Review of final RFS2 analysis March 24, 2010 1 Review of final RFS2 analysis Richard Plevin Energy and Resources Group, UC Berkeley plevin@berkeley.edu Improvements in the final RFS2 analysis EPA has improved their analysis is a number of important areas since the proposed rule. These include:  InclusioŶ of the foƌestƌLJ seĐtoƌ iŶ FA“OM’s ŵodeliŶg of the U“ eĐoŶoŵLJ  Moƌe detailed ŵodeliŶg of Bƌazil’s agƌiĐultuƌal seĐtoƌ  Inclusion of a price-induced yield effect in the FAPRI model  Use of MODIS 5 data, with increased resolution and a longer time period for change detection  New soil carbon data  Analysis of (some of) the uncertainty in remote sensing and emission factors  Corrected N 2 O emission factors for soybeans Otheƌ ĐhaŶges ǁeƌe ŵade, ďut it’s uŶĐleaƌ ǁhetheƌ theLJ ƌepƌeseŶt iŵpƌoǀeŵeŶts. These iŶĐlude projections of increased crop yields and improvements in biorefining anticipated to be available in 2022. Analysis conducted in 2022 overestimates near-term benefits As with their draft rule, EPA performs its GHG analysis in a projected 2022 world, assuming a wide range crop yield and technology improvements. This approach regulates near-term biofuels based on hypothetical improvements anticipated 12 years in the future. EPA writes (RIA, p. 310): "We focus our final rule analyses on 2022 results for two main reasons. First, it would require an extremely complex assessment and administratively difficult implementation program to track how biofuel production might continuously change from month to month or year to year. Instead, it seems appropriate that each biofuel be assessed a level of GHG performance that is constant over the implementation of this rule, allowing fuel providers to anticipate how these GHG performance assessments should affect their production plans. Second, it is appropriate to focus on 2022, the final year of ramp up in the required volumes of renewable fuel as this year. Assessment in this year allows the complete fuel volumes specified in EISA to be incorporated. This also allows for the complete implementation of technology changes and updates that were made to improve or modeling efforts. For example, the inclusion of price induced yield increases and the efficiency gains of DDGS replacement are phased in over time. Furthermore, these changes are in part driven by the changes in earlier years of increased biofuel use." This argument is unconvincing. Month-to-month tracking is a straw man; even annual tracking is not required. For most fuels, EPA has already analyzed results in 2012, 2017, and 2022. The use of 2012 results for, say, 2010, until, say, 2015, would be quite reasonable. In 2015, EPA could re-assess the expected outcomes in 2017 and 2022, adjusting assumptions to better approximate the unfolding