RFA to EPA: Use Current Data and GREET Model to Update Corn Ethanol GHG Analysis

In response to the U.S. Environmental Protection Agency’s recent workshop on biofuel greenhouse gas modeling, the Renewable Fuels Association submitted comments Friday stressing the importance of using updated and transparent data,  a level analytical playing field, and state-of-the-art modeling tools when conducting lifecycle analysis.

“RFA commends the EPA for holding the recent workshop and soliciting related comments,” wrote RFA President and CEO Geoff Cooper in a cover letter. “The Agency’s last analysis of the GHG emissions associated with corn ethanol was conducted in 2010, as part of the rulemaking process for the RFS after it was revised by the Energy Independence and Security Act of 2007. Over the ensuing 12 years, the RFA has consistently urged the EPA to update its analysis to reflect the efficiencies that have been gained in ethanol production and the advances that have been made in lifecycle analysis.”

Calling it the “gold standard” of lifecycle models, RFA strongly recommended that EPA use the Argonne National Laboratory GREET model to update the agency’s corn ethanol GHG analysis. In addition, EPA must consider significant indirect GHG effects for all fuels, including petroleum, which is consistent with the Energy Independence and Security Act of 2007.

Rebuttal to Lark et al.

Importantly, RFA used this comment opportunity to provide a thorough rebuttal to a recent paper by the University of Wisconsin’s Tyler Lark and others in the Proceedings of the National Academy of Sciences, titled “Environmental Outcomes of the U.S. Renewable Fuel Standard.”