Comments to Draft EPA Regulations on Biofuels Mandate (RFS2)

Comments to Draft EPA Regulations on Biofuels Mandate (RFS2)

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The Renewable Fuels Standard (RFS), as passed in the 2007 Energy Bill, is one more step closer to being finalized.  Comments to EPA’s draft regulation, released in the Spring 2009, were due September the 25th of 2009.  The Environmental Community, including Friends of the Earth, wrote brief comments on this issue and were overall supportive with the general approach the EPA took to protect natural lands from biofuel, accounting for global warming pollution from biofuels, and applying sustainabiltiy standards to the fuels. However, we also made some specific recommendations for how EPA could improve the effectiveness of the rule.

Specifically, we asked that EPA address six key issues:

  • 1) Account for the full lifecycle impact of biofuels, using the best available science, in order to ensure emissions reductions,
  • 2) Define renewable biomass in a manner that steers the industry to the most sustainable sources of biomass,
  • 3) Ensure that the lifecycle assessment is transparent and based on the best available assessments of agricultural markets and land-use change,
  • 4) Confine the timeframe of the analysis to no more than 30 years,
  • 5) Limit the grandfathering provisions to the language of the statute, and
  • 6) Ensure that the waiver provisions are used to avoid unintended economic or environmental harm.

Friends of the Earth also joined more specific comments from the Clean Air Task Force, which detailed suggestions on how best to model what types of land are likely to be converted into agricutlural land as a result of increased biofuels production. 

Lastly, thank you to the thousands of Friends of the Earth biofuels activists that wrote into EPA with their own comments, supporting strong and complete climate protections from biofuels in the RFS.

Environmental Communtiy Comments CATF and Friends of the Earth Comments