EPA palm oil analysis draws support, criticism as comments close
April 26, 2012
BY Erin Voegele
The public comment period for the U.S. EPA’s palm oil pathway assessment under the renewable fuel standard (RFS2) closes April 27. As the deadline approaches, groups representing both sides of the issue are speaking out in an effort to sway the EPA’s final decision on the matter.
In January, the EPA published its Notice of Data Availability for renewable fuels produced with palm oil feedstock. In the NODA the agency noted its analysis determined that biodiesel and renewable diesel made from palm oil feedstock does not meet the 20 percent greenhouse gas (GHG) emission reductions required by RFS2 to qualify as renewable fuel. Data published by the EPA found palm oil biodiesel to have a GHG reduction rating of 17 percent. Alternatively, palm oil derived renewable diesel only had an 11 percent GHG reduction.
The public comment period on the NODA was set to expire Feb. 27. However, the EPA published a comment period extension notice on Feb. 14 announcing that the comment period would be extended until April 27. As of April 26, 219 public submissions have been made under the docket with more expected to be posed before the deadline.
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As the deadline approaches, parties arguing in support and opposition of the EPA’s findings are speaking out. Robert Shapiro, chairman and co-founder of Sonecon LLC, a firm that advises organizations on market conditions and economic policy, is one of the people who has submitted comments opposing the EPA’s analysis of palm oil biofuels.
In his comment, Shapiro describes three specific problems he has identified with the EPA’s analysis. First, he questions the accuracy of the agency’s method to predict indirect land use change (ILUC), noting that without the highly unreliable inclusion of ILUC data, palm oil-based biodiesel and renewable diesel would meet the prescribed RFS2 thresholds. He also states that his analysis has found that the EPA’s assumption that palm oil yields will not increase in the future is false. He also stated that the EPA’s calculated “midpoints” for its projected range of emissions effects are inaccurate.
“There is considerable literature on [ILUC], and most of the literature has concluded that the models thus far are not very accurate, and that they are highly speculative,” Shapiro said. He also said that he takes issue with the fact that the EPA has not disclosed how it selected the “midpoint” for GHG ranges. According to Shapiro, another problem with the analysis is that the EPA didn’t show that there was a statistically significant difference between their midpoint and their threshold.
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Shapiro said he would like the EPA to reconsider its whole palm oil analysis. “There are a lot of people submitting comments on this, and they need to go back and redo the technical analysis and either reconfirm it, or adjust it based on better information or more rigorous models,” he said.
However, there are also individuals and groups that are arguing that the EPA’s analysis was too lenient, and the actually GHG emissions associated with palm oil biofuels are much higher. A group of scientific and environmental groups, including the Union of Concerned Scientists, is set to submit a public comment on the issue April 27 agreeing with EPA’s assessment that these fuels don’t meet RFS2 GHG reduction thresholds, and also arguing that the agency’s GHG assessments are too low.
According to Jeremy Martin, senior scientist for the UCS’ Clean Vehicles Program, the EPA’s analysis underestimates the serious environmental problems caused by palm oil production. “We’ve done a thorough review of EPA’s analysis and have found that in several important areas they did substantially underestimate the emissions,” Martin said. “We’ve provided EPA with data substantiating more appropriate values.” Using those new values, Martin said the analysis shows palm oil biofuels actually result in more GHG emissions than petroleum-based fuels. He also brought up issues associated with food production and the long history of deforestation associated with palm oil production.
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