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December 14, 2011

MEMORANDUM

TO: Air Docket EPA-HQ-OAR-2011-0542

SUBJECT: Supporting Documentation for Analysis of Lifecycle Greenhouse Gas 

(GHG) Emissions from Palm Oil-Based Biodiesel and Renewable 

Diesel 

This memorandum accompanies information related to EPA’s analysis of lifecycle greenhouse 

gas (GHG) emissions from palm oil-based biodiesel and renewable diesel. As explained in the 

preamble to the Notice of Data Availability (NODA), our analysis utilizes several data sources 

and models. To facilitate public review, below is a brief description of the informational 

materials which accompany this memorandum.

1. Summary of Modeling Inputs and Assumptions

This memorandum provides information on the key inputs and assumptions used in EPA’s 

lifecycle analysis of palm oil used as a feedstock to produce biodiesel and renewable diesel. 

Assumptions include crop yields, energy use, energy sources, fertilizer use, co-products, and 

other important factors in our lifecycle analysis.

2. Consideration of Uncertainty

This memorandum provides additional information regarding consideration of uncertainty in our

modeling of the lifecycle GHG emissions associated with the palm oil-based biodiesel and

renewable diesel fuel production pathways analyzed in the Notice of Data Availability (NODA).

3. Lifecycle GHG Emissions Results

A spreadsheet that integrates results from all stages of the fuel lifecycle to calculate lifecycle 

GHG emissions from the production and use of the palm oil-based biodiesel and renewable 

diesel pathways analyzed. The lifecycle GHG reductions are calculated as percent emissions 

reductions compared to the statutory 2005 petroleum baseline.

4. Calculation of International Agricultural Impacts from the FAPRI-CARD Model

This spreadsheet includes calculations that convert the raw FAPRI-CARD model results into 

differences between scenarios to determine biofuel-induced GHG emissions impacts associated 

with the palm oil-based biofuel pathways analyzed.

5. Spatial Modeling of Future Oil Palm Expansion in Indonesia

This report explains the models, data and assumptions used to project the future locations of 

palm oil expansion in Indonesia for the scenarios modeled. The results include the area of palm 

oil expansion by administrative unit, land cover type converted and soil type converted. The 

results are used to calculate land use change GHG emissions in Indonesia for the scenarios 

modeled.

6. Spatial Modeling of Future Oil Palm Expansion in Malaysia
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This report explains the models, data and assumptions used to project the future locations of 

palm oil expansion in Malaysia for the scenarios modeled. The results include the area of palm 

oil expansion by administrative unit, land cover type converted and soil type converted. The 

results are used to calculate land use change GHG emissions in Malaysia for the scenarios 

modeled.

7. High Resolution Land Use Change Analysis of Oil Palm Plantations in Sumatra and 

Kalimantan Circa 2000

This report documents our analysis of remote sensing data to map areas of oil palm cultivation in 

Indonesia in the 2000 time period. The resulting spatial map was used as a data input to the 

spatial modeling of future oil palm expansion in Indonesia.

8. High Resolution Land Use Change Analysis of Oil Palm Plantations in Sumatra and 

Kalimantan Circa 2010

This report documents our analysis of remote sensing data to map areas of oil palm cultivation in 

Indonesia in the 2010 time period. The resulting spatial map was used as a data input to the 

spatial modeling of future oil palm expansion in Indonesia.

9. Revisions to Land Conversion Emission Factor’s since the RFS2 Final Rule

This report explains the revisions made, based on new data, since the RFS2 final rule to the land 

conversion emissions factors used in our analysis of land use change GHG emissions. Such 

revisions include updates to our treatment of harvested wood products, oil palm carbon stocks, 

peat soil assumptions and forest carbon stocks.