Notice of Opportunity To Comment on the Lifecycle Greenhouse Gas Emissions for Renewable Fuels Produced From Biomass Sorghum, 78855-78861 [2014-30712]
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BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–OAR–2014–0537–; FRL–9921–15–
OAR]
Notice of Opportunity To Comment on
the Lifecycle Greenhouse Gas
Emissions for Renewable Fuels
Produced From Biomass Sorghum
Environmental Protection
Agency.
ACTION: Notice.
AGENCY:
In this Notice, the
Environmental Protection Agency (EPA)
is inviting comment on its preliminary
analysis of the greenhouse gas (GHG)
emissions attributable to the growth and
transport of biomass sorghum feedstock
for use in making biofuels such as
ethanol or diesel. This notice explains
EPA’s analysis of the growth and
transport components of the lifecycle
greenhouse gas emissions from biomass
sorghum, and describes how EPA may
apply this analysis in the future to
determine whether biofuels produced
from such biomass sorghum meet the
necessary GHG reductions required for
qualification under the Renewable Fuels
Standard (RFS) program. Based on this
analysis, we anticipate that biofuels
produced from biomass sorghum could
qualify for cellulosic biofuel renewable
identification numbers (RINs) if certain
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SUMMARY:
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State
Zip code
fuel production process technology
conditions are met.
DATES: Comments must be received on
or before January 30, 2015.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2014–0537, by one of the
following methods:
• https://www.regulations.gov. Follow
the on-line instructions for submitting
comments.
• Email: a-and-r-docket@epa.gov,
Attention Air and Radiation Docket ID
No. EPA–HQ–OAR–2014–0537.
• Mail: Air and Radiation Docket,
Docket No. EPA–HQ–OAR–2014–0537,
Environmental Protection Agency, Mail
code: 28221T, 1200 Pennsylvania Ave.
NW., Washington, DC 20460.
• Hand Delivery: EPA Docket Center,
EPA/DC, EPA WJC West, Room 3334,
1301 Constitution Ave. NW.,
Washington, DC 20460, Attention Air
and Radiation Docket, ID No. EPA–HQ–
OAR–2014–0537. Such deliveries are
only accepted during the Docket’s
normal hours of operation, and special
arrangements should be made for
deliveries of boxed information.
Instructions: Direct your comments to
Docket ID No. EPA–HQ–OAR–2014–
0537. EPA’s policy is that all comments
received will be included in the public
docket without change and may be
made available online at
www.regulations.gov, including any
personal information provided, unless
the comment includes information
claimed to be Confidential Business
Information (CBI) or other information
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Code
whose disclosure is restricted by statute.
Do not submit information that you
consider to be CBI or otherwise
protected through www.regulations.gov
or email. The www.regulations.gov Web
site is an ‘‘anonymous access’’ system,
which means EPA will not know your
identity or contact information unless
you provide it in the body of your
comment. If you send an email
comment directly to EPA without going
through www.regulations.gov, your
email address will be automatically
captured and included as part of the
comment that is placed in the public
docket and made available on the
Internet. If you submit an electronic
comment, EPA recommends that you
include your name and other contact
information in the body of your
comment and with any disk or CD–ROM
you submit. If EPA cannot read your
comment due to technical difficulties
and cannot contact you for clarification,
EPA may not be able to consider your
comment. Electronic files should avoid
the use of special characters, any form
of encryption, and be free of any defects
or viruses. For additional information
about EPA’s public docket visit the EPA
Docket Center homepage at https://
www.epa.gov/epahome/dockets.htm.
Docket: All documents in the docket
are listed in the www.regulations.gov
index. Although listed in the index,
some information is not publicly
available, e.g., CBI or other information
for which disclosure is restricted by
statute. Certain other material, such as
copyrighted material, will be publicly
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available only in hard copy. Publicly
available docket materials are available
either electronically in
www.regulations.gov or in hard copy at
the Air and Radiation Docket, EPA/DC,
EPA West, Room 3334, 1301
Constitution Ave. NW., Washington,
DC. The Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday
through Friday, excluding legal
holidays. The telephone number for the
Public Reading Room is (202) 566–1744,
and the telephone number for the Air
and Radiation Docket is (202) 566–1742.
FOR FURTHER INFORMATION CONTACT: Jon
Monger, Office of Transportation and
Air Quality, Mail Code: 6406J, U.S.
Environmental Protection Agency, 1200
Pennsylvania Avenue NW., 20460;
telephone number: (202) 564–0628; fax
number: (202) 564–1686; email address:
monger.jon@epa.gov.
SUPPLEMENTARY INFORMATION:
This notice is organized as follows:
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I. Introduction
II. Analysis of Greenhouse Gas Emissions
Associated With use of Biomass
Sorghum as a Biofuel Feedstock
A. Feedstock Description, Production, and
Distribution
B. Summary of Agricultural Sector
Greenhouse Gas Emissions
C. Fuel Production and Distribution
D. Cellulosic Content of Biomass Sorghum
III. Summary
I. Introduction
As part of changes to the Renewable
Fuel Standard (RFS) program
regulations published on March 26,
2010 1 (the ‘‘March 2010 rule’’), EPA
specified the types of renewable fuels
eligible to participate in the RFS
program through approved fuel
pathways. Table 1 to 40 CFR 80.1426 of
the RFS regulations lists three critical
components of an approved fuel
pathway: (1) Fuel type; (2) feedstock;
and (3) production process. Fuel
produced pursuant to each specific
combination of the three components, or
fuel pathway, is designated in the Table
as eligible for purposes of the Act’s
requirements for greenhouse gas
reductions, to qualify as renewable fuel
or one of three subsets of renewable fuel
(biomass-based diesel, cellulosic biofuel
or advanced biofuel). EPA may also
independently approve additional fuel
pathways not currently listed in Table 1
to § 80.1426 for participation in the RFS
program, or a third-party may petition
for EPA to evaluate a new fuel pathway
in accordance with 40 CFR 80.1416.
EPA’s lifecycle analyses are used to
assess the overall greenhouse gas
impacts of a fuel throughout each stage
1 See
of its production and use. The results of
these analyses, considering uncertainty
and the weight of available evidence,
are used to determine whether a fuel
meets the necessary greenhouse gas
reductions required under the Clean Air
Act (CAA) for it to be considered
renewable fuel or one of the subsets of
renewable fuel. Lifecycle analysis
includes an assessment of emissions
related to the full fuel lifecycle,
including feedstock production,
feedstock transportation, fuel
production, fuel transportation and
distribution, and tailpipe emissions. Per
the CAA definition of lifecycle GHG
emissions, EPA’s lifecycle analyses also
include an assessment of significant
indirect emissions such as emissions
from land use changes, agricultural
sector impacts, and production of coproducts from biofuel production.
Pursuant to 40 CFR 80.1416, EPA
received a petition from the National
Sorghum Producers (NSP), submitted
under a claim of confidential business
information (CBI), requesting that EPA
evaluate the lifecycle GHG emissions for
biofuels produced using a biomass
sorghum feedstock, and that EPA
provide a determination of the
renewable fuel categories, if any, for
which such biofuels may be eligible. As
an initial step in this process, EPA has
conducted a preliminary evaluation of
the GHG emissions associated with the
growth and transport of biomass
sorghum when it is used as a biofuel
feedstock, and is seeking public
comment on the methodology and
results of this preliminary evaluation.
After considering comments received,
EPA expects to revise its assessment as
appropriate and then use the
information to evaluate petitions
received pursuant to 40 CFR 80.1416
which propose to use biomass sorghum
as a feedstock for the production of
biofuel, and which seek an EPA
determination regarding whether such
biofuels qualify as renewable fuel under
the RFS program. In evaluating such
petitions, EPA will consider the GHG
emissions associated with petitioners’
biofuel production processes, as well as
emissions associated with the transport
and use of the finished biofuel, in
addition to the GHG emissions
associated with the use and transport of
biomass sorghum feedstock in
determining whether petitioners’
proposed biofuel production pathway
satisfies CAA renewable fuel lifecycle
GHG reduction requirements.
22:02 Dec 30, 2014
To evaluate the lifecycle GHG
emissions associated with the use of
biomass sorghum feedstock to produce
biofuels, we used a similar approach to
that used for miscanthus in the March
2010 rule, in which GHG emissions
associated with the growth and
transport of miscanthus was determined
by comparing feedstock-related GHG
emissions to those of switchgrass. In the
March 2010 rule, EPA determined that
biofuel made from switchgrass using
designated processes meets the GHG
emissions reduction threshold for
cellulosic fuels. For miscanthus, new
agricultural modeling was deemed
unnecessary; EPA ultimately
determined that miscanthus would have
similar lifecycle GHG emissions to
switchgrass and therefore that biofuels
made from designated processes using
miscanthus as a feedstock would have
similar lifecycle GHG emissions as
similar biofuels made through the same
processes with switchgrass. EPA also
followed a similar approach in assessing
GHG emissions associated with the use
of energy cane, giant reed, and napier
grass in rules published on March 5,
2013 (the ‘‘March 2013 rule’’) 2 and July
11, 2013 (the ‘‘July 2013 rule’’).3
As described in detail in the following
sections of this notice, EPA believes that
new agricultural sector modeling is not
needed to analyze biomass sorghum.
Instead, we evaluated the agricultural
sector GHG emissions impacts of using
biomass sorghum by reference to
switchgrass. Both biomass sorghum and
switchgrass are grasses with high yields
and high cellulosic contents. Our
preliminary assessment indicates that
on a per dry ton of feedstock basis
indirect land use emissions would be
lower, direct emissions associated with
use of farm machinery, fertilizers and
pesticides would be lower, and that
emissions associated with feedstock
transport would be the same as for
switchgrass. Therefore, we propose in
responding to petitions received
pursuant to 40 CFR 80.1416 to assume
that on a per dry ton of feedstock basis
GHG emissions associated with biomass
sorghum production and use are the
same as those associated with the
production and use of switchgrass for
biofuel production. We believe that this
is a conservative approach, and we
invite comment on it.
3 78
75 FR 14670.
VerDate Sep<11>2014
II. Analysis of Greenhouse Gas
Emissions Associated With Use of
Biomass Sorghum as a Biofuel
Feedstock
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A. Feedstock Description, Production,
and Distribution
Although all types of cultivated
sorghum belong to the species Sorghum
bicolor (L.) Moench, breeding for
different purposes has led to significant
variation within this species. Sorghum
is native to Africa, but was introduced
to the U.S. in the early 17th century.
Historically, sorghum has been bred to
be used as a grain, a source of sugar, and
as animal forage. More recently, it has
also been bred to increase biomass.
Different types of sorghum have
different characteristics and may
therefore qualify as different types of
renewable fuels under the RFS program,
making it important to distinguish
among the different types of sorghums.
Grain Sorghum. In the U.S., grain
sorghum is commonly used as animal
feed similar to feed corn, although in
other parts of the world it is used for
human consumption. Pathways for
ethanol produced from grain sorghum
feedstock were approved in a rule
published on December 17, 2012 (the
‘‘December 2012 RFS rule’’).4
Sweet Sorghum. Sweet sorghum has
historically been bred to maximize sugar
content, and is crushed to yield a juice
that is high in sugars that are easily
fermentable. Processing sweet sorghum
is similar to processing sugarcane, and
the resulting juice can be used to
produce sorghum syrup for food
consumption or as a biofuel feedstock.
Forage sorghum. Varieties of forage
sorghum are typically used for animal
grazing. These varieties of sorghum have
been bred for optimal nutrition,
including high content of digestible
nutrients and low lignin content.
Sorghum bred for biomass content.
Recently, producers have begun
breeding sorghum as a feedstock for
biofuel production, beginning with
forage sorghum varieties. The goal of
these breeding efforts has been to
maximize the total biomass yield for use
as biofuel feedstock. The resultant
sorghum varieties generally have greatly
enhanced biomass yields (plants can
grow to be over 20 feet tall), longer
growing seasons, and lower nitrogen
demand because digestibility is not a
concern.
Differentiating the types of sorghum
for purposes of the lifecycle analysis
required under the RFS program is
challenging because varieties bred for
different purposes all belong to the same
species and are often defined based on
end-use, rather than based on specific
physical characteristics.5 For purposes
4 See
77 FR 74592.
Stefaniak, T.R., J.A. Dahlberg, B.W. Bean,
N. Dighe, E.J. Wolfrum, and W.L. Rooney (2012).
5 E.g.
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22:02 Dec 30, 2014
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of this Notice, EPA considers biomass
sorghum to be Sorghum bicolor that has
been selected or bred to maximize
cellulosic content rather than sugar or
grain content, and which therefore has
at least 75% cellulosic content. EPA
also considers hybrids that are crosses
of Sorghum bicolor and sudangrass 6 to
be biomass sorghum if they have 75%
cellulosic content, but EPA does not
consider hybrids that are crosses of
Sorghum bicolor and Johnsongrass
(Sorghum halepense) to be biomass
sorghum, even if such hybrids have
75% or higher cellulosic content. This
approach is consistent with the NSP
petition, which explicitly excluded
Johnsongrass due to concerns regarding
its potential to behave as an invasive
species. See Section II.D. for further
discussion of varieties considered
biomass sorghum for purposes of this
Notice.
1. Crop Yields
For the purposes of analyzing the
GHG emissions from biomass sorghum
production, EPA examined crop yields
and production inputs in relation to
switchgrass to assess the relative GHG
impacts. For the switchgrass lifecycle
analysis, EPA assumed national average
yields of approximately 4.5 to 5 dry tons
per acre.7 Based on field trials in nine
states under a range of growing
conditions, the 2012 average yield of
sorghum grown for biomass content is
approximately 11 dry tons per acre,8
suggesting that biomass sorghum will
have significantly higher yields than
switchgrass.
Furthermore, EPA’s analysis of
switchgrass for the RFS rulemaking
Variation in biomass composition components
among forage, biomass, sorghum-sudangrass and
sweet sorghum types. Crop Science, 52, 1949–1954.
6 Sudangrass (Sorghum x drummondii) is a forage
grass which is commonly crossed with Sorghum
bicolor to produce hybrids. FAO Grassland Species
Profile, https://www.fao.org/ag/agp/AGPC/doc/
gbase/data/pf000494.HTM. Accessed 15 September,
2014.
7 Kumar, A. and S. Sokhansanj (2007).
‘‘Switchgrass (Panicum vigratum, L,) delivery to a
biorefinery using integrated biomass supply
analysis and logistics (IBSAL) model.’’ Bioresource
Technology, 98:1033–1044. A more recent study
compiled switchgrass yield data from 45 studies
from 1991–2010, and found an average yield of 4.9
dry tons per acre: Maughan, M.W. (2011)
‘‘Evaluation of switchgrass, M. x giganteus, and
sorghum as biomass crops: Effects of environment
and field management practices.’’ Ph.D.
Dissertation, University of Illinois at UrbanaChampaign.
8 Petition, based on data from 8 sources. A study
of the yield of biomass sorghum in Illinois found
yields from 10.1–13.4 dry tons/acre: Maughan,
M.W. (2011). ‘‘Evaluation of switchgrass, M. x
giganteus, and sorghum as biomass crops: Effects of
environment and field management practices.’’
Ph.D. Dissertation, University of Illinois at UrbanaChampaign.
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78857
assumed a 2% annual increase in yield
that would result in an average national
yield of 6.6 dry tons per acre in 2022.9
EPA anticipates similar yield
improvements for biomass sorghum as
for switchgrass since both feedstocks are
energy crops in the early stages of
development, and improvements in
farming practices or new hybrids could
increase the yield over time.10 Given the
potential for yield improvements, our
analysis assumed an average biomass
sorghum yield of 13 dry tons per acre
in the southern United States by 2022,
which was calculated using a 2%
annual increase in yield.
Because of its higher yield, biomass
sorghum grown in areas with suitable
growing conditions would require
approximately 50% less land area
compared to switchgrass to produce the
same amount of biomass. Even without
yield growth assumptions, the current
higher crop yield means the land use
required for biomass sorghum should be
lower than for switchgrass. Therefore
less crop area would be converted and
displaced through use of biomass
sorghum as compared to switchgrass.
2. Land Use
Biomass sorghum is not currently
grown at commercial scale in the United
States for the purpose of biofuel
production, although approximately 1.4
million acres of forage sorghum were
planted in 2012. Biomass sorghum is
currently grown in test plots as part of
research to develop it as an energy crop,
and currently has no other uses.
Biomass sorghum can be planted as
early as April and can continue growing
until the fall.11 Production is expected
to be concentrated in the South Central
U.S. in Texas, Oklahoma and Kansas, as
well as in Missouri and Arkansas.12
9 A recently released switchgrass cultivar,
‘‘Liberty’’ has a yield of 8.1 tons/acre in Nebraska
(7.3 dry tons/acre, assuming a dry matter content
of 90%). As hybrids like this become more
commonly used, average national yields will
increase; Vogel, K.P., R.B. Mitchell, M.D. Casler and
G. Sarath (2014). ‘‘Registration of ‘Liberty’
Switchgrass.’’ Journal of Plant Registrations, 8:242–
247.
10 Progress is being made in developing new
biomass sorghum hybrids with higher yields than
the parents. Increased used of these hybrids will
increase national average yields. Packer, D.J. and
W.L. Rooney (2014). ‘‘High-parent heteropsis for
biomass yield in photoperiod-sensitive sorghum
hybrids.’’ Field Crops Research, 167:153–158.
11 Blade Energy Crops (2010). ‘‘Managing HighBiomass Sorghum as a Dedicated Energy Crop.’’
Available at: www.bladeenergy.com/Bladepdf/
Blade_SorghumMgmtGuide2010.pdf.
12 According to DOE’s Billion-Ton Update,
‘‘dedicated biomass sorghums grow well throughout
the eastern and central United States as far north
at 40° latitude.’’ Department of Energy (DOE)
(2011). U.S. Billion-Ton Update: Biomass Supply
for a Bioenergy and Bioproducts Industry, https://
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These areas are similar to the acres
where our agricultural sector modeling
projected switchgrass would be grown
in the March 2010 rule. In addition,
modeling results presented in DOE’s
Billion-Ton Update suggest that biomass
sorghum and switchgrass will be grown
in similar regions.13
In EPA’s analysis for the March 2010
rule, switchgrass plantings were
projected to primarily displace soybeans
and wheat, and to a lesser extent hay,
rice, grain sorghum, and cotton in the
South Central U.S. Because biomass
sorghum is likely to be grown on similar
existing agricultural land in the same
regions, as explained above, and
because biomass sorghum yields are
higher than yields of switchgrass (so
should displace fewer total acres) EPA
concludes that the indirect land use
GHG impact for biomass sorghum per
gallon should be no greater and likely
less than estimated for switchgrass.
In the switchgrass ethanol scenario
done for the March 2010 rule, total
cropland acres were projected to
increase by 4.2 million acres, including
an increase of 12.5 million acres of
switchgrass and decreases of 4.3 million
acres of soybeans, 1.4 million acres of
wheat, and 1 million acres of hay, as
well as smaller decreases in a variety of
other crop acreages. This analysis took
into account the economic conditions
such as input costs and commodity
prices when evaluating the GHG and
land use change impacts of switchgrass.
Given the higher yields of the biomass
sorghum considered here compared to
switchgrass, there should be ample land
available for production without having
any adverse impacts beyond those
projected for switchgrass production.
The indirect land use impacts for
biomass sorghum are assumed to be
similar to or less than those modeled for
switchgrass. The justification for this
assumption is that both crops are
expected to be grown in the South
Central U.S. and will likely displace the
same types of cropland, but because of
higher biomass sorghum yields, fewer
total acres will be displaced per gallon
of fuel produced.14 Furthermore, we
believe biomass sorghum will have a
similar impact on international markets
as assumed for switchgrass. Like
switchgrass, biomass sorghum is not
expected to be traded internationally
and its impacts on other crops are
expected to be limited. Accordingly,
indirect land use change GHG emissions
associated with biomass sorghum would
likely be smaller than such emissions
for switchgrass. Thus, we believe that
our proposal to assume in our lifecycle
GHG emissions assessments that
indirect land use change GHG emissions
from biomass sorghum would be similar
to switchgrass represents a conservative
approach.
3. Crop Inputs and Feedstock Transport
EPA also assessed the GHG impacts
associated with planting, harvesting,
and transporting biomass sorghum in
comparison to switchgrass. Table 1
below shows the assumed 2022
commercial-scale production inputs for
switchgrass modeled for the March 2010
rule and average biomass sorghum
production inputs based on U.S.
Department of Agriculture (USDA)
projections and industry data. Available
data gathered by EPA suggest that
biomass sorghum requires on average
less nitrogen, phosphorous, potassium,
and pesticide than switchgrass per dry
ton of biomass, but more herbicide and
diesel per dry ton of biomass. The
inputs were given to EPA from the
petitioners based on field trials, verified
by the USDA, and documented in peerreviewed journals where possible. Since
biomass sorghum is an annual crop and
switchgrass is a perennial, some inputs
required for growing biomass sorghum,
such as herbicide and diesel, are slightly
higher than inputs for switchgrass (see
Table 1 below). Applying the GHG
emission factors used for the March
2010 rule, biomass sorghum production
results in lower GHG emissions per dry
ton of biomass produced relative to
switchgrass production, as shown in
Table 1, below. More information on
biomass sorghum inputs is available in
the docket.
TABLE 1—DIRECT INPUTS FOR SWITCHGRASS AND BIOMASS SORGHUM 15
Switchgrass 16
Biomass sorghum 17
Category
Inputs
(per dry ton of biomass)
Emissions
(per dry ton of
feedstock)
Inputs
(per dry ton of biomass)
Yield (Projected) ................
Nitrogen Fertilizer ..............
N2O ....................................
Phosphorus Fertilizer ........
Potassium Fertilizer ...........
Herbicide ...........................
Insecticide ..........................
Lime ...................................
Diesel .................................
Electricity (irrigation) ..........
6.6 dry tons/acre ...............
15.2 lbs/dry ton .................
N/A ....................................
6.1 lbs/dry ton ...................
6.1 lbs/dry ton ...................
0.002 lbs/dry ton ...............
0.02 lbs/dry ton .................
0 lbs/dry ton ......................
0.4 gal/dry ton ...................
0 kWh/dry ton ....................
...........................................
25 kg CO2eq .....................
136 kg CO2eq ...................
3 kg CO2eq .......................
2 kg CO2eq .......................
0.02 kg CO2eq ..................
0.3 kg CO2eq ....................
0 kg CO2eq .......................
6 kg CO2eq .......................
0 kg CO2eq .......................
13 dry ton/acre
4.6 lbs/dry ton ...................
N/A ....................................
1.2 lbs/dry ton ...................
0.5 lbs/dry ton ...................
0.4 lbs/dry ton ...................
0.003 lbs/dry ton ...............
0 lbs/dry ton ......................
0.7 gal/dry ton ...................
0.0 kWh/dry ton .................
8 kg CO2eq
105 kg CO2eq
0.6 kg CO2eq
0.2 kg CO2eq
5 kg CO2eq
0.05 kg CO2eq
0 kg CO2eq
9 kg CO2eq
0 kg CO2eq
...........................................
173 kg CO2eq ...................
...........................................
128 kg CO2eq
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Total GHG emissions
www1.eere.energy.gov/biomass/pdfs/billion_ton_
update.pdf. DOE’s Billion Ton study conducted a
technical analysis of the amount of potential
biomass that could be produced in the U.S. under
a range of different conditions. This study showed
that biomass sorghum and switchgrass have the
potential to contribute enough biomass to exceed
the volumes of cellulosic biofuel required by the
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CAA. The purpose of EPA’s 2010 analysis was to
estimate one potential scenario for meeting the
biofuel volume requirements in the CAA, not to
estimate the maximum potential volumes of
biofuels that could be produced in the U.S.
13 Department of Energy (DOE) (2011). U.S.
Billion-Ton Update: Biomass Supply for a
Bioenergy and Bioproducts Industry, https://
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Emissions
(per dry ton of
feedstock)
www1.eere.energy.gov/biomass/pdfs/billion_ton_
update.pdf.
14 Department of Energy (DOE) (2011). U.S.
Billion-Ton Update: Biomass Supply for a
Bioenergy and Bioproducts Industry, https://
www1.eere.energy.gov/biomass/pdfs/billion_ton_
update.pdf.
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The lifecycle GHG emissions
associated with distributing biomass
sorghum feedstock are expected to be
similar to EPA’s estimates for
switchgrass feedstock. One major
difference is that switchgrass has a
longer harvest window than biomass
sorghum. Biomass sorghum is typically
harvested in the fall, whereas
switchgrass can be harvested from July
to March. This suggests that for fuel
production purposes, harvested
switchgrass would not need to be stored
as long as biomass sorghum because it
would be available directly from the
field for a longer period of time.18
However, harvesting switchgrass just
once per year, in the fall, can maximize
yield and minimize nutrient inputs.19
Therefore, even though switchgrass
could be harvested more often, in
practice it may just be harvested once
per year in the fall, like biomass
sorghum. In addition, the biomass
sorghum harvest window can be
extended by staggering planting times,
using a range of hybrids with different
harvesting times, or using multiple
cuttings, which would reduce storage
needs.20 When switchgrass and biomass
sorghum need to be stored, both can be
stored in bales.21
15 The IPCC equations for N O emissions were
2
updated since our earlier analysis of switchgrass.
We use the updated equations here.
16 Beach, R.H. and B.A. McCarl (2010). U.S.
Agricultural and Forestry Impacts of the Energy
Independence and Security Act: FASOM Results
and Model Description. Docket EPA–HQ–OAR–
2005–0161–3178.
17 Input data are from petitioners, peer-reviewed
literature, and USDA. Details on the sources of
input data can be found in the docket. Emissions
are calculated based on the input data and emission
factors.
18 Haque, M. and F. M. Epplin (2012). ‘‘Cost to
produce switchgrass and cost to produce ethanol
from switchgrass for several levels of biorefinery
investment cost and biomass to ethanol conversion
rates.’’ Biomass and Bioenergy, 46:517–530.
19 Mitchell, R. B., and M. R. Schmer (2012).
‘‘Switchgrass harvest and storage.’’ Switchgrass. A.
Monti (ed.), London: Springer-Verlag, 113–127;
Garland, C. D., et al. (2008). ‘‘Growing and
harvesting switchgrass for ethanol production in
Tennessee.’’ University of Tennessee Agricultural
Extension Service.
20 Turhollow, A. F. E. G. Webb, and M. E.
Downing (2010). ‘‘Review of sorghum production
practices: Applications for Bioenergy.’’ Oak Ridge
National Laboratory, Oakridge, TN. Available at:
https://info.ornl.gov/sites/publications/files/
Pub22854.pdf; Blade Energy Crops (2010).
‘‘Managing high-biomass sorghum as a dedicated
energy crop.’’ Available at: https://
www.bladeenergy.com/Bladepdf/Blade_
SorghumMgmtGuide2010.pdf.
21 Blade Energy Crops (2010). ‘‘Managing highbiomass sorghum as a dedicated energy crop.’’
Available at: https://www.bladeenergy.com/
Bladepdf/Blade_SorghumMgmtGuide2010.pdf;
Sanderson, M. A., R. P. Egg, and A. E. Wiselogel
(1997). ‘‘Biomass losses during harvest and storage
of switchgrass.’’ Biomass and Bioenergy, 12(2):107–
114.
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Biomass sorghum is expected to
achieve higher yields and thus the
feedstock distribution radius around a
similar sized biofuel production plant,
or biomass collection hub, could be
lower for biomass sorghum than for
switchgrass. Therefore, even though
there can be differences in the harvest
period of switchgrass and biomass
sorghum, our analysis makes the
simplifying assumption that both crops
require similar transport, loading,
unloading, and storage regimes, and
have the same GHG emissions for
feedstock distribution, on a per dry ton
of feedstock basis. Harvesting, storage,
and distribution were a small fraction of
the total GHG emissions for switchgrass,
so we do not believe this simplification
substantially affects our lifecycle
analysis.
B. Summary of Agricultural Sector
Greenhouse Gas Emissions
Based on our comparison of biomass
sorghum to switchgrass, EPA proposes
to use, in its future evaluations of
petitions proposing to use biomass
sorghum as feedstock for biofuel
production, an estimate of the GHG
emissions associated with the
cultivation and transport of biomass
sorghum that is the same as that which
we have used for switchgrass, on a per
dry ton of feedstock basis. EPA solicits
comment on this proposed approach.
C. Fuel Production and Distribution
Biomass sorghum is suitable for the
same conversion processes as approved
cellulosic feedstocks such as
switchgrass and corn stover. After
reviewing comments received in
response to this Notice, we will
combine our evaluation of agricultural
sector GHG emissions associated with
the use of biomass sorghum feedstock
with our evaluation of the GHG
emissions associated with individual
producers’ production processes and
finished fuels to determine whether the
proposed pathways satisfy CAA
lifecycle GHG emissions reduction
requirements for RFS-qualifying
renewable fuels. Based on our
evaluation of the lifecycle GHG
emissions attributable to the growth and
transport of biomass sorghum feedstock,
EPA anticipates that fuel produced from
biomass sorghum feedstock through the
same biochemical or thermochemical
process technologies that EPA evaluated
for the March 2010 RFS rule for biofuel
derived from switchgrass feedstock
would qualify for cellulosic biofuel (Dcode 3) renewable identification
numbers (RINs) or cellulosic diesel (Dcode 7) RINs depending on the type of
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fuel produced.22 However, EPA will
evaluate petitions for fuel produced
from biomass sorghum feedstock on a
case-by-case basis.23
D. Cellulosic Content of Biomass
Sorghum
For biomass sorghum-derived biofuels
to qualify as cellulosic biofuel under the
RFS program, the fuel must achieve a
60% lifecycle GHG reduction as
compared to the 2005 baseline fuels,
and must also be derived from cellulose,
hemicellulose and lignin. This section
of the Notice discusses our preliminary
analysis of the extent to which fuel
made from biomass sorghum may
qualify as derived from cellulose,
hemicellulose and lignin. For
simplicity, these three chemicals are
hereafter referred to as ‘‘cellulose,’’ and
their presence in feedstock as the
feedstock’s ‘‘cellulosic content.’’
In the rule published on July 18, 2014
(the ‘‘July 2014 rule’’),24 EPA
determined that fuel generated from
feedstocks with an average adjusted
cellulosic content 25 of 75% or more is
eligible to generate cellulosic biofuel
RINs for the entire fuel volume. EPA
examined the biochemical composition
of different feedstocks commonly
understood to be ‘‘cellulosic,’’ including
corn stover and other crop residues,
switchgrass, miscanthus, energy cane,
giant reed, napier grass, and various
woods and tree branches. Based on this
work, EPA found that roughly 75–90%
of the organic biomass of these
feedstocks was cellulosic, and the
balance was comprised of other
constituents, such as starches and
sugars.26 EPA considered in the July
2014 rule the extent to which fuel made
from these and other feedstocks with
some amount of cellulosic content
22 The biochemical and thermochemical
processes that EPA evaluated for the March 2010
RFS rule for biofuel derived from switchgrass
feedstock are described in section 2.4.7.4
(Cellulosic Biofuel) of the Regulatory Impact
Analysis for the March 2010 RFS rule (EPA–420–
R–10–006).
23 Similarly, EPA anticipates that naphtha
produced from biomass sorghum feedstock through
any of the gasification and upgrading processes that
EPA evaluated in the March 2010 RFS rule (78 FR
14190) for biofuel derived from switchgrass
feedstock would likely qualify for cellulosic biofuel
(D-code 3) RINs, but EPA intends to evaluate
petitions for naphtha produced from biomass
sorghum feedstock on a case-by-case basis.
24 ‘‘Regulation of Fuels and Fuel Additives: RFS
Pathways II, and Technical Amendments to the RFS
Standards and E15 Misfueling Mitigation
Requirements.’’ 79 FR 42128.
25 Adjusted cellulosic content is the percent of
organic material that is cellulose, hemicellulose,
and lignin.
26 See ‘‘Cellulosic Content of Various
Feedstocks—2014 Update.’’ Docket EPA–HQ–OAR–
2012–0401.
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should be considered ‘‘cellulosic
biofuel,’’ and determined in the rule
that the entire volume of fuel derived
from feedstocks with at least 75%
adjusted cellulosic content should be
considered cellulosic biofuel. Fuel made
from feedstocks having less cellulosic
content could qualify for the generation
of cellulosic biofuel RINs for a portion
of the finished fuel.
In the July 2014 rule, EPA described
in more detail why we believed that
setting the threshold at 75% percent
appropriately implements the statutory
requirements while not imposing
excessive administrative burden on
industry. In that rulemaking, EPA also
explained that we would apply the 75%
threshold to feedstocks that we
evaluated in the future, and finalized a
definition of energy cane, which can
have a wide range of cellulosic contents.
Consistent with that rulemaking, we
have evaluated the cellulosic content of
natural heterogeneity within crops and
the fact that breeders are still
experimenting with sorghum to find
which varieties are best for biofuel
usage, and thus have not yet settled on
any particular sets of ‘‘ideal’’ properties
or compositions for this crop. Breeding
of sorghum to enhance biomass content
is in the early stages, and it is likely that
in the future, these feedstocks may be
bred to contain greater proportions of
cellulose, hemicellulose and lignin.
Data submitted by NexSteppe and
available in the docket indicate that
newer hybrids of sorghum do have
higher percentages of cellulose,
hemicellulose, and lignin, in the range
of 75–81%, with a range of 77–89% for
the adjusted cellulosic content. Some of
the sorghum samples also contained
significant proportions of sugar (0.3–
19%) and starch (0–12%), as shown in
Table 2.
biomass sorghum. The results of
chemical analyses of biomass sorghum
and other types of sorghum are shown
in Table 2 below and derive from two
scientific studies and industry data. One
study found that sorghum selected or
bred for enhanced biomass content was
composed of 61–72% cellulosic
materials, with an average of 67%
cellulosic material, whereas the other
found an average composition of 59%
cellulosic material. When these values
are adjusted to remove the ash content
(which will not yield biofuel),27 the
adjusted cellulosic contents are 75%
and 63%, respectively, from the two
studies (Table 2). Compared to
traditional forage sorghums, one study
found sorghums selected or bred for
biomass content had greater cellulosic
content, whereas the other found they
had lower cellulosic content. These
differences likely reflect both the
TABLE 2—CHEMICAL COMPOSITION OF DIFFERENT TYPES OF SORGHUM SAMPLES, AS DETERMINED BY TWO RESEARCH
STUDIES AND FROM INDUSTRY DATA
[The adjusted cellulosic composition was calculated by adjusting the reported content of cellulose, hemicellulose and lignin for the ash content
and for the total yields]
Source
NexSteppe 30
Chemical composition (%)
Dahlberg et al.
Sorghum variety
Sudan/
sorghum
High-yield
Number of samples ...........................................
Sucrose (sugar):
Average ......................................................
Range .........................................................
Starch:
Average ......................................................
Range .........................................................
Cellulosic Components:
Average ......................................................
Range .........................................................
Adjusted Cellulosic Composition:
Average ......................................................
Range .........................................................
(2011) * 28
Stefaniak et al.
Sudan/
sorghum
Biomass ∧
Forage
(2012) † 29
Forage
Biomass ∧
Sweet
5
4
15
51
6
41
54
7
2.9
1.6–4.6
2.7
0.4–3.5
1.0
0.2–1.7
9.0
0.3–19
2.4
0.4–4.6
1.1
0.2–3.0
9.8
0.2–23.9
4.5
1.2–8.5
0.8
0–4
5.6
0–15
18.1
0–25.2
5.6
0–12.0
1.1
0–4.0
1.8
0–8.9
7.3
0–16.6
3.4
0.3–8.1
66.7
61.3–72.3
62.0
53.8–67.5
54.9
46.8–73.6
59.2
....................
63.9
....................
66.4
....................
58.3
....................
77.5
75.3–80.5
75.4
68.9–82.8
70.0
61.2–75.8
60.5
50.5–84.4
63.2
....................
72.5
....................
70.1
....................
61.8
....................
83.7
77.4–88.6
* This paper analyzed 22 samples of forage sorghum, including some high-yield varieties that could be used for biomass purposes. The four sudan/sorghum varieties include two samples
that were also counted in the high-yield category. The remaining varieties fall into the forage sorghum category.
† This study separated 152 samples of sorghum into groups based on end use, with samples being harvested at different growth stages and containing various tissue types depending on
how the material would ultimately be used. See the original source for more information about the different classes of sorghum.
∧ These sources refer to certain hybrids as ‘‘biomass’’ sorghum. However, this does not necessarily mean that these varieties meet EPA’s 75% adjusted cellulosic content threshold.
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In the July 2014 rule, EPA considered
the cellulosic content of energy cane.
Like biomass sorghum, cane can be bred
for a wide range of cellulosic and sugar
contents. In that rule, EPA defined
‘‘energy cane’’ as cultivars containing at
least 75% adjusted cellulosic content.
EPA also indicated that in the future,
feedstocks that could be bred for a wide
range of uses and fiber content would
have registration requirements similar to
energy cane, in order to demonstrate
that the adjusted cellulosic content of
varieties used is at least 75%. Therefore,
for the purposes of the cellulosic
content issue, EPA intends to treat
biomass sorghum similar to energy cane.
For purposes of this Notice, we consider
biomass sorghum to include varieties
containing at least 75% adjusted
cellulosic content. If, as a result of a
complete lifecycle assessment in
response to individual producer
petitions EPA determines that a given
fuel product made from biomass
sorghum satisfies the 60% lifecycle
GHG reduction requirement for
cellulosic biofuel, 100% of the fuel in
question would qualify for cellulosic
biofuel RINs, provided the producer can
27 Adjustments are also made to account for
percent recoveries less than 100%. If all chemical
components of a feedstock are analyzed, the total
recovery should equal 100%. However, recoveries
may be lower than 100% because of losses during
sample processing. For recoveries less than 100%,
the percent concentration of each component was
adjusted so that the total percent recovery equaled
100%. For more information, see ‘‘Cellulosic
Content of Various Feedstocks—2014 Update.’’
Docket EPA–HQ–OAR–2012–0401.
28 Dahlberg, J., E. Wolfrum, B. Bean, and W.L.
Rooney (2011). Compositional and agronomic
evaluation of sorghum biomass as a potential
feedstock for renewable fuels. Journal of Biobased
Materials and Bioenergy. 5, 1–7. Values include
additional data provided by J. Dahlberg on October
22, 2013.
29 Stefaniak, T.R., J.A. Dahlberg, B.W. Bean, N.
Dighe, E.J. Wolfrum, and W.L. Rooney (2012).
Variation in biomass composition components
among forage, biomass, sorghum-sudangrass and
sweet sorghum types. Crop Science, 52, 1949–1954.
30 For more information, see ‘‘14–10–09
NexSteppe EPA submission.pdf.’’ Docket EPA–HQ–
OAR–2014–0537.
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demonstrate that the varieties they use
as a feedstock contain at least 75%
adjusted cellulosic content and satisfy
all other applicable definitional,
registration, recordkeeping, and
reporting requirements. We would
consider any cultivars with an adjusted
cellulosic content less than 75% to be
forage sorghum, which we are not
addressing in this Notice. See the
discussion regarding energy cane in the
July 2014 rule and accompanying memo
to the docket 31 for a description of the
methodologies and data EPA considers
suitable for demonstrating that the
average adjusted cellulosic content is at
least 75%. We expect that any approved
petition for cellulosic biofuel made from
biomass sorghum would contain
registration requirements comparable to
those set forth at 40 CFR
80.1450(b)(1)(xiv).
III. Summary
EPA invites public comment on its
preliminary analysis of GHG emissions
associated with the cultivation and
transport of biomass sorghum as a
feedstock for biofuel production. EPA
expects to revise its analysis as
appropriate in light of public comments
received, and to thereafter use the
analysis as part of its evaluation of the
lifecycle GHG emissions of biofuel
production pathways described in
petitions received pursuant to 40 CFR
80.1416 which use biomass sorghum as
a feedstock.
Dated: December 17, 2014.
Christopher Grundler,
Director, Office of Transportation and Air
Quality.
[FR Doc. 2014–30712 Filed 12–30–14; 8:45 am]
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–ORD–2014–0882; FRL–9920–92–
ORD]
Human Studies Review Board;
Notification of a Public Meeting
Environmental Protection
Agency.
ACTION: Notice.
AGENCY:
The Environmental Protection
Agency (EPA) Office of the Science
Advisor announces a public meeting of
the Human Studies Review Board to
advise the Agency on the ethical and
scientific reviews of EPA research with
human subjects.
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SUMMARY:
31 79 FR 42128; ‘‘Cellulosic Content of Various
Feedstocks—2014 Update.’’ Docket EPA–HQ–OAR–
2012–0401.
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This public meeting will be held
on January 14, 2015, from
approximately 10:00 a.m. to
approximately 5:00 p.m. Eastern Time.
Comments may be submitted on or
before noon (Eastern Time) on
Wednesday, January 7, 2015.
ADDRESSES: The meeting will be
conducted entirely on the Internet using
Adobe Connect. Registration is required
to attend this meeting. Please visit the
HSRB Web site: https://www.epa.gov/
hsrb to register.
Comments: Submit your written
comments, identified by Docket ID No.
EPA–HQ–ORD–2014–0882, by one of
the following methods:
Internet: https://www.regulations.gov:
Follow the online instructions for
submitting comments.
Email: ORD.Docket@epa.gov.
Mail: The EPA Docket Center EPA/
DC, ORD Docket, Mail code: 28221T,
1200 Pennsylvania Avenue NW.,
Washington, DC 20460.
Hand Delivery: The EPA/DC Public
Reading Room is located in the EPA
Headquarters Library, Room Number
3334 in the EPA WJC West, at 1301
Constitution Avenue NW., Washington,
DC 20460. The hours of operation are
8:30 a.m. to 4:30 p.m. Eastern Time,
Monday through Friday, excluding
federal holidays. Please call (202) 566–
1744 or email the ORD Docket at
ord.docket@epa.gov for instructions.
Updates to Public Reading Room access
are available on the Web site https://
www.epa.gov/epahome/dockets.htm.
Instructions: The Agency’s policy is
that all comments received will be
included in the public docket without
change and may be made available
online at https://www.regulations.gov,
including any personal information
provided, unless the comment includes
information claimed to be Confidential
Business Information or other
information the disclosure of which is
restricted by statute. Do not submit
information that you consider to be CBI
or otherwise protected through https://
www.regulations.gov or email. The
https://www.regulations.gov Web site is
an ‘‘anonymous access’’ system, which
means EPA will not know your identity
or contact information unless you
provide it in the body of your comment.
If you send an email comment directly
to the EPA without going through
https://www.regulations.gov, your email
address will be automatically captured
and included as part of the comment
that is placed in the public docket and
made available on the Internet. If you
submit an electronic comment, the EPA
recommends that you include your
name and other contact information in
DATES:
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the body of your comment and with any
electronic storage media you submit. If
the EPA cannot read your comment due
to technical difficulties and cannot
contact you for clarification, the EPA
may not be able to consider your
comment. Electronic files should avoid
the use of special characters, any form
of encryption, and be free of any defects
or viruses.
Any
member of the public who wishes to
receive further information should
contact Jim Downing at telephone
number (202) 564–2468; fax: (202) 564–
2070; email address: downing.jim@
epa.gov; mailing address Environmental
Protection Agency, Office of the Science
Advisor, Mail code 8105R, 1200
Pennsylvania Avenue NW., Washington,
DC 20460. General information
concerning the EPA HSRB can be found
on the EPA Web site at https://
www.epa.gov/hsrb.
FOR FURTHER INFORMATION CONTACT:
SUPPLEMENTARY INFORMATION:
Meeting access: Access to this Internet
meeting is open to all at the information
provided above.
Procedures for providing public input:
Interested members of the public may
submit relevant written or oral
comments for the HSRB to consider
during the advisory process. Additional
information concerning submission of
relevant written or oral comments is
provided in Section I, ‘‘Public Meeting’’
under subsection D. ‘‘How May I
Participate in this Meeting?’’ of this
notice.
I. Public Meeting
A. Does this action apply to me?
This action is directed to the public
in general. This Notice may, however,
be of particular interest to persons who
conduct or assess human studies,
especially studies on substances
regulated by the EPA, or to persons who
are, or may be required to conduct
testing of chemical substances under the
Federal Food, Drug, and Cosmetic Act
or the Federal Insecticide, Fungicide,
and Rodenticide Act. This notice might
also be of special interest to participants
of studies involving human subjects, or
representatives of study participants or
experts on community engagement. The
Agency has not attempted to describe all
the specific entities that may have
interest in human subjects research. If
you have any questions regarding this
notice, consult Jim Downing listed
under FOR FURTHER INFORMATION
CONTACT.
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Agencies
[Federal Register Volume 79, Number 250 (Wednesday, December 31, 2014)]
[Notices]
[Pages 78855-78861]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-30712]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2014-0537-; FRL-9921-15-OAR]
Notice of Opportunity To Comment on the Lifecycle Greenhouse Gas
Emissions for Renewable Fuels Produced From Biomass Sorghum
AGENCY: Environmental Protection Agency.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: In this Notice, the Environmental Protection Agency (EPA) is
inviting comment on its preliminary analysis of the greenhouse gas
(GHG) emissions attributable to the growth and transport of biomass
sorghum feedstock for use in making biofuels such as ethanol or diesel.
This notice explains EPA's analysis of the growth and transport
components of the lifecycle greenhouse gas emissions from biomass
sorghum, and describes how EPA may apply this analysis in the future to
determine whether biofuels produced from such biomass sorghum meet the
necessary GHG reductions required for qualification under the Renewable
Fuels Standard (RFS) program. Based on this analysis, we anticipate
that biofuels produced from biomass sorghum could qualify for
cellulosic biofuel renewable identification numbers (RINs) if certain
fuel production process technology conditions are met.
DATES: Comments must be received on or before January 30, 2015.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2014-0537, by one of the following methods:
https://www.regulations.gov. Follow the on-line
instructions for submitting comments.
Email: a-and-r-docket@epa.gov, Attention Air and Radiation
Docket ID No. EPA-HQ-OAR-2014-0537.
Mail: Air and Radiation Docket, Docket No. EPA-HQ-OAR-
2014-0537, Environmental Protection Agency, Mail code: 28221T, 1200
Pennsylvania Ave. NW., Washington, DC 20460.
Hand Delivery: EPA Docket Center, EPA/DC, EPA WJC West,
Room 3334, 1301 Constitution Ave. NW., Washington, DC 20460, Attention
Air and Radiation Docket, ID No. EPA-HQ-OAR-2014-0537. Such deliveries
are only accepted during the Docket's normal hours of operation, and
special arrangements should be made for deliveries of boxed
information.
Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-
2014-0537. EPA's policy is that all comments received will be included
in the public docket without change and may be made available online at
www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through www.regulations.gov or email. The
www.regulations.gov Web site is an ``anonymous access'' system, which
means EPA will not know your identity or contact information unless you
provide it in the body of your comment. If you send an email comment
directly to EPA without going through www.regulations.gov, your email
address will be automatically captured and included as part of the
comment that is placed in the public docket and made available on the
Internet. If you submit an electronic comment, EPA recommends that you
include your name and other contact information in the body of your
comment and with any disk or CD-ROM you submit. If EPA cannot read your
comment due to technical difficulties and cannot contact you for
clarification, EPA may not be able to consider your comment. Electronic
files should avoid the use of special characters, any form of
encryption, and be free of any defects or viruses. For additional
information about EPA's public docket visit the EPA Docket Center
homepage at https://www.epa.gov/epahome/dockets.htm.
Docket: All documents in the docket are listed in the
www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., CBI or other information
for which disclosure is restricted by statute. Certain other material,
such as copyrighted material, will be publicly
[[Page 78856]]
available only in hard copy. Publicly available docket materials are
available either electronically in www.regulations.gov or in hard copy
at the Air and Radiation Docket, EPA/DC, EPA West, Room 3334, 1301
Constitution Ave. NW., Washington, DC. The Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays. The telephone number for the Public Reading Room is (202)
566-1744, and the telephone number for the Air and Radiation Docket is
(202) 566-1742.
FOR FURTHER INFORMATION CONTACT: Jon Monger, Office of Transportation
and Air Quality, Mail Code: 6406J, U.S. Environmental Protection
Agency, 1200 Pennsylvania Avenue NW., 20460; telephone number: (202)
564-0628; fax number: (202) 564-1686; email address:
monger.jon@epa.gov.
SUPPLEMENTARY INFORMATION:
This notice is organized as follows:
I. Introduction
II. Analysis of Greenhouse Gas Emissions Associated With use of
Biomass Sorghum as a Biofuel Feedstock
A. Feedstock Description, Production, and Distribution
B. Summary of Agricultural Sector Greenhouse Gas Emissions
C. Fuel Production and Distribution
D. Cellulosic Content of Biomass Sorghum
III. Summary
I. Introduction
As part of changes to the Renewable Fuel Standard (RFS) program
regulations published on March 26, 2010 \1\ (the ``March 2010 rule''),
EPA specified the types of renewable fuels eligible to participate in
the RFS program through approved fuel pathways. Table 1 to 40 CFR
80.1426 of the RFS regulations lists three critical components of an
approved fuel pathway: (1) Fuel type; (2) feedstock; and (3) production
process. Fuel produced pursuant to each specific combination of the
three components, or fuel pathway, is designated in the Table as
eligible for purposes of the Act's requirements for greenhouse gas
reductions, to qualify as renewable fuel or one of three subsets of
renewable fuel (biomass-based diesel, cellulosic biofuel or advanced
biofuel). EPA may also independently approve additional fuel pathways
not currently listed in Table 1 to Sec. 80.1426 for participation in
the RFS program, or a third-party may petition for EPA to evaluate a
new fuel pathway in accordance with 40 CFR 80.1416.
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\1\ See 75 FR 14670.
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EPA's lifecycle analyses are used to assess the overall greenhouse
gas impacts of a fuel throughout each stage of its production and use.
The results of these analyses, considering uncertainty and the weight
of available evidence, are used to determine whether a fuel meets the
necessary greenhouse gas reductions required under the Clean Air Act
(CAA) for it to be considered renewable fuel or one of the subsets of
renewable fuel. Lifecycle analysis includes an assessment of emissions
related to the full fuel lifecycle, including feedstock production,
feedstock transportation, fuel production, fuel transportation and
distribution, and tailpipe emissions. Per the CAA definition of
lifecycle GHG emissions, EPA's lifecycle analyses also include an
assessment of significant indirect emissions such as emissions from
land use changes, agricultural sector impacts, and production of co-
products from biofuel production.
Pursuant to 40 CFR 80.1416, EPA received a petition from the
National Sorghum Producers (NSP), submitted under a claim of
confidential business information (CBI), requesting that EPA evaluate
the lifecycle GHG emissions for biofuels produced using a biomass
sorghum feedstock, and that EPA provide a determination of the
renewable fuel categories, if any, for which such biofuels may be
eligible. As an initial step in this process, EPA has conducted a
preliminary evaluation of the GHG emissions associated with the growth
and transport of biomass sorghum when it is used as a biofuel
feedstock, and is seeking public comment on the methodology and results
of this preliminary evaluation.
After considering comments received, EPA expects to revise its
assessment as appropriate and then use the information to evaluate
petitions received pursuant to 40 CFR 80.1416 which propose to use
biomass sorghum as a feedstock for the production of biofuel, and which
seek an EPA determination regarding whether such biofuels qualify as
renewable fuel under the RFS program. In evaluating such petitions, EPA
will consider the GHG emissions associated with petitioners' biofuel
production processes, as well as emissions associated with the
transport and use of the finished biofuel, in addition to the GHG
emissions associated with the use and transport of biomass sorghum
feedstock in determining whether petitioners' proposed biofuel
production pathway satisfies CAA renewable fuel lifecycle GHG reduction
requirements.
II. Analysis of Greenhouse Gas Emissions Associated With Use of Biomass
Sorghum as a Biofuel Feedstock
To evaluate the lifecycle GHG emissions associated with the use of
biomass sorghum feedstock to produce biofuels, we used a similar
approach to that used for miscanthus in the March 2010 rule, in which
GHG emissions associated with the growth and transport of miscanthus
was determined by comparing feedstock-related GHG emissions to those of
switchgrass. In the March 2010 rule, EPA determined that biofuel made
from switchgrass using designated processes meets the GHG emissions
reduction threshold for cellulosic fuels. For miscanthus, new
agricultural modeling was deemed unnecessary; EPA ultimately determined
that miscanthus would have similar lifecycle GHG emissions to
switchgrass and therefore that biofuels made from designated processes
using miscanthus as a feedstock would have similar lifecycle GHG
emissions as similar biofuels made through the same processes with
switchgrass. EPA also followed a similar approach in assessing GHG
emissions associated with the use of energy cane, giant reed, and
napier grass in rules published on March 5, 2013 (the ``March 2013
rule'') \2\ and July 11, 2013 (the ``July 2013 rule'').\3\
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\2\ 78 FR 14190.
\3\ 78 FR 41703.
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As described in detail in the following sections of this notice,
EPA believes that new agricultural sector modeling is not needed to
analyze biomass sorghum. Instead, we evaluated the agricultural sector
GHG emissions impacts of using biomass sorghum by reference to
switchgrass. Both biomass sorghum and switchgrass are grasses with high
yields and high cellulosic contents. Our preliminary assessment
indicates that on a per dry ton of feedstock basis indirect land use
emissions would be lower, direct emissions associated with use of farm
machinery, fertilizers and pesticides would be lower, and that
emissions associated with feedstock transport would be the same as for
switchgrass. Therefore, we propose in responding to petitions received
pursuant to 40 CFR 80.1416 to assume that on a per dry ton of feedstock
basis GHG emissions associated with biomass sorghum production and use
are the same as those associated with the production and use of
switchgrass for biofuel production. We believe that this is a
conservative approach, and we invite comment on it.
[[Page 78857]]
A. Feedstock Description, Production, and Distribution
Although all types of cultivated sorghum belong to the species
Sorghum bicolor (L.) Moench, breeding for different purposes has led to
significant variation within this species. Sorghum is native to Africa,
but was introduced to the U.S. in the early 17th century. Historically,
sorghum has been bred to be used as a grain, a source of sugar, and as
animal forage. More recently, it has also been bred to increase
biomass. Different types of sorghum have different characteristics and
may therefore qualify as different types of renewable fuels under the
RFS program, making it important to distinguish among the different
types of sorghums.
Grain Sorghum. In the U.S., grain sorghum is commonly used as
animal feed similar to feed corn, although in other parts of the world
it is used for human consumption. Pathways for ethanol produced from
grain sorghum feedstock were approved in a rule published on December
17, 2012 (the ``December 2012 RFS rule'').\4\
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\4\ See 77 FR 74592.
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Sweet Sorghum. Sweet sorghum has historically been bred to maximize
sugar content, and is crushed to yield a juice that is high in sugars
that are easily fermentable. Processing sweet sorghum is similar to
processing sugarcane, and the resulting juice can be used to produce
sorghum syrup for food consumption or as a biofuel feedstock.
Forage sorghum. Varieties of forage sorghum are typically used for
animal grazing. These varieties of sorghum have been bred for optimal
nutrition, including high content of digestible nutrients and low
lignin content.
Sorghum bred for biomass content. Recently, producers have begun
breeding sorghum as a feedstock for biofuel production, beginning with
forage sorghum varieties. The goal of these breeding efforts has been
to maximize the total biomass yield for use as biofuel feedstock. The
resultant sorghum varieties generally have greatly enhanced biomass
yields (plants can grow to be over 20 feet tall), longer growing
seasons, and lower nitrogen demand because digestibility is not a
concern.
Differentiating the types of sorghum for purposes of the lifecycle
analysis required under the RFS program is challenging because
varieties bred for different purposes all belong to the same species
and are often defined based on end-use, rather than based on specific
physical characteristics.\5\ For purposes of this Notice, EPA considers
biomass sorghum to be Sorghum bicolor that has been selected or bred to
maximize cellulosic content rather than sugar or grain content, and
which therefore has at least 75% cellulosic content. EPA also considers
hybrids that are crosses of Sorghum bicolor and sudangrass \6\ to be
biomass sorghum if they have 75% cellulosic content, but EPA does not
consider hybrids that are crosses of Sorghum bicolor and Johnsongrass
(Sorghum halepense) to be biomass sorghum, even if such hybrids have
75% or higher cellulosic content. This approach is consistent with the
NSP petition, which explicitly excluded Johnsongrass due to concerns
regarding its potential to behave as an invasive species. See Section
II.D. for further discussion of varieties considered biomass sorghum
for purposes of this Notice.
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\5\ E.g. Stefaniak, T.R., J.A. Dahlberg, B.W. Bean, N. Dighe,
E.J. Wolfrum, and W.L. Rooney (2012). Variation in biomass
composition components among forage, biomass, sorghum-sudangrass and
sweet sorghum types. Crop Science, 52, 1949-1954.
\6\ Sudangrass (Sorghum x drummondii) is a forage grass which is
commonly crossed with Sorghum bicolor to produce hybrids. FAO
Grassland Species Profile, https://www.fao.org/ag/agp/AGPC/doc/gbase/data/pf000494.HTM. Accessed 15 September, 2014.
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1. Crop Yields
For the purposes of analyzing the GHG emissions from biomass
sorghum production, EPA examined crop yields and production inputs in
relation to switchgrass to assess the relative GHG impacts. For the
switchgrass lifecycle analysis, EPA assumed national average yields of
approximately 4.5 to 5 dry tons per acre.\7\ Based on field trials in
nine states under a range of growing conditions, the 2012 average yield
of sorghum grown for biomass content is approximately 11 dry tons per
acre,\8\ suggesting that biomass sorghum will have significantly higher
yields than switchgrass.
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\7\ Kumar, A. and S. Sokhansanj (2007). ``Switchgrass (Panicum
vigratum, L,) delivery to a biorefinery using integrated biomass
supply analysis and logistics (IBSAL) model.'' Bioresource
Technology, 98:1033-1044. A more recent study compiled switchgrass
yield data from 45 studies from 1991-2010, and found an average
yield of 4.9 dry tons per acre: Maughan, M.W. (2011) ``Evaluation of
switchgrass, M. x giganteus, and sorghum as biomass crops: Effects
of environment and field management practices.'' Ph.D. Dissertation,
University of Illinois at Urbana-Champaign.
\8\ Petition, based on data from 8 sources. A study of the yield
of biomass sorghum in Illinois found yields from 10.1-13.4 dry tons/
acre: Maughan, M.W. (2011). ``Evaluation of switchgrass, M. x
giganteus, and sorghum as biomass crops: Effects of environment and
field management practices.'' Ph.D. Dissertation, University of
Illinois at Urbana-Champaign.
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Furthermore, EPA's analysis of switchgrass for the RFS rulemaking
assumed a 2% annual increase in yield that would result in an average
national yield of 6.6 dry tons per acre in 2022.\9\ EPA anticipates
similar yield improvements for biomass sorghum as for switchgrass since
both feedstocks are energy crops in the early stages of development,
and improvements in farming practices or new hybrids could increase the
yield over time.\10\ Given the potential for yield improvements, our
analysis assumed an average biomass sorghum yield of 13 dry tons per
acre in the southern United States by 2022, which was calculated using
a 2% annual increase in yield.
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\9\ A recently released switchgrass cultivar, ``Liberty'' has a
yield of 8.1 tons/acre in Nebraska (7.3 dry tons/acre, assuming a
dry matter content of 90%). As hybrids like this become more
commonly used, average national yields will increase; Vogel, K.P.,
R.B. Mitchell, M.D. Casler and G. Sarath (2014). ``Registration of
`Liberty' Switchgrass.'' Journal of Plant Registrations, 8:242-247.
\10\ Progress is being made in developing new biomass sorghum
hybrids with higher yields than the parents. Increased used of these
hybrids will increase national average yields. Packer, D.J. and W.L.
Rooney (2014). ``High-parent heteropsis for biomass yield in
photoperiod-sensitive sorghum hybrids.'' Field Crops Research,
167:153-158.
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Because of its higher yield, biomass sorghum grown in areas with
suitable growing conditions would require approximately 50% less land
area compared to switchgrass to produce the same amount of biomass.
Even without yield growth assumptions, the current higher crop yield
means the land use required for biomass sorghum should be lower than
for switchgrass. Therefore less crop area would be converted and
displaced through use of biomass sorghum as compared to switchgrass.
2. Land Use
Biomass sorghum is not currently grown at commercial scale in the
United States for the purpose of biofuel production, although
approximately 1.4 million acres of forage sorghum were planted in 2012.
Biomass sorghum is currently grown in test plots as part of research to
develop it as an energy crop, and currently has no other uses. Biomass
sorghum can be planted as early as April and can continue growing until
the fall.\11\ Production is expected to be concentrated in the South
Central U.S. in Texas, Oklahoma and Kansas, as well as in Missouri and
Arkansas.\12\
[[Page 78858]]
These areas are similar to the acres where our agricultural sector
modeling projected switchgrass would be grown in the March 2010 rule.
In addition, modeling results presented in DOE's Billion-Ton Update
suggest that biomass sorghum and switchgrass will be grown in similar
regions.\13\
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\11\ Blade Energy Crops (2010). ``Managing High-Biomass Sorghum
as a Dedicated Energy Crop.'' Available at: www.bladeenergy.com/Bladepdf/Blade_SorghumMgmtGuide2010.pdf.
\12\ According to DOE's Billion-Ton Update, ``dedicated biomass
sorghums grow well throughout the eastern and central United States
as far north at 40[deg] latitude.'' Department of Energy (DOE)
(2011). U.S. Billion-Ton Update: Biomass Supply for a Bioenergy and
Bioproducts Industry, https://www1.eere.energy.gov/biomass/pdfs/billion_ton_update.pdf. DOE's Billion Ton study conducted a
technical analysis of the amount of potential biomass that could be
produced in the U.S. under a range of different conditions. This
study showed that biomass sorghum and switchgrass have the potential
to contribute enough biomass to exceed the volumes of cellulosic
biofuel required by the CAA. The purpose of EPA's 2010 analysis was
to estimate one potential scenario for meeting the biofuel volume
requirements in the CAA, not to estimate the maximum potential
volumes of biofuels that could be produced in the U.S.
\13\ Department of Energy (DOE) (2011). U.S. Billion-Ton Update:
Biomass Supply for a Bioenergy and Bioproducts Industry, https://www1.eere.energy.gov/biomass/pdfs/billion_ton_update.pdf.
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In EPA's analysis for the March 2010 rule, switchgrass plantings
were projected to primarily displace soybeans and wheat, and to a
lesser extent hay, rice, grain sorghum, and cotton in the South Central
U.S. Because biomass sorghum is likely to be grown on similar existing
agricultural land in the same regions, as explained above, and because
biomass sorghum yields are higher than yields of switchgrass (so should
displace fewer total acres) EPA concludes that the indirect land use
GHG impact for biomass sorghum per gallon should be no greater and
likely less than estimated for switchgrass.
In the switchgrass ethanol scenario done for the March 2010 rule,
total cropland acres were projected to increase by 4.2 million acres,
including an increase of 12.5 million acres of switchgrass and
decreases of 4.3 million acres of soybeans, 1.4 million acres of wheat,
and 1 million acres of hay, as well as smaller decreases in a variety
of other crop acreages. This analysis took into account the economic
conditions such as input costs and commodity prices when evaluating the
GHG and land use change impacts of switchgrass. Given the higher yields
of the biomass sorghum considered here compared to switchgrass, there
should be ample land available for production without having any
adverse impacts beyond those projected for switchgrass production.
The indirect land use impacts for biomass sorghum are assumed to be
similar to or less than those modeled for switchgrass. The
justification for this assumption is that both crops are expected to be
grown in the South Central U.S. and will likely displace the same types
of cropland, but because of higher biomass sorghum yields, fewer total
acres will be displaced per gallon of fuel produced.\14\ Furthermore,
we believe biomass sorghum will have a similar impact on international
markets as assumed for switchgrass. Like switchgrass, biomass sorghum
is not expected to be traded internationally and its impacts on other
crops are expected to be limited. Accordingly, indirect land use change
GHG emissions associated with biomass sorghum would likely be smaller
than such emissions for switchgrass. Thus, we believe that our proposal
to assume in our lifecycle GHG emissions assessments that indirect land
use change GHG emissions from biomass sorghum would be similar to
switchgrass represents a conservative approach.
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\14\ Department of Energy (DOE) (2011). U.S. Billion-Ton Update:
Biomass Supply for a Bioenergy and Bioproducts Industry, https://www1.eere.energy.gov/biomass/pdfs/billion_ton_update.pdf.
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3. Crop Inputs and Feedstock Transport
EPA also assessed the GHG impacts associated with planting,
harvesting, and transporting biomass sorghum in comparison to
switchgrass. Table 1 below shows the assumed 2022 commercial-scale
production inputs for switchgrass modeled for the March 2010 rule and
average biomass sorghum production inputs based on U.S. Department of
Agriculture (USDA) projections and industry data. Available data
gathered by EPA suggest that biomass sorghum requires on average less
nitrogen, phosphorous, potassium, and pesticide than switchgrass per
dry ton of biomass, but more herbicide and diesel per dry ton of
biomass. The inputs were given to EPA from the petitioners based on
field trials, verified by the USDA, and documented in peer-reviewed
journals where possible. Since biomass sorghum is an annual crop and
switchgrass is a perennial, some inputs required for growing biomass
sorghum, such as herbicide and diesel, are slightly higher than inputs
for switchgrass (see Table 1 below). Applying the GHG emission factors
used for the March 2010 rule, biomass sorghum production results in
lower GHG emissions per dry ton of biomass produced relative to
switchgrass production, as shown in Table 1, below. More information on
biomass sorghum inputs is available in the docket.
Table 1--Direct Inputs for Switchgrass and Biomass Sorghum \15\
----------------------------------------------------------------------------------------------------------------
Switchgrass \16\ Biomass sorghum \17\
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Category Inputs (per dry Emissions (per dry Inputs (per dry Emissions (per dry
ton of biomass) ton of feedstock) ton of biomass) ton of feedstock)
----------------------------------------------------------------------------------------------------------------
Yield (Projected)............... 6.6 dry tons/acre. .................. 13 dry ton/acre ..................
Nitrogen Fertilizer............. 15.2 lbs/dry ton.. 25 kg CO2eq....... 4.6 lbs/dry ton... 8 kg CO2eq
N2O............................. N/A............... 136 kg CO2eq...... N/A............... 105 kg CO2eq
Phosphorus Fertilizer........... 6.1 lbs/dry ton... 3 kg CO2eq........ 1.2 lbs/dry ton... 0.6 kg CO2eq
Potassium Fertilizer............ 6.1 lbs/dry ton... 2 kg CO2eq........ 0.5 lbs/dry ton... 0.2 kg CO2eq
Herbicide....................... 0.002 lbs/dry ton. 0.02 kg CO2eq..... 0.4 lbs/dry ton... 5 kg CO2eq
Insecticide..................... 0.02 lbs/dry ton.. 0.3 kg CO2eq...... 0.003 lbs/dry ton. 0.05 kg CO2eq
Lime............................ 0 lbs/dry ton..... 0 kg CO2eq........ 0 lbs/dry ton..... 0 kg CO2eq
Diesel.......................... 0.4 gal/dry ton... 6 kg CO2eq........ 0.7 gal/dry ton... 9 kg CO2eq
Electricity (irrigation)........ 0 kWh/dry ton..... 0 kg CO2eq........ 0.0 kWh/dry ton... 0 kg CO2eq
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Total GHG emissions......... .................. 173 kg CO2eq...... .................. 128 kg CO2eq
----------------------------------------------------------------------------------------------------------------
[[Page 78859]]
The lifecycle GHG emissions associated with distributing biomass
sorghum feedstock are expected to be similar to EPA's estimates for
switchgrass feedstock. One major difference is that switchgrass has a
longer harvest window than biomass sorghum. Biomass sorghum is
typically harvested in the fall, whereas switchgrass can be harvested
from July to March. This suggests that for fuel production purposes,
harvested switchgrass would not need to be stored as long as biomass
sorghum because it would be available directly from the field for a
longer period of time.\18\ However, harvesting switchgrass just once
per year, in the fall, can maximize yield and minimize nutrient
inputs.\19\ Therefore, even though switchgrass could be harvested more
often, in practice it may just be harvested once per year in the fall,
like biomass sorghum. In addition, the biomass sorghum harvest window
can be extended by staggering planting times, using a range of hybrids
with different harvesting times, or using multiple cuttings, which
would reduce storage needs.\20\ When switchgrass and biomass sorghum
need to be stored, both can be stored in bales.\21\
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\15\ The IPCC equations for N2O emissions were
updated since our earlier analysis of switchgrass. We use the
updated equations here.
\16\ Beach, R.H. and B.A. McCarl (2010). U.S. Agricultural and
Forestry Impacts of the Energy Independence and Security Act: FASOM
Results and Model Description. Docket EPA-HQ-OAR-2005-0161-3178.
\17\ Input data are from petitioners, peer-reviewed literature,
and USDA. Details on the sources of input data can be found in the
docket. Emissions are calculated based on the input data and
emission factors.
\18\ Haque, M. and F. M. Epplin (2012). ``Cost to produce
switchgrass and cost to produce ethanol from switchgrass for several
levels of biorefinery investment cost and biomass to ethanol
conversion rates.'' Biomass and Bioenergy, 46:517-530.
\19\ Mitchell, R. B., and M. R. Schmer (2012). ``Switchgrass
harvest and storage.'' Switchgrass. A. Monti (ed.), London:
Springer-Verlag, 113-127; Garland, C. D., et al. (2008). ``Growing
and harvesting switchgrass for ethanol production in Tennessee.''
University of Tennessee Agricultural Extension Service.
\20\ Turhollow, A. F. E. G. Webb, and M. E. Downing (2010).
``Review of sorghum production practices: Applications for
Bioenergy.'' Oak Ridge National Laboratory, Oakridge, TN. Available
at: https://info.ornl.gov/sites/publications/files/Pub22854.pdf;
Blade Energy Crops (2010). ``Managing high-biomass sorghum as a
dedicated energy crop.'' Available at: https://www.bladeenergy.com/Bladepdf/Blade_SorghumMgmtGuide2010.pdf.
\21\ Blade Energy Crops (2010). ``Managing high-biomass sorghum
as a dedicated energy crop.'' Available at: https://www.bladeenergy.com/Bladepdf/Blade_SorghumMgmtGuide2010.pdf;
Sanderson, M. A., R. P. Egg, and A. E. Wiselogel (1997). ``Biomass
losses during harvest and storage of switchgrass.'' Biomass and
Bioenergy, 12(2):107-114.
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Biomass sorghum is expected to achieve higher yields and thus the
feedstock distribution radius around a similar sized biofuel production
plant, or biomass collection hub, could be lower for biomass sorghum
than for switchgrass. Therefore, even though there can be differences
in the harvest period of switchgrass and biomass sorghum, our analysis
makes the simplifying assumption that both crops require similar
transport, loading, unloading, and storage regimes, and have the same
GHG emissions for feedstock distribution, on a per dry ton of feedstock
basis. Harvesting, storage, and distribution were a small fraction of
the total GHG emissions for switchgrass, so we do not believe this
simplification substantially affects our lifecycle analysis.
B. Summary of Agricultural Sector Greenhouse Gas Emissions
Based on our comparison of biomass sorghum to switchgrass, EPA
proposes to use, in its future evaluations of petitions proposing to
use biomass sorghum as feedstock for biofuel production, an estimate of
the GHG emissions associated with the cultivation and transport of
biomass sorghum that is the same as that which we have used for
switchgrass, on a per dry ton of feedstock basis. EPA solicits comment
on this proposed approach.
C. Fuel Production and Distribution
Biomass sorghum is suitable for the same conversion processes as
approved cellulosic feedstocks such as switchgrass and corn stover.
After reviewing comments received in response to this Notice, we will
combine our evaluation of agricultural sector GHG emissions associated
with the use of biomass sorghum feedstock with our evaluation of the
GHG emissions associated with individual producers' production
processes and finished fuels to determine whether the proposed pathways
satisfy CAA lifecycle GHG emissions reduction requirements for RFS-
qualifying renewable fuels. Based on our evaluation of the lifecycle
GHG emissions attributable to the growth and transport of biomass
sorghum feedstock, EPA anticipates that fuel produced from biomass
sorghum feedstock through the same biochemical or thermochemical
process technologies that EPA evaluated for the March 2010 RFS rule for
biofuel derived from switchgrass feedstock would qualify for cellulosic
biofuel (D-code 3) renewable identification numbers (RINs) or
cellulosic diesel (D-code 7) RINs depending on the type of fuel
produced.\22\ However, EPA will evaluate petitions for fuel produced
from biomass sorghum feedstock on a case-by-case basis.\23\
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\22\ The biochemical and thermochemical processes that EPA
evaluated for the March 2010 RFS rule for biofuel derived from
switchgrass feedstock are described in section 2.4.7.4 (Cellulosic
Biofuel) of the Regulatory Impact Analysis for the March 2010 RFS
rule (EPA-420-R-10-006).
\23\ Similarly, EPA anticipates that naphtha produced from
biomass sorghum feedstock through any of the gasification and
upgrading processes that EPA evaluated in the March 2010 RFS rule
(78 FR 14190) for biofuel derived from switchgrass feedstock would
likely qualify for cellulosic biofuel (D-code 3) RINs, but EPA
intends to evaluate petitions for naphtha produced from biomass
sorghum feedstock on a case-by-case basis.
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D. Cellulosic Content of Biomass Sorghum
For biomass sorghum-derived biofuels to qualify as cellulosic
biofuel under the RFS program, the fuel must achieve a 60% lifecycle
GHG reduction as compared to the 2005 baseline fuels, and must also be
derived from cellulose, hemicellulose and lignin. This section of the
Notice discusses our preliminary analysis of the extent to which fuel
made from biomass sorghum may qualify as derived from cellulose,
hemicellulose and lignin. For simplicity, these three chemicals are
hereafter referred to as ``cellulose,'' and their presence in feedstock
as the feedstock's ``cellulosic content.''
In the rule published on July 18, 2014 (the ``July 2014
rule''),\24\ EPA determined that fuel generated from feedstocks with an
average adjusted cellulosic content \25\ of 75% or more is eligible to
generate cellulosic biofuel RINs for the entire fuel volume. EPA
examined the biochemical composition of different feedstocks commonly
understood to be ``cellulosic,'' including corn stover and other crop
residues, switchgrass, miscanthus, energy cane, giant reed, napier
grass, and various woods and tree branches. Based on this work, EPA
found that roughly 75-90% of the organic biomass of these feedstocks
was cellulosic, and the balance was comprised of other constituents,
such as starches and sugars.\26\ EPA considered in the July 2014 rule
the extent to which fuel made from these and other feedstocks with some
amount of cellulosic content
[[Page 78860]]
should be considered ``cellulosic biofuel,'' and determined in the rule
that the entire volume of fuel derived from feedstocks with at least
75% adjusted cellulosic content should be considered cellulosic
biofuel. Fuel made from feedstocks having less cellulosic content could
qualify for the generation of cellulosic biofuel RINs for a portion of
the finished fuel.
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\24\ ``Regulation of Fuels and Fuel Additives: RFS Pathways II,
and Technical Amendments to the RFS Standards and E15 Misfueling
Mitigation Requirements.'' 79 FR 42128.
\25\ Adjusted cellulosic content is the percent of organic
material that is cellulose, hemicellulose, and lignin.
\26\ See ``Cellulosic Content of Various Feedstocks--2014
Update.'' Docket EPA-HQ-OAR-2012-0401.
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In the July 2014 rule, EPA described in more detail why we believed
that setting the threshold at 75% percent appropriately implements the
statutory requirements while not imposing excessive administrative
burden on industry. In that rulemaking, EPA also explained that we
would apply the 75% threshold to feedstocks that we evaluated in the
future, and finalized a definition of energy cane, which can have a
wide range of cellulosic contents. Consistent with that rulemaking, we
have evaluated the cellulosic content of biomass sorghum. The results
of chemical analyses of biomass sorghum and other types of sorghum are
shown in Table 2 below and derive from two scientific studies and
industry data. One study found that sorghum selected or bred for
enhanced biomass content was composed of 61-72% cellulosic materials,
with an average of 67% cellulosic material, whereas the other found an
average composition of 59% cellulosic material. When these values are
adjusted to remove the ash content (which will not yield biofuel),\27\
the adjusted cellulosic contents are 75% and 63%, respectively, from
the two studies (Table 2). Compared to traditional forage sorghums, one
study found sorghums selected or bred for biomass content had greater
cellulosic content, whereas the other found they had lower cellulosic
content. These differences likely reflect both the natural
heterogeneity within crops and the fact that breeders are still
experimenting with sorghum to find which varieties are best for biofuel
usage, and thus have not yet settled on any particular sets of
``ideal'' properties or compositions for this crop. Breeding of sorghum
to enhance biomass content is in the early stages, and it is likely
that in the future, these feedstocks may be bred to contain greater
proportions of cellulose, hemicellulose and lignin. Data submitted by
NexSteppe and available in the docket indicate that newer hybrids of
sorghum do have higher percentages of cellulose, hemicellulose, and
lignin, in the range of 75-81%, with a range of 77-89% for the adjusted
cellulosic content. Some of the sorghum samples also contained
significant proportions of sugar (0.3-19%) and starch (0-12%), as shown
in Table 2.
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\27\ Adjustments are also made to account for percent recoveries
less than 100%. If all chemical components of a feedstock are
analyzed, the total recovery should equal 100%. However, recoveries
may be lower than 100% because of losses during sample processing.
For recoveries less than 100%, the percent concentration of each
component was adjusted so that the total percent recovery equaled
100%. For more information, see ``Cellulosic Content of Various
Feedstocks--2014 Update.'' Docket EPA-HQ-OAR-2012-0401.
\28\ Dahlberg, J., E. Wolfrum, B. Bean, and W.L. Rooney (2011).
Compositional and agronomic evaluation of sorghum biomass as a
potential feedstock for renewable fuels. Journal of Biobased
Materials and Bioenergy. 5, 1-7. Values include additional data
provided by J. Dahlberg on October 22, 2013.
\29\ Stefaniak, T.R., J.A. Dahlberg, B.W. Bean, N. Dighe, E.J.
Wolfrum, and W.L. Rooney (2012). Variation in biomass composition
components among forage, biomass, sorghum-sudangrass and sweet
sorghum types. Crop Science, 52, 1949-1954.
\30\ For more information, see ``14-10-09 NexSteppe EPA
submission.pdf.'' Docket EPA-HQ-OAR-2014-0537.
Table 2--Chemical Composition of Different Types of Sorghum Samples, as Determined by Two Research Studies and From Industry Data
[The adjusted cellulosic composition was calculated by adjusting the reported content of cellulose, hemicellulose and lignin for the ash content and for
the total yields]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Source Chemical composition (%) NexSteppe
-------------------------------------------------------------------------------------------------------------------------------------------- \30\
Dahlberg et al. (2011) * \28\ Stefaniak et al. (2012) [dagger] \29\ ------------
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Sorghum variety Sudan/ Biomass Sudan/ Biomass
High-yield sorghum Forage [caret] sorghum Forage Sweet [caret]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Number of samples............................... 5 4 15 51 6 41 54 7
Sucrose (sugar):
Average..................................... 2.9 2.7 1.0 9.0 2.4 1.1 9.8 4.5
Range....................................... 1.6-4.6 0.4-3.5 0.2-1.7 0.3-19 0.4-4.6 0.2-3.0 0.2-23.9 1.2-8.5
Starch:
Average..................................... 0.8 5.6 18.1 5.6 1.1 1.8 7.3 3.4
Range....................................... 0-4 0-15 0-25.2 0-12.0 0-4.0 0-8.9 0-16.6 0.3-8.1
Cellulosic Components:
Average..................................... 66.7 62.0 54.9 59.2 63.9 66.4 58.3 77.5
Range....................................... 61.3-72.3 53.8-67.5 46.8-73.6 ........... ........... ........... ........... 75.3-80.5
Adjusted Cellulosic Composition:
Average..................................... 75.4 70.0 60.5 63.2 72.5 70.1 61.8 83.7
Range....................................... 68.9-82.8 61.2-75.8 50.5-84.4 ........... ........... ........... ........... 77.4-88.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
* This paper analyzed 22 samples of forage sorghum, including some high-yield varieties that could be used for biomass purposes. The four sudan/sorghum
varieties include two samples that were also counted in the high-yield category. The remaining varieties fall into the forage sorghum category.
[dagger] This study separated 152 samples of sorghum into groups based on end use, with samples being harvested at different growth stages and
containing various tissue types depending on how the material would ultimately be used. See the original source for more information about the
different classes of sorghum.
[caret] These sources refer to certain hybrids as ``biomass'' sorghum. However, this does not necessarily mean that these varieties meet EPA's 75%
adjusted cellulosic content threshold.
In the July 2014 rule, EPA considered the cellulosic content of
energy cane. Like biomass sorghum, cane can be bred for a wide range of
cellulosic and sugar contents. In that rule, EPA defined ``energy
cane'' as cultivars containing at least 75% adjusted cellulosic
content. EPA also indicated that in the future, feedstocks that could
be bred for a wide range of uses and fiber content would have
registration requirements similar to energy cane, in order to
demonstrate that the adjusted cellulosic content of varieties used is
at least 75%. Therefore, for the purposes of the cellulosic content
issue, EPA intends to treat biomass sorghum similar to energy cane. For
purposes of this Notice, we consider biomass sorghum to include
varieties containing at least 75% adjusted cellulosic content. If, as a
result of a complete lifecycle assessment in response to individual
producer petitions EPA determines that a given fuel product made from
biomass sorghum satisfies the 60% lifecycle GHG reduction requirement
for cellulosic biofuel, 100% of the fuel in question would qualify for
cellulosic biofuel RINs, provided the producer can
[[Page 78861]]
demonstrate that the varieties they use as a feedstock contain at least
75% adjusted cellulosic content and satisfy all other applicable
definitional, registration, recordkeeping, and reporting requirements.
We would consider any cultivars with an adjusted cellulosic content
less than 75% to be forage sorghum, which we are not addressing in this
Notice. See the discussion regarding energy cane in the July 2014 rule
and accompanying memo to the docket \31\ for a description of the
methodologies and data EPA considers suitable for demonstrating that
the average adjusted cellulosic content is at least 75%. We expect that
any approved petition for cellulosic biofuel made from biomass sorghum
would contain registration requirements comparable to those set forth
at 40 CFR 80.1450(b)(1)(xiv).
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\31\ 79 FR 42128; ``Cellulosic Content of Various Feedstocks--
2014 Update.'' Docket EPA-HQ-OAR-2012-0401.
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III. Summary
EPA invites public comment on its preliminary analysis of GHG
emissions associated with the cultivation and transport of biomass
sorghum as a feedstock for biofuel production. EPA expects to revise
its analysis as appropriate in light of public comments received, and
to thereafter use the analysis as part of its evaluation of the
lifecycle GHG emissions of biofuel production pathways described in
petitions received pursuant to 40 CFR 80.1416 which use biomass sorghum
as a feedstock.
Dated: December 17, 2014.
Christopher Grundler,
Director, Office of Transportation and Air Quality.
[FR Doc. 2014-30712 Filed 12-30-14; 8:45 am]
BILLING CODE 6560-50-P