Document vBkZdm9BrprOLJDrg2Ow4j9bE

February 23, 2018 Administrator Scott Pruitt U.S. Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460 Dear Administrator Pruitt: We respectfully request the Environmental Protection Agency (EPA) adopt an updated lifecycle analysis for corn ethanol. EPA's lifecycle analysis was originally established in 2009 and published in the regulatory impact analysis to a 2010 Renewable Fuel Standard (RFS) rule; this analysis does not reflect improvements in corn and ethanol production since then. Adopting an updated analysis would help fulfill the Trump Administration's pledge to rely on sound science and transparency. Over the last eight years, our organizations and others appealed to the previous administration and the career experts at EPA to update these numbers to no avail. EPA's forthcoming Triennial Report to Congress offers a new opportunity for the Agency to correct these outdated estimates and take advantage of recent lifecycle analysis updates completed by other federal agencies and university researchers. The U.S. Department of Energy (DOE), through Argonne National Laboratory, and the U.S Department of Agriculture have both been working on updating the input data for corn and ethanol production, improving models, vetting the results, and using the latest analytical resources to develop the most accurate lifecycle numbers possible. Many universities such as Purdue, the University of Illinois at Chicago, and Iowa State show similar improvements. Most of these recent modeling results have been published in peer-reviewed journals. While lifecycle analysis for corn ethanol may seem less important now for the administration of the RFS, the lifecycle values of biofuels have become very important in global ethanol export markets. EPA's outdated life cycle estimates may now seriously impact corn ethanol exports to foreign markets such as Japan, Brazil, Europe, and South Korea, which are establishing their own greenhouse gas (GHG) standards and/or evaluating ethanol imports based on EPA's outdated lifecycle numbers. Specifically, in the short term, if these numbers are not updated, the United States risks losing export opportunities to competing sugarcane ethanol from Brazil. For example, the United States recently had the opportunity to compete for ethanol as a feedstock for ETBE exports to Japan. The U.S. Grains Council (in cooperation with agribusiness groups, ethanol organizations, and with university input) demonstrated the significant improvements in the lifecycle emissions of corn ethanol over the past decade, using both the USDA lifecycle analysis estimates and the DOE Argonne model. Due to the differences in the more recent lifecycle analysis from USDA and the outdated estimates from EPA, the U.S. ethanol industry spent additional resources to educate the Japanese authorities on the discrepancies between the USDA and EPA lifecycle analyses. Ultimately, Japanese authorities 1 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00161531-00001 accepted the USDA methodology. Attached to this letter is a table used in Japan's original analysis of corn-based ethanol. As you may know, Brazil became our largest foreign market for corn ethanol in 2016 and remained our largest market in 2017, importing 446 million gallons. Unfortunately, in a move to limit U.S. access to its market, Brazil has implemented a tariff rate quota (TRQ) for ethanol imports. With the TRQ, a tariff is applied to purchases from the U.S. after a 150 million liter (39.6 million gallon) per quarter quota is met. The original argument for a tariff was based on Brazil's purported interest in reducing carbon emissions from fuel. Brazilian regulators used the 2010 study from the EPA website to arrive at an estimated duty rate slightly below 20 percent. If Brazil had used figures from the USDA study released in December 2016, the same Brazilian formula results in a tariff of just 2.7 percent. The outdated EPA numbers hold the potential to reduce ethanol export opportunities and negatively impact U.S. jobs and the rural economy. Outdated data and poor models could cause the U.S. corn and ethanol producers to lose market access. These losses will further the economic crisis for corn growers currently struggling with stagnant demand and low prices. Countries that are establishing carbon standards realize that blending ethanol has major GHG reducing impacts and will move to encourage its usage. GHG criteria are important to work the U.S. ethanol industry is carrying out in Colombia, Japan, the EU, and Canada. We expect even more countries will examine the GHG reducing properties of ethanol over the next few years, but they will not choose U.S. ethanol when they rely on the 2010 EPA lifecycle analysis. We encourage your agency to adopt either DOE/Argonne's latest published results or USDA's recently reported data. We would also be pleased to work with you and your staff to provide information regarding improvements in corn production to help inform EPA's forthcoming Triennial Report. Sincerely, Mike Lefever Colorado Corn Administrative Committee President Dave Eckhardt Colorado Corn Growers Association President Aron Carlson Illinois Corn Growers Association President PaulJeschke Illinois Corn Marketing Board Chairman Sarah Delbecq Indiana Corn Growers Association President 2 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00161531-00002 Mark Recker Iowa Corn Growers Association President Dennis McNinch Kansas Corn Commission Chairman Ken McCauley Kansas Corn Growers Association President Mark Roberts Kentucky Corn Growers Association Jason McConnachie Michigan Corn Growers Association President Kirby Hettver Minnesota Corn Growers Association President Kyle Kirby Missouri Corn Growers Association President David Merrell Nebraska Corn Board Chairman Dan Wesely Nebraska Corn Growers Association President Carson Klosterman North Dakota Corn Growers Association President Jed Bower Ohio Corn and Wheat Growers Association President Troy Knecht South Dakota Corn Growers Association President Casey Kelleher Wisconsin Corn Growers Association President Kevin Skunes National Corn Growers Association President Enel.: Basic Concepts of GHG Emission Reduction Requirement cc: Secretary Sonny Perdue, U.S. Department of Agriculture Secretary Rick Perry, U.S. Department of Energy Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 3 ED 002061 00161531-00003 Basic Concepts of GHG Emission Reduction Requirement It is important to establish the GHG emission reduction requirement that is at least targeting C02 reduction not weaker than other countries, and that possess sufficient effects from the point of efficient biomass utilization. Taking into consideration availability of biofuel meeting the requirement, it is decided to be up from 50% gasoline equivalent to 55% gasoline equivalent. Europe and the U.S. Europe (RED) UK (RTFO) ^US (RFS2) Values w hen the current requirem ents w ere established (2011) 35% 50% Existing: 20% Next generation: 50-60% Japan GHG em ission reduction by w oodchip biom ass generation A vailable biofuel 42.8 gC02/M J (52.4% reduction com pared w ith gasoline) Brazil A t p resen t (Janu ary 1, 2018 for EU) 50% (Plant built before O ctober 5, 2015) 60% (Plant built before O ctober 5, 2015) Same as RED No changes of the requirem ents but the target volum e of advanced biofuel introduction has been increasing 47.5 gC02/M J (56.5% reduction com pared w ith gasoline) Brazil U.S. (dom estic next generation) Summary on the Concept of Proposed Standards (Public Notice) for the Next Policy The term for the next policy will be 5 years (2018-2022) with the target volume of bioethanol introduction will be 500,000 KL gasoline equivalent each year. The new LCA assessment value for GHG emission (standard value) for U.S. corn bioethanol will be newly established. The GHG emission reduction requirement will be raised from 50% gasoline equivalent to 55% gasoline equivalent, in order that at least targets CO2 reduction not weaker than other countries, and that possesses sufficient effects from the point of efficient biomass utilization. From the point of view of competition with food crops and self-sufficiency, development of domestic next generation biofuel will be continued. The target volume and required policy will be determined in the next minor revision scheduled to be early 2020. The treatment of biodiesel and other biofuel will continue to be discussed. 4 Sierra Club v. EPA 18cv3472 NDCA Tier 3/4 ED 002061 00161531-00004