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Our Comments So Far to Environmental Regulators and Legislators

By Leticia Phillips posted Jun 20, 2013
Sugarcane ethanol producers are stepping up our profile in the debate over the Renewable Fuel Standard (RFS). We’ve been active for a while sharing vital facts about clean, advanced biofuels like sugarcane ethanol and lending our expertise and support to policymakers currently exploring the issue. Here’s a quick update on our activities so far and future plans.

As I wrote a couple weeks ago in my last post, sugarcane ethanol producers are stepping up our profile in the debate over the Renewable Fuel Standard (RFS). We’ve been active for a while sharing vital facts about clean, advanced biofuels like sugarcane ethanol and lending our expertise and support to policymakers currently exploring the issue.  Here’s a quick update on our activities so far and future plans.

Where We’ve Been: On the Record

In April, the Brazilian Sugarcane Industry Association (UNICA) submitted comments to the Environmental Protection Agency in response to their proposed RFS requirements for 2013. Our letter touches on a number of key issues, but most importantly, addresses concerns that Brazil cannot supply enough sugarcane ethanol to meet America’s needs.  On the contrary, updated harvest and export capacity estimates confirm that Brazilian sugarcane ethanol producers can meet EPA’s projections for ethanol exports to the United States.  Our comments to EPA conclude:

UNICA is confident that Brazilian sugarcane ethanol producers will be able to meet—and if necessary surpass—EPA’s projections for Brazilian sugarcane ethanol exports to the United States. Further, we believe this updated information resolves any residual uncertainty regarding Brazilian sugarcane production and ethanol production and obviates any need to reduce the statutory volume requirement for advanced biofuels as a hedge against poor production in Brazil. (Page 12)

Congress is also getting into the act, with the House Committee on Energy and Commerce releasing a series of white papers seeking input on the renewable fuel standard.

We welcomed the opportunity to answer the committee’s questions and illustrate the ways sugarcane ethanol is helping America meet RFS goals – particularly improving energy security and reducing greenhouse gas emissions. Some of the highlights from last month’s letter to Congress:

The RFS – and sugarcane ethanol in particular – works to reduce greenhouse gas emissions (GHG). As demonstrated by EPA’s own lifecycle analysis, the GHG emissions reductions associated with Brazilian sugarcane ethanol exceed the emissions thresholds for all categories of advanced biofuels included in the RFS program. Sugarcane ethanol is the most efficient biofuel produced at a commercial scale and can reduce GHG emissions by over 60% when compared to a fossil fuel baseline. (Pages 1-2)

Sugarcane ethanol helps meet advanced biofuel mandates. The Environmental Protection Agency has conducted rulemakings each year that waive significant portions of the Energy Independence and Security Act of 2007 (EISA) cellulosic ethanol mandate.  As development of commercial-scale cellulosic biofuel facilities has been slow, that volume mandate has been met with other advanced biofuels that offer comparable GHG emission reduction benefits, such as Brazilian sugarcane ethanol.  As a result, the GHG emission reduction benefits anticipated by the EISA have been achieved, even if through different paths. (Page 5)

Brazil is dedicated to the current and future success of the RFS. Our members are committed to producing increasing quantities of Brazilian sugarcane ethanol to help ensure compliance with the RFS program’s advanced biofuel mandate in the future. Brazilian sugarcane producers  have made a long-term commitment to providing clean, renewable sugarcane ethanol to meet  energy and environmental goals in Brazil and globally as evidenced by the considerable investments by major global energy companies, such as Shell, BP, Total and Petrobras, in the sugarcane industry. (Page 2)

Where We’re Going

We’re proud of the role that sugarcane ethanol plays in helping the U.S. reduce greenhouse gases. And sugarcane ethanol producers are committed to providing clean, renewable fuel for Brazil, the U.S. and the world. As the debate heats up and congressional scrutiny intensifies this summer, we will continue to highlight the benefits and stress the importance of access to clean, advanced biofuels like sugarcane ethanol.

We’ll also be keeping a close eye on RFS rulemaking coming out of EPA later this year.  We’ve seen troubling signs that the regulatory process might be misused to impose onerous, anti-competitive requirements on foreign ethanol.  More to come.

Our Authors

 

Géraldine Kutas, Head of International Affairs & Senior International Adviser to the President of UNICA Géraldine Kutas
Head of International Affairs & Senior International Adviser to the President

 

Leticia Phillips, Representative-North AmericaLeticia Phillips
Representative, North America

 

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