CATF & Achten comments:

Chris

-- In response to your request (below) for input regarding additional literature or data that should be included in the analysis of the lifecy cle GHG emissions of jatropha

- based biofuels, the Clean Air Task Force strongly encourages EPA and RTI to bolster con sideration of all production

- related land use change emissions in the final report. As a general matter, a full assessment of GHG emissions from land use changes

-- especially indirect land use change

-- that are connected to policy

- driven increases in bi ofuel production must be part of ever y lifecy cle analy sis conducted to determine RFS eligibility. This is more than just a legal requirement, it's an essential part of developing a fuller understanding of the net environmental impact associated with poten tially eligible biofuels. Numerous studies have shown that lifecycle analyses that fail to account for ILUC emissions aren't just incomplete, they are dangerously misleading. The September 2012 draft report recognizes the need to examine land use impacts

. The papers cited in the draft report indicate that jatropha grown on good farmland fares much better than jatropha grown on ma rginal land (an intuitively obvious point that is nonetheless often ignored), and that jatropha typically requires significantl y m ore water and fertilizer than was previously thought in order to achieve commercial yi elds. "Research demonstrates that marginal lands typically produce poor yields and that the highest yi elds come from more productive lands and more intensive producti on practices," the authors write in the intro. "This is consistent with historical experience with production of other crops, but means that jatropha production is more likely to compete for land used to produce alternative crops than was originally antic ipated." (p1

- 1) It was discouraging, then, to find that only one of the papers cited in the draft report looks explicitly at ILUC. I connected with the author of that paper, Dr. W outer Achten of KU Leuven in the Netherlands, to ask if he had any feedback on the draft report and/or any suggestions on additional resources that EPA and RTI should consider. Dr. Achten, who is copied here, wrote the following: I had a quick look at the references used in the report, I didn’t take the time (yet) to get into t he conclusions drawn from the studies brought together. Concerning the completeness of the literature overview, I can make some more suggestions (see list of papers below).Concerning the completeness of the literature overview, I can make some more suggest ions (see list of papers below). ILUC is not all that easy, an is indeed not often included in global warming potential quantifications, however, Lapola et al. have done a very relevant study in Brazil (see attach, although the main paper does not focus on Jatropha the supporting information contains information on the LUC and ILUC Jatropha can trigger in Brazil and what kind of impacts that can have). Further it is worthwhile to take a look at 3 other studies in which the direct land use change is consi dered (in quite different ways and on different scales) (Achten et al. 2012, Bailis & McCarthy 2011 and Romijn 2011). Concerning LCA studies... there are actually several more. The first 3 I list I used myself to compare my results with, but one can actual ly find more (and more recent) (when I do a quick search), but I have no insight in their quality. [...] Impact quantification of land use change (not necessarily incorporated in LCA method, but linked with LCA results) Lapola, D. M., R. Schaldach, J. Alcamo, A. Bondeau, J. Kock, C. Koelking, and J. A. Priess. 2010. Indirect land

- use changes can overcome carbon savings from biofuels in Brazil. Proceedings of the National Academy of Sciences of the United States of America 107:3388

– 3393. http://dx.doi.org/10.1073/ pnas.0907318107Title: Carbon impacts of direct land use change in semiarid woodlands converted to biof uel plantations in India and Brazil Author(s): Bailis, Rob; McCarthy, Heather Source: GLOBAL CHANGE BIOLOGY BIOENERGY Volume: 3 Issue: 6 Pages: 449

- 460 DOI: 10.1111/j.1757

- 1707.2011.01100.x Achten,W.M.J., et al., Global greenhouse gas implications of land conversion to biofuel crop cultivation in arid and semi

- arid lands eLessons learned from Jatropha, Journal of Arid Environments (2012), http://dx.doi.org/10.1016/j.jaridenv.2012.06.0 15 Romijn, H. A. 2011. Land clearing and greenhouse gas emissions from Jatropha biofuels on African miombo woodlands. Energy Policy 39:5751

– 5762
Dr. Achten also suggested several additional studies that do not take land use change into account:

Ou , X. M., X. C. Zhang, S. Y. Chang, and Q. F. Guo. 2009. Energy consumption and GHG emissions of six biofuel pathways by LCA in (the) People’s Republic of China. Applied Energy 86:S197

– S208. http:

//dx.doi.org/10.1016/j.apenergy.2009.04.045 Title: Life cycle assessment of village electrification based on straight jatropha oil in Chhattisgarh, India Author(s): Gmuender, Simon Michael; Zah, Rainer; Bhatacharjee, Somnath; et al. Source: BIOMASS & BIOENERGY Volume: 34 Issue: 3 Pages: 347

- 355 DOI: 10.1016/j.biombioe.20 09.11.006 Published: MAR 2010 Title: Life cycle assessment for the produc tion of biodiesel: A case study in Malaysia for palm oil versus jatropha oil Author(s): Lam, Man Kee; Lee, Keat Teong; Mohamed, Abdul Rahman Source: BIOFUELS BIOPRODUCTS & BIOREFINING

- BIOFPR Volume: 3 Issue: 6 Pages: 601

- 612 DOI: 10.1002/bbb.182 P ublished: NOV

- DEC 2009 Title: Environmental Impacts of Jatropha curcas Biodi esel in India Author(s): Gmuender, Simon; Singh, Reena; Pfister, Stephan; et al. Source: JOURNAL OF BIOMEDICINE AND BIOTECHNOLOGY Article Number: 623070 DOI: 10.1155/2012/623070 Published: 2012
Dr. Achten passed along copies of three of the papers (Achten et al (2012), Lapola et al (2010), and Ou et al (2009)); those three are attached here. If y ou cannot locate the other articles listed above, please let me k now. I want to thank EPA and RTI for the work that you are doing on this subject, and also for seeking feedback early in the process. If there is anything else that the Clean Air Task Force can do to help EPA in its analy sis of jatropha

- based fuels, please let me know. Best regards, Jonathan

--- **Jonathan Lewis** Senior Counsel

- Climate Polic y Clean Air Task Force 18 Tremont Street, Suite 530 Boston, MA 02108 office: +1 (617) 624

- 0234 x153mo bile: +1 (617) 894

- 3788

www.catf.us jlewis@catf.us