July 16, 2010 

MEMORANDUM 

TO: Air and Radiation Docket EPA-HQ-OAR-2010-0133 

SUBJECT: Summary of Modeling Input Assumptions for Canola Oil Biodiesel 

for the Notice of Supplemental Determination for Renewable Fuels 

Produced Under the Final RFS2 Program 

This memorandum provides information on the key input assumptions used for modeling 

the canola oil biodiesel lifecycle pathway. Assumptions include crop yields, energy use, 

fertilizer use, etc. Data sources are presented to promote transparency on our modeling 

inputs. 
Canola Data 

Agricultural Sector Inputs 

Category Assumption Source

Production  

Crop Yield (unit/acre)

(historical)

1,461 lbs seed/acre

(U.S., 2008)

1,735 lbs seed/acre

(Canada, 2008)

http://quickstats.nass.usda.gov/

USDA Production, Supply and Distribution (PS&D) Database,

http://www.fas.usda.gov/psdonline/

Crop Yield (unit/acre)

(projected)

1,681 lbs seed/acre

(U.S. Avg., 2022)

1,806 lbs seed/acre

(Canada, 2022)

Based on historic trends, see  discussion and Figure 2 below

Based on historic trends, see  discussion and Figure 4 below  

Harvested acres

(historical)

989 thousand acres

(U.S., 2008)

16 million acres

(Canada, 2008)

http://quickstats.nass.usda.gov/

USDA Production, Supply and Distribution (PS&D) Database,

http://www.fas.usda.gov/psdonline/

Harvested acres

(projected)

0.9 M acres

(U.S., 2022)

1.2 M acres

(U.S., 2022)

17.4 M acres

(Canada, 2022)

17.6 M acres

(Canada, 2022)

FASOM modeled results without increase in canola oil biodiesel

production

FASOM modeled results with increase in canola oil biodiesel

production

FAPRI modeled results without increase in canola oil biodiesel

production

FAPRI modeled results with increase in canola oil biodiesel

production

Energy Use

Gasoline See Table 1&2 U.S. rates based on various state and regional crop budgets, see

EPA‐HQ‐OAR‐2005‐0161‐3178 (Technical Report describing the

FASOM model) and Renewable Fuel Standard Program (RFS2)

Regulatory Impact Analysis (RIA) Section 2.4.2.1 “Domestic Crop

Inputs” for more information

Diesel See Table 1&2 U.S. rates based on various state and regional crop budgets, see

EPA‐HQ‐OAR‐2005‐0161‐3178 and RFS2 RIA Section 2.4.2.1 for

more information

Canadian rates based on Agriculture and Agri‐Food Canada

Research Centers and the University of Manitoba data, see

“CANOLA LCA DATA” report in the docket from the Canola Council

of Canada for more information

2
Electricity See Table 2 Canadian rates based on USDA energy survey data for wheat in the

northern tier states of Minnesota, North Dakota, and Montana,

adjusted for Canola, see “CANOLA LCA DATA” report in the docket

from the Canola Council of Canada for more information

Fertilizer Use

Nitrogen

Phosphorus

Potassium

See Table 3&4 U.S. rates based on various state and regional crop budgets, see

EPA‐HQ‐OAR‐2005‐0161‐3178 and RFS2 RIA Section 2.4.2.1 for

more information

Canadian rates based on the Food and Agricultural Organization's

Fertistat database, which reports fertilizer use by crop and by

country, for a single year between 1988 and 2004.

(www.fao.org/ag/agl/fertistat/).   Also described in “Notable

Revisions and Recalculations: International Agriculture GHG

Emissions and GHG Metrics” (2009) see docket ID EPA‐HQ‐OAR‐

2005‐0161‐3037

Others Inputs Use

Herbicide

Fungicides &

Bactericides

Insecticides

See Table 3&4 U.S. rates based on various state and regional crop budgets, see

EPA‐HQ‐OAR‐2005‐0161‐3178 and RFS2 RIA Section 2.4.2.1 for

more information

Canadian rates based on Chemical Consumption Rates and

Agricultural Area from FAO’s FAOSTAT Database  

(http://faostat.fao.org/site/395/default.aspx) Also described in

“Notable Revisions and Recalculations: International Agriculture

GHG Emissions and GHG Metrics” (2009) see docket ID EPA‐HQ‐

OAR‐2005‐0161‐3037

Canadian canola N2O

Emissions

See Table 5 Environment Canada and Agriculture Canada Tier 2 country‐

specific factors, see2006 IPCC Guidelines for National Inventories,

Volume 4, Chapter 11: N2O Emissions from Managed Soils, and CO2

Emissions from Lime and Urea Application (for methodological

approach)

U.S. canola N2O

Emissions

Included in FASOM

model

See RFS2 RIA Section 2.4.2.2 “Domestic Nitrous Oxide Emissions”

for more information

Canola Crushing 

Category Assumption Source

Energy Use

Natural Gas 1.0 GJ/tonne seed crushed

2.34 GJ/tonne oil produced

Canadian Oilseed Processors Association

survey data, see “CANOLA LCA DATA”

report in the docket from the Canola

Council of Canada for more information

Electricity 49 GJ/tonne seed crushed

114.5 GJ/tonne oil produced

Canadian Oilseed Processors Association

survey data, see “CANOLA LCA DATA”

report in the docket from the Canola

Council of Canada for more information

3
Yields     

Canola Oil 0.40 lbs oil / lb canola seed USDA Production, Supply and Distribution

(PS&D) database,

http://www.fas.usda.gov/psdonline/

Canola Meal 0.61 lbs meal / lb canola seed USDA Production, Supply and Distribution

(PS&D) database,

http://www.fas.usda.gov/psdonline/

Biodiesel Production 

Category Assumption Source

Energy Use

Natural Gas 1,459 Btu/gal biodiesel USDA Process energy model, see RFS2

RIA Section 2.4.7.3.3 “Conversion of Oil

to Biofuel” for more information

Electricity 575 Btu/gal biodiesel USDA Process energy model, see RFS2

RIA Section 2.4.7.3.3 “Conversion of Oil

to Biofuel” for more information

Yields     

Biodiesel from Canola Oil 7.6 lbs canola oil / gal biodiesel RFS2 final rule analysis – same as

soybean oil  

Co‐product (glycerine) Replaces residual oil RFS2 final rule analysis – same as

soybean oil

Volume Scenarios 

Assumption Source

Future potential production 200 MG by 2022 Estimated market potential from

feedstock availability, competing uses,

etc. See text below for more

information.

Table 1. U.S. Agricultural Energy Use 

Input GP LS RM PNWE SW Units

Gasoline NA NA 0.6 NA NA gal/acre

Diesel 4.0 4.1 7.1 5.4 4.3 gal/acre

GP: Great Plains; LS: Lake States; RM: Rocky Mountains; 

PNWE: Pacific Northwest-East side; SW: Southwest 

Table 2. Canadian Agricultural Energy Use

Input Amount Units

Gasoline NA NA

Diesel 3.60 gal/acre

Electricity 29.64 kWh/ha

4
Table 3. U.S. Fertilizer, Herbicide, Insecticide and Other Agricultural Inputs 

Input GP LS RM PNWE SW Units

Nitrogen Fertilizer (as N) 64.6 65.2 61.0 110.0 89.3 lbs/acre

Phosphorus Fertilizer (as

P2O5)

20.0 20.0 32.1 NA 23.0 lbs/acre

Potassium Fertilizer (as K2O) 30.0 30.0 9.3 NA NA lbs/acre

Herbicides 0.6 0.6 0.6 0.2 0.8 lbs/acre

Insecticides 0.6 0.6 0.6 0.3 0.5 lbs/acre

Table 4. Canadian Fertilizer, Herbicide, Insecticide and Other Agricultural Inputs 

Input Amount Units

Nitrogen Fertilizer (as N) 75.0 kg/ha

Phosphorus Fertilizer (as P2O5) 20.0 kg/ha

Potassium Fertilizer (as K2O) 15.0 kg/ha

Fungicides & Bactericides 0.042 kg/ha

Herbicides 0.342 kg/ha

Insecticides 0.047 kg/ha

Table 5. Canadian N2O Emission Factors 

Factor Amount

Dry matter fraction of harvested

product (DRY)

0.26

RAG(T) 2.31

NAG(T) 0.007

RBG(T) 0.58

NBG(T) 0.01

Yield Trends for Canola in the U.S. 

Figure 1 shows U.S. canola yields for 1991 to 2008 with the trend estimated for 

the same period. The EPA national-level projection for canola yield (see Figure 2) is an 

extension of the historical data trend forward to 2022. EPA’s yield growth estimate for 

canola in the U.S. was based on the same approach as used for all crops in the RFS2 final 

rule analysis, see RFS2 RIA Section 5.1.3 “Key Modeling Assumptions” for more 

information on yield growth projections in the analysis. The USDA baseline yield 

growth (from the USDA canola baseline projections available in the Docket for this 

NODA) is based on the same historic data but EPA considers yield changes 

independently for different regions in the U.S. whereas USDA uses national aggregate 

values, EPA believes it’s approach is more accurate because it takes into account regional 

differences. 

5
Figure 1. U.S. Canola Yields (historical) 

0

200

400

600

800

1000

1200

1400

1600

1800

Lbs/Acre

Canola yield Linear (Canola yield)

Figure 2. U.S. Canola Yields (projected) 

0

200

400

600

800

1000

1200

1400

1600

1800

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

Pounds per Acre

U.S. Canola Seed Yield Over Time

USDA

EPA

Yield Trends for Canola in Canada 

Figure 3 shows Canadian canola yields for the 1982/1983 to the 2008/2009 

marketing years, with the trend estimated for the same period. Projections for the RFS2 

6
runs start in 2009/2010, thus 2008/2009 is the last year for the data analysis (see Figure 

4). The slope for the period is 0.0199 tons per hectare per year. This is the slope used in 

the analysis. Yield growth for canola internationally was based on the same approach as 

used for all crops in the RFS2 final rule analysis, see RFS2 RIA Section 5.1.3 “Key 

Modeling Assumptions” for more information on yield growth projections in the analysis. 

Figure 3. Canadian Canola Yields (historical) 

y = 0.0199x + 1.1063

0

0.5

1

1.5

2

2.5

tons/ha

Yields Linear (Yields)

Figure 4. Canadian Canola Yields (projected) 

0

500

1000

1500

2000

2500

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022

Pounds per Acre

CanadianCanola Seed Yield Over Time

Canola Council

EPA

7
Volume Scenarios 

The following section describes our rationale for assuming an incremental volume of 200 

million gallons of canola oil biodiesel for modeling the impact of an increase of canola 

oil biodiesel by 2022. This volume was based on the evaluation of historical volumes, 

potential feedstock availability and competitive uses (e.g., for food or export instead of 

for domestic fuel), potential increases in crop acreage, and potential increases in crop 

yields. 

Historical U.S. Canola Biodiesel Production: According to information provided by the 

National Biodiesel Board, the U.S. Canola Association, and other stakeholders, 

production of U.S. canola biodiesel in 2008 and 2009 was approximately 96 million 

gallons and 35 million gallons, respectively.1 See Table 6 for a list of facilities. To put 

this in perspective, U.S. canola biodiesel made up 13.9% of total biodiesel produced in 

2008 and 6.4% of total biodiesel produced in 2009. See Figure 5 for an estimate of 

historical U.S. biodiesel production.2

Table 6. Canola Biodiesel Capacity and Production 

Facility Name Annual Capacity

(Mgal)

Approximate Volume

Produced 2008 (Mgal)

Approximate Volume

Produced 2009 (Mgal)

Archer Daniels

Midland (ADM)

85 61.6 20.2

Imperium Renewables 100 26 10

Western Dubuque 30 8 3.7

Inland Empire

Oilseeds

8 .02 0.4

Sun Power Biodiesel 3 .15 0.7

TOTAL 226 96 35

 

1

 U.S. Canola Association & Canola Biodiesel Stakeholders, Document submitted to EPA “RE: Canola 

Life-Cycle Analysis (LCA) Information”, April 8, 2010. 

2

 National Biodiesel Board, “Biodiesel Fact Sheets: Biodiesel Production Estimates CY2005- current”, 

http://www.biodiesel.org/resources/fuelfactsheets/ 

8
Figure 5. Estimated U.S. Biodiesel Production by Calendar Year (gallons) 

We can use our understanding of historical market share of canola oil biodiesel to project 

future volumes. EISA requires that, at a minimum, the biomass-based diesel standard 

require the use of 1 billion gallons per year in 2013 and beyond.3 We anticipate, 

however, that additional biodiesel could potentially be used to meet the “un-specified” 

advanced biofuel category, thus exceeding the 1 billion gallon minimum from the 

biomass-based diesel standard.4 For the final RFS2 rule, we had assumed 1.67 billion 

gallons could be possible from all biodiesel feedstocks in 2022. If we assume that canola 

oil biodiesel maintains similar biodiesel market share as seen in 2008 and 2009 projected 

to 2022 (13.9% or 6.4% of 1.67 billion gallons), it appears reasonable that 107-232 

million gallons of canola oil biodiesel could be produced in 2022. We believe there is 

good reason that canola oil biodiesel could either maintain its current market share or 

possibly even improve it over time given the growing interest and potential uses for this 

crop. Thus, an incremental volume change of 200 million gallons by 2022, representing 

the recent canola market share times projected total biodiesel production in 2022 appears 

to us to provide a reasonable estimate of canola oil production for purposes of our 

modeling effort. 

While we described above the market demand potential for canola oil biodiesel, there 

must also be enough supply of canola feedstocks to actually produce the volumes 

demanded. The following sections evaluate the factors that influence the volume of 

canola oil available for the markets and show, that given these factors, it is reasonable to 

assume 200 million gallons of canola oil biodiesel by 2022. 

 

3

 EPA is authorized to require larger volumes after considering the factors specified in Clean Air Act 

211(o)(2)(B)(ii). 

4

 Assuming no waivers, the advanced biofuels standard for 2022 is 21 bgal: 1bgal is biomass-based diesel, 

16 bgal is cellulosic biofuels, the remaining 4 bgal is un-specified advanced biofuels. 

9
10

 

Potential Feedstock Availability & Uses: Canola oil is primarily used for food, with the 

remainder used for industrial purposes (e.g., biodiesel, lubricants, etc.).5

 Current U.S. 

production of canola is approximately 1.4 billion pounds which equates to roughly 0.6 

billion pounds of oil. As noted, about 35 million gallons of canola-based biodiesel was 

produced in the U.S. Assuming a conversion yield of approximately 7.6 pounds canola 

oil per gallon biodiesel (as was assumed for soybean oil biodiesel for the final RFS2 

analysis), about 270 million pounds would have been needed to produce 35 million 

gallons of canola biodiesel in 2009. This amount is about a third of the total current U.S. 

production of canola oil. Thus, even without any additional production, maximum use of 

U.S. canola production for biodiesel could yield up to ~80 million gallons. 

In addition to U.S. production of canola oil, it can also be imported from Canada. In 

2008, Canada grew 16 million acres of canola with an average yield of 1,735 lbs of 

seed/acre, if all this were converted to oil it would result in approximately 11 billion 

pounds of oil. Possible conversion of this volume to biodiesel would yield about 1.4 

billion gallons of canola oil biodiesel. In 2008, the US imported approximately 2.3 

billion pounds of Canola oil, representing approximately 1/5 of Canadian canola 

production in that year. It can be expected that in the future much of the Canadian canola 

production would continue to be used in Canada rather than imported, and much of the 

imports to the US would likely continue to be used for food purposes, so only a relatively 

small portion of potential Canadian production is likely to be available for US biofuel 

production. Nevertheless, the large potential for import of Canadian canola supports the 

assumption that 200 million gallons of canola biodiesel could be produced in 2022 for 

use in the U.S. 

Increased Crop Yield and Acreage: The agricultural models project increased canola 

yields over time based on historical trends. Refer to the section on yields above for more 

information. Increased yields allow for greater volumes of canola oil to be produced per 

a given amount of area. In addition, the models also project expansion of total canola 

crop acreage. This expansion alone including yield growth has the potential to add more 

than 200 million gallons of canola oil biodiesel by 2022. 

Therefore, our evaluation of existing canola production and projected increase in 

production from improving yields and expanded acres supports a conclusion that 200 

million gallons of incremental volume of canola oil biodiesel by 2022 is a reasonably 

attainable estimate for modeling purposes. We have discussed this volume assumption 

with industry and USDA representatives, and they have agreed that this assumption is 

within reason. 

5

 USDA Economic Research Service, Soybeans and Oil Crops: Canola Seed, Oil, and Meal 

http://www.ers.usda.gov/Briefing/SoybeansOilcrops/Canola.htm