NWF Comments:

Dear ChristopherThank you for the opportunity to provide input into EPA’s literature review on jatropha. While I do not have 

any comments related specifically to lifecycle GHG emissions of jatropha, I do have two comments on 

behalf of the National Wildlife Federation:

1. NWF is very concerned about the potential for jatropha (and other feedstocks) to become 

invasive and cause economic and ecological damage While jatropha is not necessarily invasive, 

and certainly not necessarily invasive everywhere – we believe that there is enough in the 

literature on the potential for jatropha to become invasive to warrant further investigation, 

including through a literature review and a weed risk assessment. We urge EPA to include this 

vital assessment as part of the RFS pathway approval process. Under Executive Order 13112, 

(issued Feb 3, 1999), a federal agency cannot take action that causes or promotes the spread of 

invasive species unless the agency has publicly determined that the benefits of such actions 

clearly outweigh the potential harm. Therefore, we believe that EPA must evaluate the invasive 

potential of jatropha. To that end, I’ve included a list of publications that would be useful in 

evaluating the invasive potential of jatropha. Additionally, I am attaching a letter signed by over 

200 scientists from 41 states calling on federal agencies to comply with the E.O. 13112 and do an 

assessment of the invasion risk of bioenergy feedstocks before they are eligible for federal 

incentives that pave the way for their cultivation.

2. The use of the term “jatropha” as a common name is vague and therefore problematic. 

Jatropha refers to a genus, not a species. There are around 170 species included in the genus 

jatropha, each with different characteristics- and likely a different GHG profile. NWF strongly 

believes that full scientific taxonomy – including genus and species, as well as subspecies, 

cultivar, hybrid, or variety when applicable—should be used in RFS feedstock pathway 

rulemaking in order to be as specific as possible and prevent problems down the line.

Thank you for your consideration. I’d be happy to answer any questions or to come in and discuss these 

issues with you further.

Regards,

Aviva Glaser

Suggested literature on jatropha invasive potential

Chimera, C, CE Buddenhagen, and PM Clifford. 2010. Biofuels: the risks and dangers of introducing 

invasive species. Biofuels 1(5): 785-796.

Csurhes, SM. 1999. Bellyache bush (Jatropha gossypiifolia) in Queensland. Pest Status Review 

Series. Queensland, Australia.

Gordon, DR, KJ Tancig, DA Onderdonk, and CA Gantz. 2011. Assessing the invasive potential of biofuel 

species proposed for Florida and the United States using the Australian Weed Risk 

Assessment. Biomass and Bioenergy 35(1): 74-79.

Heard, TA, RR Chan, and R Segura. 2002. Prospects for the biological control of bellyache 

bush, Jatropha gossypiifolia. Thirteenth Australian Weeds 

Conference. http://www.caws.org.au/awc/2002/awc200213661.pdf.

Henderson, L. 20007. Invasive, naturalized, and casual alien plants in southern Africa: a summary based 

on the Southern African Plant Invaders Atlas (SAPIA). Bothalia 27(2): 215-248.

Low, T and C Booth. 2007. The Weedy Truth about biofuels. Published by the Invasive Species Council. 

http://www.lifeofthelandhawaii.org/Bio_Documents/2007.0346/LOL_EXH_7_Weedy_Truth.pdf

Prentis, PJ, DP Sigg, S Raghu, K Dhileepan, A Pavasovic, and AJ Lowe. 2009. Understanding invasion 

history: genetic structure and diversity of two globally invasive plants and implications for their 

management. Diversity and Distributions 15(5): 822-830.
Sahoo, NK, A Kumar, S Sharma, and SN Naik. 2009. Interaction of Jatropha Plantation with 

Ecosystem. Proceedings of International Conference on Energy and Environment ISSN: 2070-3740.

------------------------------------

Aviva Glaser

Legislative Representative, Agriculture Policy

National Wildlife Federation

901 E St. NW, Suite 400

Washington, DC 20004

202-797-6616

GlaserA@nwf.org