Since Brazil’s new RenovaBio program will likely cause significant growth in the country’s biofuels consumption, the Renewable Fuels Association (RFA) wants to make sure their methodology for estimating carbon intensity correctly reflects the emissions impacts of corn ethanol.

Under RenovaBio, which was approved in late December 2017, the average carbon intensity (CI) of gasoline must be reduced by 10.1% by 2028. In comments to Brazil’s Ministry of Mines and Energy, RFA focused on the draft CI calculation tool (known as “RenovaCalc”) that will be used to determine CI values for various biofuel pathways.

“Given that many of our member companies produce ethanol that is exported to Brazil, the pathway for imported corn ethanol is of particular interest to RFA….[I]t is imperative that the CI scoring of biofuel pathways under RenovaBio is conducted in an accurate, transparent, and science-based manner,” RFA explained in its comments.

RFA is seeking clarity on the wide discrepancy between CI scores for imported corn ethanol and Brazil-produced corn ethanol. Under preliminary RenovaCalc estimates, imported corn ethanol is found to reduce GHG emissions by more than 50% compared to Brazilian gasoline. Meanwhile, Brazil-produced corn ethanol is found to reduce GHG emissions by 70%.

With certain further refinements, RFA said it believes the calculator can provide both regulators and regulated entities with reliable estimates of the CI associated with various fuel pathways.