The Renewable Fuels Association today released comments to be filed with the Environmental Protection Agency regarding proposed regulations to implement the expanded renewable fuel standard (RFS) program enacted by Congress in the Energy Independence and Security Act (EISA) in 2007.

“Reducing America’s dependence on foreign oil was part of the Energy Security Act, providing economic opportunity and job creation and supporting rural communities were all equally important goals,” said RFA president and CEO Bob Dinneen during a press conference to announce the organization’s comments. “We’re concerned that EPA appears to be ignoring those objectives as it pursues greenhouse gas reduction based on unproven theory.”

In specific comments to be submitted to EPA, Dinneen says they will stress that, “International indirect land use change simply should not be included,” Dinneen said. “Congress did not intend to penalize America’s ethanol producers for decisions made by farmers and governments in other countries.”

The RFA also released a report conducted by Informa Economics that will be included in comments submitted to the EPA. “It calculates that the land needed to meet the demands of the growing RFS mandate would be in the range of 2.2 million acres,” said Dinneen. “Put in perspective, that is one half of one percent of U.S. crop land, one tenth of one percent of world cropland, and six 100ths of a percent of world arable land – certainly not enough to have any meaningful impact on greenhouse gases across the globe.”

Dinneen says RFA is in the process of finalizing its comments to EPA, which will be submitted tomorrow on the final day of the comment period.

Listen to Dinneen’s opening comments here: