We submit this letter to EPA in response to the proposed Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes (hereafter, “the Set Proposal”) and the associated Draft Regulatory Impact Analysis (DRIA).

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• The economic effect of the RFS on corn prices and acres planted in corn.
• The causal linkage between the RFS and LUC.
• Wetlands, ecosystems, habitat, and wildlife.
• Soil and water quality and water quantity.

Overall, our research concludes that the studies conducted by the EPA (2022b), Taheripour et al. (2022a), and Austin et al. (2022), are more representative of the likely effects of the implied conventional volume and ethanol production on corn prices and corn acres planted than are the results of Lark et al. (2022). The methods used by the EPA (2022b) and Taheripour et al. (2022a) account for effects of the global and domestic economies. The methods we use in this report, although high level, are based on 18 years of observed data. The results of our analysis confirm that the implied conventional volume has minimal to no effect on corn prices and acres of corn planted, consistent with the work by the EPA (2022b) and Taheripour et al. (2022a).

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Meeting attendees discussed our industry’s renewed push for a stronger Renewable Fuel Standard (RFS) – one that ensures ethanol continues to play a growing role in meeting our nation’s climate needs and energy demands.

GEBS also coincided with the end of the 2022 summer driving season, which allowed attendees in over 150 Capitol Hill meetings promote the meaningful cost-savings higher blends offer consumers – with an ask that Congress provide a permanent, federal fix so drivers can access lower-cost E15 year-round, nationwide, and in the summers to come.

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1. The land use changes we identify specifically represent the conversion of pasture and Conservation Reserve Program (CRP) lands to crops and thus are likely to cause a large carbon debt upon conversion. In our study, we used USDA National Resources Inventory (NRI) data–not the Cropland Data Layer (CDL)–to estimate the types, amount, and regional locations of land converted to crop production due to corn ethanol and the RFS (see Lark et al. 2022, SI Appendix, ln 375-393). The USDA NRI dataset specifically identifies land as pasture or CRP, and such areas are known to result in a substantial carbon debt upon their conversion to cropland (Guo and Gifford 2002; Gelfand et al. 2011; Sanderman et al. 2017; Spawn-Lee et al. 2021). Taheripour et al. quote and appear to conflate our methods for estimating water quality impacts (Lark et al. SI ln 696) with our methods for identifying land transitions (SI ln 375) and also seem to misinterpret our use of satellite-based data, which we use only to infer at a higher resolution the biophysical characteristics of converted lands for our water quality and greenhouse gas modeling (SI ln 555). While the USDA NRI data allow us to identify the type, amount, and regional locations of land use changes, we do not know the exact location of those land use changes. Therefore, we used satellite-based data on land conversions only to help parameterize our water quality and greenhouse gas models at sub-regional levels.

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In their assessment, Lark et al. assumed a business-as-usual (BAU) scenario (representing the goals of RFS1 for ethanol volume, as adopted in the 2005 Energy Policy Act by Congress, between 2008 and 2016), a new scenario (representing the goals of RFS2 for ethanol volume, as adopted in the 2007 EISA by Congress, between 2008 and 2016) to determine domestic LUC due to the RFS2. With no integrative modeling exercise, the authors simply calculated the average of the annual differences between the goals of RFS1 and RFS2 (5.5 billion gallons [Bgal]) and considered that volume of ethanol as the average annual contribution of RFS2 to new ethanol consumption between 2008 and 2016. Instead of using an integrated, coherent framework, as is the case with equilibrium models, in which changes in crop prices and associated LUCs at the intensive and extensive margin are determined simultaneously, Lark et al. applied a few loosely connected empirical methods to examine the impact of the RFS2 on three crops (corn, soybeans, and wheat). They estimated the short-term increases in commodity prices between 2008 and 2016 induced by the RFS2 and estimated that the prices of corn, soybeans, and wheat would increase by 30%, 20%, and 20%, respectively, due to an increase in the annual consumption of ethanol by 5.5 Bgal.

In the next step, Lark et al. used the Cropland Data Layer (CDL) from the United States Department of Agriculture (USDA) in combination with some other information on returns on cropland to estimate the probabilities of land transitions between cropland, pasture land, and Conservation Reserve Program (CRP) land. Using their projected increases in the prices of corn, soybeans, and wheat in combination with the estimated land transition functions, Lark et al. calculated that the area of corn plantation, adjusted for distiller’s dried grains (DDG), would increase by 2.8 million hectares (Mha) due to the RFS2, and that would lead to an increase in cropland area by 2.1 Mha. They showed that an overwhelming share of land conversion due to the RFS2 would be conversion of CRP land to active cropland. Lark et al. assigned a set of significantly large land use emissions factors to the CRP land conversion and likely double counted the N2O emissions in adding their LUC emissions to the rest of life-cycle analysis (LCA) emissions of corn-based ethanol, leading to the conclusion that the GHG emissions (commonly called carbon intensity) of ethanol are at least 24% higher than those of gasoline.

After a detailed technical review of the modeling practices and data used by Lark et al., we conclude that the results and conclusions provided by the authors are based on several questionable assumptions and a simple modeling approach that has resulted in overestimation of the GHG emissions of corn ethanol. In what follows, we present the general findings of our review.

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•  The study importantly neglects to evaluate the relationship between oil prices and corn prices.
• The study fails to adequately explain and evaluate uncertainties associated with its use of a “Business as usual” scenario absent the RFS as a counterfactual.
• With respect to land use change modeling, the study purports to correct for grave deficiencies in one of the author’s prior work by applying “recommended practices,” but does not explain how those practices were applied. Further, it is not possible to evaluate some of the data sets themselves as they are non-public, thus limiting third party reviewers’ abilities to evaluate the validity of the conclusions the authors draw.
• The authors characterize as fact numerous modeled results, giving the reader a misleading impression of false confidence in the conclusions which are drawn from highly uncertain models embedded with extensive assumptions that may or may not reflect the real-world.

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Bioenergy is an essential component of most proposed pathways to reduce anthropogenic greenhouse gas (GHG) emissions and limit global warming to 1.5 or 2 °C by middle to late century. Liquid biofuels may contribute to bioenergy’s share of climate mitigation by displacing petroleum-based fuels with those generated from modern-day plants. The GHG benefits of such substitution, however, are dependent on several factors including whether biofuel production invokes additional plant growth, the extent to which combusted plants (typically crops) are replaced in the food system, and the degree to which biofuel production directly and indirectly alters patterns of land use and management. Because land use changes (LUCs) and other consequences induced by biofuels have the potential to cause significant novel GHG emissions and modify other ecosystem services and disservices, accurately estimating and accounting these outcomes is critical for the formation of effective climate and environmental policy.

The United States is the world leader in biofuel production by volume and generated 47% of global output over the last decade under the purview of its Renewable Fuel Standard (RFS). First enacted in 2005 and greatly expanded in 2007, the RFS requires that biofuels be blended into the transportation fuel supply at annually increasing increments. Volume targets exist for several advanced biofuel types including biomass-based diesel and those made from cellulosic feedstocks. However, the vast majority (∼87%) of the mandate to date has been fulfilled by conventional renewable fuels, specifically corn grain ethanol, such that the potential benefits of its more advanced fuel requirements have not yet materialized.

To comply with the policy’s GHG reduction goals, the RFS requires conventional renewable fuels to generate life cycle GHG savings of at least 20% relative to gasoline. Upon enactment, the policy’s regulatory analysis projected that life cycle emissions of corn ethanol production would just clear the 20% threshold by 2022, even when emissions from LUC were included. At the time, most LUC emissions were projected to occur internationally. Since the initial RFS policy-making, however, observations of widespread land conversion and resultant GHG emissions within the United States have also emerged.

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EIA lists the U.S. ethanol nameplate production capacity for 2020 at 17.38 billion gallons per year. How much of this ethanol production capacity can be used is primarily a function of the available feedstock, corn, and the conversion capacity of ethanol plants. We consider three different approaches to determine the real world maximum potential ethanol production in 2022: historical maximum, previous year, and potential expansion.

The highest year of ethanol production was 2018, when 16.061 billion gallons of ethanol were produced domestically. In 2021, it is estimated that 14.87 billion gallons of ethanol were produced. We believe that both of these figures represent conservative estimates of how much ethanol could reasonably be produced in 2022. The 2021 volume was suppressed substantially by low demand for transportation fuel in response to the Covid-19 pandemic. And neither figure accounts for the continuing growth in the productivity of U.S. corn growers or the steady improvements in the efficiency of U.S. corn ethanol plants. As explained below in greater detail, these developments have allowed U.S. ethanol production to continuously increase their production capability without requiring increasing corn acreage or adversely impacting the supply of corn available for other domestic non-ethanol demands or export markets. In fact, we conclude that, accounting for these developments, 15.565 billion gallons could be produced domestically in 2022.

While the 15.565 billion gallons of ethanol for 2022 in Table 4 seems like an upper limit on ethanol production in 2022, it is in fact limited by the decision to keep the planted acres constant the decision to keep the portion of corn used for ethanol constant, and the representation of new technology implementation as a straight line. The reality is that market forces are always in play. A positive future market outlook may cause more acres to be planted in corn that year. It may cause plant maintenance to be delayed until next year. A very promising technology may be implemented earlier and to a larger extent than typical technology is implemented. Table 4 and the other tables in that section represent average conditions which can be increased or decreased by each farmer or ethanol production facility’s market outlook. Indeed, as noted, the actual ethanol production in 2018 exceeded our projection for 2022 by a
substantial margin, at a time when yield rates and conversion efficiency were lower than they are now.

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• Ramboll. August 18, 2019. The RFS and ethanol production: Lack of proven impacts to land and water. Prepared for Growth Energy. Ramboll, Seattle, WA. (Exhibit 1).
• Ramboll. November 29, 2019. Memorandum: Supplemental analysis regarding allegations of potential impacts of the RFS on species listed under the Endangered Species Act. Prepared for Growth Energy. Ramboll, Seattle WA. (Exhibit 2).

These prior analyses addressed the absence of a demonstrated causal nexus between the RFS and land use change (LUC); adverse impacts to wetlands, ecosystems, and wildlife habitat; and adverse impacts to water resource availability and water quality. Our analyses refuted claims by other investigators that the RFS causes quantifiable adverse impacts to environmental media. We have
evaluated more recent scientific literature on this topic and continue to find that there is no evidence the RFS program causes these adverse environmental impacts. Based on this finding, there is no evidence that the Proposed Rule will result in land conversion or cause adverse impacts to wetlands, ecosystems, wildlife habitat, water availability and water quality. We encourage EPA to update its
analysis in the RIA to address these findings and correct its potentially misleading discussion of environmental impacts of the program.

The RIA presents only a generalized discussion of the drivers for and nature of potential impacts of biofuel feedstock production and biofuel refining on LUC; wetlands, ecosystems, and wildlife habitat; and water availability and water quality. It fails to recognize the complex causal links between drivers of impacts and the potential impacts described to land and water, which in turn creates the misleading impression that there is a causal relationship between the RFS and impacts to land and water, where no such relationship has been established.

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