Comment Form for Soybean Producers

Below is the text of the letter that you will be sending to Administrator Jackson. After reading the letter, go to the bottom of the letter to complete your contact information and hit the Submit Comments button.

The Honorable Lisa Jackson Administrator U.S. Environmental Protection Agency Ariel Rios Building 1200 Pennsylvania Ave., N.W. Washington, D.C. 20460 RE: Docket No. EPA-HQ-OAR-2005-0161 Dear Administrator Jackson: As a soybean producer I appreciate the opportunity to submit comments on the proposed rule for implementation of the expanded Renewable Fuels Standard (RFS-2). First and foremost, the evidence demonstrates that U.S. biodiesel production is not the cause of significant land use change in Brazil or elsewhere. U.S. soybean farmers should not be penalized based on flawed and immature assumptions and theories. Further, we are concerned with the unnecessary and unworkable feedstock certification requirements that EPA has proposed. Soybean farmers have a great interest in the implementation of the RFS-2. Biodiesel production in the United States has predominantly utilized soybean oil as a feedstock. EPA must understand that soybeans are produced primarily for the meal that is used in the feed and food market. Historically, there has been surplus soybean oil that has depressed prices for soybeans. The EPA’s proposed rule on RFS-2 implementation is significantly flawed and would do unnecessary harm to the competitive position of the U.S. soy biodiesel industry. For soybean farmers the vital flaws and concerns with the RFS-2 proposed rule include: 1) Indirect Land Use - Flawed and immature assumptions and methodology utilized to measure the indirect land use impacts of U.S. soy biodiesel production. 2) Feedstock Certification – Unnecessary and onerous feedstock certification requirements. 3) Nitrogen – The EPA methodology contains a major error pertaining to the direct emission calculations for nitrogen in soybean production. 4) Co-Products - The EPA did not account for glycerine as a co-product. 5) Biodiesel Energy Balance - EPA inaccurately assesses the energy balance of biodiesel. 6) Biodiesel Pathway - The proposed pathway of using a 52-48 feedstock ratio of biodiesel feedstocks is not workable in practice. 7) GHG Calculations Must Account for Improved Agriculture Yields and Efficiency 8) Petroleum Baseline - EPA’s analysis compares estimated, future direct and indirect GHG emissions for biodiesel to only direct emissions for petroleum. We believe that corrected values for nitrogen emissions, co-products, and the energy balance from biodiesel production would result in soy biodiesel GHG emissions that are over 60% better than petroleum, easily exceeding the 50% GHG threshold called for under the RFS-2 biomass-based diesel schedule. An appropriate indirect land use analysis would further enhance soy biodiesel’s value relative to petroleum diesel. Again, thank you for the opportunity to comment on the proposed rule for implementation of the RFS-2.