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Grassroots Voice: The Realities of the Political Process
by Brian Jennings

The political process is messy. That means the decisions that Congress and federal agencies render are rarely clean victories for any group.

EPA’s final RFS2 rule is a perfect example. Their decisions on how to implement the rule and whether various forms of biofuel will qualify for the lifecycle greenhouse gas (GHG) reduction requirements did not fully satisfy anyone, yet at the same time no one was entirely unhappy either.

ACE found the final RFS2 rule imperfect in many ways (namely that EPA insisted upon penalizing ethanol for so-called international land use changes), but on balance the rule will help ethanol succeed.

Perhaps most importantly, EPA’s final rule indicated ethanol reduces GHGs more significantly than the agency previously assumed. EPA has ruled that corn ethanol reduces GHG emissions compared to 2005 petroleum by at least 20 percent. The result: all corn ethanol qualifies for the RFS2 program.

EPA indicated that three factors drove their decision to update and refine their modeling which led to improving the carbon footprint for corn ethanol.

First, the agency acknowledged the crop yields they were modeling to predict land use changes were “wrong” and outdated. With updated yields, the models proved that corn ethanol resulted in less land needed domestically for corn and internationally for other crops.

Second, EPA credited distillers grain for replacing both corn and soybean meal in livestock feed rations (something ACE specifically asked them to do). Because DDGs are an efficient feed product, less corn is needed for livestock feed and fewer soybeans are needed to replace corn than EPA previously assumed, and exports of corn are not reduced by corn ethanol.

Third, EPA’s proposed rule assumed that corn ethanol in the U.S. displaced pasture land in Brazil which in turn displaced the Amazon rainforest. Remarkably, EPA decided to use not only more satellite imagery but also more precise satellite data for the final rule and found that, in reality, these sort of land use changes did not occur as predicted. Recall that as ethanol production has increased, deforestation rates in the Amazon have decreased.

EPA also determined ethanol and the RFS2 program would accomplish much by 2022, including:

· Reducing foreign oil purchases by $41.5 billion.

· Increasing farm income by $13 billion.

· Cutting GHG emissions by 138 million metric tons, the equivalent of removing 27 million cars from the road.

The next major decision our industry awaits from EPA is on the E15 waiver. To avoid another “messy” outcome (i.e. E15 approved for new cars only), ACE will remain vigilant in providing EPA the data and rationale for making their conclusion on our request as “clean” as possible.

© American Coalition for Ethanol, all rights reserved.
The American Coalition for Ethanol publishes Ethanol Today magazine each month to cover the biofuels industryís hot topics, including cellulosic ethanol, E85, corn ethanol, food versus fuel, ethanolís carbon footprint, E10, E15, and mid-range ethanol blends.
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