Notice of Opportunity To Comment on an Analysis of the Greenhouse Gas Emissions Attributable to Production and Transport of Jatropha Curcas Oil for Use in Biofuel Production, 61406-61419 [2015-26039]
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Federal Register / Vol. 80, No. 197 / Tuesday, October 13, 2015 / Notices
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[FR Doc. 2015–25912 Filed 10–9–15; 8:45 am]
BILLING CODE 6717–01–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ–OAR–2015–0293; FRL–9935–46–
OAR]
Notice of Opportunity To Comment on
an Analysis of the Greenhouse Gas
Emissions Attributable to Production
and Transport of Jatropha Curcas Oil
for Use in Biofuel Production
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
The Environmental Protection
Agency (EPA) is inviting comment on
its analysis of the greenhouse gas
emissions attributable to the production
and transport of Jatropha curcas
(‘‘jatropha’’) oil feedstock for use in
making biofuels such as biodiesel,
renewable diesel, jet fuel, naphtha and
liquefied petroleum gas. This notice
explains EPA’s analysis of the
production and transport components of
the lifecycle greenhouse gas emissions
of biofuel made from jatropha oil, and
describes how EPA may apply this
analysis in the future to determine
whether such biofuels meet the
necessary greenhouse gas reductions
required for qualification as renewable
fuel under the Renewable Fuel Standard
program. Based on this analysis, we
anticipate that biofuels produced from
jatropha oil could qualify as biomassbased diesel or advanced biofuel if
typical fuel production process
technologies or process technologies
with the same or lower GHG emissions
are used.
DATES: Comments must be received on
or before October 13, 2015.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2015–0293 to the Federal
eRulemaking Portal: https://
www.regulations.gov. Follow the online
instructions for submitting comments.
Once submitted, comments cannot be
edited or withdrawn. The EPA may
publish any comment received to its
public docket. Do not submit
electronically any information you
SUMMARY:
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consider to be Confidential Business
Information (CBI) or other information
whose disclosure is restricted by statute.
Multimedia submissions (audio, video,
etc.) must be accompanied by a written
comment. The written comment is
considered the official comment and
should include discussion of all points
you wish to make. The EPA will
generally not consider comments or
comment contents located outside of the
primary submission (i.e., on the web,
cloud, or other file sharing system). For
additional submission methods, the full
EPA public comment policy,
information about CBI or multimedia
submissions, and general guidance on
making effective comments, please visit
https://www2.epa.gov/dockets/
commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT:
Christopher Ramig, Office of
Transportation and Air Quality,
Transportation and Climate Division,
Mail Code: 6401A, U.S. Environmental
Protection Agency, 1200 Pennsylvania
Avenue NW., 20460; telephone number:
(202) 564–1372; fax number: (202) 564–
1177; email address: ramig.christopher@
epa.gov.
SUPPLEMENTARY INFORMATION:
I. General Information
A. Submitting CBI. Do not submit this
information to EPA through
www.regulations.gov or email. Clearly
mark the part or all of the information
that you claim to be CBI. For CBI
information in a disk or CD ROM that
you mail to EPA, mark the outside of the
disk or CD ROM as CBI and then
identify electronically within the disk or
CD ROM the specific information that is
claimed as CBI. In addition to one
complete version of the comment that
includes information claimed as CBI, a
copy of the comment that does not
contain the information claimed as CBI
must be submitted for inclusion in the
public docket. Information so marked
will not be disclosed except in
accordance with procedures set forth in
40 CFR part 2.
B. Tips for Preparing Your Comments.
When submitting comments, remember
to:
• Identify the rulemaking by docket
number and other identifying
information (subject heading, Federal
Register date and page number).
• Follow directions—The agency may
ask you to respond to specific questions
or organize comments by referencing a
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or section number.
• Explain why you agree or disagree;
suggest alternatives and substitute
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• Describe any assumptions and
provide any technical information and/
or data that you used.
• If you estimate potential costs or
burdens, explain how you arrived at
your estimate in sufficient detail to
allow for it to be reproduced.
• Provide specific examples to
illustrate your concerns, and suggest
alternatives.
• Explain your views as clearly as
possible, avoiding the use of profanity
or personal threats.
• Make sure to submit your
comments by the comment period
deadline identified.
This notice is organized as follows:
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I. General Information
II. Introduction
III. Analysis of Greenhouse Gas Emissions
Associated With Use of Jatropha Oil as
a Biofuel Feedstock
A. Summary of Greenhouse Gas Analysis
B. Feedstock Description and Growing
Conditions
C. Cultivation and Harvesting
D. Land Use Change and Agricultural
Sector Emissions
E. Feedstock Transport and Processing
F. Potential Invasiveness
G. Summary of GHG Emissions From
Jatropha Oil Production and Transport
H. Fuel Production and Distribution
IV. Summary
II. Introduction
As part of changes to the Renewable
Fuel Standard (RFS) program
regulations published on March 26,
2010 1 (the ‘‘March 2010 RFS 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 to qualify as renewable fuel.
EPA may also approve additional fuel
pathways not currently listed in Table 1
to 40 CFR 80.1426 for participation in
the RFS program, including in response
to a petition filed pursuant to 40 CFR
80.1416 by a biofuel producer seeking
EPA evaluation of a new fuel pathway.
EPA’s lifecycle analyses are used to
assess the overall greenhouse gas (GHG)
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
1 See
75 FR 14670.
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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.
EPA received a petition submitted
pursuant to 40 CFR 80.1416 from Global
Clean Energy Holdings (‘‘GCEH’’ or the
‘‘GCEH petition’’) and Emerald Biofuels,
LLC, submitted under a claim of
confidential business information (CBI),
requesting that EPA evaluate the
lifecycle GHG emissions for biofuels
(biodiesel, renewable diesel, jet fuel and
naphtha) produced from the oil
extracted from Jatropha curcas
(hereafter referred to as ‘‘jatropha’’ or
‘‘jatropha oil’’). The petition also
requested EPA provide a determination
of the renewable fuel categories, if any,
for which such biofuels may be eligible
under the Renewable Fuel Standard
(RFS) program. The Agency also
received a separate petition from Plant
Oil Powered Diesel Fuel Systems, Inc.,
submitted under a claim of CBI,
requesting that EPA evaluate the
lifecycle GHG emissions for the use of
neat jatropha oil as a transportation fuel,
and that EPA provide a determination of
the renewable fuel categories, if any, for
which such neat jatropha oil fuel may
be eligible.2
EPA has conducted an evaluation of
the GHG emissions associated with the
production and transport of jatropha oil
when it is used as a biofuel feedstock,
and is seeking public comment on the
methodology and results of this
evaluation. In this document, we are
describing EPA’s evaluation of the GHG
emissions associated with the feedstock
production and feedstock transport
stages of the lifecycle analysis of
jatropha oil when it is used to produce
a biofuel, including the indirect
agricultural and forestry sector impacts.
We are seeking public comment on the
methodology and results of this
evaluation. For the reasons described in
Section III below, we believe that it is
reasonable to apply the GHG emissions
2 There are no further references in this Notice to
Plant Oil Powered Diesel Fuel Systems, Inc., as they
did not agree to waive CBI claims to the data/
information contained in their petition and
supporting documentation submitted to EPA
pursuant to 40 CFR 80.1416, or references thereto.
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estimates we established in the March
2010 rule for the production and
transport of soybean oil to the
production and transport of jatropha oil.
If appropriate, EPA will update its
evaluation of the feedstock production
and transport phases of the lifecycle
analysis for jatropha oil based on
comments received in response to this
action. EPA will then use this feedstock
production and transport information to
evaluate facility-specific petitions,
received pursuant to 40 CFR 80.1416,
that propose to use jatropha oil as a
feedstock for the production of biofuel.
In evaluating such petitions, EPA will
consider the GHG emissions associated
with the production and transport of
jatropha oil feedstock. In addition, EPA
will determine—based on information
in the petition and other relevant
information, including the petitioner’s
energy and mass balance data—the GHG
emissions associated with petitioners’
biofuel production processes, as well as
emissions associated with the transport
and use of the finished biofuel. We will
then combine our assessments into a
full lifecycle GHG analysis and
determine whether the fuel produced at
an individual facility satisfies CAA
renewable fuel GHG reduction
requirements.
III. Analysis of Greenhouse Gas
Emissions Associated With Use of
Jatropha Oil as a Biofuel Feedstock
EPA has evaluated the GHG emissions
associated with the production and
transport of jatropha oil for use as a
biofuel feedstock, based on information
provided in the GCEH petition and
other data gathered by EPA. Section III–
A includes an overview of our GHG
analysis of jatropha oil production and
transport. Section III–B describes
jatropha oil and available information
about the growing conditions suitable
for commercial-scale production.
Section III–C explains our analysis of
the GHG emissions attributable to
growing and harvesting jatropha seeds.
Section III–D describes our analysis of
the land use change and other
agricultural sector emissions, including
significant indirect emissions,
attributable to producing jatropha oil for
use as a biofuel feedstock. Section III–
E explains our assessment of the GHG
emissions associated with feedstock
transport and processing, including oil
extraction and pre-treatment. Section
III–F discusses the potential
invasiveness of jatropha. Section III–G
summarizes GHG emissions from
jatropha oil production and transport.
Section III–H discusses how EPA
intends to consider the GHG emissions
associated with fuel production and
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distribution when evaluating facilityspecific petitions from biofuel
producers seeking to generate renewable
identification numbers (RINs) for nongrandfathered volumes of biofuel
produced from jatropha oil.
This Notice explains and seeks
comment on each component of EPA’s
GHG assessment of jatropha oil
production and transportation. We also
discuss and seek comment on potential
invasiveness concerns for jatropha as
they relate to GHG emissions. In this
Notice we compare our assessment of
jatropha oil to our previous evaluation
of soybean oil for the March 2010 RFS
rule because jatropha oil and soybean
oil can be used in the same types of
production processes to produce
biodiesel, renewable diesel, jet fuel, and
other similar types of biofuels. In the
March 2010 RFS rule, EPA determined
that several renewable fuel pathways
using soybean oil feedstock meet the
required 50% lifecycle GHG reduction
threshold under the RFS for biomassbased diesel and advanced biofuel.3
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A. Summary of Greenhouse Gas
Analysis
Based on the limited data available on
where jatropha will be produced at
commercial scale for use in making
biofuels for the RFS program, we
evaluated a number of scenarios with
different assumptions about where
jatropha will be grown and what type of
land jatropha plantations will use. This
section briefly discusses the two main
scenarios that we evaluated and our
overall findings based on these analyses.
As explained in more detail in
Section III–B below, based on
information in the GCEH petition and
other data gathered by EPA through
literature review and expert
consultations, we believe that southern
Mexico (specifically the states of
Yucatan, Oaxaca and Chiapas) and
northeastern Brazil 4 are the likely
locations for commercial-scale
production of jatropha for use in making
biofuels for the RFS program. Given the
limited amount of available data, these
are the two countries where we found
reliable evidence on jatropha
production that could supply significant
volumes of qualifying biofuel feedstock
under the RFS program. In the first
scenario that we evaluated, we assume
3 These pathways included biodiesel produced
from soybean oil through a transesterification
production process, and renewable diesel, jet fuel
and heating oil produced from soybean oil through
a hydrotreating production process.
4 Specifically the regions of Brazil that
encompasses the following provinces: Alagoas,
Bahia, Ceara, Maranhao, Paraiba, Pernambuco,
Piaui, Rio Grande do Norte, Sergipe, Tocantins.
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that jatropha production will occur on
grassland in southern Mexico and
northeastern Brazil that is not currently
being used for crop production or
pasture use. As explained more below,
we estimate that on average the GHG
emissions attributable to jatropha oil
extracted from jatropha seeds grown on
unused grasslands in southern Mexico
are 951 kilograms of carbon dioxideequivalent emissions (kgCO2e) per tonne
of jatropha oil that has been harvested,
extracted, pre-treated to lower acidity
and delivered to a biofuel producer
(‘‘delivered jatropha oil’’), compared to
1,425 kgCO2e per tonne of delivered
soybean oil. If jatropha is grown on
grassland in northeastern Brazil that
would not otherwise have been used for
crop production or grazing, we estimate
that the GHG emissions would be 1,858
kgCO2e per tonne of delivered jatropha
oil. Land use change emissions are
higher in northeastern Brazil than in
Mexico because, on average, grasslands
in northeastern Brazil sequester
significantly more carbon than
grasslands in southern Mexico.5 Since
we think it is likely that jatropha will be
grown in both locations, we believe it is
appropriate to evaluate a scenario in
which we assume an equal amount of
growth on grasslands in southern
Mexico and northeastern Brazil. In this
scenario, the GHG emissions are 1,404
kgCO2e per tonne of delivered jatropha
oil, which is lower than the emissions
attributable to delivered soybean oil.
In a second scenario, we considered
the possibility that jatropha will be
grown on land that would have
otherwise been used for agriculture
(crop production or grazing/pasture).
For this analysis we used the Food and
Agricultural Policy and Research
Institute international models as
maintained by the Center for
Agricultural and Rural Development at
Iowa State University (the FAPRI–CARD
model),6 that has been used for a
number of previous RFS rulemakings,
including the March 2010 RFS rule. We
conducted two analyses within this
scenario: One where we assumed that
jatropha will displace crops
(predominantly corn) in Mexico, and
one where jatropha is grown on
cropland in Mexico and on agricultural
land in Brazil (with the model choosing
5 Based on our assessment of land use change
emissions factors for previous RFS rules, on average
grasslands in Mexico sequester approximately 15
tonnes CO2e per hectare compared to 40 tonnes
CO2e per hectare in northeastern Brazil.
6 For more information on the FAPRI–CARD
model see the March 2010 RFS rule and associated
Regulatory Impact Analysis: Renewable Fuel
Standard Program (RFS2) Regulatory Impact
Analysis. EPA–420–R–10–006. https://www.epa.gov/
oms/renewablefuels/420r10006.pdf
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what land to displace in Brazil). The
second scenario, where jatropha is
grown on land otherwise used for
agricultural production, evaluates the
impacts associated with jatropha
displacing crop and pasture land,
including evaluating whether and where
increased crop production or pasturage
would occur in other regions to
compensate for the jatropha
displacement. In both of these analyses
the GHG emissions attributable to the
production of jatropha oil are much
lower than the corresponding emissions
for soybean oil. Specifically, for the
Mexico cropland analysis we estimated
GHG emissions of negative 721 kgCO2e
per tonne of delivered jatropha oil. As
explained more below, the net GHG
emissions in this analysis are negative
primarily because jatropha sequesters
more carbon than the cropland it
displaces and the indirect emissions are
relatively small because the displaced
corn production is backfilled by higher
yield producers (e.g., corn production in
the United States). For the Mexico and
Brazil analysis, the net GHG emissions
are 128 kgCO2e per tonne of delivered
jatropha oil, which is also significantly
less than the emissions per tonne of
delivered soybean oil.
Based on the two scenarios described
above, we believe it is reasonable, as a
conservative approach, to apply the
GHG emissions estimates we established
in the March 2010 rule for the
production and transport of soybean oil
to jatropha oil when evaluating future
facility-specific petitions from biofuel
producers seeking to generate RINs for
volumes of biofuel produced from
jatropha oil.7 The following sections
and supporting documentation in the
public docket provides more details on
the scenarios and analyses described
7 The purpose of lifecycle assessment under the
RFS program is not to precisely estimate lifecycle
GHG emissions associated with particular biofuels,
but instead to determine whether or not the fuels
satisfy specified lifecycle GHG emissions thresholds
to qualify as one or more of the four types of
renewable fuel specified in the statute. If the record
demonstrates that the GHG emissions associated
with the use of jatropha oil are at least as low as
those of soybean oil (which meets the most
stringent, 50%, lifecycle GHG reduction threshold
specified for non-cellulosic feedstocks) then EPA
can conclude that where comparable biofuel
production methods are used that jatropha oil-based
biofuels will qualify in the same manner as soybean
oil-based biofuels. In some cases, as here, this
comparative approach simplifies EPA’s assessment,
and allows relevant conclusions to be drawn
despite uncertainty that may be associated with an
attempt to determine a more precise lifecycle GHG
assessment. Similarly, where there are a range of
possible outcomes and the fuel satisfies GHG
reduction requirements for the optimum RFS
renewable fuel qualification when ‘‘conservative’’
assumptions are used, then a more precise
quantification of the matter is not required for
purposes of a pathway determination.
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above. We welcome public comments
on all aspects of our assessment.
B. Feedstock Description and Growing
Conditions
Jatropha is a deciduous, perennial
shrub or tree species belonging to the
Euphorbiaceae family that grows
approximately 8 to 15 meters tall.
Experts agree that jatropha is native to
the American tropics; however there is
disagreement in the literature regarding
its origin and the borders of jatropha’s
native range.8 However, it is naturalized
throughout Latin America, including
Mexico, Central America and the
Caribbean, and to a lesser extent in
Argentina, Bolivia, Brazil, Colombia,
Ecuador, Paraguay, Peru and
Venezuela.9 Traditionally, it has been
grown in tropical and sub-tropical
regions in Africa, Asia and Latin
America as a hedge and ornamental
plant. Jatropha is adapted to arid and
semi-arid conditions and high
temperatures, and it has been found to
be very frost intolerant. In its Latin
American range, it is common in
deciduous forests and open spaces
including grassland-savannah and scrub
forests. It prefers low altitudes, well
drained soils and good aeration. It is
adapted to marginal lands with low
nutrient content, but commercial
production has been unsuccessful in
these conditions. Jatropha fruit, similar
in appearance to a walnut, can be
harvested at least once per year, though
multiple harvests are possible as mature
jatropha plants flower throughout the
year. The fruit has a thick outer covering
called a husk. Each fruit contains one to
three seeds, each with a durable outer
shell and a softer oil-bearing inner
kernel. The seeds are 25–50 percent oil
by mass. When oil is extracted from the
kernel the remaining material forms a
seedcake (also known as press cake or
meal cake) that contains curcin, a highly
toxic protein. Although the oil and
seedcake are toxic to humans and
livestock, the oil has good properties for
use as a biofuel feedstock to produce
fuels such as biodiesel, renewable diesel
and jet fuel, and the seedcake can be
used as fertilizer or as fuel for process
heat.
Jatropha does not have a long history
as a planted crop. As a result, empirical
data on crop yields, crop inputs, and
other key agricultural characteristics are
not readily available. In order to fill
these knowledge gaps to the greatest
extent possible, EPA conducted a
literature review of agronomic and
8 CABI Jatropha Curcas Data Sheet, https://
www.cabi.org/isc/datasheet/28393
9 Ibid.
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lifecycle GHG analysis studies of
jatropha.10 We sought input on a draft
of the literature review from a wide
array of stakeholders, including
academics, environmental
organizations, industry groups and the
parties who submitted petitions
involving the use of jatropha oil
feedstock. The comments we received
were considered in preparing the
revised document available in the
public docket associated with this
Notice.
Several past efforts to cultivate
jatropha for biofuel use attempted,
without commercial success, to produce
jatropha on marginal agricultural land
with minimal inputs.11 By contrast, the
petitioners and others working to
commercialize jatropha more recently
have utilized higher quality agricultural
land and have made much more
extensive use of fertilizer, irrigation, and
other agricultural inputs. Therefore, for
purposes of this assessment, we assume
that jatropha grown for use as a biofuel
feedstock will be grown as a planted
crop under normal agricultural
conditions. In other words, we expect
jatropha to be grown by farmers on
arable land with the use of fertilizer,
pesticides, irrigation where necessary,
and other crop inputs. Our projection
that jatropha grown for biofuel feedstock
targeted to the U.S. market will be
cultivated on agricultural-quality land
also aligns with the definition of
renewable biomass at 40 CFR 80.1401,
which specifies that planted crops must
be grown on existing agricultural land
cleared or cultivated prior to December
19, 2007.
Based on conversations with
researchers at the United States
Department of Agriculture Agricultural
Research Service (USDA–ARS) and
other organizations, we determined that
jatropha is unlikely to be commercially
grown in the United States because of
its high intolerance to frost.12 USDA and
several university research groups have
attempted to grow jatropha in the
United States, including projects in
Arizona, California, and Florida. To
date, no one has demonstrated that
jatropha would be a viable commercial10 See ‘‘GHG Assessments of Jatropha Oil
Production: Literature Review and Synthesis’’ in
Docket EPA–HQ–OAR–2015–0293.
11 Kant, P. and S. Wu. 2011. ‘‘The Extraordinary
Collapse of Jatropha as a Global Biofuel.’’
Environmental Science & Technology 45(17):7114–
7115. doi: 10.1021/es201943v.
12 Telephone conversations with Terry Coffelt
(USDA–ARS), Terry Isbell (USDA–ARS), Roy Scott
(USDA–ARS), Dan Parfitt (University of CaliforniaDavis), Wagner Vendrame (University of Florida),
Jaime Barton (Hawaii Agricultural Research Center),
Bob Osgood (HARC), Richard Oguchi (University of
Hawaii), Robert Bailis (Yale).
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61409
scale crop in the United States due
primarily to its extreme frost
intolerance.13 Even in the southernmost
reaches of the country, occasional frosts
have proven too severe for the plant to
be viable. For these reasons, EPA’s
analysis does not consider jatropha
production in the United States.
Projecting where jatropha will be
produced is difficult, as evidenced by
previous government projects to support
the expansion of jatropha production
that did not materialize.14 Given the
poor track record of pronouncements
about future jatropha development, we
focused our analysis on regions where
we could find evidence of current
production at commercial scale.
Through literature review and
conversations with researchers and
industry experts, we found evidence of
significant commercial jatropha
production in Mexico and Brazil. In
contrast, although large areas of Asian
jatropha production were planned and
reported in global surveys, EPA was not
able to verify the existence of successful
commercial scale plantations in these
regions. While there is potential for
jatropha cultivation in India and Africa,
it remains uncertain whether jatropha
oil grown in those locations would be
exported to the United States or whether
it would qualify as renewable biomass
as defined in the CAA and
implementing RFS regulations.15 The
scenarios we evaluated looked only at
jatropha production in Mexico and
Brazil, because, as discussed in more
detail below, these are the two countries
where we found reliable evidence on
jatropha production that could supply
significant volumes of qualifying biofuel
feedstock under the RFS program.
Mexico and Brazil offer hospitable
environments for jatropha. Both
countries are part of jatropha’s
naturalized range, and several efforts to
commercialize jatropha have been
reported there.16 In the GEXSI jatropha
market survey of Latin America, Mexico
and Brazil were the only countries
classified as having ‘‘strong commercial
13 Ibid.
14 See ‘‘GHG Assessments of Jatropha Oil
Production: Literature Review and Synthesis’’ on
Docket EPA–HQ–OAR–2015–0293.
15 For example, recent trade data shows that in
general the U.S. receives substantially more
agricultural imports from Mexico and Brazil than
from Africa and India. For example, in Fiscal Year
2014, the U.S. imported over 22.5 billion dollars of
agricultural products from Mexico and Brazil,
compared to approximately 5.7 billion dollars from
Africa and India. Source: USDA Economic Research
Service and Foreign Agricultural Service. 2015.
Outlook for U.S. Agricultural Trade, AES–89,
August 27, 2015.
16 CABI Jatropha Curcas Data Sheet, https://
www.cabi.org/isc/datasheet/28393
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activities.’’ 17 The global survey
completed by Leuphana in 2012 also
identified Mexico and Brazil as the
dominant jatropha producers in Latin
America with area planted of 8,000 and
3,100 hectares respectively.18 These
survey results are supported by other
studies in the literature and information
gathered by EPA.19 According to the
GCEH petition, GCEH recently
established a jatropha plantation in the
Yucatan Peninsula encompassing
several thousand hectares, with plans
for expansion in the same region.
Furthermore, the Mexican government
has supported jatropha through the
ProArbol program of the National
Forestry Commission of Mexico
(CONAFOR) that provides subsidies for
the promotion of jatropha as a form of
reforestation.20 Bailis and Baka, for their
study on using jatropha oil to produce
jet fuel, focused on Brazil because its
position as a major biofuel and
commercial agricultural exporter makes
it a potential site for large-scale jatropha
production.21 As another reason for
focusing on Brazil as a growth region for
jatropha, Bailis and Baka cited the major
push by EMBRAPA, the federal
agricultural research and support
organization, to develop the crop.
Furthermore, our literature review
identified additional studies that
reported commercial scale jatropha
production in Mexico and Brazil.22
There have been several efforts to
commercialize jatropha in other parts of
the world, including Sub-Saharan
Africa, India, East Asia, Southeast Asia,
and Oceania. However, the commercial
scale viability of jatropha farms in all of
these regions is currently uncertain. The
global surveys conducted by GEXSI and
Leuphana reported that the vast
majority of jatropha being cultivated
worldwide was being grown in
Southeast Asia, including India, China
17 The Global Exchange for Social Investment
(GEXSI). 2008. Global Market Study on Jatropha.
Final report. Available at: https://www.jatrophaalliance.org/fileadmin/documents/GEXSI_GlobalJatropha-Study_FULL–REPORT.pdf.
18 Wahl et al. 2012. Insights into Jatropha Projects
Worldwide. Leuphana University.
19 See ‘‘GHG Assessments of Jatropha Oil
Production: Literature Review and Synthesis’’ on
Docket EPA–HQ–OAR–2015–0293.
20 Skutsch, M., E. de los Rios, S. Solis, E.
Riegelhaupt, D. Hinojosa, S. Gerfert, Y. Gao, and O.
Masera. 2011. ‘‘Jatropha in Mexico: Environmental
and Social Impacts of an Incipient Biofuel
Program.’’ Ecology and Society 16(4):11.
doi:10.5751/ES–04448–160411.
21 Bailis, R.E. and J.E. Baka. 2010. ‘‘Greenhouse
Gas Emissions and Land Use Change from Jatropha
Curcas-Based Jet Fuel in Brazil.’’ Environmental
Science & Technology 44(22):8684–8691.
doi:10.1021/es1019178.
22 See ‘‘GHG Assessments of Jatropha Oil
Production: Literature Review and Synthesis’’ on
Docket EPA–HQ–OAR–2015–0293.
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and Indonesia. The most recent of these
surveys collected data in 2011.23
However, after reviewing these surveys
carefully and discussing their results
with experts in industry and the USDA,
we determined that practically all of the
reported jatropha plantations in Asia
were aspirational and have not resulted
in commercially significant volumes of
jatropha oil. EPA has not been able to
locate any information that confirms the
presence of the large scale Asian
projects reported in the GEXSI and
Leuphana surveys, and there does not
appear to be any official data confirming
their existence.24 These surveys relied
on data that were self-reported and in
many cases were based on goals rather
than outcomes.25 A 2012 report by the
USDA Foreign Agricultural Service
(FAS) confirms the very small scale of
commercial jatropha oil production in
India.26 More recently, multiple
companies working to commercialize
jatropha in parts of Asia also confirmed
that, while several large projects were
planned in Southeast Asia, they have all
since been scaled back to pilot projects
or abandoned for funding and other
reasons.27 For these reasons, our
analysis of the GHG emissions
attributable to jatropha oil produced as
biofuel feedstock for the RFS program
does not project jatropha oil production
from Asia.
Africa is another region with
significant potential for jatropha
production. However, we decided not to
model jatropha oil from Africa in our
analysis. First, there is uncertainty
about whether African jatropha oil
production would qualify as renewable
biomass, because it is not clear that the
land where it would be grown could be
considered existing agricultural land, as
required in the CAA to qualify as
renewable biomass.28 Furthermore,
according to one agricultural trade
expert, it is viewed as unlikely for
economic reasons that Africa would be
a significant exporter of jatropha oil to
the United States by the year 2022, in
part because it would require the
23 Wahl
et al. 2012.
from Cosmo Biofuels Group, ‘‘Jatropha
RFS2 Pathway Petition Insights Into Jatropha
Projects Worldwide.’’ February 7, 2014
25 For example, a review of jatropha promotion in
India is provided in Kumar, S., Chaube, A., Jain, S.,
K. 2012. ‘‘Critical review of jatropha biodiesel
promotion policies in India. Energy Policy, 41: 775–
781.
26 USDA–FAS. 2012. India Biofuels Annual.
Global Agricultural Information Network. GAIN
Report Number: IN2081.
27 Letter from BEI International, LLC, ‘‘Jatropha
RFS2 Pathway Petition Insights Into Jatropha
Projects Worldwide.’’ January 9, 2014.
28 See the definition of renewable biomass at 40
CFR 80.1401.
24 Letter
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development of a new and potentially
costly infrastructure to grow, process,
and transport the feedstock or fuel to the
United States.29 For these reasons, our
analysis of the GHG emissions
attributable to jatropha oil produced as
biofuel feedstock for the RFS program
does not project jatropha oil production
from Africa, and we seek comment on
this approach.
Although we are specifically
modelling jatropha growth and transport
in Mexico and Brazil, and expect most
jatropha oil used as renewable fuel
feedstock for the RFS program to be
grown in those countries, we intend to
apply our analysis of the GHG emissions
attributable to jatropha oil production
and transport when evaluating facilityspecific petitions that propose to use
jatropha oil as biofuel feedstock,
regardless of the country of origin where
their jatropha oil feedstock is grown. In
the future, some jatropha oil feedstock
used to produce biofuels for the RFS
may be sourced from countries other
than Mexico and Brazil, but this would
be unlikely to change our overall
assessment of the aggregate GHG
impacts from growing and transporting
jatropha oil. Consistent with EPA’s
approach for previous RFS pathway
analyses, we will periodically
reevaluate whether our assessment of
GHG impacts will need to be updated in
the future based on new information or
a new methodology that has the
potential to significantly change our
assessment.
C. Cultivation and Harvesting
Our assessment includes the GHG
emissions attributable to growing and
harvesting jatropha seeds, including
field preparation, planting, annual
inputs and harvesting, and replanting.
We also estimate the average yields, in
terms of tonnes of dry jatropha seed per
hectare, in both Mexico and Brazil. The
GHG emissions associated with
cultivation and harvesting are the same,
per tonne of delivered jatropha oil, in
both of the main scenarios that we
evaluated, as the type of land converted
is not expected to impact the emissions
from these stages of jatropha oil
production. The data for our evaluation
of these stages of jatropha oil production
came from the GCEH petition, as well as
EPA’s literature review and our
previous lifecycle GHG assessments for
the RFS program. The values and
calculations in our analysis are
discussed briefly here and in more
29 Conversation with Bruce Babcock, January 8,
2013.
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detail in a technical memorandum to
the docket.30
Seed and Oil Yields. For the purposes
of this analysis, we project that in 2022,
on average, one hectare of jatropha in
southern Mexico will yield five tonnes
of dry jatropha seeds per year, while one
hectare in Brazil will yield four tonnes
per hectare. For Mexico, five tonnes per
hectare reflects a middle to upper bound
estimate of recorded yields in the
literature, and is also supported by
information provided in the GCEH
petition for current yields. We view five
tonnes per hectare as a conservative
estimate of yields in the year 2022
because intensive jatropha cultivation is
relatively new, with significant room for
potential advances through genetics,
breeding and improved agronomic
practices. There are fewer recorded
observed yields in northeastern Brazil;
however, based on evidence from our
literature review of environmental and
climate characteristics, we expect
jatropha yield in this region will be
somewhat lower than yields in southern
Mexico.31 Given the potential for
scientific breakthroughs to produce
yield improvements for jatropha, we
also consider this a conservative
projection for 2022 yields in Brazil.
Based on the information discussed in
Section III–E below, we assume that
after crushing, pre-treatment and
transport, each tonne of dry jatropha
seeds yields 0.26 tonnes of jatropha oil
delivered to a biofuel production
facility. (This figure is used to convert
cultivation and harvesting GHG
emissions from kgCO2e per hectare of
jatropha production to kgCO2e per tonne
of delivered oil.)
Preparation and Planting. When
jatropha is first planted, chemical and
energy inputs are required. For our
analysis, we used average inputs of
nitrogen, phosphate, potassium,
herbicide, and diesel use from data in
the GCEH petition, as shown in Table
III–1.32 In Brazil, lime is also added as
a soil amendment during preparation
and planting, 33 although it is not
required in many parts of southern
Mexico.34 While there is relatively little
30 For more details see ‘‘Jatropha Supporting Data
and Assumptions’’ in Docket EPA–HQ–OAR–2015–
0293.
31 See for example Trabucco et al. 2010.
32 Table III–1 shows the average results for a
scenario with equal amounts of jatropha output (by
mass) in Mexico and Brazil.
33 Bailis, R. E. and J. E. Baka. 2010. Greenhouse
gas emissions and land use change from Jatropha
curcas-based jet fuel in Brazil. Environmental
Science and Technology, 44(22) 8684–8691.
34 Lime is required in Brazil because the soils
there are highly acidic, but it is not required in
southern Mexico where the native soil pH is wellsuited for jatropha.
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some of the husks from the jatropha
fruits are used for fertilizer. In addition,
the seedcake produced after pressing oil
from the seeds can be used as an organic
fertilizer. We assumed that fertilizer
inputs would have to at least make up
for nutrients lost from harvesting the
jatropha fruits.37 Using literature values
for nitrogen, phosphorous and
potassium in jatropha fruits, husks, and
seedcake,38 and our projected seed
yield, we determined that the jatropha
husks and seedcake have nearly enough
nutrients to replace the nutrients lost
from harvesting the seed fruit. We
assume that growers will apply 9.3
kilograms per hectare of additional
inorganic fertilizer to replace the lost
nutrients from harvesting, which is
within the range of literature values and
similar to the data provided by GCEH.
We also assumed use of small amounts
of pesticide, herbicide and insecticide
based on information from the peer
TABLE III–1—ANNUALIZED GHG EMIS- reviewed literature.39 The GHG
SIONS FROM PREPARATION AND emissions associated with fertilizer and
pesticide use were estimated using the
PLANTING
methodology developed for the March
[kgCO2e per tonne of delivered jatropha oil]
2010 RFS rule.40 Table III–2 shows the
GHG emissions from annual fertilizer
Inputs
GHG
and pesticide use, not including nitrous
per
emissions
oxide emissions that occur after they are
hectare
applied to the field (which is discussed
Nitrogen fertilizer ... 0.07 kg ..
0.01
separately, below).
Phosphorus fer0.02 kg ..
0.001
Annual Energy Use. In addition to
tilizer.
chemical inputs, energy will be used
Potassium fertilizer 0.09 kg ..
0.003 annually for irrigation, and to power
Herbicide ............... 1.2 gal ...
1.8
equipment used for field maintenance
Lime ...................... 1.1
21.3
and harvesting. For the annual diesel,
tonnes.
gasoline and electricity inputs, we used
Diesel .................... 79.3 gal
43.5
values provided in the GCEH petition,
which are within the range of values
Total
...........
66.6
EPA found through literature review.41
Annualized
data available on the inputs and energy
requirements for the preparation and
planting stages of jatropha, the values
provided in the GCEH petition were
within the range of other values that we
found through literature review.35
We assumed that jatropha has a 20
year crop cycle, meaning that every 20
years the existing jatropha plants are
removed and the crop is replanted.36
Therefore, the GHG emissions
associated with preparation and
planting occur every 20 years.
Annualized emissions from preparation
and planting are shown in Table III–1.
We estimate total GHG emissions from
jatropha preparation and planting of
66.6 kilograms of carbon dioxideequivalent emissions (kgCO2e) per ton
of jatropha oil that has been harvested,
extracted, pre-treated to lower acidity
and delivered to a biofuel producer
(‘‘delivered jatropha oil’’).
Emissions.
Annual Inputs and Harvesting. After
the jatropha fields are prepared and
planted, there are annual GHG
emissions associated with applying crop
inputs and harvesting the jatropha
seeds. To estimate the average annual
emissions from these activities we
assumed an average twenty year
replanting cycle, meaning that in any
given year five percent of the jatropha
fields will be in the replanting stage,
and therefore have zero emissions
associated with annual crop inputs and
harvesting. Table III–2 summarizes the
emissions from these activities.
Annual Fertilizer and Pesticide
Inputs. The GCEH petition states that
35 We consider the crop input data used in our
assessment to be conservative because they result
in greater estimate GHG emissions per tonne of oil
produced than most of the other data we reviewed.
36 For more details see ‘‘Jatropha Supporting Data
and Assumptions’’ in Docket EPA–HQ–OAR–2015–
0293.
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TABLE III–2 GHG EMISSIONS FROM
ANNUAL INPUTS AND HARVESTING
[kgCO2e per tonne of delivered jatropha oil]
Inputs
(per ha)
Nitrogen fertilizer ...
Phosphorus fertilizer.
Potassium fertilizer
Herbicide ...............
GHG
emissions
9.3 kg ....
9.3 kg ....
27.8
9.5
9.3 kg ....
0.5 kg ....
6.3
11.5
37 Bailis and Baka 2010 used the same approach
to estimate fertilizer requirements.
38 Bailis, R. E. and J. E. Baka. 2010. Greenhouse
gas emissions and land use change from Jatropha
curcas-based jet fuel in Brazil. Environmental
Science and Technology, 44(22) 8684–8691.
39 Bailis, R. E. and J. E. Baka. 2010. Greenhouse
gas emissions and land use change from Jatropha
curcas-based jet fuel in Brazil. Environmental
Science and Technology, 44(22) 8684–8691.
40 See Section 2.4.3.1 of the Regulatory Impact
Analysis for the March 2010 RFS rule.
41 Supporting Documentation for Jatropha Oil
Production and Transport GHG Emissions, Air and
Radiation Docket EPA–HQ–OAR–2015–0293.
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Table III–4 provides a summary of the
TABLE III–2 GHG EMISSIONS FROM
ANNUAL INPUTS AND HARVESTING— average GHG emissions attributable to
growing and harvesting jatropha in
Continued
indirect emissions) of growing jatropha
on land that would otherwise be used
for crops or pasture.
Jatropha on Currently Unused
southern Mexico and northeastern
[kgCO2e per tonne of delivered jatropha oil]
Grassland Scenario. Analyzing the land
Brazil. Each of the emissions categories
use change emissions associated with
listed in the table are explained above
Inputs
GHG
growing jatropha on grassland that is
in this section.
(per ha)
emissions
not currently being used for agricultural
TABLE III–4 GHG EMISSIONS ATTRIB- purposes requires estimates of the
Fungicide0.02 L ....
0.01
Bacteriocide.
UTABLE TO GROWING AND HAR- carbon sequestered by the jatropha
Pesticide ............... 0.06 L ....
0.7
plantations, as compared to the
VESTING JATROPHA
Diesel .................... 15.6 gal
162.5
grasslands they would replace. We
[kgCO2e per tonne of delivered jatropha oil]
Gasoline ................ 1.6 gal ...
14.8
estimated the average amount of
Electricity ............... 184 kWh
40.9
biomass carbon sequestered by jatropha
GHG
Total ............... ...............
274.0
Emissions Category
plantations in southern Mexico and
emissions
northeastern Brazil, projected out to
Preparation and Planting ..........
67 2022. Jatropha biomass carbon stocks
Annual Nitrous-Oxide Emissions.
Annual Inputs and Harvesting ..
274 were estimated using available scientific
Nitrous oxide (N2O) is emitted from
Nitrous Oxide Emissions ..........
709 information from the literature.
nitrogen fertilizer and from parts of the
Total ...................................
1,050 Reinhardt et al. measured basic data
jatropha plant that are left on the field
to decay or applied as fertilizer
about jatropha plants, such as root to
D. Land Use Change and Agricultural
(‘‘jatropha residues’’). The jatropha
shoot ratios and biomass carbon
Sector Emissions
content. Bailis and Baka used the data
residues can be divided into three
As explained in Section III–B, above,
from Reinhardt et al. to estimate
categories: (1) Husks that are applied to
we believe that southern Mexico and
biomass carbon stocks for different
the field as fertilizer, (2) seedcake that
northeastern Brazil are the most likely
jatropha yield scenarios. Using our
is applied to the field as fertilizer, and
locations for commercial-scale
projected jatropha yields of 5 and 4
(3) above and below ground biomass
production of jatropha for use in making tonnes per hectare per year for Mexico
from the jatropha plant (e.g., the trunk,
biofuels for the RFS program. According and Brazil respectively (the basis for
branches, leaves, and roots). The above
to the GCEH petition, there are large
these projections is discussed above),
and below ground biomass from the
areas of grasslands in southern Mexico
we used the Bailis and Baka approach
jatropha plant becomes a plant residue
that are suitable areas for jatropha
to estimate average biomass carbon
every 20 years, when the old plants are
production. These areas were used for
stocks of 8.9 and 8.1 tonnes per hectare
removed and new plants are planted.
crop production or pasture, but they are for ten year old jatropha plantations in
For each of these categories of jatropha
Mexico and Brazil, respectively. Per the
residues, we used equations and factors now fallow or used for very low
intensity grazing. For example, Skutsch
methodology developed for the March
from the United Nations
et al. evaluated jatropha land use change 2010 RFS rule, we translated these
Intergovernmental Panel on Climate
impacts in Yucatan, Mexico and found
estimates into average biomass carbon
Change (IPCC) to calculate direct and
two plantations that had been planted
stocks over 30 years. Assuming linear
indirect N2O emissions, and we
on estates that had previously been used growth rates, a 20 year replanting cycle
annualized them by dividing by 20.42
for low-intensity grazing.43 There are
and pruning of any growth after 10 years
Estimated annual emissions from
also grasslands in northeastern Brazil
to ensure fruit accessibility, we
fertilizer and plant residues are shown
that are suitable for jatropha production, estimated average jatropha plantation
in Table III–3.
although much of this land may
biomass carbon stocks over 30 years to
currently be in use as pasture. For
be 6.9 and 6.3 tonnes per hectare for
TABLE III–3—N2O EMISSIONS FROM
Mexico and Brazil respectively.45 These
FERTILIZER AND JATROPHA RESIDUES example, Bailis and Baka surveyed
jatropha producers in northeastern
values are within the range of estimates
[kgCO2e per tonne of delivered jatropha oil]
Brazil and found that the producers they in the literature for jatropha plantations
approached had primarily planted their in these regions.46
GHG
jatropha on pasture land.44
For comparison, based on our analysis
emissions
Based on this information, the first
for the March 2010 RFS rule we
Fertilizer, direct .........................
37.4 scenario we evaluated for land use
estimate that grasslands in Mexico and
Fertilizer, indirect ......................
12.2 change emissions considers jatropha
Brazil contain approximately 4.1 and
Husks, direct .............................
51.5 production on grasslands that would
10.9 tonnes of carbon per hectare,
Husks, indirect ..........................
11.6 otherwise not be used for crops or
respectively. For our first scenario, we
Seedcake, direct .......................
281.7 pasture. In a second scenario, we used
looked at the land use change and
Seedcake, indirect ....................
63.4 economic modeling to look at the
agricultural sector emissions associated
Above and below ground biopotential land use change and
with growing jatropha on grassland in
mass, direct ...........................
204.7 agricultural sector emissions (including
Mexico and Brazil that would not
Above and below ground biootherwise be used for crop production
mass, indirect ........................
46.0
43 Skutsch, M., E. de los Rios, S. Solis, E.
or pasture. Comparing the carbon stocks
Total ...................................
709.4
42 Direct
emissions are emitted from the jatropha
plantation, whereas indirect emissions occur for
material that has moved to another location (e.g.,
through leaching or runoff) before it produces N2O
or a pre-cursor of N2O. For crop residues, such as
above and below ground biomass, direct emissions
occur when the plant material decays.
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Riegelhaupt, D. Hinojosa, S. Gerfert, Y. Gao, and O.
Masera. 2011. ‘‘Jatropha in Mexico: Environmental
and Social Impacts of an Incipient Biofuel
Program.’’ Ecology and Society 16(4):11.
doi:10.5751/ES–04448–160411.
44 Bailis, R.E. and J.E. Baka. 2010. ‘‘Greenhouse
Gas Emissions and Land Use Change from Jatropha
Curcas-Based Jet Fuel in Brazil.’’ Environmental
Science & Technology 44(22):8684–8691.
doi:10.1021/es1019178.
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45 For details on this calculation see ‘‘Jatropha Oil
Production and Transport GHG Calculations’’
spreadsheet on Docket EPA–HQ–OAR–2015–0293.
46 For a comparison with other values in the
literature see Supporting Documentation for
Jatropha Oil Production and Transport GHG
Emissions, Air and Radiation Docket EPA–HQ–
OAR–2015–0293.
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of jatropha and the grassland it replaces,
we estimate that growing jatropha on
grassland in Mexico results in a net
carbon sequestration, or negative
emissions, because the jatropha
plantation sequesters more carbon on
average over thirty years. Conversely,
planting jatropha on grassland in Brazil
results in a net carbon emission.
Specifically, for jatropha grown on
otherwise unused grasslands in Mexico
and Brazil we estimate land use change
emissions of negative 268 and positive
550 kgCO2e per tonne of delivered
jatropha oil, respectively. Looking at a
scenario in which we assume an equal
amount of growth of jatropha from
unused grasslands in Mexico and Brazil
results in land use change emissions of
141 kgCO2e per tonne of delivered
jatropha oil. (For comparison, for the
March 2010 RFS rule we estimated land
use change emissions of 1,158 kgCO2e
per tonne of soybean oil used for
biofuel.) In this scenario there are no
indirect agricultural sector emissions,
such as from indirect impacts on crop
or livestock production, because
jatropha is not an agricultural
commodity, and the displaced land
would not otherwise have been used for
commodity production.
Jatropha on Agricultural Land
Scenario. In the second scenario we
evaluated, we assumed jatropha would
be grown on land that would otherwise
be used to grow crops or for pasture. In
this case jatropha production would
impact market prices for the crops and
livestock it displaces, leading to other
indirect effects. For example, one of the
likely indirect impacts would be to
increase crop and livestock production
in other locations to make up for the
production displaced by jatropha. As we
have done for the other RFS analyses,
we estimated the size of these impacts
with an agricultural sector model.
For our agricultural sector modeling
of jatropha oil, we used a similar
approach to the one we used for
sugarcane in the March 2010 RFS rule,
in which agricultural sector modeling
was conducted using only the FAPRI–
CARD model, and not the Forestry and
Agricultural Sector Optimization Model
(FASOM). For other feedstocks (e.g.,
corn, soybeans, grain sorghum), we used
FASOM to model domestic forestry and
agricultural impacts in addition to using
the FAPRI–CARD model for
international impacts. Similar to
sugarcane, for jatropha we only used the
FAPRI–CARD model because we do not
expect jatropha to be grown in the
United States as a biofuel feedstock for
the RFS program.
To date, jatropha has not achieved a
significant presence in global
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agricultural markets. For example, EPA
is not aware that it is traded on any
agricultural exchange, and there does
not appear to be any publicly available
data on jatropha prices or trade flows.
These limitations create significant
difficulties when attempting to model
jatropha in an agro-economic
framework, such as the FAPRI–CARD
model. The creation of robust
assumptions for production costs at
various levels of production (i.e.,
production cost curves), as well as
estimates for supply and demand at
various prices (i.e., supply curves and
demand curves), depends upon these
types of historical data. We considered
building production cost curves for
jatropha oil based on land, crop yield,
and crop input data. However, for
jatropha, production cost data are
limited to a very small number of
companies and regions, making it
difficult to estimate or project how
much jatropha oil could be produced at
various production cost levels. We also
have limited information to determine
the price that jatropha might command
on the open market, or the extent to
which it might be competitive with
other planted crops for acreage. Without
this information, it is not possible to
form supply and demand curves for
jatropha in the FAPRI–CARD model,
which the model typically uses for other
crops that we have evaluated to project
where and in what quantities jatropha
will be grown. Because of these
limitations, EPA applied a slightly
modified methodology in this analysis.
For other crops that EPA has
evaluated for the RFS program, we have
used the FAPRI–CARD model to project
international agricultural sector impacts
by running different biofuel volume
scenarios and allowing the model to
decide where to grow the additional
crops needed to produce the biofuel
volumes. Because of the data limitations
regarding jatropha, the FAPRI–CARD
model is not able to decide where to
grow jatropha or what other types of
land uses to displace for its production.
Therefore, to model the agricultural
sector impacts of expanding jatropha
production, we exogenously specified
how much and what types of land it
would displace in Mexico and Brazil.
The FAPRI–CARD model then estimated
how the crops and pasture displaced by
jatropha would be made up elsewhere
via crop switching, land conversion and
other market-mediated effects.
First, similar to our modeling for
other feedstocks, we used available
information to project the amount of
jatropha oil produced as biofuel
feedstock for the RFS program in the
year 2022. We developed two analyses
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for the production of 130 million
gallons of biodiesel in 2022, one where
all of the jatropha oil is produced in
Mexico (the ‘‘Mexico only case’’) and
one where the jatropha oil production is
split evenly between Mexico and Brazil
(the ‘‘Mexico and Brazil case’’).
Although there is limited historical data
available to use as the basis for
formulating jatropha oil volume
scenarios for modeling, we believe that
a total production level of 130 million
gallons of biodiesel in 2022 is
sufficiently large to produce robust
estimates of agricultural and GHG
impacts in the FAPRI–CARD model,
while still being feasible. As described
elsewhere in this notice, we
conservatively project that in 2022
Mexico and Brazil will have delivered
jatropha oil yields of 1.3 and 1.0 tonnes
per hectare per year, respectively.47
Based on these oil yields, in the Mexico
only case the production of enough
jatropha oil feedstock to produce 130
million gallons of biodiesel would
require approximately 350 thousand
hectares of jatropha production in
Mexico. In the Mexico and Brazil case,
we modeled approximately 172
thousand hectares of jatropha in Mexico
and 216 thousand hectares in Brazil.48
The results of our modeling are based
on a comparison of this jatropha
production case to a control case that
included no jatropha oil production.
To model the agricultural sector
impacts of jatropha production in
Mexico, we specified in the FAPRI–
CARD model the area and types of crop
land that jatropha would displace.
Based on the information provided in
the GCEH petition and collected
through EPA’s literature review,
jatropha production in southern Mexico
will most likely occur in the states of
Yucatan, Chiapas and Oaxaca because
they offer the most suitable climate
conditions and available land. Over 80
percent of the agricultural land in this
area is used for corn production, with
smaller areas devoted to specialty crops
such as fruits, vegetables, herbs and
spices.49 We do not expect jatropha to
47 Based on projected average 2022 dry seed
yields in Mexico and Brazil of five and four tonnes
per hectare, respectively. We also assume that dry
seeds have 35% oil content, 75% oil extraction
efficiency and a 1.4 percent loss from oil pretreatment.
48 Given the yields for Mexico and Brazil
described above, these cultivation areas correspond
with 65 million gallons of jatropha oil biodiesel
each from Mexican and Brazilian jatropha oil
production, for a total of 130 million gallons. The
specific underlying assumptions and calculations
that produced these figures are available in the
docket for this notice at EPA–HQ–OAR–2015–0293.
49 Mexico Information Service for Agribusiness
and Fisheries (SIAP), https://www.siap.gob.mx/
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displace the higher value specialty
crops, so we focused our analysis on the
land used for commodity crops: corn,
grain sorghum, soybeans and wheat. We
then specified in the FAPRI–CARD
model that jatropha will displace these
staple crops based on their current share
of land used for commodity crops: 96
percent corn, two percent grain
sorghum, and one percent each of
soybeans and wheat.
For Brazil we used a slightly different
approach to take advantage of the fact
that the FAPRI–CARD model for Brazil
is significantly more detailed than the
Mexico module. As explained above,
based on EPA’s literature review we
determined that jatropha production in
Brazil would predominantly occur in
the northeastern part of the country,
which correlates with the Northeast
Coast and North-Northeast Cerrados
regions in the FAPRI–CARD Brazil
module. Unlike the Mexico part of the
FAPRI–CARD model, the Brazil module
includes crop and pasture land, and
allows for switching between the two.
Instead of specifying how much of each
type of crop and pasture to displace
with jatropha, we specified the area
needed for jatropha production and
allowed the FAPRI–CARD model to
project the land used for jatropha
production.
Table III–5 summarizes the land use
changes projected in our modeling. We
evaluated two cases: one involving
jatropha production only in Mexico, and
the other involving production in both
Brazil and Mexico. In both cases, the
land use impacts in Mexico are the
replacement of other crops (primarily
corn) with jatropha. In the Brazil and
Mexico case, jatropha is planted on
roughly three-quarters pasture and onequarter crop land in Brazil. In both
cases, the rest of the world (outside of
Mexico and Brazil) increases its crop
area. However, globally the total area
devoted to non-jatropha crops and
pasture decreases. Overall, the rest of
the world expands their agricultural
land (the sum of crop and pasture land
including jatropha), meaning that other
types of land, including unmanaged
grassland and forest, are converted for
agricultural uses.
TABLE III–5—PROJECTED LAND USE CHANGES BY CASE IN 2022
[Thousand hectares] 50
Crop Land
Pasture
Jatropha
Other Crops
All Crops
Mexico Only Case
Mexico ..........................................................................................................
Brazil ............................................................................................................
Rest of World ...............................................................................................
345
0
0
(345)
9
114
0
9
114
0
(5)
(63)
Total ......................................................................................................
345
(222)
123
(68)
Mexico ..........................................................................................................
Brazil ............................................................................................................
Rest of World ...............................................................................................
172
216
0
(172)
(62)
81
0
154
81
0
(154)
(49)
Total ......................................................................................................
388
(153)
235
(203)
Brazil and Mexico Case
Table III–6 summarizes the projected
changes in the production of corn,
soybeans and sugarcane, the crops with
the largest changes in the cases we
simulated. In both cases, there is a
reduction in the total area of corn but
an increase in the amount of corn
produced. This is the result of corn
production shifting to regions with
higher yields, particularly the United
States. In both cases, there is a reduction
in the area and production of soybeans
and sugarcane. All of these changes are
less than 0.1% of projected crop
production in 2022.
TABLE III–6—PROJECTED CROP PRODUCTION CHANGES BY CASE IN 2022
[Thousand metric tonnes]
Corn
Soybeans
Sugarcane
Mexico Only Case
(1,151)
292
738
115
185
(9)
103
(97)
(1)
(8)
0
(51)
5
(7)
(4)
Total ................................................................................................................................
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Mexico ....................................................................................................................................
Brazil ......................................................................................................................................
United States .........................................................................................................................
China ......................................................................................................................................
Rest of World .........................................................................................................................
178
(12)
(58)
(578)
110
375
(4)
22
(37)
0
(300)
2
Mexico and Brazil Case
Mexico ....................................................................................................................................
Brazil ......................................................................................................................................
United States .........................................................................................................................
50 For the tables in this Notice, the numbers in
parentheses are negative and the totals may not sum
due to rounding.
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TABLE III–6—PROJECTED CROP PRODUCTION CHANGES BY CASE IN 2022—Continued
[Thousand metric tonnes]
Corn
Soybeans
Sugarcane
China ......................................................................................................................................
Rest of World .........................................................................................................................
62
101
1
1
(2)
54
Total ................................................................................................................................
70
(18)
(246)
projections we used the satellite data to
determine what types of land have been
converted to crops and pasture in each
region, and then applied those land use
change patterns to the agricultural
changes projected by the FAPRI–CARD
modeling. Land use change GHG
emissions were then estimated over 30
TABLE III–7—CHANGES IN GLOBAL
years using emission factors derived
MEAT PRODUCTION BY CASE IN 2022 from various data sources accounting for
average carbon stocks on eight types of
[thousand metric tonnes]
land in 755 distinct regions.52
The land use change GHG emissions
Mexico
Brazil and
only case
Mexico Case are summarized in Table III–8,
including results for both the Mexico
Beef ..................
(0.4)
(4.1) only and Mexico and Brazil cases. The
Pork ..................
(9.4)
(5.7)
results are broken out regionally by
Poultry ...............
(10.0)
(5.8)
Mexico, Brazil, and Rest of World,
because as discussed above, the great
Overall, the projected agricultural
majority of land use change impacts
sector impacts in 2022 of growing
came from Mexico and Brazil. Table III–
jatropha on agricultural land in Mexico
and Brazil in the two cases we evaluated 8 also includes the total emissions for
the low and high ends of the 95%
can be summarized as a reduction in
confidence range for land use change
crop and pasture land in Mexico and
Brazil which triggers an increase in crop GHG emissions, based on the land use
change uncertainty analysis
area in other countries. Just over half of
methodology developed for the March
the increase in crop area in other
2010 RFS rule, which considers the
countries comes at the expense of
uncertainty in the satellite data and land
pasture land, with the rest coming from
use change emissions factors used in
other types of land, including
our assessment.
unmanaged grassland and forest.
Globally, corn production increases,
TABLE III–8—LAND USE CHANGE
while soybean, sugarcane and meat
GHG EMISSIONS BY CASE IN 2022
production declines. Detailed modeling
results and further explanation are
[kgCO2e per tonne delivered jatropha oil]
provided in the docket for this notice,51
Mexico
Brazil and
and we welcome comments on all
]
Only case
Mexico Case
aspects of our analysis.
To estimate the GHG emissions
Mexico ..........
(2,795)
(1,397)
associated with the land use changes
Brazil .............
843
636
summarized in Table III–5, EPA used
Rest of World
569
356
the same methodology as developed for
Total (Mean)
(1,383)
(406)
the March 2010 RFS rule. Per this
Total (Low) ....
(3,725)
(1,827)
methodology, the crop and pasture area
Total (High) ...
612
809
changes in 2022 derived from the
In both cases, the mean values suggest
FAPRI–CARD model were evaluated
negative land use change emissions (net
with Moderate Resolution Imaging
sequestration) associated with growing
Spectroradiometer (MODIS) satellite
jatropha on agricultural land. This is
data to project what types of land (e.g.,
due primarily to the net sequestration
grassland, savanna, forest) would be
that we project from replacing corn
converted to agricultural land (crops
fields with jatropha plantations in
and pasture) in regions where the
Mexico. Per our analysis for the March
FAPRI–CARD model projected
2010 RFS rule, corn in Mexico has
agricultural expansion. For these
mstockstill on DSK4VPTVN1PROD with NOTICES
Table III–7 summarizes the projected
impacts on global meat production. In
both of the cases, meat production
declines. These changes are on the order
of approximately 0.01%, or less, of
projected global livestock production in
2022.
51 Supporting Documentation for Jatropha Oil
Production and Transport GHG Emissions, Air and
Radiation Docket EPA–HQ–OAR–2015–0293.
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52 See Section 2.4 of the Regulatory Impact
Analysis for the March 2010 RFS rule, https://
www.epa.gov/otaq/renewablefuels/420r10006.pdf.
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average biomass carbon stocks of five
tonnes per hectare.53 In our assessment
average jatropha plantation biomass
carbon stocks are 6.9 tonnes per hectare,
so every hectare of corn replaced by
jatropha increases biomass carbon by
1.9 tonnes (including both above- and
below-ground biomass). Additionally,
converting corn to jatropha results in
additional soil carbon sequestration.
Due to the reduced tillage and increased
biomass returned to the soil for jatropha
(tree litter and prunings) compared to
corn, we estimate that after 20 years
jatropha would add approximately 27.7
tonnes of soil carbon per hectare
compared to corn production in
Mexico.54 Therefore, annualized over
thirty years we estimate that replacing
corn with jatropha in Mexico would
result in additional soil sequestration of
approximately 1.0 tonnes of carbon per
hectare.
In both cases, we project positive land
use change emissions in Brazil and
other countries. We project land use
change emissions in Brazil for a number
of reasons. In the Mexico only case,
Brazil expands its crop production to
backfill for some of the lost production
in Mexico. Some of this crop expansion
occurs on pasture, which results in net
land use change emissions from both
biomass and soil carbon, and some of
the crop expansion occurs on other
types of land, including forests. In
particular, the FAPRI–CARD model
projects crop and pasture expansion in
the Amazon, an area with particularly
high carbon stocks, resulting in large
emissions per hectare of conversion. In
the Brazil and Mexico case, the
expansion of jatropha onto corn or
soybean land results in a net
sequestration, but this net sequestration
is smaller than the emissions associated
with replacing sugarcane and pasture
with jatropha.
53 See Section 2.4 of the Regulatory Impact
Analysis for the March 2010 RFS rule, https://
www.epa.gov/otaq/renewablefuels/420r10006.pdf.
54 Based on the methodology developed for the
March 2010 RFS rule, the soil carbon stocks reach
equilibrium after 20 years.
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In both cases, we also project land use
change emissions from the rest of the
world (all regions other than Mexico
and Brazil). In our modeling the main
impact in other countries is increased
crop production to respond to higher
prices and to backfill for some of the
lost production from Mexico and Brazil.
The additional cropland replaces some
pasture and some other types of land,
including unmanaged grasslands and
forests, which results in net land use
change emissions.
For this second scenario, our analysis
also considers indirect emissions
associated with changes in fertilizer,
pesticide and energy use for crop
production, and methane and nitrous
oxide emissions associated with
changes in crop production. The sources
of indirect livestock emissions include
emissions from energy use for livestock
production, and methane and nitrous
oxide emissions associated with raising
cattle, dairy cows, swine and poultry.
The emissions for indirect crop
production were estimated based on
international crop input data and
emission factors developed and peer
reviewed for the March 2010 RFS rule.
The livestock emissions factors are from
the IPCC.
In the first main scenario we
evaluated, where jatropha production
occurs on grassland that is not
otherwise used for crop production or
grazing, there are no indirect emissions
associated with changes in fertilizer,
pesticide and energy use for crop
production, and methane and nitrous
oxide emissions associated with
changes in crop production. In the
second scenario, where jatropha is
grown on agricultural land, there are
indirect emissions associated with how
the agricultural sector responds to the
displacement of crop and grazing land
for jatropha. Table III–9 summarizes the
indirect crop production and livestock
emissions impacts for both of the cases
we evaluated for scenario two. Indirect
agricultural emissions are negative in
both cases, primarily because of
emission reductions from decreased
corn production in Mexico. Indirect
livestock emissions are negative,
because as shown in Table III–7, we
project reductions in meat production in
the cases evaluated.
TABLE III–9—INDIRECT CROP PRODUCTION AND LIVESTOCK EMISSIONS
BY CASE IN 2022
[kgCO2e per tonne delivered jatropha oil]
Mexico
only case
Indirect Crop
Production .....
Indirect Livestock ..............
Mexico and
Brazil case
(431)
(338)
(125)
(392)
Table III–10 summarizes the land use
change, and agricultural sector
emissions in the two main scenarios
that we evaluated. Note that this table
does not include the emissions
associated with cultivation and
harvesting discussed above in Section
III–C.
TABLE III–10—LAND USE CHANGE AND INDIRECT AGRICULTURAL SECTOR EMISSIONS BY SCENARIO IN 2022
[kgCO2e per tonne delivered jatropha oil]
Scenario
Jatropha produced
on unused
grassland in
Mexico in Brazil
Case
Jatropha
produced on
agricultural land
Mexico only
Mexico and Brazil
Land Use Change ....................................................................................................
Indirect Crop Production ..........................................................................................
Indirect Livestock .....................................................................................................
141
..................................
..................................
(1,383)
(431)
(125)
(406)
(338)
(392)
Total ..................................................................................................................
141
(1,940)
(1,136)
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E. Feedstock Transport and Processing
Producing fuels from jatropha
requires oil to be first extracted from its
seeds, and then refined into a finished
fuel product. Oil can either be expelled
from the seeds by mechanical treatment
or extracted using chemical solvents.
There are two commonly used types of
mechanical expellers, the screw press
and the ram press. The screw press is
typically used, and is somewhat more
efficient at expelling oil (75–80% yield)
than the ram press (60–65% yield). Up
to three passes is common to achieve
these yields. Certain pretreatments of
jatropha seeds, such as cooking, can
increase the expelled oil yield to 89%
after a single pass using a screw press
and 91% after a second pass. Chemical
extraction can achieve greater oil yields
than mechanical expulsion. (The most
commonly used chemical extraction
method, the n-hexane method, can
achieve yields of 99%). However,
chemical extraction is capital intensive
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and only economical at very large scales
of production. According to Bailis and
Baka, all jatropha oil produced in Brazil
is extracted by screw press at one
facility. Based on our review of
available literature, EPA’s evaluation
considered oil recovery from jatropha
seeds to occur via screw press
mechanical expulsion assuming oil
yield of 75% and seed oil content of
35%.55 Based on reported electricity
and fuel demands for jatropha oil
extraction, we estimate that oil
extraction results in emissions of 175
kgCO2e per ton of delivered jatropha
oil.56
Our evaluation also considers
emissions associated with pretreating
55 See
‘‘GHG Assessments of Jatropha Oil
Production: Literature Review and Synthesis’’ on
Docket EPA–HQ–OAR–2015–0293.
56 For details on this calculation see the ‘‘Jatropha
Lifecycle GHG Calculations’’ spreadsheet on Docket
EPA–HQ–OAR–2015–0293.
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the jatropha oil.57 Based on data
provided in the GCEH petition, we
evaluated the emissions from jatropha
oil pretreatment with chemicals
(typically sodium hydroxide) to lower
its acid content, and electricity used to
heat the reaction.58 The outputs from
the pre-treatment process are pre-treated
jatropha oil, soapstock and filter cake.
The pre-treated jatropha oil is ready for
transport and use as a biodiesel
feedstock. The soapstock and filter cake
are low value byproducts, and as a
conservative approach we model them
as resulting in no GHG emissions
impacts, i.e., we do not give a
displacement credit for these
byproducts. We estimate the GHG
57 Other vegetable oils that EPA has approved as
feedstocks, including soybean oil, commonly
undergo similar pre-treatment before they are
converted to biofuels. The oil recovered after
pretreatment is still chemically jatropha oil.
58 The pre-treatment data provided in the GCEH
petition is within the range of values EPA found in
the literature.
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emissions from pre-treatment are
approximately 4.7 kgCO2e per ton of
delivered jatropha oil. Pretreatment may
occur at the oil extraction facility or the
biofuel production facility, so it may be
appropriate for EPA to revise the pretreatment emissions on a case-by-case
basis when evaluating petitions from
specific biofuel production facilities.
For our GHG analysis, we assumed
that jatropha is produced, and the
jatropha oil is extracted and pre-treated
in Mexico and Brazil, and that the pretreated oil is then transported to the
United States for use as biofuel
feedstock. First, we calculate the
emissions associated with transporting
the jatropha seed 20 miles by truck to
a facility where the crude jatropha is
extracted via screw press and then pretreated. The truck is loaded with kernel
shells and seedcake and returns 20
miles to the plantation. The pre-treated
jatropha oil is transported 75 miles by
truck to a port and then shipped 500
miles by barge to a port in the U.S. Gulf
of Mexico. For this scenario we estimate
the seed transport emissions to be 24
kgCO2e/mmBtu and the oil transport
emissions to be 10 kgCO2e/mmBtu. For
our analysis, the distances and modes
for seed and oil transport are based on
data provided in the GCEH petition for
jatropha production in Yucatan, Mexico.
We believe these values are also
reasonable to apply for jatropha
production in other regions, including
Brazil. This jatropha oil transport
scenario was developed based on the
best currently-available information, but
may need to be adjusted when EPA
evaluates individual petitions if the
petitioner’s jatropha oil feedstocks are
delivered via a significantly different
route than the one EPA modeled.
mstockstill on DSK4VPTVN1PROD with NOTICES
F. Potential Invasiveness
Jatropha is not currently widespread
in the United States, and is not listed on
the federal noxious weed list.59 A recent
weed risk assessment by USDA found
that jatropha has a moderate risk of
invasiveness in the United States.60 Its
seeds are toxic to animals and humans,
and it is considered a weed in
anthropogenic production and natural
systems. Jatropha is a perennial plant,
meaning that if a grove is abandoned,
seeds would still be produced. In
addition, jatropha can regrow from its
roots. For these reasons, and in
consultation with USDA, the use of
59 USDA (2014). ‘‘Federal Noxious Weed List.’’
Available at: https://www.aphis.usda.gov/plant_
health/plant_pest_info/weeds/downloads/
weedlist.pdf.
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jatropha as a biofuel feedstock raises
concerns about its threat of invasiveness
and whether its production could
require remediation activities that
would be associated with additional
GHG emissions. Therefore, similar to
EPA’s actions with respect to other
biofuel feedstocks found to present
invasiveness risks, such as Arundo
donax and Pennisetum purpureum, EPA
anticipates that any petition approvals
for renewable fuel pathways involving
the use of jatropha oil as feedstock will
include requirements related to
mitigating risks associated with
invasiveness. However, based on our
consultations with USDA, EPA does not
believe that the requirements for
jatropha are likely to be as stringent as
those for Arundo donax and Pennisetum
purpureum, because, in the judgment of
USDA, the risk of invasiveness for
jatropha is likely to be smaller than for
these two other feedstocks.61 A fuel
producer may alternatively demonstrate
that there is not a significant likelihood
of spread beyond the planted area, or
that the species will be grown and
processed in its native range where no
or little risk of impact is expected if it
spreads from planting sites. As outlined
in the rule published on July 11, 2013
(78 FR 41702) for Arundo donax and
Pennisetum purpureum, the fuel
producer would need a letter from
USDA that concludes that jatropha does
not pose a spread of risk beyond the
planted area. With these requirements
in place, we would assume that there
are no GHG emissions associated with
potential invasiveness when jatropha oil
is used as a biofuel feedstock. EPA is
taking comment on the invasiveness
concerns of jatropha and the
appropriateness of the referenced
requirements in mitigating those
concerns.
G. Summary of GHG Emissions From
Jatropha Oil Production and Transport
The results of our analysis of the GHG
emissions associated with jatropha oil
production and transport are
summarized in Table III–11. The table
summarizes the results for the two main
scenarios that we evaluated: the first
scenario where jatropha is grown on
unused grassland in Mexico and Brazil
and a second scenario where it is grown
on agricultural land. For the second
scenario, results are summarized for two
cases: the first with jatropha production
60 USDA Animal and Plant Health Inspection
Service (2015). ‘‘Weed risk assessment for Jatropha
curcas L. (Euphorbiaceae)—Physic nut.’’ The weed
risk assessment classifies jatropha as ‘‘evaluate
further,’’ which means it poses a moderate risk of
invasiveness.
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on agricultural land in Mexico, and the
second with jatropha production on
agricultural land in Mexico and Brazil.
For comparison, Table III–11 also
includes a summary of soybean oil
production and transport GHG
emissions as estimated for the March
2010 RFS rule. (Some emissions
categories for the soybean results have
been combined to align as much as
possible with the jatropha results.) The
results summarized in Table III–11
show that based on the scenarios we
evaluated, the GHG emissions
associated with producing and
transporting jatropha oil as a biofuel
feedstock are less than similar emissions
for soybean oil. When evaluating
petitions to use jatropha oil as biofuel
feedstock we would also consider GHG
emissions from fuel production and fuel
distribution, in addition to the
emissions summarized in Table III–11
(adjusted as appropriate for petitioners’
individual circumstances).
The agency also conducted an
uncertainty analysis and estimated the
95 percent confidence range for each of
the scenarios evaluated. For this
evaluation, we used the same
methodology and spreadsheet model
used for the March 2010 RFS rule. For
the unused grassland scenarios we
considered the uncertainty in the
emissions factors used in our analysis.
For the agricultural land scenarios, we
considered the uncertainty in both the
range of potential values for the satellite
data and land use change emissions
factors used in our modeling. The low
and high ends of the 95 percent
confidence range are presented below in
Table III–11, with results from the
jatropha scenarios displayed along with
the results from our soybean oil
modeling for the March 2010 RFS rule.
The range is narrowest for the unused
grassland-only scenario because it does
not incur uncertainty associated with
using satellite data to project land use
change patterns. Comparing the
uncertainty estimates for the scenario
with jatropha oil produced on
agricultural land and the estimates for
the soybean oil results, the confidence
range is narrower for the soybean results
because a greater proportion of the land
use change impacts for soybeans are in
regions and impact types of land where
EPA has better quality data. We invite
comment on our analysis and the results
presented below.
61 For details on the requirements imposed on
Arundo donax and Pennisetum purpureum, see the
rule published on July 11, 2013 (78 FR 41702),
https://www.gpo.gov/fdsys/pkg/FR–2013–07–11/pdf/
2013–16488.pdf.
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Federal Register / Vol. 80, No. 197 / Tuesday, October 13, 2015 / Notices
TABLE III–11—PRODUCTION AND TRANSPORT GHG EMISSIONS FOR JATROPHA OIL
[kgCO2e per tonne of delivered oil] 62
Jatropha oil
Produced on
Unused grassland
in Mexico
and Brazil
Emissions category
mstockstill on DSK4VPTVN1PROD with NOTICES
Land Use Change ..................................................................
Preparation and Planting .......................................................
Annual Cultivation ..................................................................
Indirect Crop Production ........................................................
Indirect Livestock ...................................................................
Oil Extraction .........................................................................
Oil Pre-Treatment ..................................................................
Seed Transport ......................................................................
Oil Transport ..........................................................................
Total ................................................................................
Low ........................................................................................
High ........................................................................................
Based on the results summarized in
Table III–11, we believe it is reasonable,
as a conservative approach (and subject
to confirmation upon review of
individual petition submissions), to
apply the GHG emissions estimates we
established in the March 2010 rule for
the production and transport of soybean
oil to jatropha oil when evaluating
future facility-specific petitions from
biofuel producers seeking to generate
RINs for volumes of biofuel produced
from jatropha oil. While it is possible
that jatropha could be grown on other
types of land, such as shrubland or
secondary forest, that would result in
higher GHG emissions than the
scenarios we evaluated, the RFS
program’s qualification requirements for
renewable biomass would prevent the
use of jatropha grown on such lands
from use as an RFS renewable fuel
feedstock. The renewable biomass
definition would not prevent a scenario
where jatropha is planted on
agricultural land, and the displaced
crops or pasturage is then shifted to
shrubland or forestland. However, as
discussed above, our modeling suggests
that this scenario is not expected.
Therefore, we believe it is reasonable to
conclude that the overall emissions
attributable to the production and
transportation of jatropha oil used to
produce biofuels for the RFS program
will be equal to or less than the same
types of emissions attributable to
soybean oil. We welcome public
comments on all aspects of our
assessment.
62 Totals may not sum due to rounding. The
‘‘Total’’ results represents our mean estimates, and
the ‘‘Low’’ and ‘‘High’’ results represent the low
and high ends of the 95 percent confidence range.
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21:23 Oct 09, 2015
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Produced on agricultural land
Mexico Only
141
67
983
..................................
..................................
175
5
24
10
1,404
1,217
1,590
Jatropha oil is suitable for the same
conversion processes as soybean oil and
other previously approved feedstocks
for making biodiesel, renewable diesel,
jet fuel, naphtha and liquefied
petroleum gas. In addition, the fuel
yield per pound of oil is expected to be
similar for fuel produced from jatropha
oil and soybean oil through these
processes. Jatropha may also be suitable
for other conversion processes and types
of fuel that EPA has not previously
evaluated. After reviewing comments
received in response to this action, we
will combine our evaluation of
agricultural sector GHG emissions
associated with the use of jatropha oil
feedstock with our evaluation of the
GHG emissions associated with
individual producers’ production
processes and finished fuels to
determine whether any proposed
pathway satisfies CAA lifecycle GHG
emissions reduction requirements for
RFS-qualifying renewable fuels. Each
biofuel producer seeking to generate
RINs for non-grandfathered volumes of
biofuel produced from jatropha oil will
first need to submit a petition requesting
EPA’s evaluation of their new renewable
fuel pathway pursuant to 40 CFR
80.1416 of the RFS regulations, and
include all of the information specified
at 40 CFR 80.1416(b)(1). Because EPA is
evaluating the greenhouse gas emissions
associated with the production and
transport of jatropha oil feedstock
through this action and comment
process, petitions requesting EPA’s
evaluation of biofuel pathways
involving jatropha oil feedstock will not
have to include the information for new
feedstocks specified at 40 CFR
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Fmt 4703
Sfmt 4703
Mexico and Brazil
(1,383)
40
964
(431)
(125)
175
5
24
10
(721)
(3,063)
1,273
H. Fuel Production and Distribution
Soybean oil
(406)
67
983
(338)
(392)
175
5
24
10
128
(1,293)
1,342
1,158
(3)
(291)
470
91
1,425
470
2,580
80.1416(b)(2).63 Based on our evaluation
of the lifecycle GHG emissions
attributable to the production and
transport of jatropha oil feedstock, EPA
anticipates that fuel produced from
jatropha oil feedstock through the same
transesterification or hydrotreating
process technologies that EPA evaluated
for the March 2010 RFS rule for biofuel
derived from soybean oil and the March
2013 RFS rule for biofuel derived from
camelina oil would qualify for biomassbased diesel (D-code 4) RINs or
advanced biofuel (D-code 5) RINs.64
However, EPA will evaluate petitions
for fuel produced from jatropha oil
feedstock on a case-by-case basis.
IV. Summary
EPA invites public comment on its
analysis of GHG emissions associated
with the production and transport of
jatropha oil as a feedstock for biofuel
production. EPA will consider public
comments received when evaluating the
lifecycle GHG emissions of biofuel
production pathways described in
63 For information on how to submit a petition for
biofuel produced from jatropha oil see EPA’s Web
page titled ‘‘How to Submit a Complete Petition’’
(https://www.epa.gov/otaq/fuels/renewablefuels/
new-pathways/how-to-submit.htm) including the
document on that Web page titled ‘‘How to Prepare
a Complete Petition.’’ Petitions for biofuel produced
from jatropha oil should include all of the
applicable information outlined in Section 3 of the
‘‘How to Prepare a Complete Petition’’ document,
but they do not need to provide the information
outlined in section 3(F)(2) (Information for New
Feedstocks).
64 The transesterification process that EPA
evaluated for the March 2010 RFS rule for biofuel
derived from soybean oil feedstock is described in
section 2.4.7.3 (Biodiesel) of the Regulatory Impact
Analysis for the March 2010 RFS rule (EPA–420–
R–10–006). The hydrotreating process that EPA
evaluated for the March 2013 rule for biofuel
derived from camelina oil feedstock is described in
section II.A.3.b of the March 2013 rule (78 FR
14190).
E:\FR\FM\13OCN1.SGM
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Federal Register / Vol. 80, No. 197 / Tuesday, October 13, 2015 / Notices
petitions received pursuant to 40 CFR
80.1416 that use jatropha oil as a
feedstock.
FOR FURTHER INFORMATION CONTACT:
Dated: September 30, 2015.
Christopher Grundler,
Director, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2015–26039 Filed 10–9–15; 8:45 am]
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
[EPA–HQ 20415–0641; FRL –9935–60–OW]
Proposed Information Collection
Request; Comment Request;
Information Collection Request for
Reporting Requirements for BEACH
Act Grants (Renewal)
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
The Environmental Protection
Agency is planning to submit an
information collection request (ICR),
‘‘Information collection request for
reporting requirements for BEACH act
grants (renewal)’’ (EPA ICR No. 2048.05,
OMB Control No. 2040–0244) to the
Office of Management and Budget
(OMB) for review and approval in
accordance with the Paperwork
Reduction Act (44 U.S.C. 3501 et seq.).
Before doing so, EPA is soliciting public
comments on specific aspects of the
proposed information collection as
described below. This is a proposed
extension of the ICR, which is currently
approved through December 31, 2015.
An Agency may not conduct or sponsor
and a person is not required to respond
to a collection of information unless it
displays a currently valid OMB control
number.
DATES: Comments must be submitted on
or before December 14, 2015.
ADDRESSES: Submit your comments,
referencing Docket ID No. EPA–HQ
20415–0614 online using
www.regulations.gov (our preferred
method), or by mail to: EPA Docket
Center, Environmental Protection
Agency, Mail Code 28221T, 1200
Pennsylvania Ave., NW., Washington,
DC 20460.
EPA’s policy is that all comments
received will be included in the public
docket without change including any
personal information provided, unless
the comment includes profanity, threats,
information claimed to be Confidential
Business Information (CBI) or other
information whose disclosure is
restricted by statute.
mstockstill on DSK4VPTVN1PROD with NOTICES
SUMMARY:
VerDate Sep<11>2014
21:23 Oct 09, 2015
Jkt 238001
Tracy Bone, OW, 4305T, Environmental
Protection Agency, 1200 Pennsylvania
Ave., NW., Washington, DC 20460;
telephone number: 202–564–5257;
email address: bone.tracy@epa.gov.
SUPPLEMENTARY INFORMATION:
Supporting documents which explain
in detail the information that the EPA
will be collecting are available in the
public docket for this ICR. The docket
can be viewed online at
www.regulations.gov or in person at the
EPA Docket Center, WJC West, Room
3334, 1301 Constitution Ave., NW.,
Washington, DC. The telephone number
for the Docket Center is 202–566–1744.
For additional information about EPA’s
public docket, visit https://www.epa.gov/
dockets.
Pursuant to section 3506(c)(2)(A) of
the PRA, EPA is soliciting comments
and information to enable it to: (i)
evaluate whether the proposed
collection of information is necessary
for the proper performance of the
functions of the Agency, including
whether the information will have
practical utility; (ii) evaluate the
accuracy of the Agency’s estimate of the
burden of the proposed collection of
information, including the validity of
the methodology and assumptions used;
(iii) enhance the quality, utility, and
clarity of the information to be
collected; and (iv) minimize the burden
of the collection of information on those
who are to respond, including through
the use of appropriate automated
electronic, mechanical, or other
technological collection techniques or
other forms of information technology,
e.g., permitting electronic submission of
responses. EPA will consider the
comments received and amend the ICR
as appropriate. The final ICR package
will then be submitted to OMB for
review and approval. At that time, EPA
will issue another Federal Register
notice to announce the submission of
the ICR to OMB and the opportunity to
submit additional comments to OMB.
Abstract: The Beaches Environmental
Assessment and Coastal Health
(BEACH) Act amends the Clean Water
Act (CWA) in part and authorizes the
U.S. Environmental Protection Agency
(EPA) to award BEACH Act Program
Development and Implementation
Grants to coastal and Great Lakes states,
tribes, and territories (collectively
referred to as states) for their beach
monitoring and notification programs.
The grants will assist those states to
develop and implement a consistent
approach to monitor recreational water
quality; assess, manage, and
communicate health risks from
PO 00000
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Fmt 4703
Sfmt 4703
61419
waterborne microbial contamination;
notify the public of pollution
occurrences, and post beach advisories
and closures to prevent public exposure
to microbial pathogens. To qualify for a
BEACH Act Grant, a state must submit
information to EPA documenting that its
beach monitoring and notification
program is consistent with 11
performance criteria outlined in the
National Beach Guidance and Required
Performance Criteria for Grants, 2014
Edition.
Form Numbers: None.
Respondents/affected entities: Entities
potentially affected by this action are
environmental and public health
agencies in coastal and Great Lakes
states, territories, and tribes.
Respondent’s obligation to respond:
Required to obtain the grants as directed
by the Beaches Environmental
Assessment and Coastal Health
(BEACH) Act amendment to the Clean
Water Act (CWA).
Estimated number of respondents: 38.
Frequency of response: Submitting
monitoring and notification reports
quarterly, all other reporting annual.
Total estimated burden: 92,391 hours
(per year). Burden is defined at 5 CFR
1320.03(b)
Total estimated cost: $13,302,102 (per
year), includes $9,731,280 operation &
maintenance costs. There are no capital
costs.
Changes in Estimates: There is an
increase of 3,579 hours in the total
estimated respondent burden compared
with the ICR currently approved by
OMB. This increase is due to an
additional respondent qualifying for a
grant and to additional performance
criteria related to public evaluation of
programs and implementation
schedules, which are discussed in the
updated grant guidance document,
National Beach Guidance and Required
Performance Criteria for Grants, 2014
Edition.
Dated: October 1, 2015.
Elizabeth Southerland,
Director, Office of Science and Technology.
[FR Doc. 2015–26037 Filed 10–9–15; 08:45 am]
BILLING CODE 6560–50–P
EXPORT-IMPORT BANK
[Public Notice 2015–3020]
Agency Information Collection
Activities: Comment Request
Export-Import Bank of the U.S.
Submission for OMB review and
comments request.
AGENCY:
ACTION:
E:\FR\FM\13OCN1.SGM
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]]>Agencies
[Federal Register Volume 80, Number 197 (Tuesday, October 13, 2015)]
[Notices]
[Pages 61406-61419]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-26039]
=======================================================================
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2015-0293; FRL-9935-46-OAR]
Notice of Opportunity To Comment on an Analysis of the Greenhouse
Gas Emissions Attributable to Production and Transport of Jatropha
Curcas Oil for Use in Biofuel Production
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Environmental Protection Agency (EPA) is inviting comment
on its analysis of the greenhouse gas emissions attributable to the
production and transport of Jatropha curcas (``jatropha'') oil
feedstock for use in making biofuels such as biodiesel, renewable
diesel, jet fuel, naphtha and liquefied petroleum gas. This notice
explains EPA's analysis of the production and transport components of
the lifecycle greenhouse gas emissions of biofuel made from jatropha
oil, and describes how EPA may apply this analysis in the future to
determine whether such biofuels meet the necessary greenhouse gas
reductions required for qualification as renewable fuel under the
Renewable Fuel Standard program. Based on this analysis, we anticipate
that biofuels produced from jatropha oil could qualify as biomass-based
diesel or advanced biofuel if typical fuel production process
technologies or process technologies with the same or lower GHG
emissions are used.
DATES: Comments must be received on or before October 13, 2015.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2015-0293 to the Federal eRulemaking Portal: https://www.regulations.gov. Follow the online instructions for submitting
comments. Once submitted, comments cannot be edited or withdrawn. The
EPA may publish any comment received to its public docket. Do not
submit electronically any information you consider to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Multimedia submissions (audio, video, etc.) must
be accompanied by a written comment. The written comment is considered
the official comment and should include discussion of all points you
wish to make. The EPA will generally not consider comments or comment
contents located outside of the primary submission (i.e., on the web,
cloud, or other file sharing system). For additional submission
methods, the full EPA public comment policy, information about CBI or
multimedia submissions, and general guidance on making effective
comments, please visit https://www2.epa.gov/dockets/commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT: Christopher Ramig, Office of
Transportation and Air Quality, Transportation and Climate Division,
Mail Code: 6401A, U.S. Environmental Protection Agency, 1200
Pennsylvania Avenue NW., 20460; telephone number: (202) 564-1372; fax
number: (202) 564-1177; email address: ramig.christopher@epa.gov.
SUPPLEMENTARY INFORMATION:
I. General Information
A. Submitting CBI. Do not submit this information to EPA through
www.regulations.gov or email. Clearly mark the part or all of the
information that you claim to be CBI. For CBI information in a disk or
CD ROM that you mail to EPA, mark the outside of the disk or CD ROM as
CBI and then identify electronically within the disk or CD ROM the
specific information that is claimed as CBI. In addition to one
complete version of the comment that includes information claimed as
CBI, a copy of the comment that does not contain the information
claimed as CBI must be submitted for inclusion in the public docket.
Information so marked will not be disclosed except in accordance with
procedures set forth in 40 CFR part 2.
B. Tips for Preparing Your Comments. When submitting comments,
remember to:
Identify the rulemaking by docket number and other
identifying information (subject heading, Federal Register date and
page number).
Follow directions--The agency may ask you to respond to
specific questions or organize comments by referencing a Code of
Federal Regulations (CFR) part or section number.
Explain why you agree or disagree; suggest alternatives
and substitute language for your requested changes.
[[Page 61407]]
Describe any assumptions and provide any technical
information and/or data that you used.
If you estimate potential costs or burdens, explain how
you arrived at your estimate in sufficient detail to allow for it to be
reproduced.
Provide specific examples to illustrate your concerns, and
suggest alternatives.
Explain your views as clearly as possible, avoiding the
use of profanity or personal threats.
Make sure to submit your comments by the comment period
deadline identified.
This notice is organized as follows:
I. General Information
II. Introduction
III. Analysis of Greenhouse Gas Emissions Associated With Use of
Jatropha Oil as a Biofuel Feedstock
A. Summary of Greenhouse Gas Analysis
B. Feedstock Description and Growing Conditions
C. Cultivation and Harvesting
D. Land Use Change and Agricultural Sector Emissions
E. Feedstock Transport and Processing
F. Potential Invasiveness
G. Summary of GHG Emissions From Jatropha Oil Production and
Transport
H. Fuel Production and Distribution
IV. Summary
II. Introduction
As part of changes to the Renewable Fuel Standard (RFS) program
regulations published on March 26, 2010 \1\ (the ``March 2010 RFS
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 to qualify as renewable fuel. EPA may also
approve additional fuel pathways not currently listed in Table 1 to 40
CFR 80.1426 for participation in the RFS program, including in response
to a petition filed pursuant to 40 CFR 80.1416 by a biofuel producer
seeking EPA evaluation of a new fuel pathway.
---------------------------------------------------------------------------
\1\ See 75 FR 14670.
---------------------------------------------------------------------------
EPA's lifecycle analyses are used to assess the overall greenhouse
gas (GHG) 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.
EPA received a petition submitted pursuant to 40 CFR 80.1416 from
Global Clean Energy Holdings (``GCEH'' or the ``GCEH petition'') and
Emerald Biofuels, LLC, submitted under a claim of confidential business
information (CBI), requesting that EPA evaluate the lifecycle GHG
emissions for biofuels (biodiesel, renewable diesel, jet fuel and
naphtha) produced from the oil extracted from Jatropha curcas
(hereafter referred to as ``jatropha'' or ``jatropha oil''). The
petition also requested EPA provide a determination of the renewable
fuel categories, if any, for which such biofuels may be eligible under
the Renewable Fuel Standard (RFS) program. The Agency also received a
separate petition from Plant Oil Powered Diesel Fuel Systems, Inc.,
submitted under a claim of CBI, requesting that EPA evaluate the
lifecycle GHG emissions for the use of neat jatropha oil as a
transportation fuel, and that EPA provide a determination of the
renewable fuel categories, if any, for which such neat jatropha oil
fuel may be eligible.\2\
---------------------------------------------------------------------------
\2\ There are no further references in this Notice to Plant Oil
Powered Diesel Fuel Systems, Inc., as they did not agree to waive
CBI claims to the data/information contained in their petition and
supporting documentation submitted to EPA pursuant to 40 CFR
80.1416, or references thereto.
---------------------------------------------------------------------------
EPA has conducted an evaluation of the GHG emissions associated
with the production and transport of jatropha oil when it is used as a
biofuel feedstock, and is seeking public comment on the methodology and
results of this evaluation. In this document, we are describing EPA's
evaluation of the GHG emissions associated with the feedstock
production and feedstock transport stages of the lifecycle analysis of
jatropha oil when it is used to produce a biofuel, including the
indirect agricultural and forestry sector impacts. We are seeking
public comment on the methodology and results of this evaluation. For
the reasons described in Section III below, we believe that it is
reasonable to apply the GHG emissions estimates we established in the
March 2010 rule for the production and transport of soybean oil to the
production and transport of jatropha oil.
If appropriate, EPA will update its evaluation of the feedstock
production and transport phases of the lifecycle analysis for jatropha
oil based on comments received in response to this action. EPA will
then use this feedstock production and transport information to
evaluate facility-specific petitions, received pursuant to 40 CFR
80.1416, that propose to use jatropha oil as a feedstock for the
production of biofuel. In evaluating such petitions, EPA will consider
the GHG emissions associated with the production and transport of
jatropha oil feedstock. In addition, EPA will determine--based on
information in the petition and other relevant information, including
the petitioner's energy and mass balance data--the GHG emissions
associated with petitioners' biofuel production processes, as well as
emissions associated with the transport and use of the finished
biofuel. We will then combine our assessments into a full lifecycle GHG
analysis and determine whether the fuel produced at an individual
facility satisfies CAA renewable fuel GHG reduction requirements.
III. Analysis of Greenhouse Gas Emissions Associated With Use of
Jatropha Oil as a Biofuel Feedstock
EPA has evaluated the GHG emissions associated with the production
and transport of jatropha oil for use as a biofuel feedstock, based on
information provided in the GCEH petition and other data gathered by
EPA. Section III-A includes an overview of our GHG analysis of jatropha
oil production and transport. Section III-B describes jatropha oil and
available information about the growing conditions suitable for
commercial-scale production. Section III-C explains our analysis of the
GHG emissions attributable to growing and harvesting jatropha seeds.
Section III-D describes our analysis of the land use change and other
agricultural sector emissions, including significant indirect
emissions, attributable to producing jatropha oil for use as a biofuel
feedstock. Section III-E explains our assessment of the GHG emissions
associated with feedstock transport and processing, including oil
extraction and pre-treatment. Section III-F discusses the potential
invasiveness of jatropha. Section III-G summarizes GHG emissions from
jatropha oil production and transport. Section III-H discusses how EPA
intends to consider the GHG emissions associated with fuel production
and
[[Page 61408]]
distribution when evaluating facility-specific petitions from biofuel
producers seeking to generate renewable identification numbers (RINs)
for non-grandfathered volumes of biofuel produced from jatropha oil.
This Notice explains and seeks comment on each component of EPA's
GHG assessment of jatropha oil production and transportation. We also
discuss and seek comment on potential invasiveness concerns for
jatropha as they relate to GHG emissions. In this Notice we compare our
assessment of jatropha oil to our previous evaluation of soybean oil
for the March 2010 RFS rule because jatropha oil and soybean oil can be
used in the same types of production processes to produce biodiesel,
renewable diesel, jet fuel, and other similar types of biofuels. In the
March 2010 RFS rule, EPA determined that several renewable fuel
pathways using soybean oil feedstock meet the required 50% lifecycle
GHG reduction threshold under the RFS for biomass-based diesel and
advanced biofuel.\3\
---------------------------------------------------------------------------
\3\ These pathways included biodiesel produced from soybean oil
through a transesterification production process, and renewable
diesel, jet fuel and heating oil produced from soybean oil through a
hydrotreating production process.
---------------------------------------------------------------------------
A. Summary of Greenhouse Gas Analysis
Based on the limited data available on where jatropha will be
produced at commercial scale for use in making biofuels for the RFS
program, we evaluated a number of scenarios with different assumptions
about where jatropha will be grown and what type of land jatropha
plantations will use. This section briefly discusses the two main
scenarios that we evaluated and our overall findings based on these
analyses.
As explained in more detail in Section III-B below, based on
information in the GCEH petition and other data gathered by EPA through
literature review and expert consultations, we believe that southern
Mexico (specifically the states of Yucatan, Oaxaca and Chiapas) and
northeastern Brazil \4\ are the likely locations for commercial-scale
production of jatropha for use in making biofuels for the RFS program.
Given the limited amount of available data, these are the two countries
where we found reliable evidence on jatropha production that could
supply significant volumes of qualifying biofuel feedstock under the
RFS program. In the first scenario that we evaluated, we assume that
jatropha production will occur on grassland in southern Mexico and
northeastern Brazil that is not currently being used for crop
production or pasture use. As explained more below, we estimate that on
average the GHG emissions attributable to jatropha oil extracted from
jatropha seeds grown on unused grasslands in southern Mexico are 951
kilograms of carbon dioxide-equivalent emissions (kgCO2e)
per tonne of jatropha oil that has been harvested, extracted, pre-
treated to lower acidity and delivered to a biofuel producer
(``delivered jatropha oil''), compared to 1,425 kgCO2e per
tonne of delivered soybean oil. If jatropha is grown on grassland in
northeastern Brazil that would not otherwise have been used for crop
production or grazing, we estimate that the GHG emissions would be
1,858 kgCO2e per tonne of delivered jatropha oil. Land use
change emissions are higher in northeastern Brazil than in Mexico
because, on average, grasslands in northeastern Brazil sequester
significantly more carbon than grasslands in southern Mexico.\5\ Since
we think it is likely that jatropha will be grown in both locations, we
believe it is appropriate to evaluate a scenario in which we assume an
equal amount of growth on grasslands in southern Mexico and
northeastern Brazil. In this scenario, the GHG emissions are 1,404
kgCO2e per tonne of delivered jatropha oil, which is lower
than the emissions attributable to delivered soybean oil.
---------------------------------------------------------------------------
\4\ Specifically the regions of Brazil that encompasses the
following provinces: Alagoas, Bahia, Ceara, Maranhao, Paraiba,
Pernambuco, Piaui, Rio Grande do Norte, Sergipe, Tocantins.
\5\ Based on our assessment of land use change emissions factors
for previous RFS rules, on average grasslands in Mexico sequester
approximately 15 tonnes CO2e per hectare compared to 40
tonnes CO2e per hectare in northeastern Brazil.
---------------------------------------------------------------------------
In a second scenario, we considered the possibility that jatropha
will be grown on land that would have otherwise been used for
agriculture (crop production or grazing/pasture). For this analysis we
used the Food and Agricultural Policy and Research Institute
international models as maintained by the Center for Agricultural and
Rural Development at Iowa State University (the FAPRI-CARD model),\6\
that has been used for a number of previous RFS rulemakings, including
the March 2010 RFS rule. We conducted two analyses within this
scenario: One where we assumed that jatropha will displace crops
(predominantly corn) in Mexico, and one where jatropha is grown on
cropland in Mexico and on agricultural land in Brazil (with the model
choosing what land to displace in Brazil). The second scenario, where
jatropha is grown on land otherwise used for agricultural production,
evaluates the impacts associated with jatropha displacing crop and
pasture land, including evaluating whether and where increased crop
production or pasturage would occur in other regions to compensate for
the jatropha displacement. In both of these analyses the GHG emissions
attributable to the production of jatropha oil are much lower than the
corresponding emissions for soybean oil. Specifically, for the Mexico
cropland analysis we estimated GHG emissions of negative 721
kgCO2e per tonne of delivered jatropha oil. As explained
more below, the net GHG emissions in this analysis are negative
primarily because jatropha sequesters more carbon than the cropland it
displaces and the indirect emissions are relatively small because the
displaced corn production is backfilled by higher yield producers
(e.g., corn production in the United States). For the Mexico and Brazil
analysis, the net GHG emissions are 128 kgCO2e per tonne of
delivered jatropha oil, which is also significantly less than the
emissions per tonne of delivered soybean oil.
---------------------------------------------------------------------------
\6\ For more information on the FAPRI-CARD model see the March
2010 RFS rule and associated Regulatory Impact Analysis: Renewable
Fuel Standard Program (RFS2) Regulatory Impact Analysis. EPA-420-R-
10-006. https://www.epa.gov/oms/renewablefuels/420r10006.pdf
---------------------------------------------------------------------------
Based on the two scenarios described above, we believe it is
reasonable, as a conservative approach, to apply the GHG emissions
estimates we established in the March 2010 rule for the production and
transport of soybean oil to jatropha oil when evaluating future
facility-specific petitions from biofuel producers seeking to generate
RINs for volumes of biofuel produced from jatropha oil.\7\ The
following sections and supporting documentation in the public docket
provides more details on the scenarios and analyses described
[[Page 61409]]
above. We welcome public comments on all aspects of our assessment.
---------------------------------------------------------------------------
\7\ The purpose of lifecycle assessment under the RFS program is
not to precisely estimate lifecycle GHG emissions associated with
particular biofuels, but instead to determine whether or not the
fuels satisfy specified lifecycle GHG emissions thresholds to
qualify as one or more of the four types of renewable fuel specified
in the statute. If the record demonstrates that the GHG emissions
associated with the use of jatropha oil are at least as low as those
of soybean oil (which meets the most stringent, 50%, lifecycle GHG
reduction threshold specified for non-cellulosic feedstocks) then
EPA can conclude that where comparable biofuel production methods
are used that jatropha oil-based biofuels will qualify in the same
manner as soybean oil-based biofuels. In some cases, as here, this
comparative approach simplifies EPA's assessment, and allows
relevant conclusions to be drawn despite uncertainty that may be
associated with an attempt to determine a more precise lifecycle GHG
assessment. Similarly, where there are a range of possible outcomes
and the fuel satisfies GHG reduction requirements for the optimum
RFS renewable fuel qualification when ``conservative'' assumptions
are used, then a more precise quantification of the matter is not
required for purposes of a pathway determination.
---------------------------------------------------------------------------
B. Feedstock Description and Growing Conditions
Jatropha is a deciduous, perennial shrub or tree species belonging
to the Euphorbiaceae family that grows approximately 8 to 15 meters
tall. Experts agree that jatropha is native to the American tropics;
however there is disagreement in the literature regarding its origin
and the borders of jatropha's native range.\8\ However, it is
naturalized throughout Latin America, including Mexico, Central America
and the Caribbean, and to a lesser extent in Argentina, Bolivia,
Brazil, Colombia, Ecuador, Paraguay, Peru and Venezuela.\9\
Traditionally, it has been grown in tropical and sub-tropical regions
in Africa, Asia and Latin America as a hedge and ornamental plant.
Jatropha is adapted to arid and semi-arid conditions and high
temperatures, and it has been found to be very frost intolerant. In its
Latin American range, it is common in deciduous forests and open spaces
including grassland-savannah and scrub forests. It prefers low
altitudes, well drained soils and good aeration. It is adapted to
marginal lands with low nutrient content, but commercial production has
been unsuccessful in these conditions. Jatropha fruit, similar in
appearance to a walnut, can be harvested at least once per year, though
multiple harvests are possible as mature jatropha plants flower
throughout the year. The fruit has a thick outer covering called a
husk. Each fruit contains one to three seeds, each with a durable outer
shell and a softer oil-bearing inner kernel. The seeds are 25-50
percent oil by mass. When oil is extracted from the kernel the
remaining material forms a seedcake (also known as press cake or meal
cake) that contains curcin, a highly toxic protein. Although the oil
and seedcake are toxic to humans and livestock, the oil has good
properties for use as a biofuel feedstock to produce fuels such as
biodiesel, renewable diesel and jet fuel, and the seedcake can be used
as fertilizer or as fuel for process heat.
---------------------------------------------------------------------------
\8\ CABI Jatropha Curcas Data Sheet, https://www.cabi.org/isc/datasheet/28393
\9\ Ibid.
---------------------------------------------------------------------------
Jatropha does not have a long history as a planted crop. As a
result, empirical data on crop yields, crop inputs, and other key
agricultural characteristics are not readily available. In order to
fill these knowledge gaps to the greatest extent possible, EPA
conducted a literature review of agronomic and lifecycle GHG analysis
studies of jatropha.\10\ We sought input on a draft of the literature
review from a wide array of stakeholders, including academics,
environmental organizations, industry groups and the parties who
submitted petitions involving the use of jatropha oil feedstock. The
comments we received were considered in preparing the revised document
available in the public docket associated with this Notice.
---------------------------------------------------------------------------
\10\ See ``GHG Assessments of Jatropha Oil Production:
Literature Review and Synthesis'' in Docket EPA-HQ-OAR-2015-0293.
---------------------------------------------------------------------------
Several past efforts to cultivate jatropha for biofuel use
attempted, without commercial success, to produce jatropha on marginal
agricultural land with minimal inputs.\11\ By contrast, the petitioners
and others working to commercialize jatropha more recently have
utilized higher quality agricultural land and have made much more
extensive use of fertilizer, irrigation, and other agricultural inputs.
Therefore, for purposes of this assessment, we assume that jatropha
grown for use as a biofuel feedstock will be grown as a planted crop
under normal agricultural conditions. In other words, we expect
jatropha to be grown by farmers on arable land with the use of
fertilizer, pesticides, irrigation where necessary, and other crop
inputs. Our projection that jatropha grown for biofuel feedstock
targeted to the U.S. market will be cultivated on agricultural-quality
land also aligns with the definition of renewable biomass at 40 CFR
80.1401, which specifies that planted crops must be grown on existing
agricultural land cleared or cultivated prior to December 19, 2007.
---------------------------------------------------------------------------
\11\ Kant, P. and S. Wu. 2011. ``The Extraordinary Collapse of
Jatropha as a Global Biofuel.'' Environmental Science & Technology
45(17):7114-7115. doi: 10.1021/es201943v.
---------------------------------------------------------------------------
Based on conversations with researchers at the United States
Department of Agriculture Agricultural Research Service (USDA-ARS) and
other organizations, we determined that jatropha is unlikely to be
commercially grown in the United States because of its high intolerance
to frost.\12\ USDA and several university research groups have
attempted to grow jatropha in the United States, including projects in
Arizona, California, and Florida. To date, no one has demonstrated that
jatropha would be a viable commercial-scale crop in the United States
due primarily to its extreme frost intolerance.\13\ Even in the
southernmost reaches of the country, occasional frosts have proven too
severe for the plant to be viable. For these reasons, EPA's analysis
does not consider jatropha production in the United States.
---------------------------------------------------------------------------
\12\ Telephone conversations with Terry Coffelt (USDA-ARS),
Terry Isbell (USDA-ARS), Roy Scott (USDA-ARS), Dan Parfitt
(University of California-Davis), Wagner Vendrame (University of
Florida), Jaime Barton (Hawaii Agricultural Research Center), Bob
Osgood (HARC), Richard Oguchi (University of Hawaii), Robert Bailis
(Yale).
\13\ Ibid.
---------------------------------------------------------------------------
Projecting where jatropha will be produced is difficult, as
evidenced by previous government projects to support the expansion of
jatropha production that did not materialize.\14\ Given the poor track
record of pronouncements about future jatropha development, we focused
our analysis on regions where we could find evidence of current
production at commercial scale. Through literature review and
conversations with researchers and industry experts, we found evidence
of significant commercial jatropha production in Mexico and Brazil. In
contrast, although large areas of Asian jatropha production were
planned and reported in global surveys, EPA was not able to verify the
existence of successful commercial scale plantations in these regions.
While there is potential for jatropha cultivation in India and Africa,
it remains uncertain whether jatropha oil grown in those locations
would be exported to the United States or whether it would qualify as
renewable biomass as defined in the CAA and implementing RFS
regulations.\15\ The scenarios we evaluated looked only at jatropha
production in Mexico and Brazil, because, as discussed in more detail
below, these are the two countries where we found reliable evidence on
jatropha production that could supply significant volumes of qualifying
biofuel feedstock under the RFS program.
---------------------------------------------------------------------------
\14\ See ``GHG Assessments of Jatropha Oil Production:
Literature Review and Synthesis'' on Docket EPA-HQ-OAR-2015-0293.
\15\ For example, recent trade data shows that in general the
U.S. receives substantially more agricultural imports from Mexico
and Brazil than from Africa and India. For example, in Fiscal Year
2014, the U.S. imported over 22.5 billion dollars of agricultural
products from Mexico and Brazil, compared to approximately 5.7
billion dollars from Africa and India. Source: USDA Economic
Research Service and Foreign Agricultural Service. 2015. Outlook for
U.S. Agricultural Trade, AES-89, August 27, 2015.
---------------------------------------------------------------------------
Mexico and Brazil offer hospitable environments for jatropha. Both
countries are part of jatropha's naturalized range, and several efforts
to commercialize jatropha have been reported there.\16\ In the GEXSI
jatropha market survey of Latin America, Mexico and Brazil were the
only countries classified as having ``strong commercial
[[Page 61410]]
activities.'' \17\ The global survey completed by Leuphana in 2012 also
identified Mexico and Brazil as the dominant jatropha producers in
Latin America with area planted of 8,000 and 3,100 hectares
respectively.\18\ These survey results are supported by other studies
in the literature and information gathered by EPA.\19\ According to the
GCEH petition, GCEH recently established a jatropha plantation in the
Yucatan Peninsula encompassing several thousand hectares, with plans
for expansion in the same region. Furthermore, the Mexican government
has supported jatropha through the ProArbol program of the National
Forestry Commission of Mexico (CONAFOR) that provides subsidies for the
promotion of jatropha as a form of reforestation.\20\ Bailis and Baka,
for their study on using jatropha oil to produce jet fuel, focused on
Brazil because its position as a major biofuel and commercial
agricultural exporter makes it a potential site for large-scale
jatropha production.\21\ As another reason for focusing on Brazil as a
growth region for jatropha, Bailis and Baka cited the major push by
EMBRAPA, the federal agricultural research and support organization, to
develop the crop. Furthermore, our literature review identified
additional studies that reported commercial scale jatropha production
in Mexico and Brazil.\22\
---------------------------------------------------------------------------
\16\ CABI Jatropha Curcas Data Sheet, https://www.cabi.org/isc/datasheet/28393
\17\ The Global Exchange for Social Investment (GEXSI). 2008.
Global Market Study on Jatropha. Final report. Available at: https://www.jatropha-alliance.org/fileadmin/documents/GEXSI_Global-Jatropha-Study_FULL-REPORT.pdf.
\18\ Wahl et al. 2012. Insights into Jatropha Projects
Worldwide. Leuphana University.
\19\ See ``GHG Assessments of Jatropha Oil Production:
Literature Review and Synthesis'' on Docket EPA-HQ-OAR-2015-0293.
\20\ Skutsch, M., E. de los Rios, S. Solis, E. Riegelhaupt, D.
Hinojosa, S. Gerfert, Y. Gao, and O. Masera. 2011. ``Jatropha in
Mexico: Environmental and Social Impacts of an Incipient Biofuel
Program.'' Ecology and Society 16(4):11. doi:10.5751/ES-04448-
160411.
\21\ Bailis, R.E. and J.E. Baka. 2010. ``Greenhouse Gas
Emissions and Land Use Change from Jatropha Curcas-Based Jet Fuel in
Brazil.'' Environmental Science & Technology 44(22):8684-8691.
doi:10.1021/es1019178.
\22\ See ``GHG Assessments of Jatropha Oil Production:
Literature Review and Synthesis'' on Docket EPA-HQ-OAR-2015-0293.
---------------------------------------------------------------------------
There have been several efforts to commercialize jatropha in other
parts of the world, including Sub-Saharan Africa, India, East Asia,
Southeast Asia, and Oceania. However, the commercial scale viability of
jatropha farms in all of these regions is currently uncertain. The
global surveys conducted by GEXSI and Leuphana reported that the vast
majority of jatropha being cultivated worldwide was being grown in
Southeast Asia, including India, China and Indonesia. The most recent
of these surveys collected data in 2011.\23\ However, after reviewing
these surveys carefully and discussing their results with experts in
industry and the USDA, we determined that practically all of the
reported jatropha plantations in Asia were aspirational and have not
resulted in commercially significant volumes of jatropha oil. EPA has
not been able to locate any information that confirms the presence of
the large scale Asian projects reported in the GEXSI and Leuphana
surveys, and there does not appear to be any official data confirming
their existence.\24\ These surveys relied on data that were self-
reported and in many cases were based on goals rather than
outcomes.\25\ A 2012 report by the USDA Foreign Agricultural Service
(FAS) confirms the very small scale of commercial jatropha oil
production in India.\26\ More recently, multiple companies working to
commercialize jatropha in parts of Asia also confirmed that, while
several large projects were planned in Southeast Asia, they have all
since been scaled back to pilot projects or abandoned for funding and
other reasons.\27\ For these reasons, our analysis of the GHG emissions
attributable to jatropha oil produced as biofuel feedstock for the RFS
program does not project jatropha oil production from Asia.
---------------------------------------------------------------------------
\23\ Wahl et al. 2012.
\24\ Letter from Cosmo Biofuels Group, ``Jatropha RFS2 Pathway
Petition Insights Into Jatropha Projects Worldwide.'' February 7,
2014
\25\ For example, a review of jatropha promotion in India is
provided in Kumar, S., Chaube, A., Jain, S., K. 2012. ``Critical
review of jatropha biodiesel promotion policies in India. Energy
Policy, 41: 775-781.
\26\ USDA-FAS. 2012. India Biofuels Annual. Global Agricultural
Information Network. GAIN Report Number: IN2081.
\27\ Letter from BEI International, LLC, ``Jatropha RFS2 Pathway
Petition Insights Into Jatropha Projects Worldwide.'' January 9,
2014.
---------------------------------------------------------------------------
Africa is another region with significant potential for jatropha
production. However, we decided not to model jatropha oil from Africa
in our analysis. First, there is uncertainty about whether African
jatropha oil production would qualify as renewable biomass, because it
is not clear that the land where it would be grown could be considered
existing agricultural land, as required in the CAA to qualify as
renewable biomass.\28\ Furthermore, according to one agricultural trade
expert, it is viewed as unlikely for economic reasons that Africa would
be a significant exporter of jatropha oil to the United States by the
year 2022, in part because it would require the development of a new
and potentially costly infrastructure to grow, process, and transport
the feedstock or fuel to the United States.\29\ For these reasons, our
analysis of the GHG emissions attributable to jatropha oil produced as
biofuel feedstock for the RFS program does not project jatropha oil
production from Africa, and we seek comment on this approach.
---------------------------------------------------------------------------
\28\ See the definition of renewable biomass at 40 CFR 80.1401.
\29\ Conversation with Bruce Babcock, January 8, 2013.
---------------------------------------------------------------------------
Although we are specifically modelling jatropha growth and
transport in Mexico and Brazil, and expect most jatropha oil used as
renewable fuel feedstock for the RFS program to be grown in those
countries, we intend to apply our analysis of the GHG emissions
attributable to jatropha oil production and transport when evaluating
facility-specific petitions that propose to use jatropha oil as biofuel
feedstock, regardless of the country of origin where their jatropha oil
feedstock is grown. In the future, some jatropha oil feedstock used to
produce biofuels for the RFS may be sourced from countries other than
Mexico and Brazil, but this would be unlikely to change our overall
assessment of the aggregate GHG impacts from growing and transporting
jatropha oil. Consistent with EPA's approach for previous RFS pathway
analyses, we will periodically reevaluate whether our assessment of GHG
impacts will need to be updated in the future based on new information
or a new methodology that has the potential to significantly change our
assessment.
C. Cultivation and Harvesting
Our assessment includes the GHG emissions attributable to growing
and harvesting jatropha seeds, including field preparation, planting,
annual inputs and harvesting, and replanting. We also estimate the
average yields, in terms of tonnes of dry jatropha seed per hectare, in
both Mexico and Brazil. The GHG emissions associated with cultivation
and harvesting are the same, per tonne of delivered jatropha oil, in
both of the main scenarios that we evaluated, as the type of land
converted is not expected to impact the emissions from these stages of
jatropha oil production. The data for our evaluation of these stages of
jatropha oil production came from the GCEH petition, as well as EPA's
literature review and our previous lifecycle GHG assessments for the
RFS program. The values and calculations in our analysis are discussed
briefly here and in more
[[Page 61411]]
detail in a technical memorandum to the docket.\30\
---------------------------------------------------------------------------
\30\ For more details see ``Jatropha Supporting Data and
Assumptions'' in Docket EPA-HQ-OAR-2015-0293.
---------------------------------------------------------------------------
Seed and Oil Yields. For the purposes of this analysis, we project
that in 2022, on average, one hectare of jatropha in southern Mexico
will yield five tonnes of dry jatropha seeds per year, while one
hectare in Brazil will yield four tonnes per hectare. For Mexico, five
tonnes per hectare reflects a middle to upper bound estimate of
recorded yields in the literature, and is also supported by information
provided in the GCEH petition for current yields. We view five tonnes
per hectare as a conservative estimate of yields in the year 2022
because intensive jatropha cultivation is relatively new, with
significant room for potential advances through genetics, breeding and
improved agronomic practices. There are fewer recorded observed yields
in northeastern Brazil; however, based on evidence from our literature
review of environmental and climate characteristics, we expect jatropha
yield in this region will be somewhat lower than yields in southern
Mexico.\31\ Given the potential for scientific breakthroughs to produce
yield improvements for jatropha, we also consider this a conservative
projection for 2022 yields in Brazil.
---------------------------------------------------------------------------
\31\ See for example Trabucco et al. 2010.
---------------------------------------------------------------------------
Based on the information discussed in Section III-E below, we
assume that after crushing, pre-treatment and transport, each tonne of
dry jatropha seeds yields 0.26 tonnes of jatropha oil delivered to a
biofuel production facility. (This figure is used to convert
cultivation and harvesting GHG emissions from kgCO2e per
hectare of jatropha production to kgCO2e per tonne of
delivered oil.)
Preparation and Planting. When jatropha is first planted, chemical
and energy inputs are required. For our analysis, we used average
inputs of nitrogen, phosphate, potassium, herbicide, and diesel use
from data in the GCEH petition, as shown in Table III-1.\32\ In Brazil,
lime is also added as a soil amendment during preparation and planting,
\33\ although it is not required in many parts of southern Mexico.\34\
While there is relatively little data available on the inputs and
energy requirements for the preparation and planting stages of
jatropha, the values provided in the GCEH petition were within the
range of other values that we found through literature review.\35\
---------------------------------------------------------------------------
\32\ Table III-1 shows the average results for a scenario with
equal amounts of jatropha output (by mass) in Mexico and Brazil.
\33\ Bailis, R. E. and J. E. Baka. 2010. Greenhouse gas
emissions and land use change from Jatropha curcas-based jet fuel in
Brazil. Environmental Science and Technology, 44(22) 8684-8691.
\34\ Lime is required in Brazil because the soils there are
highly acidic, but it is not required in southern Mexico where the
native soil pH is well-suited for jatropha.
\35\ We consider the crop input data used in our assessment to
be conservative because they result in greater estimate GHG
emissions per tonne of oil produced than most of the other data we
reviewed.
---------------------------------------------------------------------------
We assumed that jatropha has a 20 year crop cycle, meaning that
every 20 years the existing jatropha plants are removed and the crop is
replanted.\36\ Therefore, the GHG emissions associated with preparation
and planting occur every 20 years. Annualized emissions from
preparation and planting are shown in Table III-1. We estimate total
GHG emissions from jatropha preparation and planting of 66.6 kilograms
of carbon dioxide-equivalent emissions (kgCO2e) per ton of
jatropha oil that has been harvested, extracted, pre-treated to lower
acidity and delivered to a biofuel producer (``delivered jatropha
oil'').
---------------------------------------------------------------------------
\36\ For more details see ``Jatropha Supporting Data and
Assumptions'' in Docket EPA-HQ-OAR-2015-0293.
Table III-1--Annualized GHG Emissions From Preparation and Planting
[kgCO2e per tonne of delivered jatropha oil]
------------------------------------------------------------------------
GHG
Inputs per hectare emissions
------------------------------------------------------------------------
Nitrogen fertilizer................ 0.07 kg............... 0.01
Phosphorus fertilizer.............. 0.02 kg............... 0.001
Potassium fertilizer............... 0.09 kg............... 0.003
Herbicide.......................... 1.2 gal............... 1.8
Lime............................... 1.1 tonnes............ 21.3
Diesel............................. 79.3 gal.............. 43.5
------------------------------------
Total Annualized Emissions..... ...................... 66.6
------------------------------------------------------------------------
Annual Inputs and Harvesting. After the jatropha fields are
prepared and planted, there are annual GHG emissions associated with
applying crop inputs and harvesting the jatropha seeds. To estimate the
average annual emissions from these activities we assumed an average
twenty year replanting cycle, meaning that in any given year five
percent of the jatropha fields will be in the replanting stage, and
therefore have zero emissions associated with annual crop inputs and
harvesting. Table III-2 summarizes the emissions from these activities.
Annual Fertilizer and Pesticide Inputs. The GCEH petition states
that some of the husks from the jatropha fruits are used for
fertilizer. In addition, the seedcake produced after pressing oil from
the seeds can be used as an organic fertilizer. We assumed that
fertilizer inputs would have to at least make up for nutrients lost
from harvesting the jatropha fruits.\37\ Using literature values for
nitrogen, phosphorous and potassium in jatropha fruits, husks, and
seedcake,\38\ and our projected seed yield, we determined that the
jatropha husks and seedcake have nearly enough nutrients to replace the
nutrients lost from harvesting the seed fruit. We assume that growers
will apply 9.3 kilograms per hectare of additional inorganic fertilizer
to replace the lost nutrients from harvesting, which is within the
range of literature values and similar to the data provided by GCEH. We
also assumed use of small amounts of pesticide, herbicide and
insecticide based on information from the peer reviewed literature.\39\
The GHG emissions associated with fertilizer and pesticide use were
estimated using the methodology developed for the March 2010 RFS
rule.\40\ Table III-2 shows the GHG emissions from annual fertilizer
and pesticide use, not including nitrous oxide emissions that occur
after they are applied to the field (which is discussed separately,
below).
---------------------------------------------------------------------------
\37\ Bailis and Baka 2010 used the same approach to estimate
fertilizer requirements.
\38\ Bailis, R. E. and J. E. Baka. 2010. Greenhouse gas
emissions and land use change from Jatropha curcas-based jet fuel in
Brazil. Environmental Science and Technology, 44(22) 8684-8691.
\39\ Bailis, R. E. and J. E. Baka. 2010. Greenhouse gas
emissions and land use change from Jatropha curcas-based jet fuel in
Brazil. Environmental Science and Technology, 44(22) 8684-8691.
\40\ See Section 2.4.3.1 of the Regulatory Impact Analysis for
the March 2010 RFS rule.
---------------------------------------------------------------------------
Annual Energy Use. In addition to chemical inputs, energy will be
used annually for irrigation, and to power equipment used for field
maintenance and harvesting. For the annual diesel, gasoline and
electricity inputs, we used values provided in the GCEH petition, which
are within the range of values EPA found through literature review.\41\
---------------------------------------------------------------------------
\41\ Supporting Documentation for Jatropha Oil Production and
Transport GHG Emissions, Air and Radiation Docket EPA-HQ-OAR-2015-
0293.
Table III-2 GHG Emissions From Annual Inputs and Harvesting
[kgCO2e per tonne of delivered jatropha oil]
------------------------------------------------------------------------
GHG
Inputs (per ha) emissions
------------------------------------------------------------------------
Nitrogen fertilizer................ 9.3 kg................ 27.8
Phosphorus fertilizer.............. 9.3 kg................ 9.5
Potassium fertilizer............... 9.3 kg................ 6.3
Herbicide.......................... 0.5 kg................ 11.5
[[Page 61412]]
Fungicide-Bacteriocide............. 0.02 L................ 0.01
Pesticide.......................... 0.06 L................ 0.7
Diesel............................. 15.6 gal.............. 162.5
Gasoline........................... 1.6 gal............... 14.8
Electricity........................ 184 kWh............... 40.9
Total.......................... ...................... 274.0
------------------------------------------------------------------------
Annual Nitrous-Oxide Emissions. Nitrous oxide (N2O) is
emitted from nitrogen fertilizer and from parts of the jatropha plant
that are left on the field to decay or applied as fertilizer
(``jatropha residues''). The jatropha residues can be divided into
three categories: (1) Husks that are applied to the field as
fertilizer, (2) seedcake that is applied to the field as fertilizer,
and (3) above and below ground biomass from the jatropha plant (e.g.,
the trunk, branches, leaves, and roots). The above and below ground
biomass from the jatropha plant becomes a plant residue every 20 years,
when the old plants are removed and new plants are planted. For each of
these categories of jatropha residues, we used equations and factors
from the United Nations Intergovernmental Panel on Climate Change
(IPCC) to calculate direct and indirect N2O emissions, and
we annualized them by dividing by 20.\42\ Estimated annual emissions
from fertilizer and plant residues are shown in Table III-3.
---------------------------------------------------------------------------
\42\ Direct emissions are emitted from the jatropha plantation,
whereas indirect emissions occur for material that has moved to
another location (e.g., through leaching or runoff) before it
produces N2O or a pre-cursor of N2O. For crop
residues, such as above and below ground biomass, direct emissions
occur when the plant material decays.
Table III-3--N2O Emissions From Fertilizer and Jatropha Residues
[kgCO2e per tonne of delivered jatropha oil]
------------------------------------------------------------------------
GHG
emissions
------------------------------------------------------------------------
Fertilizer, direct......................................... 37.4
Fertilizer, indirect....................................... 12.2
Husks, direct.............................................. 51.5
Husks, indirect............................................ 11.6
Seedcake, direct........................................... 281.7
Seedcake, indirect......................................... 63.4
Above and below ground biomass, direct..................... 204.7
Above and below ground biomass, indirect................... 46.0
Total.................................................. 709.4
------------------------------------------------------------------------
Table III-4 provides a summary of the average GHG emissions
attributable to growing and harvesting jatropha in southern Mexico and
northeastern Brazil. Each of the emissions categories listed in the
table are explained above in this section.
Table III-4 GHG Emissions Attributable to Growing and Harvesting
Jatropha
[kgCO2e per tonne of delivered jatropha oil]
------------------------------------------------------------------------
GHG
Emissions Category emissions
------------------------------------------------------------------------
Preparation and Planting................................... 67
Annual Inputs and Harvesting............................... 274
Nitrous Oxide Emissions.................................... 709
Total.................................................. 1,050
------------------------------------------------------------------------
D. Land Use Change and Agricultural Sector Emissions
As explained in Section III-B, above, we believe that southern
Mexico and northeastern Brazil are the most likely locations for
commercial-scale production of jatropha for use in making biofuels for
the RFS program. According to the GCEH petition, there are large areas
of grasslands in southern Mexico that are suitable areas for jatropha
production. These areas were used for crop production or pasture, but
they are now fallow or used for very low intensity grazing. For
example, Skutsch et al. evaluated jatropha land use change impacts in
Yucatan, Mexico and found two plantations that had been planted on
estates that had previously been used for low-intensity grazing.\43\
There are also grasslands in northeastern Brazil that are suitable for
jatropha production, although much of this land may currently be in use
as pasture. For example, Bailis and Baka surveyed jatropha producers in
northeastern Brazil and found that the producers they approached had
primarily planted their jatropha on pasture land.\44\
---------------------------------------------------------------------------
\43\ Skutsch, M., E. de los Rios, S. Solis, E. Riegelhaupt, D.
Hinojosa, S. Gerfert, Y. Gao, and O. Masera. 2011. ``Jatropha in
Mexico: Environmental and Social Impacts of an Incipient Biofuel
Program.'' Ecology and Society 16(4):11. doi:10.5751/ES-04448-
160411.
\44\ Bailis, R.E. and J.E. Baka. 2010. ``Greenhouse Gas
Emissions and Land Use Change from Jatropha Curcas-Based Jet Fuel in
Brazil.'' Environmental Science & Technology 44(22):8684-8691.
doi:10.1021/es1019178.
---------------------------------------------------------------------------
Based on this information, the first scenario we evaluated for land
use change emissions considers jatropha production on grasslands that
would otherwise not be used for crops or pasture. In a second scenario,
we used economic modeling to look at the potential land use change and
agricultural sector emissions (including indirect emissions) of growing
jatropha on land that would otherwise be used for crops or pasture.
Jatropha on Currently Unused Grassland Scenario. Analyzing the land
use change emissions associated with growing jatropha on grassland that
is not currently being used for agricultural purposes requires
estimates of the carbon sequestered by the jatropha plantations, as
compared to the grasslands they would replace. We estimated the average
amount of biomass carbon sequestered by jatropha plantations in
southern Mexico and northeastern Brazil, projected out to 2022.
Jatropha biomass carbon stocks were estimated using available
scientific information from the literature. Reinhardt et al. measured
basic data about jatropha plants, such as root to shoot ratios and
biomass carbon content. Bailis and Baka used the data from Reinhardt et
al. to estimate biomass carbon stocks for different jatropha yield
scenarios. Using our projected jatropha yields of 5 and 4 tonnes per
hectare per year for Mexico and Brazil respectively (the basis for
these projections is discussed above), we used the Bailis and Baka
approach to estimate average biomass carbon stocks of 8.9 and 8.1
tonnes per hectare for ten year old jatropha plantations in Mexico and
Brazil, respectively. Per the methodology developed for the March 2010
RFS rule, we translated these estimates into average biomass carbon
stocks over 30 years. Assuming linear growth rates, a 20 year
replanting cycle and pruning of any growth after 10 years to ensure
fruit accessibility, we estimated average jatropha plantation biomass
carbon stocks over 30 years to be 6.9 and 6.3 tonnes per hectare for
Mexico and Brazil respectively.\45\ These values are within the range
of estimates in the literature for jatropha plantations in these
regions.\46\
---------------------------------------------------------------------------
\45\ For details on this calculation see ``Jatropha Oil
Production and Transport GHG Calculations'' spreadsheet on Docket
EPA-HQ-OAR-2015-0293.
\46\ For a comparison with other values in the literature see
Supporting Documentation for Jatropha Oil Production and Transport
GHG Emissions, Air and Radiation Docket EPA-HQ-OAR-2015-0293.
---------------------------------------------------------------------------
For comparison, based on our analysis for the March 2010 RFS rule
we estimate that grasslands in Mexico and Brazil contain approximately
4.1 and 10.9 tonnes of carbon per hectare, respectively. For our first
scenario, we looked at the land use change and agricultural sector
emissions associated with growing jatropha on grassland in Mexico and
Brazil that would not otherwise be used for crop production or pasture.
Comparing the carbon stocks
[[Page 61413]]
of jatropha and the grassland it replaces, we estimate that growing
jatropha on grassland in Mexico results in a net carbon sequestration,
or negative emissions, because the jatropha plantation sequesters more
carbon on average over thirty years. Conversely, planting jatropha on
grassland in Brazil results in a net carbon emission. Specifically, for
jatropha grown on otherwise unused grasslands in Mexico and Brazil we
estimate land use change emissions of negative 268 and positive 550
kgCO2e per tonne of delivered jatropha oil, respectively.
Looking at a scenario in which we assume an equal amount of growth of
jatropha from unused grasslands in Mexico and Brazil results in land
use change emissions of 141 kgCO2e per tonne of delivered
jatropha oil. (For comparison, for the March 2010 RFS rule we estimated
land use change emissions of 1,158 kgCO2e per tonne of
soybean oil used for biofuel.) In this scenario there are no indirect
agricultural sector emissions, such as from indirect impacts on crop or
livestock production, because jatropha is not an agricultural
commodity, and the displaced land would not otherwise have been used
for commodity production.
Jatropha on Agricultural Land Scenario. In the second scenario we
evaluated, we assumed jatropha would be grown on land that would
otherwise be used to grow crops or for pasture. In this case jatropha
production would impact market prices for the crops and livestock it
displaces, leading to other indirect effects. For example, one of the
likely indirect impacts would be to increase crop and livestock
production in other locations to make up for the production displaced
by jatropha. As we have done for the other RFS analyses, we estimated
the size of these impacts with an agricultural sector model.
For our agricultural sector modeling of jatropha oil, we used a
similar approach to the one we used for sugarcane in the March 2010 RFS
rule, in which agricultural sector modeling was conducted using only
the FAPRI-CARD model, and not the Forestry and Agricultural Sector
Optimization Model (FASOM). For other feedstocks (e.g., corn, soybeans,
grain sorghum), we used FASOM to model domestic forestry and
agricultural impacts in addition to using the FAPRI-CARD model for
international impacts. Similar to sugarcane, for jatropha we only used
the FAPRI-CARD model because we do not expect jatropha to be grown in
the United States as a biofuel feedstock for the RFS program.
To date, jatropha has not achieved a significant presence in global
agricultural markets. For example, EPA is not aware that it is traded
on any agricultural exchange, and there does not appear to be any
publicly available data on jatropha prices or trade flows. These
limitations create significant difficulties when attempting to model
jatropha in an agro-economic framework, such as the FAPRI-CARD model.
The creation of robust assumptions for production costs at various
levels of production (i.e., production cost curves), as well as
estimates for supply and demand at various prices (i.e., supply curves
and demand curves), depends upon these types of historical data. We
considered building production cost curves for jatropha oil based on
land, crop yield, and crop input data. However, for jatropha,
production cost data are limited to a very small number of companies
and regions, making it difficult to estimate or project how much
jatropha oil could be produced at various production cost levels. We
also have limited information to determine the price that jatropha
might command on the open market, or the extent to which it might be
competitive with other planted crops for acreage. Without this
information, it is not possible to form supply and demand curves for
jatropha in the FAPRI-CARD model, which the model typically uses for
other crops that we have evaluated to project where and in what
quantities jatropha will be grown. Because of these limitations, EPA
applied a slightly modified methodology in this analysis.
For other crops that EPA has evaluated for the RFS program, we have
used the FAPRI-CARD model to project international agricultural sector
impacts by running different biofuel volume scenarios and allowing the
model to decide where to grow the additional crops needed to produce
the biofuel volumes. Because of the data limitations regarding
jatropha, the FAPRI-CARD model is not able to decide where to grow
jatropha or what other types of land uses to displace for its
production. Therefore, to model the agricultural sector impacts of
expanding jatropha production, we exogenously specified how much and
what types of land it would displace in Mexico and Brazil. The FAPRI-
CARD model then estimated how the crops and pasture displaced by
jatropha would be made up elsewhere via crop switching, land conversion
and other market-mediated effects.
First, similar to our modeling for other feedstocks, we used
available information to project the amount of jatropha oil produced as
biofuel feedstock for the RFS program in the year 2022. We developed
two analyses for the production of 130 million gallons of biodiesel in
2022, one where all of the jatropha oil is produced in Mexico (the
``Mexico only case'') and one where the jatropha oil production is
split evenly between Mexico and Brazil (the ``Mexico and Brazil
case''). Although there is limited historical data available to use as
the basis for formulating jatropha oil volume scenarios for modeling,
we believe that a total production level of 130 million gallons of
biodiesel in 2022 is sufficiently large to produce robust estimates of
agricultural and GHG impacts in the FAPRI-CARD model, while still being
feasible. As described elsewhere in this notice, we conservatively
project that in 2022 Mexico and Brazil will have delivered jatropha oil
yields of 1.3 and 1.0 tonnes per hectare per year, respectively.\47\
Based on these oil yields, in the Mexico only case the production of
enough jatropha oil feedstock to produce 130 million gallons of
biodiesel would require approximately 350 thousand hectares of jatropha
production in Mexico. In the Mexico and Brazil case, we modeled
approximately 172 thousand hectares of jatropha in Mexico and 216
thousand hectares in Brazil.\48\ The results of our modeling are based
on a comparison of this jatropha production case to a control case that
included no jatropha oil production.
---------------------------------------------------------------------------
\47\ Based on projected average 2022 dry seed yields in Mexico
and Brazil of five and four tonnes per hectare, respectively. We
also assume that dry seeds have 35% oil content, 75% oil extraction
efficiency and a 1.4 percent loss from oil pre-treatment.
\48\ Given the yields for Mexico and Brazil described above,
these cultivation areas correspond with 65 million gallons of
jatropha oil biodiesel each from Mexican and Brazilian jatropha oil
production, for a total of 130 million gallons. The specific
underlying assumptions and calculations that produced these figures
are available in the docket for this notice at EPA-HQ-OAR-2015-0293.
---------------------------------------------------------------------------
To model the agricultural sector impacts of jatropha production in
Mexico, we specified in the FAPRI-CARD model the area and types of crop
land that jatropha would displace. Based on the information provided in
the GCEH petition and collected through EPA's literature review,
jatropha production in southern Mexico will most likely occur in the
states of Yucatan, Chiapas and Oaxaca because they offer the most
suitable climate conditions and available land. Over 80 percent of the
agricultural land in this area is used for corn production, with
smaller areas devoted to specialty crops such as fruits, vegetables,
herbs and spices.\49\ We do not expect jatropha to
[[Page 61414]]
displace the higher value specialty crops, so we focused our analysis
on the land used for commodity crops: corn, grain sorghum, soybeans and
wheat. We then specified in the FAPRI-CARD model that jatropha will
displace these staple crops based on their current share of land used
for commodity crops: 96 percent corn, two percent grain sorghum, and
one percent each of soybeans and wheat.
---------------------------------------------------------------------------
\49\ Mexico Information Service for Agribusiness and Fisheries
(SIAP), https://www.siap.gob.mx/
---------------------------------------------------------------------------
For Brazil we used a slightly different approach to take advantage
of the fact that the FAPRI-CARD model for Brazil is significantly more
detailed than the Mexico module. As explained above, based on EPA's
literature review we determined that jatropha production in Brazil
would predominantly occur in the northeastern part of the country,
which correlates with the Northeast Coast and North-Northeast Cerrados
regions in the FAPRI-CARD Brazil module. Unlike the Mexico part of the
FAPRI-CARD model, the Brazil module includes crop and pasture land, and
allows for switching between the two. Instead of specifying how much of
each type of crop and pasture to displace with jatropha, we specified
the area needed for jatropha production and allowed the FAPRI-CARD
model to project the land used for jatropha production.
Table III-5 summarizes the land use changes projected in our
modeling. We evaluated two cases: one involving jatropha production
only in Mexico, and the other involving production in both Brazil and
Mexico. In both cases, the land use impacts in Mexico are the
replacement of other crops (primarily corn) with jatropha. In the
Brazil and Mexico case, jatropha is planted on roughly three-quarters
pasture and one-quarter crop land in Brazil. In both cases, the rest of
the world (outside of Mexico and Brazil) increases its crop area.
However, globally the total area devoted to non-jatropha crops and
pasture decreases. Overall, the rest of the world expands their
agricultural land (the sum of crop and pasture land including
jatropha), meaning that other types of land, including unmanaged
grassland and forest, are converted for agricultural uses.
Table III-5--Projected Land Use Changes by Case in 2022
[Thousand hectares] \50\
----------------------------------------------------------------------------------------------------------------
Crop Land
------------------------------------------------- Pasture
Jatropha Other Crops All Crops
----------------------------------------------------------------------------------------------------------------
Mexico Only Case
----------------------------------------------------------------------------------------------------------------
Mexico........................................ 345 (345) 0 0
Brazil........................................ 0 9 9 (5)
Rest of World................................. 0 114 114 (63)
-----------------------------------------------------------------
Total..................................... 345 (222) 123 (68)
----------------------------------------------------------------------------------------------------------------
Brazil and Mexico Case
----------------------------------------------------------------------------------------------------------------
Mexico........................................ 172 (172) 0 0
Brazil........................................ 216 (62) 154 (154)
Rest of World................................. 0 81 81 (49)
-----------------------------------------------------------------
Total..................................... 388 (153) 235 (203)
----------------------------------------------------------------------------------------------------------------
Table III-6 summarizes the projected changes in the production of
corn, soybeans and sugarcane, the crops with the largest changes in the
cases we simulated. In both cases, there is a reduction in the total
area of corn but an increase in the amount of corn produced. This is
the result of corn production shifting to regions with higher yields,
particularly the United States. In both cases, there is a reduction in
the area and production of soybeans and sugarcane. All of these changes
are less than 0.1% of projected crop production in 2022.
---------------------------------------------------------------------------
\50\ For the tables in this Notice, the numbers in parentheses
are negative and the totals may not sum due to rounding.
Table III-6--Projected Crop Production Changes by Case in 2022
[Thousand metric tonnes]
----------------------------------------------------------------------------------------------------------------
Corn Soybeans Sugarcane
----------------------------------------------------------------------------------------------------------------
Mexico Only Case
----------------------------------------------------------------------------------------------------------------
Mexico....................................................... (1,151) (9) 0
Brazil....................................................... 292 103 (51)
United States................................................ 738 (97) 5
China........................................................ 115 (1) (7)
Rest of World................................................ 185 (8) (4)
--------------------------------------------------
Total.................................................... 178 (12) (58)
----------------------------------------------------------------------------------------------------------------
Mexico and Brazil Case
----------------------------------------------------------------------------------------------------------------
Mexico....................................................... (578) (4) 0
Brazil....................................................... 110 22 (300)
United States................................................ 375 (37) 2
[[Page 61415]]
China........................................................ 62 1 (2)
Rest of World................................................ 101 1 54
--------------------------------------------------
Total.................................................... 70 (18) (246)
----------------------------------------------------------------------------------------------------------------
Table III-7 summarizes the projected impacts on global meat
production. In both of the cases, meat production declines. These
changes are on the order of approximately 0.01%, or less, of projected
global livestock production in 2022.
Table III-7--Changes in Global Meat Production by Case in 2022
[thousand metric tonnes]
------------------------------------------------------------------------
Mexico Brazil and
only case Mexico Case
------------------------------------------------------------------------
Beef.......................................... (0.4) (4.1)
Pork.......................................... (9.4) (5.7)
Poultry....................................... (10.0) (5.8)
------------------------------------------------------------------------
Overall, the projected agricultural sector impacts in 2022 of
growing jatropha on agricultural land in Mexico and Brazil in the two
cases we evaluated can be summarized as a reduction in crop and pasture
land in Mexico and Brazil which triggers an increase in crop area in
other countries. Just over half of the increase in crop area in other
countries comes at the expense of pasture land, with the rest coming
from other types of land, including unmanaged grassland and forest.
Globally, corn production increases, while soybean, sugarcane and meat
production declines. Detailed modeling results and further explanation
are provided in the docket for this notice,\51\ and we welcome comments
on all aspects of our analysis.
---------------------------------------------------------------------------
\51\ Supporting Documentation for Jatropha Oil Production and
Transport GHG Emissions, Air and Radiation Docket EPA-HQ-OAR-2015-
0293.
---------------------------------------------------------------------------
To estimate the GHG emissions associated with the land use changes
summarized in Table III-5, EPA used the same methodology as developed
for the March 2010 RFS rule. Per this methodology, the crop and pasture
area changes in 2022 derived from the FAPRI-CARD model were evaluated
with Moderate Resolution Imaging Spectroradiometer (MODIS) satellite
data to project what types of land (e.g., grassland, savanna, forest)
would be converted to agricultural land (crops and pasture) in regions
where the FAPRI-CARD model projected agricultural expansion. For these
projections we used the satellite data to determine what types of land
have been converted to crops and pasture in each region, and then
applied those land use change patterns to the agricultural changes
projected by the FAPRI-CARD modeling. Land use change GHG emissions
were then estimated over 30 years using emission factors derived from
various data sources accounting for average carbon stocks on eight
types of land in 755 distinct regions.\52\
---------------------------------------------------------------------------
\52\ See Section 2.4 of the Regulatory Impact Analysis for the
March 2010 RFS rule, https://www.epa.gov/otaq/renewablefuels/420r10006.pdf.
---------------------------------------------------------------------------
The land use change GHG emissions are summarized in Table III-8,
including results for both the Mexico only and Mexico and Brazil cases.
The results are broken out regionally by Mexico, Brazil, and Rest of
World, because as discussed above, the great majority of land use
change impacts came from Mexico and Brazil. Table III-8 also includes
the total emissions for the low and high ends of the 95% confidence
range for land use change GHG emissions, based on the land use change
uncertainty analysis methodology developed for the March 2010 RFS rule,
which considers the uncertainty in the satellite data and land use
change emissions factors used in our assessment.
Table III-8--Land Use Change GHG Emissions by Case in 2022
[kgCO2e per tonne delivered jatropha oil]
------------------------------------------------------------------------
Mexico Brazil and
Only case Mexico Case
------------------------------------------------------------------------
Mexico...................................... (2,795) (1,397)
Brazil...................................... 843 636
Rest of World............................... 569 356
Total (Mean)................................ (1,383) (406)
Total (Low)................................. (3,725) (1,827)
Total (High)................................ 612 809
------------------------------------------------------------------------
In both cases, the mean values suggest negative land use change
emissions (net sequestration) associated with growing jatropha on
agricultural land. This is due primarily to the net sequestration that
we project from replacing corn fields with jatropha plantations in
Mexico. Per our analysis for the March 2010 RFS rule, corn in Mexico
has average biomass carbon stocks of five tonnes per hectare.\53\ In
our assessment average jatropha plantation biomass carbon stocks are
6.9 tonnes per hectare, so every hectare of corn replaced by jatropha
increases biomass carbon by 1.9 tonnes (including both above- and
below-ground biomass). Additionally, converting corn to jatropha
results in additional soil carbon sequestration. Due to the reduced
tillage and increased biomass returned to the soil for jatropha (tree
litter and prunings) compared to corn, we estimate that after 20 years
jatropha would add approximately 27.7 tonnes of soil carbon per hectare
compared to corn production in Mexico.\54\ Therefore, annualized over
thirty years we estimate that replacing corn with jatropha in Mexico
would result in additional soil sequestration of approximately 1.0
tonnes of carbon per hectare.
---------------------------------------------------------------------------
\53\ See Section 2.4 of the Regulatory Impact Analysis for the
March 2010 RFS rule, https://www.epa.gov/otaq/renewablefuels/420r10006.pdf.
\54\ Based on the methodology developed for the March 2010 RFS
rule, the soil carbon stocks reach equilibrium after 20 years.
---------------------------------------------------------------------------
In both cases, we project positive land use change emissions in
Brazil and other countries. We project land use change emissions in
Brazil for a number of reasons. In the Mexico only case, Brazil expands
its crop production to backfill for some of the lost production in
Mexico. Some of this crop expansion occurs on pasture, which results in
net land use change emissions from both biomass and soil carbon, and
some of the crop expansion occurs on other types of land, including
forests. In particular, the FAPRI-CARD model projects crop and pasture
expansion in the Amazon, an area with particularly high carbon stocks,
resulting in large emissions per hectare of conversion. In the Brazil
and Mexico case, the expansion of jatropha onto corn or soybean land
results in a net sequestration, but this net sequestration is smaller
than the emissions associated with replacing sugarcane and pasture with
jatropha.
[[Page 61416]]
In both cases, we also project land use change emissions from the
rest of the world (all regions other than Mexico and Brazil). In our
modeling the main impact in other countries is increased crop
production to respond to higher prices and to backfill for some of the
lost production from Mexico and Brazil. The additional cropland
replaces some pasture and some other types of land, including unmanaged
grasslands and forests, which results in net land use change emissions.
For this second scenario, our analysis also considers indirect
emissions associated with changes in fertilizer, pesticide and energy
use for crop production, and methane and nitrous oxide emissions
associated with changes in crop production. The sources of indirect
livestock emissions include emissions from energy use for livestock
production, and methane and nitrous oxide emissions associated with
raising cattle, dairy cows, swine and poultry. The emissions for
indirect crop production were estimated based on international crop
input data and emission factors developed and peer reviewed for the
March 2010 RFS rule. The livestock emissions factors are from the IPCC.
In the first main scenario we evaluated, where jatropha production
occurs on grassland that is not otherwise used for crop production or
grazing, there are no indirect emissions associated with changes in
fertilizer, pesticide and energy use for crop production, and methane
and nitrous oxide emissions associated with changes in crop production.
In the second scenario, where jatropha is grown on agricultural land,
there are indirect emissions associated with how the agricultural
sector responds to the displacement of crop and grazing land for
jatropha. Table III-9 summarizes the indirect crop production and
livestock emissions impacts for both of the cases we evaluated for
scenario two. Indirect agricultural emissions are negative in both
cases, primarily because of emission reductions from decreased corn
production in Mexico. Indirect livestock emissions are negative,
because as shown in Table III-7, we project reductions in meat
production in the cases evaluated.
Table III-9--Indirect Crop Production and Livestock Emissions by Case in
2022
[kgCO2e per tonne delivered jatropha oil]
------------------------------------------------------------------------
Mexico Mexico and
only case Brazil case
------------------------------------------------------------------------
Indirect Crop Production...................... (431) (338)
Indirect Livestock............................ (125) (392)
------------------------------------------------------------------------
Table III-10 summarizes the land use change, and agricultural
sector emissions in the two main scenarios that we evaluated. Note that
this table does not include the emissions associated with cultivation
and harvesting discussed above in Section III-C.
Table III-10--Land Use Change and Indirect Agricultural Sector Emissions by Scenario in 2022
[kgCO2e per tonne delivered jatropha oil]
----------------------------------------------------------------------------------------------------------------
Scenario Jatropha produced Jatropha produced on agricultural
------------------------------------------------------- on unused land
grassland in ------------------------------------
Case Mexico in Brazil Mexico only Mexico and Brazil
----------------------------------------------------------------------------------------------------------------
Land Use Change....................................... 141 (1,383) (406)
Indirect Crop Production.............................. ................... (431) (338)
Indirect Livestock.................................... ................... (125) (392)
---------------------------------------------------------
Total............................................. 141 (1,940) (1,136)
----------------------------------------------------------------------------------------------------------------
E. Feedstock Transport and Processing
Producing fuels from jatropha requires oil to be first extracted
from its seeds, and then refined into a finished fuel product. Oil can
either be expelled from the seeds by mechanical treatment or extracted
using chemical solvents. There are two commonly used types of
mechanical expellers, the screw press and the ram press. The screw
press is typically used, and is somewhat more efficient at expelling
oil (75-80% yield) than the ram press (60-65% yield). Up to three
passes is common to achieve these yields. Certain pretreatments of
jatropha seeds, such as cooking, can increase the expelled oil yield to
89% after a single pass using a screw press and 91% after a second
pass. Chemical extraction can achieve greater oil yields than
mechanical expulsion. (The most commonly used chemical extraction
method, the n-hexane method, can achieve yields of 99%). However,
chemical extraction is capital intensive and only economical at very
large scales of production. According to Bailis and Baka, all jatropha
oil produced in Brazil is extracted by screw press at one facility.
Based on our review of available literature, EPA's evaluation
considered oil recovery from jatropha seeds to occur via screw press
mechanical expulsion assuming oil yield of 75% and seed oil content of
35%.\55\ Based on reported electricity and fuel demands for jatropha
oil extraction, we estimate that oil extraction results in emissions of
175 kgCO2e per ton of delivered jatropha oil.\56\
---------------------------------------------------------------------------
\55\ See ``GHG Assessments of Jatropha Oil Production:
Literature Review and Synthesis'' on Docket EPA-HQ-OAR-2015-0293.
\56\ For details on this calculation see the ``Jatropha
Lifecycle GHG Calculations'' spreadsheet on Docket EPA-HQ-OAR-2015-
0293.
---------------------------------------------------------------------------
Our evaluation also considers emissions associated with pretreating
the jatropha oil.\57\ Based on data provided in the GCEH petition, we
evaluated the emissions from jatropha oil pretreatment with chemicals
(typically sodium hydroxide) to lower its acid content, and electricity
used to heat the reaction.\58\ The outputs from the pre-treatment
process are pre-treated jatropha oil, soapstock and filter cake. The
pre-treated jatropha oil is ready for transport and use as a biodiesel
feedstock. The soapstock and filter cake are low value byproducts, and
as a conservative approach we model them as resulting in no GHG
emissions impacts, i.e., we do not give a displacement credit for these
byproducts. We estimate the GHG
[[Page 61417]]
emissions from pre-treatment are approximately 4.7 kgCO2e
per ton of delivered jatropha oil. Pretreatment may occur at the oil
extraction facility or the biofuel production facility, so it may be
appropriate for EPA to revise the pre-treatment emissions on a case-by-
case basis when evaluating petitions from specific biofuel production
facilities.
---------------------------------------------------------------------------
\57\ Other vegetable oils that EPA has approved as feedstocks,
including soybean oil, commonly undergo similar pre-treatment before
they are converted to biofuels. The oil recovered after pretreatment
is still chemically jatropha oil.
\58\ The pre-treatment data provided in the GCEH petition is
within the range of values EPA found in the literature.
---------------------------------------------------------------------------
For our GHG analysis, we assumed that jatropha is produced, and the
jatropha oil is extracted and pre-treated in Mexico and Brazil, and
that the pre-treated oil is then transported to the United States for
use as biofuel feedstock. First, we calculate the emissions associated
with transporting the jatropha seed 20 miles by truck to a facility
where the crude jatropha is extracted via screw press and then pre-
treated. The truck is loaded with kernel shells and seedcake and
returns 20 miles to the plantation. The pre-treated jatropha oil is
transported 75 miles by truck to a port and then shipped 500 miles by
barge to a port in the U.S. Gulf of Mexico. For this scenario we
estimate the seed transport emissions to be 24 kgCO2e/mmBtu
and the oil transport emissions to be 10 kgCO2e/mmBtu. For
our analysis, the distances and modes for seed and oil transport are
based on data provided in the GCEH petition for jatropha production in
Yucatan, Mexico. We believe these values are also reasonable to apply
for jatropha production in other regions, including Brazil. This
jatropha oil transport scenario was developed based on the best
currently-available information, but may need to be adjusted when EPA
evaluates individual petitions if the petitioner's jatropha oil
feedstocks are delivered via a significantly different route than the
one EPA modeled.
F. Potential Invasiveness
Jatropha is not currently widespread in the United States, and is
not listed on the federal noxious weed list.\59\ A recent weed risk
assessment by USDA found that jatropha has a moderate risk of
invasiveness in the United States.\60\ Its seeds are toxic to animals
and humans, and it is considered a weed in anthropogenic production and
natural systems. Jatropha is a perennial plant, meaning that if a grove
is abandoned, seeds would still be produced. In addition, jatropha can
regrow from its roots. For these reasons, and in consultation with
USDA, the use of jatropha as a biofuel feedstock raises concerns about
its threat of invasiveness and whether its production could require
remediation activities that would be associated with additional GHG
emissions. Therefore, similar to EPA's actions with respect to other
biofuel feedstocks found to present invasiveness risks, such as Arundo
donax and Pennisetum purpureum, EPA anticipates that any petition
approvals for renewable fuel pathways involving the use of jatropha oil
as feedstock will include requirements related to mitigating risks
associated with invasiveness. However, based on our consultations with
USDA, EPA does not believe that the requirements for jatropha are
likely to be as stringent as those for Arundo donax and Pennisetum
purpureum, because, in the judgment of USDA, the risk of invasiveness
for jatropha is likely to be smaller than for these two other
feedstocks.\61\ A fuel producer may alternatively demonstrate that
there is not a significant likelihood of spread beyond the planted
area, or that the species will be grown and processed in its native
range where no or little risk of impact is expected if it spreads from
planting sites. As outlined in the rule published on July 11, 2013 (78
FR 41702) for Arundo donax and Pennisetum purpureum, the fuel producer
would need a letter from USDA that concludes that jatropha does not
pose a spread of risk beyond the planted area. With these requirements
in place, we would assume that there are no GHG emissions associated
with potential invasiveness when jatropha oil is used as a biofuel
feedstock. EPA is taking comment on the invasiveness concerns of
jatropha and the appropriateness of the referenced requirements in
mitigating those concerns.
---------------------------------------------------------------------------
\59\ USDA (2014). ``Federal Noxious Weed List.'' Available at:
https://www.aphis.usda.gov/plant_health/plant_pest_info/weeds/downloads/weedlist.pdf.
\60\ USDA Animal and Plant Health Inspection Service (2015).
``Weed risk assessment for Jatropha curcas L. (Euphorbiaceae)--
Physic nut.'' The weed risk assessment classifies jatropha as
``evaluate further,'' which means it poses a moderate risk of
invasiveness.
\61\ For details on the requirements imposed on Arundo donax and
Pennisetum purpureum, see the rule published on July 11, 2013 (78 FR
41702), https://www.gpo.gov/fdsys/pkg/FR-2013-07-11/pdf/2013-16488.pdf.
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G. Summary of GHG Emissions From Jatropha Oil Production and Transport
The results of our analysis of the GHG emissions associated with
jatropha oil production and transport are summarized in Table III-11.
The table summarizes the results for the two main scenarios that we
evaluated: the first scenario where jatropha is grown on unused
grassland in Mexico and Brazil and a second scenario where it is grown
on agricultural land. For the second scenario, results are summarized
for two cases: the first with jatropha production on agricultural land
in Mexico, and the second with jatropha production on agricultural land
in Mexico and Brazil. For comparison, Table III-11 also includes a
summary of soybean oil production and transport GHG emissions as
estimated for the March 2010 RFS rule. (Some emissions categories for
the soybean results have been combined to align as much as possible
with the jatropha results.) The results summarized in Table III-11 show
that based on the scenarios we evaluated, the GHG emissions associated
with producing and transporting jatropha oil as a biofuel feedstock are
less than similar emissions for soybean oil. When evaluating petitions
to use jatropha oil as biofuel feedstock we would also consider GHG
emissions from fuel production and fuel distribution, in addition to
the emissions summarized in Table III-11 (adjusted as appropriate for
petitioners' individual circumstances).
The agency also conducted an uncertainty analysis and estimated the
95 percent confidence range for each of the scenarios evaluated. For
this evaluation, we used the same methodology and spreadsheet model
used for the March 2010 RFS rule. For the unused grassland scenarios we
considered the uncertainty in the emissions factors used in our
analysis. For the agricultural land scenarios, we considered the
uncertainty in both the range of potential values for the satellite
data and land use change emissions factors used in our modeling. The
low and high ends of the 95 percent confidence range are presented
below in Table III-11, with results from the jatropha scenarios
displayed along with the results from our soybean oil modeling for the
March 2010 RFS rule. The range is narrowest for the unused grassland-
only scenario because it does not incur uncertainty associated with
using satellite data to project land use change patterns. Comparing the
uncertainty estimates for the scenario with jatropha oil produced on
agricultural land and the estimates for the soybean oil results, the
confidence range is narrower for the soybean results because a greater
proportion of the land use change impacts for soybeans are in regions
and impact types of land where EPA has better quality data. We invite
comment on our analysis and the results presented below.
[[Page 61418]]
Table III-11--Production and Transport GHG Emissions for Jatropha Oil
[kgCO[ihel2]e per tonne of delivered oil] \62\
----------------------------------------------------------------------------------------------------------------
Jatropha oil
------------------------------------------------------------
Emissions category Produced on Unused Produced on agricultural land Soybean oil
grassland in Mexico ---------------------------------------
and Brazil Mexico Only Mexico and Brazil
----------------------------------------------------------------------------------------------------------------
Land Use Change.................... 141 (1,383) (406) 1,158
Preparation and Planting........... 67 40 67 (3)
Annual Cultivation................. 983 964 983
Indirect Crop Production........... ................... (431) (338)
Indirect Livestock................. ................... (125) (392) (291)
Oil Extraction..................... 175 175 175 470
Oil Pre-Treatment.................. 5 5 5
Seed Transport..................... 24 24 24 91
Oil Transport...................... 10 10 10
Total.......................... 1,404 (721) 128 1,425
Low................................ 1,217 (3,063) (1,293) 470
High............................... 1,590 1,273 1,342 2,580
----------------------------------------------------------------------------------------------------------------
Based on the results summarized in Table III-11, we believe it is
reasonable, as a conservative approach (and subject to confirmation
upon review of individual petition submissions), to apply the GHG
emissions estimates we established in the March 2010 rule for the
production and transport of soybean oil to jatropha oil when evaluating
future facility-specific petitions from biofuel producers seeking to
generate RINs for volumes of biofuel produced from jatropha oil. While
it is possible that jatropha could be grown on other types of land,
such as shrubland or secondary forest, that would result in higher GHG
emissions than the scenarios we evaluated, the RFS program's
qualification requirements for renewable biomass would prevent the use
of jatropha grown on such lands from use as an RFS renewable fuel
feedstock. The renewable biomass definition would not prevent a
scenario where jatropha is planted on agricultural land, and the
displaced crops or pasturage is then shifted to shrubland or
forestland. However, as discussed above, our modeling suggests that
this scenario is not expected. Therefore, we believe it is reasonable
to conclude that the overall emissions attributable to the production
and transportation of jatropha oil used to produce biofuels for the RFS
program will be equal to or less than the same types of emissions
attributable to soybean oil. We welcome public comments on all aspects
of our assessment.
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\62\ Totals may not sum due to rounding. The ``Total'' results
represents our mean estimates, and the ``Low'' and ``High'' results
represent the low and high ends of the 95 percent confidence range.
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H. Fuel Production and Distribution
Jatropha oil is suitable for the same conversion processes as
soybean oil and other previously approved feedstocks for making
biodiesel, renewable diesel, jet fuel, naphtha and liquefied petroleum
gas. In addition, the fuel yield per pound of oil is expected to be
similar for fuel produced from jatropha oil and soybean oil through
these processes. Jatropha may also be suitable for other conversion
processes and types of fuel that EPA has not previously evaluated.
After reviewing comments received in response to this action, we will
combine our evaluation of agricultural sector GHG emissions associated
with the use of jatropha oil feedstock with our evaluation of the GHG
emissions associated with individual producers' production processes
and finished fuels to determine whether any proposed pathway satisfies
CAA lifecycle GHG emissions reduction requirements for RFS-qualifying
renewable fuels. Each biofuel producer seeking to generate RINs for
non-grandfathered volumes of biofuel produced from jatropha oil will
first need to submit a petition requesting EPA's evaluation of their
new renewable fuel pathway pursuant to 40 CFR 80.1416 of the RFS
regulations, and include all of the information specified at 40 CFR
80.1416(b)(1). Because EPA is evaluating the greenhouse gas emissions
associated with the production and transport of jatropha oil feedstock
through this action and comment process, petitions requesting EPA's
evaluation of biofuel pathways involving jatropha oil feedstock will
not have to include the information for new feedstocks specified at 40
CFR 80.1416(b)(2).\63\ Based on our evaluation of the lifecycle GHG
emissions attributable to the production and transport of jatropha oil
feedstock, EPA anticipates that fuel produced from jatropha oil
feedstock through the same transesterification or hydrotreating process
technologies that EPA evaluated for the March 2010 RFS rule for biofuel
derived from soybean oil and the March 2013 RFS rule for biofuel
derived from camelina oil would qualify for biomass-based diesel (D-
code 4) RINs or advanced biofuel (D-code 5) RINs.\64\ However, EPA will
evaluate petitions for fuel produced from jatropha oil feedstock on a
case-by-case basis.
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\63\ For information on how to submit a petition for biofuel
produced from jatropha oil see EPA's Web page titled ``How to Submit
a Complete Petition'' (https://www.epa.gov/otaq/fuels/renewablefuels/new-pathways/how-to-submit.htm) including the document on that Web
page titled ``How to Prepare a Complete Petition.'' Petitions for
biofuel produced from jatropha oil should include all of the
applicable information outlined in Section 3 of the ``How to Prepare
a Complete Petition'' document, but they do not need to provide the
information outlined in section 3(F)(2) (Information for New
Feedstocks).
\64\ The transesterification process that EPA evaluated for the
March 2010 RFS rule for biofuel derived from soybean oil feedstock
is described in section 2.4.7.3 (Biodiesel) of the Regulatory Impact
Analysis for the March 2010 RFS rule (EPA-420-R-10-006). The
hydrotreating process that EPA evaluated for the March 2013 rule for
biofuel derived from camelina oil feedstock is described in section
II.A.3.b of the March 2013 rule (78 FR 14190).
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IV. Summary
EPA invites public comment on its analysis of GHG emissions
associated with the production and transport of jatropha oil as a
feedstock for biofuel production. EPA will consider public comments
received when evaluating the lifecycle GHG emissions of biofuel
production pathways described in
[[Page 61419]]
petitions received pursuant to 40 CFR 80.1416 that use jatropha oil as
a feedstock.
Dated: September 30, 2015.
Christopher Grundler,
Director, Office of Transportation and Air Quality, Office of Air and
Radiation.
[FR Doc. 2015-26039 Filed 10-9-15; 8:45 am]
BILLING CODE 6560-50-P
