EPA Issues Notice of Data Availability
Concerning Renewable Fuels Produced
from Barley 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 barley used as a feedstock to produce
ethanol 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 barley, when used to make ethanol at facilities that use
natural gas for all process energy, grid electricity, and drying 100% distillers grains,
will meet the lifecycle greenhouse gas emissions reduction threshold of 20% required
by the Clean Air Act (CAA) for conventional renewable fuel. When barley is used
to make ethanol at facilities that use certain processing technologies, it will meet the
lifecycle greenhouse gas emissions reduction threshold of 50% required by the Energy
Independence and Security Act of 2007 (EISA) for advanced renewable fuel.
Background
In the final RFS 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 CAA Section 211 (o), as amended by 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% reduc-
tion for biomass-based diesel or advanced biofuel, and a 60% reduction for cellulosic
biofuel.
SEPA
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-13-039
July 2013
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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 lifecycle GHG emissions
of the gasoline or diesel fuel that it replaces. The CAA defines lifecycle GHG emissions as
follows:
The term 'lifecycle greenhouse gas emissions' means the aggregate quantity of green-
house 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
distribution, from feedstock generation or extraction through the distribution and deliv-
ery and use of the finished fuel to the ultimate consumer, where the mass values for all
greenhouse gases are adjusted to account for their relative global warming potential.1
In the March 2010 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, and would complete this process through a supplemental rule-
making process. This NODA presents our analysis of potential pathways for ethanol produced
from a barley feedstock.
Lifecycle Analysis
In order to calculate lifecycle GHG emissions for the NODA regarding barley biofuel pathways,
EPA utilized models developed for the March 2010 final 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 approach to
estimate global land use change GHG emissions from using barley as a feedstock as we have used
to analyze other biofuel pathways.
Pathway Determinations
EPA's analysis found that ethanol produced from barley have an estimated lifecycle GHG emis-
sions reduction of 47% when produced at dry mill ethanol facilities that use natural gas for all
process energy, thus meeting the GHG emission reduction threshold for conventional renewable
fuels. EPA's analysis also found dry milled ethanol facilities that use certain technologies could
meet the 50% GHG emissions reduction threshold for advanced biofuels required by EISA,
Administrative Process
With this NODA, EPA is soliciting comments on our analysis of the pathways for ethanol pro-
duced from barley. 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 Federal Register notice, a rulemaking action or a guidance document.
Clean Air Act Section 211(o)(l)
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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:
www.epa.gov/otaq/fuels/renewablefuels/index.htm
To submit a question on the RFS program, and to view Frequently Asked Questions, please visit:
www.epa.gov/otaq/fuels/renewablefuels/compliancehelp/index.htm
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