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 Ethanol produced from sugarcane in Brazil can help the United States meet its advanced renewable fuel targets, while helping reduce emissions. This is one of the conclusions presented by the Brazilian Sugarcane Industry Association (UNICA) to the U.S. Environmental Protection Agency (EPA), in a public comment submitted on September 25.
The 40-page letter on the new Renewable Fuel Standard (RFS2) explains that the performance of Brazilian ethanol remains strong, even when its theoretical Indirect Land Use Change (ILUC) impacts are taken into consideration.
"We emphatically demonstrated, with verifiable scientific evidence, that Brazilian ethanol is certainly an appropriate alternative for meeting the advanced biofuel requirements of RFS2," says UNICA's Chief Representative for North America, Joel Velasco.
The proposed RFS2 establishes minimum biofuels consumption in the U.S. of more than ten billion gallons per year in 2009, reaching 36 billion gallons in 2022, of which 21 billion gallons per year would have to be "advanced biofuels" with significant greenhouse gas (GHG) reduction thresholds.
UNICA's four-part letter emphasizes the role of sugarcane as a key raw material to advance the use of clean, renewable energy. It describes the sustainable production of ethanol in Brazil, using just over 1% of the country's arable land, as well as additional benefits such as bioelectricity generation from sugarcane bagasse. UNICA refutes, with hard facts, various myths on cane production, such as the recurring accusation of cultivation in the Amazon.
Recalling that the EPA is required to implement RFS2 at the earliest opportunity, UNICA emphasizes that the agency is more than a year late in implementing RFS2 and several court decisions show that further delays are problematic. Although UNICA notes that the EPA's technical analysis thoroughly considered and evaluated the major issues, its letter suggests various areas to improve the implementation of RFS2, such as allowing other qualified advanced biofuels to be used in cases where the EPA would otherwise have to waive the cellulosic biofuel mandate due to lack of cellulosic biofuel production.
According to EPA calculations, Brazilian cane ethanol reduces GHG emissions by 44% considering a 2005 gasoline baseline. That would classify sugarcane ethanol as an advanced biofuel. Nevertheless, under suggested revisions, UNICA points out that sugarcane ethanol would reduce GHG emissions by 82% or more.
RFS2 calls for 21 billion gallons of advanced biofuels by 2022, which would make a significant contribution in terms of energy security as well as GHG reduction. In its letter, UNICA shows that if the EPA concludes that CO2 is harmful to human health, under an Endangerment Finding, the Clean Air Act is straightforward in its requirement that the use of fossil fuels would need to be limited. In the case of the RFS2, this would mean encouraging the use of biofuels that offer greater GHG reductions, as is the case with sugarcane ethanol and other advanced biofuels.
UNICA also refuted what it calls EPA emission calculation errors in two key areas. The first is the lack of emission credits from the production of bioelectricity from sugarcane. The letter describes the entire cogeneration process and its growth and role in the Brazilian electricity grid, concluding with what several studies already show: renewable bioelectricity reduces emissions that would be otherwise produced by thermal plants that burn fossil fuels.
The letter also criticizes the model used to calculate emissions resulting from ILUC effects, an academic theory that has little to do with the reality of agriculture in the world. In this critique, based in part on the work of the Institute for International Trade Negotiations (ICONE) also delivered to EPA, UNICA shows that Brazilian agriculture and livestock can meet the increased U.S. demand for biofuels without causing deforestation or significant land use changes.
The UNICA letter points out that if the EPA applies minimal but necessary changes to their calculations, the GHG reduction of sugarcane ethanol would reach 82% compared to the 2005 gasoline baseline.
UNICA's comments concludes by warning the EPA about the need to revise its regulations to avoid additional problems before the World Trade Organization (WTO). Several aspects of the proposed EPA regulations are inconsistent with WTO rules and, therefore, need to be reviewed in UNICA's view. The Association also recommends a series of proposed regulatory changes to facilitate compliance and enforcement with RFS2.
"In our assessment, these are arguments that should provide greater certainty in the regulation of biofuels in the United States. We are confident that EPA will make an independent, scientific determination that sugarcane ethanol qualifies as an advanced biofuel under RFS2," says UNICA's Joel Velasco.
The Brazilian Sugarcane Industry Association (UNICA) represents the top producers of sugar and ethanol in Brazil's South-Central region, especially the state of São Paulo, which accounts for about 50% of the country's sugarcane harvest and 60% of total ethanol production.
UNICA, among other things, develops position papers, statistics and specific research in support of Brazil's sugar, ethanol and bioelectricity sectors. In 2008, Brazil produced an estimated 565 million metric tons of sugarcane, which yielded 31.3 million tons of sugar and 25.7 billion liters (6.8 billion gallons) of ethanol.
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NOTHING ELSE !!!!!
But then why is Brazil taxing CARS MADE IN USA....with a 100 % import tax ?
In my view the USA should also charge 100 % IMPORT TAX on brazilian ethanol.
That would be far more than the 54 cents...per gallon the U.S. actually charges !
Europe and Japan should do no differently !
Cars made in developed countries also meet the whatever International regulations.
Funny how brazilians have on purpose only HALF A BRAIN SO MANY TIMES !
A one way brain...meaning exports Yesssss....imports and you have head pains.