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• Undercut EPA’s ability to have any renewable fuel mandate in place for calendar year 2010
in accordance with EISA, causing tremendous uncertainty in all biofuel markets, including
corn ethanol and biodiesel at a time when fuel prices and tight capital markets are already
making things uncertain. This includes--
o Implementation of the 2010 (and therefore also the 2009) biodiesel mandate. (The
biodiesel industry is highly concerned not having these mandates in place.)
o Implementation of the cellulosic mandate—removing the market signal for
investment in advanced biofuels
• Stop short the public process—preventing EPA from using public input to develop a final
rule.
• Undermine the scientific integrity of the Agency’s work and the intent of EISA.
• The comment period—which was extended to provide stakeholders additional time to review
and comment on the rule-- will close on September 25. The Agency is hoping to finalize the
rule before the end of the year.
• During the comment period the Agency conducted a formal external peer review of areas of
the lifecycle assessment that charted new ground. In addition to providing valuable technical
input, this peer review confirmed that the Agency conducted a credible, unbiased analysis
and enhanced EPA’s ability to make a sound, science-based decision.
• Based on the peer review and the important input received throughout the comment period,
EPA is considering an approach for the final rule that would reflect the degree of uncertainty
associated with assessing international land use change.
• By allowing the Agency to move forward, the 2010 fuel mandates can be implemented and
market certainty assured.
o all 15 billion gallons of corn ethanol is grandfathered from the lifecycle requirements
o a revised lifecycle approach that takes uncertainty into account means that significant
renewable fuels will likely comply with the lifecycle requirements