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EPA is proposing - Petroleum Equipment Institute

EPA is proposing - Petroleum Equipment Institute

EPA is proposing - Petroleum Equipment Institute

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would achieve alone. In addition, EISA specifies four separate categories of renewablefuels, each with a separate volume mandate. The categories are renewable fuel, advancedbiofuel, biomass-based diesel, and cellulosic biofuel. There <strong>is</strong> a notable increase in themandate for cellulosic biofuels in particular. EISA increased the cellulosic biofuelmandate from 250 million in <strong>EPA</strong>ct to 1.0 billion gallons by 2013, with additional yearlyincreases to 16 billion gallons by 2022. These requirements will provide a strongfoundation for investment in cellulosic production and position cellulosic fuel to becomea major portion of the renewable fuel pool over the next decade.The implications of the volume expansion of the program are not trivial.Development of infrastructure capable of delivering, storing and blending these volumesin new markets and expanding ex<strong>is</strong>ting market capabilities will be needed. For example,the market's absorption of increased volumes of ethanol may ultimately require new“outlets” beyond E10 blends (i.e., gasoline containing 10% ethanol by volume), such asan expansion of the number of flexible-fuel E85 vehicles and the number of retail outletsselling E85.B. Renewable Fuels and Greenhouse Gas Em<strong>is</strong>sionsAnother significant aspect of the RFS2 program <strong>is</strong> the focus on the greenhousegas impact of renewable fuels, from a lifecycle perspective. The lifecycle GHGem<strong>is</strong>sions means the aggregate quantity of GHGs related to the full fuel cycle, includingall stages of fuel and feedstock production and d<strong>is</strong>tribution, from feedstock generationand extraction through d<strong>is</strong>tribution and delivery and use of the fin<strong>is</strong>hed fuel. EISAestabl<strong>is</strong>hed specific greenhouse gas em<strong>is</strong>sion thresholds for each of four types ofrenewable fuels, requiring a percentage improvement compared to a baseline of thegasoline and diesel used in 2005. <strong>EPA</strong> must conduct a lifecycle analys<strong>is</strong> to determinewhether or not renewable fuels produced under varying conditions will meet thegreenhouse gas (GHG) thresholds for the different fuel types for which EISA establ<strong>is</strong>hesmandates. While these thresholds do not constitute a control on greenhouse gases fortransportation fuels (such as a low carbon fuel standard 1 ), they do require that the volumemandates be met through the use of renewable fuels that meet certain lifecycle GHGreduction thresholds when compared to the baseline lifecycle em<strong>is</strong>sions of petroleum fuelthey replace. Compliance with the thresholds requires a comprehensive evaluation ofrenewable fuels, as well as of gasoline and diesel, on the bas<strong>is</strong> of their lifecycleem<strong>is</strong>sions. As mandated by EISA, the greenhouse gas em<strong>is</strong>sion assessments mustevaluate the full lifecycle em<strong>is</strong>sion impacts of fuel production including both direct andindirect em<strong>is</strong>sions, including significant em<strong>is</strong>sions from land use changes. We recognizethe significance of using lifecycle greenhouse gas em<strong>is</strong>sion assessments that includeindirect impacts such as em<strong>is</strong>sion impacts of indirect land use changes. Therefore, in th<strong>is</strong>preamble, we have been transparent in breaking out the various sources of greenhousegas em<strong>is</strong>sions included in the analys<strong>is</strong>. As described in detail in Section VI, <strong>EPA</strong> has1 See Section IV.D of <strong>EPA</strong>’s advanced notice of proposed rulemaking, Regulating Greenhouse GasEm<strong>is</strong>sions under the Clean Air Act, for a d<strong>is</strong>cussion of <strong>EPA</strong>’s possible authority under section 211(c) of theCAA to establ<strong>is</strong>h GHG standards for renewable and alternative fuels. 73 FR 44354, July 30, 2008.16

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