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Regulation of Fuels and Fuel Additives: Renewable Fuel Standard ...

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X. Agricultural Sector Economic Impacts<br />

As described in more detail in the Draft Regulatory Impact Analysis<br />

accompanying this proposal, we plan to evaluate the economic impact on the agricultural<br />

sector. However, due to the timing <strong>of</strong> that analysis, it will not be completed until the<br />

final rule. In the mean time, we briefly describe here (<strong>and</strong> in more detail in the draft<br />

RIA) our planned analyses <strong>and</strong> the sources <strong>of</strong> assumptions which could critically impact<br />

those assessments. Finally, we ask for specific comment on the best sources <strong>of</strong><br />

information we use in these analyses.<br />

We will be using the Forest <strong>and</strong> Agricultural Sector Optimization Model<br />

(“FASOM”) developed over the past 30 years by Bruce McCarl, Texas A&M University<br />

<strong>and</strong> others. This is a constrained optimization model which seeks to allocate resources<br />

<strong>and</strong> production to maximize producer plus consumer surpluses. We have consulted with<br />

a range <strong>of</strong> experts both within EPA as well as at our sister agencies, the U.S. Departments<br />

<strong>of</strong> Agriculture <strong>and</strong> Energy <strong>and</strong> they support the use <strong>of</strong> this model for assessing the<br />

economic impacts on the agricultural sector <strong>of</strong> various renewable fuel pathways<br />

evaluated in this rule. The objective <strong>of</strong> this modeling assessment is to predict the<br />

economic impacts that will directly result from the exp<strong>and</strong>ed use <strong>of</strong> farm products for<br />

transportation fuel production. We anticipate that the growing dem<strong>and</strong> for corn for<br />

ethanol production in particular but also soybeans <strong>and</strong> other agricultural crops such as<br />

rapeseed <strong>and</strong> other oil seeds for biodiesel production will increase the production <strong>of</strong> these<br />

feedstocks <strong>and</strong> impact farm income. The additional corn to produce ethanol may come<br />

from several sources, including (1) more intensive cultivation <strong>of</strong> existing l<strong>and</strong> that<br />

currently produce corn, (2) switching production from soybean <strong>and</strong> cotton to corn, (3)<br />

additional acres <strong>of</strong> l<strong>and</strong> being cultivated, or (4) diversion from corn exports. The<br />

implications to U.S. net exports <strong>and</strong> environment effects partially depend on which<br />

source supplies more corn. Eventually various cellulose sources such as corn stover <strong>and</strong><br />

switchgrass for cellulose-based ethanol production may well become highly dem<strong>and</strong>ed<br />

<strong>and</strong> also significantly impact the agricultural sector.<br />

Using the FASOM model, we will estimate the direct impact on farm income<br />

resulting from higher dem<strong>and</strong> for corn <strong>and</strong> soybeans, for example. Additionally, we will<br />

estimate impacts on farm employment. Since we expect the higher dem<strong>and</strong> for feedstock<br />

will increase both the supply <strong>and</strong> cost <strong>of</strong> feedstock, we will also consider how the higher<br />

renewable fuel feedstock cost impacts the cost <strong>of</strong> other agricultural products (corn <strong>and</strong><br />

soy meal are important sources not only for directly making food for human consumption<br />

but also as feed for farm animals). As an estimate <strong>of</strong> the impact on corn <strong>and</strong> soybeans<br />

prices, we are relying on the estimates provided by the U.S. Department <strong>of</strong> Agriculture 104<br />

rather than using the FASOM model to derive these price impacts. Additionally, we will<br />

rely on the Energy Information Agency’s estimates for fuel mix in predicting the amount<br />

<strong>of</strong> ethanol <strong>and</strong> biodiesel in the fuel pool. Other than these external constraints, we expect<br />

to use FASOM as the basic model for estimating economic impacts on farm sector <strong>and</strong><br />

104 “USDA Agricultural Baseline Projections to 2015”<br />

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