[Federal Register Volume 82, Number 142 (Wednesday, July 26, 2017)]
[Notices]
[Pages 34656-34663]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-15721]
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ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2016-0771; FRL-9958-88-OAR]
Notice of Opportunity To Comment on an Analysis of the Greenhouse
Gas Emissions Attributable to Production and Transport of Beta vulgaris
ssp. vulgaris (Sugar Beets) for Use in Biofuel Production
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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SUMMARY: In this notice, the Environmental Protection Agency (EPA) is
inviting comment on its analysis of the upstream greenhouse gas
emissions attributable to the production of Beta vulgaris ssp. vulgaris
(sugar beets) for use as a biofuel feedstock. This notice describes
EPA's greenhouse gas analysis of sugar beets produced for use as a
biofuel feedstock, and describes how EPA may apply this analysis in the
future to determine whether biofuels produced from sugar beets meet the
necessary greenhouse gas reduction threshold required for qualification
as renewable fuel under the Renewable Fuel Standard program. This
notice considers a scenario in which non-cellulosic beet sugar is
extracted for conversion to biofuel and the remaining beet pulp co-
product is used as animal feed. Based on this analysis, we anticipate
that biofuels produced from sugar beets could qualify as renewable fuel
or advanced biofuel, depending on the type and efficiency of the fuel
production process technology used.
DATES: Comments must be received on or before August 25, 2017.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2016-0771, at http://www.regulations.gov. Follow the online
instructions for submitting comments. Once submitted, comments cannot
be edited or withdrawn from Regulations.gov. The EPA may publish any
comment received to its public docket. Do not submit electronically any
information you consider to be Confidential Business Information (CBI)
or other information whose disclosure is restricted by statute.
Multimedia submissions (audio, video, etc.) must be accompanied by a
written comment. The written comment is considered the official comment
and should include discussion of all points you wish to make. The EPA
will generally not consider comments or comment contents located
outside of the primary submission (i.e., on the web, cloud, or other
file sharing system). For additional submission methods, the full EPA
public comment policy, information about CBI or multimedia submissions,
and general guidance on making effective comments, please visit https://www.epa.gov/dockets/commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT: Christopher Ramig, Office of Air and
Radiation, Office of Transportation and Air Quality, Mail Code: 6401A,
U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue NW.,
Washington, DC 20460; telephone number: 202-564-1372; fax number: 202-
564-1177; email address: [email protected].
SUPPLEMENTARY INFORMATION:
This notice is organized as follows:
I. Introduction
II. Analysis of GHG Emissions Associated With Production and
Transport of Sugar Beets for Use as a Biofuel Feedstock
A. Overview of Beta vulgaris ssp. vulgaris (Sugar Beets)
B. Analysis of Upstream GHG Emissions
1. Methodology and Scenarios Evaluated
2. Domestic Impacts
3. International Impacts
4. Feedstock Transport
5. Results of Upstream GHG Lifecycle Analysis
6. Fuel Production and Distribution
7. Risk of Potential Invasiveness
III. Summary
I. Introduction
Section 211(o) of the Clean Air Act establishes the renewable fuel
standard (``RFS'') program, under which EPA sets annual percentage
standards specifying the amount of renewable fuel, as well as three
subcategories of renewable fuel, that must be used to reduce or replace
fossil fuel present in transportation fuel, heating oil or jet fuel.
With limited exceptions, renewable fuel produced at facilities that
commenced construction after enactment of the Energy Independence and
Security Act of 2007 (``EISA''), must achieve at least a twenty percent
reduction in lifecycle greenhouse gas emissions as compared to baseline
2005 transportation fuel. Advanced biofuel and biomass-based diesel
must achieve at least a fifty percent reduction, and cellulosic biofuel
must achieve at least a sixty percent reduction.
As part of changes to the RFS program regulations published on
March 26, 2010 \1\ (the ``March 2010 RFS rule'') to implement EISA
amendments to the RFS program, EPA identified a number of renewable
fuel production pathways that satisfy the greenhouse gas reduction
requirements of the Act. Table 1 to 40 CFR 80.1426 of the RFS
regulations lists three critical components of approved fuel pathways:
(1) Fuel type; (2) feedstock; and (3) production process. In addition,
for each pathway, the regulations specify a ``D code'' that indicates
whether fuel produced by the specified pathway meets the requirements
for renewable fuel or one of the three renewable fuel subcategories.
EPA may independently approve additional fuel pathways not currently
listed in Table 1 to 40 CFR 80.1426 for participation in the RFS
program, or a party may petition for EPA to evaluate a new fuel pathway
in accordance with 40 CFR 80.1416. Pursuant to 40 CFR 80.1416, EPA
received petitions from Green Vision Group, Tracy Renewable Energy, and
Plant Sensory Systems, submitted under
[[Page 34657]]
partial claims of confidential business information (CBI), requesting
that EPA evaluate the GHG emissions associated with biofuels produced
using sugar beets as feedstock, and that EPA provide a determination of
the renewable fuel categories, if any, for which such biofuels may be
eligible.
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\1\ See 75 FR 14670.
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EPA's lifecycle analyses are used to assess the overall GHG impacts
of a fuel throughout each stage of its production and use. The results
of these analyses, considering uncertainty and the weight of available
evidence, are used to determine whether a fuel meets the necessary GHG
reductions required under the CAA for it to be considered renewable
fuel or one of the subsets of renewable fuel. Lifecycle analysis
includes an assessment of emissions related to the full fuel lifecycle,
including feedstock production, feedstock transportation, fuel
production, fuel transportation and distribution, and tailpipe
emissions. Per the CAA definition of lifecycle GHG emissions, EPA's
lifecycle analyses also include an assessment of significant indirect
emissions, such as indirect emissions from land use changes and
agricultural sector impacts.
This document describes EPA's analysis of the GHG emissions from
feedstock production and feedstock transport associated with sugar
beets when used to produce biofuel, including significant indirect
impacts. This notice considers a scenario in which non-cellulosic beet
sugar (primarily sucrose, glucose and/or fructose) is extracted for
conversion to biofuel and the remaining beet pulp co-product is used as
animal feed. As will be described in Section II, we estimate the GHG
emissions associated with production and transport of sugar beets for
use as a biofuel feedstock are approximately 45 kilograms of
CO2-equivalent per wet short ton (kgCO2e per wet
short ton) of sugar beets.\2\ Based on these results, we believe
biofuels produced from sugar beets through recognized conversion
processes could qualify as advanced biofuel and/or conventional (non-
advanced) renewable fuel, depending on the type and efficiency of the
fuel production process technology used. EPA is seeking public comment
on its analysis of greenhouse gas emissions related to sugar beet
feedstock production and transport.
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\2\ For purposes of this notice, we assume that sugar beets have
an average moisture content of 76%. See Food and Agriculture
Organization, 1999, ``Agribusiness Handbooks Vol. 4 Sugar Beets/
White Sugar'', http://www.responsibleagroinvestment.org/sites/responsibleagroinvestment.org/files/FAO_Agbiz%20handbook_White%20Sugar_0.pdf (Last Accessed: January 4,
2017).
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If appropriate, EPA will update this analysis based on comments
received in response to this notice. EPA will use this updated analysis
as part of the evaluation of facility-specific petitions received
pursuant to 40 CFR 80.1416 that propose to use sugar beets as a
feedstock for the production of biofuel.\3\ Based on this information,
EPA will determine the GHG emissions associated with petitioners'
biofuel production processes, as well as emissions associated with the
transport and use of the finished biofuel. EPA will combine these
assessments into a full lifecycle GHG analysis used to determine
whether the fuel produced at an individual facility satisfies the CAA
GHG emission reduction requirements necessary to qualify as renewable
fuel or one of the subcategories of renewable fuel under the RFS
program.
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\3\ Assuming the fuel pathway proposed in such petitions involve
extraction of non-cellulosic beet sugar for conversion to biofuel
and use of the resulting beet pulp co-product as animal feed.
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II. Analysis of GHG Emissions Associated With Production and Transport
of Sugar Beets for Use as a Biofuel Feedstock
A. Overview of Beta vulgaris ssp. vulgaris (Sugar Beets)
Beta vulgaris ssp. vulgaris, (commonly known as sugar beets) of the
order Caryophylalles, is a widely cultivated plant of the Altissima
group. Sugar beets are cultivated for their high percentage
concentration of sucrose in their root mass. Domestication of the plant
group took place approximately 200 years ago in Europe to selectively
breed for sugar content from crosses between Beta vulgaris cultivars,
including chard plants and fodder beets.\4\
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\4\ Juliane C. Dohm et al., ``The Genome of the Recently
Domesticated Crop Plant Sugar Beet (Beta Vulgaris),'' Nature 505,
no. 7484 (January 23, 2014): 546-49.
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Sugar beets are a biennial crop species grown across a wide
tolerance of soil conditions in areas of temperate climate, and tend to
be grown in rotation with other plant varieties.\5\ Sugar beets are
grown for their relatively high sugar content, approximately 13 to 18
percent of the plant's total mass, with around three quarters of the
plant mass comprised of water.\6\ Once harvested, sugar beets are
highly perishable and need to be processed in a short period of
time.\7\
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\5\ Michael J. McConnell, ``USDA ERS--Background,'' Crops Sugar
& Sweeteners Background, October 12, 2016, http://www.ers.usda.gov/topics/crops/sugar-sweeteners/background/.
\6\ FAO, ``Sugar Crops and Sweeteners and Derived Products,''
accessed November 30, 2016, http://www.fao.org/es/faodef/fdef03e.HTM.
\7\ Michael J. McConnell, ``USDA ERS--Policy,'' USDA ERS--
Policy, November 1, 2016, https://www.ers.usda.gov/topics/crops/sugar-sweeteners/policy.aspx.
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According to the U.S. Department of Agriculture (USDA), the largest
region for sugar beet production is the area of the Red River Valley of
western Minnesota and eastern North Dakota, and sugar beets are
commonly grown at agricultural scale across five regions of the
country, encompassing 11 states.\8\ Western regions tend to require
more irrigation while sugar beets grown in the eastern U.S. region make
greater use of natural rainfall.\9\
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\8\ Michael J. McConnell, ``USDA ERS--Background.''
\9\ Michael J. McConnell, ``USDA ERS--Background.''
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Since the mid-1990s, sugar beets have accounted for about 55
percent of sugar production in the U.S.\10\ Sugar beets are included in
the U.S. sugar program, designed to support domestic sugar prices
through loans to sugar processors. The U.S. sugar program also includes
a marketing allotment that sets the amount of sugar that domestic
processors can sell in the U.S. for human consumption, and provides
quotas on the amount of sugar that can be imported into the U.S.\11\
Sugar produced under the program cannot be used for biofuel purposes
with an exception for surplus sugar made available under the USDA
Feedstock Flexibility Program that specifically directs the excess
sugar to be used for the purpose of domestic biofuel production.\12\
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\10\ Michael J. McConnell, ``USDA ERS--Background.''
\11\ The U.S. sugar program is managed by USDA and supports
domestic sugar prices through loans to sugar processors, a marketing
allotment program, and quotas on the amount of sugar that can be
imported to the U.S. Farm Security and Rural Investment Act of 2002.
Public Law 107-171, Sec. 1401-1403.
\12\ ``Feedstock Flexibility Program,'' page, accessed November
17, 2016, https://www.fsa.usda.gov/programs-and-services/energy-programs/feedstock-flexibility/index.
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Like other sugars, beet sugar can be fermented and used as a
feedstock for biofuel production. The non-cellulosic sugars of sugar
beets, the vast majority of which is sucrose, can be converted directly
into a refined sugar available for processes such as alcoholic
fermentation to produce biofuels (e.g., ethanol).\13\ Much of the water
needed
[[Page 34658]]
for the fermentation process is provided by the sugar beets themselves.
Sugar beet pulp is a fibrous co-product of the beet sugar extraction
process.\14\ The sugar beet pulp is often dried to reduce
transportation costs and is widely sold as feed supplement for cattle
and other livestock.\15\ While biofuel production from beet sugar has
historically been limited in the U.S., sugar beets accounted for about
17 percent of European ethanol production in 2014.\16\
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\13\ Dr. Hossein Shapouri, Dr. Michael Salassi, and J. Nelson
Fairbanks, ``The Economic Feasibility of Ethanol Production from
Sugar in the United States'' (USDA, July 2006), http://www.usda.gov/oce/reports/energy/EthanolSugarFeasibilityReport3.pdf.
\14\ Eggleston, Gillian et al., ``Ethanol from Sugar Crops.''
In, Singh, Bharat P., Industrial Crops and Uses. CABI, 2010, pp. 74-
75.
\15\ Greg Lardy, ``Feeding Sugar Beet Byproducts to Cattle,''
accessed November 30, 2016, https://www.ag.ndsu.edu/publications/livestock/feeding-sugar-beet-byproducts-to-cattle.
\16\ ePURE, ``European Renewable Ethanol--Key Figures,''
accessed November 17, 2016, http://epure.org/media/1227/european-renewable-ethanol-statistics-2015.pdf.
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B. Analysis of Upstream GHG Emissions
EPA evaluated the upstream GHG emissions associated with using
sugar beets as a biofuel feedstock based on information provided by
USDA, petitioners, and other data sources. Upstream GHG emissions
include emissions from production and transport of sugar beets used as
a biofuel feedstock. The methodology EPA used for this analysis is
generally the same approach used for the March 2010 RFS rule for
lifecycle analyses of several other biofuel feedstocks, such as corn,
soybean oil, and sugarcane.\17\ The subsections below describe this
methodology, including assumptions and results of our analysis.
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\17\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
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1. Methodology and Scenarios Evaluated
The analysis EPA prepared for sugar beets used the same set of
models that were used for the March 2010 RFS rule, including the
Forestry and Agricultural Sector Optimization Model (FASOM) developed
by Texas A&M University for domestic impacts, and the Food and
Agricultural Policy and Research Institute international models as
maintained by the Center for Agricultural and Rural Development (FAPRI-
CARD) at Iowa State University for international impacts. For more
information on the FASOM and FAPRI-CARD models, refer to the March 2010
RFS rule preamble (75 FR 14670) and Regulatory Impact Analysis
(RIA).\18\ Several modifications were made to the domestic and
international agricultural economic modeling that differed from
previous analyses in order to accurately represent the U.S. sugar
program.\19\ Memoranda to the docket include detailed information on
model inputs, assumptions, calculations, and the results of our
assessment of the upstream GHG emissions for sugar beet biofuels.\20\
We invite comments on the scenarios and assumptions used for this
analysis, in particular on the key assumptions described in this
section.
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\18\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
\19\ These differences are discussed further in Sections II.D.2
and II.D.3 below.
\20\ The memoranda and modeling files are available in the
docket. EPA-HQ-OAR-2016-0771.
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Sugar beets grown under the U.S. sugar program cannot be used for
the purpose of biofuel production, except under very limited conditions
specified in the Feedstock Flexibility Program.\21\ Therefore, for this
analysis, EPA assumed that there would be no change in sugar production
on U.S. sugar program-designated acres because of demand for beet sugar
for biofuel feedstock use.\22\ In our modeling, growers selling sugar
beets to sugar processors under the U.S. sugar program in the control
case continued to do so regardless of new demand for sugar beets as a
biofuel feedstock in the test case. As a result of this assumption, in
our modeling, demand for acreage to grow sugar beets for biofuel
feedstock could only be fulfilled by converting acres from other crops
besides sugar beets, and/or from other land uses besides crop
production (e.g., pastureland, Conservation Reserve Program land).
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\21\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
\22\ The U.S. sugar program designates acres of land used to
grow sugar beets sold to domestic sugar processors who receive price
support loans and are regulated by USDA market allotments under the
program.
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Our analysis also considers the significant restrictions on the
trade of sugar beets between the U.S. and other countries. The U.S.
does not export beet sugar, as this would violate the terms of
participation in the sugar program. While the U.S. does import cane
sugar under international agreements, it does not import raw beet
sugar.\23\ Beet sugar may only enter the U.S. as refined sugar from
Canada or Mexico under the North American Free Trade Agreement (NAFTA)
and similar trade agreements, or as components of sugar-containing
products.\24\ This quantity is strictly regulated. EPA is unaware of
existing trade agreements that would allow raw beet sugar imports for
any purpose, including biofuel production. This makes it unlikely that
beet sugar would be imported for use as biofuel feedstock.
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\23\ The international agreements that allow for sugar import to
the U.S. are primarily governed by NAFTA and the Uruguay Round
Agreement on Agriculture, but also by CAFTA. See USDA's Web site on
the Sugar Import Program for more details: https://www.fas.usda.gov/programs/sugar-import-program (Last accessed December 30, 2016).
\24\ Mark A. McMinimy, ``U.S. Sugar Program Fundamentals,''
April 6, 2016, https://fas.org/sgp/crs/misc/R43998.pdf.
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Although sugar beets were modeled as grown in the U.S., we also
intend that this analysis would cover sugar beets grown and processed
into biofuels from other countries and imported to the U.S. as finished
biofuel. We expect the vast majority of beet sugar-based biofuel used
in the U.S. will come from sugar beets produced in the U.S., and
incidental amounts of fuel from crops produced in other nations will
not impact our average GHG emissions. Sugar beets require similar
climatic regions as those where they are grown in the U.S., and would
similarly impact crops such as wheat in those regions while sugar beet
pulp would displace corn as livestock feed. Therefore, EPA interprets
this upstream analysis as applicable, regardless of the country of
origin assuming that sugar beet pulp is used as a livestock feed
supplement.
To assess the impacts of an increase in sugar beet demand for
renewable fuel production, EPA modeled two scenarios: (1) A control
case with ``business-as-usual'' assumptions \25\ and no biofuel
production from sugar beets
[[Page 34659]]
and (2) a sugar beet biofuel case where 300 million ethanol-equivalent
gallons of biofuels are assumed to be from beet sugar in 2022,
requiring the use of 12 million wet short tons of sugar beets for
biofuel production. The analysis presented in this notice considered
all GHG emissions associated with the cultivation and production of
sugar beets intended for biofuel feedstock use, as well as emissions
from transporting these sugar beets to a biofuel production facility.
In lifecycle analysis literature these emissions are often referred to
as the ``upstream'' emissions, because they occur upstream of the fuel
production facility (i.e., before the biofuel feedstock arrives at that
facility).
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\25\ To assess the impacts of an increase in renewable fuel
volume from business-as-usual (what is likely to have occurred
without the RFS biofuel mandates) to levels required by the statute,
we established a control case and other cases for a number of
biofuels. The control case included a projection of renewable fuel
volumes that might be used to comply with the RFS renewable fuel
volume mandates in full. The case is designed such that the only
difference between the scenario case and the control case is the
volume of an individual biofuel, all other volumes remaining the
same. In the March 2010 RFS rule, for each individual biofuel, we
analyzed the incremental GHG emission impacts of increasing the
volume of that fuel from business as usual levels to the level of
that biofuel projected to be used in 2022, together with other
biofuels, to fully meet the CAA requirements. Rather than focus on
the GHG emissions impacts associated with a specific gallon of fuel
and tracking inputs and outputs across different lifecycle stages,
we determined the overall aggregate impacts across sectors of the
economy in response to a given volume change in the amount of
biofuel produced. For this analysis, we compared impacts in the
control case to the impacts in a new sugar beets case. The control
case used for the March 2010 RFS rule, and used for this analysis,
has zero gallons of sugar beet biofuel production.
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The analysis presented in this notice does not include fuel
production or ``downstream'' emissions, which consists of emissions
associated with fuel transport and fuel combustion. Once comments on
the upstream emissions described in this notice have been considered,
we intend to combine the upstream analysis with the fuel production and
downstream emissions associated with fuel produced at an individual
biofuel facility to determine the lifecycle GHG emissions associated
with that fuel. This lifecycle analysis would reflect any differences
in emissions that may exist between producing different types of
biofuels from sugar beets. Our analysis of the upstream emissions
associated with sugar beets assumed that non-cellulosic sugars are
extracted from the beets before the sugars are converted, and that the
beet pulp would then be sold into feed markets. Fuel production methods
that also convert the pulp into fuel (e.g., through pyrolysis of the
beet) or use the pulp for other purposes may not be compatible with
this analysis.
We evaluated a scenario with biofuels produced from this amount of
sugar beets for multiple reasons. Although biofuel production from
sugar beets is currently small in the U.S., recent trends in domestic
sugar beet yields and acreage indicate that 12 million wet short tons
of sugar beets could be produced as biofuel feedstocks if a significant
market demand emerged. An additional 12 million wet short tons of sugar
beets would represent a 34 percent increase in U.S. sugar beet
cultivation compared to 2015 levels.\26\ According to USDA data,
harvested acres of sugar beets since 2010 were, on average, about 30
percent lower than their most recent peak levels in the 1990s, an
average difference of approximately 360,000 harvested acres.\27\
Increasing beet yields over time has reduced the number of acres needed
to satisfy production targets under the U.S. sugar program.\28\
National average sugar beet yields since 2010 have been approximately
25 percent higher than yields during the 1990s, and reached almost 31
wet short tons per acre in the 2015 crop year.\29\ Were beet acres to
return to their 1990s peak, the additional approximately 360,000
harvested acres would produce about 11.2 million wet short tons of
beets at these 2015 yield levels. However, based on the steady increase
in yields over time, it seems likely that beet yields will continue to
increase between now and 2022. If national average beet yields reach at
least 33.4 wet short tons per acre by 2022, a fairly modest increase of
about 8 percent over 2015 levels, an additional 12 million wet short
tons of beets could be produced on these additional 360,000 acres.
Since further expansion of beet area beyond the historical peak is also
possible, an increase in beet production of 12 million wet short tons
appears to be very feasible. We welcome comment on this assumption.
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\26\ See, USDA, ``Sugarbeet Area and Planted Harvested Yield and
Production States and United States 2013-2015,'' in Crop Production
2015 Summary, January 2016, ISSN: 1057-7823, http://usda.mannlib.cornell.edu/usda/current/CropProdSu/CropProdSu-0112-2016.pdf. This assumes an ethanol conversion rate of 25 gallons of
ethanol/wet short ton of beets.
\27\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\28\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\29\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
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In our analysis, FASOM allowed for sugar beet production in all
areas of the continental 48 states where sugar beets had been grown
historically, including states and areas that do not currently take
part in the U.S. sugar program. The model was allowed to determine
which of these regions would be optimal for growing sugar beets for
biofuel feedstock, based on least cost of production and transport, and
considering the opportunity cost of using that land for other uses
(e.g., to produce other crops, grazing, forestry). The factors that
contributed to these crop production choices include crop yield, input
quantities, and growing strategies.
Following the methodology established in the March 2010 RFS rule,
EPA used the FAPRI model to evaluate the international impacts of
producing and transporting 12 million wet short tons of sugar beets for
biofuel production in the U.S. The FAPRI model included a
representation of the U.S. sugar program, and modeled domestic sugar
production as a function of this program. Production and consumption
levels in the U.S. were set according to the parameters of the sugar
program and were not affected by market forces. Because the existing
U.S. sugar production module in FAPRI did not respond to market forces,
for modeling purposes EPA had to make assumptions regarding in which
regions sugar beets for biofuel feedstock use would be grown. Crop
yields and the quantity of crop area displaced by expanded sugar beet
production also had to be set by assumption, since the U.S. sugar
module in FAPRI lacks market forces to create demand-pull for new beet
acres. In order to derive the quantity of crop area displaced, EPA used
a crop yield of approximately 26 wet short tons per acre, the 10-year
national average yield for sugar beets (for crop years 2005 through
2014).\30\ Actual yields on any given acre may be higher or lower than
this assumed value, based on factors such as location, annual variation
in growing conditions, growing practices, and crop rotation strategies.
Because the FAPRI analysis assumed to displace acres in North Dakota
and California, we did not believe that it was appropriate to use the
USDA 2022 national average projections for sugar beets yield. As an
alternative, EPA believes using the 10-year national average was a
reasonable assumption for our international agricultural sector
modeling. The increase in sugar yield trends over the last few decades
suggests that future yields are unlikely to be lower than the 10-year
average. As further support for our yield assumptions in FAPRI, we note
that FASOM projected sugar beet yields in 2022 that are close to the
assumptions used in FAPRI.\31\ We welcome comment on this assumption.
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\30\ USDA, ``NASS Quick Stats'', https://quickstats.nass.usda.gov (Last Accessed: November 16, 2016).
\31\ See ``Sugar Beets for Biofuel Upstream Analysis Technical
Memorandum'' in the docket for details. EPA-HQ-OAR-2016-0771.
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For the purposes of FAPRI modeling, EPA assumed that sugar beets
for fuel use would be produced in equal amounts in North Dakota and
California for the following reasons: At the onset of our analysis,
these were the regions with indications of significant sugar beet
biofuel interest.\32\ They are also
[[Page 34660]]
both regions with a long history of sugar beet production. As a
simplifying assumption, EPA assumed that all crops grown in each of
these regions were displaced by sugar beets proportionally to their
crop area in the control case. We recognize there are significant
differences in the way the sugar beet biofuel scenarios were
implemented in FASOM and FAPRI for this analysis. For example, FASOM
chose to produce all sugar beets for biofuels in North Dakota, whereas
in FAPRI we modeled this production in North Dakota and California by
assumption. Since these modeling exercises occurred concurrently, not
sequentially, we could not anticipate what choices FASOM would make at
the outset of our FAPRI modeling. This led to some differences in the
regions utilized to produce beets. However, the nationwide agricultural
market results projected by FASOM and FAPRI were similar, due to
similar dominant trends in feed markets and crop exports at the
national level. The similarity of these relevant national market
results between the two models, despite differences in U.S. growing
regions, indicates that the international impacts projected by the
FAPRI model would not have been significantly different if we had
applied the growing assumptions from FASOM. These results are discussed
below and are available in the docket for this notice.\33\ We welcome
comment on these assumptions and our results.
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\32\ At the time of this modeling we had received the petitions
from Green Vision Group proposing to produce ethanol from sugar
beets grown in North Dakota and Tracy Renewable Energy proposing to
produce ethanol from sugar beets grown in California but we had not
received the petition from Plant Sensory Systems proposing to
produce ethanol from sugar beets grown in Florida. EPA does not
expect results would have varied significantly if sugar beets had
been modeled by assumption in Florida under FAPRI due to the
similarity of these results to the results from FASOM.
\33\ See EPA-HQ-OAR-2016-0771.
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The sugar beet scenario modeled included a number of key
assumptions, such as biofuel and pulp yields per wet short ton of
beets, and the amount of corn livestock feed displaced per pound of
pulp. These key assumptions are discussed below. Information on
additional assumptions, including sugar beet crop inputs (e.g.,
fertilizer, energy) is available in the docket for this notice.
In conducting research for this analysis, we located sources for
beet pulp yield of 0.06 dry short tons of sugar beet pulp per wet short
tons of sugar beets \34\ and displacement rates of 0.9 pounds of corn
feed displaced in cattle diets \35\ for every pound of sugar beet pulp.
In livestock production, the fibrous sugar beet pulp is used as a
roughage replacement making it of use primarily for ruminants rather
than other types of livestock.\36\ In our analysis, sugar beet pulp use
by the livestock market was an important factor leading to GHG
reductions. Therefore this notice evaluates only using the non-
cellulosic portion of sugar beets for biofuel production.
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\34\ Panella, Lee and Stephen R. Kaffka, ``Sugar Beet (Beta
vulgaris L) as a Biofuel Feedstock in the United States.'' Chapter
10 in Sustainability of the Sugar and Sugar Ethanol Industries;
Eggleston, G.; ACS Symposium Series; American Chemical Society:
Washington DC, 2010, pp. 165.
\35\ To make a simplifying assumption, we averaged the value
from corn in backgrounding diets and finishing diets. Lardy, Greg,
and Rebecca Schafar, ``Feeding Sugar Beet Byproducts to Cattle,''
North Dakota State University, May 2008, pp. 2.
\36\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets''.
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2. Domestic Impacts
On the basis of least cost, FASOM chose to grow all sugar beets in
North Dakota, with approximately 477,000 acres of land required to grow
the additional sugar beets.
The vast majority of the new sugar beet acres in North Dakota was
from displacement of other crops rather than from new cropland (432,000
acres from displaced crops, or nearly 91 percent of needed acres).
Increasing sugar beet production in North Dakota primarily displaced
wheat acreage, but also soybeans, corn, and hay among other crops.\37\
Most of these displaced crops shifted to other U.S. regions, and some
crops, such as soybeans, shifted to new acreage that was more
productive than the North Dakota acres from where they were displaced.
Table II.1 indicates that production levels for hay, soy, and most
other crops are maintained.\38\ However, national crop area and
production for wheat and corn declined significantly.
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\37\ See ``FASOM Sugar Beets Results'' in the docket. EPA-HQ-
OAR-2016-0771.
\38\ Soy is captured in the ``All Else'' category in Table II.1.
See ``FASOM Sugar Beets Results'' in the docket EPA-HQ-OAR-2016-0771
for more detail.
Table II.1--Changes in U.S. Production (Million Pounds) and Harvested
Area (Thousand Acres) in 2022 Relative To Control Case \39\
------------------------------------------------------------------------
Harvested area
Production difference
difference from control
from control case
case (million (thousand
pounds) acres)
------------------------------------------------------------------------
Sugar Beets............................. +23,976 +477
Hay..................................... +8 -106
Corn.................................... -867 -96
Wheat................................... -352 -98
All Else................................ +3 -56
-------------------------------
Total............................... +22,768 +121
------------------------------------------------------------------------
The reductions in corn and wheat production were driven by
different proximate causes (though both were ultimately driven by
increased demand for sugar beets) and led to somewhat different impacts
on commodity use and trade. In the case of wheat, the decline in
production led to a decline in exports. As shown in Section II.B.3, the
decline in wheat exports created pressure on international wheat
markets and wheat production increased outside the U.S.
---------------------------------------------------------------------------
\39\ Totals may differ from subtotals due to rounding.
---------------------------------------------------------------------------
In the case of corn, the potential market impacts were mitigated by
the increased availability of sugar beet pulp into U.S. feed markets as
a result of beet sugar biofuel production. As described in Section
II.A, sugar beet pulp is a co-product used as livestock feed
supplement, mainly substituting for corn. Based on the FASOM results
for 2022, approximately 1.4 billion pounds of sugar beet pulp were
produced and sent to the feed market. In turn this displaced
approximately 1.2 billion pounds of corn, which was significantly
greater than the approximately 867 million pounds of corn production
lost to displaced acres. This led to a decrease in total demand for
corn in U.S. markets and, as a result, U.S. exports of corn increased.
As discussed in Section II.B.3 below, this reduced the price of corn
internationally and lessened the demand pull for corn to be grown in
other countries.
The rest of the needed sugar beet acres in North Dakota,
approximately 46,000 acres, came from new cropland, particularly from
cropland pasture (high-value pasture land that can also be utilized as
cropland with minimal preparation) and from acres that would otherwise
take part in the Conservation Reserve Program. Pasture area rose
modestly in some other states causing the conversion of some forest
acres to pasture. This relatively small decrease in forestland pushed
up prices slightly for forest products, leading foresters to intensify
growth on their stands. Relative to other feedstocks EPA has evaluated
for the RFS program, these domestic shifts in land use were minor, and
after the various land use changes were considered the net domestic
land use change emissions impacts were close to zero.
3. International Impacts
In the FAPRI model, the expansion of sugar beet cropland used to
produce biofuel feedstock also led to increases in corn exports and
decreases in wheat exports. Similar to the drivers of the
[[Page 34661]]
domestic results discussed in Section II.B.2, beet production displaced
wheat acres, but the beet pulp co-product reduced domestic demand for
corn. Further, the magnitude of these export impacts was quite similar
between the two models, as shown in Table II.2 below.\40\
---------------------------------------------------------------------------
\40\ Impacts on the exports of other crops were relatively
minor, but interested readers can examine the full set of FAPRI crop
trade impacts in the docket.
Table II.2--Changes in U.S. Corn and Wheat Exports in 2022 Relative To
Control Case by Model
[Million pounds]
------------------------------------------------------------------------
Difference Difference
from control from control
case in FASOM case in FAPRI
------------------------------------------------------------------------
Corn.................................... +307 +355
Wheat................................... -292 -281
------------------------------------------------------------------------
With sugar beet pulp displacing corn feed, FAPRI modeling indicated
that in 2022, both corn production and acreage would decline globally.
Production outside the U.S. of certain other crops however increased in
response to U.S. increasing demand for sugar beets; most significantly
wheat and soybeans. Wheat increased internationally in terms of both
production and acreage, with a strong response particularly in India.
Soybean acres and production also increased, particularly in Brazil.
Table II.3 below summarizes the non-U.S. increases in harvested area by
crop type, while Table II.4 shows which countries had the largest
impacts.
Table II.3--Non-U.S. Harvested Area by Crop in 2022 Relative To Control
Case
[Thousand acres] \41\
------------------------------------------------------------------------
Difference
from control
case
------------------------------------------------------------------------
Sugar Beets............................................. 0
Corn.................................................... -45
Wheat................................................... +43
Soybeans................................................ +20
All Else................................................ +37
---------------
Total............................................... +55
------------------------------------------------------------------------
As increasing sugar beet pulp use for livestock feed in the U.S.
freed up more corn for export, international livestock feed prices
declined modestly, and with it was a small rise in meat production
globally. Many of these changes occurred in Brazil and this caused some
expansion in grazing land, including in the Amazon region. This caused
further international land use change impacts, as shown in Table II.4
below.
---------------------------------------------------------------------------
\41\ These totals do not include pastureland in Brazil. Totals
may differ from subtotals due to rounding.
\42\ Totals may differ from subtotals due to rounding. Brazil
totals include pastureland. Other regions are cropland only.
Table II.4--Non-U.S. Changes in Agricultural Land by Region in 2022 Relative To Control Case
[Thousand acres] \42\
----------------------------------------------------------------------------------------------------------------
Change in Change in Total change
area harvested pasture acres in acres
----------------------------------------------------------------------------------------------------------------
Brazil.......................................................... +9 +20 +29
India........................................................... +15 .............. +15
Rest of Non-USA................................................. +32 .............. +32
-----------------------------------------------
Total Non-USA............................................... .............. .............. +75
----------------------------------------------------------------------------------------------------------------
4. Feedstock Transport
When harvested, sugar beets are heavy and perishable; therefore,
transport of sugar beets from field to processing site is expected to
occur over short distances. Information from stakeholders and
literature states that sugar beets used for biofuels are shipped by
truck from point of production to the plant with typical distances for
transport around 30 miles.\43\ GHG emissions for the transport of sugar
beets are based on emission factors developed for the March 2010 RFS
rule for trucks including capacity, fuel economy, and type of fuel
used.\44\
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\43\ Farahmand, K., N. Dharmadhikari, and V. Khiabani.
``Analysis of Transportation Economics of Sugar-Beet Production in
the Red River Valley of North Dakota and Minnesota using
Geographical Information System.'' Journal of Renewable Agriculture
7(2013):126-131.
\44\ The March 2010 RFS rule preamble (75 FR 14670, March 26,
2010) and Regulatory Impact Analysis (RIA) (EPA-420-R-10-006)
provide further discussion of our approach. These documents are
available online at https://www.epa.gov/renewable-fuel-standard-program/renewable-fuel-standard-rfs2-final-rule-additional-resources.
---------------------------------------------------------------------------
5. Results of Upstream GHG Lifecycle Analysis
As described above, EPA analyzed the GHG emissions associated with
feedstock production and transport. Table II.5 below breaks down by
stage the calculated GHG upstream emissions for producing biofuels from
sugar beets in 2022.
Table II.5--Upstream GHG Lifecycle Emissions for Sugar Beets
[gCO2-eq/wet short ton]
------------------------------------------------------------------------
Emissions (gCO2-eq/wet
Process short ton)
------------------------------------------------------------------------
Net Agriculture (w/o land use change)....... +21,615
Domestic Land Use Change.................... -882
International Land Use Change, Mean......... +16,038
(Low/High).................................. (+9249/+23,672)
[[Page 34662]]
Feedstock Transport......................... +8,183
---------------------------
Total Upstream Emissions, Mean.......... +44,954
(Low/High).............................. (+38,210/+52,588)
------------------------------------------------------------------------
Net agricultural emissions included domestic and international
impacts related to changes in crop inputs such as fertilizer, energy
used in agriculture, livestock production, and other agricultural
changes in the scenario modeled. Increased demand for sugar beets
resulted in positive net agricultural emissions relative to the control
case. Compared with other crops, sugar beets required relatively high
levels of agricultural chemical inputs (e.g., herbicides and
pesticides).\45\ Domestic land use change emissions were close to zero
for sugar beets, as described in Section II.B.2.
---------------------------------------------------------------------------
\45\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets''.
---------------------------------------------------------------------------
International land use change emissions increased as a result of
demand for sugar beets. The increase in international land use change
emissions for sugar beets was significantly larger than the decrease in
domestic land use change emissions. This is because increased demand
for sugar beets led to a significant reduction in key U.S. crop exports
(e.g., wheat exports), but very little change in domestic consumption
of agricultural goods. These greater international emissions led to a
net increase in global land use change emissions. Feedstock transport
included emissions from moving sugar beets from the farm to a biofuel
production facility, as described in Section II.B.4 above.
6. Fuel Production and Distribution
Sugar beets are suitable for the same biofuel conversion processes
as sugarcane. In Europe, where sugar beets are widely used as biofuel
feedstock, virtually all of the fuel is non-cellulosic beet sugar
ethanol produced through fermentation with the beet pulp sold into the
feed markets. Based on these data, and on information from our
petitioners and other stakeholders, EPA anticipates that most biofuel
produced from sugar beets in the U.S. would also be from the non-
cellulosic sugars via fermentation. Our upstream analysis would apply
for all facilities where non-cellulosic beet sugar is converted to
biofuel and the co-product beet pulp is used as animal feed.
Given the importance of the beet pulp co-product on the upstream
GHG emissions associated with beet pulp, pathways that do not produce a
beet pulp feed coproduct, or use it for purposes other than animal
feed, may not be compatible with our analysis. EPA would likely need to
conduct supplemental upstream GHG analysis in order to determine the
lifecycle GHG emissions associated with fuels produced under these
types of pathways.
After reviewing comments received in response to this action, EPA
will combine the evaluation of upstream GHG emissions associated with
the use of sugar beet feedstock with an evaluation of the GHG emissions
associated with individual producers' production processes and finished
fuels to determine whether fuel produced at petitioners' facilities
from the sugar in sugar beets satisfy the CAA lifecycle GHG emissions
reduction requirements for renewable fuels. Each biofuel producer
seeking to generate Renewable Identification Numbers (RINs) for non-
grandfathered volumes of biofuel from sugar beets will need to submit a
petition requesting EPA's evaluation of their new renewable fuel
pathway pursuant to 40 CFR 80.1416 of the RFS regulations, and include
all of the information specified at 40 CFR 80.1416(b)(1).\46\
---------------------------------------------------------------------------
\46\ Petitioners with pending petitions involving use of sugar
from sugar beets as feedstock will not be required to submit new
petitions. However, if any information has changed from their
original petitions, EPA will request that they update that
information.
---------------------------------------------------------------------------
Because EPA is evaluating the GHG emissions associated with the
production and transport of sugar beet feedstock through this notice
and comment process, petitioners requesting EPA's evaluation of biofuel
pathways involving sugar beet feedstock need not include the
information for new feedstocks specified at 40 CFR 80.1416(b)(2). Based
on our evaluation of the upstream GHG emissions attributable to the
production and transport of sugar beet feedstock, including our
assumptions regarding the average yield of ethanol in mmBtu per wet
short ton of sugar beets used, EPA anticipates that if a facility
produces emissions of no more than approximately 23 kgCO2e/
mmBtu of ethanol, the fuel produced would meet the 50 percent advanced
biofuel GHG reduction threshold.\47\ If a facility produces no more
than 53 kgCO2e/mmBtu of ethanol, EPA anticipates it would
meet the 20 percent renewable fuel GHG reduction threshold. EPA will
evaluate petitions for fuel produced from sugar beet feedstock on a
case-by-case basis, and will make adjustments as necessary for each
facility including consideration of differences in the yield of ethanol
per wet short ton of sugar beets used.\48\ We welcome comments on this
application of our upstream analysis.
---------------------------------------------------------------------------
\47\ In this case, emissions produced by the facility refers to
fuel production emissions, including emissions associated with
energy used for fuel, feedstock and co-product operations at the
facility. For more details on the assumptions used in this analysis,
see ``Sugar Beets for Biofuel Upstream Analysis Technical
Memorandum'' in the docket. EPA-HQ-OAR-2016-0771.
\48\ For example, EPA may need to consider additional feedstock
transportation emissions in cases where beet sugar extraction and
biofuel production do not occur in the same location, as may be the
case for biofuel produced under the USDA Feedstock Flexibility
Program.
---------------------------------------------------------------------------
7. Risk of Potential Invasiveness
Sugar beets were not listed on the Federal noxious weed list nor
did they appear on USDA's composite listing of introduced, invasive,
and noxious plants by U.S state.49 50 Based on consultation
with USDA, EPA does not believe sugar beets pose a risk of invasiveness
at this time. Current cultivars of sugar beets require extensive weed
management to survive.\51\ However, USDA notes that future cross
breeding, hybridization, and genetic manipulation could change the
[[Page 34663]]
invasiveness potential of beets, in which case a re-evaluation may be
required.\52\ Based on currently available information, EPA does not
believe monitoring and reporting of data for invasiveness concerns
would be a requirement for biofuel producers generating fuel from sugar
beets at this time.
---------------------------------------------------------------------------
\49\ USDA, ``Federal Noxious Weed List,'' July 13, 2016, https://www.aphis.usda.gov/plant_health/plant_pest_info/weeds/downloads/weedlist.pdf.
\50\ USDA, ``State and Federal Noxious Weeds List,'' accessed
November 17, 2016, http://plants.usda.gov/java/noxComposite.
\51\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
\52\ Harry Baumes, et al. (USDA), ``Summary of Discussions
Between US EPA and USDA Regarding Sugar Beets.''
---------------------------------------------------------------------------
III. Summary
EPA invites public comment on its analysis of GHG emissions
associated with the production and transport of sugar beets as a
feedstock for biofuel production. This notice analyzes a non-cellulosic
sugar beet-to-biofuel production process. Although EPA has not received
a petition for cellulosic sugar beet biofuel production, the agency is
aware of interest in this process and invites comment on the analysis
of beet pulp and its effect on agricultural markets. EPA will consider
public comments received when evaluating petitions received pursuant to
40 CFR 80.1416 that involve pathways using sugar beets as a feedstock.
Dated: January 18, 2017.
Christopher Grundler,
Director, Office of Transportation and Air Quality, Office of Air and
Radiation.
[FR Doc. 2017-15721 Filed 7-25-17; 8:45 am]
BILLING CODE 6560-50-P