EPA  Issues Notice of Data Availability
                   Concerning  Renewable Fuels
                   Produced from Palm  Oil Under the
                   RFS  Program
                      The U.S. Environmental Protection Agency (EPA) is issuing a
                      Notice of Data Availability (NODA) to release its lifecycle green-
                  house gas (GHG) analysis of palm oil used as a feedstock to produce
                  biodiesel and renewable diesel under the Renewable Fuel Standard
                  (RFS) program. The release of the NODA provides the public an
                  opportunity to comment on EPA's analysis.

                  EPA's analysis shows that biodiesel and renewable diesel produced
                  from palm oil do not meet the minimum 20% lifecycle GHG reduc-
                  tion threshold needed to qualify as renewable fuel under the RFS
                   In the final RFS2 rule, published in March 2010, EPA assessed the lifecycle GHG
                   emissions of multiple renewable fuel pathways (defined as feedstock, fuel type, and
                   fuel production process). Assessment of lifecycle GHG emissions is necessary to
                   determine which fuel pathways meet the GHG reduction thresholds for the four
                   renewable fuel categories specified in Clean Air Act (CAA) Section 211(o), as
                   amended by the Energy Independence and Security Act of 2007 (EISA). The CAA
                   requires a 20% reduction in lifecycle GHG emissions for renewable fuel produced
                   at new facilities (those constructed after EISA enactment), a 50% reduction for
                   biomass-based diesel or advanced biofuel, and a 60% reduction for cellulosic biofuel,

                   Assessing whether a fuel pathway meets these thresholds requires a comprehensive
                   evaluation of the lifecycle GHG emissions of the renewable fuel as compared to the
United States
Environmental Protection
Office of Transportation and Air Quality
                  December 2011

lifecycle GHG emissions of the gasoline or diesel fuel that it replaces. The CAA defines life-
cycle GHG emissions as follows:

       The term 'lifecycle greenhouse gas emissions' means the aggregate quantity of greenhouse
       gas emissions (including direct emissions and significant indirect emissions such as
       significant emissions from land use changes), as determined by the Administrator, related
       to the full fuel lifecycle, including all stages of fuel and feedstock production and distri-
       bution, from feedstock generation or extraction through the distribution and delivery
       and use of the finished fuel to the ultimate consumer, where the mass values for all green-
       house gases are adjusted to account for their relative global warming potential1.

In the final rule, EPA focused our lifecycle analysis on fuels that were anticipated to contribute
relatively large volumes of renewable fuel  by 2022, and thus did not cover all fuels that either
are contributing or could potentially contribute to the program. In the preamble to the final
rule, EPA indicated that we would continue to examine several additional pathways not analyzed
for the final rule, including those from palm oil, and would complete this process through a
supplemental rulemaking process. This NODA presents our analysis of potential pathways for
biodiesel and renewable diesel produced from a palm oil feedstock.
Lifecycle Analysis
In order to calculate lifecycle GHG emissions for the NODA regarding palm oil biofuel path-
ways, EPA utilized models developed for the final (RFS2) rule. These models take into account
energy and emissions inputs for fuel and feedstock production, distribution, and use, as well as
economic models that predict changes in agricultural markets,

EPA used the same general approach to estimate global land use change GHG emissions from
using palm oil as a feedstock as we have used to analyze other biofuel pathways. Our analysis
of palm oil biofuels, however, also considers new data for Indonesia and Malaysia, where close
to 90% of world palm oil is currently produced. These data include higher resolution satellite
imagery and maps of relevant geographic features, such as oil palm plantations, palm oil mills
and protected conservation areas.  EPA undertook a more detailed assessment of Malaysia and
Indonesia based on a number of factors, including the scale of the palm oil industry in this
region and the availability of new data on palm oil land use. The analysis considered past trends
to determine likely areas of future palm expansion and classified these areas according to both
their land cover and their soil type.
Pathway Determinations
EPA's analysis found that biodiesel and renewable diesel produced from palm oil have estimated
lifecycle GHG emissions reductions of 17% and 11%, respectively, compared to the baseline
petroleum diesel fuel they replace. These biofuels therefore fail to meet the minimum 20%
GHG emissions reduction threshold required by EISA for renewable fuel made in facilities that
commenced construction after December 19, 2007.
1 Clean Air Act Section 211(o)(l)

EPA's analysis highlights a number of key factors which contribute to the lifecycle emissions
estimate for biofuels based on palm oil. For example, palm oil production produces wastewater
effluent that eventually decomposes, creating methane, a GHG with a high global warming
potential. Another key factor is the expected expansion of palm plantations onto land with
carbon-rich peat soils which would lead to significant releases of GHGs to the atmosphere.
Administrative Process
With this NODA, EPA is soliciting comments on our analysis of the pathways for biodiesel and
renewable diesel produced from palm oil. We will consider all relevant comments received and
will inform the public of any resulting revisions in our analyses. Public notification could be
accomplished in one of several formats, such as a Federal Register notice, a rulemaking action or
a guidance document. The appropriate form of public notification will depend on the outcome
of any reanalysis we deem appropriate after consideration of public comments.
For More Information
For more information, please visit the RFS website at:


To submit a question on the RFS program, and to view Frequently Asked Questions, please visit: