A public hearing on the U.S Environmental Protection Agency’s (EPA) proposed rule to implement the expanded Renewable Fuels Standard (RFS2) drew a series of depositions from members of the biofuels industry, agriculture, environmental and research organizations, all of them concerned about the implications of the proposed rule on the future of biofuels and the environment. The hearing was part of a three-day workshop on the RFS2 held in Washington, D.C.

In the EPA''''s notice of proposed rulemaking on RFS2, issued last month, the agency included indirect land use change (ILUC) emissions in its lifecycle analysis requirements, a disappointing decision for biofuels industry groups, agricultural academics and some lawmakers who had asked the EPA to delay ILUC requirements until there is a widely accepted methodology for determining its impacts.

Testifying on behalf of the Brazilian Sugarcane Industry Association, Joel Velasco, the organization’s chief representative for North America, explained that the science used to determine indirect impacts is quite limited, highly uncertain and open to misuse. “If the EPA is determined to push forward with indirect land use calculations -- as it appears likely to do -- we firmly request that the best available data and latest research be used before rushing to conclusions," he said.

Velasco also explained "basic errors" made in the EPA’s lifecycle analysis, which failed to consider key aspects in the process of making sugarcane ethanol in Brazil. "First, the default values for cane straw yield appear to be based on Hawaiian, not Brazilian, sugarcane varieties. Second, the carbon intensity of Brazilian chemicals inputs is significantly lower than the GREET model assumes. And we even noted that the trucks used in sugarcane mills are far more efficient than assumed," he added.

In another deposition, the Executive Director of Brazil’s Institute for International Trade Negotiations (ICONE), Andre Nassar, also explained that ILUC methodology is not valid for calculating the cause-effect relationship of the expansion of sugarcane and grains on the conversion of the Amazon Rainforest into pasture. According to Nassar, “the analysis is missing many deforestation drivers that have nothing to do with sugarcane and other crops”. He also pointed out that cattle intensification in Brazil is freeing up more land than needed for sugarcane expansion.

Sharp disagreements on the issue of including ILUC on the RFS2 became evident throughout the workshop. The EPA has received a number of requests to extend the public comment period past the current July 27 deadline, which might make it impossible to implement the standard by the beginning of 2010. UNICA has indicated it would prefer to see the EPA’s assessment wrapped up by the end of this year, and intends to submit further comments to that effect before the deadline. According to Velasco, “the future of renewable energy will be in jeopardy if we can’t get this rule in place by year’s end”.

For the full text of Joel Velasco’s submission at the EPA workshop, click here.