ASA takes computers to farm shows, encouraging comments on RFS2 rule

Posted September 9, 2009

The American Soybean Association has made it easy for farmers attending a couple of the big farm shows to comment on the U.S. EPA's proposed rule to implement the revised renewable fuels standard (RFS2). Computers were set up for farmers to email comments on the spot at the Farm Progress Show last week, Sept. 1-3 at Decatur, Ill. The ASA leadership, including President Johnny Dodson and First Vice President Rob Joslin, as well as Vice Presidents Randy Mann, Joe Steiner and Alan Kemper were on hand to encourage comments. Members were well-informed about the proposed rule, an ASA spokeman reported, and were glad for the chance to add their comments.

Dodson and executive committee member Steve Wellman will also be available at Husker Harvest Days next week, Sept. 15-17, at Grand Island, Neb. where computers will be available for producers to submit their comments on the spot.

"The EPA's proposed rule on RFS2 implementation is significantly flawed and would do unnecessary harm to the competitive position of the U.S. soy biodiesel industry," said Dodson, a soybean producer from Halls, Tenn. "A loss of the domestic biodiesel market would significantly decrease prices paid to U.S. farmers for their soybeans."

According to the ASA, the vital flaws and concerns with the RFS2 proposed rule include flawed and immature assumptions and methodology utilized to measure the indirect land use impacts of U.S. soy biodiesel production; unnecessary and onerous feedstock certification requirements; a methodology that contains a major error pertaining to the direct emission calculations for nitrogen in soybean production; a lack of accounting for glycerin as a coproduct; inaccurate assessment of the energy balance of biodiesel; a proposed pathway of using a 52-48 feedstock ratio of virgin to waste biodiesel feedstocks that is not workable in practice; a lack of accounting for improved agriculture yields and efficiency; and a baseline analysis that compares estimated, future direct and indirect GHG emissions for biodiesel to only direct emissions for petroleum.

"Soybean farmers have a great interest in the implementation of the RFS2," Dodson said. "Unless the flaws in EPA's proposed rule are corrected, soy-based biodiesel effectively will be excluded from the meeting the renewable energy targets established under RFS2. Soybean farmers would lose a source of demand for soybean oil, biodiesel manufacturers would be left without sufficient feedstock supply, jobs would be lost, and our nation would not decrease its dependence on imported oil. None of these outcomes are what Congress intended. That's why ASA is providing detailed comments to the EPA, and why ASA is asking farmers and the agricultural community to contact EPA as well."

ASA has issued two Action Alerts to its 22,000 producer members directing them to the organization's Web site, www.SoyGrowers.com, where there is a link to the ASA online comment form.