[Federal Register Volume 77, Number 3 (Thursday, January 5, 2012)]
[Rules and Regulations]
[Pages 700-727]
[FR Doc No: 2011-31580]

Vol. 77

Thursday,

No. 3

January 5, 2012

Part V

 Environmental Protection Agency

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40 CFR Part 80

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

Federal Register / Vol. 77 , No. 3 / Thursday, January 5, 2012 /
Rules and Regulations

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ENVIRONMENTAL PROTECTION AGENCY

40 CFR Part 80

[EPA-HQ-OAR-2011-0542; FRL-9502-2]
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: Direct final rule.

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SUMMARY: EPA is issuing a direct 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 Program, as amended by the Energy Independence
and Security Act of 2007 (EISA). This direct final rule describes EPA's
evaluation of biofuels produced from camelina oil, energy cane, giant
reed, and napiergrass; it also includes an evaluation of renewable
gasoline and renewable gasoline blendstocks, as well as biodiesel from
esterification, and clarifies our definition of renewable diesel. We
are also finalizing two changes to regulation 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.
    This direct final rule adds these pathways to Table in regulation
as pathways which have been determined to meet one or more of the GHG
reduction thresholds specified in CAA 211(o), and assigns each pathway
a corresponding D-Code. It allows producers or importers of fuel
produced pursuant to these pathways to generate Renewable
Identification Numbers (RINs), providing that the fuel meets the other
requirements specified in the RFS regulations to qualify it as
renewable fuel.

DATES: This rule is effective on March 5, 2012 without further notice,
unless EPA receives adverse comment or a hearing request by February 6,
2012. If EPA receives a timely adverse comment or a hearing request, we
will publish a withdrawal in the Federal Register informing the public
that the portions of the rule with adverse comment will not take
effect.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2011-0542, by one of the following methods:
     www.regulations.gov: Follow the on-line instructions for
submitting comments.
     Email<EMAIL_ADDRESS>Attention Air and Radiation
Docket ID EPA-HQ-OAR-2011-0542
     Fax: [Insert fax number].
     Mail: Air and Radiation Docket, Docket No. EPA-HQ-OAR-
2011-0542, Environmental Protection Agency, Mailcode: 6406J, 1200
Pennsylvania Ave. NW., Washington, DC 20460.
     Hand Delivery: EPA Docket Center, EPA/DC, EPA West, Room
3334, 1301 Constitution Ave. NW., Washington, DC, 20460, Attention Air
and Radiation Docket, ID No. EPA-HQ-OAR-2011-0542. Such deliveries are
only accepted during the Docket's normal hours of operation, and
special arrangements should be made for deliveries of boxed
information.
    Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-
2011-0542. EPA's policy is that all comments received will be included
in the public docket without change and may be made available online at
www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through www.regulations.gov or email. The
www.regulations.gov Web site is an ``anonymous access'' system, which
means EPA will not know your identity or contact information unless you
provide it in the body of your comment. If you send an email comment
directly to EPA without going through www.regulations.gov your email
address will be automatically captured and included as part of the
comment that is placed in the public docket and made available on the
Internet. If you submit an electronic comment, EPA recommends that you
include your name and other contact information in the body of your
comment and with any disk or CD-ROM you submit. If EPA cannot read your
comment due to technical difficulties and cannot contact you for
clarification, EPA may not be able to consider your comment. Electronic
files should avoid the use of special characters, any form of
encryption, and be free of any defects or viruses. For additional
information about EPA's public docket visit the EPA Docket Center
homepage at http://www.epa.gov/epahome/dockets.htm.
    Docket: All documents in the docket are listed in the
www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., CBI or other information
whose disclosure is restricted by statute. Certain other material, such
as copyrighted material, will be publicly available only in hard copy.
Publicly available docket materials are available either electronically
in www.regulations.gov or in hard copy at the Air and Radiation Docket
and Information Center, EPA/DC, EPA West, Room 3334, 1301 Constitution
Ave. NW., Washington, DC. The Public Reading Room is open from 8:30
a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The
telephone number for the Public Reading Room is<PHONE_NUMBER>, and the
telephone number for the Air Docket is<PHONE_NUMBER>).

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:

I. Why is EPA using a direct final rule?

    EPA is publishing this rule without a prior proposed rule because
we view this as a noncontroversial action. These new pathway
determinations did not require new agricultural sector modeling and
involved relatively straightforward analyses that largely relied upon
work done for the RFS2 final rule. If EPA receives relevant adverse
comment or a hearing request on a distinct provision of this
rulemaking, we will publish a timely withdrawal in the Federal Register
indicating which portion of the rule is being withdrawn. Any distinct
amendment, paragraph, or section of today's rule not withdrawn will
become effective on the date set out above.
    In the ``Proposed Rules'' section of today's Federal Register, we
are publishing a separate document that will serve as the proposed rule
to update Table 1 of Sec.  80.1426 to add any additional renewable fuel
production pathways or regulatory provisions which may be withdrawn
from the direct final rule. We will not institute a second comment
period on this action. Any parties interested in commenting must do so
at this time. For further information about commenting on this rule,
see the ADDRESSES section of this document. We will address all public

comments in any subsequent final rule based on the proposed rule.

II. 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:

------------------------------------------------------------------------
                                                          Examples of
                                 NAICS \1\   SIC \2\      potentially
            Category               Codes      Codes        regulated
                                                            entities
------------------------------------------------------------------------
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.
------------------------------------------------------------------------
\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.

III. What should I consider as I prepare my comments for EPA?

    A. Submitting information claimed as CBI. Do not submit information
you claim as CBI to EPA through www.regulations.gov or email. Clearly
mark the part or all of the information that you claim to be CBI. For
CBI information in a disk or CD ROM that you mail to EPA, mark the
outside of the disk or CD ROM as CBI and then identify electronically
within the disk or CD ROM the specific information that is claimed as
CBI). In addition to one complete version of the comment that includes
information claimed as CBI, a copy of the comment that does not contain
the information claimed as CBI must be submitted for inclusion in the
public docket. Information so marked will not be disclosed except in
accordance with procedures set forth in 40 CFR part 2.
    B. Tips for Preparing Your Comments. When submitting comments,
remember to:
     Identify the rulemaking by docket number and other
identifying information (subject heading, Federal Register date and
page number).
     Follow directions--The agency may ask you to respond to
specific questions or organize comments by referencing a Code of
Federal Regulations (CFR) part or section number.
     Explain why you agree or disagree; suggest alternatives
and substitute language for your requested changes.
     Describe any assumptions and provide any technical
information and/or data that you used.
     If you estimate potential costs or burdens, explain how
you arrived at your estimate in sufficient detail to allow for it to be
reproduced.
     Provide specific examples to illustrate your concerns, and
suggest alternatives.
     Explain your views as clearly as possible, avoiding the
use of profanity or personal threats.
     Make sure to submit your comments by the comment period
deadline identified.
    C. Docket Copying Costs. You may be charged a reasonable fee for
photocopying docket materials, as provided in 40 CFR part 2.

IV. Identification of additional qualifying renewable fuel pathways
under the renewable fuel standard (RFS) program

    EPA is issuing a direct 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. This direct final rule describes EPA's evaluation of:

Camelina Oil (New Feedstock)

     Biodiesel and renewable diesel (including jet fuel and
heating oil) -- qualifying as biomass-based diesel and advanced biofuel
     Naphtha and liquefied petroleum gas (LPG) -- qualifying as
advanced biofuel

Energy Cane, Giant Reed, and Napiergrass Cellulosic Biomass (New
Feedstocks)

     Ethanol, renewable diesel (including renewable jet fuel
and heating oil), and naphtha -- qualifying as cellulosic biofuel

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 as cellulosic biofuel:
    [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

Esterification (New Production Process)

     Process used to produce biodiesel from soy bean oil, oil
from annual covercrops, algal oil, biogenic waste oils/fats/greases,
non-food grade corn oil, Canola/rapeseed oil, and camelina oil--
qualifying as biomass-based diesel and advanced biofuel
    This direct final rule adds these pathways to Table 1 to Sec.
80.1426 and assigns each pathway one or more D-Codes. This final rule
allows producers or importers of fuel produced under these pathways to
generate Renewable Identification Numbers (RINs) in accordance with the
RFS regulations, providing that the fuel meets other definitional
criteria for renewable fuel.
    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 (RFS2) Final Rule, published March
26, 2010. The evaluations here rely on comparisons to the existing
analysis. 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, Naphtha, and Liquefied Petroleum Gas (LPG)
Produced From Camelina Oil

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/publica[not]tions/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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    Camelina is currently being grown on approximately 50,000 acres of
land in the U.S., primarily in Montana, eastern Washington, and the
Dakotas.\8\ 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.\9\
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    \8\ McCormick, Margaret. ``Oral Comments of Targeted Growth,
Incorporated'' Submitted to the EPA on June 9, 2009.
    \9\ See https://www.camelinacompany.com/Marketing/PressRelease.aspx?Id=25.
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    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 during the
camelina planting. Since substituting fallow land with camelina
production would not typically displace another crop, 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 commodity 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 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.
a. Growing Practices
    Current market conditions indicate that camelina will most likely
be grown in rotation with wheat on dryland wheat acres replacing a
period that they would otherwise be left fallow.\10\ In areas with
lower precipitation, dryland wheat farmers currently leave acres fallow
once every three to four years to allow additional moisture and
nutrients to accumulate and to control pests. Current research
indicates that camelina could be introduced into this rotation in
certain areas without adversely impacting moisture or nutrient
accumulation (see Figure 1). Because camelina has shallow roots with
drought resistant characteristics, the

land can be returned to wheat cultivation the following year with
moisture and soil nutrients intact quantitatively similar to a fallow
year.\11\ In addition, camelina uses the same equipment for harvesting
as wheat; therefore, farmers would not need to invest in new equipment
to add camelina to the rotation with wheat.\12\
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    \10\ 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.
    \11\ See Shonnard et al., 2010; Lafferty et al., 2009.
    \12\ Wheeler, P and F. Guillen-Portal. 2007. Camelina Production
in Montana: A survey study sponsored by Targeted Growth, Inc. and
Barkley Ag. Enterprises, LLP (unpublished).
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BILLING CODE 6560-50-P

[GRAPHIC] [TIFF OMITTED] TR05JA12.006

BILLING CODE 6560-50-C

b. Land Availability
    USDA estimates that there are approximately 60 million acres of
wheat in the U.S.\13\ USDA and wheat state cooperative extension
reports through 2008 indicate that 83% of U.S. 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.\14\ Therefore, our analysis uses the estimate that
only 9 million wheat/fallow acres are available for camelina
production.
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    \13\ 2009 USDA Baseline. See http://www.ers.usda.gov/publications/oce091/.
    \14\ 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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c. 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.\15\ This
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. 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.\16\ 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,\17\ 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.\18\ 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.\19\
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    \15\ Wheeler, P. and Guillen-Portal F. 2007. Camelina Production
in Montana: A survey study sponsored by Targeted Growth, Inc. and
Barkley Ag. Enterprises, LLP.
    \16\ 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.
    \17\ 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.
    \18\ See Shonnard et al., 2010.
    \19\ This assumes no significant adverse climate impacts on
world agricultural yields over the analytical timeframe.
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d. 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.\20\ 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.\21\ See Table 1. For comparison purposes, the USDA projections
for wheat returns are between $88-$105 per acre between 2010 and 2020.
Over time, advancements in seed technology, improvements in planting
and harvesting techniques, and higher input usage could significantly
increase future camelina yields and returns.
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    \20\ See Lafferty et al., 2009; Shonnard et al., 2010;
Sustainable Oils Memo dated November 5, 2010,
    \21\ Wheeler & Guillen-Portal, 2007.
    \22\ See Sustainable Oils Memo dated November 5, 2010,
    \23\ Based on yields technically feasible. See McVey and Lamb,
2008; Ehrenson & Guy, 2008.
    \24\ Adapted from Shonnard et al, 2010.

                                       Table 1--Camelina Costs and Returns
----------------------------------------------------------------------------------------------------------------
             Inputs                      Rates        2010 Camelina \22\  2022 Camelina \23\  2030 Camelina \24\
----------------------------------------------------------------------------------------------------------------
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.\25\ 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.\26\ Therefore, camelina
grown outside of a wheat fallow situation was not considered as part of
this analysis.
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    \25\ 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.
    \26\ Wright & Marois, 2011.
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    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 U.S. 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.
e. 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.
[GRAPHIC] [TIFF OMITTED] TR05JA12.007

    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
impact is 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.
f. 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 RFS2
final rule, based on a process model developed by USDA-ARS.\27\ The
data on camelina crushing is from Shonnard et al. (2010).
---------------------------------------------------------------------------

    \27\ 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. Based on this, 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
equivalent to the glycerin produced from the existing biodiesel
pathways (e.g., based on soy oil) that were analyzed as part of the
RFS2 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 RFS2 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, stating 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 RFS2 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 will
likely range from fairly high reduction credits when 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 RFS2 rule) on which to allocate glycerin use
across the range of likely uses. Therefore, EPA believes that the
approach used in RFS2 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 benefit associated
with glycerin production.
    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 change 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
RFS2 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.\28\ 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.
---------------------------------------------------------------------------

    \28\ 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 RFS2 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.\29\ 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.
---------------------------------------------------------------------------

    \29\ 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,\30\ Stratton et al., 2010, Huo et al., 2008).\31\ 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.\32\ This data
is summarized in Table 4.
---------------------------------------------------------------------------

    \30\ Pearlson, M., N. 2011. A Techno-Economic and Environmental
Assessment of Hydroprocessed Renewable Distillate Fuels.
    \31\ 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.
    \32\ 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.
    \33\ 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\33\
----------------------------------------------------------------------------------------------------------------
                                            Maximized for
                                             diesel fuel     Maximized for jet      Units (per gallon of fuel
                                              production      fuel 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.

                                          Table 5--Fuel Production Lifecycle GHG Emissions (kgCO2e/mmBtu) \34\
--------------------------------------------------------------------------------------------------------------------------------------------------------
                                                              RIN-Generating
             Feedstock                Production process         products          Other co-products    Oil 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          Jet Fuel............  Propane.............                4               11               14
                                     Maximized for Jet     Diesel..............
                                     Fuel.                 Naphtha.............
                                                           LPG.
--------------------------------------------------------------------------------------------------------------------------------------------------------

    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.
---------------------------------------------------------------------------

    \34\ 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.
---------------------------------------------------------------------------

    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 naphtha
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 has limited niche
markets and 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. 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 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 RFS2 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.\35\ As was discussed previously, if the
displacement approach is used when jet fuel is the primary product
produced it results in lower emissions then 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.
---------------------------------------------------------------------------

    \35\ The exception is naphtha 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 RFS2 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, Giant Reed,
and Napiergrass

    For this rulemaking, EPA considered the lifecycle GHG impacts of
three new types of high-yielding perennial grasses similar in
cellulosic composition to switchgrass and comparable in status as an
emerging energy crop. Energy cane (related to sugarcane), giant reed
(Arundo donax), and napiergrass (pennisetum purpureum), also known as
elephant grass. In the proposed and final RFS2 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 RFS2
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 form 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,
giant reed, or napiergrass 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 energy cane,
giant reed, and napiergrass pathways, EPA has evaluated these
feedstocks and is now including the cellulose, hemicelluloses and
lignin portions of renewable biomass from energy cane, giant reed, and
napiergrass in Table 1 to Sec.  80.1426 as approved feedstocks for
cellulosic biofuel pathways.
    As described in detail in the following sections of this preamble,
because of the similarity of these feedstocks to switchgrass and
miscanthus, EPA believes that new agricultural sector modeling is not
needed to analyze them. We have instead relied upon the switchgrass
analysis to assess the relative GHG impacts of biofuel produced from
energy cane, giant reed, and napiergrass. 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 naptha)
produced from the cellulosic biomass of energy cane, giant reed, or
napiergrass 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 unsuitable 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.
    Giant reed refers to the perennial grass Arundo donax of the
Gramineae family. Giant reed thrives in subtropical and warm-temperate
areas and is grown throughout Asia, southern Europe, Africa, the Middle
East, and warmer U.S. states for multiple uses such as paper and pulp,
musical instruments, rayon, particle boards, erosion control, and
ornamental purposes.36 37 Based in

part on discussions with industry, EPA anticipates continued
development of giant reed as an energy crop particularly in the
Mediterranean region and warmer U.S. states.
---------------------------------------------------------------------------

    \36\ See http://www.fs.fed.us/database/feis/plants/graminoid/arudon/all.html.
    \37\ See Lewandowski, I., Scurlock, J.M.O., Lindvall, E.,
Christou, M. (2003). The development and current status of perennial
rhizomatous grasses as energy crops in the US and Europe. Biomass
and Bioenergy 25, 335-361.
---------------------------------------------------------------------------

    Napiergrass is a tall bunch-type grass that has traditionally been
grown as a high-yielding forage crop across the wet tropics. There is a
considerable body of agronomic research on the production of
napiergrass as a forage crop. More recently, researchers have
investigated ways to maximize traits desirable in bioenergy crops.
Practices have been developed by USDA and other researchers to lower
fertilization rates and increase biomass production. Based in part on
discussions with industry, EPA anticipates continued development of
napiergrass as an energy crop particularly in Gulf Coast Region of the
United States (more specifically the growing region includes Florida
and southern portions of Texas, Louisiana, Georgia, Alabama and
Mississippi).\38\
---------------------------------------------------------------------------

    \38\ For a map depicting the northern limit for sustained
napiergrass production in the United States see Figure 1 in Woodard,
K., R. and Sollenberger, L, E. 2008. Production of Biofuel Crops in
Florida: Elephantgrass. Institute of Food and Agricultural Sciences,
University of Florida. SS AGR 297.
---------------------------------------------------------------------------

a. Crop Yields
    For the purposes of analyzing the GHG emissions from energy cane,
giant reed, and napiergrass 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.\39\ \40\ 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. Giant reed field trials conducted in
Alabama over a 9-year period showed an average yield of 15 dry tons per
acre with no nitrogen fertilizer applied after the first year.\41\
Fertilized field trials have shown yields around 13 to 28 dry tons per
acre in Spain, and 12 dry tons per acre in Italy (based on annual
yields of 3, 14, 17, 16, and 12).\42\ High yields have been
demonstrated with unimproved giant reed populations, and therefore
there is potential for increased biomass productivity through improved
growing methods and breeding efforts.\43\ Napiergrass field trials have
produced dry biomass yields exceeding 20 tons per acre per year in
north-central Florida. Using currently available technology, average
yields for full-season napiergrass should range from 14 to 18 tons per
acre with future improvements expected. Yield depends greatly on the
type of cultivar and the amount and distribution of rainfall and
fertilization rates. There is potential for increased biomass
productivity through improved growing methods and breeding efforts.\44\
In general, the yields for all three of the energy grasses considered
here 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, napier grass, and giant reed
pathways.
---------------------------------------------------------------------------

    \39\ 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.
    \40\ See Hale, A.L. Sugar Bulletin, 2010, 88, 28-29.
    \41\ Huang, P., Bransby, D., and Sladden, S. (2010).
Exceptionally high yields and soil carbon sequestration recorded for
giant reed in Alabama. Poster session presented at: ASA, CSSA, and
SSSA 2010 International Annual Meetings, Green Revolution 2.0; 2010
Oct 31-Nov 4; Long Beach, CA.
    \42\ Mantineo, M., D'Agnosta, G.M., Copani, V., Patan[egrave],
C., and Cosentino, S.L. (2009). Biomass yield and energy balance of
three perennial crops for energy use in the semi-arid Mediterranean
environment. Field Crops Research 114, 204-213.
    \43\ Lewandowski et al. 2003.
    \44\ Based on discussions with industry and USDA and Woodard and
Sollenberger (2008).
---------------------------------------------------------------------------

    Furthermore, EPA's analysis of switchgrass for the RFS2 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, giant reed, and napiergrass
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; an average giant reed
yield of approximately 18 dry tons per acre by 2022; and an average
napiergrass yield of approximately 20 dry tons per acre by 2022.\45\
The ethanol yield for all of the grasses is approximately the same so
the higher crop yields for energy cane, napiergrass, and giant reed
result directly in greater ethanol production compared to switchgrass
per acre of production.
---------------------------------------------------------------------------

    \45\ 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, giant reed would require less than 40% of the land area
required by switchgrass to produce the same amount of biomass, and
napiergrass would require approximately 33% of the land area required
by switchgrass to produce the same amount of biomass due to their
higher yields. Even without yield growth assumptions, their currently
higher crop yield rates means the land use required for these crops
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 and napiergrass will have a
similar impact on international markets as assumed for switchgrass.
Like switchgrass, energy cane and napiergrass are not expected to be
traded internationally and their impacts on other crops are expected to
be limited. Increased giant reed demand in the U.S. for biofuels is not
expected to impact existing markets for giant reed, which are
relatively small niche markets (e.g., musical instrument reeds).
b. Land Use
    In EPA's RFS2 analysis, switchgrass plantings displaced primarily
soybeans and wheat, and to a lesser extent hay, rice, sorghum, and
cotton. Energy cane and napiergrass, with production focused in the
southern United States, are 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 and napiergrass will likely displace the
least productive land first, EPA concludes that the land use GHG impact
for energy cane and napiergrass per gallon should be no greater and
likely less than estimated for switchgrass. Given that giant reed is in
early stages of development as an energy crop, there is limited
information on where it will be grown and what crops it will displace.
We expect giant reed will displace the least productive land first and
would likely have a similar or smaller indirect impact associated with
crop displacement than what we assumed 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 the three energy grasses considered here). As
discussed previously, the camelina is expected to be grown on fallow
land in the Northwest, while energy grasses are 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 grasses
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.
c. Crop Inputs and Feedstock Transport
    EPA also assessed the GHG impacts associated with planting,
harvesting, and transporting energy cane, giant reed, and napiergrass
feedstocks in comparison to switchgrass. Table 6 shows the assumed 2022
commercial-scale production inputs for switchgrass (used in the RFS2
rulemaking analysis), average energy cane, giant reed, and napiergrass
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. Giant reed may require on average
less nitrogen and insecticide than switchgrass, but more phosphorous,
potassium, herbicide, diesel, and electricity per unit of biomass.
Napiergrass may require similar amounts of nitrogen fertilizer
application as switchgrass, less phosphorous, potassium and insecticide
than switchgrass, but more herbicide, lime, diesel, and electricity per
unit of biomass.
    This assessment assumes production of all three new feedstocks 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 RFS2 final rule,
energy cane production results in slightly higher GHG emissions
relative to switchgrass production (an increase of approximately 4 kg
CO2eq/mmbtu). Giant reed production results in slightly
lower GHG emissions relative to switchgrass production (a decrease of
approximately 2 kg CO2eq/mmbtu). Napiergrass production
results in slightly higher GHG emissions relative to switchgrass
production (an increase of approximately 6 kg CO2eq/mmbtu).

                               Table 6--Production Inputs and GHG Emissions for Switchgrass, Energy Cane, Giant Reed, and Napiergrass (Biochemical Ethanol), 2022
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
                                                               Switchgrass                         Energy Cane                         Giant Reed                         Napiergrass
                                                  ----------------------------------------------------------------------------------------------------------------------------------------------
                                 Emission factors    Inputs (per                         Inputs (per                         Inputs (per                         Inputs (per
                                                     dry ton of      Emissions (per      dry ton of      Emissions (per      dry ton of      Emissions (per      dry ton of      Emissions (per
                                                      biomass)         mmBtu fuel)        biomass)         mmBtu fuel)        biomass)         mmBtu fuel)        biomass)        mmBtu fuel)
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Nitrogen Fertilizer...........  3,29 kgCO2e/ton    15.2 lbs......  3.6 kgCO2e........  8.4 lbs.......  2 kgCO2e..........  5 lbs.........  1 kgCO2e..........  10 lbs........  2.4 kgCO2e.
                                 of nitrogen.
N2O...........................  N/A..............  N/A...........  7.6 kgCO2e........  N/A...........  5.9 kgCO2e........  N/A...........  4.8 kgCO2e........  N/A...........  7.6 kgCO2e.
Phosphorus Fertilizer.........  1,12 kgCO2e/ton    6.1 lbs.......  0.5 kgCO2e........  3.2 lbs.......  0.3 kgCO2e........  7.4 lbs.......  0.6 kgCO2e........  1.1 lbs.......  0.1 kgCO2e.
                                 of phosphate.
Potassium Fertilizer..........  743 kgCO2e/ton of  6.1 lbs.......  0.3 kgCO2e........  4.2 lbs.......  0.2 kgCO2e........  7.4 lbs.......  0.4 kgCO2e........  4.0 lbs.......  0.2 kgCO2e.
                                 potassium.
Herbicide.....................  23,45 kgCO2e/tons  0.002 lbs.....  0.003 kgCO2e......  1.0 lbs.......  1.8 kgCO2e........  0.02 lbs......  0.03 kgCO2e.......  0.4 lbs.......  0.6 kgCO2e.
                                 of herbicide.
Insecticide (average across     27,22 kgCO2e/tons  0.025 lbs.....  0.04 kgCO2e.......  0 lbs.........  0 kgCO2e..........  0 lbs.........  0 kgCO2e..........  0 lbs.........  0 kgCO2e.
 regions).                       of pesticide.
Lime..........................  408 kgCO2e/ton of  0 lbs.........  0 kgCO2e..........  104.7 lbs.....  3.1 kgCO2e........  0 lbs.........  0 kgCO2e..........  100 lbs.......  2.9 kgCO2e.
                                 lime.
Diesel........................  97 kgCO2e/mmBtu    0.4 gal.......  0.8 kgCO2e........  1.3 gal.......  2.4 kgCO2e........  1.4 gal.......  2.5 kgCO2e........  1.3 gal.......  2.2 kgCO2e.
                                 diesel.
Electricity (irrigation)......  220 kgCO2e/mmBtu.  0 kWh.........  0 kgCO2e..........  14.7 kWh......  1.6 kgCO2e........  10 kWh........  1 kgCO2e..........  25 kWh........  2.7 kgCO2e.
                                                  ----------------------------------------------------------------------------------------------------------------------------------------------
    Total Emissions...........  .................  ..............  13 kgCO2e/mmBtu...  ..............  17 kgCO2e/mmBtu...  ..............  11 kgCO2e/mmBtu...  ..............  19 kgCO2e/mmBtu.
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Assumes 2022 switchgrass yield of 6.59 dry tons/acre and 92.3 gal ethanol/dry ton, 2022 energy cane yield of 19.1 dry tons/acre and 92 gal ethanol/dry ton, 2022 giant reed yield of 18 dry tons/
  acre and 92.3 gal ethanol/dry ton, and 2022 napiergrass yield of 20 dry tons/acre and 92.3 gal ethanol/dry ton. More detail on calculations and assumptions is included in materials to the
  docket.

    GHG emissions associated with distributing energy cane, giant reed,
and napiergrass feedstocks 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, giant reed, and napiergrass feedstocks 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, giant reed, and napiergrass are suitable for the same
conversion processes as other cellulosic

feedstocks, such as switchgrass and corn stover. Currently available
information on energy cane, giant reed, and napiergrass composition
shows that their 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 RFS2 rule (biochemical ethanol,
thermochemical ethanol, and Fischer-Tropsch (F-T) diesel \46\) to
energy cane, giant reed, and napiergrass. We assumed the GHG emissions
associated with producing biofuels from energy cane, giant reed, and
napiergrass 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, giant reed, and napiergrass 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,
considering the increased transport emissions associated with sugarcane
ethanol distribution to the U.S., this would at most add 1-2% to the
overall lifecycle GHG impacts of the energy grasses.
---------------------------------------------------------------------------

    \46\ The F-T diesel process modeled applies to cellulosic
diesel, jet fuel, heating oil, and naphtha.
---------------------------------------------------------------------------

3. Summary
    Based on our comparison of switchgrass and the three feedstocks
considered here, EPA believes that cellulosic biofuel produced from the
cellulose, hemicellulose and lignin portions of energy cane, giant
reed, and napiergrass has similar or better lifecycle GHG impacts than
biofuel produced from the cellulosic biomass from switchgrass. Our
analysis suggests that the three feedstocks considered have 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, emissions from
growing and harvesting giant reed are approximately 2 kg CO2eq/mmBtu
lower than switchgrass, and emissions from growing and harvesting
napiergrass are approximately 6 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, the three feedstocks considered
are 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,
giant reed, and napiergrass still meet the 60% reduction threshold for
cellulosic biofuel, the lowest being a 64% reduction (for napiergrass
F-T diesel) compared to the petroleum baseline. We believe these are
conservative estimates, as use of energy cane, giant reed, or
napiergrass as a feedstock is expected to have smaller land-use GHG
impacts than switchgrass, due to their higher yields. The docket for
this rule provides additional detail on the analysis of energy cane,
giant reed, and napiergrass as biofuel feedstocks.
    Although this analysis assumes energy cane, giant reed, and
napiergrass 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, giant reed, and
napiergrass from other countries. We do not expect incidental amounts
of biofuels from feedstocks produced in other nations to impact our
average GHG emissions. Moreover, those countries most likely to be
exporting energy cane, giant reed, or napiergrass or biofuels produced
from these feedstocks are likely to be major producers which typically
use similar cultivars and farming techniques. Therefore, GHG emissions
from producing biofuels with energy cane, giant reed, or napiergrass
grown in other countries should be similar to the GHG emissions we
estimated for U.S. energy cane, giant reed, or napiergrass, though they
could be slightly (and insignificantly) higher or lower. For example,
the renewable biomass provisions under the Energy Independence and
Security Act would prohibit 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 RFS2 final rule and
this comparison of GHG emissions from switchgrass and energy cane,
giant reed, and napiergrass, we do not expect variations to be large
enough to bring the overall GHG impact of fuel made from energy cane,
giant reed or napier grass 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, giant reed, and napiergrass under the same pathways for
which cellulosic biomass from switchgrass qualifies under the RFS2
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 RFS2
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 RFS2 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 RFS2
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 RFS2 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 represent
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 RFS2 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 RFS2 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 gaoline blendstock (``catalytic
pyrolysis''), (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 RFS2 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.\47\ 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 RFS2 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 RFS2 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 RFS2 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.\48\ 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.\49\
---------------------------------------------------------------------------

    \47\ Kinchin, Christopher. Catalytic Fast Pyrolysis with
Upgrading to Gasoline and Diesel Blendstocks. National Renewable
Energy Laboratory (NREL). 2011.
    \48\ Aden, Andy. Feedstock Considerations and Impacts on
Biorefining. National Renewable Energy Laboratory (NREL). December
2009.
    \49\ 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.

 Table 7--Feedstock Production Emissions for Renewable Gasoline and Renewable Gasoline Blendstock Pathways Using
                                                   Corn Stover
----------------------------------------------------------------------------------------------------------------
                                                                                Direct
                                                                                biochemical
                                                             Catalytic         Biochemical        fermentation
                                                            pyrolysis to     fermentation to       process to
                                                             renewable          renewable          renewable
         Feedstock production emission sources                gasoline         gasoline via       gasoline and
                                                         blendstock (g CO2-  carboxylic acid       renewable
                                                             eq./mmBtu)     (g CO2-eq./mmBtu)       gasoline
                                                                                blendstock (g CO2-
                                                                                eq./mmBtu)
----------------------------------------------------------------------------------------------------------------
Domestic Livestock.....................................              7,648              6,770            ~ 9,086
Domestic Farm Inputs and Fertilizer N2O................              1,397              1,237            ~ 1,660
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 Fertilizer N2O...........                  0                  0                  0
International Rice Methane.............................                  0                  0                  0
International Land Use Change..........................                  0                  0                  0
                                                        --------------------------------------------------------
    Total Feedstock Production Emissions...............                287                254              ~ 361
----------------------------------------------------------------------------------------------------------------

    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 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 RFS2
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 RFS2 final rule were applied to this
analysis.
3. Use of the Fuel
    A petroleum gasoline baseline was developed as part of the RFS2
final rule which estimated the tailpipe emissions from fuel combustion.
Since renewable gasoline and renewable gasoline blendstock are similar
to petroleum gasoline, the non-CO2 combustion emissions
calculated as part of the RFS2 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 RFS2 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 RFS2 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 naphtha, a gasoline
blendstock. In the final RFS2 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.
    Since the final RFS2 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.\50\ 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.
---------------------------------------------------------------------------

    \50\ 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''),
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'').51 52
---------------------------------------------------------------------------

    \51\ Regalbuto, John. ``An NSF perspective on next generation
hydrocarbon biorefineries,'' Computers and Chemical Engineering 34
(2010) 1393-1396. February 2010.
    \52\ 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 RFS2 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 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.\53\ 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 gasoline and diesel blendstock streams (cellulosic
diesel from catalytic pyrolysis is already included as an acceptable
pathway in the RFS2 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 biomass 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.
---------------------------------------------------------------------------

    \53\ 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
             Technology                  Biomass use      Natural gas use      electricity      Sold electricity
----------------------------------------------------------------------------------------------------------------
Catalytic Pyrolysis to Renewable               136,000             51,000                  0             -2,000
 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 RFS2 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.\54\
See Table 9 for a summary of emissions from fuel production.
---------------------------------------------------------------------------

    \54\ 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 to Renewable
                  Gasoline Blendstock Using Corn Stover
------------------------------------------------------------------------
                                                            Catalytic
                                                          pyrolysis to
                                                            renewable
                    Lifecycle stage                         gasoline
                                                          blendstock (g
                                                         CO2-eq./mmBtu)
------------------------------------------------------------------------
On-Site & Upstream Emissions (Natural Gas & Biomass*).            31,000
Electricity Co-Product Credit.........................            -3,000
Total Fuel Production Emissions:......................            28,000
------------------------------------------------------------------------
Only non-CO2 combustion emissions from biomass.

    b. Fermentation and Upgrading to Renewable Gasoline and Renewable
Gasoline Blendstock
    The second production process we investigated is a biochemical
fermentation process to intermediate carboxylic acids with catalytic
upgrading to renewable gasoline or renewable gasoline blendstock. This
process involves the fermentation of biomass using a mixed-culture of
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.\55\ 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
inputs along with emission factors to estimate the GHG emissions from
this process. The energy inputs and electricity credits are shown in
Table 10, below. These inputs are based on Confidential Business
Information (CBI), rounded to the nearest 1000 units, provided by
industry as part of the petition process for new fuel pathways.
---------------------------------------------------------------------------

    \55\ Hydrogen emissions are modeled as natural gas and
electricity demands.

                                Table 10--2022 Energy Use at Cellulosic Facility
                                                    [Btu/gal]
----------------------------------------------------------------------------------------------------------------
                                                                                Purchased
             Technology                  Biomass use      Natural gas use      electricity      Sold electricity
----------------------------------------------------------------------------------------------------------------
Biochemical Fermentation to                     49,000             59,000                  0             -2,000
 Renewable Gasoline or Renewable
 Gasoline Blendstock via Carboxylic
 Acid...............................
----------------------------------------------------------------------------------------------------------------

    The process also uses a small amount of buffer material as
neutralizer which was not included in the GHG lifecycle results due to
its likely negligible emissions impact. The GHG emissions estimates
from the fuel production stage are seen in Table 11.

   Table 11--Fuel Production Emissions for Biochemical Fermentation to
 Renewable Gasoline or Renewable Gasoline Blendstock via Carboxylic Acid
                            Using Corn Stover
------------------------------------------------------------------------
                                                        GHG Emissions (g
                    Lifecycle stage                      CO2-eq./mmBtu)
------------------------------------------------------------------------
On-Site & Upstream Emissions (Natural Gas & Biomass*).            33,000
Electricity Co-Product Credit.........................            -3,000
                                                       -----------------
    Total Fuel Production Emissions:..................            30,000
------------------------------------------------------------------------
*Only non-CO2 combustion emissions from biomass

c. Direct Fermentation to Renewable Gasoline and Renewable Gasoline
Blendstock
    The third production process we investigated involves the use of
microorganisms to ferment sugars hydrolyzed from cellulose directly
into hydrocarbons which could be either a complete fuel as renewable
gasoline or a renewable gasoline blendstock. The process is similar to
the biochemical fermentation to ethanol pathway modeled for the final
RFS2 rule with the major difference being the end fuel product,
hydrocarbons instead of ethanol. Researchers believe that this new
technology could achieve improvements over classical fermentation
approaches because hydrocarbons separate spontaneously from the aqueous
phase, thereby avoiding poisoning of microbes by the accumulated
products and facilitating separation/collection of alkanes from the
reaction medium.\56\ In other words, some energy savings may result
because fewer separation unit operations could be required for
separating the final product from other reactants and there may be
better conversion yields as the fermentation microorganisms are not
poisoned when interacting with accumulated products. We also expect
that the lignin/byproduct portions of the biomass from the fermentation
to hydrocarbon process could be converted into heat and electricity for
internal demands or for export, similar to the biochemical fermentation
to ethanol pathway.
---------------------------------------------------------------------------

    \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.
---------------------------------------------------------------------------

    Therefore, we can conservatively extend our final RFS2 rule
biochemical fermentation to ethanol process results to a similar (but
likely slightly improved) process that instead produces hydrocarbons.
Since the final RFS2 rule cellulosic ethanol GHG results were well
above the 60% GHG reduction threshold for cellulosic biofuels, if
actual emissions from other necessary changes to the direct biochemical
fermentation to hydrocarbons process represent some small increment in
GHG emissions, the pathway would still likely meet the threshold. Table
12 is our qualitative assessment of the potential emissions reductions
from a process using biochemical fermentation to cellulosic
hydrocarbons assuming similarities to the biochemical fermentation to
cellulosic ethanol route from the final RFS2 rule.

   Table 12--Fuel Production Emissions for RFS2 Cellulosic Biochemical
    Ethanol Compared to Direct Biochemical Fermentation to Renewable
       Gasoline or Renewable Gasoline Blendstock Using Corn Stover
------------------------------------------------------------------------
                                                             Direct
                                                          biochemical
                                                        fermentation to
                                     RFS2 Cellulosic       renewable
                                       biochemical        gasoline and
          Lifecycle stage           ethanol emissions      renewable
                                    (g CO2-eq./mmBtu)       gasoline
                                                           blendstock
                                                       emissions (g CO2-
                                                           eq./mmBtu)
------------------------------------------------------------------------
On-Site Emissions & Upstream                    3,000       < or = 3,000
 (biomass)........................
Electricity Co-Product Credit.....            -35,000          = -35,000
                                   -------------------------------------