In formal comments to the U.S. Environmental Protection Agency (EPA) regarding the proposed rule to implement the expanded Renewable Fuel Standard, the National Corn Growers Association (NCGA) and 11 of its state affiliates express concern about biases against corn farmers, the lack of transparency in some of the modeling, and the excessive burden of regulations on growers.
“Most of the controversy over EPA’s international indirect land use change analysis can be resolved by simply calculating the domestic capability to meet fuel, food and feed demand properly,” said NCGA President Bob Dickey. “If EPA did so, the calculation would show that virtually no additional land conversion is needed -- and therefore no significant new emissions will result.”
NCGA’s full and comprehensive comments will be posted online after being formally filed with the EPA. The top three concerns raised by the organizations are:
- First, NCGA and its affiliates are concerned with the approach to lifecycle analysis and a series of incorrect assumptions that inappropriately skew the regulations against corn-based ethanol.
- Second, the lack of transparency in the modeling used to support the rule is inconsistent with EPA Administrator Lisa Jackson’s promises to operate a transparent environmental program – since no one can replicate or verify the conclusions reached by these modelers’ proprietary programs, particularly given that a range of models are being “combined.” Such an approach is also inconsistent with the Information Quality Act.
- Third, NCGA and its affiliates are concerned about the complex, overly burdensome, and unnecessary approach to tracing renewable biomass. This aspect of the program will impose tremendous costs on the industry with little or no benefit.
In the NCGA comments, Dickey notes that the EPA’s estimate of 180 corn bushels per acre in 2022 dramatically understates the estimated corn yield, and this has a significant impact on EPA’s estimate of greenhouse gas emissions from indirect land use change. The understatement of yield essentially equates to EPA ignoring some 3 billion bushels of annual
“In short, the EPA’s approach toward yields is purely backward-looking and fails to provide increases for expected technology breakthroughs, such as drought tolerance and insect and herbicide resistance,” Dickey said.
Joining NCGA in its formal comments are the Iowa Corn Growers Association, the Indiana Corn Growers Association, the Kansas Corn Growers Association, the Maryland Grain Producers Association, the Michigan Corn Growers Association, the Minnesota Corn Growers Association, the Missouri Corn Growers Association, the Nebraska Corn Board, the Nebraska Corn Growers Association, the North Dakota Corn Growers Association, and the Ohio Corn Growers Association.
NCGA commissioned a report titled “Compliance Costs Associated with the Proposed Rulemaking for RFS2," prepared by Informa Economics. The full report is available online.