Analysis of Greenhouse Gas Emissions for Biofuels Produced from Camelina Oil and Other Feedstocks
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1 February 6, 2012 Air and Radiation Docket Docket No. EPA HQ OAR Environmental Protection Agency Mailcode: 6406J 1200 Pennsylvania Ave. NW. Washington, DC Docket No. EPA HQ OAR (RIN 2060-AR07) Re: Comments on Proposed and Direct Final Rules for Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program To Whom It May Concern: Clean Air Task Force, Environmental Working Group, Friends of the Earth, National Wildlife Federation and the Natural Resources Defense Council appreciate the opportunity to submit comments on the Environmental Protection Agency s proposed and direct final rules entitled Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. We disagree with EPA s view that these rules are noncontroversial actions and therefore request that the agency carries out a full rulemaking. Our comments address three main issues: (1) an assumption that production of camelina and other biofuels feedstocks would not result in any land use change; (2) the potential for some of the proposed feedstocks to become invasive; and (3) impacts of corn stover removal. Analysis of Greenhouse Gas Emissions for Biofuels Produced from Camelina Oil and Other Feedstocks With the passage of the Energy Independence and Security Act (EISA) of 2007, EPA is required to include greenhouse gas (GHG) emissions from direct and indirect land use change in its analysis of new biofuels pathways. While some biofuel feedstocks like camelina, napier grass, giant reed and others are not predicted to result in large land use changes, even small changes, once summed up, can have a detrimental impact on our climate, water, air, soil and wildlife resources. We understand the difficulty in calculating GHG emissions from biomass production but as history has shown, scaling up biofuels production may result in numerous unintended consequences that either may or may not have been predicted years ago. As EPA noted in the direct final rule, research on biomass production from sources like camelina and giant reed is still in its early stages. As the University of Florida s Cooperative Extension Service noted, research related to [camelina] production is limited and will develop as its value increases as a renewable energy crop. 1 Despite limited information, EPA made an assumption 1 Wright, D. and Jim Marois. Camelina Production in Florida. Feb Florida Cooperative Extension Service. Accessed online 6 Feb at
2 that all camelina used for biofuels production will be grown on fallow land and will thus result in no land use change from additional acres being brought into production. 2 Unfortunately, the agency failed to cite adequate evidence to validate this assumption. By relying on one study that was co-authored by an industry official, EPA failed to explain how no land use change would occur if camelina production was significantly scaled up. 3 Shonnard et al. (2010) state that, Altogether more than 5 million U.S. acres have the potential to grow camelina in a sustainable manner with no impact on food supply. 4 But, EPA assumes that almost twice that amount 8 million acres would be planted to camelina. With a near-record number of acres being planted to corn, primarily to produce ethanol to meet the Renewable Fuel Standard (RFS) mandate, increased pressure has been placed on the environment as more marginal and fallow land has been brought into production. EPA should analyze how many acres of marginal and fallow land are currently available for biofuels production and what impacts may occur at the margin after biofuels production from camelina or other feedstocks is scaled up. Additionally, EPA must provide a more robust and better-substantiated analysis of likely production practices. When analyzing the environmental consequences of increased production of camelina, giant reed, napier grass, and energy cane, it is not enough for the agency to describe the least damaging ways in which these crops might be grown. 5 The fact that it may be physically possible to grow crops using a certain approach says nothing about whether that approach is the most economically efficient option available to farmers particularly when production is scaled up to commercially relevant volumes. Growing practices will be determined largely according to a variety of economic factors, such as input costs and commodity prices. In its proposal, EPA failed to provide factual data that show how those economic factors will shape production practices, nor has it described the methodology it would use to analyze such data. 6,7 Consequently, EPA has not provided an adequate basis for its assessment that an increase in biofuels-related production of camelina, giant reed, napiergrass and energy cane will not result in a significant increase in land use change-related GHG emissions. 2 Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. Federal Register Vol. 77, No. 3 (5 Jan. 2012): Accessed online 6 Feb at 3 Shonnard, D., L. Williams and T. Kalnes. Camelina-Derived Jet Fuel and Diesel: Sustainable Advanced Biofuels. Environmental Progress & Sustainable Energy 29.3 (2010): Accessed online 6 Feb at 4 Shonnard, D., L. Williams and T. Kalnes. Camelina-Derived Jet Fuel and Diesel: Sustainable Advanced Biofuels. Environmental Progress & Sustainable Energy 29.3 (2010): Accessed online 6 Feb at 5 See, e.g., 77 Fed. Reg. at 702, where EPA asserts that camelina can be grown during different growing seasons, can also be used to break planting cycles, and has certain attributes that allow it to be grown on marginal land without indicating the economic likelihood that these options will be pursued. 6 Cf. CAA 307(d)(3), 42 U.S.C.A. 7607(d)(3). 7 In fact, EPA acknowledged that it lacked key data concerning the impact that increased production of camelina would have on markets and market-mediated environmental effects. 77 Fed. Reg. at 702.
3 The agency also states that, The renewable biomass provisions under the Energy Independence and Security Act would prohibit direct land conversion into new agricultural land for camelina production for biofuel internationally. But without proper monitoring and enforcement, this provision will not prevent farmers from converting new land to biomass production. By assuming no land use change, EPA may underestimate the increase in GHG emissions that could result from breaking new land. This assumption is not only an issue with camelina production but could also underestimate land use change emissions associated with biomass production from giant reed, napiergrass, energy cane and other feedstocks. EPA again assumes that these feedstocks will be grown on the least productive land without citing any specific models or studies that may have informed this decision. EPA also overestimated long-term camelina yields in the direct final rule. Its estimates are on the high end of the current yield range in states like Pennsylvania, Oregon and Montana. 8 EPA assumes that U.S. yields will average 1650 pounds per acre and that investment in new seed technology could increase yields to 3000 pounds per acre. 9 However, other researchers estimate that camelina s yield potential ranges from 330 to 2400 pounds per acre without irrigation. 10,11 Reaching yields of 3000 pounds per acre may be attainable in certain areas, but previous trials do not suggest that average yields could reach this level in just ten years. Even with nitrogen application rates at two to four times the EPA estimated rate of 40 pounds per acre in 2022, yields barely exceeded 2000 to 2200 pounds per acre in trials in Colorado. 12 With the huge increase in corn ethanol production and corn acreage, new land has been brought into production with detrimental environmental consequences. 13 As an example, in 2011, the 8 McKay, K.A. and P.F. Lamb. Camelina Production in Montana. March Montana State University Extension. Accessed online 6 Feb at 9 Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. Federal Register Vol. 77 No. 3 (5 Jan. 2012): Accessed online 6 Feb at 10 Ehrensing, D.T. and S.O. Guy. Camelina. Jan Oregon State University Extension Service. Accessed online 6 Feb at 11 McKay, K.A. and P.F. Lamb. Camelina Production in Montana. March Montana State University Extension. Accessed online 6 Feb at 12 Lafferty, R.M., C. Rife and G. Foster. Spring Camelina Production Guide for the Central High Plains. Dec Blue Sun Agriculture Research and Development. Accessed online 6 Feb at =id&blobtable=mungoblobs&blobwhere= &ssbinary=true. 13 Wallander, S., R. Claassen and C. Nickerson. The Ethanol Decade: An Expansion of U.S. Corn Production, Aug United States Department of Agriculture s Economic Research Service. Accessed online 6 Feb at
4 U.S. produced about 13 billion gallons of ethanol by utilizing 40 percent of domestic corn production; U.S. farmers responded to near-record corn prices by planting 92 million acres of corn, the second-highest level since The RFS2 final rulemaking predicted that the U.S. would not plant this many acres until 2022 when corn yields reached 185 bushels per acre and corn ethanol production met its 15-billion-gallon mandate. However, with erratic weather last year, including record drought and flooding in some areas, average corn yields fell to 147 bushels per acre, the lowest level since Increased corn plantings and corn ethanol production has resulted in more water pollution, higher greenhouse gas emissions, less wildlife habitat and higher rates of soil erosion. On an international scale, cropland expansion has been even more pronounced. Abbott et al (2011) found that, Land area for thirteen major world crops increased by 27 million hectares in the five years since a 3 percent expansion of harvested area, with most of the land expansion occurring outside the United States. 15 The entirety of the increase cannot be directly tied to the biofuels boom, but since biofuels mandates introduce a fixed, inelastic demand into the market, commodity prices have become more volatile as some stocks have fallen to all-time lows. Other impacts of cropland expansion on GHG emissions, water and air quality, soil erosion and wildlife habitat should be factored into future EPA analyses of biofuels pathways to ensure that the same mistakes made with corn ethanol are not repeated with other biofuels. Failure to Evaluate the Potential for Feedstocks to Become Invasive The proposed and direct final rules include approval of giant reed (Arundo donax) and napiergrass (Pennisetum purpureum) both of which are non-native to the U.S. and have been identified as invasive species in certain parts of the country along with camelina (Camelina sativa) and energy cane (scientific name not provided in rule), two non-native species. In publishing this rule, EPA ignored Executive Order Under this executive order, federal agencies are required to not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions. 16 Despite this clear order, EPA has issued a rule that is likely to lead to the spread of invasive species without any kind of analysis on the potential harm caused by the promotion of the invasive species or determination of the benefits. 14 United States Department of Agriculture. World Agricultural Supply and Demand Estimates. 12 Jan Accessed online 6 Feb at 15 Abbott, P.C., C. Hurt and W.E. Tyner. What s Driving Food Prices in 2011? July Farm Foundation. Accessed online 6 Feb at 16 Clinton, William. Invasive Species. Executive Order of February 3, Federal Register Vol. 64, No. 25 (8 Feb. 1999): Accessed online 6 Feb at
5 Giant reed (Arundo donax), also known as giant cane, was originally introduced into the United States in the 1800s for erosion control and windbreaks, but has since become an invasive plant in much of its introduced range around the world. In the United States, giant reed is listed as a noxious weed in Texas, an exotic plant pest in California, an invasive weed in Hawaii, and as an invasive, exotic pest in Tennessee. 17 Furthermore, it has been noted as either invasive or a serious risk in New Mexico, Alabama, and South Carolina. 18 Researchers applying a Weed Risk Assessment to giant reed in Florida concluded that the plant should be rejected for use as a biofuel crop, saying that, The combination of widespread distribution of giant reed propagules and inherent weedy characters greatly increases the likelihood of escape and subsequent environmental damage. 19 Close to 30,000 hectares of riparian land in Texas are now estimated to be dominated by giant reed, 20 and the Texas Department of Agriculture has determined that giant reed has the potential to cause serious economic or ecological harm to the state. Costs to control the species are extremely high; in California, costs range between $5,000 and $17,000 per acre to eradicate the weed. 21 Napiergrass (Pennisetum purpureum), also known as elephant grass, was introduced in the early 1900s to areas of Texas and Florida, but since then it has become a highly troublesome weed. Napiergrass has been identified as one of Florida s most problematic weeds and is listed as an invasive species by the Florida Exotic Pest Plant Council. 22 The species has been documented in nearly 30 counties throughout the state, where it has taken over areas of canal and ditch banks, blocking access and impeding water flow. 23 Napiergrass can reproduce both vegetatively and through seed dispersal, and it can grow very quickly. By issuing this rule, EPA is carrying out an action that directly incentivizes planting two known invasive species, an action that is fundamentally at odds with Executive Order Given the clear risk of invasion by both Arundo donax and Pennisetum purpereum, and the potential risk 17 McWilliams, J. Arundo Donax. USDA Forest Service Fire Effects Information System Accessed online 6 Feb at 18 Florida Native Plant Society Policy Statement on Arundo Donax. Florida Native Plant Society Accessed online 6 Feb at 19 Barney, J.N. and J.M. DiTomaso. Nonnative Species and Bioenergy: Are We Cultivating the Next Invader? BioScience 58 (2008): Mack, R.N. Evaluating the Credits and Debits of Proposed Biofuel Species: Giant Reed (Arundo donax). Weed Science 56 (2008): California Invasive Plant Council. Arundo Donax Distribution and Impact Report. March Accessed online 6 Feb at 22 Odero, D.C. and C. Rainbolt. Napiergrass: Biology and Control in Sugarcane. University of Florida Institute of Food and Agricultural Services Extension Accessed online 6 Feb at 23 Florida Fish and Wildlife Conservation Commission. Plant Management in Florida Waters: An Integrated Approach. Status of the Aquatic Plant Maintenance Program in Florida Public Waters, Annual Report Fiscal Year Accessed online 9 Dec at
6 posed by the non-native species camelina and energy cane, we strongly urge the EPA to do a full rulemaking process in which Executive Order is fully considered for all feedstocks. At the very least, pursuant to EO 13112, EPA must: 1. Explain how its proposed action will not promote the introduction or spread of the proposed feedstocks in the United States, and 2. Demonstrate that the benefits of qualifying the feedstock-derived fuels for use within the RFS2 clearly outweigh the potential harm caused by further expansion of the proposed feedstocks, and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with this action. Furthermore, we urge EPA to ensure compliance with EO in future rulemaking processes by incorporating an assessment of invasiveness in future pathway determinations under the RFS program. Impacts of Corn Stover Removal When calculating GHG emissions from the removal of corn stover, EPA rightfully included emissions from a shift in cropland due to increased profitability of corn production and the need for additional fertilizer to replace nutrients lost from stover removal. However, the agency then mistakenly assumed that using corn stover for biofuels production would result in additional notill farming without any evidence that the stover would actually be removed from no-tilled acres. With recent increased profitability from corn production, farmers may actually increase tillage to reap high corn prices. As the RFS s Regulatory Impact Analysis (RIA) notes, a farmer will be concerned with using those tillage operations that will provide him with the highest possible yield at the next harvest, and not necessarily those that tend to maximize erosion control on his lands. 24 Without assurance that farmers will actually adopt more no-till practices, EPA may underestimate the amount of soil carbon that could be lost to the atmosphere if farmers either continue or adopt more intensive tillage operations. As the RFS2 RIA also notes, Residue removal leading to higher erosion and runoff rates would greatly decrease SOM and nutrients It s been reported that crop yield and the value of environmental services (C and N sequestration) were greater for soils with greater SOC. Limited research has shown that removing stover reduces grain and stover yield of subsequent crops and further lowers soil organic matter levels Environmental Protection Agency. Renewable Fuel Standard Program (RFS2) Regulatory Impact Analysis. EPA-420-R Feb Accessed online 6 Feb at 25 Environmental Protection Agency. Renewable Fuel Standard Program (RFS2) Regulatory Impact Analysis. EPA-420-R Feb Accessed online 6 Feb at
7 Schlesinger (1985) reported that soil organic carbon levels have already dropped by as much as 50 percent from levels prior to cultivation in this country. 26,27,28 Several researchers have found that as more corn stover is extracted, particularly stalks very close to the soil surface, soil organic carbon levels will decline. 29 Clapp et al (2000) found that soil organic carbon (SOC) levels in notill field plots with stover removal remained virtually unchanged over time while fields with corn stover returned increased SOC levels by about 14 percent; after 13 years, the portion of SOC levels derived from corn stover on land where no stover was harvested was three times as high as on fields where stover was extracted. 30 In 2011, EPA s draft triennial report to Congress indicated that without good conservation and best management practices, corn stover ethanol would be detrimental to nearly all environmental factors that were analyzed, including water quality, water quantity, soil quality, air quality and biodiversity. 31 The figure below shows that when corn stover is removed without offsetting practices, soil carbon levels could decline. These findings are similar to other studies, especially Johnson et al (2006). 32,33 26 Cruse, R.M. and C.G. Herndl. Balancing Corn Stover Harvest for Biofuels with Soil and Water Conservation. Journal of Soil and Water Conservation 64.4 (July/Aug. 2009): Schlesinger, W.H. Changes in Soil Carbon Storage and Associated Properties with Disturbance an Recovery. In the Changing Carbon Cycle: A Global Analysis. Ed. J.R. Trabalha and D.E. Reichle. New York: Springer-Verlag, p Davidson, E.A., and I.L. Ackerman. Changes in Soil Carbon Inventories Following Cultivation of Previously Untilled Soils. Biogeochemistry 20 (1993): Hoskinson, R.L., D.L. Karlen, S.J. Birrell, C.W. Radtke and W.W. Wilhelm. Engineering, Nutrient Removal, and Feedstock Conversion Evaluations of Four Corn Stover Harvest Scenarios. Biomass and Bioenergy 31 (2007): Accessed online 21 July 2011 at Biomass%20Bioenergy.pdf. 30 Clapp, C.E., R.R. Allmaras, M.F. Layese, D.R. Linden and R.H. Dowdy. Soil Organic Carbon and C Abundance as Related to Tillage, Crop Residue, and Nitrogen Fertilization Under Continuous Corn Management in Minnesota. Soil and Tillage Research 55 (2000): Environmental Protection Agency. Biofuels and the Environment: the First Triennial Report to Congress (External Review Draft). EPA/600/R-10/183A Accessed online 6 Feb at 32 Johnson, J.M.F., R.R. Allmaras and D.C. Reicosky. Estimating Source Carbon from Crop Residues, Roots, and Rhizodeposits Using the National Grain-yield Database. Agronomy Journal 98 (2006): National Academy of Sciences, National Academy of Engineering, and National Research Council. Liquid Transportation Fuels from Coal and Biomass: Technological Status, Costs, and Environmental Impacts. Washington, D.C.: The National Academies Press, Accessed online 21 July 2011 at
8 In the RFS2 final rulemaking, EPA projected that differing levels of corn stover could be removed from land based on whether it was conventionally tilled, conservation tilled or no-tilled. However, some researchers have recommended that other factors be taken into account beyond the type of tillage. For instance, Wilhelm et al (2007) write that stover should not be extracted from highly-erodible land (HEL) since water and soil quality can deteriorate if too much soil cover is removed. 34 Finally, this figure shows that more residue may be necessary to retain soil organic carbon than to minimize soil and wind erosion. 35,36 The figure also demonstrates that more stover must be retained on land that is in rotation with another crop like soybeans as compared to continuous corn production. 34 Johnson, J.M., D. Reicosky, R. Allmaras, D. Archer and W. Wilhelm. A Matter of Balance: Conservation and Renewable Energy. Journal of Soil and Water Conservation 61.4 (2006): Accessed online 22 July 2011 at pdf. 35 Wilhelm, W.W., J.M.F. Johnson, D.L. Karlen, and D.T. Lightle. Corn Stover to Sustain Soil Organic Carbon Further Constrains Biomass Supply. Agronomy Journal 99 (2007): National Academy of Sciences, National Academy of Engineering, and National Research Council. Liquid Transportation Fuels from Coal and Biomass: Technological Status, Costs, and Environmental Impacts. Washington, D.C.: The National Academies Press, Accessed online 21 July 2011 at
9 In conclusion, we urge EPA to consider changes to soil carbon from the removal of corn stover as they may have an impact on the GHG score of this new biofuel pathway. We also urge the agency to not simply assume that additional no-till practices will be adopted with residue extraction. As explained in a recent report that examines the use of Midwestern corn stover for cellulosic biofuels, important questions about production i.e., issues that bear heavily on the fuel s projected environmental performance need to be answered. According to the report, Harnessing the Power of Biomass Residuals (2011), these unresolved issues include the size of the potential stover resource given the competing needs of protecting soil and water resources and sustaining grain harvest, and the logistical challenges of harvesting, transporting, and storing large quantities of cellulosic biomass. 37 The report continues: Given that cellulosic fermentation technologies are not ready for widespread application, stover production and harvest field trials should continue to study and clarify production and logistical issues. Work under way at Iowa State University s New Century Farm is a good example of the type of research that is 37 Brick, Steve. Harnessing the Power of Biomass Residuals: Opportunities and Challenges for Midwestern Renewable Energy ( Harnessing ). Chicago: The Chicago Council on Global Affairs, pp. 50. Accessed online 6 Feb at mass_residuals.pdf.
10 needed to better address these questions. 38 Similar research should be replicated in the six-state Midwest region, perhaps focusing on the stover concentration areas described earlier. Research should focus on testing the economic and ecological feasibility of different tillage practices, and a close look at behavioral factors involved is also needed. The same soil management practices that would allow higher stover harvests would also reduce erosion and water pollution and potentially increase soil carbon levels. These benefits should be studied, tallied, and included in the case for change. 39 Consequently, until these important issues are examined in sufficient detail, and until their impact on lifecycle emissions have been analyzed, EPA cannot adequately assess the net climate impact associated with stover-derived biofuels. Conclusion Again, we thank EPA for the opportunity to comment on these proposed and direct final rules on new biofuels pathways. We urge the agency to consider the three issues that were addressed above and undergo the full rule-making process. We also support the agency as it plans to periodically review and revise the methodology and assumptions associated with calculating the GHG emissions from all renewable fuel feedstocks. 40 Thanks again and please let us know if you have any questions. Sincerely, Jonathan Lewis Senior Counsel Climate Policy Clean Air Task Force Sheila Karpf Legislative and Policy Analyst Environmental Working Group Michal Rosenoer Biofuels Policy Campaigner Friends of the Earth Aviva Glaser Legislative Representative, Agriculture Policy 38 Citation in original: United States Department of Agriculture. New Century Farm Accessed online 6 Feb at 39 Harnessing at Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. Federal Register Vol. 77, No. 3 (5 Jan. 2012): Accessed online 6 Feb at
11 National Wildlife Federation Nathanael Greene Director of Renewable Energy Policy Natural Resources Defense Council
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