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

petition to the Agency describing the renewable fuel, its feedstock and production
process, and the calculation of its Equivalence Value. The Agency would review the
petition and assign an appropriate Equivalence Value to the renewable fuel based on the
proposed rounding protocols described above. Regarding publication of the newly
assigned Equivalence Value, we could publish it in the Federal Register at the same time
as the annual standard is published each November. We request comment on whether
publishing new Equivalence Values in this manner is appropriate.
Regarding biodiesel (mono alkyl esters), we also considered an additional
approach in setting the Equivalence Value. Since ethanol derived from waste products
such as animal wastes and municipal solid waste will be assigned an Equivalence Value
of 2.5 based on a requirement in the Act, it might be appropriate to create a parallel
provision for biodiesel made from wastes. Under this approach, biodiesel made from
waste products would be assigned an Equivalence Value of 2.5 through 2012. Currently,
waste products (for example, poultry fats and poultry wastes, municipal solid waste, or
wastewater sludge) make up less than 10 percent of biodiesel feedstocks. This approach
would have the effect of incentivizing the use of waste products and recycled biomass to
make biodiesel. Beyond the RFS program, it could also set a precedent to promote
recycling and waste conservation. While we are not proposing to set the Equivalence
Value for waste-derived biodiesel at 2.5 in today's action, we nevertheless believe that
this approach has merit and request comment on it.
c. Lifecycle Analyses As The Basis For Equivalence Values
Although we are proposing that Equivalence Values be based on energy content
relative to ethanol and renewable content, some stakeholders have suggested that
Equivalence Values should be based on lifecycle analyses. Such an approach may have
merit, but it would also raise a number of challenges. Consequently, we are inviting
comment here not only on the merit and basis for setting equivalence values on a
lifecycle basis, but also the appropriate means of doing so.
Lifecycle analyses involve an examination of fossil fuel used, and emissions
generated, at all stages of a renewable fuel's life. A typical lifecycle analysis examines
production of the feedstock, its transport to a conversion facility, the conversion of the
feedstock into renewable motor vehicle fuel, and the transport of the renewable fuel to
the consumer. At each stage, every activity that consumes fossil fuels or results in
emissions is quantified, and these energy consumption and emission estimates are then
summed over all stages. By accounting for every activity associated with renewable fuels
over their entire life, we can assess renewable fuels in terms of not just their impact
within the transportation sector, but across all sectors, and thus for the nation as a whole.
In this way they provide a more complete picture of the potential impacts of different
fuels or different fuel sources.
Advocates for using lifecycle analyses for setting the Equivalence Values for
different renewable fuels indicate that there could be several advantages to this approach.
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