Yesterday, Growth Energy submitted comments on EPA’s first triennial report to Congress on the environmental impacts of biofuels. The organization’s comments are focused on the technical accuracy and potential implications of the Report and its implications to ethanol. The Report is required by EISA Section 204 and calls for EPA to report to Congress on the environmental and resource conservation impacts of increased biofuel production and use.

Several areas are considered in the Report including air and water quality, soil quality and conservation, water availability, ecosystem health and biodiversity, invasive species, and international impacts. In addition the report reviews impacts and mitigation tools across the biofuel supply chain including feedstock production and logistics as well as biofuel production, distribution and use. Finally, the Report focused on ethanol, both conventional (aka corn-based) and advanced (or cellulosic) as well as biomass-based diesel.

In the letter, Growth Energy wrote, “As an organization of ethanol producers, we have considerable experience in life cycle analysis (LCA) and knowledge of biofuel production, distribution and use. We would appreciate the opportunity to work with EPA, USDA, DOE and other agencies in conducting the LCA for the next triennial report due in 2013. Prior to such an analysis, it is premature to use the conclusions and recommendations from this Report to inform policy or regulatory decisions.” Click here to download Growth Energy’s full comments.

The Renewable Fuels Association (RFA) also responded to the report and RFA President and CEO Bob Dinneen said, “EPA took the ‘Murphy’s Law’ approach to this draft report—they assumed if it can go wrong, it will go wrong.”

Dinneen continued, “RFA is greatly concerned that EPA has misinterpreted and expanded the scope of the triennial report as established by the Energy Independence and Security Act (EISA). Specifically, EISA compels EPA to assess only those environmental impacts that are likely to result from the requirements of the Renewable Fuels Standard (RFS). Unfortunately, EPA’s draft report seems to raise every conceivable environmental problem that could possibly arise from biofuels expansion, without any regard for the actual likelihood that the problem will occur.” Click here to download RFA’s full comments.

Both organizations have reached out to the EPA to schedule meetings to address their concerns prior to the final report being submitted.