported into the U.S. Sugar produced under the program cannot be used for biofuel purposes, with the exception of surplus sugar make available under the USDA Feedstock Flexibility Program.

Although the use of sugar beets in biofuel production has been limited in to the U.S., the EPA points out that sugar beets accounted for approximately 17 percent of European ethanol production in 2014. In the notice, the agency indicates that although its analysis of sugar beets was modeled as grown in the U.S., it also intends its analysis to cover sugar beets grown and processed into biofuels from other countries and imported to the U.S. as finished biofuel. However, the agency said it expects the vast majority of sugar beet-based biofuel used in the U.S. will be produced domestically.

A pre-publication version of EPA’s sugar beet GHG analysis is available on the agency’s website.