Administrator
United States Environmental Protection Agency
1200 Pennsylvania Ave., NW
Washington, DC 20460
Copy to:
Office of Information and Regulatory Affairs,
Office of Management and Budget (OMB),
Attn: Desk Officer for EPA, 725 17th St., NW.,
Washington, DC 20503.
Docket ID No. EPA–HQ– OAR–2005–0161,
Subject: Comments on proposed rulemaking from Argentine stakeholders.
Dear Administrator Jackson:
In regard to what was published on page 24904 of the Federal Register / Vol. 74, No. 99 on Tuesday, May 26, 2009 under the title, ENVIRONMENTAL PROTECTION AGENCY, 40 CFR Part 80, [EPA–HQ–OAR–2005–0161; FRL–8903–1], RIN 2060–A081, Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard Program, ACTION: Notice of proposed rulemaking, in which all stakeholders of the proposed regulations are invited to inform you of opinions, we submit the following document.
The institutions and organizations that are signatories to this document have the need to make EPA aware of their concern since the theoretical bases on which the proposed rulemaking is founded, known as the international Land Use Change theory (“iLUC”), directly contradicts our experience and knowledge as central actors and stakeholders of the agricultural development in Argentina and of the care and sustainability of its ecosystems.
As mentioned repeatedly throughout the document, the Energy Independence and Security Act’s (“EISA”) mandate includes measurements of emissions related to the complete lifecycle of biofuels used in the United States, including significant direct and indirect emissions as those derived from land use changes. This requires measurement of these direct and indirect impacts not only in the United States but in other countries as well. The document also explains that in analyzing emissions that will occur in other parts of the world derived from future increases in agricultural production of developing countries, the level of uncertainty regarding the validity of the data grows enormously.[1]
Since the “indirect, international emissions are the component of [the] analysis with the highest level of uncertainty”,[2] EPA requests information regarding the best way to estimate future changes in land use and its relation to future emissions of greenhouse gases (GHG). It is with this in mind that we have decided to prepare this document in order to contribute to the Renewable Fuel Standard’s (“RFS”) objective and EISA’s mandate.
The document published by EPA takes from the iLUC theory the following premises as valid:
1. The increased use of agricultural feedstocks to produce biofuels in the United States increases their price in global markets, and this in turn promotes increased production of these agricultural feedstocks (or their substitutes) in developing countries.[3]
2. Increases in agricultural production are negative because they generate changes in land use in developing countries. [4] [5]
3. Land use changes are negative in itself, since it is assumed that they result in increases in GHG emissions and not the opposite.[6]
Let’s analyze our own vision and experience for each of the three points:
1. The increased use of agricultural feedstocks to produce biofuels in the United States increases their price in global markets, and this in turn promotes increased production of these agricultural feedstocks (or their substitutes) in developing countries.[7]
Increases in the prices of the goods produced in our ecosystems generate greater income for the players of the entire value chain (grains, beef, dairy, machinery & equipment, seed, etc.) of developing countries such as Argentina. This allows the application of better technology, training and education for all stakeholders, which, in turn helps in the conservation and improvement of the ecosystems in those countries. This increased education and knowledge translate into improvements in production and efficiency of the goods and services that are internal to the ecosystem and to those introduced by man. This necessarily leads to healthier ecosystems -- and not the opposite.
Production increases in our countries are an opportunity for the introduction of new ecosystems management technologies for the improvement of environments thru less intense production practices. Expecting a positive opportunity cost regarding GHG emissions when compared to crops produced in OECD countries.
1. Increases in agricultural production are negative because they generate changes in land use in developing countries.
Production increases of agricultural products are not negative by themselves. They are only negative if done unsustainably and without due care for the ecosystems and the soils in which these increases occurs.
Land use changes occur in nature permanently in the form of floods, droughts, frosts, wild fires, and even through seasonal change, etc. It is nature’s own vital dynamics which, interacting within itself as well as with mankind, leads to land use changes which are not evaluated by the authors quoted in the document of the proposed rulemaking. Scientific knowledge of ecosystems in all their dynamics and complexity allow us to generate changes in land use that result in a greater accumulation of biomass and better sustainability of the flora and fauna within it.
The Argentine government has established norms and standards through national laws that regulate the expansion of our agricultural frontier, and to protect areas of greater biodiversity and carbon reserves. Additionally, each province within Argentina is doing the same at a more localized level. None of these norms and regulations were taken into account by the predictive models that assume ceteris paribus criteria that extends beyond their reach.
INTA, (The National Agronomical Technology Institute Instituto Nacional de Tecnología Agropecuaria, ) is Argentine government’s lead organization in agriculture. It administers bioenergy programs, has established ecoregions, and has designated strategic areas for environmental and natural resource development. Through the execution of these integrated projects the entire country is being canvassed and is providing technical and scientific data which result in the harmonious development of the Argentine agricultural sector and the improvement of its ecosystems. INTA actively participates in most of the signing institutions of this paper.
The Argentine private sector is very active and possesses a high degree of professional expertise and a world class R&D capacity. Argentine agriculture is considered a model overseas and its know-how is being exported to several countries (No-Till farming methods, agronomical techniques, farm machinery and equipment, etc.). For example, while in Argentina fully 70% of farming is done using No-Till methods, only 6% of the rest of the world uses this method, which has been proven to reduce soil erosion by 96%.[8]
AAPRESID, one of the signing institutions has given special priority to environmental issues by designing and launching an “agricultural certification program” which focuses on sustainability and continuous environmental improvement.
Using these methods, farmers in Argentina, Chile, Brazil, Paraguay, Uruguay and Bolivia are improving their soils reducing erosion and recovering their natural resources in general. The “No-Till” system includes aspects such as crop rotation, rational use of fertilizers and other practices of sustainable management which have broken the long held assumption that to produce agricultural goods one must necessarily “tolerate” a certain level of degradation of natural resources. For example, No-Till farming methods require 66% less fuel that standard farming methods commonly used in other countries.[9]
Many of these production sites have now developed true “virtuous circles”, with higher crop yields and soils presenting better quality indices according to international standards due to higher capture of carbon and nitrogen. While undoubtedly much still needs to be done as far as agricultural policies are concerned to promote this kind of agriculture.
The undersigned institutions work diligently within each institution and from the individual firms that form them in all areas of agricultural activity in our country to develop and apply the best available technologies worldwide in order to improve the quality of our ecosystems and their soils, and in particular to increase the levels of organic matter in them, as to achieve a growing and sustainable agricultural production.
Since the introduction of annual and perennial crops in the 19th century Argentina has maintained consciousness regarding the organic matter content of soils. In the last twenty years Argentine grain production has tripled and this has been due to a large technological breakthrough that allowed the control of a group of invasive weeds that were destroying the productive potential of the ecosystems, putting at risk native flora and fauna. These species are Sorghum halepense and Cynodon dactylon.
The development of agrochemicals specifically designed to control these weeds, the introduction of new crops like soy, the outbreak of biotechnology, the design of new farm machinery, the education and training of farmers and ranchers and in particular the massive use of no-till farming, allowed the enormous productive increase accompanied by a substantial improvement in the protection of soils, including a decrease in plowing, lower use of agrochemicals and an increase of carbon content in soils.
There is still much to be done, but by no means it is acceptable to think that these changes in land use in our country had negative consequences. On the contrary, if there had not been a change in land use based on technology and knowledge of all stakeholders, the GHG emissions would actually be much higher than current levels.
2. Land use changes are negative by themselves, since it is assumed that they result in increases in GHG emissions and not the opposite.[10]
The ideas expressed in the EPA’s document contradict our common sense and our experience.
Since the introduction of the aforementioned new technologies, soils in our country have began to accumulate the stubble of previous crops, allowing the planting of all types of annual and perennial species for agricultural production, ranching and dairy farming, allowing native species to return to take their place in the different ecosystems.
This accumulation of biomass and its nutrients allows a significant reduction in GHG emissions compared to older techniques such as conventional tillage, while maintaining Carbon and Nitrogen in organic form until the time of their use by the ecosystem’s flora and fauna.
Therefore, in our experience land use change is actually an opportunity to improve ecosystems and, when desired, it is a method to accumulate organic matter and sequester in the soil the GHG emitted by other activities of mankind.
Our work proposal:
We understand that the EPA must measure indirect impacts that other countries will generate due to the use of corn-based biofuels and other crops in the United States. We hope that these studies may also serve countries such as Argentina to generate and promote better domestic agricultural practices.
Therefore, to assure that the EPA can carry out this work in the best possible manner in relation to the Argentine farm production the undersigned put forth the following proposal:
A) That all data which is used by the mathematical and econometric models chosen by the EPA to evaluate and to qualify or related to our country be verified, analyzed and adopted by mutual consent between our institutions. Bu this way we can assure that they accurately reflect Argentina’s current situation; the future prospects for our ecosystems; and the potential impact generated from the use of our soils.
B) That all data obtained from the models chosen by EPA that are related to our country and are used as a basis for Argentina’s qualification by EISA, and any another current or future regulation that evaluates our agricultural production -- relating to land use changes, GHG emissions as well as any other purpose – be verified, analyzed and adopted by mutual consent between our institutions. Only this way the EPA will be assured that the data and assumptions used reflect accurately what occurs today and what the future holds so that the norms applied in the qualification of biofuels in the United States be the most reliable for the objectives sought.
C) That the econometric models used incorporate dynamic scenarios and consider the technological changes that will be applied outside the U.S. in each of the links of the value chain.
In other words, the best solution, consistent with law and international agreements between our countries, is mutual consent and joint verification of information, with a goal of reaching as best as possible the mechanisms of mutual consent and equivalency in the work methods, which should also be based on mutually verifiable evidence.
With our best regards,
Signatures that follow:
www.crea.org.ar, www.aapa.org.ar, www.aapresid.org.ar/
www.acacoop.com.ar/, www.acsoja.org.ar/
www.acta.com.ar, www.afamac.org.ar
www.amchamar.com.ar, www.anav.org.ar, www.argentrigo.org.ar
www.asa.org.ar, www.asagir.org.ar,www.brangus.com.ar,www.hereford.org.ar/
www.bcp.or.ar,www.bolcereales.com.ar, www.bccba.com.ar,www.bolsacer.org.ar, www.bcr.com.ar,www.bcsf.com.ar, www.ensiladores.com.ar/
www.cafagda.com.ar, www.carbio.com.ar, www.casafe.org, www.ceads.org.ar/, www.ciaracec.com.ar, www.cai.org.ar, www.aviculturaargentina.com.ar/, www.ciaracec.com.ar
www.coninagro.org.ar/, www.copaer.org.ar,www.copal.com.ar
www.cpia.org.ar, www.cra.org.ar/, www.producirconservando.org.ar
www.inai.org.ar/, www.maizar.org.ar, www.matba.com.ar, www.acopiadorescba.com
www.sra.org.ar
[1] Draft Regulatory Impact Analysis: Changes to Renewable Fuel Standard Program, Section 2.1.3, Treatment of Future GHG Emissions, page 286.
[2] Ibid
[3] Page 25024 Federal Register / Vol. 74, No. 99 / Tuesday, May 26, 2009 / Proposed Rules says, “Increased U.S. demand for biofuel feedstocks diverts these feedstocks from other competing uses, and also increases the price of the feedstock, thus spurring production. To the extent feedstocks like corn and soybeans are traded internationally, this combined impact of lower supply from the U.S. and higher commodity prices encourages international production to fill the gap.”
[4] Searchinger T, et al., page 1238 29 February 2008 vol. 319 Science www.sciencemag.org. “When other countries replace U.S. exports, farmers must generally cultivate more land per ton of crop because of lower yields. Farmers would also try to boost yields through improved irrigation, drainage, and fertilizer (which have their own environmental effects), but reduced crop rotations and greater reliance on marginal lands would depress yields.”
[5] Page 25024 Federal Register / Vol. 74, No. 99 / Tuesday, May 26, 2009 / Proposed Rules says, “Our analysis uses country specific information to determine the amount, location, and type of land use change that would occur to meet this change in production patterns. … there is considerable overall certainty as to the existence of the land use changes in general, the fact that GHG emissions will result, and the cause and effect linkage of these …”
[6] Page: 25024 Federal Register / Vol. 74, No. 99 / Tuesday, May 26, 2009 / Proposed Rules says, “…there is considerable overall certainty as to the existence of the land use changes in general, the fact that GHG emissions will result, and the cause and effect linkage of these emissions impacts to the increased use of feedstock for production of renewable fuels.”
[7] Page 25024 Federal Register / Vol. 74, No. 99 / Tuesday, May 26, 2009 / Proposed Rules says, “Increased U.S. demand for biofuel feedstocks diverts these feedstocks from other competing uses, and also increases the price of the feedstock, thus spurring production. To the extent feedstocks like corn and soybeans are traded internationally, this combined impact of lower supply from the U.S. and higher commodity prices encourages international production to fill the gap.”
[10] Page: 25024 Federal Register / Vol. 74, No. 99 / Tuesday, May 26, 2009 / Proposed Rules says, “…there is considerable overall certainty as to the existence of the land use changes in general, the fact that GHG emissions will result, and the cause and effect linkage of these emissions impacts to the increased use of feedstock for production of renewable fuels.”
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