Comment submitted by Dr. Robert Shapiro and Dr. Nam Pham, Sonecon, LLC

This is a Comment on the Environmental Protection Agency (EPA) Notice: Notice of Data Availability Concerning Renewable Fuels Produced from Palm Oil Under the RFS Program

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In January 2012, the Environmental Protection Agency (EPA) released its initial assessment of the life cycle greenhouse gas emission benefits associated with the use of palm oil as an element for transportation fuels under the Renewable Fuel Standard (RFS) program. The EPA analysis found that palm oil biodiesel and palm oil renewable diesel fuels did not meet the standards of life cycle greenhouse gas (GHG) emission reductions established under the RFS program for acceptable components of transportation fuels. The EPA Notice asked for comments on these findings. We have reviewed the methodology and results reported by the EPA, and we conclude that the EPA has failed to establish a clear and convincing basis for excluding the use of palm oil under the RFS program. (See attached document) The EPA analysis relies on speculative assumptions regarding both indirect land use changes and palm oil crop yields, in ways which systematically increase the projected life cycle GHG emissions for both fuels. In addition, the EPA relies on calculated “midpoint” values for those emissions drawn from its wide range of projected values, without establishing the statistical significance of those midpoints. We urge the EPA to review its analysis in light of these comments.




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Comment Period Closed
Mar 28 2012, at 11:59 PM ET
ID: EPA-HQ-OAR-2011-0542-0143
Tracking Number: 80fdf2fd

Document Information

Date Posted: Mar 23, 2012
RIN: 2060-AR07
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