Notice of Opportunity To Comment on an Analysis of the Greenhouse Gas Emissions Attributable to Production and Transport of Beta vulgaris ssp. vulgaris (Sugar Beets) for Use in Biofuel Production, 34656-34663 [2017-15721]
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[EPA–HQ–OAR–2016–0771; FRL–9958–88–
OAR]
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Notice of Opportunity To Comment on
an Analysis of the Greenhouse Gas
Emissions Attributable to Production
and Transport of Beta vulgaris ssp.
vulgaris (Sugar Beets) for Use in
Biofuel Production
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
In this notice, the
Environmental Protection Agency (EPA)
is inviting comment on its analysis of
the upstream greenhouse gas emissions
SUMMARY:
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attributable to the production of Beta
vulgaris ssp. vulgaris (sugar beets) for
use as a biofuel feedstock. This notice
describes EPA’s greenhouse gas analysis
of sugar beets produced for use as a
biofuel feedstock, and describes how
EPA may apply this analysis in the
future to determine whether biofuels
produced from sugar beets meet the
necessary greenhouse gas reduction
threshold required for qualification as
renewable fuel under the Renewable
Fuel Standard program. This notice
considers a scenario in which noncellulosic beet sugar is extracted for
conversion to biofuel and the remaining
beet pulp co-product is used as animal
feed. Based on this analysis, we
anticipate that biofuels produced from
sugar beets could qualify as renewable
fuel or advanced biofuel, depending on
the type and efficiency of the fuel
production process technology used.
DATES: Comments must be received on
or before August 25, 2017.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2016–0771, at https://
www.regulations.gov. Follow the online
instructions for submitting comments.
Once submitted, comments cannot be
edited or withdrawn from
Regulations.gov. 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://www.epa.gov/dockets/
commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT:
Christopher Ramig, Office of Air and
Radiation, Office of Transportation and
Air Quality, Mail Code: 6401A, U.S.
Environmental Protection Agency, 1200
Pennsylvania Avenue NW., Washington,
DC 20460; telephone number: 202–564–
1372; fax number: 202–564–1177; email
address: ramig.christopher@epa.gov.
SUPPLEMENTARY INFORMATION:
This notice is organized as follows:
I. Introduction
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II. Analysis of GHG Emissions Associated
With Production and Transport of Sugar
Beets for Use as a Biofuel Feedstock
A. Overview of Beta vulgaris ssp. vulgaris
(Sugar Beets)
B. Analysis of Upstream GHG Emissions
1. Methodology and Scenarios Evaluated
2. Domestic Impacts
3. International Impacts
4. Feedstock Transport
5. Results of Upstream GHG Lifecycle
Analysis
6. Fuel Production and Distribution
7. Risk of Potential Invasiveness
III. Summary
I. Introduction
Section 211(o) of the Clean Air Act
establishes the renewable fuel standard
(‘‘RFS’’) program, under which EPA sets
annual percentage standards specifying
the amount of renewable fuel, as well as
three subcategories of renewable fuel,
that must be used to reduce or replace
fossil fuel present in transportation fuel,
heating oil or jet fuel. With limited
exceptions, renewable fuel produced at
facilities that commenced construction
after enactment of the Energy
Independence and Security Act of 2007
(‘‘EISA’’), must achieve at least a twenty
percent reduction in lifecycle
greenhouse gas emissions as compared
to baseline 2005 transportation fuel.
Advanced biofuel and biomass-based
diesel must achieve at least a fifty
percent reduction, and cellulosic biofuel
must achieve at least a sixty percent
reduction.
As part of changes to the RFS program
regulations published on March 26,
2010 1 (the ‘‘March 2010 RFS rule’’) to
implement EISA amendments to the
RFS program, EPA identified a number
of renewable fuel production pathways
that satisfy the greenhouse gas reduction
requirements of the Act. Table 1 to 40
CFR 80.1426 of the RFS regulations lists
three critical components of approved
fuel pathways: (1) Fuel type; (2)
feedstock; and (3) production process.
In addition, for each pathway, the
regulations specify a ‘‘D code’’ that
indicates whether fuel produced by the
specified pathway meets the
requirements for renewable fuel or one
of the three renewable fuel
subcategories. EPA may independently
approve additional fuel pathways not
currently listed in Table 1 to 40 CFR
80.1426 for participation in the RFS
program, or a party may petition for
EPA to evaluate a new fuel pathway in
accordance with 40 CFR 80.1416.
Pursuant to 40 CFR 80.1416, EPA
received petitions from Green Vision
Group, Tracy Renewable Energy, and
Plant Sensory Systems, submitted under
1 See
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75 FR 14670.
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partial claims of confidential business
information (CBI), requesting that EPA
evaluate the GHG emissions associated
with biofuels produced using sugar
beets as feedstock, and that EPA provide
a determination of the renewable fuel
categories, if any, for which such
biofuels may be eligible.
EPA’s lifecycle analyses are used to
assess the overall 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 GHG reductions required
under the 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 indirect
emissions from land use changes and
agricultural sector impacts.
This document describes EPA’s
analysis of the GHG emissions from
feedstock production and feedstock
transport associated with sugar beets
when used to produce biofuel,
including significant indirect impacts.
This notice considers a scenario in
which non-cellulosic beet sugar
(primarily sucrose, glucose and/or
fructose) is extracted for conversion to
biofuel and the remaining beet pulp coproduct is used as animal feed. As will
be described in Section II, we estimate
the GHG emissions associated with
production and transport of sugar beets
for use as a biofuel feedstock are
approximately 45 kilograms of CO2equivalent per wet short ton (kgCO2e
per wet short ton) of sugar beets.2 Based
on these results, we believe biofuels
produced from sugar beets through
recognized conversion processes could
qualify as advanced biofuel and/or
conventional (non-advanced) renewable
fuel, depending on the type and
efficiency of the fuel production process
technology used. EPA is seeking public
comment on its analysis of greenhouse
2 For purposes of this notice, we assume that
sugar beets have an average moisture content of
76%. See Food and Agriculture Organization, 1999,
‘‘Agribusiness Handbooks Vol. 4 Sugar Beets/White
Sugar’’, https://www.responsibleagroinvestment.org/
sites/responsibleagroinvestment.org/files/FAO_
Agbiz%20handbook_White%20Sugar_0.pdf (Last
Accessed: January 4, 2017).
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gas emissions related to sugar beet
feedstock production and transport.
If appropriate, EPA will update this
analysis based on comments received in
response to this notice. EPA will use
this updated analysis as part of the
evaluation of facility-specific petitions
received pursuant to 40 CFR 80.1416
that propose to use sugar beets as a
feedstock for the production of biofuel.3
Based on this information, EPA will
determine the GHG emissions
associated with petitioners’ biofuel
production processes, as well as
emissions associated with the transport
and use of the finished biofuel. EPA will
combine these assessments into a full
lifecycle GHG analysis used to
determine whether the fuel produced at
an individual facility satisfies the CAA
GHG emission reduction requirements
necessary to qualify as renewable fuel or
one of the subcategories of renewable
fuel under the RFS program.
II. Analysis of GHG Emissions
Associated With Production and
Transport of Sugar Beets for Use as a
Biofuel Feedstock
A. Overview of Beta vulgaris ssp.
vulgaris (Sugar Beets)
Beta vulgaris ssp. vulgaris,
(commonly known as sugar beets) of the
order Caryophylalles, is a widely
cultivated plant of the Altissima group.
Sugar beets are cultivated for their high
percentage concentration of sucrose in
their root mass. Domestication of the
plant group took place approximately
200 years ago in Europe to selectively
breed for sugar content from crosses
between Beta vulgaris cultivars,
including chard plants and fodder
beets.4
Sugar beets are a biennial crop species
grown across a wide tolerance of soil
conditions in areas of temperate climate,
and tend to be grown in rotation with
other plant varieties.5 Sugar beets are
grown for their relatively high sugar
content, approximately 13 to 18 percent
of the plant’s total mass, with around
three quarters of the plant mass
comprised of water.6 Once harvested,
3 Assuming the fuel pathway proposed in such
petitions involve extraction of non-cellulosic beet
sugar for conversion to biofuel and use of the
resulting beet pulp co-product as animal feed.
4 Juliane C. Dohm et al., ‘‘The Genome of the
Recently Domesticated Crop Plant Sugar Beet (Beta
Vulgaris),’’ Nature 505, no. 7484 (January 23, 2014):
546–49.
5 Michael J. McConnell, ‘‘USDA ERS—
Background,’’ Crops Sugar & Sweeteners
Background, October 12, 2016, https://
www.ers.usda.gov/topics/crops/sugar-sweeteners/
background/.
6 FAO, ‘‘Sugar Crops and Sweeteners and Derived
Products,’’ accessed November 30, 2016, https://
www.fao.org/es/faodef/fdef03e.HTM.
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sugar beets are highly perishable and
need to be processed in a short period
of time.7
According to the U.S. Department of
Agriculture (USDA), the largest region
for sugar beet production is the area of
the Red River Valley of western
Minnesota and eastern North Dakota,
and sugar beets are commonly grown at
agricultural scale across five regions of
the country, encompassing 11 states.8
Western regions tend to require more
irrigation while sugar beets grown in the
eastern U.S. region make greater use of
natural rainfall.9
Since the mid-1990s, sugar beets have
accounted for about 55 percent of sugar
production in the U.S.10 Sugar beets are
included in the U.S. sugar program,
designed to support domestic sugar
prices through loans to sugar processors.
The U.S. sugar program also includes a
marketing allotment that sets the
amount of sugar that domestic
processors can sell in the U.S. for
human consumption, and provides
quotas on the amount of sugar that can
be imported into the U.S.11 Sugar
produced under the program cannot be
used for biofuel purposes with an
exception for surplus sugar made
available under the USDA Feedstock
Flexibility Program that specifically
directs the excess sugar to be used for
the purpose of domestic biofuel
production.12
Like other sugars, beet sugar can be
fermented and used as a feedstock for
biofuel production. The non-cellulosic
sugars of sugar beets, the vast majority
of which is sucrose, can be converted
directly into a refined sugar available for
processes such as alcoholic
fermentation to produce biofuels (e.g.,
ethanol).13 Much of the water needed
7 Michael J. McConnell, ‘‘USDA ERS—Policy,’’
USDA ERS—Policy, November 1, 2016, https://
www.ers.usda.gov/topics/crops/sugar-sweeteners/
policy.aspx.
8 Michael J. McConnell, ‘‘USDA ERS—
Background.’’
9 Michael J. McConnell, ‘‘USDA ERS—
Background.’’
10 Michael J. McConnell, ‘‘USDA ERS—
Background.’’
11 The U.S. sugar program is managed by USDA
and supports domestic sugar prices through loans
to sugar processors, a marketing allotment program,
and quotas on the amount of sugar that can be
imported to the U.S. Farm Security and Rural
Investment Act of 2002. Public Law 107–171, Sec.
1401–1403.
12 ‘‘Feedstock Flexibility Program,’’ page,
accessed November 17, 2016, https://
www.fsa.usda.gov/programs-and-services/energyprograms/feedstock-flexibility/index.
13 Dr. Hossein Shapouri, Dr. Michael Salassi, and
J. Nelson Fairbanks, ‘‘The Economic Feasibility of
Ethanol Production from Sugar in the United
States’’ (USDA, July 2006), https://www.usda.gov/
oce/reports/energy/
EthanolSugarFeasibilityReport3.pdf.
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for the fermentation process is provided
by the sugar beets themselves. Sugar
beet pulp is a fibrous co-product of the
beet sugar extraction process.14 The
sugar beet pulp is often dried to reduce
transportation costs and is widely sold
as feed supplement for cattle and other
livestock.15 While biofuel production
from beet sugar has historically been
limited in the U.S., sugar beets
accounted for about 17 percent of
European ethanol production in 2014.16
B. Analysis of Upstream GHG Emissions
EPA evaluated the upstream GHG
emissions associated with using sugar
beets as a biofuel feedstock based on
information provided by USDA,
petitioners, and other data sources.
Upstream GHG emissions include
emissions from production and
transport of sugar beets used as a biofuel
feedstock. The methodology EPA used
for this analysis is generally the same
approach used for the March 2010 RFS
rule for lifecycle analyses of several
other biofuel feedstocks, such as corn,
soybean oil, and sugarcane.17 The
subsections below describe this
methodology, including assumptions
and results of our analysis.
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1. Methodology and Scenarios
Evaluated
The analysis EPA prepared for sugar
beets used the same set of models that
were used for the March 2010 RFS rule,
including the Forestry and Agricultural
Sector Optimization Model (FASOM)
developed by Texas A&M University for
domestic impacts, and the Food and
Agricultural Policy and Research
Institute international models as
maintained by the Center for
Agricultural and Rural Development
(FAPRI–CARD) at Iowa State University
for international impacts. For more
information on the FASOM and FAPRI–
CARD models, refer to the March 2010
RFS rule preamble (75 FR 14670) and
Regulatory Impact Analysis (RIA).18
14 Eggleston, Gillian et al., ‘‘Ethanol from Sugar
Crops.’’ In, Singh, Bharat P., Industrial Crops and
Uses. CABI, 2010, pp. 74–75.
15 Greg Lardy, ‘‘Feeding Sugar Beet Byproducts to
Cattle,’’ accessed November 30, 2016, https://
www.ag.ndsu.edu/publications/livestock/feedingsugar-beet-byproducts-to-cattle.
16 ePURE, ‘‘European Renewable Ethanol—Key
Figures,’’ accessed November 17, 2016, https://
epure.org/media/1227/european-renewableethanol-statistics-2015.pdf.
17 The March 2010 RFS rule preamble (75 FR
14670, March 26, 2010) and Regulatory Impact
Analysis (RIA) (EPA–420–R–10–006) provide
further discussion of our approach. These
documents are available online at https://
www.epa.gov/renewable-fuel-standard-program/
renewable-fuel-standard-rfs2-final-rule-additionalresources.
18 The March 2010 RFS rule preamble (75 FR
14670, March 26, 2010) and Regulatory Impact
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Several modifications were made to the
domestic and international agricultural
economic modeling that differed from
previous analyses in order to accurately
represent the U.S. sugar program.19
Memoranda to the docket include
detailed information on model inputs,
assumptions, calculations, and the
results of our assessment of the
upstream GHG emissions for sugar beet
biofuels.20 We invite comments on the
scenarios and assumptions used for this
analysis, in particular on the key
assumptions described in this section.
Sugar beets grown under the U.S.
sugar program cannot be used for the
purpose of biofuel production, except
under very limited conditions specified
in the Feedstock Flexibility Program.21
Therefore, for this analysis, EPA
assumed that there would be no change
in sugar production on U.S. sugar
program-designated acres because of
demand for beet sugar for biofuel
feedstock use.22 In our modeling,
growers selling sugar beets to sugar
processors under the U.S. sugar program
in the control case continued to do so
regardless of new demand for sugar
beets as a biofuel feedstock in the test
case. As a result of this assumption, in
our modeling, demand for acreage to
grow sugar beets for biofuel feedstock
could only be fulfilled by converting
acres from other crops besides sugar
beets, and/or from other land uses
besides crop production (e.g.,
pastureland, Conservation Reserve
Program land).
Our analysis also considers the
significant restrictions on the trade of
sugar beets between the U.S. and other
countries. The U.S. does not export beet
sugar, as this would violate the terms of
participation in the sugar program.
While the U.S. does import cane sugar
under international agreements, it does
not import raw beet sugar.23 Beet sugar
Analysis (RIA) (EPA–420–R–10–006) provide
further discussion of our approach. These
documents are available online at https://
www.epa.gov/renewable-fuel-standard-program/
renewable-fuel-standard-rfs2-final-rule-additionalresources.
19 These differences are discussed further in
Sections II.D.2 and II.D.3 below.
20 The memoranda and modeling files are
available in the docket. EPA–HQ–OAR–2016–0771.
21 Harry Baumes, et al. (USDA), ‘‘Summary of
Discussions Between US EPA and USDA Regarding
Sugar Beets.’’
22 The U.S. sugar program designates acres of land
used to grow sugar beets sold to domestic sugar
processors who receive price support loans and are
regulated by USDA market allotments under the
program.
23 The international agreements that allow for
sugar import to the U.S. are primarily governed by
NAFTA and the Uruguay Round Agreement on
Agriculture, but also by CAFTA. See USDA’s Web
site on the Sugar Import Program for more details:
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may only enter the U.S. as refined sugar
from Canada or Mexico under the North
American Free Trade Agreement
(NAFTA) and similar trade agreements,
or as components of sugar-containing
products.24 This quantity is strictly
regulated. EPA is unaware of existing
trade agreements that would allow raw
beet sugar imports for any purpose,
including biofuel production. This
makes it unlikely that beet sugar would
be imported for use as biofuel feedstock.
Although sugar beets were modeled as
grown in the U.S., we also intend that
this analysis would cover sugar beets
grown and processed into biofuels from
other countries and imported to the U.S.
as finished biofuel. We expect the vast
majority of beet sugar-based biofuel
used in the U.S. will come from sugar
beets produced in the U.S., and
incidental amounts of fuel from crops
produced in other nations will not
impact our average GHG emissions.
Sugar beets require similar climatic
regions as those where they are grown
in the U.S., and would similarly impact
crops such as wheat in those regions
while sugar beet pulp would displace
corn as livestock feed. Therefore, EPA
interprets this upstream analysis as
applicable, regardless of the country of
origin assuming that sugar beet pulp is
used as a livestock feed supplement.
To assess the impacts of an increase
in sugar beet demand for renewable fuel
production, EPA modeled two
scenarios: (1) A control case with
‘‘business-as-usual’’ assumptions 25 and
no biofuel production from sugar beets
https://www.fas.usda.gov/programs/sugar-importprogram (Last accessed December 30, 2016).
24 Mark A. McMinimy, ‘‘U.S. Sugar Program
Fundamentals,’’ April 6, 2016, https://fas.org/sgp/
crs/misc/R43998.pdf.
25 To assess the impacts of an increase in
renewable fuel volume from business-as-usual
(what is likely to have occurred without the RFS
biofuel mandates) to levels required by the statute,
we established a control case and other cases for a
number of biofuels. The control case included a
projection of renewable fuel volumes that might be
used to comply with the RFS renewable fuel
volume mandates in full. The case is designed such
that the only difference between the scenario case
and the control case is the volume of an individual
biofuel, all other volumes remaining the same. In
the March 2010 RFS rule, for each individual
biofuel, we analyzed the incremental GHG emission
impacts of increasing the volume of that fuel from
business as usual levels to the level of that biofuel
projected to be used in 2022, together with other
biofuels, to fully meet the CAA requirements.
Rather than focus on the GHG emissions impacts
associated with a specific gallon of fuel and
tracking inputs and outputs across different
lifecycle stages, we determined the overall aggregate
impacts across sectors of the economy in response
to a given volume change in the amount of biofuel
produced. For this analysis, we compared impacts
in the control case to the impacts in a new sugar
beets case. The control case used for the March
2010 RFS rule, and used for this analysis, has zero
gallons of sugar beet biofuel production.
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and (2) a sugar beet biofuel case where
300 million ethanol-equivalent gallons
of biofuels are assumed to be from beet
sugar in 2022, requiring the use of 12
million wet short tons of sugar beets for
biofuel production. The analysis
presented in this notice considered all
GHG emissions associated with the
cultivation and production of sugar
beets intended for biofuel feedstock use,
as well as emissions from transporting
these sugar beets to a biofuel production
facility. In lifecycle analysis literature
these emissions are often referred to as
the ‘‘upstream’’ emissions, because they
occur upstream of the fuel production
facility (i.e., before the biofuel feedstock
arrives at that facility).
The analysis presented in this notice
does not include fuel production or
‘‘downstream’’ emissions, which
consists of emissions associated with
fuel transport and fuel combustion.
Once comments on the upstream
emissions described in this notice have
been considered, we intend to combine
the upstream analysis with the fuel
production and downstream emissions
associated with fuel produced at an
individual biofuel facility to determine
the lifecycle GHG emissions associated
with that fuel. This lifecycle analysis
would reflect any differences in
emissions that may exist between
producing different types of biofuels
from sugar beets. Our analysis of the
upstream emissions associated with
sugar beets assumed that non-cellulosic
sugars are extracted from the beets
before the sugars are converted, and that
the beet pulp would then be sold into
feed markets. Fuel production methods
that also convert the pulp into fuel (e.g.,
through pyrolysis of the beet) or use the
pulp for other purposes may not be
compatible with this analysis.
We evaluated a scenario with biofuels
produced from this amount of sugar
beets for multiple reasons. Although
biofuel production from sugar beets is
currently small in the U.S., recent
trends in domestic sugar beet yields and
acreage indicate that 12 million wet
short tons of sugar beets could be
produced as biofuel feedstocks if a
significant market demand emerged. An
additional 12 million wet short tons of
sugar beets would represent a 34
percent increase in U.S. sugar beet
cultivation compared to 2015 levels.26
According to USDA data, harvested
26 See,
USDA, ‘‘Sugarbeet Area and Planted
Harvested Yield and Production States and United
States 2013–2015,’’ in Crop Production 2015
Summary, January 2016, ISSN: 1057–7823, https://
usda.mannlib.cornell.edu/usda/current/
CropProdSu/CropProdSu-0112-2016.pdf. This
assumes an ethanol conversion rate of 25 gallons of
ethanol/wet short ton of beets.
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acres of sugar beets since 2010 were, on
average, about 30 percent lower than
their most recent peak levels in the
1990s, an average difference of
approximately 360,000 harvested
acres.27 Increasing beet yields over time
has reduced the number of acres needed
to satisfy production targets under the
U.S. sugar program.28 National average
sugar beet yields since 2010 have been
approximately 25 percent higher than
yields during the 1990s, and reached
almost 31 wet short tons per acre in the
2015 crop year.29 Were beet acres to
return to their 1990s peak, the
additional approximately 360,000
harvested acres would produce about
11.2 million wet short tons of beets at
these 2015 yield levels. However, based
on the steady increase in yields over
time, it seems likely that beet yields will
continue to increase between now and
2022. If national average beet yields
reach at least 33.4 wet short tons per
acre by 2022, a fairly modest increase of
about 8 percent over 2015 levels, an
additional 12 million wet short tons of
beets could be produced on these
additional 360,000 acres. Since further
expansion of beet area beyond the
historical peak is also possible, an
increase in beet production of 12
million wet short tons appears to be
very feasible. We welcome comment on
this assumption.
In our analysis, FASOM allowed for
sugar beet production in all areas of the
continental 48 states where sugar beets
had been grown historically, including
states and areas that do not currently
take part in the U.S. sugar program. The
model was allowed to determine which
of these regions would be optimal for
growing sugar beets for biofuel
feedstock, based on least cost of
production and transport, and
considering the opportunity cost of
using that land for other uses (e.g., to
produce other crops, grazing, forestry).
The factors that contributed to these
crop production choices include crop
yield, input quantities, and growing
strategies.
Following the methodology
established in the March 2010 RFS rule,
EPA used the FAPRI model to evaluate
the international impacts of producing
and transporting 12 million wet short
tons of sugar beets for biofuel
production in the U.S. The FAPRI
27 USDA, ‘‘NASS Quick Stats’’, https://
quickstats.nass.usda.gov (Last Accessed: November
16, 2016).
28 USDA, ‘‘NASS Quick Stats’’, https://
quickstats.nass.usda.gov (Last Accessed: November
16, 2016).
29 USDA, ‘‘NASS Quick Stats’’, https://
quickstats.nass.usda.gov (Last Accessed: November
16, 2016).
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34659
model included a representation of the
U.S. sugar program, and modeled
domestic sugar production as a function
of this program. Production and
consumption levels in the U.S. were set
according to the parameters of the sugar
program and were not affected by
market forces. Because the existing U.S.
sugar production module in FAPRI did
not respond to market forces, for
modeling purposes EPA had to make
assumptions regarding in which regions
sugar beets for biofuel feedstock use
would be grown. Crop yields and the
quantity of crop area displaced by
expanded sugar beet production also
had to be set by assumption, since the
U.S. sugar module in FAPRI lacks
market forces to create demand-pull for
new beet acres. In order to derive the
quantity of crop area displaced, EPA
used a crop yield of approximately 26
wet short tons per acre, the 10-year
national average yield for sugar beets
(for crop years 2005 through 2014).30
Actual yields on any given acre may be
higher or lower than this assumed
value, based on factors such as location,
annual variation in growing conditions,
growing practices, and crop rotation
strategies. Because the FAPRI analysis
assumed to displace acres in North
Dakota and California, we did not
believe that it was appropriate to use the
USDA 2022 national average projections
for sugar beets yield. As an alternative,
EPA believes using the 10-year national
average was a reasonable assumption for
our international agricultural sector
modeling. The increase in sugar yield
trends over the last few decades
suggests that future yields are unlikely
to be lower than the 10-year average. As
further support for our yield
assumptions in FAPRI, we note that
FASOM projected sugar beet yields in
2022 that are close to the assumptions
used in FAPRI.31 We welcome comment
on this assumption.
For the purposes of FAPRI modeling,
EPA assumed that sugar beets for fuel
use would be produced in equal
amounts in North Dakota and California
for the following reasons: At the onset
of our analysis, these were the regions
with indications of significant sugar
beet biofuel interest.32 They are also
30 USDA, ‘‘NASS Quick Stats’’, https://
quickstats.nass.usda.gov (Last Accessed: November
16, 2016).
31 See ‘‘Sugar Beets for Biofuel Upstream Analysis
Technical Memorandum’’ in the docket for details.
EPA–HQ–OAR–2016–0771.
32 At the time of this modeling we had received
the petitions from Green Vision Group proposing to
produce ethanol from sugar beets grown in North
Dakota and Tracy Renewable Energy proposing to
produce ethanol from sugar beets grown in
California but we had not received the petition from
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mstockstill on DSK30JT082PROD with NOTICES
both regions with a long history of sugar
beet production. As a simplifying
assumption, EPA assumed that all crops
grown in each of these regions were
displaced by sugar beets proportionally
to their crop area in the control case. We
recognize there are significant
differences in the way the sugar beet
biofuel scenarios were implemented in
FASOM and FAPRI for this analysis. For
example, FASOM chose to produce all
sugar beets for biofuels in North Dakota,
whereas in FAPRI we modeled this
production in North Dakota and
California by assumption. Since these
modeling exercises occurred
concurrently, not sequentially, we could
not anticipate what choices FASOM
would make at the outset of our FAPRI
modeling. This led to some differences
in the regions utilized to produce beets.
However, the nationwide agricultural
market results projected by FASOM and
FAPRI were similar, due to similar
dominant trends in feed markets and
crop exports at the national level. The
similarity of these relevant national
market results between the two models,
despite differences in U.S. growing
regions, indicates that the international
impacts projected by the FAPRI model
would not have been significantly
different if we had applied the growing
assumptions from FASOM. These
results are discussed below and are
available in the docket for this notice.33
We welcome comment on these
assumptions and our results.
The sugar beet scenario modeled
included a number of key assumptions,
such as biofuel and pulp yields per wet
short ton of beets, and the amount of
corn livestock feed displaced per pound
of pulp. These key assumptions are
discussed below. Information on
additional assumptions, including sugar
beet crop inputs (e.g., fertilizer, energy)
is available in the docket for this notice.
In conducting research for this
analysis, we located sources for beet
pulp yield of 0.06 dry short tons of
sugar beet pulp per wet short tons of
sugar beets 34 and displacement rates of
0.9 pounds of corn feed displaced in
cattle diets 35 for every pound of sugar
Plant Sensory Systems proposing to produce
ethanol from sugar beets grown in Florida. EPA
does not expect results would have varied
significantly if sugar beets had been modeled by
assumption in Florida under FAPRI due to the
similarity of these results to the results from
FASOM.
33 See EPA–HQ–OAR–2016–0771.
34 Panella, Lee and Stephen R. Kaffka, ‘‘Sugar
Beet (Beta vulgaris L) as a Biofuel Feedstock in the
United States.’’ Chapter 10 in Sustainability of the
Sugar and Sugar Ethanol Industries; Eggleston, G.;
ACS Symposium Series; American Chemical
Society: Washington DC, 2010, pp. 165.
35 To make a simplifying assumption, we
averaged the value from corn in backgrounding
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beet pulp. In livestock production, the
fibrous sugar beet pulp is used as a
roughage replacement making it of use
primarily for ruminants rather than
other types of livestock.36 In our
analysis, sugar beet pulp use by the
livestock market was an important
factor leading to GHG reductions.
Therefore this notice evaluates only
using the non-cellulosic portion of sugar
beets for biofuel production.
2. Domestic Impacts
On the basis of least cost, FASOM
chose to grow all sugar beets in North
Dakota, with approximately 477,000
acres of land required to grow the
additional sugar beets.
The vast majority of the new sugar
beet acres in North Dakota was from
displacement of other crops rather than
from new cropland (432,000 acres from
displaced crops, or nearly 91 percent of
needed acres). Increasing sugar beet
production in North Dakota primarily
displaced wheat acreage, but also
soybeans, corn, and hay among other
crops.37 Most of these displaced crops
shifted to other U.S. regions, and some
crops, such as soybeans, shifted to new
acreage that was more productive than
the North Dakota acres from where they
were displaced. Table II.1 indicates that
production levels for hay, soy, and most
other crops are maintained.38 However,
national crop area and production for
wheat and corn declined significantly.
TABLE II.1—CHANGES IN U.S. PRODUCTION (MILLION POUNDS) AND
HARVESTED
AREA
(THOUSAND
ACRES) IN 2022 RELATIVE TO CONTROL CASE 39
Production
difference
from control
case
(million
pounds)
Harvested
area
difference from
control case
(thousand
acres)
Sugar
Beets .....
Hay ...........
Corn ..........
Wheat .......
All Else ......
+23,976
+8
¥867
¥352
+3
+477
¥106
¥96
¥98
¥56
Total ...
+22,768
+121
diets and finishing diets. Lardy, Greg, and Rebecca
Schafar, ‘‘Feeding Sugar Beet Byproducts to Cattle,’’
North Dakota State University, May 2008, pp. 2.
36 Harry Baumes, et al. (USDA), ‘‘Summary of
Discussions Between US EPA and USDA Regarding
Sugar Beets’’.
37 See ‘‘FASOM Sugar Beets Results’’ in the
docket. EPA–HQ–OAR–2016–0771.
38 Soy is captured in the ‘‘All Else’’ category in
Table II.1. See ‘‘FASOM Sugar Beets Results’’ in the
docket EPA–HQ–OAR–2016–0771 for more detail.
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The reductions in corn and wheat
production were driven by different
proximate causes (though both were
ultimately driven by increased demand
for sugar beets) and led to somewhat
different impacts on commodity use and
trade. In the case of wheat, the decline
in production led to a decline in
exports. As shown in Section II.B.3, the
decline in wheat exports created
pressure on international wheat markets
and wheat production increased outside
the U.S.
In the case of corn, the potential
market impacts were mitigated by the
increased availability of sugar beet pulp
into U.S. feed markets as a result of beet
sugar biofuel production. As described
in Section II.A, sugar beet pulp is a coproduct used as livestock feed
supplement, mainly substituting for
corn. Based on the FASOM results for
2022, approximately 1.4 billion pounds
of sugar beet pulp were produced and
sent to the feed market. In turn this
displaced approximately 1.2 billion
pounds of corn, which was significantly
greater than the approximately 867
million pounds of corn production lost
to displaced acres. This led to a
decrease in total demand for corn in
U.S. markets and, as a result, U.S.
exports of corn increased. As discussed
in Section II.B.3 below, this reduced the
price of corn internationally and
lessened the demand pull for corn to be
grown in other countries.
The rest of the needed sugar beet
acres in North Dakota, approximately
46,000 acres, came from new cropland,
particularly from cropland pasture
(high-value pasture land that can also be
utilized as cropland with minimal
preparation) and from acres that would
otherwise take part in the Conservation
Reserve Program. Pasture area rose
modestly in some other states causing
the conversion of some forest acres to
pasture. This relatively small decrease
in forestland pushed up prices slightly
for forest products, leading foresters to
intensify growth on their stands.
Relative to other feedstocks EPA has
evaluated for the RFS program, these
domestic shifts in land use were minor,
and after the various land use changes
were considered the net domestic land
use change emissions impacts were
close to zero.
3. International Impacts
In the FAPRI model, the expansion of
sugar beet cropland used to produce
biofuel feedstock also led to increases in
corn exports and decreases in wheat
exports. Similar to the drivers of the
39 Totals may differ from subtotals due to
rounding.
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domestic results discussed in Section
II.B.2, beet production displaced wheat
acres, but the beet pulp co-product
reduced domestic demand for corn.
Further, the magnitude of these export
impacts was quite similar between the
two models, as shown in Table II.2
below.40
TABLE II.2—CHANGES IN U.S. CORN
AND WHEAT EXPORTS IN 2022 RELATIVE TO CONTROL CASE BY MODEL
[Million pounds]
Difference
from control
case in
FASOM
Corn ..........
Wheat .......
outside the U.S. of certain other crops
however increased in response to U.S.
increasing demand for sugar beets; most
significantly wheat and soybeans.
Wheat increased internationally in
terms of both production and acreage,
with a strong response particularly in
India. Soybean acres and production
also increased, particularly in Brazil.
Table II.3 below summarizes the nonU.S. increases in harvested area by crop
type, while Table II.4 shows which
countries had the largest impacts.
[Thousand acres] 41
+355
¥281
With sugar beet pulp displacing corn
feed, FAPRI modeling indicated that in
2022, both corn production and acreage
would decline globally. Production
[Thousand acres] 41
Difference
from control
case
Soybeans ..............................
All Else ..................................
+20
+37
Total ...............................
+55
TABLE II.3—NON-U.S. HARVESTED
As increasing sugar beet pulp use for
AREA BY CROP IN 2022 RELATIVE livestock feed in the U.S. freed up more
corn for export, international livestock
TO CONTROL CASE
Difference
from
control
case in FAPRI
+307
¥292
TABLE II.3—NON-U.S. HARVESTED
AREA BY CROP IN 2022 RELATIVE
TO CONTROL CASE—Continued
Sugar Beets ..........................
Corn ......................................
Wheat ...................................
feed prices declined modestly, and with
it was a small rise in meat production
globally. Many of these changes
Difference
from control
occurred in Brazil and this caused some
case
expansion in grazing land, including in
0 the Amazon region. This caused further
¥45 international land use change impacts,
+43 as shown in Table II.4 below.
TABLE II.4—NON-U.S. CHANGES IN AGRICULTURAL LAND BY REGION IN 2022 RELATIVE TO CONTROL CASE
[Thousand acres] 42
Change in
area harvested
Change in
pasture acres
Total
change in
acres
Brazil ............................................................................................................................................
India .............................................................................................................................................
Rest of Non-USA .........................................................................................................................
+9
+15
+32
+20
........................
........................
+29
+15
+32
Total Non-USA .....................................................................................................................
........................
........................
+75
4. Feedstock Transport
When harvested, sugar beets are
heavy and perishable; therefore,
transport of sugar beets from field to
processing site is expected to occur over
short distances. Information from
stakeholders and literature states that
sugar beets used for biofuels are shipped
by truck from point of production to the
plant with typical distances for
transport around 30 miles.43 GHG
emissions for the transport of sugar
beets are based on emission factors
developed for the March 2010 RFS rule
for trucks including capacity, fuel
economy, and type of fuel used.44
5. Results of Upstream GHG Lifecycle
Analysis
As described above, EPA analyzed the
GHG emissions associated with
feedstock production and transport.
Table II.5 below breaks down by stage
the calculated GHG upstream emissions
for producing biofuels from sugar beets
in 2022.
TABLE II.5—UPSTREAM GHG LIFECYCLE EMISSIONS FOR SUGAR BEETS
[gCO2-eq/wet short ton]
Emissions
(gCO2-eq/wet short ton)
Process
mstockstill on DSK30JT082PROD with NOTICES
Net Agriculture (w/o land use change) ..........................................................................................................................
Domestic Land Use Change .........................................................................................................................................
International Land Use Change, Mean .........................................................................................................................
(Low/High) ......................................................................................................................................................................
40 Impacts on the exports of other crops were
relatively minor, but interested readers can examine
the full set of FAPRI crop trade impacts in the
docket.
41 These totals do not include pastureland in
Brazil. Totals may differ from subtotals due to
rounding.
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42 Totals may differ from subtotals due to
rounding. Brazil totals include pastureland. Other
regions are cropland only.
43 Farahmand, K., N. Dharmadhikari, and V.
Khiabani. ‘‘Analysis of Transportation Economics of
Sugar-Beet Production in the Red River Valley of
North Dakota and Minnesota using Geographical
Information System.’’ Journal of Renewable
Agriculture 7(2013):126–131.
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+21,615
¥882
+16,038
(+9249/+23,672)
44 The March 2010 RFS rule preamble (75 FR
14670, March 26, 2010) and Regulatory Impact
Analysis (RIA) (EPA–420–R–10–006) provide
further discussion of our approach. These
documents are available online at https://
www.epa.gov/renewable-fuel-standard-program/
renewable-fuel-standard-rfs2-final-rule-additionalresources.
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TABLE II.5—UPSTREAM GHG LIFECYCLE EMISSIONS FOR SUGAR BEETS—Continued
[gCO2-eq/wet short ton]
Emissions
(gCO2-eq/wet short ton)
Process
Feedstock Transport ......................................................................................................................................................
+8,183
Total Upstream Emissions, Mean ..........................................................................................................................
(Low/High) ..............................................................................................................................................................
+44,954
(+38,210/+52,588)
Net agricultural emissions included
domestic and international impacts
related to changes in crop inputs such
as fertilizer, energy used in agriculture,
livestock production, and other
agricultural changes in the scenario
modeled. Increased demand for sugar
beets resulted in positive net
agricultural emissions relative to the
control case. Compared with other
crops, sugar beets required relatively
high levels of agricultural chemical
inputs (e.g., herbicides and
pesticides).45 Domestic land use change
emissions were close to zero for sugar
beets, as described in Section II.B.2.
International land use change
emissions increased as a result of
demand for sugar beets. The increase in
international land use change emissions
for sugar beets was significantly larger
than the decrease in domestic land use
change emissions. This is because
increased demand for sugar beets led to
a significant reduction in key U.S. crop
exports (e.g., wheat exports), but very
little change in domestic consumption
of agricultural goods. These greater
international emissions led to a net
increase in global land use change
emissions. Feedstock transport included
emissions from moving sugar beets from
the farm to a biofuel production facility,
as described in Section II.B.4 above.
mstockstill on DSK30JT082PROD with NOTICES
6. Fuel Production and Distribution
Sugar beets are suitable for the same
biofuel conversion processes as
sugarcane. In Europe, where sugar beets
are widely used as biofuel feedstock,
virtually all of the fuel is non-cellulosic
beet sugar ethanol produced through
fermentation with the beet pulp sold
into the feed markets. Based on these
data, and on information from our
petitioners and other stakeholders, EPA
anticipates that most biofuel produced
from sugar beets in the U.S. would also
be from the non-cellulosic sugars via
fermentation. Our upstream analysis
would apply for all facilities where noncellulosic beet sugar is converted to
45 Harry Baumes, et al. (USDA), ‘‘Summary of
Discussions Between US EPA and USDA Regarding
Sugar Beets’’.
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biofuel and the co-product beet pulp is
used as animal feed.
Given the importance of the beet pulp
co-product on the upstream GHG
emissions associated with beet pulp,
pathways that do not produce a beet
pulp feed coproduct, or use it for
purposes other than animal feed, may
not be compatible with our analysis.
EPA would likely need to conduct
supplemental upstream GHG analysis in
order to determine the lifecycle GHG
emissions associated with fuels
produced under these types of
pathways.
After reviewing comments received in
response to this action, EPA will
combine the evaluation of upstream
GHG emissions associated with the use
of sugar beet feedstock with an
evaluation of the GHG emissions
associated with individual producers’
production processes and finished fuels
to determine whether fuel produced at
petitioners’ facilities from the sugar in
sugar beets satisfy the CAA lifecycle
GHG emissions reduction requirements
for renewable fuels. Each biofuel
producer seeking to generate Renewable
Identification Numbers (RINs) for nongrandfathered volumes of biofuel from
sugar beets will 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).46
Because EPA is evaluating the GHG
emissions associated with the
production and transport of sugar beet
feedstock through this notice and
comment process, petitioners requesting
EPA’s evaluation of biofuel pathways
involving sugar beet feedstock need not
include the information for new
feedstocks specified at 40 CFR
80.1416(b)(2). Based on our evaluation
of the upstream GHG emissions
attributable to the production and
transport of sugar beet feedstock,
46 Petitioners with pending petitions involving
use of sugar from sugar beets as feedstock will not
be required to submit new petitions. However, if
any information has changed from their original
petitions, EPA will request that they update that
information.
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including our assumptions regarding the
average yield of ethanol in mmBtu per
wet short ton of sugar beets used, EPA
anticipates that if a facility produces
emissions of no more than
approximately 23 kgCO2e/mmBtu of
ethanol, the fuel produced would meet
the 50 percent advanced biofuel GHG
reduction threshold.47 If a facility
produces no more than 53 kgCO2e/
mmBtu of ethanol, EPA anticipates it
would meet the 20 percent renewable
fuel GHG reduction threshold. EPA will
evaluate petitions for fuel produced
from sugar beet feedstock on a case-bycase basis, and will make adjustments as
necessary for each facility including
consideration of differences in the yield
of ethanol per wet short ton of sugar
beets used.48 We welcome comments on
this application of our upstream
analysis.
7. Risk of Potential Invasiveness
Sugar beets were not listed on the
Federal noxious weed list nor did they
appear on USDA’s composite listing of
introduced, invasive, and noxious
plants by U.S state.49 50 Based on
consultation with USDA, EPA does not
believe sugar beets pose a risk of
invasiveness at this time. Current
cultivars of sugar beets require extensive
weed management to survive.51
However, USDA notes that future cross
breeding, hybridization, and genetic
manipulation could change the
47 In this case, emissions produced by the facility
refers to fuel production emissions, including
emissions associated with energy used for fuel,
feedstock and co-product operations at the facility.
For more details on the assumptions used in this
analysis, see ‘‘Sugar Beets for Biofuel Upstream
Analysis Technical Memorandum’’ in the docket.
EPA–HQ–OAR–2016–0771.
48 For example, EPA may need to consider
additional feedstock transportation emissions in
cases where beet sugar extraction and biofuel
production do not occur in the same location, as
may be the case for biofuel produced under the
USDA Feedstock Flexibility Program.
49 USDA, ‘‘Federal Noxious Weed List,’’ July 13,
2016, https://www.aphis.usda.gov/plant_health/
plant_pest_info/weeds/downloads/weedlist.pdf.
50 USDA, ‘‘State and Federal Noxious Weeds
List,’’ accessed November 17, 2016, https://
plants.usda.gov/java/noxComposite.
51 Harry Baumes, et al. (USDA), ‘‘Summary of
Discussions Between US EPA and USDA Regarding
Sugar Beets.’’
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invasiveness potential of beets, in which
case a re-evaluation may be required.52
Based on currently available
information, EPA does not believe
monitoring and reporting of data for
invasiveness concerns would be a
requirement for biofuel producers
generating fuel from sugar beets at this
time.
III. Summary
EPA invites public comment on its
analysis of GHG emissions associated
with the production and transport of
sugar beets as a feedstock for biofuel
production. This notice analyzes a noncellulosic sugar beet-to-biofuel
production process. Although EPA has
not received a petition for cellulosic
sugar beet biofuel production, the
agency is aware of interest in this
process and invites comment on the
analysis of beet pulp and its effect on
agricultural markets. EPA will consider
public comments received when
evaluating petitions received pursuant
to 40 CFR 80.1416 that involve
pathways using sugar beets as a
feedstock.
Dated: January 18, 2017.
Christopher Grundler,
Director, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2017–15721 Filed 7–25–17; 8:45 am]
BILLING CODE 6560–50–P
ENVIRONMENTAL PROTECTION
AGENCY
[FRL–9965–17–OA]
Notification of a Public Meeting of the
Chartered Science Advisory Board
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
The Environmental Protection
Agency (EPA) Science Advisory Board
(SAB) Staff Office announces a public
meeting of the chartered SAB to:
Conduct three quality reviews of (1) the
SAB peer review of EPA’s Draft
Assessment entitled Toxicological
Review of Hexahydro-1,3,5-trinitro1,3,5-triazine (RDX); (2) the draft SAB
report on Economy-wide Modeling of
the Benefits and Costs of Environmental
Regulation and (3) the draft SAB review
of the EPA’s Framework for Assessing
Biogenic CO2 Emissions from Stationary
Sources (2014); and receive briefings on
SAB projects and future topics from the
EPA.
mstockstill on DSK30JT082PROD with NOTICES
SUMMARY:
52 Harry Baumes, et al. (USDA), ‘‘Summary of
Discussions Between US EPA and USDA Regarding
Sugar Beets.’’
VerDate Sep<11>2014
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The public meeting will be held
on Tuesday, August 29, 2017, from
10:30 a.m. to 5:00 p.m. and Wednesday,
August 30, 2016, from 9:00 a.m. to 1:00
p.m.
ADDRESSES: The meeting will be held at
the Residence Inn Arlington Capital
View, 2850 South Potomac Ave.,
Arlington, VA 22202.
FOR FURTHER INFORMATION CONTACT: Any
member of the public who wants further
information concerning the meeting
may contact Mr. Thomas Carpenter,
Designated Federal Officer (DFO), EPA
Science Advisory Board (1400R), U.S.
Environmental Protection Agency, 1200
Pennsylvania Avenue NW., Washington,
DC 20460; via telephone/voice mail
(202) 564–4885, or email at
carpenter.thomas@epa.gov. General
information concerning the SAB can be
found on the EPA Web site at https://
www.epa.gov/sab.
SUPPLEMENTARY INFORMATION:
Background: The SAB was
established pursuant to the
Environmental Research, Development,
and Demonstration Authorization Act
(ERDDAA), codified at 42 U.S.C. 4365,
to provide independent scientific and
technical advice to the Administrator on
the scientific and technical basis for
Agency positions and regulations. The
SAB is a Federal Advisory Committee
chartered under the Federal Advisory
Committee Act (FACA), 5 U.S.C., App.
2. The SAB will comply with the
provisions of FACA and all appropriate
SAB Staff Office procedural policies.
Pursuant to FACA and EPA policy,
notice is hereby given that the SAB will
hold a public meeting to discuss and
deliberate on the topics below. The
chartered SAB will conduct quality
reviews of three draft reports. The SAB
quality review process ensures that all
draft reports developed by SAB panels,
committees or workgroups are reviewed
and approved by the Chartered SAB
before being finalized and transmitted to
the EPA Administrator. These reviews
are conducted in a public meeting as
required by FACA.
Quality Review of the draft SAB
Review of EPA’s Draft Assessment
entitled Toxicological Review of
Hexahydro-1,3,5-trinitro-1,3,5-triazine
(RDX): The National Center for
Environmental Assessment (NCEA) in
the EPA’s Office of Research and
Development (ORD) develops
toxicological reviews/assessments for
various chemicals for IRIS. NCEA is
developing a draft IRIS assessment for
Hexahydro-1,3,5-trinitro-1,3,5-triazine
(RDX) and has asked the SAB to peer
review the draft document. The draft
will be a reassessment of RDX. NCEA’s
DATES:
PO 00000
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Fmt 4703
Sfmt 4703
34663
draft Toxicological Review of
Hexahydro-1,3,5-trinitro-1,3,5-triazine
(RDX) currently posted to the IRIS
database includes an oral reference dose
(RfD) (posted in 1988), and a cancer
descriptor and oral cancer slope factor
(posted in 1990). Epidemiological data,
experimental animal data, and other
relevant data from studies of the
noncancer and cancer effects of RDX are
being evaluated in this reassessment.
The reassessment is expected to include
an updated RfD and oral cancer
assessment. Background on the current
advisory activity, IRIS Assessment for
Hexahydro-1,3,5-trinitro-1,3,5-triazine
(RDX) can be found on the SAB Web
site at https://yosemite.epa.gov/sab/
sabproduct.nsf/0/50370BADC61C408
685257E380077D825?OpenDocument.
Quality Review of the draft SAB
report on Economy-wide Modeling of
the Benefits and Costs of Environmental
Regulation: The EPA requested that the
SAB provide review of the EPA’s
modeling and ability to measure full
regulatory impacts and to make
recommendations on the use of
economy-wide modeling frameworks to
characterize the social costs, benefits,
and economic impacts of air regulations
with the aim of improving benefit-cost
and economic impact analyses used to
inform decision-making at the agency.
As a first step, the EPA has asked the
SAB to provide feedback on its draft
charge questions and analytic blueprint.
Background on the current advisory
activity, Economy-wide Modeling of the
Benefits and Costs of Environmental
Regulation can be found on the SAB
Web site at https://yosemite.epa.gov/
sab/sabproduct.nsf/LookupWebProjects
CurrentBOARD/07e67cf77b54734
285257bb0004f87ed!OpenDocument&
TableRow=2.1#2.
Quality review of a draft SAB review
report on the Framework for Assessing
Biogenic CO2 Emissions from Stationary
Sources: In 2012, the SAB completed a
review of the first draft accounting
framework addressing scientific and
technical issues associated with
biogenic carbon dioxide (CO2)
emissions, Accounting Framework for
Biogenic CO2 Emissions from Stationary
Sources (September 2011). The EPA
subsequently revised the 2011
framework and requested the SAB to
conduct a review of the Framework for
Assessing Biogenic CO2 Emissions from
Stationary Sources (November 2014).
The purpose of the 2014 framework is
to develop a method for calculating the
adjustment, or Biogenic Assessment
Factor (BAF), for carbon emissions
associated with the combustion of
biogenic feedstocks taking into account
the biological carbon cycle effects
E:\FR\FM\26JYN1.SGM
26JYN1
]]>Agencies
[Federal Register Volume 82, Number 142 (Wednesday, July 26, 2017)]
[Notices]
[Pages 34656-34663]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-15721]
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ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2016-0771; FRL-9958-88-OAR]
Notice of Opportunity To Comment on an Analysis of the Greenhouse
Gas Emissions Attributable to Production and Transport of Beta vulgaris
ssp. vulgaris (Sugar Beets) for Use in Biofuel Production
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: In this notice, the Environmental Protection Agency (EPA) is
inviting comment on its analysis of the upstream greenhouse gas
emissions attributable to the production of Beta vulgaris ssp. vulgaris
(sugar beets) for use as a biofuel feedstock. This notice describes
EPA's greenhouse gas analysis of sugar beets produced for use as a
biofuel feedstock, and describes how EPA may apply this analysis in the
future to determine whether biofuels produced from sugar beets meet the
necessary greenhouse gas reduction threshold required for qualification
as renewable fuel under the Renewable Fuel Standard program. This
notice considers a scenario in which non-cellulosic beet sugar is
extracted for conversion to biofuel and the remaining beet pulp co-
product is used as animal feed. Based on this analysis, we anticipate
that biofuels produced from sugar beets could qualify as renewable fuel
or advanced biofuel, depending on the type and efficiency of the fuel
production process technology used.
DATES: Comments must be received on or before August 25, 2017.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2016-0771, at https://www.regulations.gov. Follow the online
instructions for submitting comments. Once submitted, comments cannot
be edited or withdrawn from Regulations.gov. 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://www.epa.gov/dockets/commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT: Christopher Ramig, Office of Air and
Radiation, Office of Transportation and Air Quality, Mail Code: 6401A,
U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue NW.,
Washington, DC 20460; telephone number: 202-564-1372; fax number: 202-
564-1177; email address: ramig.christopher@epa.gov.
SUPPLEMENTARY INFORMATION:
This notice is organized as follows:
I. Introduction
II. Analysis of GHG Emissions Associated With Production and
Transport of Sugar Beets for Use as a Biofuel Feedstock
A. Overview of Beta vulgaris ssp. vulgaris (Sugar Beets)
B. Analysis of Upstream GHG Emissions
1. Methodology and Scenarios Evaluated
2. Domestic Impacts
3. International Impacts
4. Feedstock Transport
5. Results of Upstream GHG Lifecycle Analysis
6. Fuel Production and Distribution
7. Risk of Potential Invasiveness
III. Summary
I. Introduction
Section 211(o) of the Clean Air Act establishes the renewable fuel
standard (``RFS'') program, under which EPA sets annual percentage
standards specifying the amount of renewable fuel, as well as three
subcategories of renewable fuel, that must be used to reduce or replace
fossil fuel present in transportation fuel, heating oil or jet fuel.
With limited exceptions, renewable fuel produced at facilities that
commenced construction after enactment of the Energy Independence and
Security Act of 2007 (``EISA''), must achieve at least a twenty percent
reduction in lifecycle greenhouse gas emissions as compared to baseline
2005 transportation fuel. Advanced biofuel and biomass-based diesel
must achieve at least a fifty percent reduction, and cellulosic biofuel
must achieve at least a sixty percent reduction.
As part of changes to the RFS program regulations published on
March 26, 2010 \1\ (the ``March 2010 RFS rule'') to implement EISA
amendments to the RFS program, EPA identified a number of renewable
fuel production pathways that satisfy the greenhouse gas reduction
requirements of the Act. Table 1 to 40 CFR 80.1426 of the RFS
regulations lists three critical components of approved fuel pathways:
(1) Fuel type; (2) feedstock; and (3) production process. In addition,
for each pathway, the regulations specify a ``D code'' that indicates
whether fuel produced by the specified pathway meets the requirements
for renewable fuel or one of the three renewable fuel subcategories.
EPA may independently approve additional fuel pathways not currently
listed in Table 1 to 40 CFR 80.1426 for participation in the RFS
program, or a party may petition for EPA to evaluate a new fuel pathway
in accordance with 40 CFR 80.1416. Pursuant to 40 CFR 80.1416, EPA
received petitions from Green Vision Group, Tracy Renewable Energy, and
Plant Sensory Systems, submitted under
[[Page 34657]]
partial claims of confidential business information (CBI), requesting
that EPA evaluate the GHG emissions associated with biofuels produced
using sugar beets as feedstock, and that EPA provide a determination of
the renewable fuel categories, if any, for which such biofuels may be
eligible.
---------------------------------------------------------------------------
\1\ See 75 FR 14670.
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EPA's lifecycle analyses are used to assess the overall 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 GHG
reductions required under the 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 indirect emissions from land use changes and
agricultural sector impacts.
This document describes EPA's analysis of the GHG emissions from
feedstock production and feedstock transport associated with sugar
beets when used to produce biofuel, including significant indirect
impacts. This notice considers a scenario in which non-cellulosic beet
sugar (primarily sucrose, glucose and/or fructose) is extracted for
conversion to biofuel and the remaining beet pulp co-product is used as
animal feed. As will be described in Section II, we estimate the GHG
emissions associated with production and transport of sugar beets for
use as a biofuel feedstock are approximately 45 kilograms of
CO2-equivalent per wet short ton (kgCO2e per wet
short ton) of sugar beets.\2\ Based on these results, we believe
biofuels produced from sugar beets through recognized conversion
processes could qualify as advanced biofuel and/or conventional (non-
advanced) renewable fuel, depending on the type and efficiency of the
fuel production process technology used. EPA is seeking public comment
on its analysis of greenhouse gas emissions related to sugar beet
feedstock production and transport.
---------------------------------------------------------------------------
\2\ For purposes of this notice, we assume that sugar beets have
an average moisture content of 76%. See Food and Agriculture
Organization, 1999, ``Agribusiness Handbooks Vol. 4 Sugar Beets/
White Sugar'', https://www.responsibleagroinvestment.org/sites/responsibleagroinvestment.org/files/FAO_Agbiz%20handbook_White%20Sugar_0.pdf (Last Accessed: January 4,
2017).
---------------------------------------------------------------------------
If appropriate, EPA will update this analysis based on comments
received in response to this notice. EPA will use this updated analysis
as part of the evaluation of facility-specific petitions received
pursuant to 40 CFR 80.1416 that propose to use sugar beets as a
feedstock for the production of biofuel.\3\ Based on this information,
EPA will determine the GHG emissions associated with petitioners'
biofuel production processes, as well as emissions associated with the
transport and use of the finished biofuel. EPA will combine these
assessments into a full lifecycle GHG analysis used to determine
whether the fuel produced at an individual facility satisfies the CAA
GHG emission reduction requirements necessary to qualify as renewable
fuel or one of the subcategories of renewable fuel under the RFS
program.
---------------------------------------------------------------------------
\3\ Assuming the fuel pathway proposed in such petitions involve
extraction of non-cellulosic beet sugar for conversion to biofuel
and use of the resulting beet pulp co-product as animal feed.
---------------------------------------------------------------------------
II. Analysis of GHG Emissions Associated With Production and Transport
of Sugar Beets for Use as a Biofuel Feedstock
A. Overview of Beta vulgaris ssp. vulgaris (Sugar Beets)
Beta vulgaris ssp. vulgaris, (commonly known as sugar beets) of the
order Caryophylalles, is a widely cultivated plant of the Altissima
group. Sugar beets are cultivated for their high percentage
concentration of sucrose in their root mass. Domestication of the plant
group took place approximately 200 years ago in Europe to selectively
breed for sugar content from crosses between Beta vulgaris cultivars,
including chard plants and fodder beets.\4\
---------------------------------------------------------------------------
\4\ Juliane C. Dohm et al., ``The Genome of the Recently
Domesticated Crop Plant Sugar Beet (Beta Vulgaris),'' Nature 505,
no. 7484 (January 23, 2014): 546-49.
---------------------------------------------------------------------------
Sugar beets are a biennial crop species grown across a wide
tolerance of soil conditions in areas of temperate climate, and tend to
be grown in rotation with other plant varieties.\5\ Sugar beets are
grown for their relatively high sugar content, approximately 13 to 18
percent of the plant's total mass, with around three quarters of the
plant mass comprised of water.\6\ Once harvested, sugar beets are
highly perishable and need to be processed in a short period of
time.\7\
---------------------------------------------------------------------------
\5\ Michael J. McConnell, ``USDA ERS--Background,'' Crops Sugar
& Sweeteners Background, October 12, 2016, https://www.ers.usda.gov/topics/crops/sugar-sweeteners/background/.
\6\ FAO, ``Sugar Crops and Sweeteners and Derived Products,''
accessed November 30, 2016, https://www.fao.org/es/faodef/fdef03e.HTM.
\7\ Michael J. McConnell, ``USDA ERS--Policy,'' USDA ERS--
Policy, November 1, 2016, https://www.ers.usda.gov/topics/crops/sugar-sweeteners/policy.aspx.
---------------------------------------------------------------------------
According to the U.S. Department of Agriculture (USDA), the largest
region for sugar beet production is the area of the Red River Valley of
western Minnesota and eastern North Dakota, and sugar beets are
commonly grown at agricultural scale across five regions of the
country, encompassing 11 states.\8\ Western regions tend to require
more irrigation while sugar beets grown in the eastern U.S. region make
greater use of natural rainfall.\9\
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\8\ Michael J. McConnell, ``USDA ERS--Background.''
\9\ Michael J. McConnell, ``USDA ERS--Background.''
---------------------------------------------------------------------------
Since the mid-1990s, sugar beets have accounted for about 55
percent of sugar production in the U.S.\10\ Sugar beets are included in
the U.S. sugar program, designed to support domestic sugar prices
through loans to sugar processors. The U.S. sugar program also includes
a marketing allotment that sets the amount of sugar that domestic
processors can sell in the U.S. for human consumption, and provides
quotas on the amount of sugar that can be imported into the U.S.\11\
Sugar produced under the program cannot be used for biofuel purposes
with an exception for surplus sugar made available under the USDA
Feedstock Flexibility Program that specifically directs the excess
sugar to be used for the purpose of domestic biofuel production.\12\
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\10\ Michael J. McConnell, ``USDA ERS--Background.''
\11\ The U.S. sugar program is managed by USDA and supports
domestic sugar prices through loans to sugar processors, a marketing
allotment program, and quotas on the amount of sugar that can be
imported to the U.S. Farm Security and Rural Investment Act of 2002.
Public Law 107-171, Sec. 1401-1403.
\12\ ``Feedstock Flexibility Program,'' page, accessed November
17, 2016, https://www.fsa.usda.gov/programs-and-services/energy-programs/feedstock-flexibility/index.
---------------------------------------------------------------------------
Like other sugars, beet sugar can be fermented and used as a
feedstock for biofuel production. The non-cellulosic sugars of sugar
beets, the vast majority of which is sucrose, can be converted directly
into a refined sugar available for processes such as alcoholic
fermentation to produce biofuels (e.g., ethanol).\13\ Much of the water
needed
[[Page 34658]]
for the fermentation process is provided by the sugar beets themselves.
Sugar beet pulp is a fibrous co-product of the beet sugar extraction
process.\14\ The sugar beet pulp is often dried to reduce
transportation costs and is widely sold as feed supplement for cattle
and other livestock.\15\ While biofuel production from beet sugar has
historically been limited in the U.S., sugar beets accounted for about
17 percent of European ethanol production in 2014.\16\
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\13\ Dr. Hossein Shapouri, Dr. Michael Salassi, and J. Nelson
Fairbanks, ``The Economic Feasibility of Ethanol Production from
Sugar in the United States'' (USDA, July 2006), https://www.usda.gov/oce/reports/energy/EthanolSugarFeasibilityReport3.pdf.
\14\ Eggleston, Gillian et al., ``Ethanol from Sugar Crops.''
In, Singh, Bharat P., Industrial Crops and Uses. CABI, 2010, pp. 74-
75.
\15\ Greg Lardy, ``Feeding Sugar Beet Byproducts to Cattle,''
accessed November 30, 2016, https://www.ag.ndsu.edu/publications/livestock/feeding-sugar-beet-byproducts-to-cattle.
\16\ ePURE, ``European Renewable Ethanol--Key Figures,''
accessed November 17, 2016, https://epure.org/media/1227/european-renewable-ethanol-statistics-2015.pdf.
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B. Analysis of Upstream GHG Emissions
EPA evaluated the upstream GHG emissions associated with using
sugar beets as a biofuel feedstock based on information provided by
USDA, petitioners, and other data sources. Upstream GHG emissions
include emissions from production and transport of sugar beets used as
a biofuel feedstock. The methodology EPA used for this analysis is
generally the same approach used for the March 2010 RFS rule for
lifecycle analyses of several other biofuel feedstocks, such as corn,
soybean oil, and sugarcane.\17\ The subsections below describe this
methodology, including assumptions and results of our analysis.
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\17\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
---------------------------------------------------------------------------
1. Methodology and Scenarios Evaluated
The analysis EPA prepared for sugar beets used the same set of
models that were used for the March 2010 RFS rule, including the
Forestry and Agricultural Sector Optimization Model (FASOM) developed
by Texas A&M University for domestic impacts, and the Food and
Agricultural Policy and Research Institute international models as
maintained by the Center for Agricultural and Rural Development (FAPRI-
CARD) at Iowa State University for international impacts. For more
information on the FASOM and FAPRI-CARD models, refer to the March 2010
RFS rule preamble (75 FR 14670) and Regulatory Impact Analysis
(RIA).\18\ Several modifications were made to the domestic and
international agricultural economic modeling that differed from
previous analyses in order to accurately represent the U.S. sugar
program.\19\ Memoranda to the docket include detailed information on
model inputs, assumptions, calculations, and the results of our
assessment of the upstream GHG emissions for sugar beet biofuels.\20\
We invite comments on the scenarios and assumptions used for this
analysis, in particular on the key assumptions described in this
section.
---------------------------------------------------------------------------
\18\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
\19\ These differences are discussed further in Sections II.D.2
and II.D.3 below.
\20\ The memoranda and modeling files are available in the
docket. EPA-HQ-OAR-2016-0771.
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Sugar beets grown under the U.S. sugar program cannot be used for
the purpose of biofuel production, except under very limited conditions
specified in the Feedstock Flexibility Program.\21\ Therefore, for this
analysis, EPA assumed that there would be no change in sugar production
on U.S. sugar program-designated acres because of demand for beet sugar
for biofuel feedstock use.\22\ In our modeling, growers selling sugar
beets to sugar processors under the U.S. sugar program in the control
case continued to do so regardless of new demand for sugar beets as a
biofuel feedstock in the test case. As a result of this assumption, in
our modeling, demand for acreage to grow sugar beets for biofuel
feedstock could only be fulfilled by converting acres from other crops
besides sugar beets, and/or from other land uses besides crop
production (e.g., pastureland, Conservation Reserve Program land).
---------------------------------------------------------------------------
\21\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
\22\ The U.S. sugar program designates acres of land used to
grow sugar beets sold to domestic sugar processors who receive price
support loans and are regulated by USDA market allotments under the
program.
---------------------------------------------------------------------------
Our analysis also considers the significant restrictions on the
trade of sugar beets between the U.S. and other countries. The U.S.
does not export beet sugar, as this would violate the terms of
participation in the sugar program. While the U.S. does import cane
sugar under international agreements, it does not import raw beet
sugar.\23\ Beet sugar may only enter the U.S. as refined sugar from
Canada or Mexico under the North American Free Trade Agreement (NAFTA)
and similar trade agreements, or as components of sugar-containing
products.\24\ This quantity is strictly regulated. EPA is unaware of
existing trade agreements that would allow raw beet sugar imports for
any purpose, including biofuel production. This makes it unlikely that
beet sugar would be imported for use as biofuel feedstock.
---------------------------------------------------------------------------
\23\ The international agreements that allow for sugar import to
the U.S. are primarily governed by NAFTA and the Uruguay Round
Agreement on Agriculture, but also by CAFTA. See USDA's Web site on
the Sugar Import Program for more details: https://www.fas.usda.gov/programs/sugar-import-program (Last accessed December 30, 2016).
\24\ Mark A. McMinimy, ``U.S. Sugar Program Fundamentals,''
April 6, 2016, https://fas.org/sgp/crs/misc/R43998.pdf.
---------------------------------------------------------------------------
Although sugar beets were modeled as grown in the U.S., we also
intend that this analysis would cover sugar beets grown and processed
into biofuels from other countries and imported to the U.S. as finished
biofuel. We expect the vast majority of beet sugar-based biofuel used
in the U.S. will come from sugar beets produced in the U.S., and
incidental amounts of fuel from crops produced in other nations will
not impact our average GHG emissions. Sugar beets require similar
climatic regions as those where they are grown in the U.S., and would
similarly impact crops such as wheat in those regions while sugar beet
pulp would displace corn as livestock feed. Therefore, EPA interprets
this upstream analysis as applicable, regardless of the country of
origin assuming that sugar beet pulp is used as a livestock feed
supplement.
To assess the impacts of an increase in sugar beet demand for
renewable fuel production, EPA modeled two scenarios: (1) A control
case with ``business-as-usual'' assumptions \25\ and no biofuel
production from sugar beets
[[Page 34659]]
and (2) a sugar beet biofuel case where 300 million ethanol-equivalent
gallons of biofuels are assumed to be from beet sugar in 2022,
requiring the use of 12 million wet short tons of sugar beets for
biofuel production. The analysis presented in this notice considered
all GHG emissions associated with the cultivation and production of
sugar beets intended for biofuel feedstock use, as well as emissions
from transporting these sugar beets to a biofuel production facility.
In lifecycle analysis literature these emissions are often referred to
as the ``upstream'' emissions, because they occur upstream of the fuel
production facility (i.e., before the biofuel feedstock arrives at that
facility).
---------------------------------------------------------------------------
\25\ To assess the impacts of an increase in renewable fuel
volume from business-as-usual (what is likely to have occurred
without the RFS biofuel mandates) to levels required by the statute,
we established a control case and other cases for a number of
biofuels. The control case included a projection of renewable fuel
volumes that might be used to comply with the RFS renewable fuel
volume mandates in full. The case is designed such that the only
difference between the scenario case and the control case is the
volume of an individual biofuel, all other volumes remaining the
same. In the March 2010 RFS rule, for each individual biofuel, we
analyzed the incremental GHG emission impacts of increasing the
volume of that fuel from business as usual levels to the level of
that biofuel projected to be used in 2022, together with other
biofuels, to fully meet the CAA requirements. Rather than focus on
the GHG emissions impacts associated with a specific gallon of fuel
and tracking inputs and outputs across different lifecycle stages,
we determined the overall aggregate impacts across sectors of the
economy in response to a given volume change in the amount of
biofuel produced. For this analysis, we compared impacts in the
control case to the impacts in a new sugar beets case. The control
case used for the March 2010 RFS rule, and used for this analysis,
has zero gallons of sugar beet biofuel production.
---------------------------------------------------------------------------
The analysis presented in this notice does not include fuel
production or ``downstream'' emissions, which consists of emissions
associated with fuel transport and fuel combustion. Once comments on
the upstream emissions described in this notice have been considered,
we intend to combine the upstream analysis with the fuel production and
downstream emissions associated with fuel produced at an individual
biofuel facility to determine the lifecycle GHG emissions associated
with that fuel. This lifecycle analysis would reflect any differences
in emissions that may exist between producing different types of
biofuels from sugar beets. Our analysis of the upstream emissions
associated with sugar beets assumed that non-cellulosic sugars are
extracted from the beets before the sugars are converted, and that the
beet pulp would then be sold into feed markets. Fuel production methods
that also convert the pulp into fuel (e.g., through pyrolysis of the
beet) or use the pulp for other purposes may not be compatible with
this analysis.
We evaluated a scenario with biofuels produced from this amount of
sugar beets for multiple reasons. Although biofuel production from
sugar beets is currently small in the U.S., recent trends in domestic
sugar beet yields and acreage indicate that 12 million wet short tons
of sugar beets could be produced as biofuel feedstocks if a significant
market demand emerged. An additional 12 million wet short tons of sugar
beets would represent a 34 percent increase in U.S. sugar beet
cultivation compared to 2015 levels.\26\ According to USDA data,
harvested acres of sugar beets since 2010 were, on average, about 30
percent lower than their most recent peak levels in the 1990s, an
average difference of approximately 360,000 harvested acres.\27\
Increasing beet yields over time has reduced the number of acres needed
to satisfy production targets under the U.S. sugar program.\28\
National average sugar beet yields since 2010 have been approximately
25 percent higher than yields during the 1990s, and reached almost 31
wet short tons per acre in the 2015 crop year.\29\ Were beet acres to
return to their 1990s peak, the additional approximately 360,000
harvested acres would produce about 11.2 million wet short tons of
beets at these 2015 yield levels. However, based on the steady increase
in yields over time, it seems likely that beet yields will continue to
increase between now and 2022. If national average beet yields reach at
least 33.4 wet short tons per acre by 2022, a fairly modest increase of
about 8 percent over 2015 levels, an additional 12 million wet short
tons of beets could be produced on these additional 360,000 acres.
Since further expansion of beet area beyond the historical peak is also
possible, an increase in beet production of 12 million wet short tons
appears to be very feasible. We welcome comment on this assumption.
---------------------------------------------------------------------------
\26\ See, USDA, ``Sugarbeet Area and Planted Harvested Yield and
Production States and United States 2013-2015,'' in Crop Production
2015 Summary, January 2016, ISSN: 1057-7823, https://usda.mannlib.cornell.edu/usda/current/CropProdSu/CropProdSu-0112-2016.pdf. This assumes an ethanol conversion rate of 25 gallons of
ethanol/wet short ton of beets.
\27\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\28\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\29\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
---------------------------------------------------------------------------
In our analysis, FASOM allowed for sugar beet production in all
areas of the continental 48 states where sugar beets had been grown
historically, including states and areas that do not currently take
part in the U.S. sugar program. The model was allowed to determine
which of these regions would be optimal for growing sugar beets for
biofuel feedstock, based on least cost of production and transport, and
considering the opportunity cost of using that land for other uses
(e.g., to produce other crops, grazing, forestry). The factors that
contributed to these crop production choices include crop yield, input
quantities, and growing strategies.
Following the methodology established in the March 2010 RFS rule,
EPA used the FAPRI model to evaluate the international impacts of
producing and transporting 12 million wet short tons of sugar beets for
biofuel production in the U.S. The FAPRI model included a
representation of the U.S. sugar program, and modeled domestic sugar
production as a function of this program. Production and consumption
levels in the U.S. were set according to the parameters of the sugar
program and were not affected by market forces. Because the existing
U.S. sugar production module in FAPRI did not respond to market forces,
for modeling purposes EPA had to make assumptions regarding in which
regions sugar beets for biofuel feedstock use would be grown. Crop
yields and the quantity of crop area displaced by expanded sugar beet
production also had to be set by assumption, since the U.S. sugar
module in FAPRI lacks market forces to create demand-pull for new beet
acres. In order to derive the quantity of crop area displaced, EPA used
a crop yield of approximately 26 wet short tons per acre, the 10-year
national average yield for sugar beets (for crop years 2005 through
2014).\30\ Actual yields on any given acre may be higher or lower than
this assumed value, based on factors such as location, annual variation
in growing conditions, growing practices, and crop rotation strategies.
Because the FAPRI analysis assumed to displace acres in North Dakota
and California, we did not believe that it was appropriate to use the
USDA 2022 national average projections for sugar beets yield. As an
alternative, EPA believes using the 10-year national average was a
reasonable assumption for our international agricultural sector
modeling. The increase in sugar yield trends over the last few decades
suggests that future yields are unlikely to be lower than the 10-year
average. As further support for our yield assumptions in FAPRI, we note
that FASOM projected sugar beet yields in 2022 that are close to the
assumptions used in FAPRI.\31\ We welcome comment on this assumption.
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\30\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\31\ See ``Sugar Beets for Biofuel Upstream Analysis Technical
Memorandum'' in the docket for details. EPA-HQ-OAR-2016-0771.
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For the purposes of FAPRI modeling, EPA assumed that sugar beets
for fuel use would be produced in equal amounts in North Dakota and
California for the following reasons: At the onset of our analysis,
these were the regions with indications of significant sugar beet
biofuel interest.\32\ They are also
[[Page 34660]]
both regions with a long history of sugar beet production. As a
simplifying assumption, EPA assumed that all crops grown in each of
these regions were displaced by sugar beets proportionally to their
crop area in the control case. We recognize there are significant
differences in the way the sugar beet biofuel scenarios were
implemented in FASOM and FAPRI for this analysis. For example, FASOM
chose to produce all sugar beets for biofuels in North Dakota, whereas
in FAPRI we modeled this production in North Dakota and California by
assumption. Since these modeling exercises occurred concurrently, not
sequentially, we could not anticipate what choices FASOM would make at
the outset of our FAPRI modeling. This led to some differences in the
regions utilized to produce beets. However, the nationwide agricultural
market results projected by FASOM and FAPRI were similar, due to
similar dominant trends in feed markets and crop exports at the
national level. The similarity of these relevant national market
results between the two models, despite differences in U.S. growing
regions, indicates that the international impacts projected by the
FAPRI model would not have been significantly different if we had
applied the growing assumptions from FASOM. These results are discussed
below and are available in the docket for this notice.\33\ We welcome
comment on these assumptions and our results.
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\32\ At the time of this modeling we had received the petitions
from Green Vision Group proposing to produce ethanol from sugar
beets grown in North Dakota and Tracy Renewable Energy proposing to
produce ethanol from sugar beets grown in California but we had not
received the petition from Plant Sensory Systems proposing to
produce ethanol from sugar beets grown in Florida. EPA does not
expect results would have varied significantly if sugar beets had
been modeled by assumption in Florida under FAPRI due to the
similarity of these results to the results from FASOM.
\33\ See EPA-HQ-OAR-2016-0771.
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The sugar beet scenario modeled included a number of key
assumptions, such as biofuel and pulp yields per wet short ton of
beets, and the amount of corn livestock feed displaced per pound of
pulp. These key assumptions are discussed below. Information on
additional assumptions, including sugar beet crop inputs (e.g.,
fertilizer, energy) is available in the docket for this notice.
In conducting research for this analysis, we located sources for
beet pulp yield of 0.06 dry short tons of sugar beet pulp per wet short
tons of sugar beets \34\ and displacement rates of 0.9 pounds of corn
feed displaced in cattle diets \35\ for every pound of sugar beet pulp.
In livestock production, the fibrous sugar beet pulp is used as a
roughage replacement making it of use primarily for ruminants rather
than other types of livestock.\36\ In our analysis, sugar beet pulp use
by the livestock market was an important factor leading to GHG
reductions. Therefore this notice evaluates only using the non-
cellulosic portion of sugar beets for biofuel production.
---------------------------------------------------------------------------
\34\ Panella, Lee and Stephen R. Kaffka, ``Sugar Beet (Beta
vulgaris L) as a Biofuel Feedstock in the United States.'' Chapter
10 in Sustainability of the Sugar and Sugar Ethanol Industries;
Eggleston, G.; ACS Symposium Series; American Chemical Society:
Washington DC, 2010, pp. 165.
\35\ To make a simplifying assumption, we averaged the value
from corn in backgrounding diets and finishing diets. Lardy, Greg,
and Rebecca Schafar, ``Feeding Sugar Beet Byproducts to Cattle,''
North Dakota State University, May 2008, pp. 2.
\36\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets''.
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2. Domestic Impacts
On the basis of least cost, FASOM chose to grow all sugar beets in
North Dakota, with approximately 477,000 acres of land required to grow
the additional sugar beets.
The vast majority of the new sugar beet acres in North Dakota was
from displacement of other crops rather than from new cropland (432,000
acres from displaced crops, or nearly 91 percent of needed acres).
Increasing sugar beet production in North Dakota primarily displaced
wheat acreage, but also soybeans, corn, and hay among other crops.\37\
Most of these displaced crops shifted to other U.S. regions, and some
crops, such as soybeans, shifted to new acreage that was more
productive than the North Dakota acres from where they were displaced.
Table II.1 indicates that production levels for hay, soy, and most
other crops are maintained.\38\ However, national crop area and
production for wheat and corn declined significantly.
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\37\ See ``FASOM Sugar Beets Results'' in the docket. EPA-HQ-
OAR-2016-0771.
\38\ Soy is captured in the ``All Else'' category in Table II.1.
See ``FASOM Sugar Beets Results'' in the docket EPA-HQ-OAR-2016-0771
for more detail.
Table II.1--Changes in U.S. Production (Million Pounds) and Harvested
Area (Thousand Acres) in 2022 Relative To Control Case \39\
------------------------------------------------------------------------
Harvested area
Production difference
difference from control
from control case
case (million (thousand
pounds) acres)
------------------------------------------------------------------------
Sugar Beets............................. +23,976 +477
Hay..................................... +8 -106
Corn.................................... -867 -96
Wheat................................... -352 -98
All Else................................ +3 -56
-------------------------------
Total............................... +22,768 +121
------------------------------------------------------------------------
The reductions in corn and wheat production were driven by
different proximate causes (though both were ultimately driven by
increased demand for sugar beets) and led to somewhat different impacts
on commodity use and trade. In the case of wheat, the decline in
production led to a decline in exports. As shown in Section II.B.3, the
decline in wheat exports created pressure on international wheat
markets and wheat production increased outside the U.S.
---------------------------------------------------------------------------
\39\ Totals may differ from subtotals due to rounding.
---------------------------------------------------------------------------
In the case of corn, the potential market impacts were mitigated by
the increased availability of sugar beet pulp into U.S. feed markets as
a result of beet sugar biofuel production. As described in Section
II.A, sugar beet pulp is a co-product used as livestock feed
supplement, mainly substituting for corn. Based on the FASOM results
for 2022, approximately 1.4 billion pounds of sugar beet pulp were
produced and sent to the feed market. In turn this displaced
approximately 1.2 billion pounds of corn, which was significantly
greater than the approximately 867 million pounds of corn production
lost to displaced acres. This led to a decrease in total demand for
corn in U.S. markets and, as a result, U.S. exports of corn increased.
As discussed in Section II.B.3 below, this reduced the price of corn
internationally and lessened the demand pull for corn to be grown in
other countries.
The rest of the needed sugar beet acres in North Dakota,
approximately 46,000 acres, came from new cropland, particularly from
cropland pasture (high-value pasture land that can also be utilized as
cropland with minimal preparation) and from acres that would otherwise
take part in the Conservation Reserve Program. Pasture area rose
modestly in some other states causing the conversion of some forest
acres to pasture. This relatively small decrease in forestland pushed
up prices slightly for forest products, leading foresters to intensify
growth on their stands. Relative to other feedstocks EPA has evaluated
for the RFS program, these domestic shifts in land use were minor, and
after the various land use changes were considered the net domestic
land use change emissions impacts were close to zero.
3. International Impacts
In the FAPRI model, the expansion of sugar beet cropland used to
produce biofuel feedstock also led to increases in corn exports and
decreases in wheat exports. Similar to the drivers of the
[[Page 34661]]
domestic results discussed in Section II.B.2, beet production displaced
wheat acres, but the beet pulp co-product reduced domestic demand for
corn. Further, the magnitude of these export impacts was quite similar
between the two models, as shown in Table II.2 below.\40\
---------------------------------------------------------------------------
\40\ Impacts on the exports of other crops were relatively
minor, but interested readers can examine the full set of FAPRI crop
trade impacts in the docket.
Table II.2--Changes in U.S. Corn and Wheat Exports in 2022 Relative To
Control Case by Model
[Million pounds]
------------------------------------------------------------------------
Difference Difference
from control from control
case in FASOM case in FAPRI
------------------------------------------------------------------------
Corn.................................... +307 +355
Wheat................................... -292 -281
------------------------------------------------------------------------
With sugar beet pulp displacing corn feed, FAPRI modeling indicated
that in 2022, both corn production and acreage would decline globally.
Production outside the U.S. of certain other crops however increased in
response to U.S. increasing demand for sugar beets; most significantly
wheat and soybeans. Wheat increased internationally in terms of both
production and acreage, with a strong response particularly in India.
Soybean acres and production also increased, particularly in Brazil.
Table II.3 below summarizes the non-U.S. increases in harvested area by
crop type, while Table II.4 shows which countries had the largest
impacts.
Table II.3--Non-U.S. Harvested Area by Crop in 2022 Relative To Control
Case
[Thousand acres] \41\
------------------------------------------------------------------------
Difference
from control
case
------------------------------------------------------------------------
Sugar Beets............................................. 0
Corn.................................................... -45
Wheat................................................... +43
Soybeans................................................ +20
All Else................................................ +37
---------------
Total............................................... +55
------------------------------------------------------------------------
As increasing sugar beet pulp use for livestock feed in the U.S.
freed up more corn for export, international livestock feed prices
declined modestly, and with it was a small rise in meat production
globally. Many of these changes occurred in Brazil and this caused some
expansion in grazing land, including in the Amazon region. This caused
further international land use change impacts, as shown in Table II.4
below.
---------------------------------------------------------------------------
\41\ These totals do not include pastureland in Brazil. Totals
may differ from subtotals due to rounding.
\42\ Totals may differ from subtotals due to rounding. Brazil
totals include pastureland. Other regions are cropland only.
Table II.4--Non-U.S. Changes in Agricultural Land by Region in 2022 Relative To Control Case
[Thousand acres] \42\
----------------------------------------------------------------------------------------------------------------
Change in Change in Total change
area harvested pasture acres in acres
----------------------------------------------------------------------------------------------------------------
Brazil.......................................................... +9 +20 +29
India........................................................... +15 .............. +15
Rest of Non-USA................................................. +32 .............. +32
-----------------------------------------------
Total Non-USA............................................... .............. .............. +75
----------------------------------------------------------------------------------------------------------------
4. Feedstock Transport
When harvested, sugar beets are heavy and perishable; therefore,
transport of sugar beets from field to processing site is expected to
occur over short distances. Information from stakeholders and
literature states that sugar beets used for biofuels are shipped by
truck from point of production to the plant with typical distances for
transport around 30 miles.\43\ GHG emissions for the transport of sugar
beets are based on emission factors developed for the March 2010 RFS
rule for trucks including capacity, fuel economy, and type of fuel
used.\44\
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\43\ Farahmand, K., N. Dharmadhikari, and V. Khiabani.
``Analysis of Transportation Economics of Sugar-Beet Production in
the Red River Valley of North Dakota and Minnesota using
Geographical Information System.'' Journal of Renewable Agriculture
7(2013):126-131.
\44\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
---------------------------------------------------------------------------
5. Results of Upstream GHG Lifecycle Analysis
As described above, EPA analyzed the GHG emissions associated with
feedstock production and transport. Table II.5 below breaks down by
stage the calculated GHG upstream emissions for producing biofuels from
sugar beets in 2022.
Table II.5--Upstream GHG Lifecycle Emissions for Sugar Beets
[gCO2-eq/wet short ton]
------------------------------------------------------------------------
Emissions (gCO2-eq/wet
Process short ton)
------------------------------------------------------------------------
Net Agriculture (w/o land use change)....... +21,615
Domestic Land Use Change.................... -882
International Land Use Change, Mean......... +16,038
(Low/High).................................. (+9249/+23,672)
[[Page 34662]]
Feedstock Transport......................... +8,183
---------------------------
Total Upstream Emissions, Mean.......... +44,954
(Low/High).............................. (+38,210/+52,588)
------------------------------------------------------------------------
Net agricultural emissions included domestic and international
impacts related to changes in crop inputs such as fertilizer, energy
used in agriculture, livestock production, and other agricultural
changes in the scenario modeled. Increased demand for sugar beets
resulted in positive net agricultural emissions relative to the control
case. Compared with other crops, sugar beets required relatively high
levels of agricultural chemical inputs (e.g., herbicides and
pesticides).\45\ Domestic land use change emissions were close to zero
for sugar beets, as described in Section II.B.2.
---------------------------------------------------------------------------
\45\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets''.
---------------------------------------------------------------------------
International land use change emissions increased as a result of
demand for sugar beets. The increase in international land use change
emissions for sugar beets was significantly larger than the decrease in
domestic land use change emissions. This is because increased demand
for sugar beets led to a significant reduction in key U.S. crop exports
(e.g., wheat exports), but very little change in domestic consumption
of agricultural goods. These greater international emissions led to a
net increase in global land use change emissions. Feedstock transport
included emissions from moving sugar beets from the farm to a biofuel
production facility, as described in Section II.B.4 above.
6. Fuel Production and Distribution
Sugar beets are suitable for the same biofuel conversion processes
as sugarcane. In Europe, where sugar beets are widely used as biofuel
feedstock, virtually all of the fuel is non-cellulosic beet sugar
ethanol produced through fermentation with the beet pulp sold into the
feed markets. Based on these data, and on information from our
petitioners and other stakeholders, EPA anticipates that most biofuel
produced from sugar beets in the U.S. would also be from the non-
cellulosic sugars via fermentation. Our upstream analysis would apply
for all facilities where non-cellulosic beet sugar is converted to
biofuel and the co-product beet pulp is used as animal feed.
Given the importance of the beet pulp co-product on the upstream
GHG emissions associated with beet pulp, pathways that do not produce a
beet pulp feed coproduct, or use it for purposes other than animal
feed, may not be compatible with our analysis. EPA would likely need to
conduct supplemental upstream GHG analysis in order to determine the
lifecycle GHG emissions associated with fuels produced under these
types of pathways.
After reviewing comments received in response to this action, EPA
will combine the evaluation of upstream GHG emissions associated with
the use of sugar beet feedstock with an evaluation of the GHG emissions
associated with individual producers' production processes and finished
fuels to determine whether fuel produced at petitioners' facilities
from the sugar in sugar beets satisfy the CAA lifecycle GHG emissions
reduction requirements for renewable fuels. Each biofuel producer
seeking to generate Renewable Identification Numbers (RINs) for non-
grandfathered volumes of biofuel from sugar beets will 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).\46\
---------------------------------------------------------------------------
\46\ Petitioners with pending petitions involving use of sugar
from sugar beets as feedstock will not be required to submit new
petitions. However, if any information has changed from their
original petitions, EPA will request that they update that
information.
---------------------------------------------------------------------------
Because EPA is evaluating the GHG emissions associated with the
production and transport of sugar beet feedstock through this notice
and comment process, petitioners requesting EPA's evaluation of biofuel
pathways involving sugar beet feedstock need not include the
information for new feedstocks specified at 40 CFR 80.1416(b)(2). Based
on our evaluation of the upstream GHG emissions attributable to the
production and transport of sugar beet feedstock, including our
assumptions regarding the average yield of ethanol in mmBtu per wet
short ton of sugar beets used, EPA anticipates that if a facility
produces emissions of no more than approximately 23 kgCO2e/
mmBtu of ethanol, the fuel produced would meet the 50 percent advanced
biofuel GHG reduction threshold.\47\ If a facility produces no more
than 53 kgCO2e/mmBtu of ethanol, EPA anticipates it would
meet the 20 percent renewable fuel GHG reduction threshold. EPA will
evaluate petitions for fuel produced from sugar beet feedstock on a
case-by-case basis, and will make adjustments as necessary for each
facility including consideration of differences in the yield of ethanol
per wet short ton of sugar beets used.\48\ We welcome comments on this
application of our upstream analysis.
---------------------------------------------------------------------------
\47\ In this case, emissions produced by the facility refers to
fuel production emissions, including emissions associated with
energy used for fuel, feedstock and co-product operations at the
facility. For more details on the assumptions used in this analysis,
see ``Sugar Beets for Biofuel Upstream Analysis Technical
Memorandum'' in the docket. EPA-HQ-OAR-2016-0771.
\48\ For example, EPA may need to consider additional feedstock
transportation emissions in cases where beet sugar extraction and
biofuel production do not occur in the same location, as may be the
case for biofuel produced under the USDA Feedstock Flexibility
Program.
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7. Risk of Potential Invasiveness
Sugar beets were not listed on the Federal noxious weed list nor
did they appear on USDA's composite listing of introduced, invasive,
and noxious plants by U.S state.49 50 Based on consultation
with USDA, EPA does not believe sugar beets pose a risk of invasiveness
at this time. Current cultivars of sugar beets require extensive weed
management to survive.\51\ However, USDA notes that future cross
breeding, hybridization, and genetic manipulation could change the
[[Page 34663]]
invasiveness potential of beets, in which case a re-evaluation may be
required.\52\ Based on currently available information, EPA does not
believe monitoring and reporting of data for invasiveness concerns
would be a requirement for biofuel producers generating fuel from sugar
beets at this time.
---------------------------------------------------------------------------
\49\ USDA, ``Federal Noxious Weed List,'' July 13, 2016, https://www.aphis.usda.gov/plant_health/plant_pest_info/weeds/downloads/weedlist.pdf.
\50\ USDA, ``State and Federal Noxious Weeds List,'' accessed
November 17, 2016, https://plants.usda.gov/java/noxComposite.
\51\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
\52\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
---------------------------------------------------------------------------
III. Summary
EPA invites public comment on its analysis of GHG emissions
associated with the production and transport of sugar beets as a
feedstock for biofuel production. This notice analyzes a non-cellulosic
sugar beet-to-biofuel production process. Although EPA has not received
a petition for cellulosic sugar beet biofuel production, the agency is
aware of interest in this process and invites comment on the analysis
of beet pulp and its effect on agricultural markets. EPA will consider
public comments received when evaluating petitions received pursuant to
40 CFR 80.1416 that involve pathways using sugar beets as a feedstock.
Dated: January 18, 2017.
Christopher Grundler,
Director, Office of Transportation and Air Quality, Office of Air and
Radiation.
[FR Doc. 2017-15721 Filed 7-25-17; 8:45 am]
BILLING CODE 6560-50-P
