DRAFT EPA/600/R-10/183A DO NOT CITE OR QUOTE January 2011 External Review Draft



## Biofuels and the Environment: First Triennial Report to Congress

NOTICE

THIS DOCUMENT IS A PRELIMINARY DRAFT. It has not been formally released by the U.S. Environmental Protection Agency and should not at this stage be construed to represent Agency p olicy. It is being circulated for comment on its technical accuracy and policy implications.

National Center for Environmental Assessment Office of Research and Development U.S. Environmental Protection Agency Washington, DCThis document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 DRAFT

— DO NOT CITE OR QUOTE DISCLAIMER

This document is distributed solely for the purpose of pre- disseminatio n peer review under applicable information quality guidelines. It has not been formally disseminated by EPA. It does not represent and should not be construed to represent any Agency determination or policy. Mention of trade names or commercial products does not constitute endorsement or recommendation of use.Executive Summary

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## E XECUTIVE 

## S UMMARY 1 2 This report is the first of the U.S. Environmental Agency’s (EPA’s) triennial reports to 3 Congress required under the 2007 Energy Independence and Security Act (EISA). EISA require s 4 EPA to revise the Renewable Fuel Standard (RFS) program to increase the volume of renewable 5 fuel bl ended into transportation fuel from 9 billion gallons per year in 2008 to 36 billion gallons 6 per year by 2022. The revised standards (RFS2) , finalized in 2010, establish new specific annual 7 volume requirements for cellulosic biofuel, biomass- based diesel, advanced biofuel, and total 8 renewable fuel in transportation fuel

. 9

EISA Section 204 calls for EPA to report to Congress on the environmental and resource 10 conservation impacts of increased biofuel production and use, including air and water quality, 11 soil qu ality and conservation, water availability, ecosystem healt h and biodiversity, invasive 12 species, and international impacts. This report reviews impacts and mitigation tools across the 13 entire biofuel supply chain, including feedstock production and logistics, and biofuel production, 14 distribution, and use. The report focuses on: 15

**•** Six feedstocks: The two most predominantly used ( corn starch and soybeans ), 16 and four others ( corn stover, perennial grasses, woody biomass , and algae ) that 17 represent a range of feedstocks currently under development. Because the RFS2 18 limits the amount of corn starch -derived biofuel that c ounts toward the volume 19 requirement in 2022 to 15 billion gallons, an increased reliance on other 20 feedstocks is predicted. 21 22

**•** Two biofuels: Ethanol (both conventional and cellulosic) and biomass-based 23 diesel , because they are the most commercially viable in 2010 and/or projected to 24 be the most commercially available by 2022. 25 26 This first report r epresents peer

- reviewed information available through July 2010 and 27 reflects the current uncertainty about biofuel production and use. Quantitative assessments are 28 presented, where possible, however, in most cases only qualitative assessments were feasible due 29 to uncertainties and the lack of data and analyses in the peer

- reviewed literature. Conclusions, 30 which do not account for existing or potential future mitigation measures or regulations, include: 31

**•** Life Cycle Assessment

. Some segments of the biofuel life cycle result in 32 greenhouse gas (GHG) emissions; however, as noted in EPA’s RFS2 Regulatory 33 Impact Analysis, when the entire biofuel life cycle is considered, the EISA

34 mandated revisions to the RFS2 program are expected to achieve a 138

- million 35 metric ton reduction in carbon dioxide-equivalent emissions by 2022 compared to 36 continued reliance on petroleum- based fuels. 37 38

**•** Water Quality. Ground and surface water quality can be impacted by erosion and 39 runoff of fertilizers and pesticides when feedstocks, particularly row crops such as 40 corn, are cultivated for biofue l; through pollutants in the wastewater discharged 41 from biofuel production facilities; and from leaks and spills during fuel transport. 42 43Executive Summary

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— DO NOT CITE OR QUOTE **•** Water Quantity. Effects of feedstock production on water availability vary 44 greatly by feedstock, processes used to produce the feedstock, and location. 45 Depending on location, the amount of water required to grow corn and soybean 46 for biofuel can be far greater than that required to grow perennial grasses, woody 47 biomass, and algae. Water used by biofuel production facilities is modest 48 compared to that required to produce biofuel feedstocks, and impacts depend on 49 the location of the facility in relation to water resources. 50 51

**•** Soil Quality. Increased cultivation of biofuel feedstocks is likely to affect soil 52 quality in various ways, depending on the feedstock. Some feedstocks may 53 contribute to detrimental e ffects , including increased soil erosion, decreased soil 54 organic matter content, increased soil GHG emissions, and increased nitrogen and 55 phosphorus losses to ground and surface waters. Other feedstocks may contribute 56 to advantageous effects such as increased soil carbon and reduced erosion. 57 58

**•** Air Quality. Air quality may be impacted by pollutants from f eedstock 59 production, such as farm equipment emissions and soil/dust particles made 60 airborne during field tillage and fertilizer application; by emissions from 61 combustion equipment used for energy production at biofuel production facilities; 62 and by evaporat ive and tailpipe emissions from combustion in vehicles

. 63 64

**•** Ecosystem. Increased cultivation of feedstocks for biofuel could significantly 65 affect biodiversity through habitat alteration when uncultivated land is put into 66 production; from exposure of flora and fauna to pesticides; or through 67 sedimentation and eutrophication in water bodies resulting from soil erosion and 68 nutrient runoff , respectively . Invasiveness potential of cultivated feedstocks is 69 also a concern

, but varies by feedstock

. 70 71

**•** International. Inc reases in U.S. biofuel production and consumption volumes 72 will affect many different countries as trade patterns and prices adjust in response 73 to global supply and demand. This will result in land use change and effects on air 74 quality, water quality, and b iodiversity. Direct and indirect land use changes will 75 likely occur across the globe as the U.S. and other biofuel feedstock-producing 76 countries alter their agricultural sectors to allow for greater biofuel production. 77 Many locations where biofuel production is growing , such as Indonesia, 78 Malaysia, and Brazil, are also areas of high biodiversity value. Depending where 79 biofuel feedstock production occurs, and to what extent the level of production 80 increases with time, impacts to biodiversity could be signifi cant. 81 82 Most activities, processes, and products associated with the biofuel supply chain are 83 already regulated, subject to limitations , or mitigated through various approaches. To further 84 address adverse impacts, EPA recommends: 85

**•** Develop ing and evaluating Environmental Life Cycle Assessments for biofuels. 86 87

**•** Ensuring the success of current and future environmental biofuel research through 88 improved cooperation and sustained support. 89 90Executive Summary

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— DO NOT CITE OR QUOTE **•** Improving the ability of federal agencies (within their existing authorities) to 91 develop and implement best management and conservation practices and policies 92 that will avoid or mitigate negative environmental effects from biofuel production 93 and use. 94 95

**•** Engaging the international scientific communit y in cooperative efforts to identify 96 and implement sustainable biofuel practices that minimize environmental impact. 97

Because biofuel impacts cross many topics and Agency responsibilities, EPA likely will 98 address these recommendations through continued and strengthened cooperation with federal 99 agencies and international partners, including the U.S. Departments of Agriculture and Energy. 100

101Table of Contents

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## Table of Contents 1 2 Page 3

E XECUTIVE S UMMARY

...................................................................................................................... I 4

1. I NTRODUCTION ................................................................................................................. 1-1 5

2. B ACKGROUND AND A PPROACH ......................................................................................... 2-1 6 2.1 EISA and RFS2 Requirements for Biofuel Production and Use ......................... 2-1 7 2.2 Projected Fuel and Feedstock Use to Meet Required RFS2 Targets through 8 2022................................

................................ ...................................................... 2-2 9 2.3 Assessment of the Environmental and Resource Conservation Impacts of 10 Biofuels ................................................................................................................ 2-4 11 2.3.1 Approach ................................................................................................ 2-4 12 2.3.2 Biofuel Supply Chain ............................................................................... 2-5 13 2.3.3 Feedstocks and Fuels Discussed in This Report ...................................... 2-5 14 2.3.4 Impacts Discussed in This Report............................................................ 2-6 15 2.4 Regulatory Authority Relevant to Biofuel Environmental Impacts .................... 2-9 16

3. E NVIRONMENTAL I MPACTS OF S PECIFIC F EEDSTOCKS ...................................................... 3-1 17 3.1 Introduction .......................................................................................................... 3-1 18 3.2 Row Crops (Corn, Corn Stover, Soybeans) ......................................................... 3-2 19 3.2.1 Introduction .............................................................................................. 3-2 20 3.2.1.1 Current and Projected Cultivation ......................................... 3-3 21 3.2.1.2 Overview of Environmental Impacts ..................................... 3-6 22 3.2.2 Water Quality ........................................................................................... 3-9 23 3.2.2.1 Nutrient Loading .................................................................. 3-10 24 3.2.2.2 Sediment .............................................................................. 3-15 25 3.2.2.3 Pesticides

................................ .............................................. 3-16 26 3.2.2.4 Pathogens and Biological Contaminants ............................. 3-17 27 3.2.3 Water Quantity ....................................................................................... 3-18 28 3.2.3.1 Water Use

................................ ............................................. 3-18 29 3.2.3.2 Water Availability ................................................................ 3-19 30 3.2.4 Soil Quality ............................................................................................ 3-20 31 3.2.4.1 Soil Erosion .......................................................................... 3-20 32 3.2.4.2 Soil Organic Matter .............................................................. 3-21 33 3.2.5 Air Quality ............................................................................................. 3-22 34 3.2.5.1 Cultivation and Harvesting .................................................. 3-22 35 3.2.5.2 Fertilizers and Pesticides ...................................................... 3-23 36 3.2.6 Ecosystem Impacts

................................ ................................................. 3-23 37 3.2.6.1 Eutrophication, Erosion, and Biodiversity Loss .................. 3-23 38 3.2.6.2 Invasive Plants ..................................................................... 3-25 39 3.2.7 Assessment ............................................................................................. 3-25 40 3.2.7.1 Key Uncertainties and Unknowns ....................................... 3-26 41 3.3 Perennial Grasses ............................................................................................... 3-28 42Table of Contents TABLE OF CONTENTS (Continued)

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— DO NOT CITE OR QUOTE 3.3.1 In troduction ............................................................................................ 3-28 43 3.3.1.1 Current and Projected Cultivation ....................................... 3-30 44 3.3.1.2 Overview of Environmental Impacts ................................... 3-31 45 3.3.2 Water Quality ......................................................................................... 3-31 46 3.3.2.1 Nutrient Loading .................................................................. 3-32 47 3.3.2.2 Sediment .............................................................................. 3-32 48 3.3.2.3 Pestic ides

................................ .............................................. 3-33 49 3.3.2.4 Pathogens and Biological Contaminants ............................. 3-33 50 3.3.3 Water Quantity ....................................................................................... 3-33 51 3.3.3.1 Wa ter Use

................................ ............................................. 3-33 52 3.3.3.2 Water Availability ................................................................ 3-34 53 3.3.4 Soil Quality ............................................................................................ 3-34 54 3.3.4.1 Soil Erosion .......................................................................... 3-34 55 3.3.4.2 Soil Organic Matter .............................................................. 3-34 56 3.3.5 Air Quality ............................................................................................. 3-35 57 3.3.6 Ecosystem Impacts

................................ ................................................. 3-36 58 3.3.6.1 Biodiversity .......................................................................... 3-36 59 3.3.6.2 In vasive Plants ..................................................................... 3-36 60 3.3.7 Assessment ............................................................................................. 3-38 61 3.3.7.1 Key Uncertainties and Unknowns ....................................... 3-38 62 3.4 Woody Biomass ................................................................................................. 3-39 63 3.4.1 Introduction ............................................................................................ 3-39 64 3.4.1.1 Current and Projected Production Areas .............................. 3-40 65 3.4.1.2 Overview of Environmental Impacts ................................... 3-41 66 3.4.2 Water Quality ......................................................................................... 3-41 67 3.4.2.1 Nutrients ............................................................................... 3-42 68 3.4.2.2 Sediment .............................................................................. 3-43 69 3.4.2.3 Pesticides

................................ .............................................. 3-43 70 3.4.3 Water Quantity ....................................................................................... 3-43 71 3.4.3.1 Water Use

................................ ............................................. 3-43 72 3.4.3.2 Wate r Availability ................................................................ 3-44 73 3.4.4 Soil Quality ............................................................................................ 3-44 74 3.4.4.1 Soil Erosion .......................................................................... 3-44 75 3.4.4.2 So il Organic Matter .............................................................. 3-44 76 3.4.4.3 Soil Nutrients ....................................................................... 3-45 77 3.4.5 Air Quality ............................................................................................. 3-45 78 3.4.6 Ecosys tem Impacts

................................ ................................................. 3-46 79 3.4.6.1 Biodiversity .......................................................................... 3-46 80 3.4.6.2 Invasive Plants ..................................................................... 3-46 81 3.4.7 Assessment ............................................................................................. 3-47 82 3.4.7.1 Key Uncertainties and Unknowns ....................................... 3-47 83 3.5 Algae .................................................................................................................. 3-48 84 3.5.1 Introduction ............................................................................................ 3-48 85 3.5.1.1 Current and Projected Cultivation ....................................... 3-49 86Table of Contents TABLE OF CONTENTS (Continued)

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— DO NOT CITE OR QUOTE 3.5.1.2 Overview of Environmental Impacts ................................... 3-49 87 3.5.2 Water Quality ......................................................................................... 3-49 88 3.5.3 Water Quantity ....................................................................................... 3-50 89 3.5.3.1 Wa ter Use

................................ ............................................. 3-50 90 3.5.3.2 Water Availability ................................................................ 3-50 91 3.5.4 Soil Quality ............................................................................................ 3-51 92 3.5.5 Air Quality ............................................................................................. 3-51 93 3.5.6 Ecosystem Impacts

................................ ................................................. 3-51 94 3.5.6.1 Biodiversity .......................................................................... 3-51 95 3.5.6.2 In vasive Algae ..................................................................... 3-52 96 3.5.7 Assessment ............................................................................................. 3-52 97 3.5.7.1 Current and Future Impacts ................................................. 3-52 98 3.5.7.2 Key Uncertainties and Unknowns ....................................... 3-53 99 3.6 Waste

- Based Feedstocks .................................................................................... 3-54 100 3.6.1 Introduction ............................................................................................ 3-54 101 3.6.2 Municipal Solid Waste ........................................................................... 3-54 102 3.6.3 Other Wastes .......................................................................................... 3-55 103 3.6.4 Environmental Impacts of Waste

- Based Biofuel ................................... 3-55 104 3.7 Summary of Feedstock-Depende nt Impacts on Specialized Habitats ............... 3-56 105 3.7.1 Forests .............................................................................................. 3-56 106 3.7.2 Grasslands .............................................................................................. 3-57 107 3.7.3 Impact s on Wetlands .............................................................................. 3-58 108 3.8 Genetically Engineered Feedstocks ................................................................... 3-59 109

4. B IOFUEL P RODUCTION , T RANSPORT , S TORAGE AND E ND U SE ......................................... 4-1 110 4.1 Introduction .......................................................................................................... 4-1 111 4.2 Feedstock Logistics .............................................................................................. 4-2 112 4.2.1 Ha ndling, Storage, and Transport ............................................................ 4-2 113 4.2.1.1 Ethanol ................................................................................... 4-2 114 4.2.1.2 Biodiesel ................................................................................ 4-2 115 4.3 Biofuel Production ............................................................................................... 4-3 116 4.3.1 Biofuel Conversion Processes.................................................................. 4-3 117 4.3.1.1 Ethanol ................................................................................... 4-3 118 4.3.1.2 Biodiesel ................................................................................ 4-4 119 4.3.2 Air Quality ............................................................................................... 4-5 120 4.3.2.1 Ethanol ................................................................................... 4-7 121 4.3.2.2 Biodiesel ................................................................................ 4-7 122 4.3.2.3 Greenhouse Gases .................................................................. 4-7 123 4.3.3 Water Quality and Availability ................................................................ 4-9 124 4.3.3.1 Ethanol ................................................................................. 4-10 125 4.3.3.2 Distillers Grain with Solubles .............................................. 4-11 126 4.3.3.3 Biodiesel .............................................................................. 4-12 127 4.3.4 Impacts from Solid Waste Generation ................................................... 4-13 128 4.4 Biofuel Distribution ........................................................................................... 4-13 129Table of Contents TABLE OF CONTENTS (Continued)

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— DO NOT CITE OR QUOTE 4.4.1 Air Quality ............................................................................................. 4-13 130 4.4.1.1 Ethanol ................................................................................. 4-13 131 4.4.1.2 Biodiesel .............................................................................. 4-14 132 4.4.2 Water Quality ......................................................................................... 4-14 133 4.4.2.1 Ethanol ................................................................................. 4-15 134 4.4.2.2 Biodiesel .............................................................................. 4-16 135 4.5 Biofuel End Use ................................................................................................. 4-16 136 4.5.1 Air Quality ............................................................................................. 4-17 137 4.5.1.1 Ethanol ................................................................................. 4-17 138 4.5.1.2 Biodie sel .............................................................................. 4-17 139

5. I NTERNATIONAL C ONSIDERATIONS ................................................................................... 5-1 140 5.1 Introduction .......................................................................................................... 5-1 141 5.2 Import/Export Volumes ....................................................................................... 5-3 142 5.3 Environmental Impacts of Direct and Indirect Land Use Changes ..................... 5-6 143 5.4 Other Environmental Impacts ............................................................................ 5-10 144 5.5 Concluding Remarks .......................................................................................... 5-12 145

6. C ONCLUSIONS AND R ECOMMENDATIONS .......................................................................... 6-1 146 6.1 Conclusions .......................................................................................................... 6-1 147 6.1.1 Emissions Reduction ................................................................................ 6-1 148 6.1.2 Feedstock Production ............................................................................... 6-1 149 6.1.2.1 Overview ................................................................................ 6-1 150 6.1.2.2 Conclusions ............................................................................ 6-3 151 6.1.3 Biofuel Production, Transport, and Storage ............................................ 6-4 152 6.1.3.1 Overview ................................................................................ 6-4 153 6.1.3.2 Biofuel Transport and Storage ............................................... 6-7 154 6.1.4 Biofuel End Use ....................................................................................... 6-7 155 6.1.5 International Considerations .................................................................... 6-7 156 6.2 Recommendations ................................................................................................ 6-8 157 6.2.1 Comprehensive Environmental Assessment ............................................ 6-8 158 6.2.2 Coordinated Research .............................................................................. 6-8 159 6.2.3 Mitigation of Impacts from Feedstock Production .................................. 6-9 160 6.2.4 International Cooperation to Implement Sustainable Biofuel 161 Practices ................................................................................................ 6-9 162

7. A SSESSING E NVIRONMENTAL I MPACTS FROM B IOFUELS : 2013 TO 2022........................... 7-1 163 7.1 Introduction .......................................................................................................... 7-1 164 7.2 Components of the 2013 Assessment .................................................................. 7-1 165 7.2.1 Life Cycle Assessments ........................................................................... 7-2 166 7.2.2 Environmental Risk Assessment.............................................................. 7-2 167 7.2.3 Human Health Assessment ...................................................................... 7-2 168 7.2.4 Conceptual Models .................................................................................. 7-3 169 7.2.5 Monitoring, Measures, and Indicators ..................................................... 7-3 170 7.2.6 Scenarios ................................................................................................ 7-6 171Table of Contents TABLE OF CONTENTS (Continued)

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— DO NOT CITE OR QUOTE 7.2.7 Other Co mponents ................................................................................... 7-8 172

8. R EFERENCES ..................................................................................................................... 8-1 173 174 Appendix A: GLOSSARY AND ACRONYM S ...................................................................... A-1 175 176 Appendix B: SUMMARY OF SELECTED STATUTORY AUTHORITIES HAVING 177 POTENTIAL IMPACT ON THE PRODUCTION 178 AND USE OF BIOFUELS ..................................................................................B-1 179 180 Appendix C: BASIS FOR FIGURES 6 -1, 6- 2, AND 7 -3 .........................................................C-1 181 182 Appendix D: CONCEPTUAL MODELS ................................................................................. D-1 183 184 185List of Tables

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— DO NOT CITE OR QUOTE LIST OF TABLES 186 187 Page 188 189 Table 2 -1: RFS2 Renewable Fuel Requirements (billion gallons per year) ............................... 2-2 190

Table 2 -2: Overview of Environmental and Resource Conservat ion Impacts Addressed in 191 This Report....................................................................................................................... 2-7 192

Table 2 -3: Overview of Environmental and Resource Conservation Impacts on Specific 193 Ecosystems Addressed in This Report ............................................................................. 2-8 194

Table 3 -1: Primary Fuels and Feedstocks Discussed in this Report ............................................ 3-2 195

Table 3 -2: Impacts Associated with Biofuel Feedstock Production (Corn Starch, Corn 196 Stover, and Soybean) ....................................................................................................... 3-7 197

Table 3 -3: Comparison of Agricultural Intensity Metrics for Perennial Grass and 198 Conventional Crops ....................................................................................................... 3-32 199

Table 3 -4: Comparison of Agricultural Intensity Metrics for Short-Rotation Woody Crops 200 and Conventional Crops ................................................................................................. 3-42 201

Table 3 -5: Overview of Impacts on Forests from Different Types of Biofuel Feedstocks ....... 3-57 202

Table 3 -6: Overview of Impacts on Grasslands from Different Types of Biofuel 203 Feedstocks ...................................................................................................................... 3-58 204

Table 3 -7: Overview of Impacts on Wetland s from Different Types of Biofuel Feedstocks

.... 3-58 205

Table 4 -1. 2009 Summary of Inputs to U.S. Biodiesel Production ............................................. 4-4 206

Table 4 -2. Lifecycle GHG Thresholds Specified in EISA (percent reduction from 2005 207 baseline)

........................................................................................................................... 4-8 208

Table 5 -1: Top Fuel Ethanol-Producing Countries from 2005 to 2009 (All figures are in 209 millions of gallons)

.......................................................................................................... 5-2 210

Table 5 -2: RFS2 RIA Projected Imports and Corn Ethanol Production, 2011-2022 .................. 5-3 211

Table 5 -3: Historical U.S. Domestic Ethanol Production and Imports ........................................ 5-4 212

Table 5 -4: 2008-2009 Brazilian Ethanol Exports by Country of Destination ............................. 5-4 213

Table 5 -5: 2008 U.S. Biodiesel Balance of Trade ....................................................................... 5-6 214

Table 5

- 6: Changes in International Crop Area Harvested by Renewable Fuel Anticipated 215 to Result from EISA Requirements by 2022 ................................................................... 5-8 216List of Figures

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— DO NOT CITE OR QUOTE LIST OF FIGURES 217 218 Page 219 220 Figure 2

- 1: Projected Renewable Fuel Volumes to Meet RFS2 Targets

..................................... 2-3 221

Figure 2 -2: Examples of Feedstocks Available for Biofuel Production ...................................... 2-4 222

Figure 2 -3: Five Stages of the Biofuel Supply Chain .................................................................. 2-5 223

Figure 2 -4: Environmental and Resource Conservation Issues Addressed in this Report .......... 2-6 224

Figure 3 -1: U.S. Corn Production ................................................................................................ 3-2 225

Figure 3 -2: Planted Corn Acres by County, for Selected States (2009) ...................................... 3-3 226

Figure 3 -3: Planted Soybean Acres by County (2009) ................................................................ 3-6 227

Figure 3 -4: Change in Number of U.S. C oastal A reas E xperiencing Hypoxia from 1960 228 to 2008 ........................................................................................................................... 3-13 229

Figure 3

- 5: Generalized Map of Potential Rain -fed Feedstock Crops in the Conterminous 230 United States Based on Field Plots and Soil, Prevailing Temperature, and Rainfall 231 Patterns

........................................................................................................................... 3-31 232

Figure 3 -6: Estimated Forest Residues by County .................................................................... 3-41 233

Figure 4 -1: Sources of Cr iteria Air Pollutant and Toxics Emissions Associated with 234 Production and Use of Biofuel ......................................................................................... 4-1 235

Figure 5 -1: Biofuel Production Map ............................................................................................ 5-1 236

Figure 5 -2: Historic U.S. Ethanol Export Volumes and Destinations ......................................... 5-5 237

Figure 5 -3: Change in U.S. Exports by Crop Anticipated to Result from EISA 238 Requirements by 2022 (tons per 1,000 gallons of renewable fuel) ................................. 5-7 239

Figure 5 -4: International Land Use Change GHG Emissions by Renewable Fuel 240 Anticipated to Result from EISA Requirements by 2022 (kgCO2e/mmBTU) ............... 5-8 241

Figure 5 -5: Harvested Crop Area Changes by Region Anticipated to Result from EISA 242 Requirements by 2022, 2022 (ha / billion BTU) ............................................................. 5-9 243

Figure 5

- 6: Pasture Area Changes in Brazil by Renewable Fuel Anticipated to Result 244 from EISA Requirements by 2022 (ha / billion BTU) ................................................... 5-10 245

Figure 6

- 1: Maximum Potential Range of Environmental Impacts (on a Per Unit Area 246 Basis) Resulting from Cultivation and Harvesting of the Six Biofuel Feedstocks 247 Considered in This Report ............................................................................................... 6-2 248List of Figures

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— DO NOT CITE OR QUOTE Figure 6

- 2: Maximum Potential Range of Environmental Impacts (on a Per Unit Volume 249 Basis) Resulting from Ethanol and Biodiesel Production, Transport, and Storage ......... 6-6 250

Figure 7 -1: Conceptual Diagram of the Environmental Impacts of Biofuel Feedstock 251 Production ........................................................................................................................ 7-4 252

F igure 7 -2: Conceptual Diagram of the Environmental Impacts of Biofuel Production and 253 Use

................................................................................................................................... 7-5 254

Figure 7

- 3: Cumulative Domestic Environmental Impacts of All Steps in the Biofuel 255 Supply Chain System under Three Scenarios in 2022 ..................................................... 7-7 256

257Chapter 1 : Introduction

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— DO NOT CITE OR QUOTE 1. I NTRODUCTION 1

In December 2007, Congress enacted t he Energy Independence and Security Act (Public 2 Law 110-140) (EISA) to reduce U.S. energy consumption and dependence on foreign oil, and to 3 address climate change through research and implementation of strategies to reduce greenhouse 4
gases . Accordingly, EI SA requires the U.S. Environmental Protection Agency (EPA) to revise 5 the Renewable Fuel Standard (RFS) program, created under the 2005 Energy Policy Act, a to 6 increase the volume of renewable fuel b

EPA finalized revisions to the RFS program in February 2010. The revised statutory 9 requirements (commonly known as the RFS2) establish new specific annual volume standards 10 for cellulo sic biofuel, biomass- based diesel, advanced biofuel, and total renewable fuel that must 11 be used in transportation fuel (see Chapter 2). Meeting RFS2 in 2022 will result in biofuels 12 making up an estimated 7 percent of fuels (by volume) used for transportation (U.S. EPA, 13 2010a). The purpose of this report is to examine the environmental and resource conservation 14 impacts of this change, as required under EISA Section 204. 15 required to be blended into transportation fuel from 9

7 billion gallons per year in 2008 to 36 billion gallons per year by 2022. 8

EISA Section 204 calls for EPA to report to Congress every three years on the 16 environmental and resource conservation impacts of increased biofuel production and use as 17 follow s: 18

In General. Not later than 3 years after the enactment of this section and every 3 years 19 thereafter, the Administrator of the Environmental Protection Agency, in consultation with the 20 Secretary of Agriculture and the Secretary of Energy, shall assess and report to Congress on the 21 impacts to date and likely future impacts of the requirements of Section 211(o) of the Clean Air 22 Act c

1. Environmental issues, including air quality, effects on hypoxia, pesticides, on the following: 23

d

2. Resource conservation issues, including soil conservation, water availability, and 27 ecosystem health and biodiversity, including impacts on forests, grasslands, and 28 wetlands. 29 24 sediment, nutrient and pathogen levels in waters, acreage and function of waters, 25 and soil environmental quality. 26

3. The growth and use of cultivated invasive or noxious plants and their impacts on 30 the environment and agriculture. 31 4.

.... The report shall include the annual volume of imported renewable fuels and 32 feedstocks for renewable fuels, and the environmental impacts outside the United 33

a The 2005 Energy Policy Act amended the Clean Air Act and established the first national renewable fuel standards. The statute specifies the total volume of renewable fuel that is to be used based on the volume of gasoline sold in the U.S. each year, with the total volume of renewable fuel increasing over time to 7.5 billion gallons in 2012

. b To be considered “renewable,” fuels produced by biorefineries constructed after EISA’s enactment on December 19, 2007, must generally achieve at least a 20 percent reduction in life cycle greenhouse gas emissions compared to petroleum fuels.

c EISA 2007 amended Section 211(o) of the Clean Air Act to include the definitions and requirements of RFS2.

d Pes ticides include antimicrobials, fungicides, herbicides, insecticides, and rodenticides.Chapter 1 : Introduction

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— DO NOT CITE OR QUOTE States of producing such fuels and feedstocks. The report required by this 34 subsection shall include recommendations for actions to address any adverse 35 impacts found. 36 37 This is the first of EPA’s triennial reports on the current and potential future 38 environmental impacts associated with the requirements of Section 211(o) of the Clean Air Act. 39 This report reviews environmental and resource conservation impacts, as well as mitigation tools 40 to reduce these impacts, across major components of the biofuel supply chain: feedstock 41 production, feedstock logistics, biofuel production, biofuel distribution, and biofuel use. 42

This report emphasizes domestic impacts ; however, the substantial market created for 43 biofuels by the U.S , Brazil, and other countries has important global implications . For example, 44 countries that produce feedstock s, now or in the future, which are converted to biofuels that 45 qualify for use in the U.S. will experience direct impacts; other countries will have to adapt to 46 changing agricultural commodity distributions that result from diversion of food exports to 47 biofuel production. As required under EISA Section 204, this report describes the impacts of 48 increased feedstock and biofuel production in other countries as a result of U.S. policy. 49

This first triennial Report to Congress represents the best available information through 50 July 2010 and reflects the current understanding about biofuel production and use, including 51 input from the U.S Departments of Agriculture and Energy, with whom EPA consulted during 52 development of this report. Quantitative assessments a re presented, where possible, using 2010 53 or the most recently available data; however, in most cases only qualitative assessments were 54 feasible due to uncertainties and lack of data and analyses in the peer

- reviewed literature. Future 55 reports will reflect the evolving understanding of biofuel impacts in light of new research results 56 and data as they become available. This initial report to Congress serves as a starting point for 57 future assessments and for taking action to achieve the goals of EISA

. 58

59Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE 2. B ACKGROUND AND A PPROACH 1

2.1

RFS2 (the Renewable Fuel Standard as amended by t he Energy Independence and 3 Security Act [ EISA ]) establishes new specific annual volume standards for four categories of 4 renewable fuels that must be used in transportation fuel EISA and RFS2 Requirements for Biofuel Pro duction and Use 2

5 : cellulosic biofuel, biomass- based 5 diesel, advanced biofuel , and total renewable fuel (s ee Glossary in Appendix A for fuel 6 definitions). Under RFS2, conventional biofuel (i.e., ethanol derived from corn starch) with a 7 maximum volume target and “additional renewable fuels” 6 are included as eligible fuels to meet 8 the total renewable fuel standard. The revised statutory requirements also include new definitions 9 and criteria for both renewable fuels and the feedstocks used to produce them, 7

Table 2-1 shows the RFS2 annual renewable fuel standards through 2022. Total 14 renewable fuel under the standard will increase to 36 billion gallons per year (bgy) by 2022 (of 15 which corn starch ethanol is not to exceed 15 bgy). 16 including new 10 greenhouse gas emi ssion (GHG) reduction thresholds ( as determined by the life cycle assessment 11 that EPA conducted as part of its Regulatory Impact Analysis [RIA] during the final RFS2 12 rulemaking). 13

While EISA establishes the renewable fuel volumes shown in Table 2-1, it also requires 17 the EPA Administra tor each November to set the volume standards for the following year based 18 in part on information provided by the Energy Information Administration (EIA) and other data 19 indicating the commercial capacity for producing cellulosic biofuels. EISA therefore re quires the 20 EPA Administrator to adjust the cellulosic standard, and potentially the total advanced biofuel 21 and total renewable fuel standards, each year based on this assessment. For 2010, the 22 Administrator adjusted the cellulosic standard from 0.1 bgy (100 million gallons per year) in 23 RFS2 to 5.0 million gallons, but did not adjust the total advanced or total renewable fuel 24 standard. 8

5 Transportation fuel includes fuels used in motor vehicles, motor vehicle engines, non

- road vehicles

, or non

- road engines (except for ocean

- going vessels)

. Therefore, the final 2010 standard for total renewable fuel is set at 12.95 bgy, with 25 specific targets for cellulosic biofu el (5.0 million gallons per year), biomass-based diesel (1.15 26 bgy [ combining the 2009 and 2010 standards as proscribed in RFS2]), and total advanced biofuel 27 (0.95 bgy). 28

6 EISA defines “ additional renewable fuel" as “ fuel produced from renewable biomass that is used to replace or reduce fossil fuels used in heating oil or jet fuel. ” Though RFS2 does not specify a volume standard for this fuel category, it does allow renewable fuel blended into heating oil or jet fuel to count toward achieving the standard for total renewable fuel. (T his contrasts with the original RFS [RFS1] , which did not provide credit for renewable fuel blended into non

- road fuel. ) More information about “ additional renewable fuel ” can be found in Section II.b.e of the final RFS2 rule available at http://www.epa.gov/otaq/fuels/renewablefuels/regulations.htm

. 7 EISA requires that all renewable fuel be made from feedstocks that meet the new definition of renewable biomass

, which includ es certain land use restrictions. For full details, see Section 3.1.

8 Although EISA specified a 2010 cellulosic biofuel requirement of 100 million gallons/year, as shown in Table 2

- 1, EPA determined that this level was not achievable for 2010. EIA projected 5 million gallons/year of cellulosic production for 2010 (6.5 million gallons ethanol equivalent)

, and EPA accepted this as the 2010 standard. Wh ile this is lower than the level specified in EISA, no change to the advanced biofuel and total renewable fuel standards was warranted due to the inclusion of an energy

- based equivalence value for biodiesel and renewable diesel.Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE Table 2

- 1 : RFS2 Renewable Fuel Requirements (billion gallons per year) a , b

Year Renewable Fuel

Conventional Biofuel Advanced Biofuel

Total Renewable Fuel Cellulosic Biofuel Biomass

- Based Diesel Advanced Biofuel c

2008 9.0 n/a n/a n/a 9.0
2009 10.5 n/a 0.5 0.6 11.1

2010 12.0 0.1 d 0.65 0.95 12.95
2011 12.6 0.25 0.80 1.35 13.95
2012 13.2 0.5 1.0 2.0 15.2
2013 13.8 1.0 TBD e 2.75 16.55
2014 14.4 1.75 TBD e 3.75 18.15
2015 15.0 3.0 TBD e 5.5 20.5

2016 15.0 4.25 TBD e 7.25 22.25
2017 15.0 5.5 TBD e 9.0 24.0
2018 15.0 7.0 TBD e 11.0 26.0
2019 15.0 8.5 TBD e 13.0 28.0
2020 15.0 10.5 TBD e 15.0 30.0
2021 15.0 13.5 TBD e 18.0 33.0
2022 15.0 16.0 TBD e 21.0 36.0

a – T he requirements for cellulosic biofuel, biomass

- based diesel, advanced biofuel, and total renewable fuel are 29 minimum required volumes that must be achieved and may be exceeded. The conventional biofuel requirement is a 30

cap that cannot be exceeded. 31 b – Note that t he RFS2 volume requirements are nested: cellulosic biofuel and biomass

- based diesel are forms of 32 advanced biofuel; and advanced biofuel and conventional biofuel are form s of total renewable fuel. 33

c – Note that the sum of the required amounts of cellulosic biofuel and biomass

- based diesel is less than the required 34 volume of advanced biofuel. The additional volume to meet the advanced fuel requirement may be achieved by the 35 additional cellulosic biofuel and biomass

- based diesel (i.e., beyond the requir ed minimum) and/or by other fuels that 36 meet the definition of advanced biofuel (e.g., sugarcane ethanol). 37 d – As described above, and as allowed under EISA, the EPA Administrator determined that original RFS2 standard 38 of 0.1 bgy for cellulosic biofuel was not achievable for 2010 and therefore decreased this standard to 5 million 39 gallons for 2010

. 40

e – To be determined by EPA through a future rulemaking, but no less than 1.0 billion gallons. This requirement was 41 designated under EISA as “to be determined” with a minimum requirement because of the uncertainty about future 42 capacity to produce fuel that meets the biomass

- based diesel definition. 43 Source: U.S. EPA, 2010b. 44 45 2.2

Figure 2-1 summarizes the fuel types and volumes projected to meet the required targets 47 through 2022, as estimated in the RFS2 Regulatory Impact Analysis. Although actual volumes 48 and feedstocks will likely be different, EPA believes the projections are within the range of 49 expected outcomes when the standards are met (U.S. EPA, 2010b). 50 Projected Fuel and Feedstock Use to Meet Required RFS2 Targets through 2022 46Chapter 2 : Background and Approach

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Source: U.S. EPA, 2010b. 52

Figure 2-1 : Projected Renewable Fuel Volumes to Meet RFS2 Targets 53

In 2009, corn ethanol constituted 95 percent of total U.S.-produced renewable fuel, with 54 biodiesel made from soybean oil, other virgin vegetable oils, rendered fats, greases, and corn oil 55 from ethanol production accounting for almost all the remaining biofuel consumed (FAPRI, 56 2010a; EIA, 2010). However, a s technologies improve, EPA expects more advanced cellulosic 57 feedstocks

, such as agricultural residues (e.g., corn stover, sugarcane bagasse, wheat residue, 58 sweet sorghum pulp), forestry biomass, urban biomass waste, and dedicated energy crops (e.g., 59 switchgrass) to produce biofuels (Figure 2-2) (U.S. EPA, 2010b). P resent research is focused on 60 improving technologies to convert different feedstocks to biofuels in an economically viable 61 manner, and determining sustai nable biofuel production methods. 62Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE 63
Figure 2-2 : Examples of Feedstocks Available for Biofuel Production 64

With respect to biodiesel, EPA expects continued use of soybean oil, which made up 54 65 percent of feedsto ck used for biodiesel in 2009 (EIA, 2010), as well as a varying percentage of 66 other vegetable oils, rendered fats, greases, and corn oil from ethanol production through 2022 67 (see Table 4 -1 for a more detailed breakdown) (U.S. EPA, 2010b). Algae could poten tially 68 provide large volumes of oil for the production of biomass- based diesel. However, several 69 hurdles, including technical issues, will likely limit production volumes within the 2022 70 timeframe (U.S. EPA, 2010b). 71

Imported sugarcane ethanol, also represents a significant potential supply of biofuel by 72 2022 (U.S. EPA, 2010b). In 2009, the United States imported 198 million gallons of ethanol 73 (EIA, n.d. [d]). Import volumes are expected to grow as U.S. demand increases to meet the 74 biofuel targets. 75

2.3

2.3.1 Approach 77 Assessment of the Environmental and Resource Conservation Impacts of Biofuels 76

This report presents a comprehensive survey of environmental evaluations across the 78 biofuel supply chain (see below), including current and anticipated future feedstock production 79 and logistics and biofuel production, distribution, and use. It summarizes much of the available 80 information and identifies research needed to evaluate potential environmental impacts from a 81 life cycle perspective and quantify them using more substantive and systematic assessment tools. 82 This report therefore is the first step towards conducting a biofuels environmental l ife c ycle 83 assessment (LCA), which EPA will conduct for its future Report s to Congress (see Chapter 7). 84

Life cycle a ssessment evaluates environmental impacts resulting from all stages of a 85 product’s development— from extraction of fuel for power to production, marketing, use, and 86Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE disposal. EPA has begun to collaborate with partners and stakeholders to formulate specific 87 questions, establish boundaries, and identify critical assessment endpoints to be used in modeling 88 the input and output data for comprehensively assessing potential impacts across the biofuel 89 supply chain and integrating environmental risk assessment (ERA) tools. Although this report 90 does not attempt a comprehensive biofuels environmental LCA, as part of the EISA

- mandated 91 revisions to the RFS program, EPA conducted a life cycle assessment of GHG emissions from 92 increased r enewable fuels use, which projected a 138- million metric ton reduction in CO 2 - 93 equivalent emissions by 2022 (U.S. EPA, 2010b). Section 4.3.2.3 provides more details about the 94 LCA methodology and results. This work , which will provide the foundation for future versions 95 of this Report to Congress, will draw from the considerable work that has already been done to 96 develop LCA and other methodologies, including ecological and human health risk assessment
, 97
to assess imp acts of specific biofuel products and processes. 98

2.3.2 Biofuel Supply Chain 99

There are five main stages in the biofuel supply chain: feedstock production, feedstock 100 logistics, fuel production, fuel distribution, and fuel use (Figure 2- 3). The specific impacts 101

ass ociated with a particular feedstock or biofuel will vary depending on many factors, including 102 the type, source, and method of feedstock production; the technology used to convert the 103 feedstock to fuel; methods used and distances traveled to transport biofu els; the types and 104 quantities of biofuels used; and controls in place to avoid or mitigate any impacts. 105

106
Figure 2-3: Five Stages of the Biofuel Supply Chain 107

2.3.3 Feedstock s and Fuels Discussed in This Report 108

There is uncertainty regarding which feedstocks will be used to meet the RFS2 targets in 109 the mid - to long-term time horizon. A few feedstocks are already in use, including primarily corn 110 and soybean, as well as others in smaller quantities. Other feedstocks are in the early stages of 111 research and development or their potential future commercial viability is still unknown. This 112 report focuses on six feedstocks: the most predominantly used (corn and soybeans) and four 113 others (corn stover, perennial grasses, woody biomass, and algae) that represent a range of 114 feedstocks currently under development. The biofuels highlighted in this report are ethanol (both 115 conventional and cellulosic) and biomass- based diesel . Ethanol and biomass- based diesel are the 116 focus becau se they are currently the most commercially viable and/or are projected to be the 117
most commercially available by 2022 , and they are the primary fuels currently projected to meet 118 RFS2. Future reports will anal yze other feedstocks and fuels. 119Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE *

**

* 2.3.4 Impacts Discussed in This Report 120

This report focuses on specific environmental and resource conservation impacts 121 specified in EISA Section 204, as shown in Figure 2-4 and described in Table s 2-2 and 2-3. This 122 report do es not include extensive discussion of carbon dioxide or other greenhouse gas 123 emissions ; interested readers are referred to the EPA’s RFS2 Regulatory Impact Analysis (U.S. 124 EPA, 2010b). A short discussion is provided in Section 4.3.2.3 of this report. The environmental 125 and resource conservation impacts discussed in this report reflect a complex set of interactions 126 and feedbacks between land, soil, air, and water; future versions of this report will explore 127 analysis of these important complexit ies as enhanced data and analysis tools become available. 128 Thi s report does not attempt to conduct a quantitative analysis of the range of impacts associated 129 with increased production of biofuel. Instead, it represents a compilation of available information 130 and analyses that can inform the nature and extent of impact s that might be expected to occur. 131 Thus, this report does not use a baseline year, per se, against which future impacts can be 132 measured. Different impacts have been assessed using applicable baselines cited in the literature 133 or, as appropriate, in the RFS2 RIA. Generally, however, the primary reference point used in this 134 document is consistent with the primary reference case used in the RFS2 RIA. This reference 135 case is a projection made by the U.S. Energy Information Administration prior to EISA in their 136 2007 Annual Energy Outlook of renewable fuel volumes expected in 2022. 137

138

* Includes pesticides, sediments, nutrients, pathogens, and acreage/function of wetlands 139

** Includes invasive/noxious plants, forests, grasslands, wetlands, and aquatic ecosystems 140

Figure 2-4 : Environmental and Resource Conservation Issues Addressed in This Report 141Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE Chapter 3 focuses on feedstock production, including cultivation and harvest. Chapter 4 142 covers impacts of feedstock logistics and biofuel production, distribution, and use. Many 143 activities, processes, and products associated with the biofuel supply chain a re already regulated, 144

are subject to limitations , or are mitigated through various approaches, as discussed in these 145 chapters. The potential impacts associated with imported biofuels are discussed in Chapter 5. 146 Currently, imported ethanol and biodiesel sup ply a relatively small percentage of U.S. biofuel 147 consumption—approximately 9 percent in 2008 (EIA, 2009, n.d.[a]; U.S. ITC, 2010; ERS, 148 2010a). If these percentages increase, future versions of this report may provide expanded 149 analysis of international imp acts associated with imported biofuels. 150

EPA’s ability to assess environmental and resource conservation impacts is limited by 151 uncertainties associated with even a qualitative assessment of the direct impacts. M any feedstock 152 technologies are in the early stages of research and development, therefore empirical and 153 monitoring data relevant to en vironmental impacts are limited and projections of their potential 154 future use are highly speculative. Recommendations in Chapter 6 and the approach to future 155

assessme nts described in Chapter 7 address how the EPA intends to bolster data availability and 156 analysis to improve understanding of environmental impacts in future reports. 157

Table 2

- 2 : Overview of Environmental and Resource Conservation Impacts Addressed in T his Report a

Feedstock Production and Transportation Fuel Production , Distribution, and Use

Water Quality **•** Pollution of ground, surface, and drinking water due to runoff containing sediments, nutrients, p esticides , and metals

**•** Loss of aquatic habitat due to pollution and sedimentation.

**•** Water quality impacts of c onver ting pasture or marginal or non

- cultivated land to feedstock production **•** Contamination of surface, ground, and drinking water by w astewater from biofuel production facilities and from leaks and spills during fuel transportation and storage

Water Availability **•** Reduced availability of local or regional water due to withdrawals of water needed to irrigate feedstocks

**•** Loss of aquatic habitat due to lowered stream flow **•** Lowered stream flow and aquifer levels due to water withdrawals for biofuel conversion

.

**•** Reduced availability of water due to contamination (see above)
Soil Quality and Soil Conservation **•** Degradation in soil quality due to (1) changes in land use; (2) increased use of nutrient s, pesticide s, and tillage and (3) harvesting of agricultural and forest residue

**•** Soil contamination from use of pesticides **•** Soil contamination from leaks and spills during fuel transportation and storage

**•** Addition of methane to soil gas resulting from b iodegradation of spilled biofuel

Air Quality **•** Emissions of criteria pollutants, air toxics, and greenhouse gases by farm and t ransportation vehicles

**•** Fugitive dust from feedstock production operations **•** Emissions of criteria pollutants, air toxics, and greenhouse gases during conversion and by transportation vehicles and off

- road equipmentChapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE Table 2

- 2 : Overview of Environmental and Resource Conservation Impacts Addressed in T his Report a

Feedstock Production and Transportation Fuel Production , Distribution, and Use Ecosystem Health/Biodiversity (including invasive and noxious plants) **•** I mpact s on flora and fauna and loss of ecosystem services due to pollution and habitat changes

**•** E stablishment and spread of invasive or noxious plants **•** E stablishment and spread of invasive or noxious plants

a – The impacts in this table are generalized and do not take into account location or effecti veness of mitigation 158 practices. 159 160
Table 2

- 3 : Overview of Environmental and Resource Conservation Impacts on Specific Ecosystems Addressed in This Report a

Feedstock Production

Forests **•** Short rotation woody crop (SRWC) plantations may deplete soil nutrients over the long run, but appropriate management techniques may increase soil nutrients.

**•** SRWC plantations can sustain high species diversity, although bird and mammal species tend to be habitat generalists

.

**•** Some tree species under consideration as feedstocks may invade forests in certain locations.

**•** Forest thinning can reduce the threat of catastrophic wildfires.

**•** Forest thinnin g can increase nutrient availability in soils over the short term.

**•** Harvesting forest residues decreases nutrient availability, soil organic matter, and habitat for some forest species.

Grasslands **•** Conversion of grasslands to row crops impacts grassland

- obligate species, potentially leading to declines in wildlife habitat.

**•** Higher proportions of corn within grassland ecosystems leads to fewer grassland bird species.

**•** Growing more switchgrass may improve grassland habitat for some species depending on management regimes.

**•** Conversion of Conservation Reserve Program lands to perennial grasses or harvesting of existing grasslands is li kely to have low impacts on grassland species

, particularly if harvesting occurs after the breeding season

.

**•** Use of native mixtures of perennial grasses can restore some native biodiversity.

**•** Cultivation of switchgrass outside of its native range may lead to invasions of native grasslands.

**•** Cultivation of Miscanthus may lead to invasions of pasture and other grasslands.Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE Table 2

- 3 : Overview of Environmental and Resource Conservation Impacts on Specific Ecosystems Addressed in This Report a

Feedstock Production

Wetlands **•** Increased sediments, nutrients, pesticides, and pathogens from runoff can flow into downstream wetlands.

**•** Increased nutrient loadings can lead to changes in wetlands community structure

.

**•** Reduced sediment and nutrient loadings can lead to improved water quality, depending on the specific management practice used.

**•** Some grass species under consideration may invade wetlands, including giant reed ( Arundo donax ) and reed canary grass ( Phalaris arundinacea ) .

**•** Harvesting forest residues and forest thinning may increase nutrient loads, depending on slopes, soils, presence of buffer zones, and use of best management practices to reduce runoff.

**•** Algal strains created may escape from cultivation and invade wetlands.

a – The impacts in this table are generalized and do not take into account location or effectiveness of mitigation 161 practices. 162 163 2.4

EPA , as well as state s, tribes, and local environmental agencies

, ha s statutory 165 responsibility to assess and control air emissions, water discharges, use of toxic substances, 166 microbial and pesticide use , and waste disposal . Many existing environmental regulations and 167
programs are applicable to the biofuel supply chain , including feedstock production and 168 logistics ; biofuel production and distribution, and biofuel use. 169 Regulatory Authority Relevant to Biofuel Environmental Impacts 164

EPA’s primary federal regulatory authority is derived from the Clean Air Act (CAA) ; the 170 Clean Water Act (CWA), the Federal Insecticide Fungicide and Rodenticide Act (FIFRA); 171 Resource Conservation and Recovery Act (RCRA) and the Toxic Substances Control Act 172 (TSCA). Under the CAA, EPA has broad direct statutory authority to regulate fuel quality and 173 emissions from refining and production facilities for all fuels, including biofuels. The CAA also 174 establishes limits for mobile source (vehicular) emissions. The Clean Water Act requires permits 175 for point source discharges to waters of the U.S, and development of water quality standards, and 176 Total Maximum Daily Loads (TMDLs) for water bodies where water quality standards have not 177 been met. FIFRA establishes standards for storage and use of pesticides in a manner that does 178 not harm human health or the environment. RCRA governs the generation, storage, treatment, 179 transport, and disposal of hazardous waste. TSCA requires manufacturers and importers of new 180 chemicals to submit “pre

- manufacture” notices for EPA review prior to manufacture and 181 commercial use of new chemicals , including new fuels, new biological materials, and new 182 genetically engineered microorganisms used to produce biofuels or co-products. Through the 183 CWA’s Spill Prevention, Control and Count ermeasure rule, EPA has enforceable regulations to 184 control water quality impacts from spills or leaks of biofuel products and by -products . In 185 addition, the Safe Drinking Water Act establishes maximum contaminant levels (MCLs) for 186 more than 90 drinking water contaminants to ensure public health. These statutes provide 187 opportunities within the existing regulatory framework to regulate and mitigate some of the 188 potential adverse health and environmental effects of biofuels . Selected environmental laws 189 relevant to the production and use of biofuels are summarized in Appendix B. 190Chapter 2 : Background and Approach

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— DO NOT CITE OR QUOTE Generally, EPA headquarters offices develop policies and regulations for these federal 191 statutes, while regional EPA offices, in partnership with the states and tribes, implement these 192
programs, ensure compliance, and enforce regulations. EPA and its regional offices work closely 193 with states and tribes to review permit applications for new facilities and to monitor 194 environmental impacts to ensure compliance with all permit conditions. EPA has prepared two 195 documents to help biofuel facilities understand the full range of regulatory requirements (U.S. 196 EPA, 2007a, 2008a). While EPA has overs ight authority for federal environmental regulatory 197
programs and regulations, state agencies and tribes are often “delegated” the responsibility for 198 issuing permits, conducting inspections, ensuring compliance

, and taking enforcement action

. 199 EPA regulations establish minimum requirements. States can enact more stringent standards, 200 although several states have enacted legislation that prohibits adopting requirements stronger 201 than those set by EPA

. 202Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3. E NVIRONMENTAL I MPACTS OF S PECIFIC F EEDSTOCKS 1

3.1

T he Energy Independence and Security Act (EISA) requires that all renewable fuel be 3 made from feedstocks that meet the definition of renewable biomass (see textbox). Many 4 different feedstocks meet these requirements and can be used to produce ethanol, other biofuels 5 or biofuel components. 6 Introduction 2

In 2009, 95 percent —or 10.9 billion gallons—of total renewable fuel produced in the 7 U.S. was produced from corn and refined almost entirely in the form of conventional corn starch 8 ethanol (FAPRI, 2010a). S oybea n oil- based biodiesel accounted for most of the remainder—505 9 million gallons . EPA expects that corn and soybean feedstocks will continue to account for a 10 large share of biofuel production in the U.S. (U.S. EPA, 2010b) in the near future. As of July 11 2010 , there was no significant commercial -scale production of ethanol from cellulos ic or 12 hemicellulos ic feedstocks, nor was there significant biodiesel production from oil seed 13 feedstocks other than soybean in the U.S. 14

A s science and technology improves, 15 EPA expects an increase in the use of 16 cellulosic feedstoc ks to produce advanced 17 biofuel. Such feedstocks include agricultural 18 residues (e.g., corn stover, sugarcane 19 bagasse, sweet sorghum pulp), forestry 20 biomass, urban waste, and dedicated energy 21 crops (e.g., switchgrass) (U.S. EPA, 2010b). 22 Technologies for producing biodiesel from 23 vegetable oils, recycled oils, rendered fats, 24 greases, and algal oil s have been developed 25 and tested at various scales from the 26 laboratory to demonstration plants and semi

27 commercial facilities. EPA expects biodiesel 28 from these feedstocks to gain a wider market 29 share as their production becomes more 30 economically and techno logically feasible 31 (U.S. EPA, 2010b). 32

The feedstocks discussed in this 33 chapter include corn and soybeans, as well 34 as four others currently under development: 35 corn stover, perennial grasses, woody 36 biomass, and algae (see Table 3

- 1). These 37 feedstocks represe nt different cultiv ation 38 and production practices. 39

This chapter reviews the actual (where known) and potential environmental impacts of 40 producing these six feedstocks, including impacts on water quality and quantity, soil and air 41 Requirements for Renewable Fuels

Under the Energy Independence and Security Act, all renewable fuel must be made from feedstocks that meet the EISA definition of renewable biomass, which includes:

**•** Planted crops and crop residue from agricultural

land s that were cleared prior to December 19, 2007, and were actively managed or fallow on that date.

**•** Plante d trees and tree residue from tree plantations

that were cleared prior to December 19, 2007 and were actively managed on that date.

**•** Animal waste material and by

- products.

**•** Slash and pre

- commercial thinnings from non

federal forestlands that are neither old

- growth nor listed as critically imperiled or rare by a State Natural Heritage program.

**•** Biomass cleared from the vicinity of buildings and

other areas at risk of wildfire.

**•** Algae.

**•** Separated yard waste and food waste.

Currently, as described in the final RFS2 rule, EPA deems renewable fuel producers using domestically grown crops and crop residue as feedstock to be in compliance with the renewable biomass requirements. However, EPA will annually review U.S. Department of Agriculture (USDA) data on lands in agricultural production to determine if these conclusions remain valid.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE quality, and ecosystem hea lth/biodiversity. Feedstock production impacts are considered during 42 the cultivation and harvest processes (see Figure 2 -3). Impacts associated with the subsequent 43 four stages of the biofuel supply chain are presented in Chapter 4. Row crop feedstocks (corn, 44

corn stover, and soybean), which share many commonalities, are discussed in Section 3.2. 45 Sections 3.3 to 3.5 present potential effects associated with switchgrass, woody biomass, and 46 algae

. 47

Table 3

- 1: Primary Fuels and Feedstocks Discussed in this Report

EISA Biofuel Type Biofuel Feedstock
Conventional Biofuel Ethanol Corn S tarch
Cellulosic Biofuel Ethanol Corn S tover
Perennial G rasses Woody B iomass
Biomass

- Based Diesel Biomass

- Based Diesel Soybeans Algae
48 In addition to the six primary feedstocks examined in this report, Section 3.6 briefly 49 discusses waste materials as potential emerging feedstocks for biofuels. In addition to general 50 ecosystem impacts, Section 3.7 reviews impacts on specialized habitats (forests, grasslands, and 51 wetlands), as required under EISA Section 204. Section 3.8 reviews environmental concerns 52 associated with genetic engineering of feedstocks, commonly referred to as genetic ally modified 53 organisms (GMOs). 54

3.2

3.2.1 Introduction 56 Row Crops (Corn, Corn Stover, Soybeans) 55

U.S. corn and soybean production 57 have increased steadily over the past 58 several decades. I ncrease d demand for 59 biofuel provides additional incentive to 60 continue research and development for 61 increasing crop yields. As shown in Figure 62 3-1, U.S. corn production increased by 63 more than a factor of four between 1950 64 and 2010. These increases were largely 65 due to gains in efficiency and crop yield. 66 Soybean yields have also increased

. For 67 example, s o ybean yields increased from 68 21.7 bushels per acre in 1950 to 43.9 69 bushels per acre in 2010 (NASS, 2010a). 70 Source: NASS, 2010a.

Figure 3 -1: U.S. Corn ProductionChapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Actual environmental impacts will vary, depending on the number of acres in production, 71 cropping techniques, implementation of conservation practices, and the location of the crop 72 acreage including hydrology, soils, and other geographic factors. 73

3.2.1.1 Current and Projected Cultivation 74

In 2009 9

85 , U.S. farmers planted 86 million acres of corn, harvesting 13.1 billion bushels 75 (NASS, 2010a). Approximately 4.6 billion bushels of corn from the 2009 harvest were used to 76 produce corn ethanol. In 20 10, U.S. farmers planted 88 million acres of corn, harvesting 12.5 77 billion bushels (NASS, 2010a). Approximately 4.8 billion bushels (or 38.4 percent) of corn are 78 projected to be used to produce corn starch ethanol biofuel between September 2010 and August 79 2011 (ERS, 2010c), up from 11.2 percent in the 2004-2005 harvest year (ERS, 2010b, 2010c). 80 Corn is grown throughout the U.S., but the vast majority of the cro p is grown in 12 states: 81 Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Minnesota, Missouri, Nebraska, Ohio, 82 South Dakota, and Wisconsin. Figure 3 -2 shows a map of planted acres by county (for selected 83 states) in 2009. 84

Source: NASS, 2010b. 86

Figure 3

- 2: Planted Corn Acres by County , for Selected States (2009) 87

88

9 As of January 2011, 2009 was the last year for which USDA NASS and EIA had complete datasets.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE EISA establishes 15 billion gallons as the maximum amount of corn starch ethanol that 89 can contribute to meeting the 36 billion gallon per year renewable fuel target in 2022. Domestic 90 production, which totaled 10.9 billion gallons in 2009 (EIA, n.d.[c]), is expected to meet this 91 target through a combination of increased corn yield, increased acreage, and, potentially, 92 improved efficiency in converting corn starch to ethanol. U.S. Department of Agr iculture 93 (USDA) estimates that planted corn acreage will remain at 88 million acres through 2021(USDA 94 does not project acreage beyond 10 years), as U.S. demand for biofuel increases (USDA, 2010a). 95 In the RFS2 analysis, EPA estimates that in order to produce 15 billion gallons of corn starch 96 ethanol per year by 2022, the percentage of corn acreage dedicated to ethanol could rise from the 97 current 38 percent to as high as 41 percent in 2022 (U.S. EPA, 2010b). 98

Concern has been raised that the demand for corn ethanol may put pressure on the 99 USDA’s Conservation Reserve Program ( CRP ) (Secchi and Babcock, 2007). This program 100 provides farmers with financial incentives to set aside a certain portion of their cropland for 101 buffer zones in order to conserve wildlife habitat, reduce erosion, protect water quality, and 102 support other environmental goals. CRP lands are not precluded by the feedstock requirements 103 for renewable fuels (see text box on page 3 -1) from being used to grow biofuel feedstocks. 104 T herefore their conversion to biofuel feedstocks could reduce the effectiveness of the CRP 105 program in protecting the environment, and could result in increased environmental impacts, 106 depending on the nature (i.e., crop) and extent of the conversion. One estimate, which examined 107 the state of Iowa, predicted that high corn prices could lead to the recultivation of up to 70 108 percent of the expiring acreage enrolled in the CRP (Secchi and Babcock, 2007). Other states 109 may not have such high rates of recultivation given that much of the land in the CRP is marginal 110 and would be expensive to cultivate. 111

The Food, Conservation, and Energy Act of 2008 (Farm Bill) capped CRP acreage at 32 112 million, reducing enrollment by 7.2 million acres from the 2002 Farm Bill and potentially 113 making more acreage available for corn production (ERS, 2008). In 2007, approximately 28.5 114 million acres or 78 percent of all CRP lands consisted of some type of grassland (FSA, 2008). 115

A USDA study estimates that, to meet the renewable fuel standard, total cropland will 116 increase 1.6 percent over 2008 baseline conditions by 2015, with corn acreage expanding 3.5 117 percent, accounting for most of the cropland increase (Malcolm et al., 2009). While corn acreage 118 is expected to expand in every region, this USDA study estim ates that traditional corn

- growing 119 areas would likely see the largest increases —up 8.6 percent in the Northern Plains, 1.7 percent in 120 the Corn Belt, and 2.8 percent in Great Lakes States (Malcolm et al., 2009). Historically, corn 121 has been grown in rotation with other crops such as wheat, hay, oats, and especially soybeans. 122 However, high corn prices have created incentives for continuous cultivation of corn (NASS, 123 2007a), and in some cases conversion of non- cro pland to corn. 124

Corn stover— the stalks, leaves, h usks, and cobs that are not removed from the fields 125 when the corn grain is harvested—provides another potential feedstock for meeting EISA 126 requirements . I n the RFS2 RIA

, EPA estimat ed that 7.8 billion gallons of ethanol could be 127 produced from corn stover by 2022. Most corn stover harvesting for biofuel is expected to be 128 from the major corn produc ing states . As of July 2010, there is no commercial production of 129 cellulosic ethanol from corn stover. 130Chapter 3: Environmental Impact s of Specific Feedstocks

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 3-5 DRAFT—DO NOT CITE OR QUOTE 131 Because corn stover protects underlying soil from wind and water erosion, the use of corn 132 stover as a feedstock could increase soil erosion and environmental impacts compared to existing 133 practices (Sheehan et al., 2004; Williams et al., 2009). The USDA’s Natural Resource 134 Conservation Service (NRCS) has established soil loss tolerance levels, and farmers harvesting 135 corn stover are encouraged to maintain a mini mum level of groundcover or using other practices 136 to minimize soil loss. Under current rotation and tillage practices, approximately 30 to 40 percent 137 of stover could be collected cost effectively, taking into consideration erosion reduction, soil 138 moisture needs and nutrient replacement (G raham et al., 2007; Perlack et al., 2005).

139 Maintaining soil carbon levels is another con cern that should be taken into account when 140 determining the extent of stover harvesting. To ma intain soil carbon levels, a significant portion 141 of the corn stover would need to be left on fiel ds, reducing the amount of the biomass that could 142 be collected for feedstock. Sustainable residue removal rates depend on tillage practices, with no143 till allowing for the greatest level of sustainabl e removal. Developing a single national estimate 144 of the amount of residue that must remain on the ground to meet conser vation goals is difficult 145 because much depends on site-specific conditions.

146 After corn, soybean is the second largest agri cultural crop (in terms of acreage) in the 147 U.S. In 2009, American farmers planted 77.4 million acres and harvested 3.4 billion bushels. In 148 2010, American farmers planted 77.7 million acres of soybeans and again harvested 3.4 billion 149 bushels (NASS, 2010a). Soybean oil is the prin cipal oil used for co mmercial production of 150 biodiesel in the U.S., responsible for about ha lf of total biodiesel production, with the rest 151 coming from various other vegetable oils such as canola oil as well as waste fats, tallow and 152 greases (see Table 4-1 for more detailed br eakdown) (EIA, 2010). In harvest year 2008/2009, 153 approximately 5.6 percent of the soybean harvest, or about 1.9 billion pounds of soybean oil 154 (USDA, 2010b), went to biodiesel production and yielded 505 milli on gallons in calendar year 155 2009 (EIA, n.d. [d]). This was a significant de cline from the production total in 2008 of 676 156 million gallons (EIA, n.d. [d]). Nonetheless, USDA expects the percentage of soybean harvest 157 going to biodiesel to increase to 7.8 per cent by 2012 and holding steady through 2019. USDA 158 also projects that soybean oil used for biodies el will represent 13-15 percent of total use of 159 soybean oil–approximately 400 million gallons of biodiesel (USDA, 2010b). 10 USDA estimates 160 that soybean acreage will level off at approximately 76 million acres through 2019 (USDA, 161 2010b).

162 In terms of cultivation, soybeans are typically grown in the same locations as corn. Figure 163 3-3 shows that soybean production is centered in the Upper Midwest a nd along the Mississippi 164 River Valley, with Iowa, Illinoi s, Indiana, Minnesota, and Nebraska representing the top 165 soybean-producing states.

10 Percentages were calculated by multiplying together the percentage of soybean crop converted to soybean oil, percentage of soybean oil converted to biodiesel, and total bushels produced, then dividing by total bushels produced.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 166 Source: NASS, 2010b. 167

Figure 3 -3 : Planted Soybean Acres b y County (2009) 168

Much of the recent expansion in corn acreage for ethanol production has come at the 169 expense of land previously used for other crops, especially soybeans (Fargione et al., 2009; 170 Keeney and Hertel, 2009). In 2007, corn acreage expanded 23 percent in response to high prices 171 and the demand for corn ethanol production (Mitchell, 2008). This expansion resulted in a 16 172 percent decline in soybean acreage, which reduced soybean production and contributed to a 75 173 percent rise in soybean prices between April 2007 and April 2008 (Mitchell, 2008). Much of the 174 soybean acreage decrease occurred as a result of changing agricultural rotation, for example 175

some corn

- soybean -corn rotations were replaced by continuous corn (Fargione et al., 2009). In 176 2008, corn acreage declined by 7.5 million acres, to 86 million acres, while soybean acreage 177 increased by almost 11 million acres. A large proportion of the soybean acreage increase came 178 from the reduction in corn acreage as well as switching crops other than corn to soybeans, loss of 179 CRP land, and an increase in soybean double cropping (Babcock and McPhail, 2009). Such 180 tradeoffs between food crops, energy crops, and CRP lands may become more critical in the 181 future, especially as climate change affects global cropland area and water availability for 182 irrigation. One study predicted that climate change will reduce global cropland area by 9 percent 183 by the year 2050, although noting that this could be buffered by the increased use of water 184 management strategies (Rost et al. , 2009). 185

3.2.1.2 Overview of Environmental Impacts 186

Corn and soybean production entails the use of pesticides, fertilizer, water, and 187 fuel/energy, in addition to drainage systems, each of which can affect water quality, water 188Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE availability, soil quality, air quality , and ecosystem health. Changes in land cover, vegetation, 189 and habitat have additional impacts on the environment. Table 3

- 2 summarizes these impacts and 190 the factors that influence them. (Note: Because corn stover is essentially a by -product of corn 191 production, only direct environmental impacts from stover harvest are considered for discussion 192 of this feedstock’s impacts.) 193

Table 3

- 2: Impacts Associated with Biofuel Feedstock Production ( Corn Starch , Corn Stover, and Soybean)

Impact/Resource

Use Category Corn Starch a Harvest of Corn Stover Soybean
Water Quality Corn production can lead to erosion of sediment and the runoff and leaching of fertilizers such as nitrogen and

, phosphorus, and pesticides such as atrazine. Artificial drainage like tile drains increases loss of nitrogen to surface waters.
Actual water quality impacts depend on a number of geographic and management factors: for instance, the rate
, timing, and method of application of fertilizer s , manure, and pesticide s; and the use of erosion control practices such as edge of field controls like vegetative buffers, controlled drainage, or constructed wetlands. Removal of corn stover will require increases in fertilizer application rates
, which can result in t he pollution of surface and ground waters.

Erosion can also increase as more stover is removed, providing less ground

cover. Actual water quality i mpacts will depend on a variety of geographic and management factors

. The majority of soybean acreage is managed with conservation tillage, minimizing erosion.
Though soybean production requires smaller amounts of many nutrients

— especially nitrogen

— than does corn production, it often still requires potassium and phosphorus, which may impact water quality.
Actual water quality impacts depend on a variety of geographic and management factors.

Water Quantity In areas where corn production requires irrigation, surface and ground water quantities may be affected.
Irrigation requirements depend on rainfall, re lative humidity, soil properties, and crop yield. Additional water use for stover production is likely to be minimal. In areas where soybean production necessitates irrigation, surface and ground
water quantities may be affected.
Irrigation requirements depend on rainfall, relative humidity, soil properties, and crop yield.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Table 3

- 2: Impacts Associated with Biofuel Feedstock Production ( Corn Starch , Corn Stover, and Soybean)

Impact/Resource

Use Category Corn Starch a Harvest of Corn Stover Soybean
Soil Quality The conversion of uncultivated land or marginal cropland to corn production may lead to higher soil erosion and lower quantities of soil organic
matter. Soil quality is maintained through management practices that include reduced use of tillage, use of crop rotations, and the return of organic matter to the soil through cover
crops , manure, or crop residues. Excess removal of corn stover can increase erosion

, decrease soil organic
matter and degrade water quality . These impacts depend on management practices and local conditions, including slope, soil type, and prior land

use

. T he majority of soybean acreage is managed with conservation tillage pr actices, mitigating erosion and impacts on soil organic matter

.

Air Quality Emissions of criteria and air toxic pollutants are associated with several sources, including combustion of fossil fuels by farm equipment; airborne particles (dust) generated during tillage and harvesting; and the production and application of fertilizers and pesticides.
Actual impacts depend on use rates and formulations of fertilizers, and pesticides; tillage methods; the type of fuel and agricultural equipment; and conditions at time of tillage and harvest. Corn stover harvesting may affect air quality if it requires the combustion of additional diesel or gasoline beyond that used to harvest corn, if it leads to additional fertilization of fields, or if additional dust is released into the air during harvest operations. Emissions of criteria and air
t oxic pollutants are associated with several sources, including combustion of fossil fuels by farm equipment; airborne particles (dust) generated during tillage and harvesting; and the production and application of fertilizers and pesticides.
Actual impact s depend on use rates and formulations of fertilizers and pesticides; tillage methods; the type of fuel and agricultural equipment; and conditions at time of tillage and harvest.

Ecosystem Impacts The type and extent of ecosystem impacts depend on local c onditions and management. Nutrients, sediment, and pesticides can contaminate surface waters and wetlands, leading to changes in biodiversity. Corn stover harvest may decrease soil biodiversity. The water quality impacts described above may affect wetland biodiversity

. The ecosystem impacts of stover removal depend on a variety of geographic and management factors, including the amount of stover removed. The type and extent of ecosystem impacts depend on local conditions and management. Nutrients,

s ediment, and pesticides can contaminate surface waters and wetlands, leading to changes in biodiversity.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Table 3

- 2: Impacts Associated with Biofuel Feedstock Production ( Corn Starch , Corn Stover, and Soybean)

Impact/Resource

Use Category Corn Starch a Harvest of Corn Stover Soybean

Invasiveness Potential Corn is non

- invasive. See “Corn” Soybean is non

- invasive.

a – I mpacts associated with corn production are described in the “Corn Starch” column. 194 195 Cultivation of row crops such as corn and soybeans may lead to high levels of soil 196 erosion, nutrient loss, and pesticide and water use if not managed adequately (Groom et al., 197 2008, Table 1). Agricultural conservation systems may be used to reduce or minimize the impact 198 of row crop agriculture on the environment. The systems support 1) controlled application of 199 nutrients and pesticides through proper rate, timing, and method of application, 2) controlling 200 erosion in the field (i.e., reduced tillage, terraces, or grassed waterways), and 3) trapping losses 201 of soil at the edge of fields or in fields through practices such as cover crops, riparian buffers, 202 controlled drainage for tile drains, and constructed/restored wetlands (Blanco-Canqui et al., 203 2004; Dinnes et al., 2002; NRCS, 2010). 204

The effectiveness of conservation practices, however, depends upon their adoption. The 205 USDA Conservation Effects Assessment Project (CEAP) recently released a major study 206 quantifying the effects of conservation practices commonly used on cultivated cropland in the 207 Upper Mississippi River Basin. It found that, while erosion control practices are commonly used, 208 there is considerably less adoption of proper nutrient management techniques to mitigate 209 nitrogen loss to water bodies (NRCS, 2010). 210

Further, even when erosion practices are reliably implemented, conservation practices 211 and best management practices ( BMPs ) are not a panacea. A case study in the Chesapeake Bay 212 (CENR, 2010) found that, although the implementation of BMPs since 2000 has significantly 213 lowered loadings of nitrogen (72 percent of sites showed downward trends), total phosphorus (81 214 percent of sites), and sediment (43 percent of sites), lower nutrient input has not improved 215 dissolved oxygen levels overall in the Chesapeake Bay, with the exception of small- scale 216 reversals in hypoxia. 217

3.2.2 Water Quality 218

Water quality impacts from increased corn and soybean production for biofuel may be 219 signific ant, and are caused by pollution from nutrients, sediment, and pesticides, as well as 220 biological contaminants such as pathogens that are released when animal manure is applied as 221 fertilizer. Multiple studies predict that increased production of crops for b iofuels will exacerbate 222 water quality problems in the Gulf of Mexico and other U.S. coastal waters if the crops are not 223 grown under improved agricultural conservation practices and expanded nutrient BMPs (Greene 224 et al., 2009, and Rabalais et al., 2009, cited in CENR, 2010). 225Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.2.2.1 Nutrient Loading 226

Nutrients —Surface Water Impacts 227

Increased production of row crops for biofuel , especially corn, will increase nitrogen and 228 phosphorus load ing to surface water s if not managed appropriately. Excessive levels of nutrients 229 in a body of water can cause accelerated algal growth, reducing light penetration and oxygen 230 levels. Low dissolved oxygen (i.e., hypoxia) can kill fish, reducing their populations and the 231 species diversity in the affected area . This nutrient enrichment pro cess (eutrophication) can cause 232 serious deterioration of both coastal and inland water resources. According to a 2008 report by 233 the National Research Council, excess nutrients and sediment from the high corn-producing 234 Midwest are the primary sources of wat er quality degradation in the Mississippi River Basin and 235 the Gulf of Mexico (NRC, 2008, p. 88). Further, t he National Summary of Impaired Waters 236 (U.S. EPA, 2010c) 11

In evaluating the potential for water quality impacts due to increased nutrient loads to 251 surface waters, there is some debate about which nitrogen compounds to consider. Not all 252 nitrogen compounds can be easily used by algae (i.e., are bioavailable) and th us some forms of 253 nitrogen impact eutrophication more than others. Ammonia is the inorganic nitrogen compound 254 that is easiest for most algae to use, followed by nitrate and nitrite (Cole, 1983). Total nitrogen is 255 a measure of the sum of the nitrogen present in both inorganic and organic compounds in water. 256 documented that in 2008, nationwide, approximately 50 percent of the 3.5 237 million miles of stream and rivers and 66 percent of the over 41 million acres of lakes and 238 reservoirs in the U.S. were impaired due to nutrient enrichment. The 2007 National Estuarine 239 Eutrophication Assessment found that the Mid- Atlantic is the region most impacted by hypo xia, 240 with almost 60 percent of the waters affected by anthropogenic land-based sources of nutrient 241 pollution, agriculture being the largest contributor (CENR, 2010). The National Summary of 242 Impaired Waters also reported that in 2008 over 68,000 miles of st reams and rivers and over 1.3 243 million acres of lakes and reservoirs in the Mississippi River Basin states were impaired because 244 of nutrients. Increased corn and soybean production for biofuels could exacerbate this situation 245 due to the nutrients from addit ional fertilizer or increases in the acreage or extent and density of 246 subsurface tile drainage. The Committee on Environment and Natural Resources cites a 2008 247 report that predicts the average annual flux of dissolved inorganic nitrogen to the Gulf of Mexi co 248 could increase by 10 to 34 percent , based on a “pessimistic” scenario in which corn production 249 acreage increases by up to 9 percent (Donner and Kucharik, 2008, cited in CENR, 2010). 250

Although many studies track total nitrogen, some researchers argue that it is more 257 appropriate to consider inorganic nitrogen compounds only, as those are most likely to impact 258 water quality through eutrophication. When tracking the fate and transport of nitrogen in surface 259 waters within large watersheds (e.g., in the Mississippi River Basin), it is important to remember 260 that inorganic nitrogen compounds are readily converted to organic nitrogen compounds and 261 back to inorganic compounds by organisms present in surface waters and sediments. At the basin 262 scale, measuring total nitrogen provides insight into the potential maximum impact of nitrogen 263 inputs into surface waters. 264

11 Numbers in text were calculated by summing miles/acres reported by each state in their 305(b) assessments as impaired by “nutrients”; “ammonia, un

- ionized”; “nitrogen, total”; “nutrient/eutrophication”; “phosphorus, total”; “ammonia, total”; “nitrogen, nitrate”; and “ammonia.”Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Corn has the highest fertilizer use per acre of any of the biofuel feedstocks, and it 265 accounts for the largest portion of nitrogen fertilizer use among all feedstocks discussed in this 266 report (U.S. EPA, 2010b). By one estimate, which surveyed 19 U.S. states, approximately 96 267 percent of corn acreage received nitrogen fertilizer in 2005, with an average of 138 pounds per 268 acre (NASS, 2006). An Iowa State University study found that e ach acre of harvested corn also 269 requires about 55 pounds of phosphorus (in the form P 2 O 5 ) (Iowa State University, 2008). 270 Assuming a yield of 154 bushels per acre (NASS, 2010c) and an ethanol conversion rate of 2.7 271 gallons per bushel (Baker and Zahniser, 2006), this results in 0.33 pounds of nitrogen and 0.13 272 pounds of phosphorus applied per gallon of ethanol produced. Nitrogen discharged from corn 273 fields via runoff, sediment transport, tile /ditch drainage, and subsurface flow averages 24 to 36 274 percent of the nitrogen applied ( and can rang e from 5 percent in drought years to 80 percent in 275 flood years) (Dominguez- Faus e t al., 2009). 276

Nutrients are applied to fewer soybean acres compared to corn and at much lower rates 277 (U.S. EPA, 2010b). However, losses of nitrogen and phosphorus from soybeans can occur at 278 quantities that can degrade water quality (Dinnes et al., 2002; Randall et al., 1997). In 2006, the 279 USDA ’s National Agricultural Statistics Service estimated that nitrogen and phosphorus 280 fertilizers were applied to 18 percent and 23 percent of soybean acreage, respectively, with an 281 average of 16 pounds of nitrogen and 46 pounds of phosphate applied per acre fertilized (NASS, 282 2007b). The quantity of nitrogen fertilizer applied to soybean fields ranged from 0 to 20 pounds 283 per acre, while the quantity of phosphate ranged from 0 to 80 pounds per acre. Similar to corn, 284 the conversion of idled acreage to soybeans is estimated to result in losses of nitrogen and 285 phosphorus from the soil (Simpson et al., 2008). 286

Corn requires less fertilizer when grown in rotation with soybeans. Therefore , crop 287 rotation prov ides an effective strategy for reducing the amount of fertilizer and pesticide applied 288 to fields, and therefore runoff and leaching of the pollutants to water. One study estimated that 2 289
to 40 percent of the total nitrogen leached from fields planted alter nately with corn and soybeans 290 came from the fields when they were planted with soybeans, meaning that most of the nitrogen 291 runoff was due to corn production (Powers, 2005). 292

While the total amount of nitrogen lost from corn fields tends to be higher than lo sses 293 from soybean fields (Powers, 2005), loss of inorganic nitrogen from corn and soybean fields 294 tends to be similar. This suggests that eutrophic effects of nitrogen will be similar for runoff 295 from both corn and soybean fields in surface waters near the fields. However, when considering 296 impacts at the basin scale, it is more relevant to consider the total amount of nitrogen contributed 297 by each crop. 298

Use of corn stover for ethanol production would not necessarily result in increased corn 299 production. However, the removal of corn stover could lead to loss of soil surface cover if NRCS 300 guidelines are not followed, thereby increasing runoff of nitrogen and phosphorus to surface 301
waters , including wetlands (Kim and Dale, 2005). Even partial removal of corn stover can result 302 in nutrient losses to water due to increased runoff (Kim and Dale, 2005; Lal, 2004) . In addition, 303 corn stover removal can lead to the loss of soil nutrients needed for corn growth, and higher 304 fertilizer rates are likely to be required to sustain crop productivity, increasing the likelihood of 305 increased runoff and transport of non-point source pollutants (Blanco -Canqui and Lal, 2009a). 306 Typically, for each ton of corn stover harvested, an additional 16 pounds of nitrogen fertilizer 307Chapter 3: Environmental Impacts of Specific Feedst ocks

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— DO NOT CITE OR QUOTE and 6 pounds of phosphorus fertilizer must be added to the soil, though these quantities vary 308 considerably (Sawyer and Mallarino, 2007). 309

Mitigating the loss of nitrogen and other nutrients to water bodies is a research priority 310 for the USDA. Since drainage systems are a k ey conduit for nutrient loading, new research is 311 focusing on alternative surface and subsurface drainage solutions. An interagency Agricultural 312 Drainage Management Systems Task Force, formed in 2003 and recently expanded, is working 313 to reduce the loss of nitrogen and phosphorus from agricultural lands through drainage water 314 management (CENR, 2010). One emerging conservation technology that addresses water quality 315 degradation is the creation of wetlands on the perimeter of fields in order to receive surface 316 runoff and filter out nutrients prior to its discharge into streams and rivers. Surface water runoff 317 control, another conservation method used to stop water erosion, reduces the loss of nutrients to 318 the surrounding environment through overland flow, but increases infiltration and loss of soluble 319 nitrogen and phosphorus. A third strategy, lowering the water table during planting and 320 harvesting, has been predicted to lower nitrogen losses in the Chesapeake watershed by 40 321 percent (CENR, 2010) . Other strategie s, such as planting perennial grasses over subsurface tile 322 drains or placing wood chips in drainage ditches, are also being explored. Implementing 323 strategies such as these on agricultural lands that contribute a disproportionate share of nitrogen 324 loads wil l maximize the environmental benefit of their application (CENR, 2010). 325

However, none of these practices guarantee environmentally sustainable biofuel 326 production on an industrial scale. The interactions between various BMPs need to be investigated 327 more closely, as there can sometimes be unexpected adverse consequences from new 328 technologies. For example, the 2010 report by the Committee on Environment and Natural 329 Resources notes that the introduction of tile- drainage systems in the Midwest has improved 330 agric ultural yields but worsened water quality by accelerating nutrient -loaded runoff to streams 331 and rivers without allowing natural processes to filter the nutrients (CENR, 2010). 332

Nutrients —Coastal Waters Impacts 333

Nutrient enrichment is a major concern for coastal waters across the U.S. , including the 334 Gulf of Mexico, Chesapeake Bay, other estuaries, and the Great Lakes. For example, a lmost 15 335 percent of the coastal waters in the Gulf of Mexico and Northeast have poo r water quality as 336 measured by nutrient concentrations, extent of hypoxia, and water clarity (U.S. EPA, 2008b). 337 The number of U.S. coastal areas documented as experiencing hypoxia increased from 12 in 338 1960 to over 300 in 2008 (see Figure 3 -4) (CENR, 2010). While these impacts are due to a 339 number of types of nutrient inputs, such as lawn fertilizers, other agricultur al uses , atmospheric 340 deposition, and wastewater discharges, increased corn and soybean production for biofuel will 341 likely increase nutrient load ing in those watersheds where increased production occurs (CENR, 342 2010). 343Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 344 Note: Map does not display one hypoxic system in Alaska and one in Hawaii. 345 Source: CENR, 2010. 346

Figure 3 -4: Change in number of U.S. coastal areas experiencing hypoxia 347 from 1960 to 2008 348

Hypoxia in the Gulf of Mexico has been a long-standing environmental and economic 349 issue that threatens commercial and recreational fisheries in the Gulf (U.S. EPA, 2010b). The 350 primary cause of hypoxia in the Gulf of Mexico is excess nitrogen and phosphorus loadings from 351 the Upper Midwest flowing into the Mississippi River, suggesting that increased corn and 352 soybean production will exacerbate the problem (U.S. EPA, 2010b). U.S. Geological Survey 353 (USGS) SPARROW 12 modeling of the sources of nutrient loadings to the Gulf of Mexico 354 estimated that agricultural sources contributed more than 70 percent of the delivered nitrogen 355 and phosphorus to the Gulf of Mexico (Alexander et al., 2008). Corn and soybean production 356 accounted for 52 percent of nitrogen delivery and 25 percent of phosphorus delivery. Modeling 357 of the Upper Mississippi River Basin (upstream of Cairo, Illinois) using SWAT 13

12 SPARROW (S PA tially R eferenced R egressions O n W atershed) is a watershed model developed by USGS relating water quality measurements at monitoring stations to other watershed attributes. The model estimates nitrogen and phosphorus entering a stream per acre of land, and evaluates the contributions of nutrient sources and watershed properties that control nutrient transport. modeling 358 indicated that, on average, it contributes 39 percent of the nitrogen load to the Gulf of Mexico, 359 and 26 percent of the phosphorus load (SAB, 2007). One study estimated that corn production 360 contributes between 60 and 99 percent of the total nitrogen load to the Mississippi River from 361 eastern Iowa watersheds (Powers, 2007). Other studies have also determined that the majority of 362 nitrate in the Mississippi River originates in the Corn Belt (Donner et al., 2004; Goolsby et al., 363 1999). Nitrogen from fertilizers can also volatilize (and then return to water through atmospheric 364 deposition). Atmospheric nitrogen from all sources, including power plant emissions, is 365 estimated to contribute 15 to 20 percent of the nitrogen loading to the Gulf of Mexico (Ale xander 366 et al., 2008), and about 30 percent of the nitrogen loading to Chesapeake Bay (Paerl et al., 2002). 367

13 The Soil and Water Assessment Tool ( SWAT) is a public domain model jointly developed by USDA Agricultural Research Service and Texas A&M University System. SWAT is a river basin

- scale model to simulate the quality and quantity of surface and ground water and predict the environmental impact of land management practices on different soil patterns and land use patterns.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE A USDA study projects that reaching 15 billion gallons per year of ethanol from corn 368 starch (i.e., not including stover) will result in a 1.7 percent increase in nitrogen loads to surface 369 water, with the greatest increases in nitrogen load occurring in the Corn Belt and Northern Plains 370 (Malcolm et al., 2009). EPA used the SWAT model to predict the impacts of increased corn 371 production to meet the RFS2 c orn starch ethanol targets on water quality in U pper Mississippi 372 River B asin , which empties into the Gulf of Mexico. The modeling found a maximum increase 373 in nitrogen load to the Gulf of Mexico of 1.9 percent, and a maximum of 1 percent increase in 374 phosphorus load. The SWAT model also indicated that, by 2022, increased corn yields could 375 reduce the need for increasing the amount of land in corn, so nutrient loads could decrease from 376 earlier peaks (SAB, 2007). 377

Ecological features such as wetlands and riparian buffers play an important role in 378 absorbing nutrients before they run into surface waters. Conserving wetlands where they exist, or 379 creating artificial vegetated riparian buffers between waters and croplands, is a way to mitigate 380 the impacts of nutrient l oading. Riparian buffers and filter strips prevent potential pollutants in 381 agricultural runoff (sediment, nutrients, pesticides, pathogens) from reaching surface waters. 382 While the effectiveness of these buffers can vary depending on many factors, including slope, 383 width, vegetation used, and how well they are maintained, studies have shown that they can 384 remove up to 78 percent of phosphorous, 76 percent of nitrogen, and 89 percent of total 385 suspended solids (TSS) (Schwer and Clausen, 1989). 14

Nutrients —Ground Water Impacts 387 386

Excess nutrients from fertilizers can leach into ground water, which can discharge to 388 surface waters, thereby contributing to surface water nutrient loading. About two-thirds of the 389 nitrogen lost to subsurface flow eventually returns to surface water (U.S. EPA, 2010b, p. 971). 390 Ground water can also be used for public and private drinking water supplie s, and fertilizers c an 391 increase the concentration of nitrate in ground water wells, especially shallow wells (less than 392 200 feet deep). USGS samp led 495 wells in 24 well networks across the U.S. in predominantly 393 agricultural areas from 1988 to 2004 and found significant increases in concentrations of nitrate 394 in 7 of the 24 well networks. In 3 of the 7 well networks, USGS found ni trate concentration s that 395 exceeded the federal drinking water standards of 10 mg/L of nitrate

- nitrogen (Rupert, 2008). 396 Increased corn and soybean production for biofuels could worsen the problem of contaminated 397 well water because of additional nitrogen inputs from fertilizer used to grow more corn. USDA 398 projects that reaching 15 billion gallons per year of ethanol from corn will result in a 2.8 percent 399 increase in nitrogen leaching to ground water , with the greatest increases occurring in the Great 400 Lake s s tates and the Southeast (Malcolm et al., 2009). Similar estimates for soybean production 401 were not identified. Studies of nitrate leaching from corn and soybean rotation cropping systems 402 are inconclusive about whether these systems increase or decrease leaching rates (Kanwar et al., 403 1997; Klocke et al.; 1999; Weed and Kanwar, 1996; Zhu and Fox, 2003). 404

Fertilizer application management strategies aim to reduce nitrogen leach ing by 405 maximizing the efficiency of applied fertilizer. Such strategies focus on collecting precise 406 information on soil nutrient content in order to better inform application rates. The USDA 407

14 See also http://cfpub.epa.gov/npdes/stormwater/menuofbmp s/index.cfm?action=factsheet_results&view=specific&bmp=82

.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE reports that phosphorus accumulation on farms has reached levels that often exceed crop needs 408 (ARS, 2003). Better information on these conditions could help reduce nutrient runoff that leads 409 to eutrophication. There may also be economic incentives for implementing fertilizer 410 management strategies. In 2006, the University of Minnesota Extension, an agricultural research 411 partnership between federal, state and county governments, estimated that 86 percent of 412 Minnesota farmers could save more than $6 per acre and 56 percent could save more than $10 413 per acre in fertilizer cos ts by following better informed nutrient application rates (Minnesota 414 Department of Agriculture, 2010). 415

3.2.2.2 Sediment 416

Nutrients and sediment are the two major water quality problems in the U.S., and much 417 attention has been focused on these issues in the Mississippi River Basin and the Gulf of Mexico 418 (NRC, 2008, p. 88). Use of soil erosion control practices is widespread, yet 15 percent of acres in 419 the Upper Mississippi River Basin experience excessive sediment loss (NRCS, 2010). The 420 National Water Summary of Imp aired Waters stated that in 2008 over 70,000 miles of streams 421 and rivers and over 1.2 million acres of lakes and reservoirs in Mississippi River basin states are 422 impaired because of sediments or turbidity (U.S. EPA, 2010c). 15

Removal of corn stover from fields for use in biofuel production is expected to increase 436 sediment yield to surface waters and wetlands, but rates are highly variable depending on soils, 437 slope, management of fields, and the proportion of stover harvested (Cruse and Herndl, 2009; 438 Kim and Dale, 2005). Results of SWAT modeling of the Upper Mississippi River Basin 439 (AquaTerra, 2010) indicated that leaving corn stover on fields helps reduce soil erosion and 440 sediment transport, even when the amount of land in corn production increases. However, the 441 amount of soil erosion that agricultural cropland experiences is a function of many factors, 442 including not only residue left on the field, but also field operations (field preparation , tillage, 443 etc.) in preparation for the next crop, timing of field operations, and other site- specific factors 444 noted above (U.S. EPA, 2010b). 445 Nelson et al . (2006) reported 423 that row crops, such as corn and soybean, result in higher erosion rates and sediment loads to 424 surface waters, including wetlands, than non-row crops that might be used as biofuel feedstock, 425 such as grasses. Sedimentation rates in agricultural wetlands can be higher than in natural 426 grassland landscapes; increased sedimentation may, depending on sediment depths, cover viable 427 seeds sufficiently to prevent germination (Gleason et al., 2003) . EPA and USDA have evaluated 428 the impact of the RFS2 rule on sediment loads. As reported in the water quality analysis 429 conducted by EPA for the RFS2 rule , it is estimated that annual sediment loads to the Mississippi 430 River from the Upper Mississippi River Basin would increase by 6.22 million tons (15 percent) 431 between 2005 and 2022, assuming corn stover remained on the field following harvest 432 (AquaTerra, 2010). A USDA study estimates that nationally, sediment loads in 2015 will be 1.6 433 percent greater with implementation of RFS2 than without, assuming ethanol production from 434

cor n starch only (Malcolm et al., 2009). 435

15 Numbers in text were calculated by summing miles/acres reported by each state in their 305(b) assessments as impaired by “sedimentation/siltation” or “turbidity.”Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Conservation tillage practices, including no- till, strip

- till, ridge

- till, and mulch

- till, 16

3.2.2.3 Pesticides 461 can 446 reduce erosion by leaving at least 30 percent of the ground covered by crop residue and by 447 limiting soil disturbance. According to the USDA, 41 percent of planted acreage in the U.S. uses 448 conservation tillage as a mitigation strategy (ARS, 2006). These techniques have been shown to 449 reduce erosion by as much as 60 to 90 percent, depending on the conservation tillage method 450 (Minnesota Department of Agriculture, 2010). In 2002, the USDA Agricultural Research Service 451 studied the effect of ridge tillage on Northern Corn Belt plantations. The study showed that ridge 452 tillage not only reduced erosion and sediment loading but also increased profitability, reduced 453 fuel and labor use, and reduced economic risk relative to conventional tillage for a corn and 454 soybea n rotation (ARS, 2006) . Additionally, these alternative tillage approaches can reduce trips 455 across the field, lowering fuel use and improving the energy balance of the resulting biofuel. The 456 use of conservation tillage, in combination with BMPs, such as co ver crops, may partially 457 compensate for the increase in erosion potential caused by cover stover removal (Blanco -Canqui 458 and Lal, 2009b). Depending on the soil type, these practices may allow a percentage of stover to 459 be harvested sustainably (Blanco -Canqui and Lal, 2009b)

. 460

According to t he National Summary of Impaired Waters (i.e., waters that do not meet the 462 water quality standards ) (U.S. EPA, 2009a, 2010d), over 16,000 miles of streams and rivers and 463 over 370,000 acres of lakes and reservoirs in the U.S. were impaired in 2008 because of 464 pesticides, with atrazine (commonly used in corn production) specifically cited by several states 465 (U.S. EPA, 2010c). Atrazine was also estimated to be the most common pesticide lost from 466 agricultural lands in the Upper Mississippi River Basin (NRCS, 2010). 467

Corn production uses more pesticides than predicted for any other potential biofuel crop 468 produced in the U.S. (Pimentel and Patzel, 2005; Pimentel and Pimentel, 2008, p. 380; Ranney 469 and Mann, 1994). USDA ’s NASS estimates that insecticides were applied to 16 percent of the 470 2006 soybean- planted acreage (NASS, 2007b). USDA also estimates that herbicides were 471 applied to 98 percent of the planted soybean acreage in 2006. Soybean production releases less 472
p esticide to surface and ground water per unit of energy gained (Hill et al., 2006). 473

While effective pest control may be critical to achieving the yield gains that underpin 474 EISA biofuel projections and targets (Perkins, 2009), there are risks associated with the use of 475 pesticides. The FIFRA registration process is intended to minimize these risks. Many factors 476 contribute to the relative risks of pesticides on the environment, including fate and transport 477 characteristics, method of application, depth to ground water, and proximity to receiving waters. 478 To protect consumers against risks posed by ingestion of these pesticides, FFDCA requires the 479 establishment of pesticide residue tolerances on food using a standard of reasonable certainty of 480 no harm. 481

16 No

- till refers to the absence of soil tillage to establish a seed bed, meaning the farmer plants the crop directly into the previous year’s crop residue. In strip

- till , only the portion of the soil that is to contain the seed row is disturbed. In ridge

- till , plants grow on hills that a re the product of cultivation of the previous crop and are not tilled out after harvest . In mulch

- till , plant residues are conserved but a field cultivator or disks are used to till prior to planting to partially incorporate the residue into the soil.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Growing continuous corn (rather than in rotation with other crops) can increase 482 population densities of pests such as the corn rootworm, resulting in increased pesticide 483 applications to control these pest species (Whalen and Cissel, 2009). A USDA study projects that 484 cropland dedicated to continuous corn will increase by more than 4 percent by 2015 to reach the 485 15 billion gallons per year of ethanol from corn target (Malcolm et al., 2009). In addition, 486 increases in corn acreage and any conversion to corn of crops other than corn w ill most likely 487 increase total herbicide use . Increased corn and soybean production can result in the increased 488 use of herbicides that can run off or leach into surface water or ground water sources. 489

Integrated pest management (IPM) practices may help redu ce pesticide use by tailoring 490 treatment to pest infestation cycles, and by more precisely targeting the amount and timing of 491 applications. IPM focuses on extensive monitoring of pest problems, comprehensive 492 understanding of the life cycles of pests and their interaction with the environment, and very 493 precise timing of pesticide applications to minimize pesticide use. In addition to providing 494 environmental benefits of lower pesticide use, IPM often results in lower chemical pesticide 495 expenses and pest damage to crops, as well as preventing the development of pesticide- resistant 496 pests (Minnesota Department of Agriculture, 2010) . The use of cover crops is an IPM practice 497 that can dramatically reduce chemical application and soil erosion. USDA research in the 498 Mi dwest in 2006 demonstrated that autumn-planted small grain cover crops reduced soil erosion, 499 nitrate leaching, and suppressed weeds (Teasdale et al., 2007). 500

National adoption of IPM strategies varies. Corn and soybean growers reported scouting 501 for weeds, insects, and diseases on 50 percent of acres or more in 2000, but reported adjusting 502 planting or harvest dates to manage pests on less than 20 percent of acres (Weibe and Gollehon, 503 2006). 504

3.2.2.4 Pathogens and Biological Contaminants 505

The use of animal manure as a f ertiliz er has been tied to an increased risk of viruses and 506 bacteria leaching into the water supply. Pathogens such as Salmonella sp., Campylobacter sp ., 507 and Clostridium perfringens —along with additives such as livestock antibiotics and hormones— 508
may be released into surface or ground water when manure is applied to fields (Brooks et al., 509 2009; Lee et al., 2007a; Unc and Goss, 2004). The USDA Report to Congress on use of manure 510 for fertilizer and energy reports that approximately 12 percent of corn and 1 per cent of soybeans 511 are fertilized with manure (MacDonald et al., 2009). 512

The flow paths by which pathogens can contaminate ground or surface water are the 513 subject of current research. Transport through soil has been shown to remove harmful bacteria in 514

some ca ses, though this may depend on soil characteristics, the hydrologic regime (i.e., distance 515 to surface or ground water) and the pathogens in question (Malik et al., 2004; Unc and Goss, 516 2004). Contamination rates likely are greater where there is higher runo ff relative to infiltration, 517 a high water table, or a direct surface -ground water connection. Implementation of manure 518 management practices, such as covering or storage at elevated temperatures prior to application 519 can reduce runoff. In addition, applying manure during times of low runoff potential can reduce 520 the risk of water contamination (Moore et al., 1995; Guan and Holley, 2003). 521Chapter 3: Environmental Impact s of Specific Feedstocks

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 3-18 DRAFT—DO NOT CITE OR QUOTE 522 3.2.3 Water Quantity

523 3.2.3.1 Water Use

524 Over the entire biofuel supply chain (see Figu re 2-3 in Chapter 2), crop irrigation is by 525 far the most significant use of water in the etha nol production process, and it tends to be much 526 higher than water use for most other non-renewa ble forms of energy on an energy content basis 527 (Wu et al., 2009). In some geographic locations th is could lead to serious impacts on already 528 stressed water supplies, while in other locations water supply availability impacts are less likely 529 to occur. Future assessment of biofuel feedstocks will need to consider restrictions on water use 530 due to competing demand for water resources (Berndes, 2002).

531 For both corn and soybeans, the source for water used to irrigate crops varies from region 532 to region. In the West, surface water is largely us ed to irrigate crops; in the Great Plains and 533 Midwest, where the majority of corn and soybean production takes place, farmers rely heavily on 534 ground water (Kenny et al., 2009). In the future, as corn production increases to meet ethanol 535 demands, both geographical factors and the type of land/crop conversion will determine water 536 use impacts. Water use will increase as land in pa sture or other low- or non-irrigated uses are 537 converted to irrigated corn produc tion, especially in places like the Great Plains, where water 538 demand for corn irrigation is high

. Converting other crops, soybeans in particular, into corn will 539 have little effect on water use in the Midwest, but could increase the total amount of water used 540 for irrigation in the Plains because of corn’s relatively high water use intensity on a per area 541 basis (NRC, 2008).

542 Corn

543 Corn is relatively water-intensive compared to other crops. In some parts of the country, 544 water demands for corn are met by natural rainfa ll, while in other places supplemental irrigation 545 is required. For instance, in Iowa in 2007, less th an 1 percent of the more than 14 million acres 546 planted in corn was irrigated. In contrast, over 60 percent of Ne braska’s 9.5 million acres of corn 547 was irrigated in the sa me year (NASS, 2009).

548 Irrigation use for U.S. corn has been estimat ed to vary from a low of approximately 8 549 gallons of water per gallon of ethanol on averag e in Midwest states in one study (Wu et al., 550 2009) to a high of up to 1,000 gallons for states inthe Great Plains in another study (Dominguez551 Faus et al., 2009). While the data and methodol ogy used to calculate th ese estimates are not 552 uniform across studies, in general, water use is likely to be less th an 500 gallons (perhaps 553 substantially less) of irrigation water per gallon of ethanol in the Midwest and greater than 500 554 gallons per gallon of ethanol in more arid part s of the country (supporting information for Chiu 555 et al., 2009). Taking into account the total volume of corn starch ethanol produced, this might 556 translate into approximately 5 billion gallons of irrigation water in a si ngle season in places like 557 Iowa and Illinois versus 300 billion gallons in Nebraska (Chiu et al., 2009). The 2007 U.S. 558 national ethanol-production-weighted average fa rm-to-fuel pump water requirement per gallon 559 of ethanol in the U.S. was estimated to be 142 gallons (Chiu et al., 2009).Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Corn Stover 560

Allocation of proportionate water use based on the energy captured from corn starch 561 versus stover may be studied in the future as corn stover becomes a more common biofuel 562 feedstock . Water use for corn stover above and beyond corn cultivation is likely to be minimal or 563 negligible if undertaken with resource conservation practices, especially in the most productive 564

corn -growing regions of the U.S. where corn stover is not functionally necessary for retention of 565 soil moisture. If, however, corn stover is removed from dry corn cultivation areas with 566 supplemental irrigation (states like Nebraska), loss of soil moisture that would have otherwise 567 been retained by corn stover cover and contributed to productivity of the next season’s crop 568 (Blanco -Canqui and L al., 2009b) could necessitate additional irrigation. 569

Soybeans 570

Water for soybean cultivation, like corn, also comes from both natural precipitation and 571 through irrigation. In some places, the water requirements are largely met with precipitation. For 572 example, in 2007 in the leading soybean-producing state of Iowa, 8.6 million acres of soybeans 573 were grown of which less than 1 percent was irrigated (NASS, 2009). In 2007 Nebraska grew 3.8 574 mil lion acres of soybeans, of which over 40 percent was irrigated (NASS, 2009). 575

Average nationwide rates of soybean irrigation are estimated at 3,000 to 6,000 gallons of 576 irrigation water to produce a volume of biodiesel equivalent to a gallon of gasoline (U.S . DOE, 577 2006; Dominguez-Faus et al., 2009). These rates are not applicable to states such as Iowa, where 578 most soybeans are grown without irrigation. In Nebraska, however, where irrigation is heavily 579 utilized, greater than 4,000 gallons of irrigation water per gallon of gas equivalent is not an 580 unusual investment of water resources for biofuel production (supplemental information to 581 Dominguez-Faus et al., 2009). Overall, irrigation estimates for soybeans tend to be greater than 582 those needed to produce a volume of corn starch ethanol equivalent to a gallon of gasoline 583 (Dominguez-Faus et al., 2009). 584

3.2.3.2 Water Availability 585

Because agriculture accounts for such a large share of water use in the U.S. (35 percent of 586 withdrawals nationwide in 2005, and a much larger percentage in some parts of the country, 587 according to Kenny et al., 2009), changes in agricultural production could impact future water 588 availability. In particular, land conversion to corn for increased production of ethanol could 589 create more demand for water, adding to existing water constraints and potentially creating new 590

ones. The Great Plains states already have shortages, and water availability may decrease further 591 whe n typically non- irrigated pasture and CRP land is converted to irrigated corn production. 592 Converting other crops, soybeans in particular, into corn will have little effect on water use and 593 availability in the Midwest, but could increase the total amount of water used for irrigation in the 594 Plains because corn requires more water than soybeans on a per area basis in that region (NRC, 595 2008). 596

To a large extent, the current capacity to produce biodiesel from soybeans resides in 597 states with rain

- fed soybean cultivation. Such strategic siting of biodiesel production facilities 598 minimizes both demands for irrigation water for biodiesel feedstock and potential conflicts over 599Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE water availability required for other purposes such as power generation, public water use, and 600 recreation. However, if biodiesel production develops in places requiring greater soybe an 601 irrigation such as the Great Plains, water availability could be reduced. This is especially true if 602 irrigated soybean cultivation replaces other low or non-irrigated land uses. Because over 85 603 percent of irrigation withdrawals come from underground aqu ifers, ground water availability is 604 likely to be affected the most. 605

Both surface water and ground water withdrawals can negatively impact aquatic life. 606 Surface water withdrawals can reduce flood flows (or peak flow regimes), as well as reduce total 607 flow (or discharge) during summer months when irrigation requirements are high and surface 608 water levels are low (Poff and Zimmerman, 2010). Ground water availability is largely affected 609 by ground water withdrawals for irrigation. The consequences of excessive g round water 610 withdrawal can include reduced water quality, prohibitive increases in the costs of pumping, 611 reduced surface water levels through hydrological connections, and subsidence (Reilly et al., 612 2008). Several regions (e.g., High Plains aquifer, Lower Mississippi River alluvial aquifer) that 613 are already experiencing water shortages could be substantially impacted by increased corn 614 production for ethanol. Ground water withdrawals also have indirect impacts on stream flow. 615 Withdrawals from hydrologically connected aquifers can lower base flow to rivers and streams 616 that depend on ground water to maintain year- round stream flow. In some areas, stream flow has 617 been reduced to zero because of ground water depletion, but in other areas, minimum stream 618 flow duri ng the summer has been sustained because of irrigation return flow to streams 619 (Bartolino and Cunningham, 2003). 620

3.2.4 Soil Quality 621

3.2.4.1 Soil Erosion 622

Soil erosion can have substantial negative effects on soil quality by preferentially 623 removing the finest, uppermost soil particles, which are higher in organic matter, plant nutrients, 624 and water -holding capacity relative to the remaining soil (Brady and Weil, 2000). The soil 625 erosion impact of growing corn or soybeans for biofuel will vary, largely depending on the 626 particular land use/land -cover change and tillage practices. Conversion of uncultivated land, such 627 as C RP acreage, to corn or soybeans for biofuels is the land use change scenario most likely to 628 increase erosion and sedimentation . The USDA CEAP report on the Uppe r Mississippi River 629 Basin found that for land in long-term conserving cover, like CRP, soil erosion and sediment loss 630 were almost completely eliminated (NRCS, 2010). Moreover, CRP acreage in riparian areas 631 slows runoff, promoting the deposition of sediment, nutrients, and other chemicals. The USDA’s 632 Farm Service Agency estimated that, in 2008, CRP land collectively prevented 445 million tons 633 of soil from eroding (FSA, 2009). The soil- erosion effects of converting former or current 634 pasture land to corn will vary depending on prior erosion rates. Pasture land in the U.S. Southern 635 Piedmont region, for example, can exhibit soil stability equal to forested or conservation- tilled 636 land; converting this type of land to conventional corn production will increase soil erosion 637 (Franzluebbers et al., 2000). In contrast, if much of the increase in corn or soybean production 638 comes from a shift from other crops (in 2007, for example, the inc rease in corn acreage came 639 predominantly from a decrease in soybeans), the effect on soil erosion is likely to be much 640 smaller. A llocation of a higher percentage of corn or soybeans for biofuel production to land 641 currently in agricultural use likely will not alter soil erosion rates. 642Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Tillage practices can mitigate soil erosion on current agricultural lands. Conventional 643 tilling 17

Fin ally, removal of corn stover beyond a certain threshold may increase soil erosion 657
rates. Due to this and cost concerns, a recent s tudy suggested that only approximately 30 percent 658 of corn stover breaks up soil aggregates, increasing erosion by wind and water (Lal, 2003). In contrast, 644 conservation tillage

— defined as practice s that maintain at least 30 percent of the ground covered 645 by crop residue (Lal, 1997)—can considerably reduce soil erosion (Cassel et al., 1995; Shipitalo 646 and Edwards, 1998). No- till agriculture, a type of conservation tillage, disturbs the soil only 647 margi nally by cutting a narrow planting slit. According to the CEAP report, conservation tillage 648 is practiced on 96 percent of all crop acreage in the Upper Mississippi River Basin, with 23 649 percent in no-till, and only 5 percent in continuous conventional tillage (NRCS, 2010). 650 Conservation tillage practices may also partially mitigate the impact of converting CRP acreage 651 to biofuel corn production (Follett et al., 2009). A majority of CRP acreage in areas of the 652 Midwest are classified as highly erodible land , wh ere tillage practices are generally restricted by 653 the conservation compliance provisions of the 1985 Food Security Act (Secchi et al., 2009). 654 These compliance provisions can require corn

- soybean rotations with no- till cultivation (Secchi 655 et al., 2009). 656

18

3.2.4.2 Soil Organic Matter 668 would be available for sustainable harvesting in the U.S. if erosion rates were to 659 be kept lower than soil loss tolerances (T-values) as defined by the USDA NRCS (Graham et al., 660 2007). Because of wind erosion, the potential for corn stover removal in the Western Plain s tates 661 may be particularly limited (Graham et a l., 2007). Site cultivation practices may partially 662 compensate for the effects of residue removal. If no

- till agriculture w ere universally adopted, 663 sustainably harvested corn stover supplies are estimated to increase from approximately 30 to 50 664 percent (Gr aham et al., 2007). Yet, even with no- till management, corn stover removal rates at or 665 higher than 50 percent have been shown to increase erosion potential (Blanco -Canqui and Lal, 666 2009a). 667

Soil organic matter is critical because it retains plant nutrients and water, facilitates 669 carbon sequestration, promotes soil structure, and reduces erosion. The impact of corn and 670 soybean production for biofuel on soil organic matter will depend on the cultivated acreage

. 671 Corn production will negativel y impact soil quality on acreage where organic matter has 672 accumulated over time —for example, grasslands. If conventional tilling is used, a loss of organic 673 matter both to erosion and to the atmosphere as carbon dioxide due to increased microbial 674 decomposition is likely to occur (Reicosky et al., 1995). Estimates of carbon loss following 675 conventional tilling of previously undisturbed soils range from 20 to 40 percent—although how 676 much carbon is respired to the atmosphere versus lost to erosion is unclear (Davidson and 677 Ackerman, 1993). Assuming carbon loss to the atmosphere, it has been estimated that conversion 678 of grasslands in CRP to corn production would create a carbon debt requiring approximately 48 679 years to repay (Searchinger et al., 2008). In contra st, increased corn or soybean production on 680 currently cultivated land will have a smaller effect on soil organic matter, particularly where 681 substantial amounts of crop residues are returned to the soil or a cover crop is used (Adviento- 682

17 De fined as any tillage practice that leaves less than 15 percent of crop residues on the soil surface after planting.

18 It should be noted that the removal of crop residues by percent mass is not the same as by percent soil coverage. All the percentages from the studies discussed here are by percent mass, unless otherwise noted.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Borbe et al., 2007; Drinkwater et al., 1998; Lal, 2003). W hile soil quality degrades over time

, 683 yields and production can be maintained by the use of fertilizers both commercial and organic. 684

The harvesting of crop residues, such as corn stover, removes plant material that would 685 otherwise remain on and potentially be incorporated into the soil. The removal of corn stover 686 therefore has important implications for soil quality, chiefly via effects on soil retention, organic 687 matter content, nutrients, and compaction. Stover removal rates of 25 to 75 percent have been 688 shown to decrease soil organic matter across several soil types even under no

- till management 689 (Blanco

- Canqui and Lal, 2009a). Therefore, there is concern that high stover removal rates may 690 decrease soil carbon sequestra tion and lower crop yields (Karlen et al., 2009). W hatever the 691 removal rate for a particular site, it has been recommended that soil erosion and organic matter 692

co ntent be periodically monitored to allow stover removal rates to be adjusted accordingly 693 (Andrews, 2006). The effects of crop residue removals on crop yields have been shown to be 694 highly variable depending on soil type, climate, topography, and tillage management, among 695 other characteristics (Blanco -Canqui and Lal, 2009b). Research to date suggests corn stover 696 removal rates should be determined based on site- specific criteria to maximize soil quality. 697

3.2.5 Air Quality 698

Air quality impacts during cultivation and harvesting of corn and soybeans are associated 699 with emissions from combustion of fossil fuels by farm equipment and from airborne particles 700 (dust) generated during tillage and harvesting. Soil and related dust particles (e.g., fertilizer, 701 pesticide, manure) become airborne as a result of field tillage, especially in drier areas of the 702 country. In ad dition, emissions result from the production of fertilizers and pesticides used in 703 corn and soybean production, and the application of fertilizers and pesticides to each crop. Air 704 emissions associated with cultivation and harvesting of corn and soybeans fo r biofuel will mostly 705 occur in sparsely populated areas. Subsequent stages in the biofuel supply chain (see Figure 2-3), 706 including feedstock logistics and biofuel production, distribution, and use, also affect air quality 707 and are discussed in Chapter 4. 708

3.2.5.1 Cu ltivation and Harvesting 709

Cultivating and harvesting corn and soybeans require a range of mechanized equipment 710 that utilize different fuels, including diesel, gasoline, natural gas, and electric power (Sheehan et 711 al., 1998a). Generally, equipment used to produce corn and soybeans consumes more diesel than 712 for most other crops, while the rate of gasoline consumption is somewhat less than that of other 713
crops. Primary emissions from fuel use include nitrogen oxides ( NO x ), volatile organic 714 compounds (VOCs), carbon monoxide (CO), sulfur dioxide (SO 2 ) (primarily from gasoline), and 715 coarse and fine particulate matter ( PM 10 and PM 2.5 ). Gasoline use may also result in benzene, 716 formaldehyde, and acetaldehyde emissions . For corn, approximately 14 gallons of diesel f uel is 717 used per acre for tillage, harvest , and hauling. Fuel use for tillage comprises more than half of 718 this amount ; actual usage depends on soil properties and conditions (Iowa State University, 719 2009). With respect to corn stover, additional fuel use depends on the method of stover harvest. 720 For example, m ethods that can simultaneously collect grain and stover will use less fuel than 721 those requiring multiple passes with a harvester. For this reason, one- pass harvesters are 722 currently being developed and tested (Shinners et al., 2009). 723Chapter 3: Environmental Impact s of Specific Feedstocks

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 3-23 DRAFT—DO NOT CITE OR QUOTE 724 Emissions are also associated with generati on of electricity used for irrigation water 725 pumping. Irrigation power needs are estimated to range from 3 to 11 kilowatt-hours (kWh) per 726 irrigated acre, depending on the region, with a na tional average of 8 kWh per irrigated acre. For 727 soybean cultivation, electricity use is estimated to be 4.6 kWh per acre (Sheehan et al., 1998a). 728 Emissions associated with this use depend on the source of the electricity consumed. Coal is the 729 predominant fuel source for electricity in the Midwest, accounting for 71.3 percent of generation 730 in the 12 primary corn-producing states. Coal-fir ed power plants are significant sources of SO 2 , 731 NO x , carbon dioxide (CO 2 ), and mercury emissions.

732 Corn with a moisture content of over 18–20 pe rcent may require drying prior to storage 733 to avoid spoilage (South Dakota State Universi ty, 2009). Grain driers us e liquid petroleum gas 734 (LPG) and electricity. LPG and electricity use de pend on grain moisture content at harvest. For 735 example, typical Midwest grain harvest conditions and yields require 20 gallons of LPG per acre 736 harvested. The exact amount depends on gr ain moisture conditions at harvest.

737 3.2.5.2 Fertilizers and Pesticides

738 Pesticides are commonly used on both corn and soybeans, with corn having more 739 intensive application rates (NRC, 2008, p. 3, as cited in U.S. EPA, 2010b) than soybeans. Corn 740 has the highest nitrogen fertilizer use per acre of any biofuel feedstock. Because soybeans are 741 legumes, they require much lower amounts of fe rtilizer, particularly nitrogen (NASS, 2006, 742 2007b). Soybeans have the capacity to derive nitroge n from the atmosphere and therefore require 743 less external nitrogen fertilization than corn, resu lting in less nitrogen runoff in the surface water.

744 Air emissions associated with fertili zer manufacturing and transport include NO x , VOC, 745 CO, and particulate matter (PM 10 and PM 2.5 ), while pesticide production and blending may result 746 in emissions of 1,3-butadiene, benzene, and formaldehyde.

747 Application of fertilizers and pesticides may re sult in releases to the air and volatilization 748 of pesticide ingredients. The pr imary pollutants associated with the releases to air are benzene 749 and acrolein. The results described are consiste nt with another study, which found increases in 750 benzene, formaldehyde, acetaldehyde, and butadie ne emissions, although that study included 751 feedstock transport and so is not directly comp arable (Winebrake et al., 2001). Emissions of CO, 752 NO x , and SO 2 increased with the use of corn stover as a feedstock in a hypothetical system (i.e., 753 a simulation based on corn stover li fe-cycle data), with higher NO x emissions mainly due to 754 denitrification of increased amount s of nitrogen fertilizers added to farm soils (Sheehan et al., 755 2004).

756 3.2.6 Ecosystem Impacts

757 3.2.6.1 Eutrophication, Erosion, and Biodiversity Loss

758 The impact of increased corn and soybean cultivation on ecosystem and biodiversity 759 depends, in large part, on wh ere crop production occurs and wh at management techniques are 760 used. Major ecosystem-related impacts that c ould result from additional corn and soybean 761 production are eutrophication, soil eros ion and its associated increa se in turbidity of receiving 762 waters and sedimentation in basins, and impact s to biodiversity. Eutrophication can occur as 763 fertilizer application increases nutrient loadings (nitrogen and phosphorus) in surface waters suchChapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE as streams, rivers, lakes, wetlands, and estuaries (U.S. EPA, 2010b). Increased phosphorus 764 concentration has been correlated with declines in invertebrate community structure, and high 765 concentrations of ammonia nitrogen are known to be toxic to aquatic animals. Severe oxygen 766 depletion and pH increases, both of which are correlated with eutrophication, have been known 767 to cause growth problems and mortality in fish and invertebrates (U.S. EPA, 2010b). In addition, 768 as aquatic systems become more enriched by nutrients, algal growth can cause a shift in species 769 composition. Hypoxia threatens commercial and recreational fisheries in the Gulf of Mexico 770 (U.S. EPA, 2010b) and limits biodiversity (Wang et al., 2007a). 771

Soil erosion can also lead to an increase in wetland sedimentation, which may, depending 772 on sediment depths, cover viable seeds sufficiently to prevent germination (Gleason et al., 2003). 773 In aquatic ecosystems, sediments increase turbidity and water temperatures and bury stream 774 substrates, limiting habitat for coldwater fis h (U.S. EPA, 2006a). 775

In areas where corn production is already significant, increased corn acreage can further 776 reduce landscape diversity (Landis et al., 2008), which might in turn impact other aspects of 777 biological diversity and the ecosystem services ass ociated with biodiversity. In Iowa, Michigan, 778 Minnesota, and Wisconsin, biological control of soybean aphids was found to decline as the 779 proportion of corn in the local landscape increased, resulting in increased expenditures for 780 pesticides and reduced yie lds (Landis et al., 2008). In the Prairie Pothole region of Iowa, 781 Minnesota, North Dakota, and South Dakota, landscapes with higher proportions of corn acreage 782 had comparatively fewer grassland bird indicator species (Brooke et al., 2009). I f landscape 783 diversity decreases (especially in the case of transforming CRP land into corn production), 784 migratory birds will lose habitat and likely decline in numbers. On CRP lands, several grassland 785 bird species have increased in abundance, and it is estimated that, wi thout the 3 million hectares 786 of CRP in the Prairie Pothole region of the U.S., over 25 million ducks would have been lost 787 from the annual fall migratory flight s between 1992 and 2004 (Dale et al., 2010). 788

The removal of corn stover residues from agricultural corn fields for ethanol production 789 has potential consequences on aquatic ecosystems and local biodiversity. Removing crop 790 residues from farm fields has been shown to affect both terrestrial and soil biota. Crop residue 791 removal has been correlated with decreases in the diversity of biota (Lal, 2009; Johnson et al., 792 2006). 793

Intensification of soybean production and pesticide use may also threaten biodiversity 794 and nearby biota (Artuzi and Contiero, 2006; Koh and Ghazoul, 2008; Pimentel, 2006). The 795 change in l ocal habitat from corn- soybean -corn rotation to continuous corn production may 796 decrease the support for biological control in soybean cropping systems, as reduced landscape 797 diversity decreases the habitat availability of many insects and animals in the loc al region 798 (Landis et al., 2008). Also, agricultural herbicides affect the composition of local plant 799 communities, which then affects the abundance of natural enemy arthropods and the food supply 800 of local game birds (Taylor et al., 2006). Fungicide pollution from runoff events has been shown 801 to impact algae and aquatic invertebrates in areas where soybeans are intensively grown (Ochoa

802 Acuna et al, 2009). 803Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.2.6.2 Invasive Plants 804

Modern varieties of corn and soybeans under production today in the U.S. pose little risk 805 of dispersing seeds or regenerative plant parts or creating hybrids with related plants that will 806 become weeds or invasive plants in the future. Corn and soybeans rarely overwinter successfully 807 in major production areas, but on occasion, seed from the previous year’s crop can emerge in the 808 following year and the plants persist through a single growing season as a weed. Such 809 populations of plants do not become a chronic problem, however, because they do not sustain 810 themselves (Owen, 2005). To date, no cases of invasive corn or soybeans have ever been 811 reported in natural areas in the U.S. However, since U.S. seed and biotechnology companies 812 working to improve feedstocks may propagate corn in areas such as Mexico where corn and its 813 progenitors originated, it is possible that novel corn cultivars or their hybrids could spread 814 beyond the cultivated fields and survive. This potential for intermixing genetically modified 815 plants with ancestral land acres is the subject of international scientific and regulatory inte rest 816 (Mercer and Wainwright, 2008). 817

The extensive cultivation of row crops that are genetically engineered to resist the 818 herbicide glyphosate may result in indirect effects on other weed species and invasive plants. 819 One study correlated the increased use o f this herbicide with the appearance of glyphosate 820 resistance in at least ten agricultural weeds in the U.S.; loss of effectiveness of glyphosate could 821 encourage the use of more toxic herbicides (NRC, 2010). 822

3.2.7 Assessment 823

Corn and Soybean A creage : Between Sep tember 2010 and August 2011, approximately 824 38.4 percent of corn consumed domestically is projected to be converted in to ethanol biofuel 825 (NASS, 2010a; ERS, 2010c). Corn acreage has increased over 2005 levels in part due to ethanol 826 demand, and planted acreage is expected to increase from 2008/2009 levels of 85.9 million acres 827 to 90 million acres in 2019 to meet the 15 billion gallons per year annual target under EISA 828 (USDA, 2010c). Currently, 5.6 percent of the soybean harvest goes to biodiesel production, and 829 USDA expects this percentage to increase to 7.8 percent by 2012 and hold steady through 2019. 830 USDA also expects that soybean acreages will hold steady at 76 million acres, though this 831 number may be higher to meet the EISA target. Moreover, it may b e necessary to increase 832 acreage yield, or the portion of the soybean harvest that is devoted to biodiesel in order to meet 833 EISA targets (FAPRI, 2010a). Use of corn stover for ethanol production is not expected to 834 increase acreage dedicated to corn. 835

Land Us e/Land Cover Change : Much of the environmental impact of corn starch ethanol 836 and soybean biodiesel production depends on the types of land put into cultivation. To date, most 837 additional acreage has originated from lands currently in crop production. Expanding corn crop 838 production to CRP or previously uncultivated acreage will likely have varying degrees of 839 environmental impacts, depending on site- specific characteristics. 840

Water Quality : Increasing production of corn for ethanol and soybeans for biodiesel ma y 841 have implications for water quality. Increased corn and soybean production could increase 842 nutrient, sediment, and pesticide loadings to water bodies, including the Gulf of Mexico, Great 843 Lakes, and Chesapeake Bay. Private drinking water wells could see increases in nitrate and 844Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE public drinking water systems could see increases in their costs to lower nitrate levels. However, 845 some of the potential increased nutrient loadings from corn grown for ethanol might be offset by 846 increasing per

- acre corn and soybean yields and by implementing comprehensive conservation 847 systems. Increased risk of pathogens entering surface waters from application of animal manure 848 fertilizers is also possible. Removal of corn stover could lead to loss of soil surface cover, 849 thereby incr easing runoff of nitrogen and phosphorus to surface waters; harvesting corn stover 850 may reduce soil nutrient availability, leading to increased fertilizer applications 851

Water Availability : The magnitude of environmental impact from increased corn and/or 852 soyb ean production for biofuel will vary geographically. If corn replaces other crops in the 853 Midwest, water availability will be minimally impacted. Increased corn and soybean production 854 in areas requiring irrigation, such as the Great Plains

, will increase wa ter usage, potentially 855 decreas ing water availability . Removal of corn stover for ethanol will not affect water 856 availability in most parts of the U.S. 857

Soil : Impacts of expanding corn and soybean production will vary, depending on the 858 converted land use. Neg ative soil quality impacts will arise from converting a creage protected 859 with perennial vegetation to conventional corn and soybean production, which will likely 860 increase soil erosion, sedimentation , and nutrient losses. Removal of corn stover for ethanol m ay 861 lead to a decline in organic matter, decreasing soil carbon sequestration and adversely impacting 862 crop yields. Impacts can be minimized through site

- specific BMPs that limit soil erosion and 863 ensure that the amount of residue remaining on the field sustains soil quality and nutrient inputs 864 for subsequent crop productivity. 865

Air Quality : An increase in the production of corn and soybean for biofuel will likely 866 lead to increased pollution from fossil fuels associated with cultivation and harvesting and from 867 airborne particles (dust) generated during tillage and harvesting. Air emissions also result from 868 the production of fertilizers and pesticides used in corn and soybean cultivation, and the 869 application of fertilizers and pesticides for each crop. Increasing their use will likely increase the 870 volume of emissions. 871

Ecosystem Health/Biodiversity : Ecosystem health/biodiversity impacts include 872 degradation of aquatic life due to eutrophication, impaired aquatic habitat due to sedimentation 873 from soil erosion, and decreases in landscape diversity. Conversion of CRP lands, which are 874 predominantly grasslands, may lead to declines in grassland birds, ducks, and other wildlife that 875 use these lands as habitat. 876

Invasive Species : Corn and soybean typically are not invasive in the U.S. corn and 877 soybean

- growing regions. 878

3.2.7.1 Key Uncertainties and Unknowns 879

Uncertainties and a scarcity of data exist in many key areas concerning environmental 880 imp acts of biofuel feedstock production. In particular: 881

**•** The impacts of additional soybean and corn production are determined by where 882 the production occurs and the types of management practices employed, including 883Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE the extent of tile drainage. However, it is h ighly uncertain where production will 884 occur and the extent to which BMPs will be employed. In particular: 885 886

— Increased corn and soybean yields may of fset the need for increased acres 887 in production to achieve EISA goals in 2022. However, the extent to 888 which y ield increases will occur is currently unknown, and thus the extent 889 to which increased production of corn and soybeans will occur on 890 marginal lands, CRP, and/or via continuous corn production on existing 891 lands now in rotation with other crops is also uncer tain

. 892 893

— The extent to which BMPs are currently implemented on cropland 894 nationally is unknown, and the potential for future improvements, 895 including improvements in yield; management of nutrients, pesticides, 896 drainage, and energy use; and erosion control systems, is also uncertain. 897 898

**•** The ability to track impacts will depend on the quality and consistency of 899 monitoring fertilizer and pesticide usage, such as data provi ded by USDA’s 900 National Agricultural Statistics Services. 901 902

**•** The ability to evaluate current and future water shortages associated with ethanol 903 and biodiesel production is limited by the available data. Annual measurements of 904 the extent of irrigation and amou nts of surface and ground water used are not 905 systematically collected nationwide , forcing researchers to use incomplete 906 information to calculate crude water use estimates. Estimates of water use to 907 produce soybeans for biodiesel are even less certain than those for corn 908 production. The connection between water use for corn and soybean production 909 and impacts on water availability and water shortages is also surrounded by 910 uncertainty. The availability of fresh water for a particular use is determined by 911
many factors, including rainfall, soil water retention and ground water recharge, 912 water demand for competing uses, and water contamination; attribution of water 913 shortages to a specific use may be difficult to measure without improvements in 914 data collection (All ey et al., 2002; Reilly et al., 2008). 915 916

**•** The uncertainties regarding the effect of corn and soybean production on soil 917 quality arise predominantly from uncertainties regarding the amount and type of 918 land converted to corn or soybeans as a result of biofuel demand. For example, if 919 the USDA soybean acreage projections hold and additional soybean acreage is not 920 required to meet biodiesel demand, then the impact of soybeans for biodiesel on 921 soil quality is likely to be relatively minimal. However, if soybean acr eage 922 increases beyond current levels, determining how much land is being converted, 923 the previous crop-type of that land, and its geographical location will be necessary 924 to assess the impact of this increase on soil quality. More studies on land use/land 925 cover changes as a result of ethanol and biodiesel demand are needed. 926 927

**•** Secondarily, uncertainties regarding the effect on soil quality are caused by lack 928 of detailed land management data . For example, more frequent and detailed 929Chapter 3: Environmental Impact s of Specific Feedstocks

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 3-28 DRAFT—DO NOT CITE OR QUOTE 930 data—including geographical location—on tillage practices employed would 931 substantially reduce uncertainties su rrounding the soil quality response of 932 producing biofuels. 933 934 **** The key uncertainties with respect to ai r quality impacts of increased corn and 935 soybean production are similar to water qua lity with respect to fertilizer and 936 pesticide use and application. In addition, NO x emission rates from fertilized soil 937 are highly uncertain and variable as they rely on microbial co nversion of fertilizer 938 to nitrate which in turn is influenced by environmental conditions. The extent to 939 which cover crops and tillage practices are employed, both of which can reduce 940 fugitive dust emissions, are also highly uncertain. For corn stover, there are a 941 range of assumptions regarding cropping practices, harvest t echniques, and farm 942 inputs that require more study. 943 944 **** Ecosystem health and biodiversity, in cluding fish and wildlife, are highly 945 impacted by uncertain environmental factor s such as nutrient and sediment runoff. 946 Nutrient loadings from row crop pro duction into surface waters depend on a 947 variety of factors, includi ng variations due to weathe r and are therefore widely 948 variable (Powers, 2007). Regardless, the ability to reduce chemical exposure of 949 biota will be beneficial to the ecosystem and local biodiversity. In addition to 950 resolving uncertainties about those factor s, more studies are needed on landscape951 level associations between corn and soybean production a nd terrestrial and 952 aquatic biodiversity, as well as biodivers ity-related services such as pollination 953 and natural pest control. 954 955 **** There is substantial uncertainty regard ing the impacts of climate change on 956 regional precipitation patterns and temperat ures, which could si gnificantly change 957 water demand and availability, cr op yield, runoff, and soil loss. 958 959 3.3 Perennial Grasses

960 3.3.1 Introduction

961 Perennial grasses are herbaceous plants that gr ow in successive years from the same root 962 system. They lack the sugar and starch content to be converted directly into ethanol using 963 conventional methods, but can be converted us ing cellulosic conversi on technologies. While 964 cultivation of perennial grasses has potential environmental advantages over traditional row 965 crops such as corn and soybeans, major technolog ical challenges exist for the development of 966 these more advanced biofuel conversion technolo gies. Currently, no commercial-scale facilities 967 for converting perennial grasses to cellulosic ethanol are operating in the U.S.; however, six 968 switchgrass cellulosic et hanol production facilities ar e under development (RFA, 2010).

969 The predominant perennial grasses for biof uels are likely to be monocultures of 970 switchgrass ( Panicum virgatum ) or Giant Miscanthus ( Miscanthus x giganteus) , hereafter 971 referred to as Miscanthus. Research suggests that an aggressive genetics program to create fast972 growing strains could increase production of both feedstocks dramatically over current 973 production levels (Vogel and Masters, 1998). The rese arch community is also exploring mixturesChapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE of n ative grassland species

— referred to as low -input high- diversity (LIHD) mixtures

— as a 974 feedstock (see text box on next page). Compared to their constituent monoculture perennial 975 grasses, LIHD mixtures have often demonstrated higher bioenergy yields (i.e., gallons of biofuel 976 produced per unit of land), and a greater ability to grow in infertile soils, although much less is 977 known about their commercial potential (Tilman and Lehman, 2006) . Most research and 978 development has been conducted on monocultures of switchgrass and Miscanthus , therefore, 979 these species are the focus of this section. 980

Switchgrass, a native plant of North America, has historically been grown in the U.S. as 981 forage for grazing livestock (Parrish and Fike, 2005). R ecently , it has entered breeding programs 982 and agronomic testing as a biofuel feedstock. Miscanthus , which is native to Asia

, has been 983 develop ed and tested as a biofuel feedstock largely in Europe. Considerable genetic variation in 984 both these species has yet to be explored to optimize feedstock production and biofuel refining 985 (Keshwani and Cheng, 2009) , but promising traits

, incl uding low lignin and ash content, and late 986 or absent flowering periods (Jakob et al., 2009), indicate ample potential for high crop yields and 987 efficient conversion to ethanol (Jakob et al., 2009). While standard irrigation, fertilizer, and 988 pesticide use practices have yet to be developed, recent small

- scale farming and larger

- scale 989 studies, such as those conducted by the U.S. Department of Energy’s Regional Biomass Energy 990 Feedstock Partnership, continue to inform estimates of biofuel perennial grass cultivation and 991 resource requirements (Parrish and Fike, 2005). Farm

- scale studies have demon strated that 992 ethanol yield from switchgrass ranges from approximately 240-370 gallons per acre compared to 993 an average of 330 gallons per acre for corn grain (Schmer et al ., 2008). 994

EISA and Section 211(o) of the Clean Air Act limit land conversion for biofuels to 995 existing agricultural land cleared or cultivated prior to Dec. 19, 2007, or land that was non996 forested and actively managed or fallow on Dec. 19, 2007 (Clean Air Act, Section 211[o]). As of 997 November 2009, approximately 28 million of the 31.2 million CRP acres were vegetated with 998 mixtures of native or introduced grasses for a variety of environmental purposes, including 999 wildlife habitat, erosion control, and water quality. Economic modeling of global bioenergy 1000 markets (POLYSYS) estimates that approximately 8-13 million acres of CRP land and 10-23 1001 million acres of agricultur al crop land in the U.S. could possibly (but not necessarily likely) be 1002 converted to switchgrass production, depending on economic factors (Walsh et al., 2003). The 1003 gross impact on CRP land already growing switchgrass would be minimal, and the estimated 1004

com bined conversion of “idle” and “pasture” lands to switchgrass production could be between 1005 0.78 and 5.58 million acres (Walsh et al., 2003). Comparable quantitative information is not 1006 available for Miscanthus, however, high biomass yields on areas with poor soil quality in 1007 southern Illinois demonstrate the potential for Miscanthus on low fertility lands (Pyter et al., 1008 2004). In addition to CRP land, abandoned cropland is hypothetically available for perennial 1009 grass cultivation. Assuming suitable technology a nd infrastructure exists, an estimated 25 billion 1010 gallons of ethanol could potentially be produced annually if switchgrass is grown on the 1011 approximately 146 million acres of abandoned agricultural land in the U.S., as long as these 1012 lands do not fall under restrictions described in Section 211 (o) of the Clean Air Act (U.S. EPA, 1013 2010b, Chapter 6). 1014

1015

1016Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Native Grasslands as a Biofuel Feedstock 1017 1018 Recent research has suggested using mixtures of native perennials as a feedstock on marginal or infertile 1019 lands (Tilman et al., 2006 ; Tilman et. al, 2009; Campbell et al., 2008; Weigelt et al., 2009 ). This practice 1020 is limited by several technological and management hurdles, yet also enjoys many environmental benefits 1021 not found to the same degree in other feedstocks discussed in this report. Termed “low-input high1022 diversity” (LIHD) mixtures, they are essentially comprised of several plant species that perform different 1023 functions within the community (e.g., high root mass to prevent soil erosion, nitrogen fixation to reduce 1024 fe rtilizer inputs) potentially at different times (e.g. spring versus fall) or the same function in a different 1025 manner (e.g., root growth and soil carbon sequestration at shallow versus deeper soil depths). LIHD 1026 mixtures, by definition, have more plant biodiversity than other monoculture- based feedstocks. This 1027 higher plant biodiversity is often associated with a variety of benefits, including higher stability of 1028 production, higher quality of habitat for wildlife, lower potential for invasion of the community, reduced 1029 need for chemical inputs (fertilizers, pesticides), and reduced potential for plant disease and crop losses 1030 (Fargione et al., 2009; Hooper et al., 2005; Loreau et al., 2002 ; Reiss et al., 2009 ). When systems are 1031 viewed as a composite of many co -occurring processes (e.g. primary production, soil stabilization, and 1032 decomposition), polycultures sustain higher levels of multiple processes, sometimes termed “ecosystem 1033 multifunctionality” (Hector and Bagchi, 2007; Zavaleta, 2010). Diverse mixtures also o ften produce more 1034 biomass than their average constituent species grown in monoculture; however, the productivity of the 1035 most productive constituent species is in many cases similar to that of the mixture (Cardinale et al., 2006; 1036 Loreau et al., 2002 ; Cardinale, 2007). Although it seems likely that highly productive feedstocks (e.g., 1037 switchgrass and Miscanthus ) managed for maximum production will produce more biomass for biofuel 1038 production than LIHD mixtures, there are no direct field

- scale comparisons between LIHD and other 1039 feedstocks with which to evaluate this assumption. The only comparison to date found that switchgrass 1040 grown on productive lands across the Midwestern corn belt (Nebraska, South Dakota, North Dakota) out1041 produced LIHD grown on unproductive land in Minnesota (Schmer et al., 2008). However, monoculture 1042 crops are expected to require more active management (e.g., to prevent losses from pests) than 1043 polycultures such as LIHD (Hill et al., 2006 ; Tilman et al., 2009; Weigelt et al. 2009 ). Prod uction of a 1044 feedstock composed of a mixture of species will likely face greater technological and management 1045 hurdles than production of single

- species feedstocks. For example, a mixture of species, having variable 1046 tissue densities and arrangements in the c ropping system, may be more difficult to harvest, transport, and 1047 process into biofuel than a relatively uniform feedstock grown from a single species. Much more research 1048 is needed in this area to determine the potential role of LIHD as a biofuel feedstock on marginal or 1049 infertile lands. 1050

3.3.1.1 Current and Projected Cultivation 1051

Perennial grasses could thrive across many regions of the contiguous U.S. (see 1052 Figure 3- 5). Since many of these species, including switchgrass, have historically dominated 1053 much of the Midwestern landscape, they are well suited to grow over much of the agricultural 1054 region. 1055Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 1056 Source: Dale et al., 2010, updated from Wright, 1994 1057

Figure 3

- 5: Generalized Map of Potential Rain- fed Feedstock Crops in the Conterminous 1058 United States Based on Field Plo ts and Soil, Prevailing Temperature, and Rainfall Patterns 1059

3.3.1.2 Overview of Environmental Impacts 1060

As production of biofuel from perennial grass becomes technologically and economically 1061 viable, demand for perennial grass will increase. This will result in conver sion of qualifying land 1062 to perennial grasses, the location and extent of which will depend on region- specific agricultural 1063 and economic conditions. Perennial grass production will likely require traditional agricultural 1064 activities, including pesticide, fer tilizer, water, and fuel/energy usage. The intensity of these 1065 activities relative to the land management practices they are replacing will determine the extent 1066 to which perennial grass production impacts water quality, water availability, air quality, and soil 1067 quality. Finally, perennial grass feedstock transport, which often involves seed movement, may 1068 result in unintended dispersal and the spread of invasive grasses. 1069

3.3.2 Water Quality 1070

Perennial grasses, sometimes grown as a conservation practice along the mar gins of 1071 agricultural fields to reduce sediment and nutrient runoff into surface water and wetlands, are 1072 expected to have fewer water quality impacts than conventional agricultural crops (Keshwani 1073 and Cheng, 2009). This will depend, however, on the agricultural intensity of the perennial grass 1074 cropping system (e.g., the extent of fertilizer and pesticide use). Table 3 -3 shows inputs needed 1075 to grow perennial grasses compared to agricultural intensity metrics associated with growing 1076 conventional crops. 1077Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Table 3

- 3: Comparison of Agricultural Intensity Metrics for Perennial Grass and Conventional Crops

Metric Reduction Relative to Corn

- Wheat

- Soybean Average
Erosion 125 fold
Fertilizer 1.1 fold
Herbicide 6.8 fold
Insecticide 9.4 fold Fungicide 3.9 fold Source: Ranney and Mann, 1994. 1078 1079 3.3.2.1 Nutrient Loading 1080

Nutrients —Surface Water Impacts 1081

Relative to annual crops, such as corn and soybeans, production of switchgrass and 1082 Miscanthus requires less fertilizer and reduces nutrient runoff. Switchgrass is inherently e fficient 1083 in its nitrogen use, as well as its use of potassium and phosphorus (Parrish and Fike, 2005). 1084 S witchgrass and Miscanthus are both nutrient- efficient because they store carbohydrates and 1085 nutrients in their roots at the end of the growing season (Be ale and Long, 1997; Beaty et al., 1086 1978; Simpson et al., 2008). Therefore, the practice of harvesting the above-ground biomass 1087 reduces the need for fertilization in subsequent growing seasons. A recent study reported that 1088 Miscanthus can fix atmospheric nitr ogen, which could be a large benefit to its use as a feedstock 1089 (Davis et al., 2010). Studies have shown no response in Miscanthus growth to nitrogen additions, 1090 suggesting these fertilizers are not needed in its production (Clifton -Brown et al., 2007; 1091 Danal atos et al., 2007). In contrast, switchgrass yields increase with nitrogen fertilization, with 1092 recommended application rates for switchgrass grown for biofuels ranging from 41 to 120 kg 1093 nitrogen/ha/year (37 to 107 lbs nitrogen/acre/year), varying by region (McLaughlin and Kszos, 1094 2005) . Data for switchgrass and Miscanthus have been generally based on experimental plots, 1095 and management and yields may differ at the farm

- scale. However, if these lower nitrogen 1096 fertilization rates hold, average nitrogen losses to surface waters should be lower relative to the 1097 production of corn starch ethanol (ORNL, n.d.). 1098

Nutrients — Coastal Waters Impacts 1099

As mentioned above, switchgrass and Miscanthus cropping systems are expected to 1100 require fewer fertilizer additions compared to traditional row crops, and have been shown to 1101 reduce chemical oxygen demand in runoff when used as filter strips (Keshwani and Cheng, 1102 2009). This will minimize their impact on the hypoxic zones of U.S. coastal waters. 1103

3.3.2.2 Sediment 1104

Switchgrass and other peren nial grasses have been used as an erosion control 1105 management practice to reduce sediment loads from row crops (Hill, 2007; McLaughlin and 1106 Walsh, 1998; U.S. EPA, 2009a). Perennial grasses have been shown to reduce erosion 125-fold 1107 when compared to an average of corn, wheat, and soybeans (see Table 3-3 ). Therefore, assuming 1108Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE good agricultural practices, switchgrass production is not expected to increase sediment loads to 1109 surface waters. 1110

3.3.2.3 Pesticides 1111

Perennial grasses, such as switchgrass (native to the U.S. ), are generally less susceptible 1112 to pests than traditional row crops (Oyediran et al., 2004; Keshwani and Cheng, 2009). A 2004 1113 controlled greenhouse study found that recovery of a dominant pest (western corn rootworm) 1114

was 0.2 to 82 times more likely from corn than from 20 other grass species native to the Midwest 1115 (Oyediran et al., 2004). However, most species are likely to be more susceptible to pests when 1116 grown in monocultures as compared to polycultures. T he lack of commercial perennial grass 1117 production as biofuel feedstock therefore makes it difficult to predict how much pesticide would 1118 be needed for this application and what the environmental impacts would be. In non- commercial 1119 production, pesticide releases from perennial grass plantings are much less tha n from corn or 1120 soybeans (Hill et al., 2006). Switchgrass plantings use approximately 90 percent less pesticide 1121 than row crops (Keshwani and Cheng, 2009). However, herbicides are used initially to establish 1122 and maintain switchgrass plantings for harvest. Switchgrass filter strips have been shown to 1123 reduce dissolved atrazine and metachlor concentrations in runoff (Keshwani and Cheng, 2009). 1124 Information relevant to potential pesticide use for Miscanthus in the U.S. is generally lacking ; 1125 however, researchers in Europe have report ed that pesticide requirements are low compared to 1126 row crops (Lewandowski et al., 2000). 1127

Of particular concern is how cellulosic feedstock production may impact the spread of 1128 the western corn rootworm (WCR), whose soil- borne larval stage is estimated to be responsible 1129 for more than $1 billion in annual losses in the U.S. Corn Belt (Rice, 2003) . Recent research 1130 reported that WCR is able to use Miscanthus and several North American grasses as a host

, 1131 though not as effectively as corn (Oyedi ran et al., 2004; Spencer and Raghu, 2009). Similar 1132 information on WCR use of switchgrass as a host is not available, though perennial grasses 1133 generally are more resistant to pests than corn (Lewandowski et al., 2003; Oyediran et al., 2004). 1134

3.3.2.4 Pathogens and Biological Contaminants 1135

The reviewed literature does not directly discuss the effect of perennial grass plantings on 1136 pathogens in runoff or the potential for pathogen loads associated with perennial grass 1137 management (i.e., from manure used as fertilizer). Since perennial grasses require fewer inputs 1138 and take up more impurities from surface water, fewer contaminants are expected from its 1139 growth compared to row crops. 1140

3.3.3 Water Quantity 1141

3.3.3.1 Water Use 1142

Switchgrass is an important native grass in prairies across North America and does not 1143 require additional irrigation. As such, studies that calculate water use for ethanol produced from 1144 switchgrass often assume that the feedstock is rain -fed, requiring no irrigation, and is capable of 1145 tolerating moisture deficits (Domingu ez -Faus et al., 2009; Wu et al., 2009). Nonetheless, 1146 greenhouse and field studies indicate switchgrass significantly increases biomass production with 1147Chapter 3: Environm ental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE access to ample water (Barney et al., 2009; Heaton et al., 2004). Thus, farmers may irrigate crops 1148
to max imize biomass production, though likely at much lower levels than required for row crops. 1149

Two major subtypes of switchgrass that differ in their water use characteristics have been 1150 identified in the wild: an upland and a lowland type. The upland type tends to tolerate dry 1151 conditions, though there is considerable variation in growth characteristics based on 1152 environment, which is likely due to limited crop selection and improvement. The lowland type 1153 requires more water (Parrish and Fike, 2005) . Switchgrass fa rmers may be able to minimize 1154 water use by cultivating the upland type of switchgrass. 1155

Miscanthus appears to be at least as efficient at using water for growth as corn and likely 1156

more so (Beale et al., 1999) , though considerable variation exists in the productivity of 1157 Miscanthus based on the identity of the cultivar, where it is grown, and the irrigation regime 1158 (Clifton -Brown et al., 2001; Richter et al., 2008). Published field studies testing Miscanthus in 1159 the U.S. are limited, however, and water use practices have not been established. 1160

3.3.3.2 Water Availability 1161

Depending on where perennial grasses are grown, whether irrigation is required, and 1162 what crops they replace (if any) , perennial grass production could improve water availability. 1163 Ground water availability, in particular, could be improved in places like Nebraska, where 1164 aquifers provide 85 percent of the water to agriculture (Kenny et al., 2009) , if perennial grasses 1165 replace more water -dependent crops (N ASS, 2009). Water availability will be minimally 1166 affected in areas requiring little or no irrigation. 1167

3.3.4 Soil Quality 1168

3.3.4.1 Soil Erosion 1169

Both switchgrass and Miscanthus have extensive root systems that prevent the erosion of 1170 soil and, unlike corn and soybeans, these perennial grasses are not planted on an annual basis, 1171 reducing the frequency of soil disturbance. Currently, switchgrass can be planted in conventional 1172 tillage and no

- till systems, whereas Miscanthus is planted in tilled fields (Heaton et al., 2008; 1173 Parr ish and Fike, 2005). This one- time tillage can increase erosion risk, particularly in 1174 Miscanthus where plant growth is slow the first year following planting and does not provide 1175 substantial ground cover (Lewandowski et al., 2000). In subsequent years, how ever, Miscanthus 1176 stands generally have high yields and dense root mats (Heaton et al., 2008; Lewandowski et al., 1177 2000), and likely provide substantial erosion control benefits relative to annually planted crops. 1178 Erosion control by switchgrass has received more study than that of Miscanthus . Switchgrass has 1179 been extensively planted on CRP acreage for erosion reduction, and planting switchgrass in 1180 riparian zone grass barriers and vegetation strips has been shown to substantially reduce runoff, 1181 sedimentation, and nutrient loss (Blanco -Canqui et al., 2004). 1182

3.3.4.2 Soil Organic Matter 1183

In general, soil organic matter increases more under perennial species than annual species 1184 because of the continuous accumulation of plant material (Sartori et al., 2006). Soil carbon is a 1185 primary constituent of soil organic matter. The production of both switchgrass and Miscanthus 1186Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE can increase soil carbon, but these organic matter benefits are likely to depend on the particular 1187 land use replaced and specific management practices. Where per ennials are planted on degraded 1188 soils with low organic matter content, soil erosion can be reduced and carbon stocks restored 1189 (Clifton -Brown et al., 2007; McLaughlin and Kszos, 2005). For example, on such a soil, 1190 switchgrass has been predicted to increase soil carbon by approximately 12 percent following 1191 one decade of production and harvesting (Garten and Wullschleger, 2000). If perennial grasses 1192 replace annual crops

, perennials will likely increase soil organic matter, though direct 1193 comparisons are limited (Bransby et al., 1998; Schneckenberger and Kuzyakov, 2007). In one 1194 such study, relative to reported values for corn, soil carbon increased under Miscanthus 1195 cultivation when its above-ground vegetation was harvested annually; however, this result varied 1196

ac cording to soil type, with carbon increasing in a loamy soil but not in a sandier textured soil 1197 (Schneckenberger and Kuzyakov, 2007). Soil organic matter accumulation under these 1198 perennials depends, in part, on harvest frequency, and, in the case of switchgrass, on the potential 1199 application of nitrogen fertilizer (Lee et al., 2007b). On the other hand, the effect on soil organic 1200 matter of preparing previously undisturbed land for these biofuel feedstocks has received little 1201 attention to date. Estimates of c arbon loss following conventional tilling of undisturbed soils 1202 range from 20 to 40 percent (Davidson and Ackerman, 1993). The amount of time needed for 1203 these perennials to restore soil carbon lost following site preparation is uncertain. 1204

3.3.5 Air Quality 1205

As men tioned earlier, little is known overall about the extent to which fertilizer, 1206 herbicides, and pesticides will be used to increase perennial grass production. Grasses require 1207 significantly less nitrogen fertilizer than corn or soybean, and studies indicate that NO x emissions 1208 should decrease when switchgrass is used as a feedstock (Wu and Wang, 2006). However, 1209 switchgrass is not currently grown on large scales under typical farm conditions. Nitrogen 1210 fertilizer rates are based on field trials, which are not ex tensive (Wu and Wang, 2006) and may 1211 differ from on -farm conditions (Hill et al., 2009). Similarly, switchgrass has been shown to 1212 require lower amounts of phosphorus (P 2 O 5 ) fertilizer, which translates to lower SO 2 emissions 1213 (Wu and Wang, 2006) 1214

As described earlier in Section 3.3.2.3, perennial grasses are expected to require less 1215 pesticide and herbicide than row crops (except when initially establishing perennial grass 1216 plantings); however, the lack of experience with commercial perennial grass production as a 1217 biofuel feedstock precludes firm conclusions about potential air quality impacts. 1218

As with corn and soybeans, harvesting of switchgrass will involve use of farm 1219 equipment, and thus is expected to generate NO x and PM emissions. However, VOCs and NO x 1220 and PM emissions associated with switchgrass harvesting have been found to be much l ower 1221 than those associated with corn harvesting (Hong and Wang, 2009). Decreases in VOCs, CO, 1222 NO x , PM 10 , PM 2.5 , and SO 2 emissions associated with switchgrass production as compared to 1223 corn or soybean have been reported (Wu and Wang, 2006; Hess et al., 2009). 1224Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.3.6 Ecosystem Impacts 1225

3.3.6.1 Biodiversity 1226

Models indicate that a greater diversity of birds are supported by switchgrass than by row 1227 crops (corn or soy), though some non- priority specie s such as horned lark ( Eremophila alpestris) 1228 and killdeer ( Charadrius vociferous ) may decline (Murray and Best, 2003; Murray et al., 2003). 1229 One study found that perennial grass crops can provide substantially improved habitat for many 1230 forms of native wildl if e—including ground flora, small mammals, and bird species—due to the 1231 low intensity of the agricultural management system (Semere and Slater, 2006). I ncreases in 1232 avian diversity are insensitive to whether switchgrass is strip harvested or completely harve sted 1233 (Murray and Best, 2003). However, field studies have shown that different species prefer habitats 1234 under different management regimes, suggesting that switchgrass cultivation under a mosaic of 1235 field ages and management regimes will maximize total avian diversity over a large landscape 1236 (Murray and Best, 2003; Roth et al., 2005) . Research from Nebraska and Iowa shows that 1237 populations of white-tailed deer are not likely to decline following conversion of land from corn 1238 to native grassland (i.e., dominated by switchgrass), but may experience contraction of home 1239 ranges to areas near row crops, increasing crop losses and the potential for disease transmission 1240 among wildlife (Walter et al., 2009). Though similar studies for Miscanthus in the U.S. are 1241 lacking, r esearch from the United Kingdom shows that non-crop plants from a wide range of 1242 families ( Poaceae, Asteraceae, and Polygonaceae ) coexist within young Miscanthus cropping 1243 systems due to a lack of herbicide applications, and support a greater diversity of bird 1244 populations than annual row crops (especially of passerines, game birds, and thrushes) (Bellamy 1245 et al., 2009) . These effects are likely to be transient as fi elds mature and crop height and 1246 coverage become more homogeneous (Bellamy et al., 2009; Fargione et al., 2009) . Similar 1247 patterns are likely for the U.S. Use of native mixtures of perennial grasses can restore some 1248 native biodiversity (Tilman et al., 2006). 1249

3.3.6.2 Invasive Plants 1250

G rasses are successful at reproducing, dispersing, and growing under diverse 1251 environmental conditions. This helps explain their dominance across many areas of the globe, 1252 and contributes to their potential risk as agricultural weeds and invasive plants. The risk that 1253 switchgrass or Miscanthus will become an agricultural weed or invasive plant depends on their 1254 specific biology and their interaction with the environments in which they are grown. One study 1255 noted that well-managed biofuel feedstock production must not only prevent feedstock crops 1256 from invading local habitat, but also prevent the crops from genetically invading native species 1257 (Firbank, 2007). 1258

Switchgrass produces large amounts of seed, a trait that correlates with the ability to 1259 spread, though it remains unclear how much and how far switchgrass seed can disperse. 1260 Switchgrass is being bred for vegetative reproduction, tolerance to low fertility soils, and the 1261 ability to grow in dense stands (Parrish and Fike, 2005) , all of which cou ld increase invasive 1262 potential. On the other hand, breeding for traits like sterility can be utilized to reduce the risk of 1263 escape and likelihood of negative impacts. For example, hybrid Miscanthus cultivars have been 1264 bred to produce almost no viable seed. 1265Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE The location where a feedstock is grown and the interaction between the feedstock and 1266 the local environment will be important for determining its invasion potential. Using species 1267 native to the area they are cultivated minimizes the risk of invasion into natural areas. 1268 Switchgrass is native east of the Rocky Mountains, although a variety could be bred or 1269 engineered to be substantially different from local populations. Switchgrass in any form is not 1270 native west of the Rockies. One risk assessment of introdu cing switchgrass to California 1271 indicated that it could become invasive relatively easily (Barney and DiTomaso, 2008). The 1272 potential for switchgrass to become a weed of other agricultural crops, even within its native 1273 range, is not known. 1274

Unlike switchgrass, Miscanthus x giganteus (the variety of Miscanthus that has been 1275 tested in Europe as a biofuel feedstock) is not native anywhere in the U.S. Little information 1276 exists about the ability of M. x giganteus to disperse from cultivation and p ersist as a weed or 1277 invade natural areas. One risk assessment recommended no restrictions on planting in the U.S. 1278 because the plant produces no living seeds and is therefore unlikely to spread easily (Barney and 1279 DiTomaso, 2008). A different study, however, noted that Miscanthus can spread vegetatively and 1280 could undergo genetic changes to produce seeds once more— making it potentially invasive 1281 (Raghu et al., 2006). Miscanthus sinensis has been grown in the U.S. for landscaping and 1282 horticultural purposes. Herbarium specimens and field observations indicate that it can disperse 1283 live seeds and persist in areas beyond where it was originally planted. Miscanthus sinensis, a 1284 species related to Giant Miscanthus, has been grown in the U.S. for landscaping and horticultural 1285 purposes, and is also being developed as a biofuel feedstock. Herbarium specimens and field 1286 observations indicate that it can disperse live seeds and persist in areas beyond where it was 1287 originally planted, including a variety of habitats lik e pasture, clearcut forests, and residential 1288

areas (Quinn et al., 2010). A recent study found that Miscanthus sinensis spreads quickly enough 1289 to be labeled invasive (Quinn and Stewart, 2010). Some other grass species that have been 1290 considered for use as biofuel currently invade wetlands, including giant reed ( Arundo donax ) 1291 (Bell, 1997) and reed canary grass ( Phalaris arundinacea ) (Lavergne and Molofsky, 2004). 1292

While feedstock cultivation poses the greatest risk for invasive impacts, reproductive 1293 parts from feedstocks could also be dispersed during transport from the field to storage or 1294 ethanol- processing facilities. Roads, railroads, and waterways can act as man

- made corridors for 1295 non-native and invasive plants. Harvested switchgrass possesses living seed and Miscanthus can 1296 reproduce vegetatively from plant cuttings, both of which may be dispersed during feedstock 1297 transport. 1298

One mitigation option for reducing the potentially negative environmental impacts from 1299 perennial grass production is avoiding cultivation of feedstocks with a history of invasiveness, 1300 especially in places that are climatically similar to where invasion has already occurred. Another 1301 option is to breed feedstocks to limit their dispersal into other fields or natural areas (e.g., the 1302 sterile Miscanthus x giganteus ). For instance, sterile, seedless switchgrass cultivars would be less 1303 likely to become invasive than current, seed-bearing cultivars. Often, higher reproduction 1304 correlates with lower biomass, so aggressive breeding programs to increase biomass and 1305 decrease seed production could produce multiple benefits. 1306

Another strategy for managing potential invasiveness is cleaning harvesting machinery 1307 and vehicles used to transport harvested feedstock, which would help to decrease unintended 1308Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE dispersal. Though prevention is most desirable, early detection and rapid response mechanisms 1309 could also be put into place to eradicate persistent populations of feedstock species as they arise, 1310 but before they have the chance to spread widely (DiTomaso et al., 2010) . Such early detection 1311 and rapid response mechanisms might involve local monitoring networks and suggested 1312 mechanical and chemical control strategies (timing and application rate of herbicides, for 1313 example) devised by local agricultural extension scientists for specific feedstocks. 1314

3.3.7 Assessment 1315

P erennial grasses are likely to require less pesticide, fertilizer, and water than traditional 1316 row crops used for biofuel production (Downing et al., 1995) . The benefits of perennial grasses 1317 as a feedstock include reduced soil erosion, enhanced soil structure and carbon sequestration, 1318 reduced nitrogen loading and sedimentation to waterways, reduced hypoxia in coastal areas, and 1319 greater support for populations of non- crop plants as well as animals and soil bi ota (Fargione et 1320 al., 2009; Hill, 2007; Williams et al., 2009). Use of perennial grasses as a biofuel feedstock 1321 carries many advantages to ecosystem services and to biodiversity relative to traditional row 1322 crops. The magnitude of these advantages depends on resolving some uncertainties and also on 1323 whether perennial grasses are replacing CRP land, row crop farmland, or other lands such as 1324 pasture land , and whether they are grown in a monoculture or in a mixture of species. The 1325 maintenance of landscape

- level biodiversity (e.g., including non- cultivated

, protected areas 1326 nearby ) will depend on the spatial arrangement of reserves promoting connectivity and 1327 population persistence, local management practices, and potential for biofuel crops and their 1328 pests to spread beyond managed boundaries. 1329

3.3.7.1 Key Uncertainties and Unknowns 1330

**•** Because no commercial

- scale facilities exist for converting perennial grasses to 1331 cellulosic ethanol, many uncertainties remain about how growing perennial 1332 grasses as a feedstock will affect enviro nmental conditions when grown at 1333 commercial scales. This holds for all endpoints documented in this report (soil 1334 carbon, leaching, etc.) and highlights the need for large- scale studies comparing 1335 perennial grass cultivated under a variety of management regi mes with row crops 1336 and other feedstocks. 1337 1338

**•** Most existing literature on switchgrass examines the plant’s rangeland and 1339 ecological purposes; this literature might not be completely applicable to 1340 switchgrass used as a biofuel feedstock. 1341 1342

**•** Much genetic potential for both Miscanthus and switchgrass remains to be 1343 explored for increasing their feasibility as feedstocks. If researchers are able to 1344 develop novel cultivars of these plants with significantly improved yields, there 1345 may be less potential for environmental damage from Miscanthus and switchgrass 1346 production. 1347 1348

**•** Little is known about usage of fertilizer and pesticides for increasing perennial 1349 grass production. The usage of precision management strategies (e.g., minimal 1350 fertilization, irrigation, and pest management at specific times) may potentially 1351Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE increase productivity without deleterious ecological impacts. Depending on where 1352 these crops are grown and what crops or other land use they are replacing, they 1353 may improve water quality relative to the previous land use. 1354 1355

**•** The water requirements of different grass species in different areas of the country 1356
are not documented, and the use and preferred method of irrigation remains to be 1357 determined. 1358 1359

**•** The role of nitrogen fixation in explaining the productivity of Miscanthus requires 1360 further study and may have large ramifications on the potential use of Miscanthus 1361 as a feedstock. 1362 1363

**•** The potential invasiveness of switchgrass in the western U.S. and Miscanthus 1364 across all the entire U.S. is relatively unknown. Studies to evaluat e feedstocks for 1365 the biological characteristics associated invasiveness, including rate of seed 1366 production, rate and maximum distance of dispersal from field-scale plots, modes 1367 of dispersal (e.g., wind, water, bird), rate of hybridization with already inva sive 1368 relatives, resistance to chemical or mechanical control, etc., are crucial for 1369 anticipating and preventing negative impacts and for determining which 1370 alternative feedstocks might pose lower risks. 1371 1372

**•** It remains uncertain whether the continual removal of above-ground biomass will 1373 deplete soil nutrients over the long term, particularly on marginal soils. On these 1374 soils, it may be particularly critical to harvest after translocation of nutrients back 1375 into the root systems. 1376 1377

**•** More landscape- level research is needed to understand how the distribution of 1378 multiple land use systems across a large landscape (e.g., row crops interspersed 1379 with perennial biofuel grasses and native habitat) will affect local and regional 1380 biodiversity. 1381 1382 3.4

3.4.1 Introduction 1384 Woody Biomass 1383

Woody biomass includes trees (e.g., removed or “thinned” from forests to reduce fire 1385 hazard or stimulate growth of remaining stands); forest residues (e.g., limbs, tree tops, and other 1386 materials generally left on

- site after logging ); short-rotation woody crops (SRWCs; i.e., fast1387 growing tree species cultivated in plantation

- like settings) and milling residues. Woody biomass 1388 is an attractive energy source because of its widespread availability and capacity to store carbon. 1389 However, to date woody biomass has been of limited use for energy production, with the 1390 exception of pulp and saw mill residues burned to produce heat, steam, and electricity. Woody 1391 biomass has been of particular interest as a biofuel feedstock because some forests might benefit 1392 from thinning and/or residue removal: removing forest residues from forests could reduce the 1393 threat of catastrophic wildfires, at least in some ecosystems, while providing a feedstock for 1394 energy production (Gorte, 2009). N o commercial

- scale biofuel plants using woody biomass as a 1395Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE feedstock are yet in operation , but demonstration and development facilities exist, and woody 1396 biomass is projected to be a future source of cellulosic biofuels. 1397

The U.S. has substantial domestic capacity for producing fuel from woody biomass. 1398 Estimates of the amount of woody biomass available for biofuel production differ widely and 1399 vary by price paid per ton of feedstock. EPA’s RFS2 RIA notes that, at $70 per ton, 40 to 118 1400 million dry tons of woody biomass may be available for biofuel production in 2022 (U.S. EPA, 1401 2010b, p. 49). At a currently demonstrated conversion rate of 80 gallons of ethanol per dry ton, 1402 up to 9.4 billion gallons of ethanol could be produced from 118 million dry tons (Foust et al., 1403 2009). Additionally, the conversion rate of biomass to ethanol will likely improve in the future. 1404

Under the RFS2 requirements, not all woody biomass would be available. The RFS2 1405 limits the origin of woody biomass to “planted trees and tree residue from actively managed tree 1406 plantations on non-federal land cleared at any time prior to December 19, 2007” (U.S. EPA, 1407 2010h, p. 56). Both forest harvesting residues and thinning operations are expected to be the 1408 predominant sources of woody biomass for future biofuel use, but SRWCs may be importa nt as 1409 well at higher feedstock prices (Perlack et al., 2005; U.S. EPA, 2010b, pp. 38-49; White, 2010). 1410 In the following sections, the potential impacts of harvest residues, thinning, and SRWCs are 1411 discussed in more detail. For comparison purposes, the envi ronmental impacts of SRWCs are 1412 considered in relationship to annual row crops. However, economic analyses suggest that the 1413 most likely sources of land for SRWC plantations are CRP or fallow agricultural lands, rather 1414 than prime agricultural acres or grasslands; therefore, SRWCs are generally unlikely to replace 1415 row crops (Volk et al., 2006; Walsh et al., 2003). 1416

3.4.1.1 Current and Projected Production Areas 1417

The potential sources of woody biomass vary by region of the country, and only SRWC 1418 plantations are likely to result in land use/land cover changes. Forest harvest residues are 1419 produced in major forest harvesting areas, predominantly in places such as the upper Lake States, 1420 the Southeast and the Pacific Northwest (see Figure 3

- 6). Since these residues will most l ikely be 1421 collected as a by -product of harvesting operations, the use of forest harvest residues is unlikely to 1422 produce land use/land cover changes (Williams et al., 2009). However, a rise in price paid per 1423 ton for woody biomass may provide an incentive for additional harvesting. Woody biomass from 1424 forest thinning will also occur in major forest harvesting areas, and potentially in areas of high 1425 wildfire risk. In contrast, SRWC plantations can have substanti al land use/land cover effects. 1426Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 1427 Source: Milbrandt , 2005. 1428

Figure 3 -6: Estimated Forest Residues by County 1429

3.4.1.2 Overview of Environmental Impacts 1430

Several activities associated with woody biomass as a feedstock may impact the 1431 environment. In the case of forest thinning and residue removal, there may be a direct 1432 environmental impact of biomass removal, as well as an impact from operation of forestry 1433 machinery. In the case of SRWCs, traditional forestry and agricultural activities undertaken 1434 during feedstock cultivation and harvest, such as pesticide, fertilizer, w ater , and fuel/energy use, 1435 have the potential to impact the environment. In addition, the choice of tree species may 1436 influence the risk of establishment, invasion, and impact during both feedstock production and 1437 transport. All these activities can alter ai r quality, water quality, water availability , and soil 1438 quality, with resulting impacts on ecosystems, though the extent of the impacts depends on each 1439 activity’s intensity. 1440

3.4.2 Water Quality 1441

Use of woody biomass as a feedstock can impact water quality, primari ly through 1442 nutrient runoff and sedimentation. However, the impacts of harvesting trees or removing forest 1443 residues can be limited through implementation of forestry best management practices. The 1444 extent to which SRWCs have a lower water quality impact than conventional crops will depend 1445 on the agricultural intensity of the short rotation woody crops production system (e.g., the extent 1446Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE of fertilizer, pesticide use and replanting interval). Table 3 -4 shows inputs needed to grow 1447 SRWCs compared to agricultural intensity metrics associated with growing conventional crops. 1448

Table 3

- 4 : Comparison of Agricultural Intensity Metrics for Short -Rotation Woody Crops and Conventional Crops

Metric Reduction R elative to C orn - W heat

- S oybean A verage Erosion 12.5 fold
Fertilizer 2.1 fold
Herbicide 4.4 fold
Insecticide 19 fold Fungicide 39 fold Source: Ranney and Mann

, 1994. 1449 1450 3.4.2.1 Nutrients 1451

The literature is mixed on whether residue removal increases (Kreutzweiser et al., 2008) 1452 or decreases (Lundborg, 1997) nutrient loads to surface water bodies, including wetlands. The 1453 impacts of removing tree harvest residues on nutrient loads vary depending on topography 1454 (slope), soil nutrient content, and the chemistry of the residues themselves (Titus et al., 1997). 1455 Compar ed to forest residue removal, moderate forest thinning typically does not increase loss of 1456 soil nutrients to ground or surface waters (Baeumler and Zech, 1998; Knight et al., 1991). 1457

F orestry Best Management Practices (BMPs) such as buffer zones (vegetated setbacks 1458 from water bodies) are used to reduce water quality impacts. Careful planning to minimiz e the 1459 construction of roads and stream crossings or the use of portable stream crossing structures can 1460 help reduce erosion and sedimentation (Aust and Blinn, 2004; Shepard, 2006). Other BMPs 1461 include: using energy efficient machinery, minimizing traffic in buffer zones and choosing low1462 impact equipment that is of the appropriate size and scope for the site (Phillips et al., 2000). The 1463 draft 2010 National Report on Sustainable Forests by USDA’s U.S. Forest Service suggests 1464 widespread adoption of forestry BMPs to protect water resources, although many states failed to 1465 respond to a request for data (U.S. Forest Service, 2010). If practices are followed, i mpacts can 1466 be minimized; outreach, education, and monitoring to ensure implementation and effectiveness 1467 are ongoing

. 1468

As described above, SRWCs are unlikely to directly replace row crops; however, for 1469 comparative purposes, it is noted that nutrient losses from SRWCs are in general considerably 1470 less than in annually cropped systems, depending in part on the harvesting and replanting 1471 interval. In willow plantations, the recommended fertilization rate is 89 pounds of nitrogen per 1472 acre (100 kg/hectare) every 3 y ears, which equates on an annual basis to approximately 22 1473 percent of the average rate for corn production (Keoleian and Volk, 2005; NASS, 2006). In the 1474 first year or two following planting, SRWC plantations can exhibit losses of nitrogen at rates 1475 comparab le to conventional grain production, yet following this initial establishment phase, 1476 nitrogen losses decline to low levels (Aronsson et al., 2000; Goodlass et al., 2007; Randall et al., 1477 1997). A comparison of nutrient exports from a short-rotation poplar s tand and a native forest 1478 found no difference (Perry et al., 1998), and measurements of nitrogen in ground water and 1479Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE leaching from established willow plantations generally show little eutrophication potential for 1480 aquatic ecosystems (Keoleian and Volk, 2005) . In coppiced systems, where trees are harvested at 1481 the ground level and re-grow from the stump, the harvesting of the aboveground portion of the 1482 tree appears to have little impact on nitrogen leaching (Goodlass et al., 2007). Losses can be 1483 substantially h igher when the stand is replanted (Goodlass et al., 2007). Longer rotation lengths 1484 would likely improve nutrient retention on- site and reduce losses to waterways. 1485

3.4.2.2 Sediment 1486

Forest soils generally exhibit low erosion rates and thus small sediment losses to s urface 1487 waterways (Neary et al., 2009)

. However, when forests are harvested and the soil prepared for 1488 the next stand without using BMPs, erosion rates can increase significantly (McBroom et al., 1489 2008). Harvesting residues left on- site physically shield soil particles from wind and water 1490 erosion, and promote soil stability through the addition of organic matter. Thus, removal of 1491 harvest residues is an element of harvest operations that could increase erosion and associated 1492 sediment loading to surface waters, especially on steeper slopes (Edeso et al., 1999). Thinning 1493 can also increase erosion and sediment loads to surface waters, depending on the site 1494 characteristics and the methods used (Cram et al., 2007; U.S. Forest Service, 2005; Whicker et 1495 al., 2008). Res earch indicates that proper use of BMPs, such as road design and buffer zones, can 1496 significantly reduce sediment impacts to surface waters (Aust and Blinn, 2004; Shepard, 2006). 1497 In addition, erosion rates at harvested sites decline once vegetation re-colon izes the site (Aust et 1498 al., 1991; Miller et al., 1988). See Section 3.4.4.1 for discussion of impacts of SRWCs on soil 1499 erosion and sedimentation. 1500

3.4.2.3 Pesticides 1501

Pesticides might be used with SRWCs; for purposes of comparison, it is noted that the 1502 amount used would be significantly less than that for corn or soybeans (Ranney and Mann, 1503 1994). 1504

3.4.3 Water Quantity 1505

3.4.3.1 Water U se 1506

The utilization of harvest residues from mature stands of trees and thinning does not 1507 require additional water use at the feedstock production stage. 1508

For the most part, growth of SRWCs will likely occur in areas with high water 1509 availability, such as the Northeast, Southeast, and Northwest. Because they are usually not 1510 irrigated, trees require less total water than row crops (Evans and Cohen, 2009). However, they 1511 can still have a large impact on regional water availability due to their much higher 1512 evapotranspiration rate. In places where high- intensity tree plantations replace existing 1513 ecosystems with lower evapotranspiration rates, the potential for increased water consumption is 1514 significant. A study of southern pine in the Southeast found that an additional 865 gallons of 1515 water is consumed per gallon of ethanol produced from woody biomass (roughly 1,300 gallons 1516 of water per gallon of gasoline equivalent), due to land conversion for woody biomass 1517 production (Evans and Cohen, 2009). Further, in certain locations and in some years, additional 1518Chapter 3: Environmental Impacts of Specific Feedst ocks

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— DO NOT CITE OR QUOTE irrigation water may be required to maintain high biomass accumulation (Hansen, 1988). 1519 Precision application systems can reduce the amount of water applied. 1520

3.4.3.2 Water Availability 1521

Use of forest harvest residues and biomass from thinning should have little or no effect 1522 on water availability at the feedstock production stage. Plantations of SRWCs may reduce runoff 1523 into streams and rivers compared to traditional row crops like corn and soybeans, potentially 1524 benefiting water quality (Updegraff et al., 2004). However, some experts warn that reduced 1525 runoff coupled with high water requirements could reduce or eliminate stream flow (Jackson et 1526 al., 2005). In places with seasonal flooding, modulation of surface water flow closer to pre1527 agricultural development levels could possibly mitigate flooding (Perry et al., 2001). 1528

3.4.4 So i l Quality 1529

3.4.4.1 Soil Erosion 1530

The soil erosion impacts of SRWCs will depend on harvesting and planting frequencies; 1531 impacts are lower when time between planting intervals is longer. Short-rotation woody crops 1532 require intensive soil preparation for successful establishment, and it is during this brief 1533 establishment phase that erosion rates can be a high (Keoleian and Volk, 2005). For example, 1534 higher sediment losses were observed within the first 3 years of seedling establishment in 1535 sweetgum ( Liquidamber styraciflua ) plantations compared to no- till corn or switchgrass 1536 (Nyakatawa et al., 2006). The slow-developing canopy failed to provide adequate ground cover 1537 to protect against erosion as a result of rainfall (Nyakatawa et al., 2006). However, in established 1538 SRWC plantations, soil erosion rates are likely much lower than those of annually harvested row 1539 crops. The use of a cover crop can also significantly reduce erosion caused by SRWC 1540 establishment (Nyakatawa et al., 2006), and the soil erosion effects of SRWCs are likely to be 1541 lower under a coppicing system, which reduces the frequency of soil disturbance by keeping the 1542 root systems intact. Willows are generally managed by the coppicing system and harvested at 3 - 1543 to 4-year intervals for a total of 7 to 10 harvests (Keoleian and Volk, 2005). This allows 21 to 40 1544 years bet ween soil disturbances. 1545

3.4.4.2 Soil Organic M atter 1546

Harvesting of forest residues removes plant material that could otherwise become soil 1547 organic matter. A review analysis suggested that, on average, a complete, one- time removal of 1548 forest residues slightly decreas es soil organic matter in coniferous forests, but may not affect 1549 levels in hardwood or mixed stands (Johnson and Curtis, 2001). Leaving logging residues is 1550 important for soils with low organic matter content, and repeated harvesting of residues in the 1551

same location could lead to overall declines in soil organic matter (Thiffault et al., 2006). Further 1552 research is needed to determine the cumulative effect of repeated removals. T hinning of forests 1553 has been shown to reduce carbon in forest floor layers , but le ss evidence is available regarding 1554 its impact on mineral soil organic matter levels (Grady and Hart, 2006; Jandl et al., 2007). The 1555 effect of thinning over the long-term will depend on both the frequency and intensity of the 1556 specific thinning operations. 1557Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Production of SRWCs can add organic matter to the soil, sequestering carbon, but the net 1558 soil organic matter benefits of these crops depend on land- use change and time between harvests. 1559 Generally, soil organic matter, including carbon, is initially lost whe n a forest is planted because 1560 the amount of organic matter entering the soil from the reestablishing plants is typically small 1561 and is exceeded by decomposition (Paul et al., 2002). Over time, substantial amounts of organic 1562 matter accumulate in the trees, the forest floor layer and the soil, greatly exceeding the carbon 1563 contained in abandoned agricultural systems (Schiffman and Johnson 1989; Huntington 1995; 1564 Richter et al., 1999). The amount of time it takes for soil carbon to re- accumulate varies. In 1565 hybrid poplar plantations in Minnesota, it was estimated to take 15 years to meet the carbon 1566 levels of the agricultural field replaced (Grigal and Berguson, 1998). A review study suggested 1567 that on average it can take 30 years to exceed those of abandoned agricultural fields; though 1568 when the forest floor was also considered, carbon accumulation rates were higher, reducing the 1569 time needed to regain carbon from the initial forest establishment (Paul et al., 2002). Overall, if 1570 frequently harvested SRWCs replace longer rotation, managed forest lands, then the net effect on 1571 soil organic matter is likely to be negative; but, if they are grown using longer rotations, 1572 particularly on degraded former agricultural land, substantial amounts of organic matter are 1573 likely to added to the soil (Schiffman and Johnson, 1989; Huntington 1995). 1574

3.4.4.3 Soil Nutrients 1575

Use of harvesting residues removes a potential source of soil nutrients that can be utilized 1576 by the regenerating forest. Harvesting with residue removal generally leads to declin es in soil 1577 nutrients and forest productivity, but in some cases, it can be sustainable for at least one rotation 1578 (McLaughlin and Phillips, 2006; Thiffault et al., 2006). The cumulative effects of repeated 1579 removals from the same site are likely negative, bu t require further study. Residue removal has 1580 been suggested as a management technique to reduce nitrogen in forests that receive high 1581 atmospheric deposition, such as in the northeastern U.S. (Fenn et al., 1998). However, this may 1582 lead to depletion of calcium and other nutrients critical for plant growth (Federer et al., 1989). 1583 Overall, residue removal may be less problematic on high fertility soils compared to coarser

1584 textured, low fertility soils. The risk posed to soil nutrients by thinning is likely to b e much 1585 smaller than that of the removal of harvesting residues (Luiro et al., 2010). 1586

T here is concern that continual harvesting of SRWCs will deplete soil nutrients over the 1587 long- term (Adegbidi et al., 2001). Commercial fertilizers or organic waste product s, such as 1588 municipal effluent, can be used to offset these losses (Stanton et al., 2002). Nutrient removal 1589 from such effluent s by SRWC s may provide an additional environmental benefit, though it 1590 remains unclear how much nitrogen, other nutrients, or contaminants might leach from these 1591 systems if this technique is used. 1592

3.4.5 Air Quality 1593

Few data are available for evaluating air emissions from SRWCs such as hybrid poplar 1594 and willow. As with switchgrass, SRWCs require less tillage (reducing fugitive dust emissions) 1595 and fewer applications of fertilizer (reducing emissions associated with fertilizer production and 1596 application). However, some species such as poplar and willow that are potential feedstocks for 1597 either cellulosic ethanol or biodiesel are signifi cant emitters of biogenic VOCs such as isoprene. 1598 Compared to non- woody crops that emit relatively little isoprene , extensive plantations of these 1599Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE trees have the potential to significantly impact ozone concentrations, although this effect will be 1600 highly sensitive to environmental conditions, preexisting vegetative cover, and the presence of 1601 other atmospheric chemicals, especially NOx (Hess et al., 2009; U.S. EPA, 2006b). 1602

3.4.6 Ecosystem Impacts 1603

3.4.6.1 Biodiversity 1604

Tree harvesting activities can impact aquatic biodiversit y in a number of ways. For 1605 example, removal of woody biomass by harvesting of forest residues or thinning in riparian areas 1606 may reduce the woody debris in headwater streams, which is an important component for aquatic 1607 habitat (Angermeier and Karr, 1984; Chen and Wei, 2008; Stout et al., 1993; Thornton et al., 1608 2000). In addition, tree canop ies over streams help maintain cooler water temperature s conducive 1609
to cold -water smallmouth bass, trout, or salmon populations (Binkley and Brown, 1993; U.S. 1610 EPA, 2006c). These benefits may be lost when trees are harvested. 1611

There is some evidence that planting SRWCs can improve species habitat relative to 1612 agricultural crops (Christian et al., 1998). Several studies have documented that bird species 1613 diversity on woody biomass plantations is comparable to that of natural shrubland and forest 1614 habitats (Dhondt et al., 2007; Perttu, 1995; Volk et al., 2006), though this is not always the case 1615 (Christian et al., 1998). Bird and small mammal species found on SRWC plantations tend to be 1616 habitat generalists that can also use open habitats like agricultural lands, while birds and small 1617 mammal species in mature forests are more specialized and require forest cover (Christian et al., 1618 1998). If understory plants become prevalent in SRWC plantations, species diversity can 1619 increase due to increases in habitat complexity (Christian et al., 1998). 1620

3.4.6.2 Invasive Plants 1621

Like perennial grasses, woody plants cultivated for biofuel feedstock can become 1622 invasive. However, because many woody plants have a longer life cycle than many (though not 1623 all) grasses, they tend to reproduce and spread more slowly, making the evidence of their 1624 invasion and effects on natural areas less immediate. Trees used in forestry can sometimes be 1625 highly invasive, negatively affecting biodiversity and water availability (Richardson, 1998). 1626

Proposed SRWCs, such as willow or poplar, are native or hybrids of natives in the U.S., 1627 but Eucalyptus species, which are non -native, may pose an invasive risk. Eucalyptus is an 1628 important genus of forestry plants worldwide, and its future development as a biofuel feedstock 1629 in plantations has been discussed for Florida (Rockwood et al., 2008). Several species of 1630 Eucalyptus , including E. globulus and E. grandis , have been introduced to Florida and bred 1631 conventionally and using biotechnology for traits like cold tolerance. The intent is to expand 1632 their future cultivated range to include much of the Southeast. While introduced Eucalyptus or 1633 their improved varieties have not become invasive in the Sou theast, E. globulus is a listed 1634 invasive plant in California, and recently, several cultivars of E. grandis were found to be 1635 potentially invasive by the Institute of Food and Agricultural Science at the University of Florida 1636 and are recommended for planting only under limited conditions. Reassessment of the species 1637 will take place again in two years after continued monitoring for invasion. 1638Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.4.7 Assessment 1639

Current environmental impacts of production and use of woody biomass as a biofuel 1640 feedstock are negligible, since no large

- scale, commercial operations are yet in existence to 1641 create demand for this feedstock. However, estimates suggest that the potential for biofuels made 1642 from woody biomass is substantial, with predominant sources coming from forest harvest 1643

res idues, thinning, and SRWCs. Of these, the removal of harvesting residues from logging sites 1644 is likely to have the most negative impacts on soil and water quality. Complete removal of 1645 residues poses the risk of increased nutrient and sediment losses to wate rways, and decreased 1646 plant nutrient availability and forest productivity. In comparison, moderate thinning regimes will 1647 have relatively few impacts on soil and water quality, particularly on stable slopes and finer1648 textured soils. 1649

The environmental effects of SRWCs as a source of woody biomass are more complex, 1650 since these require a shift in land use/land cover type. In general, SRWCs are expected to result 1651 in lower nutrient and sediment loads to surface waters relative to that of row crops , especially 1652

once the canopy is established . Woody biomass species require fewer inputs of fertilizer and 1653 pesticides, resulting in reduced runoff of these substances into surface and ground water. Woody 1654 biomass production requires considerable water use, but if undertaken in appropriate regions 1655 with adequate water supplies, water quality benefits may outweigh possible water availability 1656 drawbacks. 1657

3.4.7.1 Key Uncertainties and Unknowns 1658

**•** Woody biomass is not yet converted to biofuel on a large- scale; this creates 1659 considerable unknowns and uncertainties when projecting the potential 1660 environmental effects, both positive and negative, of this feedstock. 1661 1662

**•** Specific environmental impacts will vary, depending on soil type, soil chemistry, 1663 topography, climate, and other factors (e.g., the land use SRWCs would replace). 1664 1665

**•** Lack of information about the amount and relative proportion of woody biomass 1666 that would come from harvest residues, thinning, and SRWCs to support large1667 scale operations creates substantial uncertainty. The potential effects of harvest 1668 residues and thinning are easier to assess because a body of literature from other 1669 forestry applications does exist. Even so, uncertainties arise from variations in the 1670 percent of residues removed during harvesting and in the degree of thinning, 1671 which can range from small to large pro portions of the existing stand. 1672 1673

**•** Quantifying impacts of SRWCs to ecosystems and biodiversity will depend on 1674 knowing where and under what agronomic conditions SRWCs are grown and how 1675 they are managed. Uncertaint y about these factors limits understanding of the 1676 potential impacts of this feedstock. For example, it is not known whether repeated 1677 removal of biomass from SRWCs will deplete soil nutrients over the long term, 1678 particularly on marginal soils. 1679 1680Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.5

3.5.1 Introd uction 1682 Algae 1681

Algae are of interest as a biofuel feedstock because of their high oil content, low water 1683 demand

, ability to recycle waste streams from other processes, and ability to grow on marginal 1684 land s (EPA, 2010b). Algae production demands much less land area per gallon of fuel produced 1685

com pared to most other feedstocks. 1686

Research and pilot studies have shown that the lipids and carbohydrates in microalgae 19

There are many different types of algae, methods to cultivate them, and processes to 1693

recover oil from them . Algae grown photosynthetically are limited to growth during daylight 1694 hours and require carbon dioxide. Heterotrophic algae, which do not utilize photosynthesis, can 1695 be grown continuously in the dark, but require a fixed carbon source such as sugars because they 1696 cannot use carbon dioxide directly (Day et al., 1991). Cultivation of algae feedstocks can take 1697 place in photobioreactor facilities with closed

- cycle recirculation systems or in open

- system

1698 style impoundments. Open systems use pumps and paddle wheels to circulate water, algae, and 1699 nutrients through shallow, uncovered containments of various configurations. Closed systems 1700 employ flat plate and tubular photobioreactors and can be located outdoors or indoors. Variations 1701 include hybrid (combined open and closed) cultivation and heterotrophic cultivation (which uses 1702 organic carbon inste ad of light as an energy source). Different algae cultivation strategies are 1703 being studied to determine which is most suitable for supporting large-scale biofuel production 1704 (Chisti, 2007; U.S. EPA, 2010b). 1705 1687 can be refined and distilled into a variety of biodiesel- and alcohol -based fuels, including diesel, 1688 etha nol, methanol, butanol, and gasoline. Algae also have the potential to serve as feedstock for 1689 other types of fuels, including bio-oil, bio-syngas, and bio-hydrogen. This section focuses on the 1690 use of algae for biodiesel, because biodiesel is the most likel y near

- term pathway for algal use as 1691 biofuel. 1692

Harvesting requires that the algae be removed, dewatered, and dried. Dewatering is 1706 usually done mechanically using a screw press, while drying can use solar, drum, freeze, spray, 1707 or rotary techniques (NRDC, 2009). After harvesting, the biofuel production process begins 1708 when oil is extracted from the algae through chemical, mechanical, or electrical processes (U.S. 1709 EPA, 2010b, p. 61). Algal oil can then be refined with the same transesterification process used 1710 for other biofuel feedstocks such as soybeans. 1711

While the different methods of algae cultivation and recovery will clearly have very 1712 different environmenta l impacts , such as energy consumption and chemical use and disposal, it is 1713 premature to draw definitive conclusions about these impacts, given the nascent state of 1714 cultivating algae for biofuel. 1715

19 The term “microalgae” refers to photosynthetic and heterotrophic organisms too small to be easily seen with the naked eye

— distinguished from macroalgae, otherwise known as seaweed. Macroalgae is generally not grown as an energy crop. In this report the terms “algae” and “microalgae” are used interchangeably.Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.5.1.1 Curre nt and Projected Cultivation 1716

Land use consideration is one of the primary drivers behind interest in algae as a biomass 1717 feedstock. Relative to other feedstock resources, algal biomass has significantly higher 1718 productivity per cultivated acre. For example, meeting half the current U.S. transport fuel 1719 demand with soybean -based biodiesel would require an arable land area in excess of 300 percent 1720 of the area of all 2007 U.S. cropland, while the land area required to meet those same fuel needs 1721 using algal biodiesel would be less than 3 percent of all U.S. cropland in 2007 (Chisti, 2007). 1722 Moreover, algae cultivation does not require arable land. Algae’s lack of dependence on fertile 1723 soil and rainfall essentially eliminates competition among food, feed, and energy production 1724 facilities for land resources (Muhs et al., 2009). Because algae-based biofuel production facilities 1725 do not require specific land types, they may be sited closer to demand centers, reducing the need 1726 to transport significant quantities of either biofuel or feedstock from one region of the country 1727 (e.g., the Midwest) to another (e.g., coastal population centers). 1728

Proximity to input sources, such as carbon dioxide sources, and output markets, as well 1729 as the availability of affordable land, will like ly drive algae production facility siting decisions. 1730 The U.S. Southwest is viewed as a promising location for economic algae- to -biofuel cultivation 1731 due to the availability of saline ground water, high exposure to solar radiation, and low current 1732 land use development. Based on pilot studies and literature on algae cultivation, likely areas for 1733 siting algae -based biofuels facilities also include coasts, marginal lands, and even co- location 1734 with wastewater plants (Sheehan et al., 2004; U.S. EPA, 2010b). Algae grown in conjunction 1735 with animal and human wastewater treatment facilities can reduce both freshwater demands and 1736 fertilizer inputs, and may even generate revenue by reducing wastewater treatment costs. U.S. 1737 companies are already using wastewater nutrients to feed algae in intensively managed open 1738 systems for treatment of hazardous contaminants (Munoz and Guieysse, 2006). 1739

3.5.1.2 Overview of Environmental Impacts 1740

Algae

- based biofuel production systems are still being investigated at the pilot stage 1741 using smaller

- sc ale prototype research facilitie s. Evaluating the potential environmental and 1742 resource impacts of full

- scale production is highly uncertain because much of the current 1743 relevant data is proprietary or otherwise unavailable, and many key parameters are unkno wn, 1744 including where and how algae will be produced and what species and strains of al gae will be 1745 used as feedstocks. 1746

Algae cult ivation can require the use of pesticides, fertilizers, water , a nd fuel. Each of 1747 these activities, in turn, can impact air qualit y, water quality, and water availability . ( Soil quality 1748 is not a con cern .) In addition to these impacts, there is potential for invasive algae strains to 1749
escap e from cult ivation (NRDC, 2009). Industrial oil extraction and biodiesel production, 1750 biodiesel and byproduct transport and storage, and biodiesel and byproduct end use also entail 1751 environmental impacts, which are discussed further in Chapter 4. 1752

3.5.2 Water Quality 1753

Scaled production of algae oil for biofuels has not yet been demonstrated; therefore, 1754 water quality impacts associated with large

- scale use of algae

- based biofuel s are currently 1755Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE speculative. Wastewater is a key factor influencing water quality impacts of algae production 1756 facilities, inc luding whether wastewater is used as a water source for algae cultivation, and 1757 whether wastewater is discharged from the algae cultivation site. According to the National 1758 Resources Defense Council, wastewater from the dewatering stages of algae production could be 1759 released directly, sent to a treatment unit and released, or recycled back as make up water, 1760 depending on the process (NRDC, 2009). Depending on the treatment requirements, release of 1761 wastewater could potentially introduce chemicals, nutrients, additives (e.g., from flocculation), 1762 and algae, including non- native species, into receiving waters. 1763

Co

- locating algae production facilities with wastewater treatment plants, fossil fuel 1764 power plants, or other industrial pollution sources can improve water q uality and utilize waste 1765 heat that contributes to thermal pollution, while reducing freshwater demands and fertilizer 1766 inputs (Baliga and Powers, 2010; Clarens et al., 2010). By co

- locating these facilities, partially 1767 treated wastewater acts as the influent to the algae cultivation system. Algae remove nutrients as 1768 they grow, which improves the quality of the wastewater and reduces nutrient inputs to receiving 1769 waters. If fresh water or ground water is used as the influent, nutrients must be added artificiall y 1770 in the form of fertilizer. 1771

Significant environmental benefits could be associated with the ability of algae to thrive 1772 in polluted wastewater. Algae can improve wastewater quality by removing not only nutrients, 1773 but also metals and other contaminants, and by emitting oxygen. Thus, algae can effectively 1774 provide some degree of “treatment” for the wastewater (Darnall et al., 1986; Hoffmann, 1998). 1775

3.5.3 Water Quantity 1776

3.5.3.1 Water U se 1777

Water is a critical consideration in algae cultivation. Factors influencing water use 1778 include the algae species cultivated, the geographic location of production facilities, the 1779 production process employed, and the source water chemistry and characteristics. Estimates for 1780 water consumption vary widely, ranging from 25 to 974 gallons of water per gallon of biodiesel 1781 produced (U.S. EPA, 2010b). EPA has estimated that an open- system

- type biofuel facility 1782 generating 10 million gallons of biofuel each year would use between 2,710 and 9,740 million 1783 gallons of saline water each year; a similar scal e photobioreactor- type facility would use between 1784 250 and 720 million gallons of saline water annually (U.S. EPA, 2010b, Table 2.4-56, p. 426). 1785

The harvesting and extraction processes also require water, but data on specific water 1786 needs for these steps are limited (U.S. EPA, 2010b). Compared to the water required for algae 1787 growth, however, demands are expected to be much lower. 1788

3.5.3.2 Water A vailabili ty 1789

Depending on the cultivation system, algae production could exacerbate or create water 1790 availability problems, es pecially in promising locations like the Southwest, which are already 1791 experiencing water shortages. However, the water used to grow algae does not have to be high1792 quality fresh water. Algae can thrive in brackish water, with salt concentrations up to twice that 1793 of seawater (U.S. EPA, 2010b), as well as in contaminated wastewater such as agricultural, 1794 animal, or municipal effluent; or even coal, pharmaceutical, or metal plating wastewater (NRDC, 1795Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 2009). Thus, competition for freshwater resources may be mitiga ted by siting facilities in areas 1796 that can provide suitable brackish or wastewater sources. 1797

In addition to the water quality benefits described above, co-locating algae production 1798 facilities with wastewater treatment plants can reduce water demands (Claren s et al., 2010). The 1799 water availability i mpacts o f algae production for biofuel can also be mitigated in large part 1800 using photobioreactors, which require less water and land area than open systems (U.S. EPA, 1801 2010b, Table 2.4-56, p. 426). 1802

3.5.4 Soil Quality 1803

Very little peer

- reviewed literature exists on the soil impacts of algae production because 1804 these impacts are likely to be negligible and have therefore not been the subject of much study. 1805 Presumably, the primary mechanism affecting soil quality would be transport and migration into 1806 soil of wastewater, particularly highly salinated wastewater, that has been released into 1807 freshwater ecosystems (NRDC, 2009). 1808

3.5.5 Air Quality 1809

The effects of algae -based biofuels on air quality have received little attention to date in 1810
pe er

- reviewed literature. As a result, additional research is needed to determine whether anything 1811 unique to algae production processes would raise concern about a ir emissions. 1812

Open or hybrid open systems appear to have greater potential to impact air qualit y 1813 compared to enclosed photobioreactors, given the highly controlled nature of the latter systems. 1814 No studies are yet available, however, to characterize or quantify emissions associated with open 1815 systems used to produce algae for biofuel. Studies have measured air emissions of open- system 1816 algae ponds that are part of wastewater treatment systems (Van der Steen et al., 2003), but these 1817 studies may have very limited applicability to open systems for commercial -scale production of 1818 algae oil for biodiesel. Add itional research will be required to estimate and characterize 1819 emissions from pumping, circulation, dewatering, and other equipment used to produce algae for 1820 biofuel. 1821

3.5.6 Ecosystem Impacts 1822

3.5.6.1 Biodiversity 1823

Algal production has fewer biodiversity impacts than production of other feedstocks 1824 because algae typically require less fertilizer, pesticide, and water than do other feedstocks, and 1825 because algal production plants may be co

- located with wastewater treatment plants. As 1826 mentioned above, the location of algae prod uction facilities will be a key factor affecting the 1827 potential for impacts. Using wastewater to capture nutrients for algal growth could help reduce 1828 nutrient inputs to surface waters (Rittmann, 2008). Algae also require low inputs of fertilizers 1829 and pesticides compared to other feedstocks, which may translate into fewer ecological impacts 1830 to aquatic ecosystems (Groom et al., 2008). Production facilities for algae that need sunlight to 1831 grow could be located in arid regions with ample sunlight (Rittmann, 2008); however, growing 1832 algae in areas with limited water resources could impact the amount of water available for the 1833 ecosystem because of draws on ground water. It is unknown what impacts an accidental algae 1834Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE release might have on native aquatic ecosystems, particularly if the algae released have been 1835 artificially selected or genetically engineered to be highly productive and possibly adaptable to a 1836 range of conditions. 1837

3.5.6.2 Invasive Algae 1838

The potential for biofuel algae to be released into and survive and proliferate in the 1839 environment is, at present, highly uncertain. This potential will vary, depend ing on what species 1840 and strain s of naturally occurring, selectively bred, or genetically engineered algae are used and 1841 how they are cultivated

. 1842

The risk of algae dispersal into the environment is much lower in closed bioreactor 1843 systems than open system production, though unintentional spills from bioreactors in enclosed 1844 production facilities are possible. High winds blowing across open systems may carry algae long 1845 distances, depositing them in water bodies, including wetlands, near and far. Designers of coastal 1846 algae production plants must take into account hurricanes and other severe storms that could 1847 disperse algae over large areas. Wildlife, including birds, may also disperse algae. Closed 1848 systems, in addition to limiting algae dispersal, have the benefit of protecting algal media from 1849 being contaminated with other microbes, which could compete with the cultivation strains for 1850 nutrient resources. 1851

Effluent from algal biomass dewatering processes may contain residual algae, which 1852 could thrive in receiving waters. T reatment strategies will need to be developed to prevent algae 1853 in effluent from contaminating the surrounding ecosystem. 1854

The ability of cultivated algae to survive and reproduce in the natural environment is 1855 unknown: one theoretical study suggests that some, but not all, strains with the most desirable 1856 commercial characteristics would be out-competed by native algae (Flynn et al., 2010). Further 1857 empirical work is critical to determine competitive and hybridizing abilities of biofuel algae in 1858 the natural environment and to measure possible effects on algal community dynamics and 1859 ecosystem services. 1860

3.5.7 Assessment 1861

3.5.7.1 Current and Future Impacts 1862

With the exception of nutrients, open system cultivation requires far more resources than 1863 photobioreactor systems. Regardless which type of system is used commercially, future increases 1864 in production of algal biomass have the potential to impact water availability and quality, air 1865 quality and atmospheric climate, and ecosystem health and biodiversity. However, due to the 1866 lack of data on commercial

- scale algal biofuel production processes, it is uncertain what these 1867 impacts will be. 1868

In some cases, the algal production process could prove environmentally beneficial. For 1869 example, use of wastewater effluent, particularly partially treated wastewater, to cultivate algae 1870 provides benefits of removing nutrients from th e wastewater and reduces t he environmental 1871 impact of the production process. Combining commercial- scale algae production facilities with 1872Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE wastewater treatment plants may therefore create synergies that increase algae yields while 1873 decreasing environmental im pacts of both facilities

. 1874

Key points to understanding the potential environmental impacts of using algae for 1875 biofuel production are described below. 1876

Water Quality : The water quality impacts of algal biofuel production will depend on both 1877 the source of wate r used for cultivation and the quality of the water released from the production 1878 facility. Algae production facilities co

- located with water treatment plants , fossil fuel power 1879 plants, or other industrial sources of pollution could have a positive impact on water quality. 1880 However, release of wastewater from an algal biofuel production process— especially salinated 1881 wastewater released into a freshwater environment

— could adversely affect water quality. 1882

Water Quantity : Water is an important input in the algae c ultivation process; increased 1883 production of algal biofuels will impact water availability, especially in areas where water is 1884 already scarce. However, algae may be less water intensive than other feedstocks. Moreover, 1885 because algae can thrive in brackish and untreated waters, they are an ideal feedstock for water

1886 stressed locations. 1887

Soil Quality : Soil quality impacts are likely to be minimal, based on existing studies. 1888

Air Quality : Little is known about how algal biofuel production will affect air quality. 1889 However, preliminary data suggest that open system cultivation systems have a greater potential 1890 than photobioreactor systems to adversely affect air quality. 1891

Ecosystem Health/Biodiversity : Little is known about how increases in algal biofuel 1892 production might affect biodiversity. Because algae demands substantial amounts of water, its 1893 cultivation could adversely impact native species in water -stressed locations. Compared with 1894 other feedstocks, however, algae is not water intensive. Also unknown are what impacts an 1895 accidental release of algae might have on native aquatic ecosystems. Algae require low inputs of 1896 fertilizers and pesticides compared to other feedstocks, which m ay also translate into fewer 1897 ecological impacts to aquatic ecosystems 1898

Invasive Species : The ability of cultivated algae to escape into and survive in the natural 1899 environment is uncertain. Experts speculate that photobioreactor cultivation systems would be 1900 superior to open system s in preventing the escape of cultivated algae. 1901

3.5.7.2 Key Uncertainties and Unknowns 1902

**•** Most of the uncertainties related to the production of algae for biodiesel stem 1903 from a lack of knowledge about which technologies may be used in future 1904

co mmercial applications , where they will be located, and what species and strains 1905 of algae will be used. 1906 1907

**•** Water availability impacts from feedstock growth will depend on where the algae 1908 are grown, if open or closed systems are used, and whether water is recycled. 1909 1910Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.6

3.6.1 Introduction 1912 Waste- Based Feedstocks 1911

Diverse wastes, including construction debris, municipal solid waste (MSW) , yard waste, 1913 food waste, and animal waste , have the potential to serve as biofuel feedstocks. Depending on 1914 the waste, conversion system, and product, potential exists for municipalities, industries, and 1915 farmers to transform a material with high management costs to a resource that generates energy 1916 and profits. In some instances, diverting waste that cannot be recycled or reused to fuel has be en 1917 found to reduce land- filled materials by 90 percent, helping to also extend the lifetime capacity 1918 of the landfill (Helou et al., 2010). 1919

Tapping into waste energy sources has many challenges, including dispersed locations 1920 and potentially high transport c osts; lack of long- term performance data ; the cost of converting 1921
waste to energy, and the possibility that the resulting biofuel might not meet quality or regulatory 1922 specifications for use (Bracmort and Gorte, 2010). 1923

Use of wastes as biofuel feedstocks wil l vary based on their availability, the ability of 1924 conversion technologies to handle the material, and the comparative economics of their use for 1925 fuel versus power and other products. Types and quantities of wastes used will vary by region. A 1926 large number and variety of waste

- based materials are being investigated and implemented as 1927 feedstocks for ethanol and biodiesel, mostly on local scales . For example, s everal states —e.g., 1928 Massachusetts (Advanced Biofuels Task Force, 2008; Timmons et al., 2008), Califor nia (Chester 1929 et al., 2007), and Ohio 20

3.6.2 Municipal Solid Waste 1933 — have explored waste availability and its potential to meet regional 1930 energy needs, either for power or for transportation fuel. Feedstocks may be converted to biofuel 1931 or used as an energy source to power a biorefinery. 1932

The biogenic portion of municipal solid waste (paper, wood, yard trimmings, textiles, and 1934 other materials that are not plastic - or rubber-based), has the potential to be a significant 1935 feedstock for ethanol and other biofuels. Using 2005 data, the U.S. Energy Information 1936 Administration calculated that 94 million tons (MT) (about 56 percent) of the 167.8 MT of MSW 1937 waste generated that year had biogenic BTU content (EIA, 2007). This estimate included food 1938
waste (the third largest componen t by weight), which is also potentially viable as a biofuel 1939 feedstock in addition to biogenic material listed above. Some producers claim to have 1940 thermochemically

- based technology that can yield 120 gallons of ethanol per ton of MSW, and 1941 therefore, this could serve as a rough MSW yield estimate. (Fulcrum Bioenergy, 2009). 1942 Accepting this estimate, the 94 MT of biogenic MSW generated in the U .S. in 2005 would have 1943 the potential to generate up to 11 billion gallons of ethanol. While this is not a likely scenario 1944 (since, for example, some of the biogenic fraction—paper, wood, etc.—would be recycled or 1945 reused), it demonstrates that MSW could be a significant source for biofuel. In addition, there are 1946 significant environmental co -benefits associated with using MSW for biofuel, including 1947

20 Specifically, a partnership between the Solid Waste Authority of Central Ohio and Quasar Energy Group to produce ethanol from municipal solid waste (see http://www.quasarenergygroup.com/pages/home.html ), as well as the “Deploying Renewable Energy

— Transforming Waste to Value” grant program (see: http://www.biomassintel.com/ohio

- 10

- million

- available

- waste

- to

- energy

- grant

- program/ ).Chapter 3: Environmental Im pacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE diverting solid waste from landfills and incinerators, extending their useful life , and reserving 1948 that capacity for materials that cannot be recycled or reused. 1949

3.6.3 Other Wastes 1950

Several types of waste materials that currently present en vironmental and economic 1951 challenges have the potential to be harnessed as feedstock for biofuel. These materials include 1952 waste oil and grease, food processing wastes, and livestock waste (Antizar -Ladislao and Turrion1953 Gomez, 2008; Helou et al., 2010). 1954

The U .S. Department of Energy estimates that the restaurant industry generates 9 pounds 1955 of waste oil per person annually, and that the nation’s wastewater contains roughly 13 pounds of 1956 grease per person per year (Wiltsee, 1998). Several municipalities and indus tries have 1957 implemented collection programs, and are converting these wastes to biodiesel. 1958

Annually, the U.S. generates an estimated 48 million tons of food processing wastes (i.e., 1959 food residues produced during agricultural and industrial operations), not including food waste 1960 disposed and processed through wastewater treatment plants (Kantor et al., 1997). These wastes 1961 have potential a biofuel feedstocks. 1962

The U.S. generates over 1 billion tons of manure, biosolids, and industrial by-products 1963 each year (ARS, n.d.). The amount of manure generated at confined and other types of animal 1964 feeding operations in the U.S. is estimated to exceed 335 million tons of dry matter per year 1965 (ARS, n.d.). While much of this manure is applied to cropland and pasture as fertiliz er, excess is 1966 often available and could be tapped as a biofuel feedstock. It has been estimated that around 10 1967 percent of current manure production could be used for bioenergy purposes under current land 1968 use patterns once sustainability concerns are met (i.e., this manure is available after primary use 1969 of manure on soils to maintain fertility) (Perlack et al., 2005). Methane emissions from livestock 1970 manure management systems, which account for a significant percentage (10 percent, or 17.0 1971 million metric tonnes of carbon equivalent [MMTCE] [3.0 teragrams, or Tg] in 1997) of the total 1972 U.S. methane emissions, are another potential energy source (U.S. EPA, 1999). 1973

Using any of these excess waste materials as biofuel feedstocks has potential to create a 1974 higher val ue use with significant environmental and economic benefits. 1975

3.6.4 Environmental Impacts of Waste-Based Biofuel 1976

Waste -based biofuels are expected to have both environmental benefits and impacts. On 1977 the positive side, for example, diverting waste from landfills a voids generation of landfill 1978 methane gases, and diverting waste and trap greases from wastewater treatment plants helps 1979 avoid costly plant upsets that contribute to combined sewer overflow. Biorefineries that use 1980 wastes, particularly MSW, tend to be located in proximity to the waste source, which correlates 1981 well with the densely populated end-users of transportation fuels and helps reduce the GHG 1982 lifecycle footprint of waste -derived fuels (Antizar-Ladislao and Turrion- Gomez , 2008; Williams 1983 et al., 2009). 1984

Mo re information is needed to understand and evaluate the environmental effects of 1985
waste -based biofuels. Different wastes have different characteristics, including size, volume, 1986Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE heterogeneity, moisture content, and energy value. These characteristics will, to a large degree, 1987 determine feasible and appropriate collection, processing, and conversion methods, which in turn 1988 will determine net energy gain, as well as environmental impacts such as air and GHG 1989 emissions. Research is needed to compare the benefits an d impacts of various technological 1990 options for converting MSW to biofuel, and to compare, on a regional basis, the environmental 1991 benefits and impacts of MSW to other biofuel feedstocks. Currently, data are lacking for such 1992 comparisons. Comparative life cyc le assessments that consider both the direct impacts or 1993 benefits and indirect impacts or benefits (e.g., impacts of reduced landfilling of MSW) are 1994 needed to understand the true value of waste as an alternative feedstock. 1995

Assessment and Uncertainty 1996

There have been comparatively few attempts at assessing the environmental impacts 1997 associated with the production and use of waste-based biofuels (Williams et al., 2009). In 1998 general, waste as a feedstock is expected to have a smaller environmental impact than 1999

con ventional feedstocks. However, the choice of waste management options and the particular 2000 technology for energy recovery will influence the environmental medium impacted and the level 2001 of impact (Chester and Martin, 2009; Kalogo et al., 2007). As the number of waste conversion 2002 facilities increases, environmental monitoring and research will be needed to address the 2003 information gaps that currently limit environmental assessment. 2004

3.7

EISA Section 204 requires an assessment of the impacts of biofuels on a variety of 2006 environmental and resource conservation issues, including impacts on forests, grasslands, and 2007 wetlands. This section provides an overview of impacts on these specific habitats. 2008 Summary of Feedstock

- Dependent Impacts on Specialized Habitats 2005

3.7.1 Forests 2009

Woody biomass is the feedstock most likely to affect forests; row crops, algae, and most 2010 perennial grasses are unlikely to have an impact on this habitat. 2011

Section 211(o) of the Clean Air Act limits planting of short-rotation woody crops and 2012 harvesting of tree residue to actively managed tree plantations on non- federal land that was 2013 cleared prior to December 19, 2007, or to non- federal forestlands; and limits removal of slash 2014 and pre-commercial thinning to non-federal forestlands. However, as described in Ta ble 3 -5, a 2015 variety of activities associated with producing woody biomass feedstock may impact forests. 2016

2017Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Table 3

- 5: Overview of Impacts on Forests from Different Types of Biofuel Feedstocks

Feedstock Forest Impact Report Section

Row C rops Unlikely to have impacts

. Perennial G rasses Most grass species are unlikely to have impacts

. 3.3.6.2

Woody B iomass SRWC plantations may deplete soil nutrients with repeated, frequent harvesting, particularly on marginal soils, but may sustain levels with coppicing, longer

rotations, and strategic use of cover crops. 3.4. 4 .3

SRWC plantations can sustain high species diversity, although bird and mammal species tend to be habitat generalists

. 3.4. 5 .1

Some tree species under consideration, like Eucalyptus , may invade forests in certain locations

. 3.4. 5 .2

Harvesting forest residues may decrease nutrient availability, soil organic matter, and woody debris available for species habitat

. 3.4. 4 .2; 3.4. 4 .3 ; 3.4.6.1 Algae Unlikely to have impacts

. 2018 3.7.2 Grasslands 2019

Production of row crops and perennial grasses for biofuel feedstocks can impact 2020 grasslands, although perennial grasses may also have some positive effects on grasslands. 2021

In addition to the restrictions on forested sources of renewable biomass mentioned above, 2022 Section 211(o) of the Clean Air Act more broadly limits the lands on which any biofuel 2023 feedstock can be produced to those that were cleared or cultivated at any time prior to December 2024 19, 2007, either in active management or fallow and non- forested. Th erefore, grassland that 2025 remained uncultivated as of December 19, 2007, may not be converted to grow biofuel. Most of 2026 lands that would be eligible for renewable biomass production under the Clean Air Act, because 2027 they were cultivated at some point prior to December 19, 2007, are now part of the Conservation 2028 Reserve Program (see Section 3.2.1.1). T he USDA estimates that the vast majority (78 percent) 2029 of lands that will be taken out of the CRP to grown biofuel feedstock will be grasslands (FSA, 2030 2008). Therefor e, conversion of CRP lands to grow biofuels will impact grassland ecosystems, as 2031 will other aspects of biofuel feedstock production (Table 3-6 ). 2032

2033Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE Table 3

- 6: Overview of Impacts on Grasslands from Different Types of Biofuel Feedstocks

Feedstock Grasslands Impact Report Section

Row C rops Conversion of grasslands to row crops impacts grassland

- obligate species, potentially leading to declines, including declines in duck species

. 3.2. 6.1

Higher proportions of corn within grassland ecosystems leads to fewer grassland bird species

. 3.2. 6.1

Perennial G rasses Conversion of row crops to switchgrass may improve grassland habitat for some species depending on management regimes

. 3.3.6.1

Conversion of CRP lands to perennial grasses or harvesting of existing grasslands is less likely to have negative impacts on grassland species, particularly if harvesting occurs after the breeding season

. Use of native mixtures of perennial grasses can restore some native biodiversity

. 3.3.6.1 Cultivation of switchgrass outside its native range may lead to invasions of native grasslands

. 3.3.6.2

Cultivation of Miscanthus may lead to invasions of pasture and other grasslands

. 3.3.6.2 Woody B iomass Unlikely to have impacts

.

Algae Depends on siting.
2034 3.7.3 Impacts on Wetlands 2035

Provisions in both the Food Security Act of 1985 (commonly known as the Swampbuster 2036 Program) and Clean Water Act (Section 404 Regulatory Program) offer disincentives that limit 2037 the conversion and use of wetlands for agricultural production. Nevert heless

, impacts to wetlands 2038 are still expected from the feedstocks assessed in this report (Table 3 -7 ). 2039

Table 3

- 7: Overview of Impacts on Wetlands from Different Types of Biofuel Feedstocks

Feedstock Wetlands Impact Report Section

Row C rops Increased s ediment, nutrient s , chemical s , and pathogens from runoff flow into downstream wetlands

. 3.2.2

Increased nutrient loadings

, lead ing to change s in wetlands community structure

. 3.2. 2.1
Perennial G rasses Reduced sediment and nutrient loadings

, leading to improved water quality ( but dependant on specific management practice ). 3.3.2.1

Some grass species under consideration may invade wetlands, including giant reed ( Arundo donax ) and reed canary grass ( Phalaris arundinacea )

. 3.3.6.2

Woody B iomass Harvesting forest residues and thinning may increase nutrient loads, depending on slopes, soils, any buffer zones, and use of b est m anagement p ractices to reduce runoff

. 3.4. 2.1

Algae Algal strains created may escape from cultivation and invade wetlands . As noted in Section 3.5.2, use of algae for biofuel may also have positive impacts: C o- locating algae production facilities with wastewater treatment plants, fossil fuel power plants, or other industrial pollution sources can improve water quality and utilize waste heat that would otherwise contribute to thermal pollution, while reducing freshwater demands and fertilizer inputs. 3.5. 6 .2

2040Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE 3.8

Genetic engineering of crops has a history of research, development, and 2042 commercialization that extends back for more than 15 years. Along with the growth of this 2043 biotechnology industry, the U.S. established a coordinated framework for regulatory oversight in 2044 1986 (OSTP, 1986). Since then, the relevant agencies (EPA, USDA, and Food and Drug 2045 Administration) have implemented risk assessment programs that allow informed environmental 2046 decision -making prior to commercialization. These programs have been independ ently assessed 2047 over the years (NRC, 2000, 2001, 2002) and improvements made to ensure the safety of the 2048 products. At the same time, the methodology for biotechnology risk assessment has been 2049 scrutinized and general frameworks created to facilitate robust a pproaches and harmonize the 2050 processes internationally (Craig et al., 2008; Auer, 2008; Nickson, 2008; Romeis et al., 2008; 2051 Raybould, 2007; Andow and Zwalen, 2006; Conner et al., 2003; Pollard et al., 2004). This 2052 section describes e nvironmental concerns ass ociated with Genetically Modified Organisms 2053 (GMOs) that are currently used as biofuel feedstocks , as well as anticipated concerns for GMOs 2054 that will be developed for the next generation of biofuel feedstocks. 2055 Genetically Engineered Feedstocks 2041

As indicated earlier in this c hapter, great advantage has already been taken for genetically 2056 engineered corn and soybean , which are now grown worldwide, along with other engineered 2057 crops. Brookes and Barfoot have conducted a series of extensive post- commercialization 2058
assessments of genetically engineer ed maize, soybeans, cotton, sugar beets

, and canola varieties 2059 at 10

- year intervals (Brookes and Barfoot, 2006, 2008, 2009, 2010). In these analyses, the 2060 authors found consistent reductions in the amounts of pesticides used and a reduction in GHG 2061 emissions for agricultural systems where these GMO crops are grown. These results are 2062 supported by others (Brinmer et al., 2005; Knox et al., 2006), although regional differences in the 2063 reductions have been noted (Kleter et al., 2008). The results for corn and soybean independently 2064 are consistent with the general trends (Brookes and Barfoot, 2010). Assuming that current 2065 genetically engineered varieties of corn an d soybeans receive continued regulatory oversight, no 2066 additional environmental concerns are anticipated with these organisms in their current genetic 2067 configuration, even with an increase in their production. However, as feedstocks for biofuel 2068 change to accommodate cellulosic technologies and algae production, the range of environmental 2069 considerations, inclu ding impacts from GMO varieties, will change as well (Wilkinson and 2070 Tepfer, 2009; Lee et al., 2009). 2071

To harness the full potential of biomass, the genetic engineering of feedstocks has been 2072 recognized as a key technology (Gressel 2008; Antizar

- Ladislao an d Turrion-Gomez, 2008; 2073 Sexton et al., 2009). The approaches being considered include increasing plant biomass by 2074 delaying flowering, altering plant growth regulators, and manipulating photosynthetic processes; 2075 modifying traits (e.g., herbicide tolerance, i nsect resistance) in non

- row crop plants that reduce 2076 cultivation inputs; and modifying cellulose/lignin composition and other traits that result in cost 2077 reductions in bioprocessing (i.e., facilitating the biorefinery process) (Sticklen 2007, 2009; 2078 Ragauska s et al., 2006; Gressel 2008). These new varieties may have implications for the 2079 environment beyond what has been considered in first generation biotechnology crops, and the 2080 scientific community has begu n to examine whether and how well existing risk asses sment 2081 procedures will work for bioenergy crops (Wolt, 2009; Chapotin and Wolt, 2007; Wilkinson and 2082 Teper, 2009; Firbank 2007; Lee et al. 2009). For example, some first attempts have been made at 2083Chapter 3: Environmental Impacts of Specific Feedstocks

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— DO NOT CITE OR QUOTE evaluating feedstocks with particular traits; suggestions for minimizing environmental impacts 2084 are incorporated (Kausch et al., 2010a, 2010b). 2085Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE 4. B IOFUEL P RODUCTION , T RANSPORT , S TORAGE AND E ND U SE 1

4.1

This chapter addresses potential environmental impacts of post- harvest activities of the 3 biofuel supply chain (see Figure 4 -1). These activities comprise feedstock logistics (discussed in 4 Section 4.2) and biofuel production (Section 4.3), distribution (Section 4.4), and end use (Section 5 4.5). 6 Introduction 2

Production of biofuel from feedstock takes place at biofuel produc tion facilities through a 7 variety of conversion processes. The resulting biofuel is transported to blending terminals and 8 retail outlets by a variety of means, including rail, barge, tankers, and trucks. Biofuel distribution 9 almost always includes periods of storage. Once dispensed at the final outlet, biofuel is 10 combusted in vehicles and other types of engines, usually as a blend with gasoline or diesel, or in 11 some cases in neat form. 12

Biofuel production, distribution, and end use result primarily in impact s to air and water. 13 Air emissions may be released by a variety of sources (see Figure 4

- 1). Many factors affect the 14 quantity and characteristics of these emissions, including the type and age of equipment used, 15 and operating practices and conditions. 16

17
Fig ure 4 -1: Sources of Criteria Air Pollutant and Toxics Emissions Associated with 18 Production and Use of Biofuel 19Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE Air emissions associated with end use of ethanol combustion are relatively independent 20 of feedstock or conversion process, whereas biodiesel emissions are highly dependent on 21 feedstock type. As discussed later in the chapter, biofuel combustion may result in higher 22 emissions of some pollutants compared to gasoline combustion, and lower emissions of others. 23

Biofuel production may require use of water, which may contribute to ground water 24 depletion or lower surface water flow, depending on the amount of water withdrawn and water 25 availability. Potential water quality impacts include wastewater discharge during the conversion 26 process and the potential for leaks and spills to surface and groundwater during biofuel handling, 27 transport, and storage. Additionally, phosphorus runoff from the manure of animals that have 28 been fed an ethanol by-product, dried distillers grains with solubles, which has a high 29 phosphorus content (Regassa et al., 2008), may have the potential to impact water quality. 30

Possible air and water impacts associated with ethanol and biodiesel, as well as 31 opportunities for mitigation, are discussed in Sections 4.2 to 4.5. Discussion focuses p rimarily on 32 the impacts of corn ethanol and diesel from soybean, since these constitute the vast majority of 33 biofuel produced and used in the U.S. as of July 2010. 34

4.2

4.2.1 Handling, Storage, and Transport 36 Feedstock Logistics 35

Feedstock logistics comprise activities associated with handling, storing, and transporting 37 feedstocks after harvest to the point where the feedstocks are converted to biofuel. The most 38 significant environmental impacts of these activities are the emission s associated with energy 39 use. Both greenhouse gases (GHG) and criteria pollutant emissions result from the combustion of 40 fuels used during transportation. In general, feedstock logistics may be optimized, and emissions 41 reduced, by integrating feedstocks, p rocessing facilities, and consumer demands at a regional 42 scale to minimize transport distances. 43

4.2.1.1 Ethanol 44

Harvested corn is transported to a biorefinery where it is converted to ethanol and a 45 number of co-products. Air quality will be impacted by emissions f rom the combustion of fuels 46 used for transpo rtation vehicles and equipment. 47

4.2.1.2 Biodiesel 48

After harvest, soybeans are transported from fields to the drying site, storehouse, or 49 collection center, followed by transport to the biodiesel refinery. Air quality may be affected by 50 emissions from the combustion of fuels used for transportation vehicles and equipment. 51Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE 4.3

4.3.1 Biofuel Conversion Processes 53 Biofuel Production 52

4.3.1.1 Ethanol 54

As of November 2009, there were 180 corn starch ethanol facilities in the U.S. with a 55 combined capacity of 12 billion gallons per year (bgy) (U.S. EPA, 2010b, footnote 250). 21

Conventional ethanol is produced from the fermentation of corn starch. Two methods are 62 currently utilized: 63 At 56 that time, 27 of these (representing 1,400 million gallons per year (mgy) of capacity) were idled, 57 and another 10 facilities, with a combined capacity of 1,301 mgy, were under construction (U.S. 58 EPA, 2010b, p.137). These facilities are located in the major corn-producing region of the 59 country: Iowa (the largest production capacity and the greatest number of plants) followed by 60 Nebraska, Minnesota, Indiana, and Illinois (U.S. EPA, 2010b). 61

**•** Dry milling, in which the corn kernel is first ground into a meal, usually without 64 separating out the various component parts of the grain. The meal is then slurried 65 with water and cooked at high temperatures to form a mash, which then 66 undergoes fermentation. Dry mill ing is more commonly used than wet milling. 67 68

**•** Wet milling, in which the kernels are steeped in water to separate out the germ, 69 fiber, and gluten (fractionation). From this initial separation, co-products such as 70

corn meal , corn gluten meal, and corn gluten feed are recovered. The remaining 71 mash contains the water -soluble starch, which undergoes further processing for 72 biofuel. 73 74 In both processes, soluble starch is subsequently converted to a simple sugar (glucose) 75 through saccharification, an enzyme

- catalyzed hydrolysis reaction. This is followed by yeast 76 fermentation of the glucose to ethanol. Following fermentation, the mash is distilled to collect 77 the ethanol as a mixture of 95 percent alcohol and 5 percent water. A subsequent dehydration 78 step is required to remove the aqueous portion to yield 99.5 percent pure ethanol. 79

Substantial effort s are under way to develop processes to convert feedstocks containing 80 cellulose into biofuels. These cellulosic feedstocks are primarily composed of cellulose, 81 hemicellulose , and lignin polymers. Currently, two major pathways exist for converting 82 cellulosic fee dstocks into biofuel: 83

**•** Biochemical conversion using a physical and chemical process to liberate tightly 84 bound cellulose and hemicellulose from lignin. The process uses strong acid or 85 enzymes (cellulases) to hydrolyze the cellulose and hemicelluloses to glucose and 86 other simple sugars, followed by microbial fermentation of the sugars into 87 ethanol. 88

21 Sources include the Renewable Fuels Association’s Ethanol Biorefinery Locations (updated October 22, 2009) and Ethanol Producer Magazine ’s producing plant list (last modified on October 22, 2009), in addition to information gathered from producer websites and follow

- up correspondence.Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE **•** Thermochemical conversion involving gasification or pyrolysis. 89 90

— In the gasification process , biomass is heated at high temperatures with a 91 controlled amount of oxygen to decompose the cellulosic material. This 92 yields a mixture comprised mainly of carbon monoxide and hydrogen 93 known as syngas. 94 95

— In pyrolysis , the biomass is heated i n the absence of oxygen at lower 96 temperatures than used in gasification. The product is a liquid bio- oil that 97 can be used subsequently as a feedstock for a petroleum refinery. 98 99 O ther cellulosic conversion processes are in various stages of development, fro m concept 100 stage to pilot- scale development , and to demonstration plant construction. Although no U.S. 101 commercial -scale plants are operating as of July 2010, several companies are expected to have 102 facilities operating within the next few years. 103

4.3.1.2 Biodiesel 104

As of November 2009, there were approximately 191 biodiesel facilities in the U.S., with 105 a combined capacity of 2.8 billion gallons per year (bgy) (U.S. EPA, 2010b). Total domestic 106 production of biodiesel in 2009 was 505 mgy —much less than domestic productio n capacity

. 107 The dominant technology used to produce biodiesel involves a transesterification reaction in 108 which triglycerides (fats) from the oil are converted to esters in the presence of an alcohol and a 109 catalyst, such as potassium hydroxide. Plant oils (soy, rape, palm, algae, etc.) and other 110 feedstocks (e.g., animal -derived oil such as lard and tallow, recycled oil and grease from 111 restaurants and food processing plants) provide sources of triglycerides for conversion to 112 biodiesel. Free glycerol, or glyce rin, is a major co -product in transesterification, comprising an 113 estimated 10 percent of the final product (U.S. EPA, 2010b). Table 4 -1, below shows the 114 breakdown of feedstocks used to produce biodiesel in the U.S. in 2009. Soybean oil made up the 115 majority of biodiesel feedstock, comprising 54 percent. 116

Table 4

- 1. 2009 Summary of Inputs to U.S. Biodiesel Production

Input 2009 Total (lbs.) Percentage of Total Feedstock Inputs Vegetable Oils Corn Oil 84 2.3% Soybean Oil 1,974 54.0%
Other Vegetable Oil 7 0.2%

Animal Fats Poultry Fat 127 3.5%
Tallow 524 14.3%
Animal Fats White Grease 307 8.4%
Other Animal Fats 82 2.2%

Recycled Feedstock Yellow Grease 156 4.3%
Other Recycled Feedstock 13 0.4%Chapter 4: Biofuel Production, Transpor t, Storage and End Use

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— DO NOT CITE OR QUOTE Table 4

- 1. 2009 Summary of Inputs to U.S. Biodiesel Production

Input 2009 Total (lbs.) Percentage of Total Other Inputs Alcohol 328 9.0% Catalysts 56 1.5% Source: EIA, 2010 117 118 Commercial processes for large

- scale algae production and algal oil collection are 119 currently being developed as another plant oil source for biodiesel (U.S. EPA, 2010b). Lipid 120 extraction and drying currently are energy

- intensive steps in the algae diesel p roduction process. 121 Other processing techniques are currently being investigated, including enzymatic conversion 122 and catalytic cracking of algal oil, pyrolysis, and gasification of algae. However, lipid extraction 123 via solvents followed by transesterificatio n remains the most commonly used method for algal 124 oil processing (U.S. DOE, 2010). Until commercial facilities using mature technologies go into 125 production, the impacts from algal conversion will be uncertain. 126

In addition to transesterification, other meth ods for converting seed oils, algal oils, and 127 animal fats into biofuel have been developed recently using technologies that are already widely 128 employed in petroleum refineries (Huo et al., 2009). Hydrotreating technologies utilize seed oils 129 or animal fats to produce an isoparaffin- rich diesel substitute referred to as “green diesel” or 130 renewable diesel (Huo et al., 2008). 131

Although the transesterification process can generate a much larger amount of diesel 132 product than the other processes, as noted above, it requires more energy and chemical inputs 133 (Huo et al., 2008). In the case of biodiesel hydro-generation technology, inputs such as 134 hydrogen, which are very energy -intensive to produce, must be taken into consideration in a full 135 life cycle assessment in order to adequately evaluate energy efficiency of each fuel production 136 process. Compared with conventional diesel and biodiesel, renewable diesel fuels have much 137 higher cetane numbers (a measure of diesel fuel quality). 138

4.3.2 Air Quality 139

Air quality impacts associated with the production of biofuels occur throughout the 140 production chain (Figure 4-1). EPA ’s Regulatory Impact Analysis (RIA) of the revisions to the 141 national Renewable Fuel Standard Program (RFS2) assessed the air pollutant emissions and air 142 quali ty impacts of the biofuel volumes (see Table 2 -1 in Chapter 2) required under the 2007 143 Energy Independence and Security Act (EISA). The discussion below summarizes the RIA 144 results; the interested reader is referred to the RIA for additional details (U.S. E PA, 2010b). 145

The RIA analysis 22

, 23

22 The RIA’s assessment of air quality re lied on data from the EPA’s 2005 National Emissions Inventory, supplemented with the most up

- to

- date information where possible. focused on the projected impact of the renewable fuel volumes 146 required in 2022, and accounted for GHG life cycle emissions, as well as the displaced 147 petroleum consumption associated with use of biofuels. The emission impacts of the 2022 RFS2 148

23 For assessment of electrical energy demand , the RIA used a national energy source profile (i.e., coal, hydro, wind, natural g as) rather than regional source profiles, which can vary across the country.Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE volumes we re quantified relative to two reference cases: 1) the original RFS program ( RFS1 ) 149 mandate volume of 7.5 billion gallons of renewable fuel (6.7 billion gallons ethanol), and 2) the 150 U.S. Department of Energy (DOE) Annual Energy Outlook (AEO) 2007 projected 2022 volume 151 of 13.6 billion gallons of renewable fuels. The RIA analysis found decreases in overall emissions 152 for carbon monoxide (CO) and benzene, and increases in overall emissions for nitrogen oxide 153 (NO x ), volatile organic compounds (VOCs), PM, and several air toxics, especially ethanol and 154 acetaldehyde. Overall emissions of sulfur dioxide ( SO 2 ) exhibited mixed results, depending on 155 the fuel effect specified. 156

For biofuel production and distribution, the net change in VOC, CO, NO x , and PM 157 emissions can be attributed to two effects: 1) emission increases connected with biofuel 158 production, and 2) emission decreases associated with reductions in gasoline production and 159 distribution as ethanol displaces gasoline . Increases in fine particles less than 2.5 micrometers in 160 diameter ( PM 2.5 ), sulfur oxide (SO x ), and especially NO x were determined to be driven by 161 stationary combustion emissions from the substantial increase in corn and cellulosic ethanol 162 production. Sub stantial fugitive dust and particulate incr eases are also associated 163 with agricultural operations. 164

The RIA found that increasing the production and distribution of ethanol would lead to 165 higher ethanol vapor emissions. To a lesser degree, the production and distribution of greater 166 amounts of ethanol would lead to increases in emissions of formaldehyde and acrolein, as well as 167 very small decreases in benzene, 1,3 -butadiene, and naphthalene emissions relative to the total 168 volume of these emissions in the U.S. Emissions of ammonia are expected to increase 169 substantially due to increased ammonia from fertilizer use. Additional details on EPA’s analysis 170 of changes in emissions associated with the RFS2 volumes can be found in 171 www.epa.gov/otaq/fuels/renewablefuels/regulations.htm

. 172

Air pollutant emissions associated with the conversion of biomass to fuel may be 173 mitigated through the use of cleaner fuels during the conversion process and more efficient 174 process and energy generation equipment. The majority of ethanol plants built in recent years, 175 and expected to be built in the near future, utilize dry mill technology (Wang et al., 2007a). 176 Because most ethanol plants utilize similar dry milling production processes, differences in 177 environmental impacts among plants are primarily due to each plant’s choice of fuel. EPA’s RIA 178 assumes a dry mill for the base scenario. 179

EPA’s RIA examines the impacts of using energy -saving technologies such as combined 180 heat and power (CHP). CHP is an effective means to reduce air emissions associated with biofuel 181 production (both ethanol and biodiesel). CHP generates electricity by burning natural gas or 182 biogas, and then employs a heat recovery unit to capture heat from the exhaust stream as thermal 183 energy. Using energy from the same fuel source significantly reduces the total fuel used by 184 facilities along with the corresponding emissions of carbon dioxide (CO 2 ) and other pollutants. 185 Fractionation, membrane separation, and raw starch hydrolysis are additional technologies 186 examined in EPA’s RIA that increase process efficiencies by enabling producers to sell distillers 187 grains (a co -product of the corn-ethanol conversion process) wet rather than dry

, thereby 188 reducing greenhouse gas emissions and other possible environmental impacts (since drying 189 distillers grains is an energy

- intensive process)

. 190Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE 4.3.2.1 Ethanol 191

Ethanol production requires electricity and the use of steam. Electricity is either 192 purchased from the grid or pr oduced onsite, and steam is typically produced onsite from natural 193
gas. Power and the energy used to fuel boilers are responsible for emissions of VOCs, PM, CO, 194 SO x and NO x (U.S. EPA, 2010b; Wan g et al., 2007b). For corn -based ethanol, fossil fuels such 195

as natural gas are typically used to produce heat during the conversion process, although a 196 number of corn ethanol facilities are exploring new technologies with the potential to reduce 197 their energy requirements. 198

A number of processes at ethanol production f acilities result in emissions of air toxics. 199 These processes include fermentation, distillation of the resultant mash, and drying of spent wet 200 grain to produce animal feed. Emissions of air toxics vary tremendously from facility to facility 201 due to a variet y of factors, and it is difficult to determine how differences in the production 202 processes individually impact emissions (U.S. EPA, 2010b). Ethanol vapor and air toxic 203 emissions associated with biofuel production were projected to increase in EPA’s RFS2 RI A, but 204 these would be very small compared to current emissions (U.S. EPA, 2010b). 205

4.3.2.2 Biodiesel 206

While the production process for biodiesel is fundamentally different from ethanol, 207 thermal and electrical energy are still required for production. The thermal ene rgy required for 208 biodiesel production is usually met using steam generated using a natural gas boiler. In certain 209 situations, the glycerol co-product may also be burned to produce process heat, or a biomass 210 boiler may be used to replace natural gas. 211

Air qu ality issues associated with a natural gas -fired biodiesel production process are 212 similar to those for other natural gas applications such as ethanol production, and include 213 emissions of VOCs, PM, CO, SO x, and NO x . Glycerol or solid fuel biomass boilers have 214 emissions characteristics similar to those anticipated for cellulosic ethanol plants, including 215 increased particulates and the potential for VOCs, NO x , and SO x . 216

Biodiesel production using a closed hot oil heater system would have none of the air 217 emissions associated with traditional steam production. Air emissions associated with these 218 systems would be those associated with the production of the electricity, which would take place 219 outside the biodiesel plant boundary. 220

Additionally, the extraction of ve getable oil to create biodiesel in large chemical 221 processing plants is ty pically achieved using hexane, a VOC that EPA has classified as a 222 hazardous air pollutant. Hexane is also commonly used to extract algal oils. F ugitive emissions 223 of hexane may result from increased biodiesel manufacture (Hess et al., 2009). 224

4.3.2.3 Greenhouse Gases 225

Fuel combustion at ethanol and biodiesel facilities releases greenhouse gases. 226 Fermentation to ethanol also releases CO 2 . Combustion- related greenhouse gas emissions are 227 released to the atmosphere, but some ethanol facilities capture, purify, and sell their CO 2 228 associated with fermentation to the beverage industry for carbonation or to food processors for 229Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE flash freezing. Opportunities for CO 2 reuse depend on the proximity of ethanol refineries to local 230 users. The industrial gas supplier Airgas estimates that the ethanol industry captures and recovers 231 5 to 7 percent of all CO 2 that it produces from the ethanol fermentation process (spreadsheet 232 provided to EPA by Bruce Woerner at Airgas on August 14, 2009, cited in U.S. EPA, 2010b, p. 233 133). Other sources of GHG emissions, such as those from electricity generation produced from 234 coal or other GHG-emitting sources, are not currently recovered by the industry. 235

EISA Section 204 does not inclu de GHG emissions in the set of environmental issues to 236 be examined in this report. However, EPA did analyze life cycle GHG emissions from increased 237 renewable fuels use as part of the EISA -mandated revisions to the RFS program. The Act 238 established specific life cycle GHG emission thresholds for each of four types of renewable 239 fuels, requiring a percentage improvement compared to life cycle GHG emissions for gasoline or 240 diesel (whichever is being replaced by the renewable fuel) sold or distributed as transportation 241 fuel in 2005. These life cycle performance improvement thresholds are listed in Table 4-2. 242

Table 4

- 2 . Lifecycle GHG Thresholds Specified in EISA (percent reduction from 2005 baseline)

Renewable fuel a 20%
Advanced biofuel 50%
Biomass

- based diesel 50%
Cellulosic biofuel 60%

a – T he 20% criterion generally applies to renewable fuel from new 243 facilities that commenced construction after December 19, 2007. 244

EPA’s methodology for conducting the GHG life cycle assessment included use of 245 agricultural sector economic models to determine domestic agriculture sector

- wide impacts and 246 international changes in crop production and total crop. Based on these modeling results, EPA 247 estimated GHG emissions using DOE’s GREET model defaults and Intergovernmental Panel on 248 Climate Change (IPCC) emission factors. The GHGs considered in the analysis were CO 2 , 249 methane (CH 4 ), and nitrous oxide (N 2 O). Biofuel process energy use and associated GHG 250 emissions were based on process models for the different pathways considered. For ethanol and 251 biodiesel, EPA’s RFS2 RIA projected that (U.S. EPA, 2010b): 252

**•** Ethanol produced from corn starch at a new (or expanded capacity from an 253 existing) natural gas

- fired facility using advanced efficient technologies will 254 comply with the 20 percent GHG emission reduction threshold. 255 256

**•** Ethanol produced from sugarcane will comply with the 50 percent GHG reduction 257 threshold for the a dvanced fuel category. 258 259

**•** Biodiesel from soy bean oil and renewable diesel from waste oils, fats, and greases 260 will comply with the 50 percent GHG threshold for the biomass- based diesel 261 category. 262 263

**•** Diesel produced from algal oils will comply with the 50 percent GHG threshold 264 for the biomass- based diesel category. 265Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE **•** Cellulosic ethanol and cellulosic diesel (based on the modeled pathways) will 266 comply with the 60 percent GHG reduction threshold applicable to cellulosic 267 biofuels. 268 269 Based on the assessment described above, EPA projected a reduction of 138 million 270 metric ton s of CO 2 -equivalent emissions by 2022 compared to projected 2022 emissions without 271 the EISA

- mandated changes (s ee the RFS2 RIA [U.S. EPA, 2010b] for details ). 272

4.3.3 Water Quality and Availability 273

All biofuel facilities utilize process water to convert biomass to fuel. Water used in the 274 biorefining process is modest in absolute terms compared to the water applied and consumed in 275 growing the plants used to produce biofuel. T he impacts associated with water use at conversion 276 facilities depend on the location of the facility in relation to water resources. In some regions 277 where water is abundant, increased withdrawals may have little effect. Ground water depletion 278 may result in increased costs to pump water from deeper wells, loss of stream flow, and 279 subsidence of the overlying land (Reilly et al., 2008). Several areas of the country that are 280 already experiencing lowered ground water levels (e.g., High Plains aquifer, Lower Miss issippi 281 River alluvial aquifer) correspond with regions where increased biofuel production is expected. 282 In addition, minimum in

- stream flow for aquatic life can be affected by ground water depletion 283 because ground water discharge into streams is a major source of stream base flow. In some 284 areas, streams have run dry due to ground water depletion, while in other areas, minimum stream 285 flow during the summer has been sustained because of irrigation return flow to streams 286 (Bartolino and Cunningham, 2003). In the case of sole source aquifers, ground water depletion 287 may severely impact drinking water availability, since these areas have no readily available 288 alternative freshwater sources (Levin et al., 2002). 289

Comprehensive local, state, and regional water planning , as well as state regulatory 290 controls, are critical to ensure that facilities are located in watersheds that can sustain the 291 increased withdrawal without affecting other uses. The first step in mitigating water availability 292 concerns associated with increa sed biofuel production is to locate production facilities where 293 water sources are adequate to meet production needs without impacting other uses. Siting of 294 biofuel facilities may also be influenced by state laws and regulations designed to avoid or 295 mitigat e conflicts among water uses. These vary by state. For example, withdrawals associated 296 with biofuel production facilities may need a state permit to ensure that the proposed withdrawal 297 does not result in unacceptable impacts on other users or on aquatic li fe. In addition , different 298 states assign water rights in different ways. Some exercise the prior appropriation rule ( i.e., water 299 rights are determined by priority of beneficial use, meaning that the first person to use the water 300 can acquire individual righ ts to the water) ; some are based on the English law of absolute 301 ownership (i.e., rights to use water are connected to land ownership); some limit withdrawals 302 based on stream flow requirements for aquatic life ; and some have a hierarchy to prioritize uses 303

o f the water. 304

Like water quantity impacts, water quality impacts depend on a number of factors 305 including facility location, water source, receiving water, type of feedstock used, biorefinery 306 technology, effluent controls, and water re- use/recycling practices. Water quality impacts are 307 associated with the wastewater discharge from the conversion process. Biological oxygen 308Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE demand (BOD), brine, ammonia-nitrogen, and phosphorus are primary pollutants of concern 309 from ethanol facilities, while discharges of BOD, g lycerin, and to a certain extent, total 310 suspended solids (TSS) pose the major water quality concerns from biodiesel facility effluent. 311 Regulatory controls placed on the quality of biofuel production wastewater discharge can 312 mitigate water quality impacts. Discharges to publicly owned wastewater treatment works 313 (POTWs) are subject to general pre -treatment standards in the Clean Water Act (40 CFR 403.5). 314 Biofuel facilities that discharge their wastewater to POTWs are subject to whatever pre

- treatment 315 limitati ons are in force for the receiving POTW. For those facilities that treat and discharge their 316 own wastewater, EPA has enforceable regulations to control production facility effluent 317 discharges of BOD, sediment, and ammonia-nitrogen through the National Poll utant Discharge 318 Elimination System (NPDES) permit program. 319

Whether effluent is discharged to a POTW or treated onsite at the production facility, 320 BOD can lead to methane emissions during the wastewater treatment process. To mitigate the 321 release of methane to atmosphere, facilities can install anaerobic digesters as a treatment step. 322 Anaerobic digesters treat the biosolids contained in wastewater effluent, generating biogas that is 323 approximately 60 to 65 percent methane. This biogas can then either be flared or captured and 324 used as a clean energy source at the biofuel production facility or elsewhere. 325

Currently there are no effluent limitation guidelines or categorical pretreatment standards 326 that regulate process wastewater discharges from ethanol and biod iesel manufacturing facilities. 327

4.3.3.1 Ethanol 328

In 2007-2008, EPA evaluated biodiesel and corn ethanol manufacturing facilities. No 329 major effluent quality issues were found from corn ethanol plants discharging to either surface 330
waters or to wastewater treatmen t pl ants. 331

While some ethanol facilities get their process water from municipal water supplies, most 332 use onsite wells (Wu et al., 2009). However, most untreated ground water sources are generally 333 not suitable for process water because of their mineral content. Ground water high in mineral 334 content is commonly treated by reverse osmosis, which requires energy and concentrates ground 335 water minerals into reject water, with potential water quality impacts upon their release. For 336 every two gallons of pure water produc ed, about a gallon of brine is discharged as reject water 337 (U.S. EPA, 2010b). Methods to reduce the impact associated with reject water high in mineral 338 concentration include (1) further concentration and disposal, or (2) use of in- stream dilution. 339 Some etha nol facilities have constructed long pipelines to access additional water sources to 340 dilute the effluent to levels tha t meet water quality standards. 341

Once process water is treated, most is lost as steam during the ethanol production 342 process. Water use vari es depending on the age of the facility and the type of milling process. 343 Older generation production facilities use 4 to 6 gallons of process water to produce a gallon of 344 ethanol; newer facilities generally use less than 3 gallons of water in the productio n process. 345 Most of this water savings is gained through improved recycling of water and heat in the process. 346 Dry milling facilities consume on average 3.45 gallons of fresh water per gallon of ethanol 347 produced (Wu et al., 2009); newer facilities tend to consume about 27 percent less water. Wet 348 mill facilities consume an average of 3.95 gallons of fresh water per gallon of ethanol produced 349Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE (Wu, 2008). Most estimates of water consumption in ethanol production are based on the use of 350 clean process water and do not include the water discharged as reject water. 351

Ethanol plants are designed to recycle water within the plant, and improvements in water 352 use efficiency of ethanol facilities are expected through steam condensate reuse and treated 353 process water recycling (Wu et al., 2009) . New technologies that improve water efficiency will 354 help mitigate water quantity impacts. 355

Wastewater effluent from corn starch ethanol facilities is high in BOD (Powers, 2007). 356 For example, one report found that ethanol production from corn produces wastewater with BOD 357 from 18,000 to 37,000 mg/L (Pimentel and Pimentel, 2008, p. 380). Ethanol wastewater effluent 358 can also contain a mmonia -nitrogen and phosphorus. 359

Because no large

- scale cellulosic ethanol production facilities are currently operating, 360 water demand for production of cellulosic ethanol is not certain. However, for most cellulosic 361 feedstocks, including agricultural residues like corn stover and dedicated energy crops like 362 switchgrass, water demand is estimated to be between 2 an d 10 gallons of water per gallon of 363 ethanol, depending on the conversion technology, with volumes greater than 5 gallons of water 364 per gallon of ethanol cited more often (NRC, 2008; Williams et al., 2009; Wu et al., 2009). Some 365 studies assume water demand f or processing woody biomass will be similar to processing 366 cellulosic material from agricultural residues or dedicated energy crops (up to 10 gallons of 367 water per gallon of ethanol) (Evans and Cohen, 2009). Other studies state that new technologies 368 like fas t pyrolysis will require less than half that amount of water per gallon of ethanol (Wu et 369 al., 2009). Consumptive use of water is declining as ethanol producers increasingly incorporate 370 recycling and other methods of converting feedstocks to fuels that red uce water use (NRC, 371 2008). 372

Cellulosic ethanol facilities that employ biochemical conversion would be expected to 373 have similar water requirements and brine discharges as the current operating corn ethanol 374 facilities. The additional steps required to separat e the lignin from the cellulose could produce 375 wastewater streams high in BOD that would require treatment onsite or at wastewater treatment 376 plants. 377

4.3.3.2 Distillers Grain with Solubles 378

One important co-product of ethanol production is dried distillers grain wit h solubles 379 (DDGS). Due to the increase in ethanol production and the price of corn, D DGS has become an 380 increasingly important feed component for confined livestock. About one-third of the corn 381 processed into ethanol is converted into D DGS; therefore, appro ximately 45 million tons of 382 DDGS will be produced in conjunction with the 15 billion gallons of corn ethanol produced by 383 2015. 384

Livestock producers may partially replace corn or other feeds with DDGS for both 385 economic and production reasons. Different lives tock species can tolerate varying amounts of 386 D DGS in their diets. Although specific analysis of DDGS can vary among ethanol plants, D DGS 387 are higher in crude protein (nitrogen) and three to four times higher in phosphorus compared to 388 corn (Regassa et al., 2 008). 389Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE The increase in nitrogen and phosphorus from DDGS in livestock feed has potential 390 implications for water quality. When nitrogen and phosphorus are fed in excess of animals’ 391 needs, excess nutrients are excreted in urine and manure. Livestock manure ma y be applied to 392 crops, especially corn, as a source of nutrients. When manure is applied at rates above the 393 nutrient needs of the crop or when the crop cannot use the nutrients, the nitrogen and phosphorus 394 can runoff to surface waters or leach into ground water s. Excess nutrients from manure nutrients 395 have the same impact on water quality as excess nutrients from other sources. 396

Livestock producers may limit the potential pollution from manure applications to crops 397 through a variety of techniques. USDA’s Nat ural Resources Conservation Service (NRCS) has 398 developed a standard for a comprehensive nutrient management plan to address the issue of 399 proper use of livestock manure (NRCS, 2009). 400

4.3.3.3 Biodiesel 401

Biodiesel facilities use much less water than ethanol facilities to produce biofuel. The 402 primary consumptive water use at biodiesel plants is associated with washing and evaporative 403 processes. Water use is variable, but is usually less than one gallon of water for each gallon of 404 biodiesel produced (U.S. EPA, 2010b); so me facilities recycle washwater, which reduces overall 405 water consumption (U.S. EPA, 2010b). However, water use has been reported as high as three 406 gallons of water per gallon of biodiesel (Pate et al., 2007). Larger well- designed facilities use 407
water more s paringly, while smaller producers tend to use more water per production volume 408 (U.S. EPA, 2010b). New technologies that improve water efficiency will help mitigate water 409 quantity impacts. 410

In addition to water use in the washing and evaporation processes, o ther sources of 411 wastewater include steam condensate; process water softening and treatment to eliminate 412 calcium and magnesium salts, iron, and copper; and wastewaters from the glycerin refining 413 process (U.S. EPA, 2008c). In a joint DOE/USDA study, it was e stimated that consumptive 414 water use at a biodiesel refinery accounts for approximately one -third of the total water use, or 415 about 0.32 gallon of water per gallon of biodiesel produced (Sheehan et al., 1998b). New 416 technologies have reduced the amount of was tewater generated at facilities. Process wastewater 417 disposal practices include direct discharges (to waters of the United States), indirect discharges 418 (to wastewater treatment plants), septic tanks, land application, and recycling (U.S. EPA, 2008c). 419

Most b iodiesel manufacturing processes result in the generation of process wastewaters 420 with free fatty acids and glycerin (a major co -product of biodiesel production). Despite the 421 existing commercial market for glycerin, the rapid development of the biodiesel in dustry has 422 caused a glut of glycerin production, resulting in many facilities disposing glycerin. Glycerin 423 disposal may be regulated under several EPA programs, depending on the practice. However, 424 there have been incidences of glycerin dumping, including a n incident in Missouri that resulted 425 in a large fish kill (U.S. EPA, 2010b). 426

Other constituents in the biodiesel manufacturing process wastewater include organic 427 residues such as esters, soaps, inorganic acids and salts, traces of methanol, and residuals f rom 428 process water softening and treatment (U.S. EPA, 2008c). Solvents used to extract lipids from 429 algae, including hexane, alcohols, and chloroform, could also impact water quality if discharged 430Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE to surface or ground water. Typical wastewater from biodiesel facilities has high concentrations 431 of conventional pollutants—BOD, TSS, oil, and grease —and also contains a variety of non432 conventional pollutants (U.S. EPA, 2008c). 433

Some biodiesel facilities discharge their wastewater to municipal wastewater treatment 434
sy stems for treatment and discharge. In some cases, wastewater with sufficiently high glycerin 435 levels has disrupted municipal wastewater treatment plant function (U.S. EPA, 2010b). There 436 have been several cases of municipal wastewater treatment plant upsets due to high BOD 437 loadings from releases of glycerin (U.S. EPA, 2010b). To mitigate wastewater issues, some 438 production systems reclaim glycerin from the wastewater. As another option, closed-loop 439 systems in which water and solvents can be recycled and reused can reduce the quantity of water 440 that must be pretreated before discharge. 441

4.3.4 Impacts from Solid Waste Generation 442

Biofuels may also lead to significant environmental impacts stemming from solid waste 443 generated by various production processes. EPA defines “solid wastes” as any discarded 444 material, such as spent materials, by -products, scrap metals, sludge, etc., except for domestic 445 wastewater, non -point source industrial wastewater, and other excluded substances (U.S. EPA, 446 2010i). A type of solid waste that is of particular interest in the case of biofuel production is the 447 diatomaceous earth that is used as a filter to remove impurities from methyl esters, such as 448 biodiesel. Sev eral reports have indicated that diatomaceous earth may be spontaneously 449 combustible, and disposal sites consider it a potential hazardous waste (Missouri Department of 450 Natural Resources, 2008; Nebraska Department of Environmental Quality, 2009). The high 451 surface area of the diatomaceous earth and the oil sets up a rapid decomposition that creates heat. 452 Further study is needed to investigate this potential hazard and look into mitigation strategies. 453

4.4

The vast majority of biofuel feedstocks and finished biofuel are currently transported by 455 rail, barge, and tank truck. Ethanol and biodiesel are both generally blended at the end of the 456 distribution chain, just before delivery to retail outlets. Storage of biofuels typically occurs in 457 above-ground tanks at blending terminals, in underground storage tanks (USTs), and at retail 458 outlets (as a petroleum -biofuel blend). 459 Biofuel Distribution 454

The primary impacts related to transport and storage of biofuels relate to air quality (i.e., 460 emissions from transport vehicles and evaporative emissions) and water quality (i.e., leaks and 461 spills). 462

4.4.1 Air Quality 463

4.4.1.1 Ethanol 464

Air pollution emissions associated with distributing fuel come from two sources: 1) 465 evaporative, spillage, and permeation emissions from storage and transfer activities, and 2) 466 emissions from vehicles and pipeline pumps used to transport the fuels (see Figure 4- 1). 467 Emissions of ethanol occur both during transport from production facilities to bulk terminals, and 468 after blending at bulk terminals. 469Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE Although most ethanol fa cilities are concentrated in the midwestern United States, 470 gasoline consumption is highest along the east and west coasts. Fleet transport of biofuel, often 471 by barge, rail, and truck, increases emissions of air pollutants, such as CO 2 , NOx , and PM due to 472 the combustion of fuels by transport vehicles. EPA’s RFS2 RIA found relatively small increases 473 in criteria and air toxics emissions associated with transportation of biofuel feedstocks and fuels 474 (U.S. EPA, 2010b). In addition, transport and handling of biof uel may result in small but 475 significant evaporative emissions of VOCs (Hess et al., 2009). With the exception of benzene 476 emissions, which were projected to decrease slightly, EPA’s RFS2 RIA projected relatively 477 small increases in emissions of air pollutant s associated with evaporation (U.S. EPA, 2010b). 478

Pipeline transport decreases air emissions associated with fleet transport of biofuel 479 because fuel is not combusted in the transport process. However, t ransport of biofuels by 480 pipeline raises potential techn ical issues, including internal corrosion and stress corrosion 481 cracking in pipeline walls, and the potential to degrade performance of seals, gaskets , and 482 internal coatings. Additionally, ethanol’s solvency and affinity for water can generate product 483 contamination concerns (U.S. EPA, 2010b). D edicated ethanol pipelines may alleviate these 484 issues; however, they are costly to construct. Due to the incompatibility issues with the existing 485 petroleum pipeline infrastructure, the growth in ethanol production is e xpected to increase 486 emissions of criteria and toxic air pollutants from freight transport, while a corresponding 487 decrease in gasoline distribution would decrease emissions related to pipeline pumping (Hess et al., 488 2009)

. 489

4.4.1.2 Biodiesel 490

Air pollution emissions f rom fuel combustion in transport vehicles related to biodiesel 491 feedstocks and fuels are not materially different than those associated with ethanol. Currently, 492 pipeline distribution of biodiesel is still in the experimental phase. Significant evaporative 493 emissions are not expected from storage and transport of biodiesel fuel due to its low volatility 494 (U.S. EPA, 2010b). 495

4.4.2 Water Quality 496

Leaks and spills from above-ground, underground, or transport tanks may occur during 497 biofuel transport and storage, potentially contaminating ground water, surface water, or drinking 498 water supplies

. 499

For bulk transport, the major concern is based on an accident scenario in which the 500 transport tank is damaged and a large amount of fuel is spilled. In addition, leaks might occur 501 during transport because of certain fuel- related factors, such as the fuel’s corrosivity. Ethanol is 502 slightly acidic and can corrode some active metals; biodiesel is also slightly corrosive. The 503 possibility of leaks during transport is minimized by the selection of appropriate materials and 504 proper design in accordance with the app licable material standards. 505

Leaks from storage tanks are also a major concern. Most states report that underground 506 storage tanks (USTs) are a major source of ground water contamination (U.S. EPA, 2000). 507 Preliminary research has shown that any concentration of biofuel in an underground tank also 508 containing petroleum -based fuels increases the potential for groundwater migration (EPA 509Chapter 4: Biofu el Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE OSWER Biofuels Compendium, http://www.epa.gov/oust/altfuels/bfcompe nd.htm ). A leaking 510 UST can also present other health and environmental risks, including the potential for fire and 511 explosion. 512

EPA’s Office of Underground Storage Tanks is working with other agencies to better 513 understand material compatibility issues associ ated with older UST systems, in order to assess 514 the ability of these systems to handle new fuel blends (U.S. EPA, 2009b). Because most of the 515 current underground storage tank equipment, including 617,000 active USTs, was designed and 516 tested for use with pe troleum fuels, many UST systems currently in use may contain materials 517 that are incompatible with ethanol blends greater than 10 percent (U.S. EPA, 2009c) or biodiesel. 518 Although it is not possible to quantify the risk at this time, EPA is developing modeli ng software 519 to assess fuels of varying composition on ground water (U.S. EPA, 2010b). 520

Biodiesel and ethanol blend fuels degrade many non- metallic materials, such as natural 521 rubber, polyurethane, older adhesives, certain elastomers and polymers used in flex piping, 522 bushings, gaskets, meters, filters, and materials made of cork. Biodiesel and ethanol blend fuels 523 also degrade soft metals such as zinc, brass, and aluminum. If a fuel system does contain these 524 materials and users wish to fuel with blends over B20 (i.e., with fuel containing more than 20 525 percent biodiesel), replacement with compatible elastomers is needed. In many instances, 526 especially with older equipment, the exact composition of elastomers cannot be obtained and it is 527 recommended they be replace d if using blends over B20. 528

Several measures are already in place to help prevent and mitigate potential water quality 529 impacts. Under the Resource Conservation and Recovery Act (RCRA), owners and operators of 530 regulated UST systems must comply with requirem ents for financial responsibility, corrosion 531 protection, leak detection, and spill and overfill prevention. Federal regulations require that 532 ethanol and biodiesel storage containers are compatible with the fuel stored. For USTs, leak 533 detection equipment is required and must be functional. Through the Spill Prevention, Control, 534 and Countermeasure (SPCC) rule, EPA has enforceable regulations to control water quality 535 impacts from spills or leaks of bi ofuel products and by-products. 536

Further testing and certific ation of the acceptability of storage tanks and leak detection 537 systems performance will be crucial to safe storage of biofuels. In addition, developing storage 538 materials that are resistant to biofuel leaks and spills locating will help prevent spills, and 539 locating USTs away from ground water supplies, and will mitigate water quality impacts in case 540 a spill or leak does occur. 541

Additional details specific to ethanol and biodiesel are discussed below. 542

4.4.2.1 Ethanol 543

Ethanol is stored in neat form at the production fa cility, in denatured form at terminals 544 and blenders, and as E85 (85 percent ethanol and 15 percent gasoline) and E10 (10 percent 545 ethanol and 90 percent gasoline) mixtures at retail. Ethanol is water soluble and can be degraded 546 by microorganisms commonly present in ground water (U.S. EPA, 2009d). In ground water, 547 ethanol’s high oxygen demand and biodegradability changes the attenuation of the constitu ents 548 in gasoline/ethanol blends. This can cause reduced biodegradation of benzene, toluene, and 549Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE xylene (up to 50 percent for toluene and 95 percent for benzene) (Mackay et al., 2006; U.S. EPA, 550 2009d). The presence of ethanol can restrict the rate and extent of biodegradation of benzene, 551 which can cause the plumes of benzene to be longer than they would have been in the absence of 552 ethanol (Corseuil et al., 1998; Powers et al., 2001; Ruiz-Aguilar et al., 2002). This could be a 553 significant concern to communities that rely on ground water supplies with the potential to be 554 impacted by leaks or spills (Powers et al., 2001; Ruiz-Aguilar et al., 2002). In surface waters, 555 rapid biodegradation of ethanol can result in depletion of dissolved oxygen with potential 556 mortality to aquatic life (U.S. EPA, 2010b). 557

There are other potential hazards in addition to those associated wit h chemical toxicity. 558 Some spills of gasoline with ethanol may produce methane concentrations in the soil that pose a 559 risk of explosion (Da Silva and Alvarez, 2002; Powers et al., 2001). 560

4.4.2.2 Biodiesel 561

In general, if biodiesel is blended with petroleum diesel, another petroleum product, or a 562 hazardous substance, state UST regulations may apply to those blends. One-hundred percent 563 biodiesel contains no petroleum-based products or hazardous substances. Therefore, UST 564 regulations generally do not apply to 10 0 percen t biodiesel. 565

Biodiesel is not water soluble. Biodiesel degrades approximately four times faster than 566 petroleum diesel. In aquatic environments, biodiesel degrades fairly extensively (Kimble, n.d.). 567 Results of aquatic toxicity testing of biodiesel indicate that it is less toxic than regular diesel 568 (Kahn et al., 2007). Biodiesel does have a high oxygen demand in aquatic environments, and can 569 cause fish kills as a result of oxygen depletion (Kimble, n.d.). Water quality impacts associated 570 with spills at biodiesel facilities generally result from discharge of glycerin, rather than biodiesel 571 itself (Kimble, n.d.). 572

4.5

Most vehicles on the road today can operate on E10. Nearly half of U.S. gasoline is an 574 E10 mixture to boost octane for more complete combustion or to meet air quality requirements 575 (Alternative Fuels and Advanced Vehicles Data Center, 2010). E85 is another form in which 576 ethanol is consumed, but it can only be used in flex-fuel vehicles, which can run on either 577 conventional gasoline or ethanol blended into gasoline up to 85 percent. Under current market 578 circumstances, greater deployment of flex

- fuel vehicles may be needed to meet the EISA 579 mandated volume standards. Because of biodiesel’s chemical properties, it is not interchangeable 580 with petroleum- based diesel fuel. For this reason, its blend level is specifically labeled when it is 581 blended with petroleum diesel (U.S. EPA, 2010b). Biodiesel can be used in its pure form, known 582 as “neat biodiesel” or B100, but most vehicle and engine manufacturers do not recommend its 583 use in non- approved engines and vehicles. There are some concerns regarding maintenance 584 issues related to engines operated on biodiesel, because the fuel has been shown to soften and 585 degrade certain types of elastomers and natural rubber compounds over time. This will impair 586 fuel system components such as fuel hoses and fuel pump seals. Such component degradation 587 can lead to leaks, poor performance, and other problems that are likely to result in increased 588 emissions and subsequent environmental impacts. 589 Biofuel End Use 573Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE Biofuels for jet aircraft require additional refining or need to be blended with typical jet 590 fuels to meet the standards of commercial aviation fuels. There are few long

- term studies of 591 biofuel performance on large diesel engines such as stationary power generators, ships, 592 locomotives, and jet engines. 593

4.5.1 Air Quality 594

The primary impact associated with bio fuel end use is air quality. Section 211 (v) of the 595 Clean Air Act requires EPA to study the air quality impacts associated with the use of biofuel 596 and biofuel blends. EPA has already adopted mobile source emission control programs that 597 reduce air pollution emissions and improve air quality. If necessary, EPA will issue further 598 regulations to mitigate adverse air quality impacts as a result of increases in biofuels. 599

4.5.1.1 Ethanol 600

The following discussion is based on E10, because considerably more information is 601

av ailable about its use. A wide variation in evaporative and tailpipe emissions have been 602 reported due to a range of factors, such as the age of the vehicle, the power output and operating 603 condition of the engine, the fuel characteristics, how the vehicle is operated, and ambient 604 temperatures (Ginnebaugh et al., 2010; Graham et al., 2008; Yanowitz and McCormick, 2009). 605

As stated in section 4.3.2, the emission impacts of the 2022 RFS2 volumes in the RFS2 606 RIA we re quantified relative to two reference cases: 1) the original RFS program ( RFS1 ) 607 mandate volume of 7.5 billion gallons of renewable fuel (6.7 billion gallons ethanol), and 2) the 608 U.S. Department of Energy (DOE) Annual Energy Outlook (AEO) 2007 projected 2022 volume 609 of 13.6 billion gallons of renewable fu els. In the RFS2 RIA, EPA projected decreases in 610 emissions of carbon monoxide, benzene, and acrolein in 2022 under the RFS2- mandated 611 volumes of biofuels, while NO x , HC, and the other air toxics, especially ethanol and 612 acetaldehyde, were projected to increase. The inclusion of E85 emissions effects would be 613 expected to yield larger reductions in CO, benzene, and 1,3-butadiene, but more significant 614 increases in ethanol, acetaldehyde, and formaldehyde (U.S. EPA, 2010b). 615

4.5.1.2 Biodiesel 616

Air emissions from combustion of some biofuels, such as ethanol, are relatively 617 independent of feedstock or conversion process. However, biodiesel emissions may be highly 618 variable depending on the feedstock type (Lapuerta et al., 2008; U.S. EPA, 2002). With respect 619 to carbon content, plant-based biodiesel is slightly higher percentage- wise than animal

- based 620 biodiesel in gallon

- per -gallon comparisons. For NO x , PM, and CO, plant- based biodiesel te nds to 621 have higher emissions than animal-based biodiesel for all percent blends (U.S. EPA, 2002). 622

Studies of biodiesel and biodiesel blends show varying results depending on the fuel (i.e., 623 type of biodiesel, biodiesel blend, type of base diesel), the vehi cle being tested, and the type of 624 testing. In general, combustion of biodiesel has been shown to decrease PM, CO, and HC 625 emissions, increase NO x emissions, and increase ozone-forming potential (Gaffney and Marley, 626 2009; U.S. EPA, 2002). It should be kept in mind that petroleum- based diesel

- fueled vehicles are 627 expected to emit significantly lower amounts of SO 2 because of the Heavy -Duty Engine and 628 Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements (2007 Heavy- Duty 629Chapter 4: Biofuel Production, Transport, Storage and End Use

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— DO NOT CITE OR QUOTE Highway Rule) and the ava ilability of low -sulfur diesel fuel in the marketplace, which must be 630 accounted for when considering the emission benefits of low SO x biodiesel (U.S. EPA, 2001). 631 Blending biodiesel in low percentages will not have much impact on sulfur emissions. 632

With resp ect to carbon content, plant-based biodiesel is slightly higher than animal- based 633 biodiesel percentage- wise. For NO x , PM, and CO, plant-based biodiesel tends to have higher 634 emissions than animal -based biodiesel for all percent blends (U.S. EPA, 2002). 635

EPA’ s RFS2 RIA investigated the impacts of 20 volume percent biodiesel fuels on NO x , 636 PM, HC, and CO emissions from heavy-duty diesel vehicles, compared to using 100 percent 637 petroleum- based diesel. Average NO x emissions were found to increase 2.2 percent, while PM, 638 HC, and CO were found to decrease 15.6 percent, 13.8 percent, and 14.1 percent, respectively, 639 for all test cycles run on 20 volume percent soybean-based biodiesel fuel. Biodiesel results were 640 included in the EPA analysis; however, the biodiesel contribution to overall emissions is quite 641 small (U.S. EPA, 2010b). 642Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE 5. I NTERNATIONAL C ONSIDERATIONS 1

5.1

In the global context, biofuel demands from an increasing number of countries will have 3 direct and indirect impacts, not only on countries that produce biofuels, but on countries that 4 currently rely on imports of agricultural commodities from biofuel producers (Hertel et al., 2010; 5 Pimentel et al., 2009; Zah and Ruddy, 2009). Section 204 of the Energy Independence and 6 Security Act ( EISA ) calls for EPA to report to Congress the environmental impacts outside the 7 United States caused by U.S. biofuel use. Thus, the following discussion focuses on potential 8 impacts in foreign countries that may result from implementation of the RFS2 standards. 9 Introduction 2

International trade is the primary mechanism through which foreign nations will be 10 impacted by U.S. biofuel policy. Ethanol and, to a much smaller degree, biodiesel, have become 11 global commodities. They are produced in many countries (Figure 5-1) and traded in 12 international markets. Primary producers of ethanol are Brazil, the U.S., the European Union, 13 India, and China. Brazil is the only significant exporter of ethanol (Fabiosa, 2010). Changes in 14 U.S. production and consumption volumes, such as those in RFS2, will result in land allocation 15 impacts that have global ramifications through international trade and market price. A s a crop 16 price rises, land will be reallocated to grow more of that crop in response to market price; 17 conversely declining prices for a particular crop will tend to reallocate land away from that less 18 profitable crop in favor of a more profitable one. Incr eased competition for arable land is 19 expected to result in more land being allocated for crop production (Fabiosa, 2010). 20

21 22 Source: UNEP/GRID

- Arendal, 2009. 23

Figure 5-1 : Biofuel Production Map 24Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE R esultin g environmental impacts, both positive and negative, include effects from land 25 use change and effects on air quality, water quality, and biodiversity. From a U.S. perspective, 26 the severity of these impacts will depend on the volume and location of future imports and 27 exports, both of biofuel and displaced agricultural goods. 28

In 2008, the United States and Brazil together produced 89 percent of the world’s fuel 29 ethanol, with the U.S. producing around 9 billion gallons (see Table 5-1) (EIA, n.d. [c]). In 2009, 30 U.S. ethanol production increased to 10.9 billion gallons, and similar increases occurred in most 31 ethanol-producing nations as they attempted to increase the portion of biofuel in their energy mix 32 (EIA, n.d. [c]). As a result, total world production has nearly doubled from 10.9 billion gallons in 33 2006 to 20.3 billion gallons in 2009. Figure 5-1 shows the geographical distribution of biofuel 34 production. Patterns of ethanol consumption generally matched those of production, with the 35 largest producers also being the largest consumers (EIA, n.d. [c]). 36

Table 5

- 1 : Top Fuel Ethanol

- Producing Countries from 2005 to 2009 (All figures are in millions of gallons)

Country/Region 2005 2006 2007 2008 2009
United States 3,904 4,884 6, 521 9,2 83 10, 938
Brazil 4,237 4,693 5, 959 7,148 6, 896 European Union 216 427 477 723 951
China 317 369 440 5 26 5 67
Canada 67 67 21 2 2 50 2 87
Jamaica 34 80 74 98 106
Thailand 18 34 46 87 106
India 57 63 69 71 89
Colombia 8 71 72 67 80
Australia 6 20 21 38 54
Other 93 216 276 393 274

Total World Production 8,957 10,924 14,167 18,684 20,348

Source: EIA, n.d

. [c]. 37 38 The market for the other major biofuel, biodiesel, is concentrated in Europe, which 39 represented about 60 percent of world production as of 2009 (EIA, n.d. [b]). The other 40 percent 40 of the market is largely made up by the United States, Brazil, Argentina, and Thailand, with U.S. 41 production estimated at 505 million gallons for 2009, or about 10 percent of the world total (EIA, 42 n.d. [b]). World biodiesel production has been rapidly increasing over the past decade, from 242 43 million gallons in 2000 to about 4.7 billion gallons in 2009 (EIA, n.d. [b]). These production 44 increases have been driven by increa sed consumption targets. For instance, Brazil has planned to 45 increase its biodiesel blend from 5 to 10 percent by 2015. 46Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE 5.2

U.S. biofuel import volumes will depend largely on domestic production capacity, 48 including the efficiency of the domestic ethanol -producing sector, the yields attained, and any 49 excess demand left to be met via import ed biofuel or biofuel feedstocks. 50 Import/Export Volumes 47

With respect to production capacity, as discussed in Chapter 2, the renewable fuel 51 volume mandates under EISA require that U.S. biofuel consumption steadily increase to 36 52 billion gallons by 2022. This biofuel will be comprised of both conventional and advanced 53 biofuel (including cellulosic ethanol, algal biodiesel, and other forms of advanced biofuel). Most 54 of the 10.9 billion gallons of conventional ethanol that the U.S. produced in 2009 came from 55 corn starch; by 2015, this figure is expected to increase to the targeted volume provided for in the 56 revised Renewable Fuel Standards (RFS2) program (as required under EISA) of 15 billion 57 gallons (GAO, 2007; U.S. EPA, 2010b). Future production volumes of advanced biofuel that 58 have not yet been commercially developed are not quite as certain. In its RFS2 Regulatory 59 Impact Analysis (RIA), EPA estimated that cellulosic technologies could combine to provide an 60 additional 16 billion gallons of ethanol by 2022, with a substantial portion of this, 7.8 billion 61 gallons worth, using corn stover as a cellulosic feedstock source (U.S. EPA, 2010b). In addition, 62 U.S. biodiesel production is projected to increase to roughly 1.3 billion gallons by 2019 (FAPRI, 63 2010d). The RFS2 RIA also projected that the remaining 4 billion gallons needed to meet the 64 EISA 2022 mandate would be comprised of a combination of imported sugarcane ethanol from 65 Brazil a s well as “other advanced biofuel,” including cellulosic biofuel, biomass- based diesel, 66 and co -processed renewable diesel (U.S. EPA, 2010b). Table 5-2 shows the projected import 67 volumes forecasted in the RIA for each year from 2011 to 2022. 68

Table 5

- 2: RFS2 RIA Projected Imports a nd Corn Ethanol Production, 2011

- 2022

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022
U.S. C orn E thanol P roduction 12,070 12,830 13,420 14,090 14,790 15,000 15,000 15,000 15,000 15,000 15,000 15,000

Projected I mports 160 180 190 200 390 630 1,070 1,510 1,960 1,880 1,810 2,240 Source: U.S. EPA, 2010b, pp. 7 7-78. 69 Figures are in millions of gallons. 70

As Table 5 -2 shows, import volumes will be at or below 200 million gallons in years 71 preceding 2015, followed by a significant increase in import volumes between 2015 and 2022. 72 This is in part because domest ic corn starch ethanol production is expected to increase rapidly up 73 until 2015 and then level off, and also because the RFS2 total renewable fuel requirements 74 increase more rapidly in the later years. It should also be noted that 2010 import figures have 75 been much lower than those expected when forecasts were made in 2009. Imports of fuel ethanol 76 for the first three -quarters of 2010 (USDA, n.d.) have totaled 17 m illion gallons

– well below 77 EPA’s 200 million gallons forecast (EPA, 2010b). Therefore, ethanol imports may be 78 significantly lower than the projections in Table 5-2. U.S. biofuel imports and exports will also 79 be influenc ed by trade policy, including tariffs and other incentives in the U.S. and in other 80 countries. Even if the U.S. succeeds in meeting the RFS2 targets, the U.S. likely will continue to 81 import and export biofuel as individual producers take advantage of international price 82Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE differences. Over the past decade (2002 to 2009), U.S. ethanol import quantities varied 83 considerably (see Table 5 -3) , mostly due to volatility in the prices of related commodities such 84 as corn, sugar, and other feedstocks, as well as prices of energy commodities such as oil. 85

Table 5

- 3 : Historical U.S. Domestic Ethanol Production and Imports

2002 2003 2004 2005 2006 2007 2008 2009
U.S

. Production 2,1 4 0 2,8 04 3, 395 3,90 4 4,8 84 6, 521 9, 283 10, 938 Imports 13 12 149 136 731 439 530 198

Source: EIA, n.d. [c] for production figures; EIA, n.d. [d] for import figures. 86 Note: Figures are in millions of gallons. 87 88 Th e bulk of U.S. ethanol imports are sugarcane -based ethanol from Brazil. In 2008, the 89 U.S. was the largest importer of Brazilian ethanol, followed by the Netherlands and a number of 90 Caribbean countries (see Table 5 -4). However, foreign-produced ethanol is also imported to the 91 U.S. via the se Caribbean countries where the Caribbean Basin Initiative (CBI), a regional trade 92 agreement , enables up to 7 percent of the biofuel consumed in the U.S. to be imported from CBI 93 member countries duty- free (Yacobucci, 2005; Farinelli et al., 2009). Therefore, most of the 94 Brazilian exports shown as going to CBI member countries such as Costa Rica, Jam aica, El 95 Salvador, Trinidad and Tobago, (see Table 5-4), is eventually re-exported to the United States. 96 Looking closer at these Brazilian export figures in Table 5-4, it is evident that ethanol trade 97 changed somewhat dramatically in 2009, with most destin ations experiencing a significant 98 decline in imports. A large part of this decline is due to the drop in U.S. imports caused by a 99 change in energy prices

, as well an increase in sugar prices that made imported Brazilian ethanol 100 less competitive in the U.S. market (Lee and Sumner, 2010). These rising sugar prices, as 101

Table 5

- 4 : 2008

- 2009 Brazilian Ethanol Exports by Country of Destination

Destination Country Volume (million gallons)
2008 % of Total 2009 % of Total
Total 1,352.9 100% 870.8 100%
United States 401.6 29.7% 71.9 8.3%
Netherlands 351.9 26.0% 179.2 20.6%
Jamaica 115.3 8.5% 115.6 13.3%
El Salvador 94.1 7.0% 18.8 2.2% Japan 69.6 5.1% 74.0 8.4% Trinidad and Tobago 59.3 4.4% 37.0 4.2% Virgin Islands (U.S) 49.7 3.7% 3.4 0.4% Korea, Republic of (South Korea) 49.3 3.6% 82.9 9.5%
Costa Rica 28.9 2.1% 26.5 3.0% Nigeria 25.9 1.9% 30.6 3.5% United Kingdom 18.4 1.4% 42.7 4.9%
Source: SECEX, n.d. 102 Note: Percentages do not sum to 100 percent because some destinations are not listed. Original data were 103 converted from liters to gallons. 104Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE well as the recent strengthening of Brazil’s currency

, could significantly hinder Brazil’s ability to 105 supply the U.S. market moving forward. Even if the 54- cent

- per -gallon tariff on ethanol imports 106 does expire as planned at the end of 2010, these factors may limit future imports (USDA, 107 2010d). 108

The U.S. also exports biofuel (including ethanol and biodiesel) to foreign countries. 109 Canada has been the primary recipient of U.S. exports, with Europe becoming a more prevalent 110 destination beginning in 2004 ( see Figure 5 -2 ) as its biofuel consumption has increased

. U.S

. 111 ethanol exports have increased in recent years due to increased production. However, export 112 level s, ranging from about 50 million to 175 million gallons, are no more than 1 percent of 113 domestic production and are far outweighed by imports. Exports are likely to continue to lag 114 behind imports in the near-term as consumption rises. 115

116 Source: ERS, 2010a. 117 Note: Original data were converted from liters to gallons, graph was created by ERG. 118 119

Figure 5

- 2: Historic U.S

. Eth anol Export Volumes and Destinations 120

Table 5 -5 shows the 2008 U.S. biodiesel trade balance. At that time, 46.8 percent of 121 domestically produced biodiesel was exported. Biodiesel export volume has increased 122 dramatically in recent years, from about 9 million gallons in 2005 to nearly 677 million in 2008 123 (EIA, n.d.[b]). In 2009, biodiesel export volume fell dramatically to only 266 million gallon s 124 (USDA, n.d.). Current projections have net U.S. biodiesel exports (i.e., exports minus imports) 125 falling for the next few years and then rising back up to around 100 million gallons by the end of 126 the decade (FAPRI, 2010d). 127

128 0 20 40 60 80 100 120 140 160 180 200

2000/01 2001/02 2002/03 2003/04 2004/05 2005/06 2006/07 2007/08 2008/09

Harvest YearMillion Gallons Other

UAE

India

Austrailia

EU

Mexico

CanadaChapter 5: International Considerations

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— DO NOT CITE OR QUOTE Table 5

- 5 : 2008 U

. S

. Biodiesel Balance of Trade

Item Quantity

U.S. Production 774 million gallons U.S. Consumption 412 million gallons

Production

– consumption = 362 million gallons U.S. Imports 315 million gallons U.S. Exports 677 million gallons Exports

– Imports = 362 million gallons Source: EIA, 2009, n.d.[c]. 129

5.3

The issue of land use change inherently includes international considerations, as the 131 demand for biofuel in the U.S. can influence the international availability of crops such as corn 132 and soybeans for both biofuel and agricultural markets, which in turn can incentivize land use 133 changes in other countries to meet that demand. In this report, land use is defined as “the human 134 use of land involving the management and modification of natural environment or wilderness 135 into built environment such as fields, pastures, and settlements ”. Land use changes are 136 considered either direct or indirect. In the context of biofuels, direct land use change (DLUC) 137 refers to land conversion that is directly related to the biofuel supply chain. An example of direct 138 land use change would be the planting of sugarcane on Brazilian land, which was previously 139 native forest or used for another non-biofuel crop, for the purpose of increasing the supply of 140 ethanol to export to the United States. Indirect land use change (ILUC) refers to land conversion 141 that is a market -oriented response to changes in the supply and demand of goods that arise from 142 increased production of biofuel feedstocks. An example of indirect land use change would be the 143 clearing of foreign land to plant corn in response to reduced U.S. corn exports caused by 144 increased U.S. corn ethanol production. Some have argued that these indirect impacts should not 145 be counted as part of the biofuel carbon footprint because they are too difficult to relate back to 146 biofuel production. However, EISA requires that “direct emissions and significant indirect 147 emissions such as significant emissions from land use change” be considered as part of the 148 analysis of environmental impacts stemming from domestic biof uel production and consumption. 149 Environmental Impacts of Direct and Indirect Land U se Changes 130

In its RFS2 Regulatory Impact A nalysis

, EPA estimated greenhouse gas (GHG) impacts 150 of direct and indirect land use change using the FAPRI- CARD model. 24

24 FAPRI

- CARD is a worldwide agricultural sector economic model . For the RIA, the model was run by the Center for Agricultural and Rural Development at Iowa State University on beh alf of EPA. This model predicts 151 world prices by equating excess supply and demand across countri es. Changes in world prices 152 determine changes in worldwide commodity production and trade. Under this model, two 153 primary domestic effects directly affect a commodity’s worldwide use and trade: change in U.S. 154 exports and changes in domestic U.S. prices (U.S. EPA, 2010b). Using this model, along with 155 MODIS satellite data and other models, the RIA analysis compares 2022 crop area and 156 production (by crop type and country) predicted to result with and without (i.e., “business as 157 usual”) EISA requirements. The re sults of this analysis are shown in Figures 5-3, 5-4, 5-5, and 158Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE 5-6 and in Table 5-6. In Figures 5-3, 5-4, 5-5, and 5-6, each column shows the marginal impact 159 of a scenario that focuses on that particular feedstock in isolation. 160

The model forecasts that, by 2022, for every increase of 1,000 gallons of corn starch 161 ethanol production in the U.S., corn exports will have decreased by 4 tons. Similarly, for every 162 increase of 1,000 gallons of soybean-based biodiesel produced domestically, soybean oil exports 163 will have decreased by just over 2 tons (see Figure 5-3) (U.S. EPA, 2010b). Thus, as the U.S. 164 increases domestic production of corn starch ethanol and soybean diesel, exports of corn and 165 soybean for agricultural or other uses are expected to decline, which may result in indirect land 166 use change in the form of land conversion to agriculture in other countries. This result is 167 consistent with the results of a 2009 study, which predicted that due to production increases 168 required by EISA, U.S. coarse grain exports wi ll decrease to all destinations and this will cause 169 dominant export competitors and trading partners , likely in Latin America, China, and the Pacific 170 Rim , to convert more of their lands to make up the difference (Hertel et al., 2010; Keeney and 171 Hertel, 2009). However, given that RFS2 limits the amount of corn starch ethanol that can be 172 counted toward the mandated volume targets at 15 billion gallons ─a level the U.S. is expected to 173 reach by 2015 or sooner (GAO, 2007; U.S. EPA, 2010b), indirect land use chang e impacts 174 resulting from changing trade patterns of corn and other grains may level off at that point. In 175 fact, U.S. biofuel consumption could decrease pressure on conversion of land to agricultural use 176 if agricultural yield improvements occur or if cellul osic technologies develop to replace 177 conventional ethanol production. 178

179

Source: U.S. EPA, 2010b. 180

Figure 5 -3: Change in U.S. Exports by Crop Anticipated to Result from EISA 181 Requirements by 2022 (tons per 1,000 gallons of renewable fuel) 182Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE The model also predicts that the additional biofuel produced to meet the EISA mandates 183 compared to “business as usual” (2.7 billion gallons of corn starch ethanol, 7.9 billion gallons of 184 switchgrass cellulosic ethanol, 1.6 billion gallons of imported sugarcane ethanol, and 0.5 billion 185 gallons of soybean biodiesel) will lead to the creation of 2 million acres, 3.4 million acres, 1.1 186 million acres, and 1.7 million acres, respectively, of additional international cropland (see Table 187 5-6) to supply U.S. biofuel imports and also to make up for the U.S. reductions in exports shown 188 in Figure 5 -3 (U.S. EPA, 2010b). 189

Table 5

- 6 : Changes in International Crop Area Harvested by Renewable Fuel Anticipated to Result from EISA Requirements by 2022

Feedstock’s Marginal Effect Considered International Crop Area Change (000s acres) Normalized Crop Area Change (acre / billion BTU) Corn Ethanol 1,950 9.74 Soy

- Based Biodiesel 1,675 26.32 Sugarcane Ethanol 1,063 10.82 Switchgrass Ethanol 3,356 5.56
Source: U.S. EPA, 2010b. 190 Note: Figures converted from hectare to acre 191
Further, these direct and indirect land use changes will lead to significant GHG emissions 192 according to the model (before accounting for GHG savings resulting from petroleum displaced 193 as the biofuel is consumed). Figure 5-4 shows that, based on the model presented in the RIA, 194
soy

- based biodiesel causes the largest release of international land use change GHG 195 emissions. The majority of international land use change emissions originate in Brazil in the corn 196 ethanol and switchgra ss ethanol scenarios. This is largely a consequence of projected pasture 197 expansion in Brazil, and especially in the Amazon region where land clearing cau ses substantial 198

199 Source: U.S. EPA, 2010b. 200

Figure 5 -4: International L and U se C hange GHG E missions by R enewable F uel 201 Anticipated to Result from EISA Requirements by 2022 (kgCO2e/mmBTU) 202Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE Source: U.S. EPA, 2010b. 228 229

F igure 5 -5: Harvested Crop Area Changes by Region Anticipated to Result from EISA Requirements by 2022 , 2022 (ha / billion BTU) 230 231 GHG emissions. Of the renewable fuels analyzed, the model found that sugarcane ethanol causes 203 204 205 206 207

208 209 210 211 212 213 214 215 216 217 218 219 220 221 222 223 224 225 226 227 the least amount of land use change emissions. This was due largely to the EPA projection that sugarcane crops would expand onto grasslands in South and Southeast Brazil, which results in a net sequestration because sugarcane sequesters more biomass carbon than the grasslands it would replace.

The GHG emissions shown above can be seen as an international “carbon debt” (Fargione et al., 2008). C learing forested areas or pasture land for new cropland creates this carbon debt in which microbial decomposition of organic carbon stored in plant biomass (e.g. branches, leaves , and fine roots) and soils leads to a prolonged period of GHG emissions . As described in the RIA, the location of land use change is a critical factor determining the GHG impacts of land use change, because these impacts will vary substantially by region (U.S. EPA, 2010b ). The conversion of higher carbon-storing types of land such as tropical rainforest will lead to more carbon emissions (U.S. EPA, 2010b). A 2008 study forecasted that land conversion of natural ecosystems to cropland would release an estimated 17 to 420 t imes as much carbon dioxide as the biofuels themselves can reduce per year by displacing petroleum fuel (Fargione et al., 2008). Therefore, biofuel consumption may take many years to “pay down” the carbon debt created from production through the GHG savings from displaced petroleum. On the other hand, biofuel made from more sustainable grasses or woody crops using higher- yield cellulosic technologies, or from waste biomass or biomass grown on degraded and abandoned agricultural lands results in much smaller carbon debts and is more likely to lead to overall GHG reductions (Fargione et al., 2008). Figure 5 -5 shows forecasted crop area changes by region, with the heaviest impacts occurring in Brazil. It should be noted that the FAPRI-CARD model does not predict what type cropland will emerge in foreign countries if land use change does occur. This is an important source of uncertainty as GHG and other environmental impacts could vary significantly depending on what crops are grown to offset decreasing U.S. agricultural exports.Chapter 5: International Consider ations

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— DO NOT CITE OR QUOTE Because Brazil will likely be a major supplier of U.S. ethanol, it is informative to consider land use changes there. Brazil face s challenges of multiple forms of land use change, both direct and indirect. Land use changes would occur as Brazil increases ethanol production by converting more land previously used to grow other agricultural goods or pasture lands to grow sugarcane. A s pasture lands are converted to sugarcane production, ranchers are pressured to “intensify” livestock on smaller portions of land or clear more land (possibly Amazon rainforest or Cerrado woodland ) (Bustamante et al., 2009). Figures 5 -4 and 5- 6 isolate the impacts on Brazil alone. The data presented in Figure 5 -6 appear consistent with the prediction that pasture land will decrease in Brazil, while increasing in the rest of the world. However, it is unclear if this will result in rainforest loss or simply mean a greater number of livestock per acre. There are di

and

ffe

w rin

h

g opinions on the result of this tradeoff and it is not possible at this time to predict with any cert at its ainty w

env hat ir t

o y

nm pe o ental

f lan d use change will resul t from increased U.S. demand for biofuel consequences will be (Fargione et al., 2008; Goldemberg et al., 2008; Searchinger et al., 2008). A r ecent study ( Fabiosa et al ., 2010) suggests that sugarcane

based ethanol production in Br azil has less significant impact on existing arable land allocation than corn-based ethanol expansion in the United States . Fabiosa also notes that increasing corn starch -based ethanol to 15 billion gallons in the U.S. would increase corn crop area in th e United States by nearly 13 percent (corn crop area in Argentina and Brazil would increase by 9.5 and 4.5 percent , respectively). 232 233 234 235 236 237 238 239 240 241 242 243 244 245 246 247 248 249 250

Source: U.S. EPA, 2010b. 251 252

Figure 5 -6 : Pasture Area Changes in Brazil by Renewable Fuel Anticipated to Result from EISA Requi rements by 2022 (ha / billion BTU)

5.4 Other Environmental Impacts

While production of biofuel feedstocks places only one of many demands on water, fertilizer, and other inputs, its impacts will increase as its production increases. It has been suggested that, because biofuel production requires approximately 70 to 400 times as much water 253 254

256 257 258 255Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE as other energy sources such as fossil fuels, wind, and solar, an increase in biofuel crop 259 production could further strain global supplies of water (Gerbens-Leenes et al., 2008). Studies 260 have shown that water tables are already declining in the western United States , North India, 261 Pakistan, North China, Mexico, and the Mediterranean (Shah et al., 2007). These trends indicate 262 the vulnerability of various regions to water scarcity issues. T he choice of feedstock, cultivation 263 practices , and the location of cultivation will greatly influence how production of biofuel impacts 264 water availability. 265

Water quality and flooding issues are also relevant. As described in Chapter 3, U.S. corn 266 production has been a key driver of hypoxia in the Gulf of Mexico. Similar water quality issues 267 could arise or be exacerbated in other countries if agricultural use from feedstock production 268 expands. Conversion of land to feedstock production will have varying impacts, depending on 269 prior ecological function of the converted land and the types of management practices employed. 270 Impacts could include encroachment on wetlands and the discharge of excess nutrients to water 271 resources. For example, Brazilian surface waters suffered from hypoxia during the early stages 272 of their biofuel development when the vinasse, a by-product of the sugarcane-ethanol production 273 process rich in nitrogen and potassium, was routinely discarded into rivers, lakes, and reservoirs, 274

caus ing extensive eutrophication (Simpson et al., 2009). Brazilian federal law has prohibited the 275 dumping of vinasse into any water body since 1978. The effluent is now returned to the field as 276 fertilizer, and water quality has improved significantly. However, if other developing countries 277 opt to produce biofuel and do not properly regulate water quality impacts, eutrophication could 278 damage these nations’ aquatic ecosystems. Also, if biofuel

- related land use change does occur 279 and if it results in deforestation and loss of wetlands, then increased flooding, sedimentation, and 280 lower stream base flow s are also likely to occur. Examples of this have already been seen around 281 the world. For instance, in Southeast Asia, tropical peat swamps have been degraded because of 282 loss of forest cover due to logging for timber and conversion of forests to oil- palm plantations for 283 biofuel (Wösten et al., 2006). However, biofuel production was not the only cause of land 284 conversion, and it is possible that food-related demands for palm oil would have caused similar 285 deforestation. 286

Biofuel production also affects international air quality. While the displacement of 287 petroleum fuels by biofuels does have a positive impact, the air quality issues associated with 288 biofuel feedstock harvesting, refining, and transport could erode these savings if poor 289 management practices are allowed to occur. For instance, the practice of burning sugarcane 290 fields prior to harvesting is a serio us air pollution issue in Brazil. This method has resulted in 291 large aerosol and trace gas emissions, significant effects on the composition and acidity of 292 rainwater over large areas of southern regions, and elevated ozone levels in those areas affected 293 by the burning. However, harvest burning practices are being phased out in Brazil through state 294 regulations. In 2007, state laws ensured that 40 percent of the sugarcane was harvested without 295 burning in the state of Sao Paulo, and this is forecast to reach 50 percent by 2010 and about 90 296 percent by 2022 (Goldemberg et al., 2008; U.S. EPA, 2010b). Like many of the effects discussed 297 so far, the severity of air emissions will be highly sensitive to the feedstock chosen, location of 298 production, and management prac tices. 299

Finally, if increased biofuel consumption in the U.S. does lead to indirect land use 300 changes and more natural habitat is cleared to create agricultural lands, a loss of biodiversity will 301 occur. Many biofuel production regions coincide with areas with high biodiversity value. For 302Chapter 5: International Considerations

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— DO NOT CITE OR QUOTE example, Indonesia (palm oil), Malaysia (palm oil), and Brazil (sugar ethanol) all contain 303 ecosystems with well above average biodiversity. Depending where biofuel feedstock production 304 occurs, and the manner in which it occurs, impacts to biodiversity could be signif icant. 305

5.5

Projections indicate that the EISA biofuel targets will likely alter U.S. and international 307 trade patterns. How countries respond to U.S. market conditions could affect net GHG savings 308 der ived from biofuel consumption and the environmental impacts that result from biofuel 309 production. As with biofuel production in the U.S., these impacts will depend largely on where 310 the crops are grown and what agricultural practices are used to grow them. T o the extent that 311 local environmental impacts will have broader implications, such as contributing to global 312 warming, global mitigation strategies will have to consider the international implications of 313 biofuel production. Decisi ons made about what feedstocks to use, where to produce them, and 314 what production methods to employ will have significant environme ntal and economic 315 implications. 316 Concluding Remarks 306

317Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE 6. C ONCLUSIONS AND R ECOMMENDATIONS 1

6.1

A variety of factors make it difficult to draw conclusions about the potential 3 environmental and resource conservation impacts of the increased biofuel production and use 4 mandated by the Energy Independence and Security Act. Of the six feedstocks discussed in this 5 Report, only corn starch and soybean have been implemented at commercial scale to produce 6 ethanol and biodiesel, respectively . Production of biofuel from the other four feedstocks 7 discussed in this report is in various stages of research and development. Even for corn starch 8 and soybean, data needed to perform a thorough environmental life cycle assessment are 9 incomplete and the relevant available data often have a high degree of uncertainty. Nevertheless, 10 initial conclusions can be drawn about how increased biofuel production and use likely will 11 affect (or is affecting, in the case of corn starch and soybean) water quality and quantity, soil and 12 air quality, and ecosystems (biodiversity and invasive species) based on the data available as of 13 July 2 010. These conclusions are presented below for the full greenhouse gas (GHG biofuel life 14 cycle (Section 6.1.1) and for stages in the life cycle: feedstock production (Section 6.1.2); biofuel 15 production, transport, and storage (Section 6.1.3); and biofuel end use (Section 6.1.4). (See 16 Figure 2 -3 in Chapter 2 for life cycle description.) These c onclusions do not account for existing 17 or potential future mitigation measures or regulations. 18 Conclusions

2

6.1.1 Emissions Reduction 19

Fuel combustion at ethanol and biodiesel facili ties releases GHGs. However, when the 20 entire biofuel life cycle is considered (as described in Chapter 4, Section 4.3.2.3), the revisions to 21 the Renewable Fuel Standard (RFS2) program mandated by the Energy Independence and 22 Security Act ( EISA ) are expected to achieve a 138

- million metric ton reduction in CO 2 - 23 equivalent emissions by 2022. 24

6.1.2 Feedstock Production 25

6.1.2.1 Overview 26

Figure 6 -1 provides a qualitative overview, based on EPA’s best professional judgment, 27 of the maximum potential range of domestic environmental and resource conservation impacts 28 associated with per unit area production of the six feedstocks discussed in this Report. 29 Qualitative assessment is grounded in information and data published in the peer- reviewed 30 literature through July 2010, which are described in Chapter 3. Range extremes for each impact 31 category were determined by considering plausible conditions under which a “most negative” 32 and “most positive” environmental impact would likely arise. Key assumptions for these 33 conditions appear in Fi gure 6 -1; for full, detailed elaboration of the conditions, which encompass 34 a variety of factors, including land use, feedstock production management choices, region, 35 technology used, regulatory control

, and mitigati on measures, see Appendix C, Table C-1. 36Chapter 6: Conclusions and Recommendations

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Magnitude Certainty (length of bar) Negative effects Negligible effect Positive effects (shading)
Relatively large Least certain

Moderate Moderately certain Relatively minor Most certain Type of Effects Legend

38
Figure 6 -1: Maximum Potential Range of Environmental Impacts (on a P er U nit A rea 39 B asis) Resulting from Cultivation and Harvesting of the Six B iofuel F eedstocks 40 C onsidered in T his R eport 41 Water Quality (3.2.2) Conventionally managed corn replaces CRP Diversion of existing corn production to fuel Water Quantity (3.2.3) Irrigated (irr.) corn replaces non-irr. land Production of non-irr. corn

Soil Quality (3.2.4) Conventionally managed corn replaces CRP Diversion of existing corn production to fuel Air Quality (3.2.5) Irrigated corn replaces non-irrigated land Diversion of existing corn production to fuel Biodiversity (3.2.6.1) Conventionally managed corn replaces CRP Diversion of existing corn production to fuel Invasiveness (3.2.6.2) Water Quality (3.2.2) Soy replaces CRP Soy replaces corn Water Quantity (3.2.3) Irr. soy replaces non-irr. land Non-irr. soy replaces irr. corn Soil Quality (3.2.4) Soy replaces CRP Soy replaces corn Air Quality (3.2.5) Irr. soy replaces non-irr. land Non-irr. soy replaces irr. corn Biodiversity (3.2.6.1) Soy replaces CRP Soy replaces corn
Invasiveness (3.2.6.2) Water Quality (3.2.2) High removal on erodible land Site-specific removal to minimize erosion Water Quantity (3.2.3) High removal on irr. land Site-specific removal to minimize need for irrigation Soil Quality (3.2.4) High removal on erodible land Site-specific removal to minimize erosion Air Quality (3.2.5) Extra harvesting pass required Single-pass harvest with grain
Biodiversity (3.2.6.1) High removal on erodible land Site-specific removal to minimize erosion Invasiveness (3.2.6.2) Water Quality (3.4.2) Short interval woody crop replaces mature plantation Long interval woody crop replaces short interval plantation Water Quantity (3.4.3) SRWC that is irrigated Thinning or non-irr. woody crop
Soil Quality (3.4.4) Short interval woody crop replaces mature plantation Long interval woody crop replaces short interval plantation Air Quality (3.4.5) See "Water Quality" + woody crop emits isoprene See "Water Quality" + woody crop with low isoprene emissions Biodiversity (3.4.6.1) Short interval woody crop replaces mature plantation Long interval woody crop replaces short interval plantation
Invasiveness (3.4.6.2) Woody crop (ex. Eucaluptus ) invades Non-invasive woody crop used

Water Quality (3.3.2) Conventionally managed grass replaces CRP Conservation managed grass replaces conventional corn Water Quantity (3.3.3) Irr. grass replaces non-irr. land use Non-irr. grass replaces irr. corn

Soil Quality (3.3.4) Conventionally managed grass replaces CRP Conservation managed grass replaces conventional corn Air Quality (3.3.5) Irr. grass replaces non-irr. land use Conservation managed, non-irr. grass replaces irr. corn Biodiversity (3.3.6.1) Uniformly managed grass replaces CRP Diversely managed grass replaces conventional corn Invasiveness (3.3.6.2) Non-native grasses invade Non-invasive grasses used Water Quality (3.5.2) Untreated effluent is discharged Grown with wastewater
Water Quantity (3.5.3) Freshwater, open pond in dry region Recycled wastewater, closed bioreactor Soil Quality (3.5.4) Air Quality (3.5.5) Manufactured nutrients added Wastewater nutrients used Biodiversity (3.5.6.1)

Invasiveness (3.5.6.2) Algae in open ponds invade Non-invasive algae in closed bioreactors Maximum Potential Negative Environmental Impact

Negligible known impact

Negligible known impact

1 Bars are conditioned on key assumptions described briefly here and fully elaborated in Appendix C, Table C-1. Negligible known impact

Negligible known impact Impact Category (Report Section) Key Assumptions 1

Maximum Potential Positive Environmental Impact

Negligible known impact Maximum Potential Range of Environmental Impacts per Unit Area 1Corn (Starch)Corn StoverWoody BiomassPerennial GrassesAlgaeSoybeanChapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE Impacts shown in this figure are only relative to each other. No a ttempt has been made to 42 compare impacts to those of petroleum production, nor do impacts represent possible 43 environmental benefits gained by petroleum displacement. In addition, impacts are only relevant 44 for those regions where each feedstock is likely to be grown (see Chapter 3). Impacts for corn 45 stover do not include the impacts of corn production itself but rather impacts of stover removal 46 above and beyond corn cultivation and harvest. Air quality impacts do not include changes in 47 GHG emissions. 48

Bar d ire ction signifies whether the effect is negative (left) or positive (right). Bar length 49 indicates the anticipated magnitude of effect, and shading density depicts the associated degree 50 of certainty. A circle signifies that no net effect is anticipated. Secti on numbers next to the 51 impact category indicate where in this Report the information that provides the basis for the bars 52 in this figure can be found. 53

When the potential range of production conditions is considered, four feedstocks 54 (soybean, woody biomass, perennial grasses, and algae) are anticipated to have both negative and 55 positive environmental impacts. The most positive environmental outcome for corn starch and 56 corn stover is no net effect, achieved largely through minimization of land use change and 57 through site-specific agricultural management, including comprehensive conservation practices. 58 Most feedstocks (corn starch, soybean, corn stover, woody biomass, and perennial grasses) have 59 the potential to have impacts in at least five of the six environm ental categories shown in the 60 figure; algae are anticipated to have impacts in only four of the categories (water quality, water 61 quantity, air quality and invasiveness). A higher degree of certainty is associated with the two 62 feedstocks that are already co mmercially produced (corn starch and soybean) than with those in 63 development (corn stover, woody biomass, perennia l grasses, and algae). 64

6.1.2.2 Conclusions 65

Key conclusions concerning environmental impacts of biofuel feedstock cultivation are 66 as follows: 67

Water Quality

. Increased cultivation of feedstocks for biofuel may a ffect water quality 68 and hypoxia conditions in the Gulf of Mexico and other vulnerable water bodies through 69 increased erosion and runoff and leaching of fertilizers and pesticides to ground and s urface 70
waters. Cellulosic feedstocks may have less water quality impact than corn starch and corn 71 stover due to projected decreased fertilizer use and decreased soil erosion. Comprehensive 72 management systems and practices are one tool that may mitigate som e of these impacts if they 73 are widely and effectively implemented. Compared to corn and soybeans, cultivation of some 74 cellulosic feedstocks may provide benefits, including soil stabilization , reduc ed soil erosion and 75 nutrient runoff, and increas ed nutrient filtration

. 76

Water Quantity

. Effects of feedstock production on water availability vary greatly by 77 feedstock, processes used to produce the feedstock, and location. Corn and soybean cultivation 78 for biofuel production have a greater water demand than perennial grasses, woody biomass, and 79 algae . Regional differences are mostly due to precipitation which, when insufficient, necessitates 80 supplemental irrigation, which can be a significant water use in the biofuel production process. 81 In irrigated regions, the method and efficiency of irrigation can also affect the amount of water 82Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE used. For both corn and soybeans, the source for irrigation water varies from region to region, 83 potentially affecting water tables and/or surface waters. R emoval of corn stover can reduc e soil 84 moisture , resulting in a need for increase d irrigation. Water quantity effects may be mitigated by 85 growing fe edstocks in areas that do not require irrigation and by using efficient irrigation 86 practices, such as reclaimed water use. 87

Soil Quality

. Increased cultivation of corn, soybean, woody biomass, and perennial 88
grasses will affect soil quality in various ways, depending on the feedstock . Effects include 89 increased soil erosion, decreased soil organic matter content, increased soil GHG emissions, and 90 increased nitrogen and phosphorus losses to ground and surface waters. Annual crops, such as 91 soybean and corn, will have higher erosion rates than non- row crops , such as perennial grasses 92 and woody biomass. However, cultivation of corn or soybean at hi gher rates (i.e., greater yield 93 per acre) on existing corn or soybean acreage likely will not alter soil erosion rates significantly

. 94 Soil quality impacts from biofuel feedstocks may be ameliorated by the choice of feedstock and 95 by the diligent use of gene rally a ccepted conservation practices. 96

Air Quality

. Activities associated with g rowing biofuel feedstocks emit air pollutants, 97 which affect air quality, with effects vary ing by region. Production of row crops will affect air 98 quality more than non- row crops . Pollutants from row crops include farm equipment emissions 99 and s oil and related dust particles (e.g., fertilizer, pesticide, and manure) made airborne as a 100 result of field tillage and fertilizer application , especially in drier areas of the country. 101

Biodiversity

. Increased cultivation of corn and soy feedstocks could significantly affect 102 biodiversity (1) through habitat alteration when uncultivated land is moved into production, and 103 (2) from exposure of flora and fauna to high pesticides concentration s. Aquatic habitat may be 104 impaired by soil erosion and nutrient runoff. Biodiversity impacts can be mitigated by choosing 105 crop and cultivation methods that minimize habitat alteration and runoff. 106

Invasive ness. Corn and soybean pose little risk of becoming weedy or invasive in the 107 U.S . I n certain regions, some perennial grasses, short-rotation woody crops, and algae strains 108 pose greater, though uncertain, risk of becoming an agricultural weed or invasive in natural 109 areas. Transport of grass and short

- rotatio n woody crop seeds and plant parts capable of 110 vegetative reproduction from the field to biofuel production facilities may increase the 111 opportunity for seeds and plant parts capable of vegetative reproduction to establish themselves 112 in feral populations along transportation corridors. Algae produced in photo- bioreactors are less 113 likely to become invasive than algae produced in open ponds. 114

6.1.3 Biofuel Production, Transport, and Storage 115

As described below, biofuel production, transport, and storage can impact water quality, 116
water quantity, and air quality. 117

6.1.3.1 Overview 118

Figure 6 -2 provides a qualitative overview, based on EPA’s best professional judgment, 119 of the maximum potential range of domestic environmental and resource conservation impacts 120 associated with per unit volume production, transport, and storage of ethanol from corn and 121 cellulosic feedstocks and biodiesel from soybean (though biodiesel from algae should not be 122Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE appreciably different) . Qualitative assessment is grounded in information and data published in 123 the peer -reviewed literature through July 2010, which are described in Chapter 4. As with Figure 124 6- 1, range extremes for each impact category were determined by considering plausible 125 conditions under which a “most negative” and “most positive” environmenta l impact would 126 likely arise. Key assumptions for these conditions appear in Figure 6-2; for full, detailed 127 elaboration of the conditions, which encompass a variety of factors, including region, technology 128 used, regulatory control

, and mitigati on measures, see Appendix C, Table C-2. 129

Impacts shown in this figure are only relative to each other. No attempt has been made to 130 compare impacts to those of petroleum production, nor do impacts represent possible 131 environmental benefits gained by petroleum displacement. 132

Bar conventions used in Figure 6-1 are the same as those used in Figure 6-2. 133

As Figure 6 -2 illustrates, the environmental impacts of biofuel production, transport, and 134 storage are expected to be largely negative (see Chapter 4 for more details). However , for all 135 three fuel types, impacts can be minimized through appropriate facility siting, waste treatment

, 136 and improved, more efficient technology. 137

Water Quality. Pollutants in the w astewater discharge d from biofuel production impact 138 water quality. Biological oxygen demand (BOD), brine, ammonia

- nitrogen , and phosphorus are 139 primary pollutants of concern from ethanol facilities . BOD, total suspended solids, and glycerin 140 pose the major water quality concerns in biodiesel facility effluent. Actual impacts depen d on a 141 range of factors, including the type of feedstock processed , biorefinery technology, effluent 142 controls, and water re- use/recycling practices, as well as the facility location and source and 143 receiving water. 144

Water Quantity. Biofuel production facilities draw on local water supplies to produce 145 fuel, but the quantity of water used is modest compared to that required to produce biofuel 146 feedstocks. I mpacts will depend on the location of the facility in relation to wa ter resources. 147 Water availability issues can be mitigated by siting production facilities where water is abundant. 148

Air Quality

. Emissions from biofuel production facilities are generated primarily by the 149 stationary combustion equipment used for energy production. Compared to two scenarios ([1] 150 the original renewable fuel standard of 7.5 billion gallons, and [2] a 2022 renewable fuel volume 151 of 13.6 billion gallons projected by the Department of Energy’s 2007Annual Energy Outlook ), 152 RFS2

- mandated increased biofuel production will likely result in decreased emissions of carbon 153 monoxide and benzene, and increased emission s of nitrogen oxides, volatile organic compounds, 154 particulate matter, and several air toxics . Since biofuel production facilities are regulated under 155 the Clean Air Act and subject to state/local permits, enforcement of existing regulations will 156 mitigate air quality impacts . Emissions can be further reduced through use of cleaner fuels (e.g., 157 natural gas instead o f coal) and more efficient proc ess and energy generation equipment

. 158Chapter 6: Conclusions and Recommendations

159 160

161 Impact Category (Report section)

Water Quality (4.4.2, 4.6.2) High BOD effluent; DDG byproduct fed to livestock with poor waste management; underground storage tanks (USTs) leak Effluent treated; DDG-fed livestock waste managed; USTs do not leak

Water Quantity (4.3.3) 3-6 gallons water/gallon ethanol Improved water use efficiency

Air Quality 3 (4.3.2, 4.4.1, 4.5.1, 4.6.1) Ethanol facility coal-powered Ethanol facility natural gaspowered

Water Quality (4.4.2, 4.6.2) High BOD, total suspended solids (TSS), glycerin effluent Effluent treated

Water Quantity (4.3.3) <1 gallon water/gallon biodiesel <1 gallon water/gallon biodiesel

Air Quality 3 (4.3.2, 4.4.1, 4.5.1, 4.6.1) Biodiesel facility coal-powered Biodiesel facility natural gaspowered

Water Quality (4.4.2, 4.6.2) High BOD effluent; USTs leak Effluent treated; USTs do not leak

Water Quantity (4.3.3) 10 gallons of water/gallon cellulosic ethanol Improved water use efficiency

Air Quality 3 (4.3.2, 4.4.1, 4.5.1, 4.6.1) Ethanol facility coal-powered Ethanol facility natural gaspowered

2 Comparisons are made on the basis of equal volumes of the biofuels indicated.

3 Impacts shown are immediate impacts from biofuel production to end use. No attempt is made in this table to represent air quality impacts based on displaced gasoline emissions. See Section 4.5 for more information. Key Assumptions 1

Maximum Potential Negative Environmental Impact Maximum Potential Positive Environmental Impact

1 Bars are conditioned on key assumptions described briefly here and fully elaborated in Appendix C, Table C-2.CornEthanolCellulosicEthanolSoybeanBiodiesel Maximum Potential Range of Environmental Impacts per Unit
Volume 1,2

Legend

Magnitude Certainty (length of bar) Negative effects Negligible effect Positive effects (shading)
Relatively large Least certain

Moderate Moderately certain Relatively minor Most certain Type of Effects

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Fi gure 6-2: Maximum Potential Range of Environmental Impacts (on a P er U nit V olume 162 B asis) Resulting from E thanol and B iodiesel Production, Transport, and Storage 163Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE 6.1.3.2 Biofuel Transport and Storage 164

Biofuel transport and storage may impact water and air quality. 165

Water Quality. Leaks and spills of biofuel from above-ground, underground, and 166 transport tanks can potentially contaminate ground, surface, and drinking water. A leaking 167 underground storage t ank can also present other health and environmental risks, including the 168 potential for fire and explosion. Enforcement of existing regulations concerning corrosion 169 protection, leak detection, and spill and overfill prevention will minimize water contaminat ion. 170 S election and use of appropriate materials and proper design in accordance with the applicable 171 material standards will also prevent biofuel leaks. 172

Air Quality

. Air quality will be affected by emissions from biofuel transport via rail, 173 barge and tank truck and by evaporative, spillage, and permeation emissions from transfer and 174 storage activ ities. However, the impacts are not expected to be significant. 175

6.1.4 Biofuel End Use 176

Air Quality

. Evaporative and tailpipe emissions from biofuel combustion show great 177 variability due to a range of factors, including the vehicle age, how the vehicle is operated, and 178 ambient temperatures. Emissions in 2022 are expected to be higher for some pollutants and 179 lower for others compared to two scenarios (described in 6.1.3.1). In general, biodiesel 180 combustion has been shown to decrease particulate matter , carbon monoxide, and hydrocarbon 181 emissions, increase nitrogen oxide emissions , and increase ozone-forming potential compared to 182 fossil fuel diesel. Emissions from ethanol use are independent of feedstock; in contrast, 183 emissions from biodiesel use differ according to the feedstock. Particulate matter, nitrous oxide, 184 and carbon monoxide emissions are higher for plant-based biodiesel than for animal- based 185 biodiesel. 186

6.1.5 International C onsiderations 187

Increases in U.S. biofuel production and consumption volumes will affect many different 188 countries as trade patterns and prices adjust to equate global supply and demand. This will result 189 in environmental impacts, both positive and negative, i ncluding effects from land use change and 190 effects on air quality, water quality, and biodiversity. Direct and indirect land use changes will 191 likely occur across the globe as the U.S. and other biofuel feedstock-producing countries alter 192 their agricultural sectors to allow for greater biofuel production. Many locations where biofuel 193 production is growing are areas of high biodiversity value. For example, Indonesia (palm oil), 194 Malaysia (palm oil), and Brazil (sugar ethanol) all contain ecosystems with well

- ab ove- average 195 biodiversity. Depending where biofuel feedstock production occurs, impacts to biodiversity 196 could be significant. Particularly in Malaysia and Indonesia , which have already lost 197 considerable forest cover due to their large timber industries, expansion of palm oil plantations 198 for biodiesel could potentially compound impacts on natural resources. However, because corn 199 ethanol, the biofuel with the greatest potential for international impact in terms of trade pattern 200 changes, is limited by the RFS2 and is likely to reach this limit in the next few years, these 201 international impacts could level off as corn starch ethanol production levels off or is replaced by 202 more advanced technologies. 203Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE As with domestic production, the choice of feedstock, how and wh ere it is grown, the 204 resulting land -use changes, and how it is produced and transported will have a large effect on 205 how biofuel production and use affects water quality and availability , air quality (e.g. due to 206 emissions from burning crop residue), and bi odiversity. The specific impacts will reflect a 207 country’s particular circumstances. 208

6.2

EISA Section 204 specifies that EPA include recommendations for actions to address any 210 adverse impacts identified in this report. Responding specifically to this request requires a clear 211 understanding of biofuel impacts and their causes. Impacts from corn starch and soybean 212 production are relatively well understood, however, more information is needed about the 213 adverse impacts associated with production of other feedstocks and with the production and use 214 of advanced biofuel. This section presents four recommendations to address adverse impacts. 215 Because biofuel impacts cross multiple topics and EPA responsibilities, EPA likely will address 216 these recommendations through continued and strengthened cooperation with other federal 217 agencies and international partners. 218 Recommendations 209

6.2.1 Comprehensive Environmental Assessment 219

The biofuel industry is poised for significant expansion in the next few years. A variety 220 of new technologies likely will be implemented and old technologies modified to meet the 221 demands of affordable and sustainable petroleum fuel alternatives. As emphasi zed by Congress 222 in requiring triennial biofuel impact assessments, it is important to evaluate the environmental 223 implications associated with the ongoing growth of the dynamic biofuel industry. However, as 224 noted earlier, the inherent complexity and uncertainty of environmental impacts across the 225 biofuel supply chain make it difficult to provide assessments that are sufficiently d efinitive to 226 inform environmental decisions. 227

R ECOMMENDATION : Develop and evaluate environmental l ife c ycle a ssessment s for 228 biofuels. With this Report, EPA and the U.S. Departments of Agriculture and Energy (USDA 229 and DOE) have begun to develop a framework and partnership that provide an important 230 foundation for future assessments. Future assessments will address advanced biofuel production 231 associated with specific feedstock s and associated by -products and provide a comparative 232 context to fossil fuels. As described in Chapter 7, future assessments will be comprehensive and 233 will address the major environmental parameters affec ted by increased biofuel production and 234 use. These assessments will identify gaps and uncertainties in the knowledge base; inform the 235 design and implementation of monitoring strategies and measures for evaluating impacts; 236 provide comprehensive tools for comparing and evaluating development options; and provide the 237 scientific bases for regulatory agencies and the biofuel industry to make environmentally 238 conscious decisions. 239

6.2.2 Coordinated Research 240

The biofuel industry is expected to expand rapidly and broadly. This expansion will be 241 shaped to a large degree by the research behind the technological developments that make 242Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE biofuel production feasible. It will be important for the scientific infrastructure that supports 243 policy and decision-making to keep pace with industry developments. 244

R ECOMMENDATION : Ensure the success of current and future environmental biofuel 245 research through improved cooperation and sustained support. The Biomass Research and 246 Development Board, co-chaired by DOE and USDA, currently monitors in teragency biofuel 247 research cooperation. The Board recently proposed that an inventory be conducted of federal 248 activities and jurisdictions relevant to environmental, health, and safety issues associated with 249 biofuel production in order to identify issues of concern, research needs, and mitigation options. 250 Efforts to adjust and expand existing research programs to conduct biofuel- relevant research 251 have been initiated. Prioritization and collaboration by the research community will be critical to 252 provide mean ingful results in the near term and to meet the wide variety of research needs, 253 including many that have already been identified, that will be important to the industry and to 254 appropriate regulatory oversight. 255

6.2.3 Mitigation of Impacts from Feedstock Productio n 256

As the biofuel industry expands, it will be important to optimize benefits while 257 minimizing adverse impacts . Since many of the known adverse impacts are due to feedstock 258 production, this Report has described the potential for mitigation of those impacts through the 259 adoption of conservation systems and practices on farms. USDA has a variety of programs that 260 help agriculture producers implement these conservation systems. As USDA’s Conservation 261 Effects Assessment Project (CEAP) report on the Upper Mississippi River Basin demonstrates, 262 much more needs to be done to control pollution from agriculture, especially from nitrogen. A 263 collaborative effort is needed to develop and foster application of consistent and effective 264 monitoring and mitigation procedures to protect the environment and conserve biodiversity and 265 natural resources as biofuel production expands and advanced biofuels are commercially 266 produced. 267

R ECOMMENDATION : Improve the ability of federal agencies (within their existing 268 authorities) and industry to develop and implement best management and conservation 269 practices and policies that will avoid or mitigate negative environmental effects from 270 biofuel production and use. These policies and practices should be aligned and assessed within 271 the context of the environmental life cycle assessment and take a multi -factor and multi- scale 272 view of biofuels and their potential environmental effects. Priority areas for development include 273 (1) improved containment processes that minimize environmental exposure from air emissions 274 and runoff into surface and ground water, and (2) methods to monitor, track, and report biofuel 275 environmental impacts

. 276

6.2.4 International Cooperation to Implement Sustainable Biofuel Practices 277

EISA specifically identifies “significant emissions f rom land use change” as a potential 278 environmental impact stemming from domestic biofuel production and consumption. This 279 concern is relevant to all countries engaged in biofuel production, but as the U.S. increases 280 domestic production of corn starch ethanol and soybean diesel, exports of corn and soybean for 281 agricultural or other uses are expected to decline, which may result in indirect land use change in 282 the form of land conversion to agriculture in other countries. Additional biofuel produced to 283Chapter 6: Conclusions and Recommendations

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— DO NOT CITE OR QUOTE meet the EISA mandates will potentially lead to increases in acreages of international cropland, 284 although these increases may level off after 2015 (see Section 5.2). 285

R ECOMMENDATION : Engage the international community in cooperative efforts to 286 identify and implemen t sustainable biofuel practices that minimize environmental impact

. 287 U.S. and international capacity to minimize the consequences of land use change will depend not 288 only the willingness of governments and industry to make environmentally sound choices 289
regar ding biofuel production, processing, and use, but also on the availability of cost- effective 290 mitigation strategies. The U.S. can significantly contribute to such an effort by actively engaging 291 the scientific community and biofuel industry to collaboratively develop the body of knowledge 292 needed to support sound environmental decision- making. This effort will be facilitated by a 293 greater understanding and appreciation of how increased biofuel demand may impact the 294 environment internationally, particularly in c ountries that are most active, or most likely to 295 becom e active in biofuel production. 296Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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7.1

In requiring EPA to report triennially under EISA Section 204, Congress recognized that 3 the environmental and resource conservation impacts of increased biofuel production and use 4 will be dynamic, changing in both nature and scope, based on the amount, type, and location of 5 biofuels produced and used. This first triennial Report to Congress, which reflects the state of 6 scientific knowledge as of July 2010, is a firs t step toward identifying infor mation that supports 7 future assessment of environmental impacts from increased biofuel production and use. 8 Introduction 2

This chapter outlines an approach EPA will use for its futu re assessments, beginning with 9 the 2013 Report to Congress. In developing future assessments, EPA will work closely with the 10 U.S. Departments of Agriculture and Energy (USDA and DOE) and will seek extensive input 11 from industry and other stakeholders and pe er review from the scientific community to create 12 substantive, science- based analyses that facilitate environmental decision

- making. Future 13 assessments will benefit from advances in the science of environmental assessment and increased 14 availability of rele vant research results on this important topic. 15

EPA anticipates that additional research and analyses will allow for more robust and 16 quantitative assessments of biofuel environmental impacts than are reported here. For example, 17 l ife cycle assessment (LCA) tools and approaches that are currently used for evaluating “cradle

18
to -grave” resource consumption and waste disposal for specific products can be integrated into 19 risk assessment to form a powerful composite approach for assessing environmental impacts. An 20 approach to more comprehensive environmental analyses that is consistent with the integration 21 of LCA and risk assessment methods has been used in different assessments (Davis and Thomas, 22 2006; Davis 2007). This approach would necessitate extend ing conside ration of factors across 23 the entire biofuel life cycle , including current and future feedstock production and biofuel 24 conversion, distribution, use. The Agency has already applied LCA to assess greenhouse gas 25 (GHG) emissions as part of its revised Renewabl e Fuel Standard (RFS2) program (U.S. EPA, 26 2010b) and could adapt this approach to analyze other aspects of biofuel production and use, 27 such as water consumption; evaluation of fossil fuels versus biofuels; net energy balance; 28 production and use scenarios; and market impacts (economics). 29

7.2

This section briefly describes key components that EPA plans to utilize in conducting its 31 2013 assessment. Comprehensive environmental assessment (CEA) would provide an organizing 32 framework for evaluating and, where possible quantifying, risk and benefits of biofuel 33 production and use. CEA would integrate LCA, described in Section 7.2.1, and environmental 34 risk assessment, described in Section 7.2.2. The latter could be used to systematically assess 35 environmental risks, both human health (see Section 7.2.3) and ecological, for each stage in the 36 life cycle and potentially cumulative impacts. Conceptual models (Section 7.2.4) will illustrate 37 the important factors being considered in each stage of the life cycle and indicate how these 38 factors are interrelated. W here possible, environmental indicators and other metrics (Section 39 7.2.5) will be developed over the next several years to track the impacts of biofuel production 40 and use throughout its life cycle and measure the effectiveness of regulatory and voluntary 41 Components of the 2013 Assessment 30Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE p ractices in ameliorating these impacts. A scenario -based approach (Section 7.2.6) is currently 42 envisioned to provide a comparative basis for projecting and assessing how biofuel production 43 and use will affect the environment in future years. Finally, the 2013 assessment will include 44 other components, such as a comparison to fossil fuels, net energy balance, and analysis of 45 market impacts (Section 7.2.7), that are important to evaluating biofuel impacts. 46

7.2.1 Life Cycle Assessments 47

LCAs have been widely used to assess the potential and pitfalls for bio

- ethanol as a 48 transportation fuel (von Blottnitz and Curran, 2007). The majority of such analyses have focused 49 on particular components such as GHG emissions and energy balances (Hill, 2009), with varied 50 results based on the assumptions and input parameters used to drive assessments. In some cases, 51 the scientific community seems close to reconciling the various assumptions used by different 52 investigators (Anex and Lifset, 2009). To better address the EISA reporting mandate, however, a 53 broader profile of potential environmental impacts should be considered. This approach has been 54 used in several studies (von Blottnitz and Curran, 2007) and applied to evaluating trade- offs for 55 fuel options (Davis and Thomas, 2006). As part of the 2013 assessment , EPA anticipates 56 utilizing LCA in a broad context, one that considers a full range of potential environmental 57 effects and their magnitude. A variety of environmental LCA approaches have been developed 58 that would prove useful for such an effort (Duncan et al., 2008; Ekvall, 2005; Hill et al., 2006; 59 Puppan, 2002). 60

7.2.2 Environmental Risk Assessment 61

Environmental risk assessment will be fundamental for systematically evaluating the 62 human and environmental impacts of the activities involv ed in biofuel production and use. 63 Environmental risk assessment can be used to estimate the risks associated with each stage of the 64 biofuel life cycle, from production of raw materials through transportation to waste products. 65 Environmental risk assessment is initiated by clearly articulating the problem (i.e., problem 66 formulation), describing the critical factor, pathways, and linkages among these factors, 67 quantifying human/ecological exposure and effects, and subsequently characterizing and 68 estimating the risks associated these effects. Environmental risk assessment will identify which 69 stages in the biofuel life cycle contribute the greatest risk so that more informed risk 70 management practices can be developed and implemented for these stages. 71

7.2.3 Human Healt h Assessment 72

Increasing biofuel use presents the potential for distinct health effects separate from the 73 known impacts of fossil fuels. The fate and transport of these new fuel blends in the environment 74 and the subsequent exposures and human health effects have not been fully studied. Drawing 75 definitive conclusions on health impacts is not realistic at this time, given the unknowns 76 surrounding the feedstocks, technologies, and fuel blends that will be used to meet target 77 volumes, and the relatively limited availability of toxicological data to directly evaluate the 78 potential health effects of the various emissions. 79

Health effects will be assessed in the 2013 report, provided adequate data are available. 80 In examining the health risks and benefits of increased biofuel use, it will be important to 81Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE understand the unique characteristics of the new fuel blends; how and when releases occur; the 82 fate and transport of these releases; the relevant routes and duration of exposures to humans; and 83 the toxic effects of tho se exposures. Both individual and population exposures will be important 84 to consider. For example, populations in regions that both produce and use biofuel will 85 experience different exposures than those in regions that only use the fuel. Individuals within the 86 same region may experience different exposures (i.e., occupational, consumer, or public 87 exposures), and vulnerable populations may be at greater risk of adverse effects, depending on 88 their sensitivity. 89

7.2.4 Conceptual Models 90

A number of tools are available for use in problem formulation, including conceptual 91 diagrams, which hypothesize relationships between activities and impacts. These diagrams can 92 support multiple purposes, including defining system boundaries; enhancing understanding of 93 the system being analyzed; and supporting communication among assessors, between assessors 94 and stakeholders, and, ultimately, with risk managers. 95

The information provided in Chapters 3, 4, and 5 of this 2010 assessment lay a 96 foundation for constructing initial conceptual models to show relationships among biofuel 97 activities and impacts. Figures 7 -1 and 7- 2 present generalized conceptual models for feedstock 98 and biofuel production, respectively. Appendix D provides detailed conceptual diagrams for each 99 of the feedstocks and fuels considered in this Report. Based on the information gathered during 100 this 2010 assessment, the diagrams show the activities (e.g., crop rotation, water use) associated 101 with the model’s domain area and how, through a series of relationships indicated with lines and 102 arrows, these activities are associated with products and impacts. These diagrams are the first 103 step in mathematically simulating the system and quantifying impacts. Diagra ms such as these 104 will be important tools for assessments in EPA’s future Reports to Congress. 105

7.2.5 Monitoring , Measures , and Indicators 106

EPA’s ability to accurately assess impacts attributable to biofuels production and use will 107 depend on having timely, relevant, and accurate monitoring information that tracks potential 108 impacts, and how effective regulatory and voluntary management practices, risk management 109 practices, and other measures are in protecting the environment. While current environmental 110 monitoring by various agencies can provide helpful information, targeted monitoring for 111 potential biofuel impacts will be needed, requiring a collaborative effort across multiple agencies 112 and other organizations. Indicators and measures will be important for a variety of environmental 113 effects , including GHG emissions, human and ecological health indicators, eutrophication, and 114 many others. These metrics will inform decisions at all levels along the biofuel supply chain and 115 well beyond the scope of the individual decision. 116Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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Figure 7 -1: Conceptual Diagram of the Environmental Impacts of Biofuel 118 Feedstock Production 119Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE 120

Fi gure 7 -2: Conceptual Diagram of the Environmental Impacts of Biofuel 121 Production and Use 122Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE 7.2.6 Scenarios 123

EPA’s 2013 Report to Congress will assess the environmental impacts of all five stages 124 in the biofuel supply chain (Figure 2 -3). One approach may be to create scenarios based on 125 volumetric biofuel requirements for 2022 as presented in the RFS2 (see Table 2 -1). For example: 126

**•** Scenario A: 2022 RFS2- projected feedstock mix produced with comprehensive 127 conservation systems

. 128 129

**•** Scenario B: 2022 RFS2-projected feedstock mix produced with existing levels of 130 conservation practice implementation

. 131 132

**•** Scenario C: 2022 conventional feedstoc k mix (corn starch, corn stover, and 133 soybean) produced with existing levels of conservation practice implementation. 134 135 Figure 7 -3 shows possible impacts in all six impact categories for these three scenarios 136 based on the feedstocks and fuels discussed in this Report. Scenarios are for illustrative purposes 137 only to show the potential rage of environmental impacts given assumptions about feedstock 138 production locations and practices; fuel production, transport, storage, and use patterns and 139 techn ologies; and target volumes (Appendix C, Table C-3). They do not necessarily represent the 140 most likely future developments in biofuel production systems. The magnitude, direction, and 141 certainty of bars (see figure legend) are based on expert interpretation of all available scientific, 142
peer -reviewed literature as of July 2010. Bars are relative to one another and do not reflect a 143 comparison with petroleum-based transportation fuel. Future versions of this Report to Congress 144 will expand and update this assess ment

. 145

As noted earlier, the landscape of feedstock/biofuel production, conversion, and use is 146 highly dynamic and constantly evolving. Which feedstocks and technologies are used and to 147 what extent will be influenced by technological developments and market forces that are difficult 148 to predict. Development of scenarios for future assessments will need to model or otherwise 149 account for key factors that influence the biofuel market dynamics and associated environmental 150 impacts. These factors include: 151

**•** Regional considerations. In general, biofuel conversion facilities will tend to be 152 sited at reasonable distances from feedstock production areas, since cost 153 considerations limit the distance s over which biofuel feedstocks can be 154 transported. Consequently, environmental impacts of both feedstock production 155 and biofuel conversion will tend to be concentrated in particular regions. 156 157

**•** Scale and volume of future commercial biofuel operations. Future development 158 and application of commercially viable biofuel technologies will change the 159 nature of energy feedstocks and conversion processes in use, as well as the scale 160 of their operation. While the continued use of corn starch for ethanol will likely 161 not change, the future profile of feedstocks and biofuels could vary from those 162 used in 2010, but which will actually be used and to what extent is highly 163 uncertain. 164Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

165

166 Impact Category

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

Production Volume Water Quality Water Quantity Soil Quality Air Quality Biodiversity
Invasiveness

1 Bars represent total environmental impacts based on impacts from feedstock production on a per area basis; fuel production, distribution, storage and use on a per volume basis; total volume produced; and assumptions of each scenario fully described in Appendix C, Table C-3. 0.66 BG 0.66 BG 1.0 BG

0.1 BG 0.1 BG 0 BG 0.1 BG 0 BG

7.9 BG 7.9 BG 0 BG 15 BG 15 BG 15 BG

4.9 BG 4.9 BG 16 BG

0.1 BG Sc. B: Envir. impacts from 2022 RFS2 projected feedstock mix produced with minimal conservation/ BMPs and current technologies 1CornStarchCorn StoverWoodyBiomassPerennialGrassAlgae Sc. C: Envir. Impacts from 2022 conventional feedstock mix produced with minimal conservation/ BMPs and current technologies 1Soybean Sc. A: Envir. impacts from 2022 RFS2 projected feedstock mix produced with conservation/ BMPs and efficient technologies 1ConventionalEthanolCellulosic EthanolBiomass-basedDiesel

Legend

Magnitude Certainty (length of bar) Negative effect Negligible net effect Positive effect (shading) Relatively large Least certain

Moderate Moderately certain
Relatively minor Most certain Direction of Effect

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— DO NOT CITE OR QUOTE Fig ure 7-3: Cumulative D omestic Environmental Impacts of A ll S teps in the B iofuel S upply 167 C hain S ystem under T hree Scenarios in 2022 168Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE **•** Hybrid processes. Biofuel conversion processes (e.g., b iochemical and 169 thermochemical processes) may evolve in the future to be hybrid process es that 170 would produce not only biofuel but also synthetic chemicals and other industrial 171

co -products . I ntegrated biorefineries may have the a bility to make use of a 172 biofuel-only or a hybrid conversion platform

. Each new conversion option will 173 present its own range of potential environmental impacts. 174 175

**•** Changes in vehicle technologies. Changes in vehicle technologies, patterns of 176 vehicle sales, an d fueling behavior will be needed to accommodate higher ethanol 177 production volumes. Conversely, changes in vehicle technologies driven by other 178 considerations, such as the development of plug- in hybrid electric or all

- electric 179 vehicles, could change the de mand for liquid biofuels. 180 181

**•** Changes in agricultural practices due to biofuel production and implications for 182 environmental impacts. Recent increases in ethanol production have expanded the 183 market demand for corn grain, and farmers have responded to this in creased 184 demand by changing production practices from corn- soy rotations to corn- corn

185 soy or even continuous corn production . It is not clear what the effects of 186 production shifts, agricultural residue use, and associated farm- level management 187 practice chan ges will be in the short term. 188 189 7.2.7 Other Components 190

In addition to the above components, the 2013 assessment will include a several analyses 191 that provide important perspective for understand and evaluating the impacts of biofuel 192 production and use , as described below. 193

Comparison of Fossil Fuel to Biofuel. While this report provides a starting point for 194 comparing the relative impacts associated with a range of different biofuel feedstock and 195 production processes, it will also be useful to assess biofuel impacts in the larger context of the 196 conventional petroleum fuels that are being displaced under the RFS2 mandates. Ideally, this 197 comparison would cover the full life cycle for each fuel. Such an evaluation will facilitate 198 comprehensive assessment of the relative costs and benefits of RFS2 beyond GHG impacts, and 199 support identification of effective mitiga tion measures for key impacts. This type of evaluation 200 has been recommended by the National Advisory Council for Environmental Policy and 201 Technology as a m eans of conducting integrated environmental decision making (NACEPT 202 2008). Given the limitations of currently available information, a comparative assessment of 203 petroleum fuel and biofuel impacts will be largely qualitative, with significant data gaps and 204 uncertainties. Nevertheless, EPA anticipates that even a qualitative comparative analysis will be 205 an important component of the 2013 assessment. 206

Net Energy Balance. Net energy balance (i.e., the amount of energy used to develop 207 biofuels compared to the energy value derived from biofuels) is an important metric that will be 208 addressed in the 2013 assessment. It enables comparison of biofuel produced from different 209 feedstocks and via different conversion processes, as well as comparison between biofuel and 210 gasoline. The net energy balance will include consideration of energy embedded in co -products 211 of the fuel conversion process. For example, increases in corn ethanol production will increase 212Chapter 7: Assessing Environmental Impacts from Biofuels: 2013 to 2022

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— DO NOT CITE OR QUOTE the amount of co-products used in animal feed, which in turn displ aces whole corn and soybean 213 meal used for the same purpose; the “ displaced ” energy is credited to the ethanol system and 214 offsets some of the energy required for production (Hammerschlag, 2006; Liska et al., 2008). 215

Market Impacts. Biofuels displace fossil energy resources, but also consume petroleum 216 products, natural gas, electricity (much of which comes from nonrenewable energy sources), and 217 even coal at different po ints along their supply chain. Consequently, changes in fossil fuel prices 218 will impact the economics of biofuel pro duction in unpredictable ways. The 2013 assessment 219 will address market impacts and incorporate modeling of coupled energy systems and 220 agricultural markets

. 221Chapter 8: References

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— DO NOT CITE OR QUOTE 8. R EFERENCES 1

Adegbidi, HG; Volk, TA; White, EH; Abrahamson, LP; Briggs, RD; Bickelhaupt, DH. 2001. 2 Biomass and nutrient removal by willow clones in experimental bioenergy plantations in 3 New York state. Biomass and Bioenergy 20(6): 399-411. 4 Advanced Biofuels Task Force. 2008. Advanced Biofuels Task Force report. Commonwealth of 5 Massachusetts. Available at: 6 http://www.mass.gov/Eoeea/docs/eea/biofuels/biofuels_complete.pdf

. 7 Adviento-Borbe, MAA; Haddix, ML; Binder, DL; Walters, DT; Dobermann, A. 2007. Soil 8 greenhouse gas fluxes and global warming potential in four high- yielding maize systems. 9 Global Change Biology 13(9): 1972-1988. 10 Alexander, RB; Smith, RA; Schwarz, GE; Boyer, EW; Nolan, JV; Brakebill, JW. 2008. 11 Differences in phosphorus and nitrogen delivery to the Gulf of Mexico from the 12 Mississippi River Basin. Environmental Science and Technology 42(3): 822-830. 13 Available at: http://pubs.acs.org/cgi14 bin/abstract.cgi/esthag/2008/42/i03/abs/es0716103.html

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. 20 Andow, DA; Zwalen, C. 2006. Assessing environmental risks of transgenic plants. Ecology 21 Letters 9: 196-214. 22 Anex, R; Lifset, R. 2009. Post script to the corn ethanol debate: Reaching consensus. Journal of 23 Industrial Ecology 13(6): 996-998. 24 Angermeier, PL; Karr, JR. 1984. Relationships between woody debris and fish habitat in a small 25 warmwater stream. Transaction of the American Fisheries Society 113(6): 716-726. 26 Antizar -Ladislao, B; Turrion-Gomez, J. 2008. Second-generation biofuels and local bioenergy 27 systems. Biofuels, Bioproducts and Biorefining 2: 455-469. 28 Aqua Terra. 2010. Phase III/IV modeling water quality impacts of corn production for ethanol in 29 the upper Mississippi River basin. U.S. Environmental Protection Agency. 30 Aronsson, PG; Bergstrom, LF; Elowson, SNE. 2000. Long-term influence of intensively cultured 31 short-rotation willow coppice on nitrogen concentrations in ground water. Journal of 32 Environmental Management 58(2): 135-145. 33 ARS (United States Depa rtment of Agriculture, Agricultural Research Service). 2003. 34 Agricultural phosphorus and eutrophication. Second edition. ARS-149. Available at: 35 http://www.sera17.ext.vt.edu/Documents/AG_Phos_Eutro_2.pdf

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. 40 ARS (United States Department of Agriculture, Agricultural Research Service). n.d. FY -2005 41 annual report Manure and Byproduct Utilization National Program 206. Available at: 42 http://www.ars.usda.gov/research/programs/programs.htm?np_code=206&docid=13337

. 43 Artuzi, JP; Contiero, RL. 2006. Herbicidas aplicados na soja e produtividade do milho em 44 sucessão. Pesquisa Agropecuária Brasileira 41: 1119 -1123. 45Chapter 8: References

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— DO NOT CITE OR QUOTE Auer, C. 2008. Ecological risk assessment and regulation for genetically-modified ornamental 46 plants. Critical Reviews in Plant Sciences 27: 255 -271. 47 Aust, WM; Blinn, CR. 2004. Forestry Best Management Practices for timber harvesting and site 48 preparation in the eastern United States: An overview of water quality and productivity 49 research during the past 20 years (1982-2002). Water, Air, and Soil Pollution: Focus 4(1): 50 5-36. 51 Aust, WM; Lea, R; Gregory, JD. 1991. Removal of floodwater sediments by a clearcut tupelo52 cypress wetland. Journal of the American Water Resources Association 27(1): 111-116. 53 Babcock, BA; McPhail, LL. 2009. Corn or soybean for 2009? Iowa Ag Review 15(1). Available 54
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. 55 Baeumler, R; Zech, W. 1998. Soil solution chemistry and impact of forest thinning in mountain 56 forests in the Bavarian Alps. Forest Ecology and Management 108(3): 231-238. 57 Baliga, R; Powers, S. 2010. Sustainable algae biodiesel production in cold climates. International 58 Journal of Chemical Engineering. Available at: 59 http://downloads.hindawi.com/journals/ijce/2010/102179.pdf

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. 62 Barney, JN; DiTomaso, JM. 2008. Nonnative species and bioenergy: Are we cultivating the next 63 invader? Bioscience 58(1): 1-7. 64 Barney, JN; M ann, JJ; Kyser, GB; Blumwald, E; Van Deynze, A; DiTomaso, JM. 2009. 65 Tolerance of switchgrass to extreme soil moisture stress: Ecological implications. Plant 66 Science 177: 724-732. 67 Bartolino, JR; Cunningham, WL. 2003. Ground- water depletion across the nation. USGS Fact 68 Sheet 103-03. U.S. Geological Survey. 69 Bashkin, MA; Binkley, D. 1998. Changes in soil carbon following afforestation in Hawaii. 70 Ecology 79(3): 828-833. 71 Beale, CV; Long, SP. 1997. Seasonal dynamics of nutrient accumulation and partitioning in the 72 perennial C -4-grasses Miscanthus x giganteus and Spartina cynosuroides. Biomass and 73 Bioenergy 12(6): 419-428. 74 Beale, CV; Morison, JIL; Long, SP. 1999. Water use efficiency of C4 perennial grasses in a 75 temperate climate. Agricultural and Forest Meteorology 96: 103-115. 76 Beaty, ER; Engel, JL; Powell, JD. 1978. Tiller development and growth in switchgrass. Journal 77 of Range Management 31(5): 361-365. 78 Bell, GP. 1997. Ecology and management of Arundo donax, and approaches to riparian habitat 79 restoration in Southern California. In: Brock, JH; Wade, M; Pysek, P; Green, D (eds). 80 Plant invasions: Studies from North America and Europe. Backhuys Publishers. pp. 103- 81 113. 82 Bellamy, PE; Croxton, PJ; Heard, MS; Hinsley, SA; Hulmes, L; Hulmes, S; Nuttall, P; Pywell, 83 RF; Rothery, P. 2009. The impact of growing Miscanthus for biomass on farmland bird 84 populations. Biomass and Bioenergy 33: 191-199. 85 Berndes, G. 2002. Bioenergy and water— the implications of large -scale bioenergy production 86 for water use and supply. Global Environmental Change 12: 253-271. Available at: 87 http://www.unep.fr/energy/activities/water/pdf/Reading%20list%20materials_15April201 88 0/Reading%20list%20materials_15April2010/Berndes%282002%29%20- 89 %20Bioenergy%20and%20water_Largescale%20bioeenrgy%20production.pdf

. 90Chapter 8: References

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— DO NOT CITE OR QUOTE Cardinale, BJ; Wright, JP; Cadotte, MW; Carroll, IT; Hector, A; Srivastava, DS; Loreau, M; 136 Weis, JJ. 2007. Impacts of plant diversity on biomass production increase through time 137 because of species complementarity. Proceedings of the National Academy of Sciences 138 of th e United States of America 104: 18123-18128. 139 Cassel, DK; Raczkowski, CW; Denton, HP. 1995. Tillage effects on corn production and soil 140 physical conditions. Soil Science Society of America Journal 59(5): 1436-1443. 141 CENR (Committee on Environment and Natural Resources). 2010. Scientific assessment of 142 hypoxia in U.S. coastal waters. Interagency Working Group on Harmful Algal Blooms, 143 Hypoxia, and Human Health of the Joint Subcommittee on Ocean Science and 144 Technology. Available at: 145 http://www.whitehouse.gov/sites/default/files/microsites/ostp/hypoxia -report.pdf

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. 158 Chiu, Y-W; Walseth, B; Suh, S. 2009. Water embodied in bioethanol in the United States. 159 Environmental Science and Technology 43(8): 2688-2692. Available at: 160 http://pubs.acs.org/doi/suppl/10.1021/es8031067/suppl_file/es8031067_si_001.pdf

. 161 Chisti, Y. 2007. Biodiesel from microalgae. Biotechnology Advances 25: 294-306. 162 Christian, DP; Hoffman, W; Hanowski, JM; Niemi, GJ; Beyea, J. 1998. Bird and mammal 163 diversity on woody biomass plantations in North America. Biomass and Bioenergy 14: 164 395-402. 165 Clarens, AF; Resurreccion, EP; White, MA; Colosi, LM. 2010. Environmental life cycle 166 comparison of algae to other bioenergy feedstocks. Environmental Science and 167 Technology 44(5): 1813-1819. 168 Clifton -Brown, JC; Lewandowski, I; Andersson, B; Basch, G; Christian, DG; Kjeldsen, JB; 169 Jorgensen, U; Mortensen, JV; Riche, AB; Schwarz, K-U; Tayebi, K; Teixeira, F. 2001. 170 Perfo rmance of 15 Miscanthus genotypes at five sites in Europe. Agronomy Journal 93: 171 1013-1019. 172 Clifton -Brown, JC; Breuer, J; Jones, MB. 2007. Carbon mitigation by the energy crop, 173 Miscanthus. Global Change Biology 13(11): 2296-2307. 174 Cole, GA. 1983. Textbook of limnology. Third edition. Waveland Press. 175 Conner, AJ; Glare, TR; Nap, JP. 2003. The release of genetically modified crops into the 176 environment. Part II. Overview of ecological risk assessment. The Plant Journal (33): 177 19-46. 178 Corseuil, HX; Hunt, CS; Ferreira dos Santos, RC; Alvarez, PJJ. 1998. The influence of the 179 gasoline oxygenate ethanol on aerobic and anaerobic BTX degradation. Water Resources 180 Research 33(7): 2056–2072. 181Chapter 8: References

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— DO NOT CITE OR QUOTE Craig, W; Tepfer, M; Degrassi, G; Ripandelli, D. 2008. An overview of general feature s of risk 182 assessments of genetically modified crops. Euphytica 164(3): 853-880. 183 Cram, DS; Baker, TT; Fernald, AG; Madrid, A; Rummer, B. 2007. Mechanical thinning impacts 184 on runoff, infiltration, and sediment yield following fuel reduction treatments in 185 southwestern dry mixed conifer forest. Journal of Soil and Water Conservation 62(5): 186 359-366. 187 Cruse, RM; Herndl, CG. 2009. Balancing corn stover harvest for biofuels with soil and water 188 conservation. Journal of Soil and Water Conservation 64: 286-291. 189 Dale, V H; Kline, KL; Wiens, J; Fargione, J. 2010. Biofuels: Implications for land use and 190 biodiversity. Ecological Society of America. Available at: 191 http://esa.org/ biofuelsreports/files/ESA%20Biofuels%20Report_VH%20Dale%20et%20a 192 l.pdf

. 193 Danalatos, NG; Archontoulis, SV; Mitsios, I. 2007. Potential growth and biomass productivity of 194 Miscanthus x giganteus as affected by plant density and N- fertilization in central Greece

. 195 Biomass and Bioenergy 31(2 -3): 145-152. 196 Darnall, DW ; Greene, B ; Hosea, H ; McPherson, RA ; Henzl, M . 1986. Recovery of heavy metals 197 by immobilized algae. In: Thompson, R. (ed). Trace metal removal from aqueous 198 solution. Special Publication No. 61. Royal Society of Chemistry. pp. 1-24. 199 Da Silva, MLB; Alvarez, PJJ. 2002. Effects of ethanol versus MTBE on benzene, toluene, 200 ethylbenzene, and xylene natural attenuation in aquifer columns. Journal of 201 Environmental Engineering 128: 862-867. 202 Davidson, EA; Ackerman, IL. 1993. Changes in soil carbon inventories following cultivation of 203 previously untilled soils. Biogeochemistry 20(3): 161-193. 204 Davis, JM. 2007. How to assess the risks of nanotechnology: Learning from past experi ence. 205 Journal of Nanoscience and Nanotechnology 7: 402-409. 206 Davis, JM; Thomas, VM. 2006. Systematic approach to evaluating trade-offs among fuel 207 options: The lessons of MTBE. Annals of the New York Academy of Sciences 1076: 208 498-515. 209 Davis, SC; Parton, WJ; Dohleman, FG; Smith, CM; Del Grosso, S; Kent, AD; Delucia, EH. 210 2010. Comparative biogeochemical cycles of bioenergy crops reveal nitrogen- fixation 211 and low greenhouse gas emissions in a Miscanthus x giganteus agro- ecosystem. 212 Ecosystems 13(1): 144-156. 213 Day, JD; Edwards, AP; Rodgers, GA. 1991. Development of an industrial- scale process for the 214 heterotrophic production of a micro-algal mollusc feed. Bioresource Technology 38(2- 3): 215 245-249. 216 Dhondt, AA; Wrege, PH; Cerretani, J; Sydenstricker, KV. 2007. Avian spec ies richness and 217 reproduction in short rotation coppice habitats in central and western New York. Bird 218 Study 54: 12-22. 219 Dinnes, DL; Karlen, DL; Jaynes, DB; Kaspar, TC; Hatfield, JL; Colvin, TS; Cambardella, CA. 220 2002. Nitrogen management strategies to reduce nitrate leaching in tile

- drained 221 midwestern soils. Agronomy Journal 94(1): 153-171. 222 DiTomaso, JM; Reaser, JK.; Dionigi, CP; Doering, OC; Chilton, E; Schardt, JD; Barney, JN. 223 2010. Biofuel vs. bioinvasion: Seeding policy priorities. Environmental Sci ence and 224 Technology 44: 6906-6910. 225 Dominguez-Faus, R; Powers, S; Burken, J; Alvarez, P. 2009. The water footprint of biofuels: A 226 drink or drive issue? Environmental Science and Technology 43(9): 3005-3010. 227Chapter 8: References

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— DO NOT CITE OR QUOTE Donner, SD; Kucharik, CJ; Foley, JA. 2004. Impact of changing land use practices on nitrate 228 export by the Mississippi River. Global Biogeochemical Cycles 18: GB1028. 229 Downing, M; Walsh, M; McLaughlin, S. 1995. Perennial grasses for energy and conservation: 230 Evaluating some ecological, agricultural, and econ omic issues. Center for Agriculture, 231 Food and Environment, Tufts University. 232 Drinkwater, LE; Wagoner, P; Sarrantonio, M. 1998. Legume- based cropping systems have 233 reduced carbon and nitrogen losses. Nature 396(6708): 262-265. 234 Duncan, M; Lippiatt, BC; Haq, Z; Wang, M; Conway, RK. 2008. Metrics to support informed 235 decision making for consumers of biobased products. USDA/OCE AIB 803. 236 Edeso, JM; Merino, A; Gonzalez, MJ; Marauri, P. 1999. Soil erosion under different harvesting 237 managements in steep forestlands fr om northern Spain. Land Degradation and 238 Development 10(1): 79-88. 239 EIA (Energy Information Administration). 2007. Methodology for allocating municipal solid 240 waste to biogenic and non- biogenic energy. Available at: 241 http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw.pdf

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. 245 EIA (Energy Information Administration). 2010. Biodiesel monthly report: 2009 edition. 246 Available at: 247 http://www.eia.doe.gov/cneaf/solar.renewables/page/biodiesel/biodiesel.html

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. 258 EIA (Energy Information Administration). n.d.[d]. U.S. imports of fuel ethanol (thousands of 259 barrels per day). Petroleum Navigator. Available at: 260 http://www.eia.doe.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=MFEIMUS1&f=A

. 261 Ekvall, T. 2005. SETAC summaries. Journal of Cleaner Production 13: 1351-1358. 262 ERS (United States Department of Agriculture, Economic Research Service). 2008. 2008 farm 263 bill side

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. 265 ERS (United States Department of Agriculture, Economic Research Service). 2010a. NEW feed 266 grains data: Yearbook tables: U.S. exports of ethyl alcohol by selected destinations. 267 Available at: http://www.ers.usda.gov/Data/feedgrains/Table.asp?t=32

. 268 ERS (United States Department of Agriculture, Economic Research Service). 2010b. Feed grains 269 data yearbook tables: Table 1. Corn, sorghum, barley, and oats: Planted acreage, 270 harvested acreage, production, yield, and farm price. Available at: 271 http://www.ers.usda.gov/data/feedgrains/Table.asp?t=01

. 272Chapter 8: References

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— DO NOT CITE OR QUOTE ERS (United States Department of Agriculture, Economic Research Service). 2010c. Feed grains 273 data yearbook tables: Table 31. Corn: Food, seed, and industrial use. Available at: 274 http://www. ers.usda.gov/data/feedgrains/Table.asp?t=31

. 275 Evans, JM; Cohen, MJ. 2009. Regional water resource implications of bioethanol production in 276 the southeastern United States. Global Change Biology 15: 2261-2273. 277 Fabiosa, J; Beghin, J; Fengxia, D; Elobeid, A; Tokgoz, S; Yu, T. 2010. Land allocation effects of 278 the global ethanol surge: Predictions from the International FAPRI model. Land 279 Economics 86(4): 687-706. 280 FAPRI (Food and Agricultural Policy Research Institute). 2008. U.S. and world agricultural 281 outlook. Av ailable at: http://www.fapri.iastate.edu/outlook/2008/

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. 292 FAPRI (Food and Agricultural Policy Research Institute). 2010d. World biofuels. In: U.S. and 293 world agricultural outlook. Available at: 294 http://www.fapri.iastate.edu/outlook/2010/text/15Biofuels.pdf

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cross -country analysis. Journal of Cleaner Production 17: S9-S17. 302 Federer, CA; Hornbeck, JW; Tritton, LM; Martin, CW; Pierce, RS; Smith, CT (1989). Long303 term depletion of calcium and other nutrients in Eastern US forests. Environmental 304 Management 13(5):593-601. 305 Fenn, ME; Poth, MA; Aber, JD; Baron, JS; Bormann, BT; Johnson, DW; Lemly, AD; McNulty, 306 SG; Ryan, DE; Stottlemyer, R. 1998. Nitrogen excess in North American ecosystems: 307 Predisposing factors, ecosystem responses, and management strategies. Ecological 308 Applications 8(3): 706-733. 309 Firbank, L. 2007. Assessing the ecolog ical impacts of bioenergy projects. Bioenergy Research 310 doi: 10.1007/s12155-007-9000- 8. Available at: 311 https://files.pbworks.com/download/HjG9dZBkTr/np312 net/12639072/Firbank%20%282008%29%20Assessing%20ecological%20impacts 313 %20bioenergy%20projects.pdf

. 314 Flynn, KJ; Greenwell, HC; Lovitt, RW; Shields, RJ. 2010. Selection for fitness at the individual 315 or popul ation level: Modeling effects of genetic modification in microalgae on 316 productivity and environmental safety. Journal of Theoretical Biology 263(3): 269-280. 317Chapter 8: References

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. 519 Lapola, D; Schal dach, R; Alcamo, J; Bondeau, A; Koch, J; Koelking, C; Priess, J. 2010. Indirect 520 land -use changes can overcome carbon savings from biofuels in Brazil. Proceedings of 521 the National Academy of Sciences of the United States of America. Available at: 522 http://www.pnas.org/content/early/2010/02/02/0907318107.full.pdf+html

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— DO NOT CITE OR QUOTE Lewandowski, I; Clifton-Brown, JC; Andersson, B; Basch, G; Christian, DG; Jorgensen, U; 544 Jones, MB; Riche, AB; Schwarz, KU; Tayebi, K; Teixeira, F. 2003. Environment and 545 harvest time affects the com bustion qualities of Miscanthus genotypes. Agronomy 546 Journal 95: 1274-1280. 547 Licht, FO. 2007. World—biodiesel production (tonnes). F.O. Licht’s World Ethanol and 548 Biofuels Report 5(14): 291. 549 Liska, AJ, Yang, HS; Bremer, VR; Klopfenstein, TJ; Walters, DT; Eric kson, GE; Cassman, KG. 550 2008. Improvements in life cycle energy efficiency and greenhouse gas emissions of 551

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— DO NOT CITE OR QUOTE NASS (United States Department of Agriculture, National Agricultural Statistics Service). 634 2010b. County maps. Available at: 635 http://www.nass.usda.gov/Charts_and_Maps/Crops_County/index.asp

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. 826 Searchinger, T; Heimlich, R; Houghton, RA; Dong, FX; Elobeid, A; Fabiosa, J; Tokgoz, S; 827 Hayes, D; Yu, TH. 2008. Use of US croplands f or biofuels increases greenhouse gases 828 through emissions from land use change. Science 319(5867): 1238-1240. 829 Secchi, S; Babcock, BA. 2007. Figure 9. Acreage out of CRP as a function of corn prices and 830 CRP payments. In: Impact of high crop prices on environ mental quality: A case of Iowa 831 and the Conservation Reserve Program. Report No. 07- WP -447. Iowa State University, 832 Center for Agricultural and Rural Development. 833 Secchi, S; Gassman, PW; Williams, JR; Babcock, BA. 2009. Corn-based ethanol production and 834 environmental quality: A case of Iowa and the conservation reserve program. 835 Environmental Management 44(4): 732-744. 836 SECEX (Brazilian Ministry of Development, Industry and Trade). n.d. Table: Destino das 837 exportações brasileiras de álcool etílico. Available at: 838 http://www.desenvolvimento.gov.br/sitio/interna/interna.php?area=2&menu=999

. 839 Semere, T; Slater, FM. 2006. Ground flora, small mammal and bird species diversity in 840 mi scanthus and reed canary -grass fields. Biomass and Bioenergy 31(1): 20-29. 841 Sexton, S; Zilberman, D; Rajagopal, D; Hochman, G. 2009. The role of biotechnology in a 842 sustainable biofuel future. AgBioForum 12(1): 130-140. 843 Shah, T; Burke, J; Villholth, K. 2007. Groundwater: A global assessment of scale and 844 significance. Chapter 10. In: Molden, D. (ed.). Water for food, water for life: A 845 comprehensive assessment of water management in agriculture. Earthscan. 846 Sheehan, J; Camobreco, V; Duffield, J; Graboski, M; Shapouri, H. 1998a. Life cycle inventory 847 of biodiesel and petroleum diesel for use in an urban bus. NREL/SR-580-24089. National 848 Renewable Energy Laboratory. 849 Sheehan, J; Camboreco, V; Duffield, J; Graboski, M; Shapouri, H. 1998b. An overview of 850 biodiesel and p etroleum diesel life cycles. National Renewable Energy Laboratory. 851 Sheehan, J; Aden, A; Paustian, K; Killian, K; Brenner, J; Walsh, M; Nelson, R. 2004. Energy 852 and environmental aspects of using corn stover for fuel ethanol. Journal of Industrial 853 Ecology 7(3-4): 117-146. 854 Shepard, JP. 2006. Water quality protection in bioenergy production: the US system of forestry 855 Best Management Practices. Biomass and Bioenergy 30(4): 378 -384. 856 Shinners, KJ; Boettcher, GC; Hoffman, DS; Munk, JT; Muck, RE; Weimer, PJ. 2009. Single

857 pass harvest of corn grain and stover: Performance of three harvester configurations. 858 Transactions of the ASABE 52(1): 51-60. 859Chapter 8: References

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— DO NOT CITE OR QUOTE Shipitalo, MJ; Edwards, WM. 1998. Runoff and erosion control with conservation tillage and 860 reduced -input practices on cropped watersheds. Soil & Tillage Research 46(1- 2): 1 -12. 861 Simpson, TW; Sharpley, AN; Howarth, RW; Paerl, HW; Mankin, KR. 2008. The new gold rush: 862 Fueling ethanol production while protecting water quality. Journal of Environmental 863 Quality 37(2): 318-324. 864 Simpson, TW; Martinelli, LA; Sharpley, AN; Howarth, RW. 2009. Impact of ethanol production 865 on nutrient cycles and water quality: The United States and Brazil as case studies. In: 866 Howarth, RW; Bringezu, S (eds). Biofuels: Environmental consequences and int eractions 867 with changing land use. Proceeding of the Scientific Committee on Problems of the 868 Environment (SCOPE) International Biofuels Project Rapid Assessment. pp. 153-167. 869 South Dakota State University. 2009. The cost of wet corn at harvest. Extension Ex tra. 870 ExEx5056. Available at: http://agbiopubs.sdstate.edu/articles/ExEx5056.pdf

. 871 Spencer, JL; Raghu, S. 2009. Refuge or reservoir? The potential impacts of the biofuel crop 872 Miscanthus x gigan teus on a major pest of maize. PLoS One 4(12): e8336. 873 Stanton, B; Eaton, J; Johnson, J; Rice, D; Schuette, B; Moser, B. 2002. Hybrid poplar in the 874 Pacific Northwest

— the effects of market -driven management. Journal of Forestry 100(4): 875 28-33. 876 Sticklen, MB. 2007. Feedstock crop genetic engineering for alcohol fuels. Crop Science 47: 877 2238-2248. 878 Sticklen, MB. 2009. Expediting the biofuels agenda via genetic manipulations of cellulosic 879 bioenergy crops. Biofuels, Bioproducts and Biorefining 3: 448-455. 880 Stout, BM; Benfield, EF; Webster, JR. 1993. Effects of forest disturbance on shredder 881 production in Southern Appalachian headwater stream s. Freshwater Biology 29(1): 882 56-69. 883 Suter, GW. 2007. Ecological risk assessment. CRC Press. 884 Taylor, RL; Maxwell, BD; Boik, RJ. 2006. Indirect effects of herbicides on bird food resources 885 and beneficial arthropods. Agriculture, Ecosystems and Environment 116(3-4): 157-164. 886 Teasdale, JR; Brandsaeter, LO; Calegari, A; Skora Neto, F. 2007. Cover crops and weed 887 management. Non- chemical weed management. Available at: 888 http://www.ars.usda.gov/sp2UserFiles/Place/12650400/Non-ChemWeedMgmt.pdf

. 889 Thiffault, E; Pare, D; Belanger, N; Munson, A; Marquis, F. 2006. H arvesting intensity at clear

890 felling in the boreal forest: Impact on soil and foliar nutrient status. Soil Science Society 891 of America Journal 70(2): 691-701. 892 Thornton, KW; Holbrook, SP; Stolte, KL; Landy, RB. 2000. Effects of forest management 893 practices on Mid -Atlantic streams. Environmental Monitoring and Assessment 63: 31-41. 894 Thurmond, W. 2008. Biodiesel 2020: A global market survey. Available at: 895 http://www.emerging -markets.com/biodiesel

. 896 Tilman, D; Lehman, C. 2006. Carbon-negative biofuels from low-input high diversity grassland 897 biomass. Science 314: 1598-1600. 898 Tilman, D; Hill, J; Lehman, C. 2006. Carbon-negative biofuels from low- impact high

- diversity 899 grassland biomass. Science 314 (5805): 1598-1600. 900 Tilman, D; Socolow, R; Foley, JA; Hill, J; Larson, E; Lynd, L; Pacala, S; Reilly, J; Searchinger, 901 T; Somerville, C; Williams, R. 2009. Beneficial biofuels —the food, energy, and 902 environment trilemma. Science 325: 270-271. 903 Timmons, D; Allen, G; Damery, D. 2008. Biomass energy crops: Massachusetts’ potential. 904 http://www.mass.gov/Eoeea/docs/doer/renewables/biomass/bio

- ma -potential-crop.pdf

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— DO NOT CITE OR QUOTE Titus, BD; Roberts, BA; Deering, KW. 1997. Soil solution concentrations on three white birch 906 sites in central Newfoundland following different harvesting intensities. Biomass and 907 Bioenergy 13(4-5): 313-330. 908 Unc, A; Goss, MJ. 2004. Transport of bacteria from manure and protection of water resources. 909 Applied Soil Ecology 25(1): 1-18. 910 UNEP/GRID

- Arendal. 2009. Kick the habit: A UN guide to climate neutrality. Available at: 911 http://maps.grida.no/go/graphic/biofuel-production- map

. 912 Updegraff, K; Baughman, MJ; Taff, SJ. 2004. Environmental benefits of cropland conversion to 913 hybrid poplar: economic and policy considerations. Biomass and Bioenergy 27: 411-428. 914 USDA (United States D epartment of Agriculture). 2010a. USDA long- term agricultural 915 projection tables. Table 18. U.S. corn. Available at: 916 http://usda.mannlib.cornell.edu/MannUsda/viewStaticPage.do?url=http://usda.mannlib.co 917 rnell.edu/usda/ers/94005/./2010/index.html

. 918 USDA (United States Department of Agriculture). 2010b. USDA long- term agricultural 919 projection tables. Table 23. Soybeans and products. Available at: 920 http://usda.mannlib.cornell.edu/MannUsda/viewStaticPage.do?url=http://usda.mannlib.co 921 rnell .edu/usda/ers/94005/./2010/index.html

. 922 USDA (United States Department of Agriculture). 2010c. USDA long- term agricultural 923 projection tables. Table 17. Acreage for major field crops and Conservation Reserve 924 Program (CRP) assumptions, long- term projections. Available at: 925 http://usda.mannlib.cornell.edu/MannUsda/viewStaticPage.do?url=http://usda.mannlib.co 926 rnell.edu/usda/ers/94005/./2010/index.html

. 927 USDA (United States Department of Agriculture). 2010d. Sugar and sweeteners outlook. Effects 928 of global sugar markets on U.S. ethanol. Economic Research Service. Available at: 929 http://www.ers.usda.gov/publications/sss/2010/Nov/SSSM267.pdf

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. 936 U.S. DOE (United States Department of Energy). 2008. World biofuels production potentia l: 937 Understanding the challenges to meeting the U.S. Renewable Fuel Standard. Available at: 938 http://www.pi.energy.gov/documents/20080915_WorldBiofuelsProductionPotential.pdf

. 939 U.S. DOE (United States Department of Energy). 2010. National algal biofuels technology 940 roadmap. Available at: 941 http://www1.eere.energy.gov/biomass/pdfs/algal_biofuels_roadmap.pdf

. 942 U.S. EPA (United States Environmental Protection Agency). 1999. 5. Livestock manure 943 management. In: U.S. methane emissions 1990-2020: Inventories, projections, and 944 opportunities for reductions. Available at: http://epa.gov/methane/reports/05 -manure.pdf

. 945 U.S. EPA (United States Environmental Protection Agency). 2000. National water quality 946 inventory 2000 report. Available at: http://w ww.epa.gov/305b/2000report

. 947 U.S. EPA (United States Environmental Protection Agency). 2001. Control of air pollution from 948 new motor vehicles: Heavy -duty engine and vehicle standards and highway diesel fuel 949 sulfur control requirements. 40 CFR Parts 69, 80, and 86. Available at: 950 http://www.epa.gov/otaq/highway- diesel/regs/2007

- heavy -duty-highway.htm

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— DO NOT CITE OR QUOTE U.S. EPA (United States Environmental Protection Agency). 2002. A comprehen sive analysis of 952 biodiesel impacts on exhaust emissions. EPA-420-P-02-001. Available at: 953 http://www.epa.gov/otaq/models/analysis/biodsl/p02001.pdf

. 954 U.S. EPA (United States Environmental Protection Agency). 2006a. Framework for developing 955 suspended and bedded sediments (SABS) water quality criteria. EPA-822-R-06-001. 956 Available at: http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=164423

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. 962 U.S. EPA (United States Environmental Protection Agency). 2007a. Environmental law 963 applicable to construction and operation of ethanol plants. EPA-907-B-07-001. Available 964
at: http://www.epa.gov/region07/priorities/agriculture/pdf/ethanol_plants_manual.pdf

. 965 U.S. EPA (United States Environmental Protection Agency). 2008a. Environmental law 966 applicable to construction and operation of biodiesel production facilities. EPA-907-B967 08-001. Available at: 968 http://www.epa.gov/Region7/priorities/agriculture/pdf/biodiesel_manual.pdf

. 969 U.S. EPA (United States Environmental Protection Agency). 2008b. National coastal condition 970 report

— III. EPA -842-R-08-002. Available at: http://www.epa.gov/nccr

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. 977 U.S. EPA (United States Environmental Protection Agency). 2009b. Biofuels compendium. 978 Available at: http://www.epa.gov/oust/altfuels/bfcompend.htm

. 979 U.S. EPA (United States Environmental Protection Agency). 2009c. Biofuels compendium— 980 ethanol— equipment compatibility. Available at: 981 http://www.epa.gov/oust/altfuels/ethcompat.htm

. 982 U.S. EPA (United States Environmental Protection Agency). 2009d. Report to Congress on 983 public health, air quality, and water resource impacts of fuel additive substitutes for 984 MTBE, as required by Section 1505 of the Energy Policy Act 2005. 985 U.S. EPA (United States Environmental Protection Agency). 2010a. Regulation of fuels and fuel 986 additives: Changes to Renewable Fuel Standard Program: Final rule. Available at: 987 http://www.regulations.gov/search/Regs/contentStreamer?objectId=0900006480ac93f2& 988 disposition=attachment&contentType=pdf

. 989 U.S. EPA (Uni ted States Environmental Protection Agency). 2010b. Renewable fuel standard 990 program (RFS2) regulatory impact analysis. EPA-420-R-10-006. Available at: 991 http://www.epa.gov/otaq/renewablefuels/420r10006.pdf

. 992 U.S. EPA (United States Environmental Protection Agency). 2010c. Water quality assessment 993 and total maximum daily loads information (ATTAINS). Available at: 994 http://www.epa.gov/waters/ir/ index.html

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— DO NOT CITE OR QUOTE U.S. EPA (United States Environmental Protection Agency). 2010d. National causes of 996 impairment. In: National summary of state information. Available at: 997 http://i aspub.epa.gov/waters10/attains_nation_cy.control#causes

. 998 U.S. EPA (United States Environmental Protection Agency). 2010e. Acetochlor (CASRN 34256- 999 82- 1). In: Integrated Risk Information System. Available at: 1000 http://www.epa.gov/IRIS/subset/0521.htm

. 1001 U.S. EPA (United States Environmental Protection Agency). 2010f. Alachlor (CASRN 15972- 1002 60- 8). In: Integrated Risk Information System. Available at: 1003 http://ww w.epa.gov/IRIS/subst/0129.htm

. 1004 U.S. EPA (United States Environmental Protection Agency). 2010g. Carbaryl (CASRN 63-25- 1005 2). In: Integrated Risk Information System. Available at: 1006 http://www.epa.gov/IRIS/subst/0019.htm

. 1007 U.S. EPA (United States Environmental Protection Agency). 2010h. Regulation of fuels and fuel 1008 additives: Changes to renewable fuel standard program. EPA

- HQ

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. 1011 U.S. Forest Service. 2005. Evaluating sedimentation risks associated with fuel management. 1012 RMRS

- RN -23-8- WWW. 1013 U.S. Forest Service. 2010. Draft—National Report on Sustainable Forests—2010. Available at: 1014 http://www.fs.fed.us/research/sustain/2010SustainabilityReport/documents/draft2010sust 1015 ainabilityreport.pdf

. 1016 U.S. ITC (United States International Trade Commission). 2010. Interactive Tariff and Trade 1017 DataWeb. U.S. imports for consumption. Report: HTS-2207: Ethyl alcohol, undenatured 1018 of an alcoholic strength by volume of 80% vol. or higher; ethyl alcohol and other spirits, 1019 denatured, of any strength first unit of quantity by first unit of quantity. 1020 Van der Steen, NP; Nakiboneka, P; Mangalika, L; Ferrer, AVM; Gijzen, HJ. 2003. Effect of 1021 duckweed cover on greenhouse gas emissions and odor release from waste stabilization 1022 ponds. Water Science and Technology 48(2): 341-348. 1023 Vogel, KP; Masters, RA. 1998. Developing switchgrass into a biomass fuel crop for the 1024 midw estern USA. Paper presented at BioEnergy ’98: Expanding Bioenergy Partnerships, 1025 Madison, Wisconsin, 4–8 October 1998. 1026 Volk, TA; Abrahamson, LP; Nowak, CA; Smart, LB; Tharakan, PJ; White, EH. 2006. The 1027 development of short-rotation willow in the northeastern United States for bioenergy and 1028 bioproducts, agroforestry and phytoremediation. Biomass and Bioenergy 30(8- 9): 1029 715-727. 1030 Von Blottnitz, H; Curran, MA. 2007. A review of assessments conducted on bio- ethanol as a 1031 transportation fuel from a net energy, greenhouse gas, and environmental life cycle 1032 perspective. Journal of Cleaner Production 15: 607-619. 1033 Walsh, ME; de la Torre Ugarte, DG; Shapouri, H; Slinsky, SP. 2003. Bioenergy crop production 1034 in the United States: Potential quantities, land use changes, and economic impacts on the 1035 agricultural sector. Environmental and Resource Economics 24(4): 313-333. 1036 Walter, WD; Vercauteren, KC; Gilsdorf, JM; Hygnstrom, SE. 2009. Crop, native vegetation, and 1037 biofuels: Response of white- tailed deer to changing management pri orities. Journal of 1038 Wildlife Management 73: 339-344. 1039Chapter 8: References

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— DO NOT CITE OR QUOTE Wang, L; Robertson, DM; Garrison, PJ. 2007a. Linkages between nutrients and assemblages of 1040 macroinvertebrates and fish in wadeable streams. Environmental Management 39: 194- 1041 212. Available at : http://www.springerlink.com/content/4k441384336k1x28/fulltext.pdf

. 1042 Wang, M; Wu, M; Huo, H. 2007b. Life-cycle energy and greenhouse gas emission impacts of 1043 different corn ethanol plant ty pes. Environmental Research Letters 2: 1 -13. 1044 Weed, DAJ; and Kanwar, RS. 1996. Nitrate and water present in and flowing from root-zone 1045 soil. Journal of Environmental Quality 25: 709-719. 1046 Weibe, K; Gollehon, N. 2006. Agricultural resources and environmental indicators, 2006 edition. 1047 Economic Information Bulletin No. (EIB-16). U.S. Department of Agriculture, Economic 1048 Research Service. Available at: http://www.ers.usda.gov/publications/arei/eib16/

. 1049 Weigelt, A; Weisser, WW; Buchmann, N; Scherer -Lorenzen, M. 2009. Biodiversity for 1050 multifunctional grasslands: Equal productivity in high -diversity low-input and low1051 diversity high-input systems. Biogeosciences 6: 1695-1706. 1052 Whalen, J; Cissel, B. 2009. Soil insect management in field corn. University of Delaware 1053 Cooperative Extension. 1054 Whicker, JJ; Pinder, JE; Breshears, DD. 2008. Thinning semiarid forests amplifies wind erosion 1055 comparably to wildfire: Implications for restoration and soil stability. Journal of Arid 1056 Environments 72(4): 494-508. 1057 White, EM. 2010. Woody biomass for bioenergy and biofuels in the United States— a briefing 1058 paper. Gen. Tech. Rep. PNW- GTR -825. U.S. Department of Agriculture. 1059 Wilkinson, M; Tepfer, M. 2009. Fitness and beyond: Preparing for the arrival of GM crops with 1060 ecologically important novel characters. Environmental Biosafety Research 8: 1 -14. 1061 Williams, PR; Inman, DD; Aden, A; Heath, GA. 2009. Environmental and sustainability factors 1062 associated with next -generation biofuels in the U.S.: What do we really know? 1063 Environmental Science and Technology 43: 4763-4775. 1064 Wiltsee, G. 1998. Urban waste grease resource assessment. NREL/SR-570-26141. National 1065 Renewable Energy Laboratory. Available at: 1066 http://www.biodiesel.org/resources/sustainability/pdfs/NREL%20Urban%20Waste%20G 1067 rease%20Resources%20Assessment.pdf

. 1068 Winebrake, J; Wang, M; He, D. 2001. Toxic emissions from mobile sources: A total fuel- cycle 1069 analysis for conventional and alternative fuel vehicles. Journal of the Air and Waste 1070 Management Association 51: 1073-1086. 1071 Wolt, JD. 2009. Advancing environmental risk assessment for transgenic biofeedstock crops. 1072 Biotech nology for Biofuels. 2: 27 doi: 10.1186/1754-6834-2-27. 1073 Wösten, JHM; van den Berg, J; van Eijk, P; Gevers, GHM; Giesen, WBJT; Hooijer, A; Idris, A; 1074 Leenman, PH; Rais, DS; Siderius, C; Silvius, MJ; Suryadiputra, N; Wibisono, IT. 2006. 1075 Interrelationships between hydrology and ecology in fire degraded tropical peat swamp 1076 forests. International Journal of Water Resources Development 22(1): 157-174. 1077 Wright LL. 1994. Production technology status of woody and herbaceous crops. Biomass and 1078 Bioenergy 6(3): 191-210. 1079 Wu, M. 2008. Analysis of the efficiency of the U.S. ethanol industry. Center for Transportation 1080 Research, Argonne National Laboratory. 1081 Wu, M; Wang, M. 2006. Energy and emission benefits of alternative transportation liquid fuel 1082 derived from switchgrass: A fuel life -cycle assessment. Biotechnology Progress 22(4): 1083 1012-1024. 1084Chapter 8: References

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— DO NOT CITE OR QUOTE Wu, M; Mintz, M; Wang, M; Arora, S. 2009. Water consumption in the production of ethanol 1085 and petroleum gasoline. Environmental Management 44: 981-997. 1086 Yacobucci, B. 2005. CRS report to Congress: Ethanol imports and the Caribbean Basin 1087 Initiative. Congressional Research Service. Order Code RS21930. Available at: 1088 http://www.policyarchive.org/handle/10207/bitstreams/3978.pdf

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1099Appendix A

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— DO NOT CITE OR QUOTE 

## Appendix A 1

2 

## Glossary and Acronyms 3Appendix A

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 A-2 DRAFT

— DO NOT CITE OR QUOTE a dvanced biofuel: A renewable fuel, other than ethanol derived from corn starch that has life 4 cycle greenhouse gas (GHG) emissions that are at least 50 percent less than life cycle GHG 5 emissions from petroleum fuel. A 60-percent reduction in GHG is required from cellulosic 6 biofuels to get credit for being an “advanced” biofuel. 7 8

a gricultural residue: Plant parts, primarily stalks and leaves that are not removed from fields 9 used for agriculture during harvesting of the primary food or fiber product. Examples include 10 corn stover (stalks, leaves, husks, and cobs), wheat straw, and rice straw. 11 12 algae: Any plant-like organisms that are usually photosynthetic and aquatic, but do not have true 13 roots, stems, leaves, or vascular tissue , and that have simple reproductive structures. Algae are 14 distributed worldwide in the sea, in fresh water , and in wastewater. Most are microscopic, but 15 some are quite large ( e.g. , some marine seaweeds that can exceed 50 meters in length ). 16

B100: Pure (i.e., 100 percent ) biodiesel, also known as “neat biodiesel.” 17 18 B20: A fuel mixture that includes 20 percent biodiesel and 80 percent conventional diesel and 19 other additives. Similar mixtures, such as B5 or B10, also exist and contain 5 and 10 percent 20 biodiesel, respectively. 21 22 Best Management Practices (BMPs): B est management practices are the techniques, methods, 23
processes , and activities commonly accepted and used to facilitate compliance with applicable 24 requirements, and that provide an effective and practicable means of avoiding or reducing the 25 poten tial environmental impacts. 26 27 b iodiesel (also known as “biomass-based diesel”): A renewable fuel produced through 28 transesterification of organically derived oils and fats. May be used as a replacement for or 29 component of diesel fuel. 30 31 biodiversity: The variety and variability among living organisms and the ecological complexes 32 in which they occur. Biodiversity can be defined as the number and relative frequency of 33 different items, from complete ecosystems to the biochemical structures that are the molecular 34 basis of heredity. Thus, the term encompasses ecosystems, species, and genes. 35 36 b iofuel: Any fuel made from organic materials or their processing and conversion derivatives. 37 38 b iofuel blend: Fuel mixtures that include a blend of renewable biofuel and petro leum

- based fuel. 39 This is opposed to “neat form” biofuel that is pure, 100 percent renewable biofuel. 40 41 biofuel distribution: Transportation of biofuel to blending terminals and retail outlets by a 42 variety of means, including rail, barge, tankers, and trucks. This a lmost always includes periods 43 of storage. 44 45 biofuel end use: Combustion of biofuel in vehicles and various types of engines, usually as a 46 blend with gasoline or diesel, or in some cases in neat form. 47 48Appendix A

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— DO NOT CITE OR QUOTE b iofuel life cycle: All the consecutive and interlinked stages of biofuel production and use, from 49 feedstock generation to biofuel production, distribution, and end use by the consumer. 50 51 biofuel production: The process or processes involved in converting a feedstock into a 52

co nsumer- ready biofuel. 53 54 biofuel supply chain : The five main stages involved in the life cycle of a biofuel: feedstock 55 production, feedstock logistics, fuel production, fuel distribution, and fuel use. 56 57 biogenic: Produced by living organisms or a biological process. 58 59 biomass: Any plant-derived organic matter (e.g., agricultural crops and crop wastes; wood and 60 wood wastes and residues; aquatic plants; perennial grasses). 61 62 biomass- based diesel: See “biodiesel” above. Biomass -based diesel includes non- co

- processed 63 renewable diesel, which does not use the transesterification technology. 64 65

c ellulosic biofuel: A renewable fuel derived from lignocellulose (i.e., plant biomass comprised 66 of cellulose

, hemicellulose, and lignin that is a main component of nearly every plant, tree, and 67 bush in meadows, forests, and fields). Lignocellulose is converted to cellulosic biofuel by 68 separating the sugars from the residual material, mostly lignin, and then fermenting, distilling, 69 and dehydrating this sugar solution. 70 71 Conservation Reserve Program (CRP) : A U.S. Department of Agriculture program that 72 provides technical and financial assistance to eligible farmers and ranchers to address soil, water, 73 and related natural resource concerns on their lands in an environmentally beneficial and cost74 effective manner. It encourages farmers to convert highly erodible cropland or other 75 environmentally sensitive acreage to vegetative cover, such as tame or native grasses, wildlife 76 plantings, trees, filter strips, or riparian buffers. Farmers rec eive an annual rental payment for the 77 term of the multi

- year contract. 78 79 conservation tillage: Any cultivation system that leaves at least one third of the land surface 80 covered with residue after planting in order to reduce soil erosion and conserve soil productivity. 81 One example would be “no- till,” where fields are not tilled at all and crops are planted directly 82 into the existing residue. Other variations include “strip- till” or “ridge -till,” which remove some, 83 but not all, of the residue from the harvest ed area. 84 85

c onventional biofuel: In the context of this report, “conventional biofuel” refers to ethanol 86 derived from corn starch that does not lead to at least a 50 percent reduction in greenhouse gas 87 emissions compared to petroleum. 88 89
corn stover: The stalks, leaves, husks, and cobs that are not removed from the fields when the 90 corn is harvested. 91 92

c rop yield: The quantity of grains or dry matter produced from a particular area of land . (In this 93 report, crop yield is most often measured in corn or soybean bushels per acre.) 94Appendix A

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— DO NOT CITE OR QUOTE d irect land use change: In the context of biofuel, “direct land use change” refers to land 95 conversion that is directly related and easily attributable to the biofuel supply chain. For 96 example, a U.S. farmer deciding to take land o ut of the Conservation Reserve Program in order 97 to grow more corn for ethanol would be considered a direct land use change. 98

d ouble cropping: The process of planting two different crops (not including cover crops) on the 99 same piece of land over the course of a growing season. 100

d ry milling: A process for producing conventional corn starch ethanol in which the kernels are 101 ground into a fine powder and processed without fractionating the grain into its component parts. 102 Most ethanol comes from dry milling. 103 104 E10: A fuel mixture of 10 percent ethanol and 90 percent gasoline based on volume. 105 106 E85: A fuel mixture of 85 percent ethanol and 15 percent gasoline based on volume. 107 108

e cosystem health : The ability of an ecosystem to maintain its metabolic activity level and 109 internal structure and organization, and to resist external stress over time and space scales 110 relevant to the ecosystem. 111 112

e ffluent: Liquid or gas discharged in the course of industrial processing activities, usually 113 containing residues from those processes. 114 115 Energy Independence and Security Act (Public Law 110-140) (EISA): Signed into law on 116 December 19, 2007, this legislation established energy management goals and requirements 117 while also amending portions of the National Energy Conservation Policy Act. EI SA’s stated 118 goals are to move the U.S. toward greater energy independence and security; increase production 119 of clean renewable fuels; protect consumers; increase the efficiency of products, buildings, and 120 vehicles; promote research on and deploy greenhouse gas capture and storage options; and 121 improve the energy performance of the federal government. 122 123 environmental life cycle assessment: In the context of this report, an environmental life cycle 124 assessment is an assessment in which the LCA methodology (see “ life cycle assessment ” ) is 125 applied to address the full range of potential environmental impacts over all environmental 126 media. 127 128 ethanol (also known as “bioethanol”): A colorless, flammable liquid produced by fermentation 129 of sugars. Ethanol is used directly as a fuel and fuel oxygenate. 130 131

e utrophication: Nutrient enrichment of aquatic ecosystems, in which excessive nutrient levels 132 cause accelerated algal growth, which in turn can reduce light penetration and oxygen levels in 133 water necessary for healthy aquatic ecosystems. Eutrophication can cause serious deterioration of 134 both coastal and inland water resources and can lead to hypoxia. 135 136 f eedstock: In the context of biofuel, “feedstock” refers to a biomass- based material that is 137 converted for use as a fuel or energy product. 138 139Appendix A

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eedstock logistics: All activi ties associated with handling, storing, and transporting feedstocks 140 after harvest to the point where the feedstocks are converted to biofuel. 141 142 feedstock production: All activities associated with cultivation and harvest of biofuel feedstock. 143 144 f ilter strip : A strip or area of herbaceous vegetation that may reduce nutrient loading, soil 145 erosion, and pesticide contamination by removing soil particles and contaminants from overland 146 water flow. 147

f orest residue: Includes 1) tops, limbs, and other woody material not removed in forest 148 harvesting operations in commercial hardwood and softwood stands; and 2) woody material 149 resulting from forest management operations such as pre-commercial thinning and removal of 150 dead and dying trees. 151 152 f orest thinning: Removal of resid ues from overgrown forests to reduce forest fire risk or 153 increase forest productivity. Residues are typically too small or damaged to be sold as round 154 wood but can be used as biofuel feedstock. 155 156
g reenhouse gases: Gases that trap the heat of the sun in the Earth's atmosphere, producing the 157 greenhouse effect. Greenhouse gases include water vapor, carbon dioxide, hydrofluorocarbons, 158 methane, nitrous oxide, perfluorocarbons, and sulfur hexafluoride. 159 160 h arvesting forest residue: See “forest thinning” above. 161 162 hemi cellulose: any of various plant polysaccharides less complex than cellulose and easily 163 hydrolysable to monosaccharides (simple sugars) and other products. 164 165 h ybrid: A plant species created from the offspring of genetically different parents, both within 166 and between species. Hybrids combine the characteristics of the parents or exhibit new ones. 167 168 hypoxia: The state of an aquatic ecosystem characterized by low dissolved oxygen levels (less 169 than 2 to 3 parts per million) due to accelerated algal growth and reduced light penetration 170 because of excessive nutrient levels (eutrophication). Low dissolved oxygen can reduce fish 171 populations and species diversity in the affected area. 172 173 i ndirect land use change: In the context of biofuel, “ indirect land use change ” refers to land 174 conversion that occurs as a market response to changes in the supply and demand of goods other 175 than biofuel (e.g., food commodities) that result from cha nges in biofuel demand. For example

, 176 clearing of foreign land to plant corn as a food crop in response to reduced U.S. corn exports 177 caused by increased use of U.S. corn to produce ethanol is considered to be an indirect land use 178 change

. 179 180 i ntegrated pest ma nagement (IPM): An environmentally sensitive approach to pest 181 management that uses current, comprehensive information on the life cycles of pests and their 182 interaction with the environment to manage pest damage by the most economical means, and 183 with the le ast possible hazard to people, property, and the environment. 184 185Appendix A

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— DO NOT CITE OR QUOTE invasive plants (also called invasives or noxious plants): An alien species whose introduction 186 does or is likely to cause economic or environmental harm or harm to human health. 187 188 l and cover : Vegetation, habitat, or other material covering a land surface. 189 190 land use: The human use of land involving the management and modification of natural 191 environment or wilderness into built environment such as fields, pastures, and settlements. 192 193 life cycle assessment: A comprehensive systems approach for measuring the inputs, outputs, and 194 potential environmental impacts of a product or service over its life cycle, including resource 195 extraction/generation, manufacturing/production, use, and end- of

- life management. 196 197 life cycle greenhouse gas emissions: The aggregate quantity of greenhouse gas emissions 198 (including direct emissions and significant indirect emissions such as significant emissions from 199 land use changes), as determined by the EPA Administrator , related to the full fuel life cycle, 200 where the mass values for all greenhouse gases are adjusted to account for their relative global 201 warming potential. (See above for definition of “biofuel life cycle.”) 202 203 low- till: See “ conservation tillage.” 204 205

m illing r esidues (primary and secondary): Wood and bark residues produced in processing ( or 206 milling) logs into lumber, plywood, and paper. 207 208 mitigation: In the context of the environment, action to reduce adverse environmental impacts. 209 210 neat biofuel : See “B100.” 211 212

n et energy balance: In the context of biofuel, refers to the energy content in the resulting 213 biofuel less the total amount of energy used over the production and distribution process. 214 215 nitrogen fixation: The transformation of atmospheric nitrogen into nitrogen compounds that can 216 be used by growing plants. Nitrogen-fixing species, such as soybeans, can accomplish this 217 process directly. 218 219

n utrient loading: A process in which compounds from waste and fertilizers, such as nitrogen 220 and phosphorus, enter a body of water. This can happen, for example, when sewage is managed 221 poorly, when animal waste enters ground water , or when fertilizers from residential and 222 agricultural runoff wash into a stream, river, or lake. 223 224 oxygenated fuels: Fuels, typically gasoline, that have been blended with alcohols or ethers that 225 contain oxygen in order to reduce carbon monoxide and other emissions. 226 227

o zone: A form of oxygen consisting of three oxygen atoms. In the stratosphere (7 to 1 0 miles or 228 more above the E arth's surface) , ozone is a natural form of oxygen that shields the E arth from 229 ultraviolet radiation. In the troposphere (the layer extending up 7 to 10 miles from the E arth's 230 surface), ozone is a widespread pollutant and major component of photochemical smog. 231Appendix A

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p erennial grass: A species of grass that lives more than two years and typically has low nutrient 233 demand and diverse geographical growing range, and offers important soil and water 234 conservation benefits. 235 236 photobioreactor: A vessel or closed

- cycle recirculation system containing some sort of 237 biological process that incorporates some type of light source. Often used to grow small 238 phototrophic organisms such as cyanobacteria, moss plants, or algae for biodiesel production. 239 240

r enewable biomass: As defined by the 2007 Energy Independence and Security Act, renewable 241 biomass means each of the following: 242 243

**•** Planted crops and crop residue from agricultural land cleared prior to December 244 19, 2007, and actively managed or fallow on that date. 245

**•** Planted trees and tree residue from tree plantations cleared prior to December 19, 246 2007, and actively managed on that date. 247

**•** Animal waste material and byproducts. 248

**•** Slash and pre-commercial thinnings from non- federal forestlands that are neither 249 old- gro wth nor listed as critically imperiled or rare by a State Natural Heritage 250
program. 251

**•** Biomass cleared from the vicinity of buildings and other areas at risk of wildfire. 252

**•** Algae. 253

**•** Separated yard waste and food waste. 254 255

r enewable fuel: A fuel produced from renewa ble biomass that is used to replace or reduce the 256 use of fossil fuel. 257 258 Renewable Fuels Standard (RFS) program : An EPA program created under the Energy Policy 259 Act (EPAct) of 2005 that established the first renewable fuel volume mandate in the United 260 States . The original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be 261 blended into gasoline by 2012. (See below for RFS2.) 262 263 RFS2: The Renewable Fuels Standard program as revised in response to requirements of the 264 2007 Energy Independence and Security Act. RFS2 increased the volume of renewable fuel 265 required to be blended into transportation fuel to 36 billion gallons per year by 2022. 266 267 RFS2 R egulatory Impact Analysis (RIA): EPA’s analysis of the impacts of the increase in 268 production, distribution, and use of the renewable fuels need to meet the RFS2 volumes 269 established by Congress in the 2007 Energy Independence and Security Act (EISA). 270 271

r iparian forest buffer: An area of trees and shrubs located adjacent to streams, lakes, ponds, 272 and wetla nds that may reduce nutrient loading, soil erosion, and pesticide contamination by 273 removing soil particles and contaminants from overland water flow. 274

r ow crop: A crop planted in rows wide enough to allow cultivators between the rows. Examples 275 include corn, soybeans, peanuts , potatoes, sorghum, sugar beets, sunflowers, tobacco, vegetables, 276 and cotton. 277Appendix A

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s edimentation: The process of solids settling out of water due to gravity. 279 280 short rotation woody crop (SRWC): Fast

- growing tree species grown on plantations and 281 harvested in cycles shorter than is typical of conventional wood products, generally between 3 to 282 15 years. Examples include: hybrid poplars ( Populus spp.), willow ( Salix spp.), Loblolly pine 283 ( Pinus taeda ), and Eucalyptus. 284 285

s oil erosion: The wearing away of land by the action of wind, water, gravity, or a combination 286 thereof. 287 288 soil organic matter: Decomposing plant and animal material in soil. 289 290

s oil quality : The capacity of a specific kind of soil to function, within natural or managed 291 ecosystem boundaries, to sustain plant and animal productivity, maintain or enhance water and 292 air quality, and support human health and habitation. 293 294 sugarcane bagasse: The fibrous material that remains after sugar is pressed from sugarcane. 295 296

s weet sorghum pulp: The bagasse or dry refuse left after the juice is extracted from sweet 297 sorghum stalks during the production of ethanol and other sweet sorghum products. The pulp is 298 usually treated as farm waste in plantations that grow sweet sorghum for biofuel production. 299 300
t ransesterification: In the context of biofuel, the chemical process that reacts an alcohol with 301 triglycerides in vegetable oils and animal fats to produce biodiesel and glycerin. 302 303
t urbidity: A cloudy condition in water due to suspended si lt or organic matter. 304 305

v egetative reproduction: A form of asexual reproduction in plants by which new individuals 306 arise without the production of seeds or spores. It can occur naturally or be induced by 307 horticulturists

. 308 309 water availability: In the context of this report, water availability refers to t he amount of water 310 that can be appropriated from surface water sources (e.g., rivers, streams, lakes) or ground water 311 sources (e.g., aquifers) for consumptive uses. 312 313 water quality: Water quality is a measure of the suitability of water for a particular use based on 314 selected physical, chemical , and biological characteristics. It is most frequently measured by 315 characteristics of the water such as temperature, dissolved oxygen, and poll utant levels, which 316 are compared to numeric standards and guidelines to determine if the water is suitable for a 317 particular use 318 319

w et milling: In the context of biofuel, a process for producing conventional corn starch ethanol 320 in which the corn is soaked in water or dilute acid to separate the grain into its component parts 321 (e.g., starch, protein, germ, oil, kernel fibers) before converting the starch to sugars that are then 322 fermented to ethanol. 323Appendix A

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w oody biomass: Tree biomass thinned from dense stands or cult ivated from fast -growing 325 plantations. This also includes small- diameter and low -value wood residue, such as tree limbs, 326 tops, needles, and bark, which are often by- products of forest management activities. 327 328Appendix B

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## A PPENDIX 

## B: 1

2 

## S UMMARY OF 

## S ELECTED 

## S TATUTORY 

## A UTHORITIES 3 

## H AVING 

## P OTENTIAL 

## I MPACT ON THE 

## P RODUCTION 4


### AND 

## U SE OF 

## B IOFUELS 5Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Clean Air Act (CAA) (http://www.epa.gov/air/caa/)
The CAA defines EPA’s responsibilities for protecting and improving air quality and stratospheric ozone

. It requires EPA to set national ambient air quality standards (NAAQS) for widespread pollutants from numerous and diverse sources considered harmful to public health and the environment

. EPA and s tates must develop regulations to achieve and maintain the NAAQS and to control other pollutants. V ehicle s used for the transportation of feedstock may be subject to an inspection and maintenance program for tailpipe emissions and vehicle emission standa rds for air quality

. **•** A biofuel plant will need to obtain an air operating permit for day

- to

- day facility operations

. Based on potential

- to

- emit, a facility may be required to obtain a Title V Air Operating Permit

. Operating permits will be issued containing emission limits, monitoring, and record keeping requirements.

**•** Pre

- construction permits will be required for initial construction and for changes made to the plant. There are two types of major pre

- construction permits under the New Source Review (NSR) Pr ogram: Prevention of Significant Deterioration permits, and Nonattainment NSR permits

. A minor
pre

- construction permit would be required if major NSR is not required.

**•** A vehicle used for the transportation of biofuels may be subject to an inspection and mai ntenance
program. The CAA regulates the amount of ethanol mixed in gasoline as part of the reformulated gasoline program

.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Clean Water Act (CWA) (http://www.epa.gov/watertrain/cwa/)
The goal of the CWA is to restore and maintain the chemical, physical, and biological integrity of the nation’s waters.

Entities that discharge to waters of the U.S. through point sources (i.e., pipes, ditches, concentrated animal feeding operations), must obtain a National Pollutant Discharge Elimination System (NPDES) permit. These entities include many municipal, industrial, and construction

- related sources of
stormwater.

States develop w ater quality standards (WQS) that define the goals for a water body by designating its uses, setting criteria to protect those uses, and establishing provisions to protect that water body. The CWA requires states to identify waters not meeting WQS and to develop Total Maximum Daily Loads ( TMDLs ) for those waters . T MDLs identify point and nonpoint source loads that can be discharged to a water body and still meet WQS. Agricultural storm water and irrigation returns flows are exempted from NPDES permit requirements.

Under Section 319, EPA provides grants to states to address non

- point

sour ces of pollution. A biofuel production facility typically uses water for cooling and also for washing the biofuel product to remove impurities. The wastewater is discharged either directly to a water body or indirectly to a municipal
wastewater treatment plant. Both are point source discharges, regardless whether the facility uses a septic tank or treatment prior to discharge. Any discharge into a water body by a point source must have a n NPDES permit prior to discharge

. Permits may be required for discharge to a municipal wastewater treatment system, which could include pre

- treatment requirements

. Land application of wastewater may be covered by an NPDES permit if it is determined that pollutants run off the application site to a waterway in a discernable channel or pipe

.
To minimize the impact of site runoff on water quality,

a NPDES stormwater permit must be obtained for discharges to waters of the U.S. from any construction activity that disturbs 1 acre or more of land (including smaller sites that are part of a larger common plan of development)

. Management of emergency response oil discharges must be reported to the National Response Center if they are in a quantity that “may be harmful

. ”Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel CWA: Section 404 Wetlands Program (www.epa.gov/owow/wetlands/laws/)
Section 404 address es the discharges of dredged or fill material into waters of the United States, including wetlands.

Permits are required for activities such as expanded water resource projects ( including dams, impoundments, and levees) and altering or dredging a water of the United States. Most ongoing agricultural maintenance practices are exempt from Section 404

. Generally, Section 404 requires a permit before these materials may be placed in a U.S. wa ter, such as a wetland, stream, river, slough, lake, bay, etc., during construction activities.

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) (http://www.epa.gov/lawsregs/laws/cercla.html) CERCLA provides a f ederal "Superfund" to clean up uncontrolled or abandoned hazardous

- waste sites as well as accidents, spills, and other emergency releases of pollutants and contaminants into the environment. Through CERCLA, EPA was given authority to assure responsible parties’ c ooperation in site cleanup

. CERCLA also regulates the property transfer of these sites. Requirements under CERCLA that may apply include:

**•** Reporting requirements for hazardous substances

.

**•** Implementation and periodic revision of the National Contingency Plan

.

**•** Management by emergency response authorities and responses to discharges of biofuels

.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Emergency Planning and Community Right Know ACT (EPCRA) (http://www.epa.gov/oecaagct/lcra.html) The objective of the EPCRA is to: (1) allow state and local planning for chemical emergencies, (2) provide for notification of emergency releases of chemicals, and (3) address communities' right

to

- know about toxic and hazardous chemicals. Section 302 requires facilities with regulated chemicals (extremely hazard ous substances) above threshold planning quantities to notify the state emergency response commission (SERC) and the local emergency planning committee (LEPC). Section 304 requires facilities to report a release of an extremely hazardous substance. Section 311 requires the facility to have material safety data sheets (MSDSs) on site for hazardous chemicals, as defined by the Occupational Safety and Health Act, that exceed certain quantities and to submit copies to their SERC, LEPC, and local fire department . Section 312 establishes reporting for any hazardous chemical or extremely hazardous chemical that is stored at a facility in excess of the designated threshold planning quantity. These reports are also known as the Tier II hazardous chemical inventory fo rm. Section 313 (Toxics Release Inventory) requires owners or operators of certain facilities that manufacture, process or otherwise use any listed toxic chemicals, or chemical categories, in excess of threshold quantities to report annually to the EPA and to the state in which such facilities are located. Electric utilities are subject to EPCRA Section 313 – Toxic Release Inventory Reporting

.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (http://www.epa.gov/oecaagct/lfra.html)
The objective of FIFRA is to provide federal control of pesticide distribution, sale, and use. EPA reviews and registers pesticides for specified uses and can cancel the registration if information shows continued use would pose unreasonable risk

. Consideratio n is given to worker exposure ecological exposure and food

- chain imports. Hazardous Materials Transportation Act (Regulations codified 49 CFR) ( http:/ /www.phmsa.dot.gov/hazmat/regs and http://www.fmcsa.dot.gov/safety

- security/hazmat/security

- plan

- guide.htm) The Department of Transportation regulations require procedures to be put in place ensuring the safe transport of hazardous materials

. Also, regulation HM

- 232 requires companies to complete a written security assessment and to develop a security plan that is based on the
assessment. Requirements are in place for shippers and carriers of hazardous materials to prepare shipments for tran sport, placard containers for easy identification of hazards, and ensure the safe loading, unloading, and transport of materials

. HM

- 232 requires companies to complete a written security assessment and to develop a security plan that is based on the assess ment.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel National Environmental Policy Act (NEPA) (http://www.epa.gov/compliance/nepa/) NEPA requires federal agencies to integrate environmental values into their decision making processes by considering the environmental impacts of their proposed actions and reasonable alternatives to those actions. To meet NEPA requirements in certain circ umstances federal agencies prepare a detailed statement known as an Environmental Impact Statement (EIS). If federal money is being used to partially or entirely finance the construct ion of a biofuel plant or any associated facility, such as an access road or water supply facility , then construction of the plant may be subject to NEPA. NEPA requires federal agencies to incorporate environmental considerations in their planning and decision

- making and to prepare a detailed statement assessing the environmental impact of activities and alternatives that significantly affect the environment.

Oil Pollution Act (OPA) of 1990 (http://www.epa.gov/lawsregs/laws/opa.html)
The OPA of 1990 streamlined and strengthened EPA’s ability to prevent and respond to catastrophic oil spills

. A trust fund financed by a tax on oil is available to clean up spills when the responsible party is incapable or unwilling to do so

. The OPA requires oil storage facilities and vessels to submit to the Federal government plans deta iling how they will respond to large discharges. Provides that the responsible party for a vessel or facility from which oil is discharged, or which poses a substantial threat of a discharge, is liable for: (1) certain specified damages resulting from t he discharged oil; and (2) removal costs incurred in a manner consistent with the National Contingency Plan. Provides for spill contingency plans and mandates development of response plans for worst case discharge; and provides for requirements for spill

r emoval equipment

. Oil Spill Plans must be in place prior to operation, at facilities that have the potential to spill oil to navigable waters.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel
Renewable Fuel Standard (RFS) (http://www.epa.gov/otaq/fuels/renewablefuels/index.htm) The RFS program was created under the Energy Policy Act (EPAct) of 2005, and established the first renewable fuel volume mandate in the United States. As required under EPAct, the original RFS program (RFS1) required 7.5 billion gallons of renewable fuel to be blended into gasoline by 2012. Under the Energy Independence and Security Act (EISA) of 2007, the RFS program was expanded. EISA also required EPA to apply lifecycle greenhouse gas (GHG) performance threshold standards. The GHG requirement is that the lifecycle GHG emiss ions of a qualifying renewable fuel must be less than the lifecycle GHG emissions of the 2005 baseline average gasoline or diesel fuel that it replaces. Four different levels of reductions are required for the four different renewable fuel standards: Renew able Fuel (20%); Advanced Biofuel (50%); Biomass

- based Diesel (50%); and Cellulosic Biofuel (60%). If a facility produces 10,000 gallons or more of renewable fuel per year, then it may participate in the RFS p rogram , though it is not required to do so. I f a facility chooses to participate in the RFS program, it must satisfy the following criteria :

**•** Register

**•** Generate renewable identification

**•** Transfer RIN s with fuel

**•** Provide product transfer documents

**•** Follow blending requirements

**•** Follow exporting requirement s

**•** Follow non

- road use of fuel

**•** Attest engagements

**•** Keep records for 5 years

**•** Report quarterlyAppendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Resource Conservation and Recovery Act (RCRA) (http://www.epa.gov/lawsregs/laws/rcra.html) RCRA gives EPA the authority to control hazardous waste generation, transportation, treatment, storage, and disposal of hazardous waste. Facilities that handle hazardous waste are required to obtain an operating permit from the state agency or EPA

. RCRA regulates USTs

. Regulatory issues related to waste generated by bio fuel production - solid and hazardous waste include:

**•** New regula tions on storage and transport of fuel related to expanded use of biofuels

.

**•** New concerns related to assessing compatibility of fuel storage systems, managing water in storage tanks, protecting against corrosiveness and conductivity, managing methane formation, and detecting, preventing and responding to storage tank and pipe leaks and spills

.

**•** Management of emergency response authorities and responses to biofuels spills

. UST leak detection and prevention are required

.

Safe Drinking Water Act (SDWA) (http://www.epa.gov/ogwdw/sdwa/)
The SDWA is the federal law that protects the safety of water distributed by public water systems. Under SDWA, EPA has National Primary Drinking Water Regulations for more than 90 contaminants and rules regarding monitoring of treated drinking water as well as reporting and public notification. There are a number of threats to drinking water: anthropogenic chemicals including pesticides and improperly disposed chemi cals; animal wastes; and naturally occurring substances. A primary impact to drinking water is nitrate pollution from
row crops. Wastewater from biofuel production facilities or corn starch ethanol facilities and leaking biofuel storage tanks can contamin ate surface and ground drinking water resources, requiring treatment under SDWA.Appendix B

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- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Safe Drinking Water Act: Underground Injection Control (UIC) Program (http://www.epa.gov/safewater/uic/)
The UIC program protects underground sources of drinking water by regulating the construction, operation, permitting, and closure of injection wells that place fluids underground for storage or disposal. Agriculture drainage wells are Class V UIC wells. They are primaril y regulated under state law. A biofuels plant is subject to the requirements of the UIC Program if any of the following apply:

**•** It is disposing of storm water, cooling water, industrial or other fluids into the subsurface via an injection well;

**•** It has an on

- site sanitary waste disposal system (e.g., septic system) that serves or has the capacity to serve 20 or more persons;

**•** It has an on

- site sanitary waste disposal system that is receiving other than a solely sanitary waste stream regardless of its capaci ty; or

**•** It is undergoing a remediation process where fluids are being introduced into the subsurface via an injection well to facilitate or enhance the cleanup. Spill Prevention, Control and Countermeasure (SPCC) and Facility Response Plans (FRP) (http://www.epa.gov/oem/content/spcc/index.htm)
The SPCC rule includes requirements for oil spill prevention, preparedness, and response to prevent oil discharges to navigable waters and adjoining shorelines. The rule requires specific facilities to prepare, amend, and implement SPCC Plans. The SPCC rule is part of the Oil Pollution Prevention regulation, which also includes the Facility Response Plan (FRP) rule. The SPCC program requires certain farms (e.g., those that store oil and could reasonably be expected to discharge oil to waters of the US) to prepare and implement an SPCC Plan. A biofuel facility is subject to this regulation if the following apply :

**•** It is non

- transportation related

.

**•** It has a total above

- ground oil storage capacity greater tha n 1,320 gallons or a completely buried oil storage capacity greater than 42,000 gallons

.

**•** There is a reasonable expectation of an oil discharge into or upon navigable waters of the U.S. or adjoining shorelines

.

**•** S econdary containment cannot be provided for all regulated oil storage tanks.Appendix B

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— DO NOT CITE OR QUOTE Table B

- 1: Summary of Selected Statutory Authorities Having Potential Impact on the Production and Use of Biofuels

Summary of Statute/Program Stage of Lifecycle
Feedstock Production and Transport Biofuel Production, Transport, and Storage Use of Biofuel Toxic Substances Control Act (TSCA) (http://www.epa.gov/lawsregs/laws/tsca.html) TSCA gives EPA broad authority to identify and control chemical substances that may pose a threat to human health or the environment

. EPA's Office of Pollution Prevention and Toxics operates both the New Chemicals Program and the Biotechnology Program under Section 5 of TSCA

. Both programs were established to help manage the potential risk from chemical substances and genetically

- enginee red (intergeneric) microorganisms new to the marketplace or applied in significant new uses

. Additional sections of TSCA give EPA the broad authority to issue toxicity testing orders or to regulate the use of any existing chemicals that pose unreasonable risk. Notification and review of new intergeneric genetically engineered microbes (e.g. bacteria, fungi and algae) used to produce biofuels feedstocks. Mandatory notification and approval for new chemicals and new biological products, prior to manufacture and commercial use

. New uses of chemicals are subject to review for potential environmental hazards under the Signifi cant New Use Notification process

. As a result of the review process, health and environmental effects testing of existing or new chemicals that pose unreasonable risk may be required

. EPA may also restrict use and handling of chemicals or biological products as a result of their review.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-1 DRAFT

— DO NOT CITE OR QUOTE 

## Appendix C 1

2 

## Basis for Figures 6

- 1, 6

- 2, and 7 -3 3Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-2 DRAFT

— DO NOT CITE OR QUOTE This appendix presents three tables, Tables C- 1, C -2, and C-3, which summarize the information providing the basis for 4 Figures 6 -1, 6-2, and 7-3, respectively. For each of the six feedstocks included in this report, Tables C-1 and C- 2 briefly describe the 5 current production status (Background), as well as the conditions anticipated to result in the most n egative environmental effect (Most 6 Negative Future Scenario) and the most positive environmental effect (Most Positive Future Scenario) in each of the environme ntal 7 media considered. Table C -3 describes the basis for the three scenarios included in Figure 7-3. 8 9 Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactCorn Starch Most current corn feedstock cultivation for biofuel production is a result of either 1) dis placing soy production

, 2) diverting existing corn grain to processing for fuel, or 3) placing former
ag ricultural land back into production. Water Quality Corn grown with conventional tillage and high chemical inputs replaces lands in the Conservation Reserve Program ( CRP ). Corn grown with comprehensive conservation practices replaces corn grown with existing production systems. Water Quantity Irrigated c orn replaces non

- irrigated land use in drier area. Production of non

- irrigated c orn

.

Soil Quality Corn grown with conventional tillage and high chemical inputs replaces lands in the Conservation Reserve Program ( CRP ). Corn grown with comprehensive conservation practices replaces corn grown with existing production systems. Air Quality Irrigated c orn grown with conventional tillage and high chemical inputs replaces lands in the Conservation Reserve Program ( CRP ). Corn grown with comprehensive conservation practices replaces corn grown with existing production systems.

Biodiversity Corn grown with conventional tillage and high chemical inputs replaces lands in the Conservation Reserve Program ( CRP ). Corn grown with comprehensive conservation practices replaces corn grown with existing production systems.

Invasive ness Negligible known effect

. Negligible kno wn effect

.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-3 DRAFT

— DO NOT CITE OR QUOTE Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactSoybean Most current soybean biofuel production comes from increased allocation of existing harvest to biodiesel. Water Quality Soy replaces lands in the Conservation Reserve Program ( CRP ). Soy grown with comprehensive conservation practices replaces c orn grown with conventional tillage and high chemical inputs. Water Quantity Irrigated soy replaces non

- irrigated land use in drier area. Non

- irrigated soy replaces irrigated corn.

Soil Quality Soy replaces lands in the Conservation Reserve Program ( CRP ). Soy grown with comprehensive conservation practices replaces c orn grown with conventional tillage and high chemical inputs. Air Quality Irrigated soy replaces non

- irrigated land use in drier area. Non

- irrigated soy grown with comprehensive conservation practices replaces c orn grown with conventional tillage and high chemical inputs. Biodiversity Soy replaces lands in the Conservation Reserve Program ( CRP ). Soy grown with comprehensive conservation practices is diverted from existing production systems.
Invasive ness Negligible known effect

. Negligible known effect

.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-4 DRAFT

— DO NOT CITE OR QUOTE Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactCorn Stover Not currently produced commercial ly for biofuel feedstock. Water Quality High rate of stover removal on highly erodible land. Appropriate rate of s tover removal to minimize erosion given site

- specific characteristics and management practices.

Water Quantity High rate of stover removal on irrigated land in drier areas. Appropriate rate of s tover removal to minimize additional irrigation given site

specific characteristics and management practices. Soil Quality High rate of stover removal on highly erodible land with low organic matter soil. Appropriate rate of s tover removal to minimize erosion given site

- specific characteristics and management practices. Air Quality High stover removal requires additional harvesting pass and increased subsequent fertilizer applications. Appropriate rate of stover removal to minimize subsequent fertilizer applications; stover removed with corn in a single harvesting pass. Biodiversity High rate of stover removal on highly erodible land that results in sedimentation to aquatic systems. Appropriate rate of s tover removal to

m inimize erosion given site

- specific characteristics and management practices.
Invasiveness Negligible known effect

. Negligible known effect

.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-5 DRAFT

— DO NOT CITE OR QUOTE Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactWoody Biomass Not currently produced commercial ly for biofuel feedstock. Water Quality Short

- rotation woody crops ( SRWC ) with short replanting intervals and high chemical inputs, and without coppicing replace mature, managed tree plantations. Short

- rotation, coppiced woody crops with long replanting intervals, and low chemical inputs replace non

- coppiced, managed forests with short replanting intervals, and high chemical inputs. Water Quantity Irrigated SRWCs are g rown in drier region s. Production of non

- irrigated SRWC in wetter regions.

or Low to moderate rate of forest residue removal or thinning

. Soil Quality SRWC with short replanting intervals and without coppicing replace mature, managed tree plantations. Short

- rotation, coppiced woody crops with long replanting intervals, and low chemical inputs replace non

- coppiced, managed forests with short replanting intervals, and high chemical inputs. Air Quality SRWC with short replanting intervals, high chemical inputs, high isoprene emissions, and without coppicing replace mature, managed, low

- isoprene emitting tree plantations. Short

- rotation, coppiced woody crops with long replanting intervals, low chemical inputs and low isoprene emissions replace

non

- coppiced, managed forests with short replanting intervals, high chemical inputs, and high isoprene emissions. Biodiversity SRWC with short r eplanting intervals and high chemical inputs, and without coppicing replace mature, managed tree plantations. Long rotation woody crop stands replace SRWC with short replanting intervals and high chemical inputs.

Invasive ness Woody species (e.g.

, E. grandis ) are grown and become invasive

. Production and harvesting of non

- invasive woody species.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-6 DRAFT

— DO NOT CITE OR QUOTE Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactPerennial Grass Not currently produced commercial ly for biofuel feedstock. Water Quality Perennial grasses established with conventional tillage and grown with a short planting interval and chemical inputs replace land in the CRP. Perennial grasses established with no till grown with low chemical inputs and a long replanting interval replace corn grown with conventional tillage and high chemical inputs. Water Quantity Irrigated perennial grasses re place non

irrigated land use in drier regions

. Non

- irrigated perennial grass es replace irrigated corn. Soil Quality Perennial grasses established with conventional tillage and grown with a short planting interval and chemical inputs replace land in the CRP. Perennial grasses established with no till with a long replanting interval replace conventionally tilled row crops

.

Air Quality Irrigated perennial grasses established with conventional tillage and grown with a short planting interval and chemical inputs replace land in the CRP. Non

- irrigated perennial grasses established with no till and grown with low chemical inputs and a long replanting interval replace irrigated corn grown with conventional till age and high chemical inputs. Biodiversity Uniformly

- managed perennial grasses established with conventional tillage and grown with a short planting interval and chemical inputs replace land in the CRP. Perennial grasses grown with low chemical inputs replace corn grown with conventional tillage and high chemical inputs.

Invasiveness S witchgrass (west of the Rockies) and Miscanthus are grown and become invasive or weedy. Production of non

- invasive native grasses or
g rass varieties bred for decreas ed invasiveness or weediness (e.g., sterile varieties)

.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-7 DRAFT

— DO NOT CITE OR QUOTE Table C

- 1: Basis for Figure 6

- 1 ( Maximum Potential Range of Environmental Impacts [ on a P er U nit A rea B asis ] R esulting from Cultivation and Harvesting of the Six B iofuel F eedstocks C onsidered in this R eport )

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactAlgae Not currently produced commercial ly for biofuel feedstock. Water Quality Untreated effluent from growing algae is discharged to the environment

. Algae are grown with wastewater; treated effluent is recycled for further use. Water Quantity Algae are grown in drier regions (e.g.

, Southwest) with freshwater in open ponds. Algae are g rown with wastewater in closed bioreactors; treated effluent is recycled for further use. Soil Quality Negligible known effect

. Negligible known effect Air Quality Algae grown with added nutrients. Algae grown with nutrients in wastewater. Biodiversity Negligible known effect

. Negligible known effect

. Invasiveness Invasive algae species grown in open ponds escape and proliferate. Production of non

- invasive algae species in closed bioreactors.
10Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-8 DRAFT

— DO NOT CITE OR QUOTE Table C

- 2: Basis for Figure 6

- 2 (Maximum Potential Range of E nvironmental Impacts [ on a P er U nit V olume Basis] R esulting from Ethanol and B iodiesel P roduction , Transport, Storage and Use)

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactCorn Ethanol As of 2009, 180 corn ethanol facilities

were operating in the U.S. , mostly in the Midwest. Future corn ethanol production is expected to expand in the same region. Water Quality Effluent with high biological oxygen demand ( BOD ); Dried Distillers Grain (DDG) byproduct fed to livestock with inadequate waste managem ent practices; under

- ground storage tanks (UST) leak. Effluent effectively treated for BOD; DDG

- fed livestock waste incorporated into comprehensive nutrient management plan; USTs do not leak.

Water Quantity 3

- 6 gal lons of water required per gal lon of ethanol produced

. Improvement in water use efficiency and recycling

. Air Quality Ethanol facility powered by coal. Ethanol facility powered by natural gas.SoybeanBiodiesel In 2009, 191 biodiesel facilities were operating in the U.S., many producing under their capacity. Water Quality Effluent with high BOD, total suspended solids ( TSS ) and glycerin content. Effluent effectively treated for BOD, TSS and glycerin.

Water Quantity <1 gal lon of water required per gal lon of biodiesel produced

. <1 gal lon of water required per gal lon of biodiesel produced

. Air Quality Biodiesel facility powered by coal. Biodiesel facility power by natural gas.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-9 DRAFT

— DO NOT CITE OR QUOTE Table C

- 2: Basis for Figure 6

- 2 (Maximum Potential Range of E nvironmental Impacts [ on a P er U nit V olume Basis] R esulting from Ethanol and B iodiesel P roduction , Transport, Storage and Use)

Background Impact Category Conditions for Maximum Potential Negative Environmental Impact Conditions for Maximum Potential Positive Environmental ImpactCellulosicEthanol As of 2009, there were n o commercially operating cellulosic ethanol facilities in the U.S

. There is u ncertainty about when and where the first facilities will start producing. Water Quality Effluent possibly with high BOD ; USTs leak. Effluent effectively treated for BOD; USTs do not leak. Water Quantity 10 gal lons of water required per gal lon of cellulosic ethanol

. Improvement in water use efficiency and recycling

. Air Quality Ethanol facility powered by coal. Ethanol facility powered by natural gas.

11Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-10 DRAFT

— DO NOT CITE OR QUOTE Table C

- 3: Description of Scenarios in Figure 7

- 3 ( Cumulative Domestic Environmental Impacts of All Steps in the Biofuel Supply Chain System under Three Scenarios in 2022 )

Feedstock Scenario A
2022 RFS2

- projected feedstock mix produced with conservation/best management practices (BMPs) and efficient technologies Scenario B
2022 RFS2

- projected feedstock mix produced with minimal conservation/BMPs and current technologies Scenario C 2022 conventional feedstock mix (corn starch, corn stover, and soybean) produced with minimal conservation/BMPs and current technologies

Conventional EthanolCorn Starch 15 BG

**•** No decrease in crop rotation with soybeans. **•** Increased use of continuous corn production and reduction in crop rotation.

**•** Increases in grain yield primarily due to breeding new varieties that also require fewer production inputs, including fertilizer, pesticides

, and irrigation. **•** Increased grain yields using greater production inputs, including fertilizer, pesticides

, and irrigation

.

**•** No conversion of marginal lands to corn production. **•** Conversion of marginal land to corn production, including in areas that require irrigation.

**•** Increased use of conservation practices, including conservation tillage, nutrient management

, and efficient irrigation delivery. **•** No increases in conservation practices.

**•** Increased fuel conversion efficiency and reductions in fuel production inputs, including fresh water. **•** No increases in fuel conversion efficiency n or reductions in fuel production inputs.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-11 DRAFT

— DO NOT CITE OR QUOTE Table C

- 3: Description of Scenarios in Figure 7

- 3 ( Cumulative Domestic Environmental Impacts of All Steps in the Biofuel Supply Chain System under Three Scenarios in 2022 )

Feedstock Scenario A
2022 RFS2

- projected feedstock mix produced with conservation/best management practices (BMPs) and efficient technologies Scenario B
2022 RFS2

- projected feedstock mix produced with minimal conservation/BMPs and current technologies Scenario C 2022 conventional feedstock mix (corn starch, corn stover, and soybean) produced with minimal conservation/BMPs and current technologies

Cellulosic E thanolCornStover 4.9 BG 16 BG

**•** Stover harvest limited to acreage with low erosion potential

, or erosion is mitigated with conservation tillage. **•** Stover harvest ed on acreage regardless of erosion potential.

**•** Stover harvested with single

- pass harvester. **•** Stover harvested with multi

- pass harvester

.

**•** Increase d use of conservation practices. **•** No increase in use of conservation practices.WoodyBiomass 0.1 BG 0 BG

**•** Biomass produced via l ight

- to

- moderate forest thinning or from short

- rotation woody crops cultivated with long planting intervals on non

- federal land currently in managed forest with short planting intervals

. **•** Short

- rotation woody crops with short planting intervals and high che mical inputs cultivated on non

federal land currently in mature, managed forest plantations

.Perennial Grass 7.9 BG from dedicated energy crops 0 BG

**•** Switchgrass production area limited to east of Rocky Mountains. **•** Cellulosic feedstock (switchgrass or Miscanthus ) produced on marginal land requiring high production inputs, including fertilizer, pesticides

, and irrigation. **•** Conversion of land currently in row crop production to switchgrass production.

**•** Conversion of low diversity, marginal land to conservation managed switchgrass production.

**•** Increased fuel conversion efficiency and reductions in fuel production inputs, including fresh water. **•** No increases in fuel conversion efficiency or reductions in fuel production inputs, including fresh
water.Appendix C

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 C-12 DRAFT

— DO NOT CITE OR QUOTE Table C

- 3: Description of Scenarios in Figure 7

- 3 ( Cumulative Domestic Environmental Impacts of All Steps in the Biofuel Supply Chain System under Three Scenarios in 2022 )

Feedstock Scenario A
2022 RFS2

- projected feedstock mix produced with conservation/best management practices (BMPs) and efficient technologies Scenario B
2022 RFS2

- projected feedstock mix produced with minimal conservation/BMPs and current technologies Scenario C 2022 conventional feedstock mix (corn starch, corn stover, and soybean) produced with minimal conservation/BMPs and current technologies

Biomass

- based D ieselSoybean 0.66 BG 1 BG

**•** Increases in yield primarily due to breeding new varieties that also require fewer production inputs, including fertilizer, pesticides

, and irrigation. **•** Increases in yield primarily due to higher production inputs, including fertilizer, pesticides

, and irrigation.

**•** No conversion of marginal lands to soybean production. **•** Conversion of marginal lands to soybean production, including areas requiring irrigation.

**•** Increased use of conservation practices, including conservation tillage, nutrient management

, and efficient irrigation delivery. **•** No increase in use of conservation practices (i.e., conservation tillage, nutrient management

, and efficient irrigation delivery ).Algae 0.1 BG 0 BG

**•** Algae production co

- located with stationary carbon dioxide source on marginal land. **•** Algae produc ed on land converted from natural cover.

**•** Nutrient inputs from wastewater or other waste sources. **•** Large nutrient inputs from non

waste sources.

**•** Closed bioreactors co

- located with publicly owned treatment works and other wastewater treatment facilities. **•** Open pond production using fresh
water. 12Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-1 DRAFT

— DO NOT CITE OR QUOTE 

## A PPENDIX 

## D: 1

2 

## C ONCEPTUAL 

## M ODELS 3 4 5Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-2 DRAFT

— DO NOT CITE OR QUOTE As d escribed in this report, the activities associated with cultivation of biofuel feedstocks 6 and their conversion to fuel result in a complex set of inter

- related environmental impacts. 7 Conceptual models provide a useful tool to describe, understand, and comm unicate the complex 8 pathways by which these activities lead to impacts. As noted in Chapter 7, EPA anticipates 9 developing and using conceptual models as an important tool for the assessment in its 2013 10 Report to Congress. The conceptual models presented in this appendix lay a foundation for this 11 future effort. Figures D-1 to D-7 present conceptual models for feedstock cultivation and harvest. 12 Figures D-8 and D-9 present models for biofuel production and distribution. (Note that models 13 are not included for end use of biofuel.) These early renditions graphically present the 14 environmental effects most commonly identified in current peer- reviewed literature and, while 15 comprehensive, do not attempt to include all possible effects. 16

17

19 Feedstock Production 18

Figures D-1 to D-7 present seven models for the six feedstocks covered in this report: 20 corn starch; soybean; corn stover; perennial grass; woody biomass (short-rotation woody crops 21 and forest thinning/residue removal); and algae production. 22

Different pathways are introduced at the top of several of these feedstocks models. These 23 pathways were selected because: (1) they will likely be pursued in combination in order to grow 24 enough feedstock to meet RFS2 2022 biofuel requirements (see Chapter 2 for a description of 25 requirements ), and (2) they result in different environmental impacts. 26

Arrows in the impact boxes (below the initial row of activities) depict whether the 27 impacts are negative or positive. The number(s) by each arr ow designate the pathway to which 28 the arrows refer. A few pathways can have both negative and positive impacts (e.g., corn starch 29 cultivation could result in increased or decreased use of ground and surface water). Dotted 30 borders denote impacts that have a relatively large degree of uncertainty due to a lack of 31 Terms and Abbreviations Used in the Conceptual Models From the Legend

**•** b iotic response - Response of living parts of terrestrial or aquatic ecosystems, either in terms of numbe r of species or numbers of individuals of a particular species

**•** e cosystem service - Direct or indirect contribution of the environment to human well

- being

**•** e nvironmental parameter - A measureable attribute of the environment

From the Diagrams

**•** a quatic life use support - A beneficial use designation in which the water body provides suitable habitat for survival and reproduction of desirable fish, shellfish, and other aquatic organisms (this is a synthetic quality made up of many different environmental paramet ers)

**•** BOD - biological oxygen demand

**•** c ontamination - R elease of nutrients or pesticides used in feedstock production to waterways or bodies of
water

**•** PM – particulate matter

**•** T & E species - threatened and endangered species

**•** VOC – volatile organic compoundAppendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-3 DRAFT

— DO NOT CITE OR QUOTE information. Dotted boxes without arrows depict highly uncertain impacts that nonetheless are 32 described in the literature. 33

35 Fuel Production and Distribution 34

Figures D-8 and D-9 present conceptual mo dels for production and distribution of the 36 two biofuels covered in this report: ethanol and biodiesel. 37

Ethanol Production 38 39 Figure D -8 shows the activities and impacts associated with production and distribution 40 of ethanol from both starch (i.e., corn grain) and cellulosic feedstocks, including corn stover, 41 perennial grasses, and woody biomass. A single model is provided for these four types of 42 feedstocks because their impacts and associated uncertainty are largely similar, with a few 43 exceptions ( e.g., wate r use will likely be slightly higher for cellulose conversion). 44

As depicted in the upper left of the Figure D-8, conversion of starch to ethanol consists of 45 several sequential steps, including milling, hydrolysis, and fermentation. There currently are two 46 distinct alternatives for converting cellulosic feedstock into ethanol: (1) biochemical conversion 47 (which is preceded by a catalysis step to separate cellulose and hemicellulose from their tightly 48 bound state with lignin), and (2) thermochemical conversio n. These alternatives vary slightly in 49 terms of their chemical processes and by -products. As with Figures D-1 to D-7, a dotted border 50 is used to denote i mpacts with relatively large uncertainty due to a lack of information

. 51

Biodiesel Production 52 53 Figure D -9 shows the activities and impacts associated with production of biodiesel from 54 soybeans and algae. Several techniques may be used to convert plant oils into biodiesel, 55 including hydrogenation, catalytic cracking, and transesterification. All these processes produce 56 biodiesel, with glycerin as a by-product. 57Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-4 DRAFT

— DO NOT CITE OR QUOTE 58 59 Figure D

- 1: Pathways for Potentia l Environmental Impacts of C orn Starch Feedstock Cultivat ion 60Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-5 DRAFT

— DO NOT CITE OR QUOTE 61 62 Figure D

- 2: Pathways for Potential Environmental Impacts of Soybean Feedstock Cultivation 63

. 64Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-6 DRAFT

— DO NOT CITE OR QUOTE 65 66 Figure D

- 3: Pathways for Potential Environmental Impacts of Corn Stover Feedstock Cultivation* 67 *Corn stover is a waste product of corn starch cultivation. The impacts of corn cultivation are shown in Figure D

- 1. Figure D

- 3 highlights the 68 environmental impacts of stover removal above and beyond those impacts attributable to corn grain production. 69Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-7 DRAFT

— DO NOT CITE OR QUOTE 70 71 Figure D

- 4: Pathways for Potential Environmental Impacts of Perennial Grass Feedstock Cultivation 72Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-8 DRAFT

— DO NOT CITE OR QUOTE 73 74 Figure D

- 5: Pathways for Potential Enviro nmental Impacts of Short- Rotati on Woody Crop Feedstock Cultivation 75 *These particular land use changes may not currently be allowable under RFS2. 76Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-9 DRAFT

— DO NOT CITE OR QUOTE 77 78 Figure D

- 6: Pathways for Potential Environmental Impacts of Forest Thinning and Residue Removal 79Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-10 DRAFT

— DO NOT CITE OR QUOTE 80 81 Figure D

- 7: Potential Environmental Impacts of Algae Feedstock Production 82Appendix D

This document is a draft for review purposes only and does not constitute Agency policy. 1/19/11 D-11 DRAFT

— DO NOT CITE OR QUOTE 83 84 Figure D

- 8 : Potential Environmental Impacts of Producing and Distributing Conventional and Cellulosic Ethanol 85 (Impacts of Fuel Use N ot Included) 86Appendix D

This document is a draft for review purposes only and does not constitute Agency polic y. 1/19/11 D-12 DRAFT

— DO NOT CITE OR QUOTE 87 88 Figure D

- 9: Potential Environmental Impacts of Producing and Distributing Biodiesel 89 (Impacts of Fuel Use N ot Included) 90 91