In a 40 page letter submitted to the Environmental Protection Agency (EPA), UNICA, the organization representing the Brazilian sugarcane industry, noted that even accounting for theoretical Indirect Land Use Changes, sugarcane ethanol reduces greenhouse gas emissions (GHGs) by up to 85 percent. In addition, the organization cites that sugarcane ethanol is a viable way to help the U.S. meet the advanced biofuels requirements of RFS2 (Renewable Fuels Standard).

“We emphatically demonstrated, with verifiable scientific evidence, that Brazilian ethanol is certainly an appropriate alternative for meeting the advanced biofuel requirements of RFS2,” says UNICA’s Chief Representative for North America, Joel Velasco.

The implementation of RFS2 is more than a year delayed and court actions could be taken if the EPA doesn’t take action quickly. One area of concern has been the question of whether the ethanol industry will, or can, meet the cellulosic ethanol requirements. To alleviate this issue, UNICA has suggested modifying the rules to include advanced biofuels such as sugarcane, rather than drowning cellulosic ethanol via the action of waiving that portion of the mandate.

According to EPA calculations, Brazilian cane ethanol reduces GHG emissions by 44 percent considering a 2005 gasoline baseline. That would classify sugarcane ethanol as an advanced biofuel. Nevertheless, under suggested revisions, UNICA points out that sugarcane ethanol would reduce GHG emissions by 82 percent or more.

“We are confident that EPA will make an independent, scientific determination that sugarcane ethanol qualifies as an advanced biofuel under RFS2,” concludes Velasco.