RFA expresses EPA rulemaking concerns
In the US, the Renewable Fuels Association (RFA) is requesting more transparency over the Environmental Protection Agency’s (EPA) Renewable Fuel Standard Notice of Proposed Rulemaking.
The RFA says many of the models, data sets, and other pertinent pieces of information used by EPA for its lifecycle analysis are not publicly available, preventing third parties like the RFA from replicating and validating EPA’s work.
‘Such transparency is absolutely critical so that constructive comments and peer reviews can be completed effectively,’ the RFA states.
EPA’s inclusion of the highly uncertain theories of international land use effects and indirect emissions in their greenhouse gas emissions calculation for biofuels makes the need for access to how EPA connected the dots that much more imperative, the RFA says.
The RFA has expressed its concerns in a letter to EPA requesting more information and access to the entire EPA modeling framework.
Requests in the letter include: the EPA should provide public access to the FAPRI system of models as configured for the RFS analysis. This should include all assumptions, inputs, price and demand elasticities used, outputs for all scenarios and sensitivity cases, and other pertinent information.
The RFA says many of the models, data sets, and other pertinent pieces of information used by EPA for its lifecycle analysis are not publicly available, preventing third parties like the RFA from replicating and validating EPA’s work.
‘Such transparency is absolutely critical so that constructive comments and peer reviews can be completed effectively,’ the RFA states.
EPA’s inclusion of the highly uncertain theories of international land use effects and indirect emissions in their greenhouse gas emissions calculation for biofuels makes the need for access to how EPA connected the dots that much more imperative, the RFA says.
The RFA has expressed its concerns in a letter to EPA requesting more information and access to the entire EPA modeling framework.
Requests in the letter include: the EPA should provide public access to the FAPRI system of models as configured for the RFS analysis. This should include all assumptions, inputs, price and demand elasticities used, outputs for all scenarios and sensitivity cases, and other pertinent information.
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