EPA is proposing - Petroleum Equipment Institute

emissions means the aggregate quantity of GHG emissions related to the full fuel cycle,including all stages of fuel and feedstock production and distribution, from feedstockgeneration or extraction through distribution and delivery and use of the finished fuel. Asmandated by EISA, it includes direct emissions and significant indirect emissions such assignificant emissions from land use changes. EPA believes that compliance with theEISA mandate – determining the aggregate GHG emissions related to the full fuellifecycle, including both direct emissions and significant indirect emissions such as landuse changes – make it necessary to assess those direct and indirect impacts that occur notjust within the United States but also those that occur in other countries. This applies todetermining the lifecycle emissions for petroleum-based fuels to determine the baseline,as well as the lifecycle emissions for biofuels. For biofuels, this includes evaluatingsignificant emissions from indirect land use changes that occur in other countries as aresult of the increased domestic production or importation of biofuels into the U.S. Asdetailed in Section VI, we have included the GHG emission impacts of international landuse changes including the indirect land use changes that result from domestic productionof biofuel feedstocks. We recognize the significance of including international land useemission impacts and, in our analysis presentation in Section VI, have been transparent inbreaking out the various sources of GHG emissions so that the reader can readily see theimpact of including international land use impacts.Table II.A.3-1 Lifecycle GHG Thresholds Specified in EISA (percent reduction from baseline) Renewable fuel a20%Advanced biofuel50%Biomass-based diesel 50%Cellulosic biofuel60%a The 20% criterion generally applies to renewable fuel from new facilities that commenced construction after December 19, 2007.The lifecycle GHG emissions of the renewable fuel are compared to the lifecycleGHG emissions for gasoline or diesel (whichever is being replaced by the renewablefuel) sold or distributed as transportation fuel in 2005. EISA provides some limitedflexibility for EPA to adjust these GHG percentage thresholds downward by up to 10percent under certain circumstances. As discussed in Section VI.D, we are proposing thatthe GHG threshold for advanced biofuels be adjusted to 44% or potentially as low as40% depending on the results from the analyses that will be conducted for the final rule.This adjustment would allow ethanol produced from sugarcane to count as advancedbiofuel and would help ensure that the volume mandate for advanced biofuel could bemet.The regulatory purpose of the lifecycle greenhouse gas emissions analysis is todetermine whether renewable fuels meet the GHG thresholds for the different categoriesof renewable fuel. As described in detail in Section VI, EPA has analyzed the lifecycleGHG impacts of the range of biofuels currently expected to contribute significantly tomeeting the volume mandates of EISA through 2022. In these analyses we have used thebest science available. Our analysis relies on peer reviewed models and the best estimate24