RFS2 comments due Friday, Sept. 25

By Susanne Retka Schill | September 18, 2009
Posted September 21, 2009

The comment period for the U.S. EPA's proposed rule to implement the renewable fuels standard is due to close Friday, Sept. 25. Both the American Soybean Association and the National Biodiesel Board are encouraging those supporting the biodiesel industry to submit their comments, if they haven't already. Both organizations have made it easy to access information at their Web sites, providing background information, sample comments, links to the EPA Web site and instructions on emailing comments. The ASA form is available at www.soygrowers.com/policy/RFS2.htm. The NBB's action center is available at http://biodiesel.org/news/RFS/. The NBB provides an express comment that features a condense message and only requires a name, city, state and email address. "it takes less than 20 seconds to fill out and submit," the NBB says. The NBB also offers long and short versions of sample comments to make, and provides information for an individual to craft a unique response.

The stakes are high for the biodiesel industry. "As EPA's proposed rule is written, soy biodiesel would no longer qualify under the specific federal mandate for biomass-based diesel use," ASA President Johnny Dodson explained. "With the future of the U.S. biodiesel industry at stake, farmers need to get involved right now by voicing their opposition to the proposed rule." The ASA has reached out to U.S. soybean farmers in their campaign, as have several state soybean associations and corn grower associations as well to comment on the impact on corn ethanol.

The NBB has spent the summer encouraging the industry to respond, developing the action center on its Web site, as it continued to evaluate the lengthy proposed rule to provide detailed and comprehensive positions and data to address all aspects of the proposed rule.

The most contentious portion of the rule for biofuels producers is the inclusion of international indirect land use impacts into the calculations of greenhouse gas emissions. Another widespread concern is the possibility of having to certify that feedstocks were grown on cropland currently in production, raising the question of whether a new certification system would have to be formed and whether commingled, bulk commodities like soybeans could be traced.

Language to further study the indirect land use issue and deal with the eligible feedstock problem did pass the U.S. House as an amendment to the Climate Change Bill. That legislation has not been taken up by the U.S. Senate as yet, and it is uncertain whether that language would be maintained in the final version. Industry spokesman have said that it would be quicker to have the rule itself be corrected, which will require an informed public response during the comment period.
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