RFA requests more transparency in EPA's RFS2 rulemaking process

By Erin Voegele | May 04, 2009
Report posted June 2, 2009, at 5:15 p.m. CST

On June 1 Renewable Fuels Association President and CEO Bob Dinneen sent a letter to U.S. EPA Administrator Lisa Jackson requesting more transparency in the agency's calculations of indirect land use.

According to the letter, various models and data sets used by the EPA to calculate key aspects of the proposed rulemaking for the renewable fuels standard, enacted in the Energy Independence & Security Act of 2007, are not publicly accessible and have not been added to the docket as of May 29. The RFA is requesting that the agency provide additional information on these models and data sets in order to ensure transparency and give the public a meaningful opportunity to participate in the rulemaking process.

"This information is of central relevance to EPA's analysis and decision making and must be made publicly available," the letter stated. "Indeed, the importance of EPA's life cycle cannot be disputed, and EPA's approach in the proposal is novel, complex, and highly controversial. As such, transparency in this case is vital to ensure scientific objectivity and integrity and adequate public participation."

According to the RFA, the information that has been provided by the EPA is insufficient to allow third parties to replicate the results of the agency's biofuels lifecycle modeling. In the letter, Dinneen said it's important that stakeholders are able to replicate EPA's results for variety of reasons. It would allow stakeholders to understand the structure of the modeling framework and the impact of certain parameters on the modeling outcomes, validate the accuracy and precision of EPA's analysis, and perform independent analyses using alternative assumptions and inputs.

The RFA specifically requests the EPA:
  • • Provide public access to the Food and Agriculture Policy Research Institute (FAPRI) system of models as configured for the RFS analysis, including all assumptions, inputs, price and demand elasticities used, outputs for all scenarios and sensitivity cases, and other pertinent information.

  • • Provide public access to the Forestry and Agriculture Sector Optimization Model (FASOM) as configured for the RFS analysis, including all assumptions, inputs, price and demand elasticities used, outputs for all scenarios and sensitivity cases, and other pertinent information.

  • • Provide the version of the GREET model used for the RFS analysis along with all assumptions and inputs that differ from GREET defaults, and the ASPEN-based model used by EPA would be made available with documentation describing how the model was used to generate 2022-era performance assessments.

  • • Provide detailed documentation describing exactly how all of the various models used were integrated and what adjustments were made to each to enable amalgamation, including a thorough description of how all of the inputs and outputs from each model were reconciled and harmonized.

  • • Provide the results of a formal uncertainty analysis including confidence intervals and probability distributions.