The U.S. EPA has scheduled an independent peer review meeting for March 14 to review a draft report it is preparing for Congress which will detail the current and potential future environmental impacts associated with biofuel production. The 2007 Energy Independence and Security Act requires the EPA to assess and report to Congress every three years on the impacts associated with increased biofuels production and use. The report being reviewed March 14, “Biofuels and the Environment: First Triennial Report to Congress,” is the first report required through the legislation.

According to the EPA, the report emphasizes ethanol and biomass-based diesel because they are the most commercially viable biofuels currently and are projected to the most commercially available by 2022. Six feedstocks are evaluated, including corn, soybeans, corn stover, perennial grasses, woody biomass and algae. As required by EISA, the report covers biofuels’ impacts on air and water quality, soil quality and conservation, water availability, ecosystem health and biodiversity, the potential invasiveness of feedstocks and international environmental impacts.

Ethanol industry groups filed lengthy comments with the EPA regarding the draft, claiming the agency has misinterpreted and expanded the scope of the report and questioning its failure to compare biofuels’ impact on the environment with petroleum’s environmental impact.

“EISA compels EPA to assess only those environmental impacts that are likely to result from the requirements of the renewable fuel standard (RFS),” the Renewable Fuels Association stated in its comment. “Unfortunately, EPA’s draft report seems to raise every conceivable environmental problem that could possibly arise from biofuels expansion, without any regard for the actual likelihood that the problem will occur. RFA believes the draft report’s general approach and content should be substantively reconsidered. Further, we believe significant revisions are needed before the report can reasonably be finalized and submitted to Congress for consideration.” The EPA misinterpreted its direction for assessing indirect land use change, the RFA stated, and should be evaluating the effects of Brazilian sugarcane-based ethanol rather than domestic feedstocks. Additionally, the group commented that the EPA “entirely omitted” discussion of positive environmental impacts of co-products such as distillers grains, focusing instead on potential negative impacts associated with increased feeding of distillers grains.

“The report presents a running narrative of potential environmental concerns about biofuels with very little information that would quantify these concerns absolutely or relatively to other fuels, to the status quo or to alternative scenarios,” Growth Energy stated in its comments. The group challenged the technical accuracy of several of the EPA’s assumptions and stressed that while a life cycle analysis for biofuels would provide a more robust quantitative assessment of the environmental impact for biofuels, it is only meaningful if the same analysis is completed for petroleum-based fuels.

Information published by the EPA in the Federal Register states the agency admits “substantial uncertainties” impact its ability to assess environmental and resource conservation impacts with particular feedstocks. “Since many feedstock technologies are in the early stages of research and development, data relevant to impacts are limited and projections of their potential future use are highly speculative,” the agency stated. The RFA commented that this admitted uncertainty should be openly stated by the agency early in its final report and recommends the EPA should attempt to quantify the uncertainty associated with the environmental factors analyzed for the report.

The final report, scheduled to be delivered to Congress mid-year, will be used to influence future biofuels policy. According to the EPA, panel members selected to participate in the March 14 peer review meeting will include scientists with a number of specific disciplines, including: renewable fuels, economics, ecology, environmental science, environmental engineering, agricultural systems development, resource conservation, fresh water hydrology, biofuel conversion technology, agronomy, ecotoxicology, atmospheric chemistry, ecological risk assessment, human health risk assessment and biofuel chemistry. Comments submitted by the RFA and Growth Energy, as well as any public comments submitted prior to the Feb. 28 deadline, will be forwarded to the panel prior to the meeting for their consideration. The peer review meeting is open to members of the public who register to attend. For more information and to review the draft report, visit www.epa.gov/ncea.