Farmers have until next week (Sept. 25)
to tell the Environmental Protection Agency (EPA) what they think about the proposed revised Renewable Fuel Standard regulations, known as RFSII.
There is much debate regarding the proposed standard due to the fact the EPA wants to include the theory of Indirect Land Use in its regulation, effectively creating a nationwide carbon penalty for biofuels compared with gasoline, according to biofuels industry supporters.
The theory predicts that using biofuels made from U.S. corn and soybeans causes a farmer halfway around the world to make a land use decision to plow virgin land to replace feed. It also suggests that any carbon emissions resulting from this land use change should be ascribed to biofuels. The biggest problem with ILUC theory, however, is that there is no scientific consensus to its validity. Research on the effects of biofuels on greenhouse gas emissions (GHG) is relatively young, with most studies appearing just in the last two or three years.
EPA's current proposed rule could place a huge burden on corn growers, for example, by requiring proof that feedstocks used for ethanol production came from cropland which was in production prior to 2007, says National Corn Grower Association Ethanol Committee Chairman Steve Ruh, an Illinois farmer. “We need farmers to voice their opinions on the proposed standard,” he says.
For more informatio on the issue or assistance in crafting comments to the EPA, the National Corn Growers Association
, American Soybean Association
and National Biodiesel Board
are providing form letters and email links to the EPA comment area.