[Federal Register Volume 78, Number 43 (Tuesday, March 5, 2013)]
[Rules and Regulations]
[Pages 14190-14217]
[FR Doc No: 2013-04929]

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 80

[EPA-HQ-OAR-2011-0542; FRL-9686-3]
RIN 2060-AR07

Regulation of Fuels and Fuel Additives: Identification of
Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel
Standard Program

AGENCY: Environmental Protection Agency (EPA).

ACTION: Final rule.

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SUMMARY: EPA is issuing a final rule identifying additional fuel
pathways that EPA has determined meet the biomass-based diesel,
advanced biofuel or cellulosic biofuel lifecycle greenhouse gas (GHG)
reduction requirements specified in Clean Air Act section 211(o), the
Renewable Fuel Standard (RFS) Program, as amended by the Energy
Independence and Security Act of 2007 (EISA). This final rule describes
EPA's evaluation of biofuels produced from camelina (Camelina sativa)
oil and energy cane; it also includes an evaluation of renewable
gasoline and renewable gasoline blendstocks, and clarifies our
definition of renewable diesel. The inclusion of these pathways creates
additional opportunity and flexibility for regulated parties to comply
with the advanced and cellulosic requirements of EISA and provides the
certainty necessary for investments to bring these biofuels into
commercial production from these new feedstocks.
    We are not finalizing at this time determinations on biofuels
produced from giant reed (Arundo donax) or napier grass (Pennisetum
purpureum) or biodiesel produced from esterification. We continue to
consider the issues concerning these proposals, and will make a final
decision on them at a later time.

DATES: This rule is effective on May 6, 2013.

FOR FURTHER INFORMATION CONTACT: Vincent Camobreco, Office of
Transportation and Air Quality (MC6401A), Environmental Protection
Agency, 1200 Pennsylvania Ave. NW., Washington, DC 20460; telephone
number:<PHONE_NUMBER>; fax number:<PHONE_NUMBER>; email address:
<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

Does this action apply to me?

    Entities potentially affected by this action are those involved
with the production, distribution, and sale of transportation fuels,
including gasoline and diesel fuel or renewable fuels such as ethanol
and biodiesel. Regulated categories and entities affected by this
action include:

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                                                NAICS \1\                     Examples of potentially regulated
                  Category                        Codes       SIC \2\ Codes                entities
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Industry...................................          324110            2911  Petroleum Refineries.
Industry...................................          325193            2869  Ethyl alcohol manufacturing.
Industry...................................          325199            2869  Other basic organic chemical
                                                                              manufacturing.
Industry...................................          424690            5169  Chemical and allied products
                                                                              merchant wholesalers.
Industry...................................          424710            5171  Petroleum bulk stations and
                                                                              terminals.
Industry...................................          424720            5172  Petroleum and petroleum products
                                                                              merchant wholesalers.
Industry...................................          454319            5989  Other fuel dealers.
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\1\ North American Industry Classification System (NAICS).
\2\ Standard Industrial Classification (SIC) system code.

    This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be regulated by this
action. This table lists the types of entities that EPA is now aware
could be potentially regulated by this action. Other types of entities
not listed in the table could also be regulated. To determine whether
your entity is regulated by this action, you should carefully examine
the applicability criteria of Part 80, subparts D, E and F of title 40
of the Code of Federal Regulations. If you have any question regarding
applicability of this action to a particular entity, consult the person
in the preceding FOR FURTHER INFORMATION CONTACT section above.

Outline of This Preamble

I. Executive Summary
    A. Purpose of the Regulatory Action
    B. Summary of the Major Provisions of the Regulatory Action In
Question
II. Identification of Additional Qualifying Renewable Fuel Pathways
Under the Renewable Fuel Standard (RFS) Program
    A. Analysis of Lifecycle Greenhouse Gas Emissions for Biodiesel,
Renewable Diesel, Jet Fuel, Heating Oil, Naphtha, and Liquefied
Petroleum Gas (LPG) Produced From Camelina Oil
    B. Lifecycle Greenhouse Gas Emissions Analysis for Ethanol,
Diesel, Jet Fuel, Heating Oil, and Naphtha Produced From Energy Cane
    C. Lifecycle Greenhouse Gas Emissions Analysis for Certain
Renewable Gasoline and Renewable Gasoline Blendstocks Pathways
    D. Esterification Production Process Inclusion for Specified
Feedstocks Producing Biodiesel
III. Additional Changes to Listing of Available Pathways in Table 1
of 80.1426
IV. Statutory and Executive Order Reviews
    A. Executive Order 12866: Regulatory Planning and Review and
Executive Order 13563: Improving Regulation and Regulatory Review
    B. Paperwork Reduction Act
    C. Regulatory Flexibility Act
    D. Unfunded Mandates Reform Act
    E. Executive Order 13132 (Federalism)
    F. Executive Order 13175 (Consultation and Coordination With
Indian Tribal Governments)
    G. Executive Order 13045: Protection of Children From
Environmental Health Risks and Safety Risks
    H. Executive Order 13211: Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use
    I. National Technology Transfer and Advancement Act
    J. Executive Order 12898: Federal Actions To Address
Environmental Justice in Minority Populations and Low-Income
Populations
    K. Congressional Review Act
V. Statutory Provisions and Legal Authority

I. Executive Summary

A. Purpose of This Regulatory Action

    In this rulemaking, EPA is taking final action to identify
additional fuel

pathways that we have determined meet the greenhouse gas (GHG)
reduction requirements under the Renewable Fuel Standard (RFS) program.
This final rule describes EPA's evaluation of biofuels produced from
camelina (Camelina sativa) oil, which qualify as biomass-based diesel
or advanced biofuel, as well as biofuels from energy cane which qualify
as cellulosic biofuel. This final rule also qualifies renewable
gasoline and renewable gasoline blendstock made from certain qualifying
feedstocks as cellulosic biofuel. Finally, this rule clarifies the
definition of renewable diesel to explicitly include jet fuel.
    EPA is taking this action as a result of changes to the RFS program
in Clean Air Act (``CAA'') Section 211(o) required by the Energy
Independence and Security Act of 2007 (``EISA''). This rulemaking
modifies the RFS regulations published at 40 CFR Sec.  80.1400 et seq.
The RFS program regulations specify the types of renewable fuels
eligible to participate in the RFS program and the procedures by which
renewable fuel producers and importers may generate Renewable
Identification Numbers (``RINs'') for the qualifying renewable fuels
they produce through approved fuel pathways. See 75 FR 14670 (March 26,
2010); 75 FR 26026 (May 10, 2010); 75 FR 37733 (June 30, 2010); 75 FR
59622 (September 28, 2010); 75 FR 76790 (December 9, 2010); 75 FR 79964
(December 21, 2010); 77 FR 1320 (January 9, 2012); and 77 FR 74592
(December 17, 2012).
    By qualifying these new fuel pathways, this rule provides
opportunities to increase the volume of advanced, low-GHG renewable
fuels--such as cellulosic biofuels--under the RFS program. EPA's
comprehensive analyses show significant lifecycle GHG emission
reductions from these fuel types, as compared to the baseline gasoline
or diesel fuel that they replace.

B. Summary of the Major Provisions of the Regulatory Action In Question

    This final rule describes EPA's evaluation of:
    Camelina (Camelina sativa) oil (new feedstock)
     Biodiesel, and renewable diesel, (including jet fuel, and
heating oil)--qualifying to generate biomass-based diesel and advanced
biofuel RINs
     Naphtha and liquefied petroleum gas (LPG)--qualifying to
generate advanced biofuel RINs
    Energy cane cellulosic biomass (new feedstock)
     Ethanol, renewable diesel (including renewable jet fuel
and heating oil), and renewable gasoline blendstock--qualifying to
generate cellulosic biofuel RINs
    Renewable gasoline and renewable gasoline blendstock (new fuel
types)
     Produced from crop residue, slash, pre-commercial
thinnings, tree residue, annual cover crops, and cellulosic components
of separated yard waste, separated food waste, and separated municipal
solid waste (MSW)
     Using the following processes--all utilizing natural gas,
biogas, and/or biomass as the only process energy sources--qualifying
to generate cellulosic biofuel RINs:
    [cir] Thermochemical pyrolysis
    [cir] Thermochemical gasification
    [cir] Biochemical direct fermentation
    [cir] Biochemical fermentation with catalytic upgrading
    [cir] Any other process that uses biogas and/or biomass as the only
process energy sources
    This final rule adds these pathways to Table 1 to Sec.  80.1426.
This final rule allows producers or importers of fuel produced under
these pathways to generate RINs in accordance with the RFS regulations,
providing that the fuel meets other definitional criteria for renewable
fuel. The inclusion of these pathways creates additional opportunity
and flexibility for regulated parties to comply with the requirements
of EISA. Substantial investment has been made to commercialize these
new feedstocks, and the cellulosic biofuel industry in the United
States continues to make significant advances in its progress towards
large scale commercial production. Approval of these new feedstocks
will help further the Congressional intent to expand the volumes of
cellulosic and advanced biofuels.
    We are also finalizing two changes to Table 1 to 80.1426 that were
proposed on July 1, 2011(76 FR 38844). The first change adds ID letters
to pathways to facilitate references to specific pathways. The second
change adds ``rapeseed'' to the existing pathway for renewable fuel
made from canola oil.

II. Identification of Additional Qualifying Renewable Fuel Pathways
Under the Renewable Fuel Standard (RFS) Program

    This rule was originally published in the Federal Register at 77 FR
462, January 5, 2012 as a direct final rule, with a parallel
publication of a proposed rule. A limited number of relevant adverse
comments were received, and EPA published a withdrawal notice of the
direct final rule on March 5, 2012 (77 FR 13009). A second comment
period was not issued, since the simultaneous publication of the
proposed rule provided an adequate notice and comment process. EPA is
finalizing several of the proposed actions in this final rule, but
continues to consider determinations on biofuels produced from giant
reed (Arundo donax) or napier grass (Pennisetum purpureum) or biodiesel
produced from esterification. EPA will make a final decision on theses
elements of the proposal at a later time.
    In this action, EPA is issuing a final rule to identify in the RFS
regulations additional renewable fuel production pathways that we have
determined meet the greenhouse gas (GHG) reduction requirements of the
RFS program. There are three critical components of a renewable fuel
pathway: (1) Fuel type, (2) feedstock, and (3) production process. Each
specific combination of the three components, or fuel pathway, is
assigned a D code which is used to designate the type of biofuel and
its compliance category under the RFS program. This final rule
describes EPA's lifecycle GHG evaluation of camelina oil and energy
cane.
    Determining whether a fuel pathway satisfies the CAA's lifecycle
GHG reduction thresholds for renewable fuels requires a comprehensive
evaluation of the lifecycle GHG emissions of the renewable fuel as
compared to the lifecycle GHG emissions of the baseline gasoline or
diesel fuel that it replaces. As mandated by CAA section 211(o), the
GHG emissions assessments must evaluate the aggregate quantity of GHG
emissions (including direct emissions and significant indirect
emissions such as significant emissions from land use changes) related
to the full fuel lifecycle, including all stages of fuel and feedstock
production, distribution, and use by the ultimate consumer.
    In examining the full lifecycle GHG impacts of renewable fuels for
the RFS program, EPA considers the following:
     Feedstock production--based on agricultural sector models
that include direct and indirect impacts of feedstock production.
     Fuel production--including process energy requirements,
impacts of any raw materials used in the process, and benefits from co-
products produced.
     Fuel and feedstock distribution--including impacts of
transporting feedstock from production to use, and transport of the
final fuel to the consumer.
     Use of the fuel--including combustion emissions from use
of the fuel in a vehicle.
    Many of the pathways evaluated in this rulemaking rely on a
comparison to the lifecycle GHG analysis work that was done as part of
the Renewable Fuel

Standard Program Final Rule, published March 26, 2010 (75 FR 14670)
(March 2010 RFS). The evaluations here rely on comparisons to the
existing analyses presented in the March 2010 final rule. EPA plans to
periodically review and revise the methodology and assumptions
associated with calculating the GHG emissions from all renewable fuel
pathways.

A. Analysis of Lifecycle Greenhouse Gas Emissions for Biodiesel,
Renewable Diesel, Jet Fuel, Heating Oil, Naphtha, and Liquefied
Petroleum Gas (LPG) Produced From Camelina Oil

    The following sections describe EPA's evaluation of camelina
(Camelina sativa) as a biofuel feedstock under the RFS program. As
discussed previously, this analysis relies on a comparison to the
lifecycle GHG analysis work that was done as part of the Renewable Fuel
Standard Program (RFS) Final Rule, published March 26, 2010 for soybean
oil biofuels.
1. Feedstock Production
    Camelina sativa (camelina) is an oilseed crop within the flowering
plant family Brassicaceae that is native to Northern Europe and Central
Asia. Camelina's suitability to northern climates and low moisture
requirements allows it to be grown in areas that are unsuitable for
other major oilseed crops such as soybeans, sunflower, and canola/
rapeseed. Camelina also requires the use of little to no tillage.\1\
Compared to many other oilseeds, camelina has a relatively short
growing season (less than 100 days), and can be grown either as a
spring annual or in the winter in milder climates.2 3
Camelina can also be used to break the continuous planting cycle of
certain grains, effectively reducing the disease, insect, and weed
pressure in fields planted with such grains (like wheat) in the
following year.\4\
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    \1\ Putnam, D.H., J.T. Budin, L.A. Field, and W.M. Breene. 1993.
Camelina: A promising low-input oilseed. p. 314-322. In: J. Janick
and J.E. Simon (eds.), New crops. Wiley, New York.
    \2\ Moser, B.R., Vaughn, S.F. 2010. Evaluation of Alkyl Esters
from Camelina Sativa Oil as Biodiesel and as Blend Components in
Ultra Low Sulfur Diesel Fuel. Bioresource Technology. 101:646-653.
    \3\ McVay, K.A., and P.F. Lamb. 2008. Camelina production in
Montana. MSU Ext. MT200701AG (revised). http://msuextension.org/publications/AgandNaturalResources/MT200701AG.pdf.
    \4\ Putnam et al., 1993.
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    Although camelina has been cultivated in Europe in the past for use
as food, medicine, and as a source for lamp oil, commercial production
using modern agricultural techniques has been limited.\5\ In addition
to being used as a renewable fuel feedstock, small quantities of
camelina (less than 5% of total U.S. camelina production) are currently
used as a dietary supplement and in the cosmetics industry.
Approximately 95% of current US production of camelina has been used
for testing purposes to evaluate its use as a feedstock to produce
primarily jet fuel.\6\ The FDA has not approved camelina for food uses,
although it has approved the inclusion of certain quantities of
camelina meal in commercial feed.\7\
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    \5\ Lafferty, Ryan M., Charlie Rife and Gus Foster. 2009. Spring
camelina production guide for the Central High Plains. Blue Sun
Biodiesel special publication. Blue Sun Agriculture Research &
Development, Golden, CO. http://www.gobluesun.com/upload/Spring%20Cam-elina%20Production%20Guide%202009.pdf.
    \6\ Telephone conversation with Scott Johnson, Sustainable Oils,
January 11, 2011.
    \7\ See http://agr.mt.gov/camelina/FDAletter11-09.pdf.
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    In response to the proposed rule, EPA received comments
highlighting the concern that by approving certain new feedstock types
under the RFS program, EPA would be encouraging their introduction or
expanded planting without considering their potential impact as
invasive species.\8\ The degree of concern expressed by the commenters
depended somewhat on the feedstock. As pointed out by the commenters,
camelina and energy cane are not ``native species,'' defined as ``a
species that, other than as a result of an introduction, historically
occurred or currently occurs in that ecosystem.'' The commenters
asserted that there is a ``potential risk posed by the non-native
species camelina and energy cane.'' In contrast, comments stated that
giant reed (Arundo donax) or napier grass (Pennisetum purpureum) have
been identified as invasive species in certain parts of the country.
These commenters asserted that the Arundo donax and napier grass pose a
``clear risk of invasion.'' Commenters stated that EPA should not
approve the proposed feedstocks until EPA has conducted an invasive
species analysis, as required under Executive Order (EO) 13112.\9\
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    \8\ Comment submitted by Jonathan Lewis, Senior Counsel, Climate
Policy, Clean Air Task Force et al., dated February 6, 2012.
Document ID  EPA-HQ-OAR-2011-0542-0118.
    \9\ http://www.gpo.gov/fdsys/pkg/FR-1999-02-08/pdf/99-3184.pdf.
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    The information before us does not raise significant concerns about
the threat of invasiveness and related GHG emissions for camelina. For
example, camelina is not listed on the Federal Noxious Weed List,\10\
nor is it listed on any state invasive species or noxious weed list. We
believe that the production of camelina is unlikely to spread beyond
the intended borders in which it is grown, which is consistent with the
assumption in EPA's lifecycle analysis that significant expenditures of
energy or other sources of GHGs will not be required to remediate the
spread of this feedstock from the specific locations where it is grown
as a renewable fuel feedstock for the RFS program. Therefore, we are
finalizing the camelina pathway in this rule based on our lifecycle
analysis discussed below.\11\
    Camelina is currently being grown on approximately 50,000 acres of
land in the U.S., primarily in Montana, eastern Washington, and the
Dakotas.\12\ USDA does not systematically collect camelina production
information; therefore data on historical acreage is limited. However,
available information indicates that camelina has been grown on trial
plots in 12 U.S. states.\13\
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    \10\ However, this list is not exhaustive and is generally
limited to species that are not currently in the U.S. or are
incipient to the U.S. See http:[sol][sol]plants.usda.gov/java/
noxious?rptType=Federal&statefips=&sort=sc. Accessed on March 28,
2012.
    \11\ EPA continues to evaluate Arundo donax and napier grass as
feedstock for a renewable fuel pathway, and will make a final
decision on these pathways at a later time.
    \12\ McCormick, Margaret. ``Oral Comments of Targeted Growth,
Incorporated'' Submitted to the EPA on June 9, 2009.
    \13\ See https:[sol][sol]www.camelinacompany.com/Marketing/
PressRelease.aspx?Id=25.
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    In response to the proposed rule, two commenters were supportive of
the use of renewable feedstocks such as camelina oil to produce
biofuels for aviation. One commenter noted that aviation is unique in
its complete dependency upon liquid fuel--today and into the
foreseeable future. Another commenter noted that development of
additional feedstocks and production pathways should increase supply
and ultimately move us closer to the day when renewable jet fuels are
price-competitive with legacy fossil fuels and help cut our dependence
on foreign oil. EPA also received comment regarding a concern that EPA
did not adequately establish that camelina would only be grown on
fallow land and therefore would not have a land use impact and that EPA
overestimated the likely yields in growing camelina and therefore
underestimated the land requirements.
    In terms of the comment on camelina not being grown on fallow land,
for the purposes of analyzing the lifecycle GHG emissions of camelina,
EPA has considered the likely production pattern for camelina grown for
biofuel production. Given the information currently available, camelina
is

expected to be primarily planted in the U.S. as a rotation crop on
acres that would otherwise remain fallow.\14\ Because camelina has not
yet been established as a commercial crop with significant monetary
value, farmers are unlikely to dedicate acres for camelina production
that could otherwise be used to produce other cash crops. Since
camelina would therefore not be expected to displace another crop but
rather maximize the value of the land through planting camelina in
rotation, EPA does not believe new acres would need to be brought into
agricultural use to increase camelina production. In addition, camelina
currently has only limited high-value niche markets for uses other than
renewable fuels. Unlike commercial crops that are tracked by USDA,
camelina does not have a well-established, internationally traded
market that would be significantly affected by an increase in the use
of camelina to produce biofuels. For these reasons, which are described
in more detail below, EPA has determined that production of camelina-
based biofuels is not expected to result in significant GHG emissions
related to direct land use change since it is expected to be grown on
fallow land. Furthermore, due to the limited non-biofuel uses for
camelina, production of camelina-based biofuels is not expected to have
a significant impact on other agricultural crop production or commodity
markets (either camelina or other crop markets) and consequently would
not result in significant GHG emissions related to indirect land use
change. To the extent camelina-based biofuel production decreases the
demand for alternative biofuels, some with higher GHG emissions, this
biofuel could have some beneficial GHG impact. However, it is uncertain
which mix of biofuel sources the market will demand so this potential
GHG impact cannot be quantified.
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    \14\ Fallow land here refers to cropland that is periodically
not cultivated.
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    Commenters stated that EPA failed to justify why camelina would be
grown on fallow land and thus result in no land use change. In the
proposed rule, EPA provided a detailed description of the economics
indicating why producers are most likely to grow camelina on land that
would otherwise remain fallow. This analysis formed the basis for why
it was reasonable and logical for camelina to be grown on acres that
would otherwise remain fallow. Comments also indicated that EPA's
economic basis for assuming camelina would most likely be grown on
fallow land was inadequate, especially if production of camelina was
scaled up. However, the comment did not indicate any specific point of
error in our economically based analysis. As we described in the
proposed rule and discuss below, camelina is currently not a
commercially raised crop in the United States, therefore the returns on
camelina are expected to be low compared to wheat and other crops with
established, commercially traded markets.\15\ Therefore, EPA expects
that initial production of camelina for biofuel production will be on
land with the lowest opportunity cost. Based on this logic, EPA
believes camelina will be grown as a rotation crop, as discussed below,
on dryland wheat acres replacing a period that the land would otherwise
be left fallow.
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    \15\ See Shonnard, D. R., Williams, L., & Kalnes, T. N. 2010.
Camelina-Derived Jet Fuel and Diesel: Sustainable Advanced
Biodiesel. Environmental Progress & Sustainable Energy, 382-392.
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    In the semi-arid regions of the Northern Great Plains, dryland
wheat farmers currently leave acres fallow once every three to four
years to allow additional moisture and nutrients to accumulate (see
Figure 1). Recent research indicates that introducing cool season
oilseed crops such as camelina can provide benefits by reducing soil
erosion, increasing soil organic matter, and disrupting pest cycles.
Although long-term data on the effects of replacing wheat/fallow
growing patterns with wheat/oilseed rotations is limited, there is some
data that growing oilseeds in drier semi-arid regions year after year
can lead to reduced wheat yields.\16\ However, the diversification and
intensification of wheat-fallow cropping systems can improve the long
term economic productivity of wheat acres by increasing soil nitrogen
and soil organic carbon pools.\17\ In addition, selective breeding is
expected to reduce the potential negative impacts on wheat yields.\18\
Additional research in this area is needed and if significant negative
impacts on crop rotations are determined from camelina grown on fallow
acres EPA would take that into account in future analysis.
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    \16\ Personal communication with Andrew Lenssen, Department of
Agronomy, Iowa State University, April 17, 2012. See also http://www.ars.usda.gov/is/pr/2010/100413.htm.
    \17\ See Sainju, U.M., T. Caesar-Tonthat, A.W. Lenssen, R.G.
Evans, and R. Kohlberg. 2007. Long-term tillage and cropping
sequence effects on dryland residue and soil carbon fractions. Soil
Science Society of America Journal 71: 1730-1739.
    \18\ See Shonnard et al., 2010; Lafferty et al., 2009.

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[GRAPHIC] [TIFF OMITTED] TR05MR13.014

    As pointed out by commenters, in the future camelina production
could expand beyond what is currently assumed in this analysis.
However, camelina would most likely not be able to compete with other
uses of land until

it becomes a commercial crop with a well-established market value. EPA
once again reiterates that we will continue to monitor the growing
patterns associated with camelina to determine whether actual
production is consistent with the assumptions used in this analysis.
Monitoring will be done by tracking the amount of RIN generating
camelina fuel produced through the EPA Moderated Transaction System
(EMTS). We can compare the amount of RIN generating fuel against
expected volumes from fallow acres in conjunction with USDA. Consistent
with EPA's approach to all RFS feedstock pathway analyses, we will
periodically reevaluate whether our assessment of GHG impacts will need
to be updated in the future based on the potential for significant
changes in our analyses.
a. Land Availability
    USDA estimates that there are approximately 60 million acres of
wheat in the U.S.\19\ USDA and wheat state cooperative extension
reports through 2008 indicate that 83% of US wheat production is under
non-irrigated, dryland conditions. Of the approximately 50 million non-
irrigated acres, at least 45% are estimated to follow a wheat/fallow
rotation. Thus, approximately 22 million acres are potentially suitable
for camelina production. However, according to industry projections,
only about 9 million of these wheat/fallow acres have the appropriate
climate, soil profile, and market access for camelina production.\20\
Therefore, our analysis uses the estimate that only 9 million wheat/
fallow acres are available for camelina production.
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    \19\ 2009 USDA Baseline. See http://www.ers.usda.gov/publications/oce091/.
    \20\ Johnson, S. and McCormick, M., Camelina: an Annual Cover
Crop Under 40 CFR Part 80 Subpart M, Memorandum, dated November 5,
2010.
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    One commenter stated that EPA assumed more than 8 million acres
would be used to produce camelina, even though a recent paper stated
that only 5 million acres would have the potential to grow camelina in
a sustainable manner in a way that would not impact the food supply.
This commenter misinterpreted EPA's assumptions. EPA's assessment is
based on a three year rotation cycle in which only one third of the 9
million available acres would be fallow in any given year. In other
words, EPA assumed only 3 million acres would be planted with camelina
in any given year. This number is less than the 5 million acres the
Shonnard et. al. paper states would be available annually for camelina
planting.
b. Projected Volumes
    Based on these projections of land availability, EPA estimates that
at current yields (approximately 800 pounds per acre), approximately
100 million gallons (MG) of camelina-based renewable fuels could be
produced with camelina grown in rotation with existing crop acres
without having direct land use change impacts. Also, since camelina
will likely be grown on fallow land and thus not displace any other
crop and since camelina currently does not have other significant
markets, expanding production and use of camelina for biofuel purposes
is not likely to have other agricultural market impacts and therefore,
would not result in any significant indirect land use impacts.\21\
Yields of camelina are expected to approach the yields of similar
oilseed crops over the next few years, as experience with growing
camelina improves cultivation practices and the application of existing
technologies are more widely adopted.\22\ Yields of 1650 pounds per
acre have been achieved on test plots, and are in line with expected
yields of other oilseeds such as canola/rapeseed. Assuming average US
yields of 1650 pounds per acre,\23\ approximately 200 MG of camelina-
based renewable fuels could be produced on existing wheat/fallow acres.
Finally, if investment in new seed technology allows yields to increase
to levels assumed by Shonnard et al (3000 pounds per acre),
approximately 400 MG of camelina-based renewable fuels could be
produced on existing acres.\24\ Depending on future crop yields, we
project that roughly 100 MG to 400 MG of camelina-based biofuels could
be produced on currently fallow land with no impacts on land use.\25\
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    \21\ Wheeler, P. and Guillen-Portal F. 2007. Camelina Production
in Montana: A survey study sponsored by Targeted Growth, Inc. and
Barkley Ag. Enterprises, LLP.
    \22\ See Hunter, J and G. Roth. 2010. Camelina Production and
Potential in Pennsylvania, Penn State University Agronomy Facts 72.
See http://pubs.cas.psu.edu/freepubs/pdfs/uc212.pdf.
    \23\ Ehrensing, D.T. and S.O. Guy. 2008. Oilseed Crops--
Camelina. Oregon State Univ. Ext. Serv. EM8953-E. See http://extension.oregonstate.edu/catalog/pdf/em/em8953-e.pdf; McVay & Lamb,
2008.
    \24\ See Shonnard et al., 2010.
    \25\ This assumes no significant adverse climate impacts on
world agricultural yields over the analytical timeframe.
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    We also received comments that we overestimated long term camelina
yields. The commentors stated that reaching yields of 3000 pounds per
acre may be attainable, but previous trials do not suggest that yields
could reach this level in ten years. As a point of clarification, we
did not assume that yields would need to be 3000 pounds per acre for
biodiesel produced from camelina oil to qualify as an advanced biofuel.
In the analysis presented below, EPA assumed yields of camelina would
be 1650 pounds per acre. Since the use of camelina as a biofuel
feedstock in the U.S. is in its infancy, it is reasonable to consider
how yields will change over time. Furthermore, jet fuel contracts and
the BCAP programs play a very important part in determining the amount
of camelina planted, and therefore interest in increasing yields. As
the commenter noted, this yield assumption is within the range of
potential yields of 330-2400 pounds per acre found in the current
literature.
c. Indirect Impacts
    Although wheat can in some cases be grown in rotation with other
crops such as lentils, flax, peas, garbanzo, and millet, cost and
benefit analysis indicate that camelina is most likely to be planted on
soil with lower moisture and nutrients where other rotation crops are
not viable.\26\ Because expected returns on camelina are relatively
uncertain, farmers are not expected to grow camelina on land that would
otherwise be used to grow cash crops with well established prices and
markets. Instead, farmers are most likely to grow camelina on land that
would otherwise be left fallow for a season. The opportunity cost of
growing camelina on this type of land is much lower. As previously
discussed, this type of land represents the 9 million acres currently
being targeted for camelina production. Current returns on camelina are
relatively low ($13.24 per acre), given average yields of approximately
800 pounds per acre and the current contract price of $0.145 per
pound.\27\ See Table 1. For comparison purposes, the USDA projections
for wheat returns are between $133-$159 per acre between 2010 and
2020.\28\ Over time, advancements in seed technology, improvements in
planting and harvesting techniques, and higher input usage could
significantly increase future camelina yields and returns.
---------------------------------------------------------------------------

    \26\ See Lafferty et al, 2009; Shonnard et al, 2010; Sustainable
Oils Memo dated November 5, 2010.
    \27\ Wheeler & Guillen-Portal, 2007.
    \28\ See http://www.ers.usda.gov/media/273343/oce121_2_.pdf.

                                       Table 1--Camelina Costs and Returns
----------------------------------------------------------------------------------------------------------------
                                                                   2010 Camelina   2022 Camelina   2030 Camelina
                Inputs                            Rates                \29\            \30\            \31\
----------------------------------------------------------------------------------------------------------------
Herbicides:
    Glysophate (Fall).................  16 oz. ( $0.39/oz)......           $7.00           $7.00           $7.00
    Glysophate (Spring)...............  16 oz. ( $0.39/oz)......           $7.00           $7.00           $7.00
    Post..............................  12 oz ( $0.67/oz).......           $8.00           $8.00           $8.00
Seed:
    Camelina seed.....................  $1.44/lb................           $5.76           $7.20           $7.20
                                                                    (4 lbs/acre)    (5 lbs/acre)    (5 lbs/acre)
Fertilizer:
    Nitrogen Fertilizer...............  $1/pd...................          $25.00          $40.00             $75
                                                                    (25 lb/acre)    (40 lb/acre)   (75 lbs/acre)
    Phosphate Fertilizer..............  $1/pd...................          $15.00          $15.00             $15
                                                                    (15 lb/acre)    (15 lb/acre)    (15 lb/acre)
        Sub-Total.....................  ........................          $67.76          $84.20         $119.20
Logistics:
    Planting Trip.....................  ........................          $10.00          $10.00          $10.00
    Harvest & Hauling.................  ........................          $25.00          $25.00          $25.00
      Total Cost......................  ........................         $102.76         $119.20         $154.20
    Yields............................  lb/acre.................             800            1650            3000
    Price.............................  $/lb....................          $0.145          $0.120          $0.090
        Total Revenue at avg prod/      ........................         $116.00            $198            $270
         pricing.
    Returns...........................  ........................          $13.24          $78.80         $115.80
----------------------------------------------------------------------------------------------------------------

    While replacing the fallow period in a wheat rotation is expected
to be the primary means by which the majority of all domestic camelina
is commercially harvested in the short- to medium-term, in the long
term camelina may expand to other regions and growing methods.\32\ For
example, if camelina production expanded beyond the 9 million acres
assumed available from wheat fallow land, it could impact other crops.
However, as discussed above this is not likely to happen in the near
term due to uncertainties in camelina financial returns. Camelina
production could also occur in areas where wheat is not commonly grown.
For example, testing of camelina production has occurred in Florida in
rotation with kanaf, peanuts, cotton, and corn. However, only 200 acres
of camelina were harvested in 2010 in Florida. While Florida acres of
camelina are expected to be higher in 2011, very little research has
been done on growing camelina in Florida. For example, little is known
about potential seedling disease in Florida or how camelina may be
affected differently than in colder climates.\33\ Therefore, camelina
grown outside of a wheat fallow situation was not considered as part of
this analysis.
---------------------------------------------------------------------------

    \29\ See Sustainable Oils Memo dated November 5, 2010.
    \30\ Based on yields technically feasible. See McVey and Lamb,
2008; Ehrenson & Guy, 2008.
    \31\ Adapted from Shonnard et al, 2010.
    \32\ See Sustainable Oils Memo dated November 5, 2010 for a map
of the regions of the country where camelina is likely to be grown
in wheat fallow conditions.
    \33\ Wright & Marois, 2011.
---------------------------------------------------------------------------

    The determination in this final rule is based on our projection
that camelina is likely to be produced on what would otherwise be
fallow land. However, the rule applies to all camelina regardless of
where it is grown. EPA does not expect that significant camelina would
be grown on non-fallow land, and small quantities that may be grown
elsewhere and used for biofuel production will not significantly impact
our analysis.
    Furthermore, although we expect most camelina used as a feedstock
for renewable fuel production that would qualify in the RFS program
would be grown in the U.S., today's rule would apply to qualifying
renewable fuel made from camelina grown in any country. For the same
reasons that pertain to U.S. production of camelina, we expect that
camelina grown in other countries would also be produced on land that
would otherwise be fallow and would therefore have no significant land
use change impacts. The renewable biomass provisions under the Energy
Independence and Security Act would prohibit direct land conversion
into new agricultural land for camelina production for biofuel
internationally. Additionally, any camelina production on existing
cropland internationally would not be expected to have land use impacts
beyond what was considered for international soybean production
(soybean oil is the expected major feedstock source for US biodiesel
fuel production and thus the feedstock of reference for the camelina
evaluation). Because of these factors along with the small amounts of
fuel potentially coming from other countries, we believe that
incorporating fuels produced in other countries will not impact our
threshold analysis for camelina-based biofuels.
d. Crop Inputs
    For comparison purposes, Table 2 shows the inputs required for
camelina production compared to the FASOM agricultural input
assumptions for soybeans. Since yields and input assumptions vary by
region, a range of values for soybean production are shown in Table 2.
The camelina input values in Table 2 represent average values, camelina
input values will also vary by region, however, less data is available
comparing actual practices by region due to limited camelina
production. More information on camelina inputs is available in
materials provided in the docket.

                               Table 2--Inputs for Camelina and Soybean Production
----------------------------------------------------------------------------------------------------------------
                                              Camelina                        Soybeans (varies by region)
                               ---------------------------------------------------------------------------------
                                                     Emissions (per      Inputs (per      Emissions (per mmBtu
                                Inputs (per acre)     mmBtu fuel)           acre)                 fuel)
----------------------------------------------------------------------------------------------------------------
N2O...........................  N/A..............  22 kg CO2-eq.....  N/A.............  9-12 kg CO2-eq.
Nitrogen Fertilizer...........  40 lbs...........  7 kg CO2-eq......  3.5-8.2 lbs.....  1-3 kg CO2-eq.
Phosphorous Fertilizer........  15 lbs...........  1 kg CO2-eq......  5.4-21.4 lbs....  0-2 kg CO2-eq.
Potassium Fertilizer..........  10 lbs...........  0 kg CO2-eq......  3.1-24.3 lbs....  0-2 kg CO2-eq.
Herbicide.....................  2.75 lbs.........  3 kg CO2-eq......  0.0-1.3 lbs.....  0-2 kg CO2-eq.
Pesticide.....................  0 lbs............  0 kg CO2-eq......  0.1-0.8 lbs.....  0-2 kg CO2-eq.
Diesel........................  3.5 gal..........  5 kg CO2-eq......  3.8-8.9 gal.....  7-20 kg CO2-eq.
Gasoline......................  0 gal............  0 kg CO2-eq......  1.6-3.0 gal.....  3-5 kg CO2-eq.
Total.........................  .................  39 kg CO2-eq.....  ................  21-47 kg CO2-eq.
----------------------------------------------------------------------------------------------------------------

    Regarding crop inputs per acre, it should be noted that camelina
has a higher percentage of oil per pound of seed than soybeans.
Soybeans are approximately 18% oil, therefore crushing one pound of
soybeans yields 0.18 pounds of oil. In comparison, camelina is
approximately 36% oil, therefore crushing one pound of camelina yields
0.36 pounds of oil. The difference in oil yield is taken into account
when calculating the emissions per mmBTU included in Table 2. As shown
in Table 2, GHG emissions from feedstock production for camelina and
soybeans are relatively similar when factoring in variations in oil
yields per acre and fertilizer, herbicide, pesticide, and petroleum
use.
    In summary, EPA concludes that the agricultural inputs for growing
camelina are similar to those for growing soy beans, direct land use
change impacts are expected to be negligible due to planting on land
that would be otherwise fallow, and the limited production and use of
camelina indicates no expected impacts on other crops and therefore no
indirect land use impacts.
e. Crushing and Oil Extraction
    We also looked at the seed crushing and oil extraction process and
compared the lifecycle GHG emissions from this stage for soybean oil
and camelina oil. As discussed above, camelina seeds produce more oil
per pound than soybeans. As a result, the lifecycle GHG emissions
associated with crushing and oil extraction are lower for camelina than
soybeans, per pound of vegetable oil produced. Table 3 summarizes data
on inputs, outputs and estimated lifecycle GHG emissions from crushing
and oil extraction. The data on soybean crushing comes from the March
2010 RFS final rule, based on a process model developed by USDA-
ARS.\34\ The data on camelina crushing is from Shonnard et al. (2010).
---------------------------------------------------------------------------

    \34\ A. Pradhan, D.S. Shrestha, A. McAloon, W. Yee, M. Haas,
J.A. Duffield, H. Shapouri, September 2009, ``Energy Life-Cycle
Assessment of Soybean Biodiesel'', United States Department of
Agriculture, Office of the Chief Economist, Office of Energy Policy
and New Uses, Agricultural Economic Report Number 845.

                     Table 3--Comparison of Camelina and Soybean Crushing and Oil Extraction
----------------------------------------------------------------------------------------------------------------
                  Item                       Soybeans        Camelina                      Units
----------------------------------------------------------------------------------------------------------------
Material Inputs:
    Beans or Seeds......................            5.38            2.90  Lbs.
Energy Inputs:
    Electricity.........................             374              47  Btu.
    Natural Gas & Steam.................           1,912             780  Btu.
Outputs:
    Refined vegetable oil...............            1.00            1.00  Lbs.
    Meal................................            4.08            1.85  Lbs.
    GHG Emissions.......................             213              64  gCO2e/lb refined oil.
----------------------------------------------------------------------------------------------------------------

2. Feedstock Distribution, Fuel Distribution, and Fuel Use
    For this analysis, EPA projects that the feedstock distribution
emissions will be the same for camelina and soybean oil. To the extent
that camelina contains more oil per pound of seed, as discussed above,
the energy needed to move the camelina would be lower than soybeans per
gallon of fuel produced. To the extent that camelina is grown on more
disperse fallow land than soybean and would need to be transported
further, the energy needed to move the camelina could be higher than
soybean. We believe the assumption to use the same distribution impacts
for camelina as soybean is a reasonable estimate of the GHG emissions
from camelina feedstock distribution. In addition, the final fuel
produced from camelina is also expected to be similar in composition to
the comparable fuel produced from soybeans, therefore we are assuming
GHG emissions from the distribution and use of fuels made from camelina
will be the same as emissions of fuel produced from soybeans.
3. Fuel Production
    There are two main fuel production processes used to convert
camelina oil into fuel. The trans-esterification process produces
biodiesel and a glycerin co-product. The hydrotreating process can be
configured to produce renewable diesel either primarily as diesel fuel
(including heating oil) or primarily as jet fuel. Possible additional
products from hydrotreating include naphtha LPG, and propane. Both
processes and the fuels produced are described in the following
sections. Both processes use camelina oil as a feedstock and camelina
crushing is also included in the analysis.

a. Biodiesel
    For this analysis, we assumed the same biodiesel production
facility designs and conversion efficiencies as modeled for biodiesel
produced from soybean oil and canola/rapeseed oil. Camelina oil
biodiesel is produced using the same methods as soybean oil biodiesel,
therefore plant designs are assumed to not significantly differ between
fuels made from these feedstocks. As was the case for soybean oil
biodiesel, we have not projected in our assessment of camelina oil
biodiesel any significant improvements in plant technology.
Unanticipated energy saving improvements would further improve GHG
performance of the fuel pathway.
    The glycerin produced from camelina biodiesel production is
chemically equivalent to the glycerin produced from the existing
biodiesel pathways (e.g., based on soy oil) that were analyzed as part
of the March 2010 RFS final rule. Therefore the same co-product credit
would apply to glycerin from camelina biodiesel as glycerin produced in
the biodiesel pathways modeled for the March 2010 RFS final rule. The
assumption is that the GHG reductions associated with the replacement
of residual oil with glycerin on an energy equivalent basis represents
an appropriate midrange co-product credit of biodiesel produced
glycerin.
    As part of our RFS2 proposal, we assumed the glycerin would have no
value and would effectively receive no co-product credits in the soy
biodiesel pathway. We received numerous comments, however, asserting
that the glycerin would have a beneficial use and should generate co-
product benefits. Therefore, the biodiesel glycerin co-product
determination made as part of the March 2010 RFS final rule took into
consideration the possible range of co-product credit results. The
actual co-product benefit will be based on what products are replaced
by the glycerin and what new uses develop for the co-product glycerin.
The total amount of glycerin produced from the biodiesel industry will
actually be used across a number of different markets with different
GHG impacts. This could include for example, replacing petroleum
glycerin, replacing fuel products (residual oil, diesel fuel, natural
gas, etc.), or being used in new products that don't have a direct
replacement, but may nevertheless have indirect effects on the extent
to which existing competing products are used. The more immediate GHG
reduction credits from glycerin co-product use could range from fairly
high reduction credits if petroleum glycerin is replaced to lower
reduction credits if it is used in new markets that have no direct
replacement product, and therefore no replaced emissions.
    EPA does not have sufficient information (and received no relevant
comments as part of the March 2010 RFS rule) on which to allocate
glycerin use across the range of likely uses. Therefore, EPA believes
that the approach used in the RFS of picking a surrogate use for
modeling purposes in the mid-range of likely glycerin uses, and the GHG
emissions results tied to such use, is reasonable. The replacement of
an energy equivalent amount of residual oil is a simplifying assumption
determined by EPA to reflect the mid-range of possible glycerin uses in
terms of GHG credits. EPA believes that it is appropriately
representative of GHG reduction credit across the possible range
without necessarily biasing the results toward high or low GHG impact.
Given the fundamental difficulty of predicting possible glycerin uses
and impacts of those uses many years into the future under evolving
market conditions, EPA believes it is reasonable to use the more
simplified approach to calculating co-product GHG benefits associated
with glycerin production at this time. EPA will continue to evaluate
the co-product credit associated with glycerine production in future
rulemakings.
    Given the fact that GHG emissions from camelina-based biodiesel
would be similar to the GHG emissions from soybean-based biodiesel at
all stages of the lifecycle but would not result in land use changes as
was the case for soy oil used as a feedstock, we believe biodiesel from
camelina oil will also meet the 50% GHG emissions reduction threshold
to qualify as a biomass based diesel and an advanced fuel. Therefore,
EPA is including biodiesel produced from camelina oil under the same
pathways for which biodiesel made from soybean oil qualifies under the
March 2010 RFS final rule.
b. Renewable Diesel (Including Jet Fuel and Heating Oil), Naphtha, and
LPG
    The same feedstocks currently used for biodiesel production can
also be used in a hydrotreating process to produce a slate of products,
including diesel fuel, heating oil (defined as No. 1 or No. 2 diesel),
jet fuel, naphtha, LPG, and propane. Since the term renewable diesel is
defined to include the products diesel fuel, jet fuel and heating oil,
the following discussion uses the term renewable diesel to also include
diesel fuel, jet fuel and heating oil. The yield of renewable diesel is
relatively insensitive to feedstock source.\35\ While any propane
produced as part of the hydrotreating process will most likely be
combusted within the facility for process energy, the other co-products
that can be produced (i.e., renewable diesel, naphtha, LPG) are higher
value products that could be used as transportation fuels or, in the
case of naphtha, a blendstock for production of transportation fuel.
The hydrotreating process maximized for producing a diesel fuel
replacement as the primary fuel product requires more overall material
and energy inputs than transesterification to produce biodiesel, but it
also results in a greater amount of other valuable co-products as
listed above. The hydrotreating process can also be maximized for jet
fuel production which requires even more process energy than the
process optimized for producing a diesel fuel replacement, and produces
a greater amount of co-products per barrel of feedstock, especially
naphtha.
---------------------------------------------------------------------------

    \35\ Kalnes, T., N., McCall, M., M., Shonnard, D., R., 2010.
Renewable Diesel and Jet-Fuel Production from Fats and Oils.
Thermochemical Conversion of Biomass to Liquid Fuels and Chemicals,
Chapter 18, p. 475.
---------------------------------------------------------------------------

    Producers of renewable diesel from camelina have expressed interest
in generating RINs under the RFS program for the slate of products
resulting from the hydrotreating process. Our lifecycle analysis
accounts for the various uses of the co-products. There are two main
approaches to accounting for the co-products produced, the allocation
approach, and the displacement approach. In the allocation approach all
the emissions from the hydrotreating process are allocated across all
the different co-products. There are a number of ways to do this but
since the main use of the co-products would be to generate RINs as a
fuel product we allocate based on the energy content of the co-products
produced. In this case, emissions from the process would be allocated
equally to all the Btus produced. Therefore, on a per Btu basis all co-
products would have the same emissions. The displacement approach would
attribute all of the emissions of the hydrotreating process to one main
product and then account for the emission reductions from the other co-
products displacing alternative product production. For example, if the
hydrotreating process is configured to maximize diesel fuel replacement
production, all of the emissions from the process would be attributed
to diesel fuel, but we would then assume the other co-products were
displacing

alternative products, for example, naphtha would displace gasoline, LPG
would displace natural gas, etc. This assumes the other alternative
products are not produced or used, so we would subtract the emissions
of gasoline production and use, natural gas production and use, etc.
This would show up as a GHG emission credit associated with the
production of diesel fuel replacement.
    To account for the case where RINs are generated for the jet fuel,
naphtha and LPG in addition to the diesel replacement fuel produced, we
would not give the diesel replacement fuel a displacement credit for
these co-products. Instead, the lifecycle GHG emissions from the fuel
production processes would be allocated to each of the RIN-generating
products on an energy content basis. This has the effect of tending to
increase the fuel production lifecycle GHG emissions associated with
the diesel replacement fuel because there are less co-product
displacement credits to assign than would be the case if RINs were not
generated for the co-products.\36\ On the other hand, the upstream
lifecycle GHG emissions associated with producing and transporting the
plant oil feedstocks will be distributed over a larger group of RIN-
generating products. Assuming each product (except propane) produced
via the camelina oil hydrotreating process will generate RINs results
in higher lifecycle GHG emissions for diesel fuel replacement as
compared to the case where the co-products are not used to generate
RINs. This general principle is also true when the hydrotreating
process is maximized for jet fuel production. As a result, the worst
GHG performance (i.e., greatest lifecycle GHG emissions) for diesel
replacement fuel and jet fuel produced from camelina oil via
hydrotreating will occur when all of the co-products are RIN-generating
(we assume propane will be used for process energy). Thus, if these
fuels meet the 50% GHG reduction threshold for biomass based diesel or
advanced biofuel when co-products are RIN-generating, they will also do
so in the case when RINs are not generated for co-products.
---------------------------------------------------------------------------

    \36\ For a similar discussion see page 46 of Stratton, R.W.,
Wong, H.M., Hileman, J.I. 2010. Lifecycle Greenhouse Gas Emissions
from Alternative Jet Fuels. PARTNER Project 28 report. Version 1.1.
PARTNER-COE-2010-001. June 2010, http://web.mit.edu/aeroastro/partner/reports/proj28/partner-proj28-2010-001.pdf.
---------------------------------------------------------------------------

    We have evaluated information about the lifecycle GHG emissions
associated with the hydrotreating process which can be maximized for
jet fuel or diesel replacement fuel production. Our evaluation
considers information published in peer-reviewed journal articles and
publicly available literature (Kalnes et al., 2010, Pearlson, M., N.,
2011,\37\ Stratton et al., 2010, Huo et al., 2008 \38\). Our analysis
of GHG emissions from the hydrotreating process is based on the mass
and energy balance data in Pearlson (2011) which analyzes a
hydrotreating process maximized for diesel replacement fuel production
and a hydrotreating process maximized for jet fuel production.\39\ This
data is summarized in Table 4.
---------------------------------------------------------------------------

    \37\ Pearlson, M., N. 2011. A Techno-Economic and Environmental
Assessment of Hydroprocessed Renewable Distillate Fuels.
    \38\ Huo, H., Wang., M., Bloyd, C., Putsche, V., 2008. Life-
Cycle Assessment of Energy and Greenhouse Gas Effects of Soybean-
Derived Biodiesel and Renewable Fuels. Argonne National Laboratory.
Energy Systems Division. ANL/ESD/08-2. March 12, 2008.
    \39\ We have also considered data submitted by companies
involved in the hydrotreating industry which is claimed as
confidential business information (CBI). The conclusions using the
CBI data are consistent with the analysis presented here.
    \40\ Based on Pearlson (2011), Table 3.1 and Table 3.2.

     Table 4--Hydrotreating Processes To Convert Camelina Oil Into Diesel Replacement Fuel and Jet Fuel\40\
----------------------------------------------------------------------------------------------------------------
                                               Maximized  for  Maximized  for
                                                diesel  fuel      jet fuel         Units (per gallon of fuel
                                                 production      production                produced)
----------------------------------------------------------------------------------------------------------------
Inputs:
    Refined camelina oil.....................            9.56           12.84  Lbs.
    Hydrogen.................................            0.04            0.08  Lbs.
    Electricity..............................          652             865     Btu.
    Natural Gas..............................       23,247          38,519     Btu.
Outputs:
    Diesel Fuel..............................      123,136          55,845     Btu.
    Jet fuel.................................       23,197         118,669     Btu.
    Naphtha..................................        3,306          17,042     Btu.
    LPG......................................        3,084          15,528     Btu.
    Propane..................................        7,454           9,881     Btu.
----------------------------------------------------------------------------------------------------------------

    Table 5 compares lifecycle GHG emissions from oil extraction and
fuel production for soybean oil biodiesel and for camelina-based diesel
and jet fuel. The lifecycle GHG estimates for camelina oil diesel and
jet fuel are based on the input/output data summarized in Table 3 (for
oil extraction) and Table 4 (for fuel production). We assume that the
propane co-product does not generate RINs; instead, it is used for
process energy displacing natural gas. We also assume that the naphtha
is used as blendstock for production of transportation fuel to generate
RINs. In this case we assume that RINs are generated for the use of LPG
in a way that meets the EISA definition of transportation fuel, for
example it could be used in a nonroad vehicle. The lifecycle GHG
results in Table 5 represent the worst case scenario (i.e., highest GHG
emissions) because all of the eligible co-products are used to generate
RINs. This is because, as discussed above, lifecycle GHG emissions per
Btu of diesel or jet fuel would be lower if the naphtha or LPG is not
used to generate RINs and is instead used for process energy displacing
fossil fuel such as natural gas. Supporting information for the values
in Table 5, including key assumptions and data, is provided through the
docket.\41\ The key assumptions and data discussed in the docket
include the emissions factors for natural gas, hydrogen and grid
average electricity, and the energy allocation and displacement credits
given to co-products. These data and assumptions are based on the
approach taken in the March 2010 RFS rule, as explained further below.
---------------------------------------------------------------------------

    \41\ See for example the spreadsheet with lifecycle GHG
emissions calculations titled ``Final Camelina Calculations for
Docket'' with document number EPA-HQ-OAR-2011-0542-0046.

                                                    Table 5--Fuel Production Lifecycle GHG Emissions
                                                                   [kgCO2e/mmBtu) \42\
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                                 RIN-Generating                                    Oil
             Feedstock                 Production process           products            Other co-products      extraction      Processing       Total
--------------------------------------------------------------------------------------------------------------------------------------------------------
Soybean Oil........................  Trans-Esterification..  Biodiesel.............  Glycerin..............              14             (1)           13
Camelina Oil.......................  Trans-Esterification..  Biodiesel.............  Glycerin..............               4             (1)            3
Camelina Oil.......................  Hydrotreating           Diesel................  Propane...............               4              8            12
                                      Maximized for Diesel.  Jet Fuel..............
                                                             Naphtha...............
                                                             LPG.
Camelina Oil.......................  Hydrotreating           Diesel Fuel...........  Propane...............               4             11            14
                                      Maximized for Jet      Jet Fuel..............
                                      Fuel.                  Naphtha...............
                                                             LPG.
--------------------------------------------------------------------------------------------------------------------------------------------------------

---------------------------------------------------------------------------

    \42\ Lifecycle GHG emissions are normalized per mmBtu of RIN-
generating fuel produced. Totals may not be the sum of the rows due
to rounding error. Parentheses indicate negative numbers. Process
emissions for biodiesel production are negative because they include
the glycerin offset credit.
---------------------------------------------------------------------------

    As discussed above, for a process that produces more than one RIN-
generating output (e.g., the hydrotreating process summarized in Table
5 which produces diesel replacement fuel, jet fuel, and naphtha) we
allocate lifecycle GHG emissions to the RIN generating products on an
energy equivalent basis. We then normalize the allocated lifecycle GHG
emissions per mmBtu of each fuel product. Therefore, each RIN-
generating product from the same process will be assigned equal
lifecycle GHG emissions per mmBtu from fuel processing. For example,
based on the lifecycle GHG estimates in Table 5 for the hydrotreating
process maximized to produce jet fuel, the jet fuel and the naphtha
both have lifecycle GHG emissions of 14 kgCO2e/mmBtu. For the same
reasons, the lifecycle GHG emissions from the jet fuel and naphtha will
stay equivalent if we consider upstream GHG emissions, such as
emissions associated with camelina cultivation and harvesting.
Lifecycle GHG emissions from fuel distribution and use could be
somewhat different for the jet fuel and naphtha, but since these stages
produce a relatively small share of the emissions related to the full
fuel lifecycle, the overall difference will be quite small.
    Given that GHG emissions from camelina oil would be similar to the
GHG emissions from soybean oil at all stages of the lifecycle but would
not result in land use change emissions (soy oil feedstock did have a
significant land use change impact but still met a 50% GHG reduction
threshold), and considering differences in process emissions between
soybean biodiesel and camelina-based renewable diesel, we conclude that
renewable diesel from camelina oil will also meet the 50% GHG emissions
reduction threshold to qualify as biomass based diesel and advanced
fuel. Although some of the potential configurations result in fuel
production GHG emissions that are higher than fuel production GHG
emissions for soybean oil biodiesel, land use change emissions account
for approximately 80% of the soybean oil to biodiesel lifecycle GHGs.
Since camelina is assumed not to have land use change emissions, our
analysis shows that camelina renewable diesel will qualify for advanced
renewable fuel and biomass-based diesel RINs even for the cases with
the highest lifecycle GHGs (e.g., when all of the co-products are used
to generate RINs.) Because the lifecycle GHG emissions for RIN-
generating co-products are very similar, we can also conclude renewable
gasoline blendstock and LPG produced from camelina oil will also meet
the 50% GHG emissions reduction threshold. If the facility does not
actually generate RINs for one or more of these co-products, we
estimate that the lifecycle GHG emissions related to the RIN-generating
products would be lower, thus renewable diesel (which includes diesel
fuel, jet fuel, and heating oil) from camelina would still meet the 50%
emission reduction threshold.
4. Summary
    Current information suggests that camelina will be produced on land
that would otherwise remain fallow. Therefore, increased production of
camelina-based renewable fuel is not expected to result in significant
land use change emissions; however, the agency will continue to monitor
volumes through EMTS to verify this assumption. For the purposes of
this analysis, EPA is projecting there will be no land use emissions
associated with camelina production for use as a renewable fuel
feedstock.
    However, while production of camelina on acres that would otherwise
remain fallow is expected to be the primary means by which the majority
of all camelina is commercially harvested in the short- to medium-
term, in the long term camelina may expand to other growing methods and
lands if demand increases substantially beyond what EPA is currently
predicting. While the impacts are uncertain, there are some indications
demand could increase significantly. For example, camelina is included
under USDA's Biomass Crop Assistance Program (BCAP) and there is
growing support for the use of camelina oil in producing drop-in
alternative aviation fuels. EPA plans to monitor, through EMTS and in
collaboration with USDA, the expansion of camelina production to verify
whether camelina is primarily grown on existing acres once camelina is
produced at larger-scale volumes. Similarly, we will consider market
impacts if alternative uses for camelina expand significantly beyond
what was described in the above analysis. Just as EPA plans to
periodically review and revise the methodology and assumptions
associated with calculating the GHG emissions from all renewable fuel
feedstocks, EPA expects to review and revise as necessary the analysis
of camelina in the future.
    Taking into account the assumption of no land use change emissions
when camelina is used to produce renewable fuel, and considering that
other sources of GHG emissions related to camelina biodiesel or
renewable diesel production have comparable GHG emissions to biodiesel
from soybean oil, we have determined that camelina-based biodiesel and
renewable diesel should be treated in the same manner as soy-based
biodiesel and renewable diesel in qualifying as biomass-based diesel
and advanced biofuel for purposes of RIN generation, since the GHG
emission performance of the

camelina-based fuels will be at least as good and in some respects
better than that modeled for fuels made from soybean oil. EPA found as
part of the Renewable Fuel Standard final rulemaking that soybean
biodiesel resulted in a 57% reduction in GHG emissions compared to the
baseline petroleum diesel fuel. Furthermore, approximately 80% of the
lifecycle impacts from soybean biodiesel were from land use change
emissions which are assumed to be not significant for the camelina
pathway considered. Thus, EPA is including camelina oil as a potential
feedstock under the same biodiesel and renewable diesel (which includes
diesel fuel, jet fuel, and heating oil) pathways for which soybean oil
currently qualifies. We are also including a pathway for naphtha and
LPG produced from camelina oil through hydrotreating. This is based on
the fact that our analysis shows that even when all of the co-products
are used to generate RINs the lifecycle GHG emissions for RIN-
generating co-products including diesel replacement fuel, jet fuel,
naphtha and LPG produced from camelina oil will all meet the 50% GHG
emissions reduction threshold.
    We are also clarifying that two existing pathways for RIN
generation in the RFS regulations that list ``renewable diesel'' as a
fuel product produced through a hydrotreating process include jet fuel.
This applies to two pathways in Table 1 to Sec.  80.1426 of the RFS
regulations which both list renewable diesel made from soy bean oil,
oil from annual covercrops, algal oil, biogenic waste oils/fats/
greases, or non-food grade corn oil using hydrotreating as a process.
If parties produce jet fuel from the hydrotreating process and co-
process renewable biomass and petroleum they can generate advanced
biofuel RINs (D code 5) for the jet fuel produced. If they do not co-
process renewable biomass and petroleum they can generate biomass-based
diesel RINs (D code 4) for the jet fuel produced.
    Sec.  80.1401 of the RFS regulations currently defines non-ester
renewable diesel as a fuel that is not a mono-alkyl ester and which can
be used in an engine designed to operate on conventional diesel fuel or
be heating oil or jet fuel. The reference to jet fuel in this
definition was added by direct final rule dated May 10, 2010. Table 1
to Sec.  80.1426 identifies approved fuel pathways by fuel type,
feedstock source and fuel production processes. The table, which was
largely adopted as part of the March 26, 2010 RFS final rule,
identifies jet fuel and renewable diesel as separate fuel types.
Accordingly, in light of the revised definition of renewable diesel
enacted after the RFS2 rule, there is ambiguity regarding the extent to
which references in Table 1 to ``renewable diesel'' include jet fuel.
    The original lifecycle analysis for the renewable diesel from
hydrotreating pathways listed in Table 1 to Sec.  80.1426 was not based
on producing jet fuel but rather other transportation diesel fuel
products, namely a diesel fuel replacement. As discussed above, the
hydrotreating process can produce a mix of products including jet fuel,
diesel, naphtha, LPG and propane. Also, as discussed, there are
differences in the process configured for maximum jet fuel production
vs. the process maximized for diesel fuel production and the lifecycle
results vary depending on what approach is used to consider co-products
(i.e., the allocation or displacement approach).
    In cases where there are no pathways for generating RINs for the
co-products from the hydrotreating process it would be appropriate to
use the displacement method for capturing the credits of co-products
produced. This is the case for most of the original feedstocks included
in Table 1 to Sec.  80.1426.\43\ As was discussed previously, if the
displacement approach is used when jet fuel is the primary product
produced it results in lower emissions than the production maximized
for diesel fuel production. Therefore, since the hydrotreating process
maximized for diesel fuel meets the 50% lifecycle GHG threshold for the
feedstocks in question, the process maximized for jet fuel would also
qualify.
---------------------------------------------------------------------------

    \43\ The exception is renewable gasoline blendstock produced
from waste categories, but these would pass the lifecycle thresholds
regardless of the allocation approach used given their low feedstock
GHG impacts.
---------------------------------------------------------------------------

    Thus, we are interpreting the references to ``renewable diesel'' in
Table 1 to include jet fuel, consistent with our regulatory definition
of ``non-ester renewable diesel,'' since doing so clarifies the
existing regulations while ensuring that Table 1 to Sec.  80.1426
appropriately identifies fuel pathways that meet the GHG reduction
thresholds associated with each pathway.
    We note that although the definition of renewable diesel includes
jet fuel and heating oil, we have also listed in Table 1 of section
80.1426 of the RFS regulations jet fuel and heating oil as specific co-
products in addition to listing renewable diesel to assure clarity.
This clarification also pertains to all the feedstocks already included
in Table 1 for renewable diesel.

B. Lifecycle Greenhouse Gas Emissions Analysis for Ethanol, Diesel, Jet
Fuel, Heating Oil, and Naphtha Produced From Energy Cane

    For this rulemaking, EPA considered the lifecycle GHG impacts of a
new type of high-yielding perennial grass similar in cellulosic
composition to switchgrass and comparable in status as an emerging
energy crop. The grass considered in this rulemaking is energy cane,
which is defined as a complex hybrid in the Saccharum genus that has
been bred to maximize cellulosic rather than sugar content.
    As discussed above, in response to the proposed rule, EPA received
comments highlighting the concern that by approving certain new
feedstock types under the RFS program, EPA would be encouraging their
introduction or expanded planting without considering their potential
impact as invasive species.\44\
---------------------------------------------------------------------------

    \44\ Comment submitted by Jonathan Lewis, Senior Counsel,
Climate Policy, Clean Air Task Force et al., dated February 6, 2012.
Document ID  EPA-HQ-OAR-2011-0542-0118.
---------------------------------------------------------------------------

    As described in the previous section on camelina, the information
before us does not raise significant concerns about the threat of
invasiveness and related GHG emissions for energy cane. Energy cane is
generally a hybrid of Saccharum officinarum and Saccharum spontaneum,
though other species such as Saccharum barberi and Saccharum sinense
have been used in the development of new cultivars.\45\ Given the fact
that S. spontaneum is listed on the Federal Noxious Weed List, this
rulemaking does not allow for the inclusion of S. spontaneum in the
definition of energy cane. However, hybrids derived from S. spontaneum
that have been developed and publicly released by USDA are included in
this definition of the energy cane feedstock. USDA's Agricultural
Research Service has developed strains of energy cane that strive to
maximize fiber content and minimize invasive traits. Therefore, we
believe that the production of cultivars of energy cane that were
developed by USDA are unlikely to spread beyond the intended borders in
which it is grown, which is consistent with the assumption in EPA's
lifecycle analysis that significant expenditures of energy or other
sources of GHGs will not be required to remediate the spread of this
feedstock from the specific locations where it is grown as a renewable
fuel

feedstock for the RFS program. Therefore, we are finalizing the energy
cane pathway in this rule based on our lifecycle analysis discussed
below.
---------------------------------------------------------------------------

    \45\ See https://www.crops.org/publications/jpr/abstracts/2/3/211?access=0&view=pdf and http://www.cpact.embrapa.br/eventos/2010/simposio_agroenergia/palestras/10_terca/Tarde/USA/4%20%20%208-10-2010%20Cold%20Tolerance.pdf.
---------------------------------------------------------------------------

    In the proposed and final RFS rule, EPA analyzed the lifecycle GHG
impacts of producing and using cellulosic ethanol and cellulosic
Fischer-Tropsch diesel from switchgrass. The midpoint of the range of
switchgrass results showed a 110% GHG reduction (range of 102%-117%)
for cellulosic ethanol (biochemical process), a 72% (range of -64% to -
79%) reduction for cellulosic ethanol (thermochemical process), and a
71% (range of -62% to -77%) reduction for cellulosic diesel (F-T
process) compared to the petroleum baseline. In the RFS final rule, we
indicated that some feedstock sources can be determined to be similar
enough to those modeled that the modeled results could reasonably be
extended to these similar feedstock types. For instance, information on
miscanthus indicated that this perennial grass will yield more
feedstock per acre than the modeled switchgrass feedstock without
additional inputs with GHG implications (such as fertilizer). Therefore
in the final rule EPA concluded that since biofuel made from the
cellulosic biomass in switchgrass was found to satisfy the 60% GHG
reduction threshold for cellulosic biofuel, biofuel produced from the
cellulosic biomass in miscanthus would also comply. In the final rule
we included cellulosic biomass from switchgrass and miscanthus as
eligible feedstocks for the cellulosic biofuel pathways included in
Table 1 to Sec.  80.1426.
    We did not include other perennial grasses such as energy cane as
feedstocks for the cellulosic biofuel pathways in Table 1 at that time,
since we did not have sufficient time to adequately consider them.
Based in part on additional information received through the petition
process for EPA approval of the energy cane pathway, EPA has evaluated
energy cane and is now including it as a feedstock in Table 1 to Sec.
80.1426 as approved pathways for cellulosic biofuel pathways.
    As described in detail in the following sections of this preamble,
because of the similarity of energy cane to switchgrass and miscanthus,
and because crop production input emissions (e.g., diesel and pesticide
emissions) are generally a small fraction of the overall lifecycle GHG
emissions (representing approximately 1% of total emissions for
switchgrass), EPA believes that new agricultural sector modeling is not
needed to analyze energy cane. We have instead relied upon the
switchgrass analysis to assess the relative GHG impacts of biofuel
produced from energy cane. As with the switchgrass analysis, we have
attributed all land use impacts and resource inputs from use of these
feedstocks to the portion of the fuel produced that is derived from the
cellulosic components of the feedstocks. Based on this analysis and
currently available information, we conclude that biofuel (ethanol,
cellulosic diesel, jet fuel, heating oil and naphtha) produced from the
cellulosic biomass of energy cane has similar lifecycle GHG impacts to
switchgrass biofuel and meets the 60% GHG reduction threshold required
for cellulosic biofuel.
1. Feedstock Production and Distribution
    For the purposes of this rulemaking, energy cane refers to
varieties of perennial grasses in the Saccharum genus which are
intentionally bred for high cellulosic biomass productivity but have
characteristically low sugar content making them less suitable as a
primary source of sugar as compared to other varieties of grasses
commonly known as ``sugarcane'' in the Saccharum genus. Energy cane
varieties developed to date have low tolerance for cold temperatures
but grow well in warm, humid climates. Energy cane originated from
efforts to improve disease resistance and hardiness of commercial
sugarcane by crossbreeding commercial and wild sugarcane strains.
Certain higher fiber, lower sugar varieties that resulted were not
suitable for commercial sugar production, and are now being developed
as a high-biomass energy crop. There is currently no commercial
production of energy cane. Current plantings are mainly limited to
research field trials and small demonstrations for bioenergy purposes.
However, based in part on discussions with industry, EPA anticipates
continued development of energy cane particularly in the south-central
and southeastern United States due to its high yields in these regions.
a. Crop Yields
    For the purposes of analyzing the GHG emissions from energy cane
production, EPA examined crop yields and production inputs in relation
to switchgrass to assess the relative GHG impacts. Current national
yields for switchgrass are approximately 4.5 to 5 dry tons per acre.
Average energy cane yields exceed switchgrass yields in both
unfertilized and fertilized trails conducted in the southern United
States. Unfertilized yields are around 7.3 dry tons per acre while
fertilized trials show energy cane yields range from approximately 11
to 20 dry tons per acre.46 47 Until recently there have been
few efforts to improve energy cane yields, but several energy cane
development programs are now underway to further increase its biomass
productivity. In general, energy cane will have higher yields than
switchgrass, so from a crop yield perspective, the switchgrass analysis
would be a conservative estimate when comparing against the energy cane
pathway.
---------------------------------------------------------------------------

    \46\ See Bischoff, K.P., Gravois, K.A., Reagan, T.E., Hoy, J.W.,
Kimbeng, C.A., LaBorde, C.M., Hawkins, G.L. Plant Regis. 2008, 2,
211-217.
    \47\ See Hale, A.L. Sugar Bulletin, 2010, 88, 28-29.
---------------------------------------------------------------------------

    Furthermore, EPA's analysis of switchgrass for the RFS rulemaking
assumed a 2% annual increase in yield that would result in an average
national yield of 6.6 dry tons per acre in 2022. EPA anticipates a
similar yield improvement for energy cane due to their similarity as
perennial grasses and their comparable status as energy crops in their
early stages of development. Given this, our analysis assumes an
average energy cane yield of 19 dry tons per acre in the southern
United States by 2022.\48\ The ethanol yield for all of the grasses is
approximately the same so the higher crop yields for energy cane result
directly in greater ethanol production compared to switchgrass per acre
of production.
---------------------------------------------------------------------------

    \48\ These yields assume no significant adverse climate impacts
on world agricultural yields over the analytical timeframe.
---------------------------------------------------------------------------

    Based on these yield assumptions, in areas with suitable growing
conditions, energy cane would require approximately 26% to 47% of the
land area required by switchgrass to produce the same amount of biomass
due to higher yields. Even without yield growth assumptions, the
currently higher crop yield rates means the land use required for
energy cane would be lower than for switchgrass. Therefore less crop
area would be converted and displaced resulting in smaller land-use
change GHG impacts than that assumed for switchgrass to produce the
same amount of fuel. Furthermore, we believe energy cane will have a
similar impact on international markets as assumed for switchgrass.
Like switchgrass, energy cane is not expected to be traded
internationally and its impacts on other crops are expected to be
limited.
b. Land Use
    In EPA's March 2010 RFS analysis, switchgrass plantings displaced
primarily soybeans and wheat, and to a lesser extent hay, rice,
sorghum, and cotton. Energy cane, with production focused in the
southern United States, is

likely to be grown on land once used for pasture, rice, commercial sod,
cotton or alfalfa, which would likely have less of an international
indirect impact than switchgrass because some of those commodities are
not as widely traded as soybeans or wheat. Given that energy cane will
likely displace the least productive land first, EPA concludes that the
land use GHG impact for energy cane per gallon should be no greater and
likely less than estimated for switchgrass.
    Considering the total land potentially impacted by all the new
feedstocks included in this rulemaking would not impact these
conclusions (including the camelina discussed in the previous section
and energy cane considered here). As discussed previously, the camelina
is expected to be grown on fallow land in the Northwest, while energy
cane is expected to be grown mainly in the south on existing cropland
or pastureland. In the switchgrass ethanol scenario done for the
Renewable Fuel Standard final rulemaking, total cropland acres
increases by 4.2 million acres, including an increase of 12.5 million
acres of switchgrass, a decrease of 4.3 million acres of soybeans, a
1.4 million acre decrease of wheat acres, a decrease of 1 million acres
of hay, as well as decreases in a variety of other crops. Given the
higher yields of the energy cane considered here compared to
switchgrass, there would be ample land available for production without
having any adverse impacts beyond what was considered for switchgrass
production. This analysis took into account the economic conditions
such as input costs and commodity prices when evaluating the GHG and
land use change impacts of switchgrass.
    One commenter stated that by assuming no land use change for energy
cane and other feedstocks, the Agency may have underestimated the
increase in GHG emissions that could result from breaking new land.
According to the commenter, EPA assumed that these feedstocks will be
grown on the least productive land without citing any specific models
or studies.
    The commenter appears to have misinterpreted EPA's analysis. EPA
did not assume these crops would be grown on fallow acres, nor did EPA
assume that switchgrass would only be produced on the least productive
lands. EPA assumed these crops would be grown on acres similar to
switchgrass, and therefore applied the land use change impacts of
switchgrass analyzed in the final RFS rule. In the final RFS, EPA
provided detailed information on the types of crops (e.g., wheat) that
would be displaced by dedicated switchgrass. This analysis took into
account the economic conditions such as input costs and commodity
prices when evaluating the GHG and land use change impacts of
switchgrass.\49\
---------------------------------------------------------------------------

    \49\ See Final Regulatory Impact Analysis Chapter 2, February
2010.
---------------------------------------------------------------------------

c. Crop Inputs and Feedstock Transport
    EPA also assessed the GHG impacts associated with planting,
harvesting, and transporting energy cane in comparison to switchgrass.
Table 6 shows the assumed 2022 commercial-scale production inputs for
switchgrass (used in the RFS rulemaking analysis), average energy cane
production inputs (USDA projections and industry data) and the
associated GHG emissions.
    Available data gathered by EPA suggest that energy cane requires on
average less nitrogen, phosphorous, potassium, and pesticide than
switchgrass per dry ton of biomass, but more herbicide, lime, diesel,
and electricity per unit of biomass.
    This assessment assumes production of energy cane uses electricity
for irrigation given that growers will likely irrigate when possible to
improve yields. Irrigation rates will vary depending on the timing and
amount of rainfall, but for the purpose of estimating GHG impacts of
electricity use for irrigation, we assumed a rate similar to what we
assumed for other irrigated crops in the Southwest, South Central, and
Southeast as shown in Table 6.
    Applying the GHG emission factors used in the March 2010 RFS final
rule, energy cane production results in slightly higher GHG emissions
relative to switchgrass production (an increase of approximately 4 kg
CO2eq/mmbtu).

[GRAPHIC] [TIFF OMITTED] TR05MR13.015

    GHG emissions associated with distributing energy cane are expected
to be similar to EPA's estimates for switchgrass feedstock because they
are all herbaceous agricultural crops requiring similar transport,
loading,

unloading, and storage regimes. Our analysis therefore assumes the same
GHG impact for feedstock distribution as we assumed for switchgrass,
although distributing energy cane could be less GHG intensive because
higher yields could translate to shorter overall hauling distances to
storage or biofuel production facilities per gallon or Btu of final
fuel produced.
2. Fuel Production, Distribution, and Use
    Energy cane is suitable for the same conversion processes as other
cellulosic feedstocks, such as switchgrass and corn stover. Currently
available information on energy cane composition shows that
hemicellulose, cellulose, and lignin content are comparable to other
crops that qualify under the RFS regulations as feedstocks for the
production of cellulosic biofuels. Based on this similar composition as
well as conversion yield data provided by industry, we applied the same
production processes that were modeled for switchgrass in the final RFS
rule (biochemical ethanol, thermochemical ethanol, and Fischer-Tropsch
(F-T) diesel \50\) to energy cane. We assumed the GHG emissions
associated with producing biofuels from energy cane are similar to what
we estimated for switchgrass and other cellulosic feedstocks. EPA also
assumes that the distribution and use of biofuel made from energy cane
will not differ significantly from similar biofuel produced from other
cellulosic sources. As was done for the switchgrass case, this analysis
assumes energy grasses grown in the United States for production
purposes. If crops were grown internationally, used for biofuel
production, and the fuel was shipped to the U.S., shipping the finished
fuel to the U.S. could increase transport emissions. However, based on
analysis of the increased transport emissions associated with sugarcane
ethanol distribution to the U.S. considered for the 2010 final rule,
this would at most add 1-2% to the overall lifecycle GHG impacts of the
energy grasses.
---------------------------------------------------------------------------

    \50\ The F-T diesel process modeled applies to cellulosic
diesel, jet fuel, heating oil, and naphtha.
---------------------------------------------------------------------------

3. Summary
    Based on our comparison to switchgrass, EPA believes that
cellulosic biofuel produced from the cellulose, hemicellulose and
lignin portions of energy cane has similar or better lifecycle GHG
impacts than biofuel produced from the cellulosic biomass from
switchgrass. Our analysis suggests that energy cane has GHG impacts
associated with growing and harvesting the feedstock that are similar
to switchgrass. Emissions from growing and harvesting energy cane are
approximately 4 kg CO2eq/mmBtu higher than switchgrass.
These are small changes in the overall lifecycle, representing at most
a 6% change in the energy grass lifecycle impacts in comparison to the
petroleum fuel baseline. Furthermore, energy cane is expected to have
similar or lower GHG emissions than switchgrass associated with other
components of the biofuel lifecycle.
    Under a hypothetical worst case, if the calculated increases in
growing and harvesting the new feedstocks are incorporated into the
lifecycle GHG emissions calculated for switchgrass, and other lifecycle
components are projected as having similar GHG impacts to switchgrass
(including land use change associated with switchgrass production), the
overall lifecycle GHG reductions for biofuel produced from energy cane
still meet the 60% reduction threshold for cellulosic biofuel. We
believe these are conservative estimates, as use of energy cane as a
feedstock is expected to have smaller land-use GHG impacts than
switchgrass, due to higher yields. The docket for this rule provides
additional detail on the analysis of energy cane as a biofuel
feedstock.
    Although this analysis assumes energy cane biofuels produced for
sale and use in the United States will most likely come from
domestically produced feedstock, we also intend for the approved
pathways to cover energy cane from other countries. We do not expect
incidental amounts of biofuels from feedstocks produced in other
nations to impact our assessment that the average GHG emissions
reductions will meet the threshold for qualifying as a cellulosic
biofuel pathway. Moreover, those countries most likely to be exporting
energy cane or biofuels produced from energy cane are likely to be
major producers which typically use similar cultivars and farming
techniques. Therefore, GHG emissions from producing biofuels with
energy cane grown in other countries should be similar to the GHG
emissions we estimated for U.S. energy cane, though they could be
slightly higher or lower. For example, the renewable biomass provisions
under the Energy Independence and Security Act as outlined in the March
2010 RFS final rule regulations, would preclude use of a crop as a
feedstock for renewable fuel if it was gown on land that was a direct
conversion of previously unfarmed land in other countries into cropland
for energy grass-based renewable fuel production. Furthermore, any
energy grass production on existing cropland internationally would not
be expected to have land use impacts beyond what was considered for
switchgrass production. Even if there were unexpected larger
differences, EPA believes the small amounts of feedstock or fuel
potentially coming from other countries will not impact our threshold
analysis.
    Based on our assessment of switchgrass in the March 2010 RFS final
rule and this comparison of GHG emissions from switchgrass and energy
cane, we do not expect variations to be large enough to bring the
overall GHG impact of fuel made from energy cane to come close to the
60% threshold for cellulosic biofuel. Therefore, EPA is including
cellulosic biofuel produced from the cellulose, hemicelluloses and
lignin portions of energy cane under the same pathways for which
cellulosic biomass from switchgrass qualifies under the RFS final rule.

C. Lifecycle Greenhouse Gas Emissions Analysis for Certain Renewable
Gasoline and Renewable Gasoline Blendstocks Pathways

    In this rule, EPA is also adding pathways to Table 1 to Sec.
80.1426 for the production of renewable gasoline and renewable gasoline
blendstock using specified feedstocks, fuel production processes, and
process energy sources. The feedstocks we considered are generally
considered waste feedstocks such as crop residues or cellulosic
components of separated yard waste. These feedstocks have been
identified by the industry as the most likely feedstocks for use in
making renewable gasoline or renewable gasoline blendstock in the near
term due to their availability and low cost. Additionally, these
feedstocks have already been analyzed by EPA as part of the RFS
rulemaking for the production of other fuel types. Consequently, no new
modeling is required and we rely on earlier assessments of feedstock
production and distribution for assessing the likely lifecycle impact
on renewable gasoline and renewable gasoline blendstock. We have also
relied on the petroleum gasoline baseline assessment from the March
2010 RFS rule for estimating the fuel distribution and use GHG
emissions impacts for renewable gasoline and renewable gasoline
blendstock. Consequently, the only new analysis required is of the
technologies for turning the feedstock into renewable gasoline and
renewable gasoline blendstock.

1. Feedstock Production and Distribution
    EPA has evaluated renewable gasoline and renewable gasoline
blendstock pathways that utilize cellulosic feedstocks currently
included in Table 1 to Sec.  80.1426 of the regulations. The following
feedstocks were evaluated:
     Cellulosic biomass from crop residue, slash, pre-
commercial thinnings and tree residue, annual cover crops;
     Cellulosic components of separated yard waste;
     Cellulosic components of separated food waste; and
     Cellulosic components of separated MSW
    The FASOM and FAPRI models were used to analyze the GHG impacts of
the feedstock production portion of a fuel's lifecycle. In the March
2010 RFS rulemaking, FASOM and FAPRI modeling was performed to analyze
the emissions impact of using corn stover as a biofuel feedstock and
this modeling was extended to some additional feedstock sources
considered similar to corn stover. This approach was used for crop
residues, slash, pre-commercial thinnings, tree residue and cellulosic
components of separated yard, food, and MSW. These feedstocks are all
excess materials and thus, like corn stover, were determined to have
little or no land use change GHG impacts. Their GHG emission impacts
are mainly associated with collection, transport, and processing into
biofuel. See the RFS rulemaking preamble for further discussion. We
used the results of the corn stover modeling in this analysis to
estimate the upper bound of agricultural sector impacts from the
production of the various cellulosic feedstocks noted above.
    The agriculture sector modeling results for corn stover represents
all of the direct and significant indirect emissions in the agriculture
sector (feedstock production emissions) for a certain quantity of corn
stover produced. For the March 2010 RFS rulemaking, this was roughly 62
million dry tons of corn stover to produce 5.7 billion gallons of
ethanol assuming biochemical fermentation to ethanol processing. We
have calculated GHG emissions from feedstock production for that amount
of corn stover. The GHG emissions were then divided by the total
heating value of the fuel to get feedstock production emissions per
mmBtu of fuel. In addition to the biochemical ethanol process, a
similar analysis was completed for thermochemical ethanol and F-T
diesel pathways as part of the RFS rulemaking.
    In this rulemaking we are analyzing renewable gasoline and
renewable gasoline blendstock produced from corn stover (and, by
extension, other waste feedstocks). The number of gallons of fuel
produced from a ton of corn stover (modeled process yields) is specific
to the process used to produce renewable fuel. EPA has adjusted the
results of the earlier corn stover modeling to reflect the different
process yields and heating value of renewable gasoline or renewable
gasoline blendstock product. The results of this calculation are shown
below in Table 7.
    We based our process yields and heating values for renewable
gasoline and renewable gasoline blendstock on several process
technologies representative of technologies anticipated to be used in
producing these fuels. As discussed later in this section, there are
four main types of fuel production technologies available for producing
renewable gasoline. These four processes can be characterized as (1)
thermochemical gasification, (2) catalytic pyrolysis and upgrading to
renewable gasoline or renewable gasoline blendstock (``catalytic
pyrolysis and upgrading''), (3) biochemical fermentation with upgrading
to renewable gasoline or renewable gasoline blendstock via carboxylic
acid (``fermentation and upgrading''), and (4) direct biochemical
fermentation to renewable gasoline and renewable gasoline blendstock
(``direct fermentation''). The thermochemical gasification process was
modeled as part of the March 2010 RFS final rule, included as producing
naptha via the F-T process. Our analysis of the catalytic pyrolysis
process was based on the modeling work completed by the National
Renewable Energy Laboratory (NREL) for this rule for a process to make
renewable gasoline blendstock.\51\ The fermentation and upgrading
process was modeled based on confidential business information (CBI)
from industry for a unique process which uses biochemical conversion of
cellulose to renewable gasoline via a carboxylic acid route. In
addition, we have qualitatively assessed the direct fermentation to
renewable gasoline process based on similarities to the biochemical
ethanol process already analyzed as part of the March 2010 RFS
rulemaking. The fuel production section below provides further
discussion on extending the GHG emissions results of the biochemical
ethanol fermentation process to a biochemical renewable gasoline or
renewable gasoline blendstock fermentation process. In some cases, the
available data sources included process yields for renewable gasoline
or renewable gasoline blendstock produced from wood chips rather than
corn stover which was specifically modeled as a feedstock in the RFS
final rule. We believe that the process yields are not significantly
impacted by the source of cellulosic material whether the cellulosic
material comes from residue such as corn stover or wood material such
as from tree residues. We made the simplifying assumption that one dry
ton of wood feedstock produces the same volume of renewable gasoline or
renewable gasoline blendstock as one dry ton of corn stover. We believe
this is reasonable considering that the RFS rulemaking analyses for
biochemical ethanol and thermochemical F-T diesel processes showed
limited variation in process yields between different feedstocks for a
given process technology.\52\ In addition, since the renewable gasoline
and renewable gasoline blendstock pathways include feedstocks that were
already considered as part of the RFS2 final rule, the existing
feedstock lifecycle GHG impacts for distribution of corn stover were
also applied to this analysis.\53\
---------------------------------------------------------------------------

    \51\ Kinchin, Christopher. Catalytic Fast Pyrolysis with
Upgrading to Gasoline and Diesel Blendstocks. National Renewable
Energy Laboratory (NREL). 2011.
    \52\ Aden, Andy. Feedstock Considerations and Impacts on
Biorefining. National Renewable Energy Laboratory (NREL). December
2009. The report indicates that woody biomass feedstocks generally
have higher yields than crop residues or herbaceous grasses (~6%
higher yields). However the same lower yield was assumed for all as
a conservatively low estimate.
    \53\ Results for feedstock distribution are aggregated along
with fuel distribution and are reported in a later section, see
conclusion section.
---------------------------------------------------------------------------

    Feedstock production emissions are shown in Table 7 below for corn
stover. Corn stover feedstock production emissions are mainly a result
of corn stover removal increasing the profitability of corn production
(resulting in shifts in cropland and thus slight emission impacts) and
also the need for additional fertilizer inputs to replace the nutrients
lost when corn stover is removed. However, corn stover removal also has
an emissions benefit as it encourages the use of no-till farming which
results in the lowering of domestic land use change emissions. This
change to no-till farming results in a negative value for domestic land
use change emission impacts (see also Table 13 below). For other waste
feedstocks (e.g., tree residues and cellulosic components of separate
yard, food, and MSW), the feedstock production emissions are even lower
than the values shown for corn stover since the

use of such feedstocks does not require land use changes or additional
agricultural inputs. Therefore, we conclude that if the use of corn
stover as a feedstock in the production of renewable gasoline and
renewable gasoline blendstock yields lifecycle GHG emissions results
for the resulting fuel that qualify it as cellulosic biofuel (i.e., it
has at least a 60% lifecycle GHG reduction as compared to conventional
fuel), then the use of other waste feedstocks with little or no land
use change emissions will also result in renewable gasoline or
renewable gasoline blendstock that qualifies as cellulosic biofuel.
    One commenter stated that the Agency assumed that using the corn
stover for biofuels production would result in additional no-till
farming without any evidence that the stover would actually be removed
from no-tilled acres. This commenter feels that with recent increased
profitability from corn production, farmers may actually increase
tillage to reap high corn prices. This commenter urged the EPA to
consider changes to soil carbon from the removal of corn stover as they
may have an impact on the GHG score of this new biofuel pathway. This
commenter further urged the Agency to not simply assume that additional
no-till practices will be adopted with residue extraction.
    The analysis the EPA conducted to evaluate the GHG impacts
associated with corn stover removal as part of the March 2010 RFS final
rule did not assume that the corn stover had to be removed from no-till
corn production. The models used to evaluate the impacts of stover
removal included the option for farmers to switch to no-till practices
and therefore have the option for more stover removal. As the demand
for stover increased in the case where stover is used for biofuel
production, the relative costs associated with no-till factored in the
impact of lost corn yield as well as higher yield for corn stover. The
model optimized the rate of returns for the farmers such that no-till
practices were applied until the increased returns for greater stover
removal on no-till acres were balanced by lost profits from lower corn
yields. Therefore, the comment that we assumed stover had to come from
no-till acres or that the economics would drive more intensive tillage
practices is not accurate, as described in more detail in the March
2010 RFS final rule.
    Furthermore, there is an annual soil carbon penalty applied to
crops with residue removal in our models. Thus, as one shifts from
conventional corn to residue corn, an annual soil carbon penalty factor
is applied. If residue removal is combined with switching to
conservation tillage or no-till, then the net soil C effect would be
the sum of the till change effect and the ``crop change'' effect.
    For the March 2010 RFS rulemaking, EPA conducted an in-depth
literature review of corn stover removal practices and consulted with
numerous experts in the field. In the FRM, EPA recognized that
sustainable stover removal practices vary significantly based on local
differences in soil and erosion conditions, soil type, landscape
(slope), tillage practices, crop rotation managements, and the use of
cover crops. EPA, in consultation with USDA, based its impacts on corn
stover from reduced till and no till acres based on agronomical
practices, nutrient requirements, and erosion considerations. EPA does
not believe that the commentor has provided new information that would
substantially change our analysis of the GHG emissions associated with
corn stover. However, EPA will continue to monitor actual practices and
based on new data will consider reviewing and revising the methodology
and assumptions associated with calculating the GHG emissions from all
renewable fuel feedstocks.

 Table 7--Feedstock Production Emissions for Renewable Gasoline and Renewable Gasoline Blendstock Pathways Using
                                                   Corn Stover
----------------------------------------------------------------------------------------------------------------
                                                                      Biochemical
                                       Catalytic pyrolysis and      fermentation and        Direct biochemical
                                        upgrading to renewable   upgrading to renewable  fermentation process to
    Feedstock production  emission      gasoline and renewable   gasoline and renewable   renewable gasoline and
               sources                 gasoline blendstock  (g  gasoline blendstock via     renewable gasoline
                                            CO2-eq./mmBtu)      carboxylic acid (g CO2-   blendstock (g CO2-eq./
                                                                       eq./mmBtu)                 mmBtu)
----------------------------------------------------------------------------------------------------------------
Domestic Livestock...................                    7,648                    6,770                  ~ 9,086
Domestic Farm Inputs and Fertilizer                      1,397                    1,237                  ~ 1,660
 N2O.................................
Domestic Rice Methane................                      366                      324                    ~ 434
Domestic Land Use Change.............                   -9,124                   -8,076                 ~-10,820
International Livestock..............                        0                        0                        0
International Farm Inputs and                                0                        0                        0
 Fertilizer N2O......................
International Rice Methane...........                        0                        0                        0
International Land Use Change........                        0                        0                        0
                                      --------------------------------------------------------------------------
    Total Feedstock Production                             287                      254                    ~ 361
     Emissions:......................
Assumed yield (gal/ton of biomass)...                     64.5                       75                     92.3
----------------------------------------------------------------------------------------------------------------

    The results in Table 7 differ for the different pathways considered
because of the different amounts of corn stover used to produce the
same amount of fuel in each case. Table 7 only considers the feedstock
production impacts associated with the renewable gasoline or renewable
gasoline blendstocks pathways, other aspects of the lifecycle are
discussed in the following sections.
2. Fuel Distribution
    A petroleum gasoline baseline was developed as part of the RFS
final rule which included estimates for fuel distribution emissions.
Since renewable gasoline and renewable gasoline blendstocks when
blended into gasoline are similar to petroleum gasoline, it is
reasonable to assume similar fuel distribution emissions. Therefore,
the existing fuel distribution lifecycle GHG impacts of the petroleum
gasoline baseline from the RFS final rule were applied to this
analysis.
3. Use of the Fuel
    A petroleum gasoline baseline was developed as part of the RFS
final rule which estimated the tailpipe emissions from fuel combustion.
Since renewable gasoline and renewable gasoline blendstock are similar
to petroleum gasoline in energy and hydrocarbon

content, the non-CO2 combustion emissions calculated as part
of the RFS final rule for petroleum gasoline were applied to our
analysis of the renewable gasoline and renewable gasoline blendstock
pathways. Only non-CO2 emissions were included since carbon
fluxes from land use change are accounted for as part of the biomass
feedstock production.
4. Fuel Production
    In the March 2010 RFS rulemaking, EPA analyzed several of the main
cellulosic biofuel pathways: a biochemical fermentation process to
ethanol and two thermochemical gasification processes, one producing
mixed alcohols (primarily ethanol) and the other one producing mixed
hydrocarbons (primarily diesel fuel). These pathways all exceeded the
60% lifecycle GHG threshold requirements for cellulosic biofuel using
the specified feedstocks. Refer to the preamble and regulatory impact
analysis (RIA) from the final rule for more details. From these
analyses, it was determined that ethanol and diesel fuel produced from
the specified cellulosic feedstocks and processes would be eligible for
cellulosic and advanced biofuel RINs.
    The thermochemical gasification process to diesel fuel (via F-T
synthesis) also produces a smaller portion of renewable gasoline
blendstock. In the final rule, naphtha produced with specified
cellulosic feedstocks by a F-T process was included as exceeding the
60% lifecycle GHG threshold, with an applicable D-Code of 3, in Table 1
to Sec.  80.1426. In this rule, we are changing the reference to F-T as
the process technology to the more correct reference as gasification
technology since F-T reactions are only part of the process technology.
    Since the final March 2010 RFS rule was released, EPA has received
several petitions and inquiries that suggest that renewable gasoline or
renewable gasoline blendstock produced using processes other than the
F-T process could also qualify for a similar D-Code of 3.\54\ For the
reasons described below, we have decided to authorize the generation of
RINs with a D code of 3 for renewable gasoline and renewable gasoline
blendstock produced using specified cellulosic feedstocks for the
processes considered here.
---------------------------------------------------------------------------

    \54\ See http://www.epa.gov/otaq/fuels/renewablefuels/compliancehelp/rfs2-lca-pathways.htm for list of petitions received
by EPA.
---------------------------------------------------------------------------

    Several routes have been identified as available for the production
of renewable gasoline and renewable gasoline blendstock from renewable
biomass. These include catalytic pyrolysis and upgrading to renewable
gasoline or renewable gasoline blendstock (``catalytic pyrolysis and
upgrading''), biochemical fermentation with upgrading to renewable
gasoline or renewable gasoline blendstock via carboxylic acid
(``fermentation and upgrading''), and direct biochemical fermentation
to renewable gasoline and renewable gasoline blendstock (``direct
fermentation'') and other thermo-catalytic hydrodeoxygenation routes
with upgrading such as aqueous phase processing.55 56
---------------------------------------------------------------------------

    \55\ Regalbuto, John. ``An NSF perspective on next generation
hydrocarbon biorefineries,'' Computers and Chemical Engineering 34
(2010) 1393-1396. February 2010.
    \56\ Serrano-Ruiz, J., Dumesic, James. ``Catalytic routes for
the conversion of biomass into liquid hydrocarbon transportation
fuels,'' Energy Environmental Science (2011) 4, 83-99.
---------------------------------------------------------------------------

    Similar to how we analyzed several of the main routes for
cellulosic ethanol and cellulosic diesel for the final March 2010 RFS
rule, we have chosen to analyze the main renewable gasoline and
renewable gasoline blendstock pathways in order to estimate the
potential GHG reduction profile for renewable gasoline and renewable
gasoline blendstock across a range of other production technologies for
which we are confident will have at least as great of GHG emission
reductions as those specifically analyzed.
a. Catalytic Pyrolysis With Upgrading to Renewable Gasoline and
Renewable Gasoline Blendstock
    The first production process we investigated for this rule is a
catalytic fast pyrolysis route to bio-oils with upgrading to a
renewable gasoline or a renewable gasoline blendstock. We utilized
process modeling results from the National Renewable Energy Laboratory
(NREL). Information provided by industry and claimed as CBI are based
on similar processing methods and suggest similar results than those
reported by NREL. Details on the NREL modeling are described further in
a technical report available through the docket.\57\ Catalytic
pyrolysis involves the rapid heating of biomass to about 500[deg]C at
slightly above atmospheric pressure. The rapid heating thermally
decomposes biomass, converting it into pyrolysis vapor, which is
condensed into a liquid bio-oil. The liquid bio-oil can then be
upgraded using conventional hydroprocessing technology and further
separated into renewable gasoline, renewable gasoline blendstock and
renewable diesel streams (cellulosic diesel from catalytic pyrolysis is
already included as an acceptable pathway in the RFS program). Some
industry sources also expect to produce smaller fractions of heating
oil in addition to gasoline and diesel blendstocks. Excess electricity
from the process is also accounted for in our modeling as a co-product
credit in which any excess displaces U.S. average grid electricity.
Excess electricity is generated from the use of co-product coke/char
and product gases and is available because internal electricity demands
are fully met. The estimated energy inputs and electricity credits
shown in Table 8, below, utilize the data provided by the NREL process
modeling. However, industry sources also identified potential areas for
improvements in energy use, such as the use of biogas fired dryers
instead of natural gas fired dryers for drying incoming wet feedstocks
and increased turbine efficiencies for electricity production which may
result in lower energy consumption than estimated by NREL and thus
improve GHG performance compared to our estimates here.
---------------------------------------------------------------------------

    \57\ Kinchin, Christopher. Catalytic Fast Pyrolysis with
Upgrading to Gasoline and Diesel Blendstocks. National Renewable
Energy Laboratory (NREL). 2011.

                            Table 8--2022 Energy Use at Cellulosic Biofuel Facilities
                                                    [Btu/gal]
----------------------------------------------------------------------------------------------------------------
                                                                                Purchased           Sold
                 Technology                     Biomass use    Natural gas use    electricity      electricity
----------------------------------------------------------------------------------------------------------------
Catalytic Pyrolysis to Renewable Gasoline or         136,000           51,000                0           -2,000
 Renewable Gasoline Blendstock..............
----------------------------------------------------------------------------------------------------------------

    The emissions from energy inputs were calculated by multiplying the
amount of energy by emission factors for fuel production and
combustion, based on the same method and factors used in the March 2010
RFS final rulemaking. The emission factors for the different fuel types
are from GREET and were based on assumed carbon contents of the
different process fuels. The emissions from producing electricity in
the U.S. were also taken from GREET and represent average U.S. grid
electricity production emissions.
    The major factors influencing the emissions from the fuel
production stage of the catalytic pyrolysis pathway are the use of
natural gas (mainly due to hydrogen production for hydroprocessing) and
the co-products available for additional heat and power generation.\58\
See Table 9 for a summary of emissions from fuel production.
---------------------------------------------------------------------------

    \58\ A steam methane reformer (SMR) is used to produce the
hydrogen necessary for hydroprocessing. In the U.S. over 95% of
hydrogen is currently produced via steam reforming (DOE, 2002 ``A
National Vision of America's Transition to a Hydrogen Economy to
2030 and Beyond''). Other alternatives are available, such as
renewable or nuclear resources used to extract hydrogen from water
or the use of biomass to produces hydrogen. These alternative
methods, however, are currently not as efficient or cost effective
as the use of fossil fuels and therefore we conservatively estimate
emissions from hydrogen production using the more commonly used SMR
technology.

Table 9--Fuel Production Emissions for Catalytic Pyrolysis and Upgrading
to Renewable Gasoline or Renewable Gasoline Blendstock Using Corn Stover
------------------------------------------------------------------------
                                                  Catalytic pyrolysis to
                                                  renewable gasoline or
                Lifecycle stage                     renewable gasoline
                                                  blendstock (g CO2-eq./
                                                          mmBtu)
------------------------------------------------------------------------
On-Site & Upstream Emissions (Natural Gas &                       31,000
 Biomass*).....................................
Electricity Co-Product Credit..................                   -3,000
                                                ------------------------
    Total Fuel Production Emissions:...........                   28,000
------------------------------------------------------------------------
* Only non-CO2 combustion emissions from biomass

    b. Catalytic Upgrading of Biochemically Derived Intermediates to
Renewable Gasoline and Renewable Gasoline Blendstock
    The second production process we investigated is a biochemical
fermentation process to intermediate, such as carboxylic acids with
catalytic upgrading to renewable gasoline or renewable gasoline
blendstock. This process involves the fermentation of biomass using
microorganisms that produce a variety of carboxylic acids. If the
feedstock has high lignin content, then the biomass is pretreated to
enhance digestibility. The acids are then neutralized to carboxylate
salts and further converted to ketones and alcohols for refining into
gasoline, diesel, and jet fuel.
    The process requires the use of natural gas and hydrogen
inputs.\59\ No purchased electricity is required as lignin is projected
to be used to meet all facility demands as well as provide excess
electricity to the grid. EPA used the estimated energy and material