How to Use the Efficient Producer
Lifecycle Greenhouse Gas Calculator
Version 1*2
United States
Environmental Protection
tl Agency
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How to Use the Efficient Producer
Lifecycle Greenhouse Gas Calculator
Version 1*2
Transportation and Climate Division
Office of Transportation and Air Quality
U.S. Environmental Protection Agency
£% United States
Environmental Protection
^1 Agency
EPA-420-B-17-032
October 2017
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1. Introduction
The U.S. Environmental Protection Agency is providing instructions on how to use version 1.2 of the
Efficient Producer Lifecycle Greenhouse Gas Calculator (the "GHG Calculator"). The GHG Calculator is a
spreadsheet tool available for download through the EPA's website for the U.S. Renewable Fuel
Standard (RFS) program. It is intended to help ethanol producers understand and be able to reproduce
the Agency's lifecycle GHG calculations for certain types of ethanol evaluated through the Agency's
Efficient Producer petition process (EP3).1 Now, with the updates made for version 1.2, the GHG
Calculator also helps producers satisfy their quarterly reporting obligations.
Disclaimer: This document provides general information and is not intended to contradict the RFS
regulations at 40 CFR Part 80 Subpart M, or the signed determination documents issued pursuant to
the petition process at 40 CFR 80.1416. To the extent there are any discrepancies, the RFS
regulations and/or the petition determination documents control and override the information in
this document.
This document is intended for companies that are interested in using the GHG Calculator in the context
of the EP3. Specifically, it provides instructions on how to fill out and submit the GHG Calculator as part
of an Efficient Producer (EP) petition. It also explains how facilities that have already been evaluated
through the EP3 can use the GHG Calculator to calculate the rolling average lifecycle GHG emissions for
the fuel they produce through a qualifying facility/process.2
The Agency recently created a new category under the EP3 for dry mill ethanol plants that produce corn
starch ethanol and cellulosic ethanol from corn kernel fiber. Updates have been incorporated for
version 1.2 to accommodate this new category. The updates for version 1.2 are summarized in Section 2
of this document.
Section 3 includes frequently asked questions about using the GHG Calculator. Section 4 provides an
overview of the GHG Calculator spreadsheet, and instructions on how to use each tab when preparing
an EP petition submission or using the GHG Calculator to calculate the rolling average lifecycle GHG
emissions for ethanol produced through a previously approved EP pathway.
The agency welcomes public input on improving the GHG Calculator and accompanying documentation.
Please send input to the EPA Fuels Program Helpdesk.3 The EPA will make updates and improvements
as warranted based on public input and updates to the EP3.
1 For information about the EP3, see the following EPA web page:
https://www.epa.gov/renewable-fuel-standard-program/how-prepare-efficient-producer-petition-under-
renewable-fuel
2 EPA petition evaluations are available on the agency's website:
https://www.epa.gov/renewable-fuel-standard-program/approved-pathways-renewable-fuel
3 https://www.epa.gov/fuels-registration-reporting-and-compliance-help/forms/fuels-program-helpdesk
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2. .ion 1.2
Based on the Agency's experience and recent updates to the EP3, we made a number of improvements
for version 1.2 of the GHG Calculator, including:
Updates to accommodate EP petitions from dry mill ethanol plants that produce corn starch
ethanol and cellulosic ethanol from corn kernel fiber
Automated data for quarterly reporting using the RFS Efficient Producer Data Form (RFS2500)
\ [ i 1 sly - -I >'\\ hrn. U. !h; lU- vi W, k J> H
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produced at your facility, so it can provide a demonstration of how your facility can meet the required
GHG reduction thresholds.
What data are required to complete the GHG Calculator for an EP petition submission?
The GHG Calculator requires the following data inputs:
Volume of feedstocks used in fuel production processes for all of the ethanol produced at your
facility during a specified time period (including ethanol that does not generate RINs or is
exempt from the GHG reduction requirements per 40 CFR 80.1403).
All of the energy used for feedstock, fuel and co-product operations.5
The volume of ethanol produced by your facility.
For your petition, data should be provided for a period of time encompassing at least 365 consecutive
days. Either historical or projected data are acceptable. If you provide historical data for your facility,
include at least the most recent 365-day period. Projected data may be more appropriate if your facility
is undertaking process efficiency improvements or for other reasons. If projected data is provided, then
it should be representative of anticipated average annual facility operations.
Do I need to enter daily data in the GHG Calculator when submitting an EP petition?
No, not when submitting an EP petition. However, daily data are required when using the GHG
Calculator to calculate the rolling average lifecycle GHG emissions for ethanol produced through a
previously approved EP pathway (and for associated recordkeeping).
When entering data into the GHG Calculator for an EP petition submission there are two options: (1)
enter daily data using one row for each day, or (2) enter aggregate data using one row for a period of
time encompassing at least 365-consecutive days. Examples of how each option would look for
electricity use data are shown below in Figure 1 and Figure 2. In both figures, the facility uses 100 kWh
of electricity each day. In Figure 1, these data are entered for 365 separate days. In Figure 2, the total
electricity use during the 365-day period is entered in one row corresponding with the first day in the
time period. Both approaches are equally valid when preparing the GHG Calculator for an EP petition.
Using the daily data approach illustrated in Figure 1, the GHG Calculator will pull data from all of the
rows encompassing the time period from 4/1/2014 to 3/31/2015. Using the aggregate data approach
illustrated in Figure 2, the GHG Calculator will only use the data entered in the first row.
Figure 1: Example of daily electricity use data entered using one row for each day
Meter 1
Day
Daily Electricity
Use
Previous Day
Meter Reading
Daily Meter
Reading
Daily Amount
Used
DD/MM/YYYY
Amount (kWh)
Amount (kWh)
Amount (kWh)
Amount (kWh)
4/1/2014
100
-
100
100
5 Energy for feedstock, fuel and co-product operations should include all energy used in any building that is used in
any part for the storage and/or processing of feedstock and all energy used in any building that is used in any part
for the production and/or storage of fuel intermediates, finished fuel or co-products. It also includes any energy
related to feedstock or waste handling.
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4/2/2014
100
100
200
100
[...]
[...]
[...]
[...]
[...]
3/30/2015
100
36,300
36,400
100
3/31/2015
100
36,400
36,500
100
Figure 2: Example of aggregate electricity use data entered using one row for a period encompassing
at Least 365-Consecutive Days
Meter 1
Day
Daily Electricity
Use
Previous Day
Meter Reading
Daily Meter
Reading
Daily Amount
Used
DD/MM/YYYY
Amount (kWh)
Amount (kWh)
Amount (kWh)
Amount (kWh)
4/1/2014
36,500
-
36,500
36,500
4/2/2014
-
36,500
(36,500)
4/3/2014
-
-
-
If you use the aggregate data entry approach shown in Figure 2, in the Cover Sheet tab you must enter
the first date in the time period you are entering data for in both of the Averaging Time Period fields.
We also ask that you explain the time period for the aggregate data in the Notes section, as shown
below in Figure 3.
Figure 3: Example of how to fill out the Averaging Time Period fields in the Cover Sheet when entering
aggregate data for a time period from 4/1/2014 to 3/31/2015
Averaging Time Period
Earliest date that you are entering data for (DD/MM/YYYY):
4/1/2014
Latest date you are entering data for (DD/MM/YYYY):
4/1/2014
Data for the 365-day period
from 4/1/14 to 3/31/15 are
Notes:
entered in one row.
What if the GHG Calculator shows that my fuel does not meet the applicable GHG
reduction threshold?
If you are using the GHG Calculator for an EP petition submission, the data entered into the GHG
Calculator and submitted as part of your EP petition should demonstrate that your fuel meets the
applicable GHG reduction threshold (20% reduction for renewable fuel or 50% reduction for advanced
biofuel). If you submit a GHG Calculator that does not demonstrate adequate GHG reductions, EPA will
return your petition as incomplete.
Please keep in mind that should your EP pathway be approved and activated, in order to generate RINs
through your activated EP pathway you will need to monitor, calculate and record your fuel's lifecycle
GHG emissions on a 365-day rolling average basis to demonstrate that it is meeting the applicable GHG
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reductions. If the GHG Calculator shows that your fuel does not meet the 20% GHG reduction threshold
specified in the CAA, RINs may not be generated for non-grandfathered volumes of fuel.
Are coproducts accounted for in the GHG Calculator?
In addition to producing ethanol, dry mill plants also produce distillers grains and solubles (DGS) as a
coproduct. Many plants also extract corn or sorghum oil as an additional coproduct. In the GHG
Calculator the GHG impacts of the DGS and oil coproducts are accounted for in the upstream GHG
emissions factors for corn and grain sorghum. This is because our analyses of the upstream emissions
attributable to corn and grain sorghum used for ethanol account for the agricultural sector impacts of
the DGS and corn oil coproducts. In our modeling, the DGS are considered a replacement animal feed
and thus reduce the demand for other sources of animal feed and the GHG emissions associated with
their production and use. Extracted oil is also accounted for in the vegetable oil and biodiesel markets.6
Who should I contact if I have more questions?
Please direct any further questions to the EPA Fuels Program Helpdesk at: https://www.epa.gov/fuels-
registration-reporting-and-compliance-help/forms/fuels-program-helpdesk. Your questions will be
delegated to appropriate EPA staff (or EPA contractor) for response.
4. Tab-by-Tab Instructions
This section includes on overview of the GHG Calculator spreadsheet, and instructions on how to use
each tab when preparing an EP petition or using the GHG Calculator to calculate the rolling average
lifecycle GHG emissions for ethanol produced through a previously approved EP pathway. It begins with
an explanation of the purpose of the GHG Calculator, followed by a brief introduction to each tab in the
spreadsheet.
Overview of the Tabs in the GHG Calculator
Table 2 lists the tabs in the GHG Calculator with a brief description. Tabs that are new for version 1.2
are shown in red text. The GHG Calculator includes three types of tabs: data entry tabs (green
background), calculation tabs (blue background), and information tabs (clear background).
Table 2: Overview of the Tabs in the GHG Calculator Spreadsheet
Tab Name
Description
Cover Sheet
Basic information regarding the fuel pathway.
Instructions
Basic instructions for using the spreadsheet
Contact Info
Enter contact information for petitioner's Responsible Corporate
Officer
Corn Use Data
Data entry for corn use in bushels.
Corn Moisture Data
Data entry for the moisture content of corn deliveries.
Sorghum Use Data
Data entry for grain sorghum use in bushels.
Sorghum Moisture Data
Data entry for the moisture content of grain sorghum deliveries.
Natural Gas Use Data
Data entry for natural gas use in standard cubic feet.
Biogas Use Data
Data entry for biogas use in standard cubic feet.
6 For more information on our corn ethanol modeling see the March 2010 rule (75 FR 14670), and for more
information on our grain sorghum modeling see the December 2012 grain sorghum rule (77 FR 74592).
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Electricity Use Data
Data entry for grid electricity use in kilowatt hours.
Coal Use Data
Data entry for coal use in tons.
Biomass Use Data
Data entry for biomass use dry pounds.
Ethanol Production Data
Data entry for ethanol production in standard gallons.
CKF Ethanol Production
Data entry for cellulosic ethanol production from corn kernel fiber, in
Data
standard gallons.
Confirm Data
Confirm that data is entered properly for each day.
Quick Check
Automatic check for missing information
Daily Data Summary
Summary of daily feedstock and energy use, and fuel production data.
Time Series Results
Time series of daily and rolling average lifecycle GHG results.
Results Summary
Updated 365-day rolling average lifecycle GHG results.
Corn Ethanol GHG Calcs
Daily and rolling average GHG calculations for corn ethanol.
Sorghum Ethanol GHG Calcs
Daily and rolling average GHG calculations for grain sorghum ethanol.
Emis Facs
Emission factors and unit conversions used in the GHG calculations.
Abbreviations
Descriptions of abbreviations used in the GHG Calculator
RFS2500-Corn
Corn starch ethanol data to be reported using the RFS Efficient
Producer Data Form
RFS2500-Sorghum
Grain sorghum ethanol data to be reported using the RFS Efficient
Producer Data Form
RFS2500-CKF
Corn kernel fiber ethanol data to be reported using the RFS Efficient
Producer Data Form
For-EPA-Use
The data collected in this tab helps the EPA review EP petitions.
This rest of this section includes instructions for each tab of the GHG Calculator.
Cover Sheet
The Cover Sheet asks for five categories of information to be entered in the green-shaded cells.
Facility information:
Company Name: Enter the name of the company that owns the fuel production facility.
Company ID: The company's four-digit identification number from CDX OTAQReg (if the
company does not yet have an ID number enter "N/A").
Facility Name: Enter a name for the fuel production facility (e.g., the company name followed by
the name of the city where the facility is located).
Facility ID: The facility's five-digit identification number from CDX OTAQReg (enter "N/A" if one
does not exist).
Facility City: The city where the fuel production facility is located.
Facility State: The state where the fuel production facility is located.
Fuel Pathway Information:
Has the EPA has activated an Efficient Producer pathwav(s) for your fuel?
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Select "No" if you are preparing the GHG Calculator as part of an EP petition.7
Select "Yes" if EPA has previously approved an EP pathway for your fuel, and the Agency has
accepted your registration for the fuel pathway.8
Some of the instructions below differ depending on your answer to this question. In these
cases, if you answered "Yes" follow the instructions below for that apply "For EP petitions" and
if you answered "No" follow the instructions that apply "For activated EP pathways."
Petition Request: Use the drop-down menu to select the appropriate option from the following:
1. New Efficient Producer corn starch ethanol pathway, for a facility that uses only corn
kernels as feedstock to produce ethanol, and generates only D-code 6 RINs for such
ethanol.
2. New Efficient Producer corn starch ethanol pathway, for a facility that uses only corn
kernels and grain sorghum as feedstocks to produce ethanol, and generates only D-code
6 RINs for the ethanol produced from corn.
3. New Efficient Producer grain sorghum ethanol pathway, to generate D-code 6 RINs for
ethanol produced from grain sorghum.
4. New Efficient Producer grain sorghum ethanol pathway, to generate D-code 5 or 6 RINs
for ethanol produced from grain sorghum.
5. Modification to an existing Efficient Producer corn starch ethanol pathway, for a facility
that seeks to co-produce cellulosic ethanol from corn kernel fiber and generate D-code
3 RINs for such ethanol.
6. New Efficient Producer corn starch ethanol pathway, for a facility that seeks to co-
produce cellulosic ethanol from corn kernel fiber and generate D-code 3 RINs for such
ethanol.
My facility's corn ethanol does not match any of the pathways in Table 1 to 40 CFR 80.1426
because the facility: Use the drop-down menu to select the appropriate option from the
following:
o dries more than 65% of the DGS it markets annually and does not use two of the
advanced technologies in Table 2 to 40 CFR 80.1426
o dries more than 50% of the DGS it markets annually and does not use any of the
advanced technologies in Table 2 to 40 CFR 80.1426
o N/A
7 This also applies if you are preparing the GHG Calculator as part of a petition requesting a modification to an
existing EP corn starch ethanol pathway, for a facility that seeks to co-produce cellulosic ethanol from corn kernel
fiber and generate D-code 3 RINs for such ethanol.
8 Your EP pathway is considered to be activated after your registration for the pathway has been accepted by EPA
and you are able to access your EP pathway in EMTS. You should receive an email notification when your pathway
is activated.
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The list of advanced technologies in Table 2 to 40 CFR 80.1426 is available on EPA's web page.9
If you are requesting a pathway for non-grandfathered corn ethanol and none of these options
look appropriate there may be an existing pathway for your fuel. If your petition only requests a
pathway for grain sorghum ethanol, select N/A.
My facility's sorghum ethanol does not match any of the advanced biofuel pathways in Table 1
to 40 CFR 80.1426 because the facility: Use the drop-down menu to select the appropriate
option from the following:
o does not use biogas from landfills, waste treatment plants, and/or waste digesters for all
process energy and for on-site production of all electricity used at the site
o uses more than 0.15 kWh of electricity from the grid per gallon of ethanol produced,
calculated on a per batch basis
o N/A
If your petition only requests a pathway for corn ethanol, select N/A.
Date EPA accepted the registration application for your original corn starch ethanol Efficient
Producer pathway:
o If you selected option 5 under Petition Request (see above), you will be prompted to
enter a date in this field. Enter the date that EPA activated your existing EP pathways
(the one you are seeking to modify). This is the date that EPA accepted the registration
application for the pathway. When EPA accepts a registration application, an email is
automatically sent from otaqfuels@epa.gov to the responsible corporate officer (RCO)
of the company that submitted the registration application. The subject line of such an
email includes the name of the company and the company request (CR) number
corresponding with the registration application submission, and the body of the email
says the company request "has been activated."
For EP petitions:
Earliest date that you are entering data for: In the following sheets, you will enter data on
feedstock use, energy use and fuel production. In this cell, enter the earliest date that you are
entering data for. For example, if you are entering data for the time period from April 1, 2014 to
March 31, 2015, you should enter "4/1/2014."
Latest date that you are entering data for:
o If you are entering daily data in the GHG Calculator, enter the latest date that you are
entering data for. For example, if you are entering daily data for the time period from
April 1, 2014 to March 31, 2015, you should enter "3/31/2015" in this field,
o If you are entering aggregate data in the GHG Calculator, enter the same date that you
entered under "Earliest date that you are entering data for." For example, if you are
entering aggregate data for the time period from April 1, 2014 to March 31, 2015, you
should enter "4/1/2014" in this field.10 If you are using this approach, you should
9 https://www.epa.gov/renewable-fyel-standard-program/approved-pathwavs-renewable-fyel
10 This is necessary because the GHG Calculator was originally designed for daily data entries.
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explain the time period for your aggregate data in the Notes field on the Cover Sheet
(see below).
o For details on choosing daily data or aggregate data, see the frequently asked question
in this document titled: Do 1 need to enter daily data in the GHG Calculator for an EP
petition?
For activated EP pathways:
Date EPA activated your EP pathwav(s): Enter the day that EPA activated your EP3 pathway.11
Today's date: Enter today's date.
Feedstock Checklist:
Does this facility use corn starch feedstock?
For EP petitions: Select "Yes" if your facility uses or intends to use a non-negligible
amount of corn starch to produce ethanol. Note, even if your petition is requesting a
pathway for ethanol made from grain sorghum, you must select "Yes" if your facility
uses corn starch.
For previously activated EP pathways: Enter "Yes" if EPA evaluated corn starch as a
feedstock for your facility's EP pathway. (The signed EP determination document issued
by EPA for your facility will specify whether EPA evaluated corn starch as a feedstock for
your facility's EP pathway.)
Does this facility use grain sorghum feedstock?
For petitioners: Select "Yes" if your facility uses or intends to use grain sorghum
feedstock to produce ethanol. Note, even if your petition is requesting a pathway for
ethanol made from corn starch, you must select "Yes" if your facility uses grain
sorghum.
For previously activated EP pathways: Enter "Yes" if EPA evaluated grain sorghum as a
feedstock for your facility's EP pathway. (The signed EP determination document issued
by EPA for your facility will specify whether EPA evaluated grain sorghum as a feedstock
for your facility's EP pathway.)
Does this facility use corn kernel fiber feedstock to produce cellulosic ethanol and generate D-
code 3 RINs for such ethanol? Select "Yes" or "No" from the drop-down options.
Does this facility use any other feedstocks? Select "Yes" or "No" from the drop-down options. If
you select "Yes" an error message will appear in the next row of the spreadsheet. This is
because the EP3 currently only allows for the use of corn starch and/or grain sorghum
feedstocks.12
11 The day your EP pathway was activated is the day that your registration for the pathway was accepted by EPA
and you were able to access your EP3 pathway in EMTS. You should have received an email notification when your
EP pathway was activated.
12 Parties who use other feedstocks and seek a new fuel pathway, may submit a standard petition pursuant to 40
CFR 80.1416. For information on how to submit a standard petition see: https://www.epa.gov/renewable-fuel-
standard-program/how-submit-complete-petition-approved-pathwav-under-renewable-fuel
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Other Information:
Baseline volume per 40 CFR 80.14003: Enter the "grandfathered" baseline volume for your
facility in gallons. If your facility does not qualify as a grandfathered facility (e.g., if it was not in
operation or had not commenced construction prior to December 19, 2007) leave this field
blank. This information is for EPA's reference only; it does not impact the GHG Calculator
results.13
Notes: Use this field to enter important notes about the data entered in the GHG Calculator. For
example, if data are not provided on a daily basis, use this field to explain how the data are
reported (for details see: Do 1 need to enter daily data in the GHG Calculator for an EP petition?).
Contact Info
Use this tab to enter information about the responsible corporate officer (RCO) and the point of contact
(POC) for the petitioning facility. The signed determination document responding to your petition will
be addressed and mailed to the RCO using the information provided in this tab. Questions during the
petition review process will be sent to the POC. (The POC and RCO may be the same person.) The entry
fields on this tab (e.g., name, address, city) should be self-explanatory. Please spell out job titles, street
names, etc., and refrain from using unnecessary abbreviations. If you have questions about how to
enter data on this tab, please send them to the Fuels Programs Support Line.14
Conn Use Data
On this tab enter your facility's corn use, in bushels, in the green-shaded cells. Two data entry methods
are available (use only one):
Inventory approach: Enter the starting inventory, shipments received and ending inventories.
All units are entered in bushels.
Direct measurement approach: Enter the amount used each day (or for a multi-day period if
entering aggregate data, see Section 4(A) of this document for details)
The GHG Calculator is designed for users to choose one data entry method (inventory or direct
measurement) and use that method for all data entry in the sheet. The tool does not support using both
methods on a single day, or switching between methods for different entry dates.
For each entry method there is an optional notes column to provide additional information about how
the data were collected.
Conn Moisture Data
Enter all of the corn deliveries to your facility including the moisture content, in mass percent, of each
and every delivery. This information is used to calculate the standardized bushels of corn at 15.5%
moisture.
The dates in column A are entered manually. If your facility receives more than one shipment on a given
day, you can use multiple rows to record shipments for that day. If your facility does not receive corn
13 For more information on what is meant by "grandfathered" fuel see: https://www.epa.gov/renewable-fuel-
standard-program/program-overview-renewable-fuel-standard-program
14 https://www.epa.gov/renewable-fuel-standard-program/forms/contact-us-about-renewable-fuel-standard-
program
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shipments for a given day you can skip to the next day. Examples of this are illustrated below in Figure
3. Optional columns are provided to record additional information about each delivery, including time,
number, type and other notes.
Figure 3: Example data entry in the Corn Moisture Data tab
Day
[...]
Amount of Corn in Delivery
Moisture Content
DD/MM/YYYY
[...]
Bu
Mass %
4/1/2014
[...]
100
15.5%
4/1/2014
[...]
200
14%
4/5/2014
[...]
100
15.5%
For the calculator to work properly, a delivery amount greater than zero and a moisture content must
be entered for the date listed in cell A4 (i.e., the earliest date that you are entering data for). If there
were no corn deliveries on the date listed in cell A4 then enter the previous day inventory and the
average moisture content for the corn in inventory.
Sorghum Use Data
On this tab enter your facility's grain sorghum use, in bushels. Two data entry methods are available:
inventory approach or direct measurement approach (for explanation see the instructions for the Corn
Use Data tab, above). The GHG Calculator is designed for users to choose one data entry method
(inventory or direct measurement) and use that method for all data entry in the sheet. The tool does not
support using both methods on a single day, or switching between methods for different entry dates.
For each entry method there is an optional notes column to provide additional information about how
the data were collected.
Sorghum Moisture Data
On this tab enter all of the grain sorghum deliveries to your facility including the moisture content, in
mass percent, of each and every delivery. This information is used to calculate the standardized bushels
of grain sorghum at 13% moisture. (See the data entry example given above for the Corn Moisture Data
tab.)
For the calculator to work properly, a delivery amount greater than zero and a moisture content must
be entered for the date listed in cell A4 (i.e., the earliest date that you are entering data for). If there
were no sorghum deliveries on the date listed in cell A4 then enter the previous day inventory and the
average moisture content for the sorghum in inventory.
Natural Gas Use Data
On this tab enter your facility's natural gas use in standard cubic feet.
Space is provided for you to record data from as many meters as necessary. For example, to add data
from an additional meter, copy columns H-J and paste them into columns L-N. Relabel the meter
number, or give it a new name. Repeat these steps as many times as needed moving from left to right in
the spreadsheet. Finally, revise the formula in column B so that it sums the "Daily Amount Used" from
all of the meters you have added (make sure to use the fill down in Excel so the formula is accurate for
all of the applicable rows).
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Biiogas L :a
On this tab enter your facility's biogas use in standard cubic feet. You must specify the methane
content, in volume percent, for the biogas your facility uses. If methane is measured directly, then enter
100% in the percent methane column for each meter.
Space is provided for you to record data from as many meters as necessary. For example, to add data
from an additional meter, copy columns J-N and paste them into columns P-T. Relabel the meter
number, or give it a new name. Repeat these steps as many times as needed moving from left to right in
the spreadsheet. Finally, revise the formula in column B so that it sums the "Daily Amount CH4 Used"
from all of the meters you have added (make sure to "fill down" the formula so that it is accurate for all
of the applicable rows).
Electricity Use Data
On this tab enter your facility's use of grid electricity in kilowatt hours. Space is provided for you to
record data from as many meters as necessary (See the instructions for the Natural Gas Use Data for
details on how to add meters).
Coal Use Data
On this tab enter your facility's coal use in tons. Two data entry methods are available: inventory
approach or direct measurement approach (for explanation see the instructions for the Corn Use Data
tab, above). The GHG Calculator is designed for users to choose one data entry method (inventory or
direct measurement) and use that method for all data entry in the sheet. The tool does not support
using both methods on a single day, or switching between methods for different entry dates.
Biomass Use Data
On this tab enter the amount of biomass used by your facility as process heat fuel in dry pounds. Two
data entry methods are available: inventory approach or direct measurement approach (for explanation
see the instructions for the Corn Use Data tab, above). For both data entry methods, you must enter
the mass and average moisture content (weight percent) of the biomass used by your facility.
The GHG Calculator is designed for users to choose one data entry method (inventory or direct
measurement) and use that method for all data entry in the sheet. The tool does not support using both
methods on a single day, or switching between methods for different entry dates.
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At this time to qualify for the EP3, all biomass used for process heat fuel must meet the RFS regulatory
definition for crop residue at 40 CFR 80.1401.15 See the July 2014 RFS rule (79 FR 42128) for more
information on what EPA considers to be a crop residue for the RFS program.16
IE'"" II Production Data
On this tab enter the amount of all ethanol produced at your facility. Two data entry methods are
provided:
Direct Measurement Approach: Enter the standardized volume of undenatured (200 proof)
ethanol produced at your facility, in gallons adjusted to 60° F.
Actual Temperature and Volume Approach: Enter the actual volume of undenatured ethanol
produced at your facility, in gallons, and the average temperature of the ethanol in degrees
Fahrenheit (volume and temperature should be measured at the same time).
The GHG Calculator allows users to switch between measurement approaches, and/or use both
approaches for the same day.
CFK Ethanol Production Data
On this tab enter the amount of cellulosic ethanol produced from corn kernel fiber feedstock at your
facility, for which D-code 3 RINs have been, or shall be, generated. See the instructions for the previous
tab on the two available data entry methods.
Confirm Data
After reviewing the data entered in the tabs listed above select from the following two options for each
day that you entered data for:
1. CONFIRMED: For this date valid data were properly collected through continuous monitoring
and accurately recorded in this spreadsheet.
2. MISSING DATA: On this date one or more of the required data inputs were not properly
collected or reported.
When submitting a GHG Calculator as part of a petition, you should select option one (confirmed) for all
of the dates that you entered data for. If you choose MISSING DATA for any of the dates that you
entered data for your petition will be returned as incomplete.
15 Per 40 CFR 80.1401: Crop residue means biomass left over from the harvesting or processing of planted crops
from existing agricultural land and any biomass removed from existing agricultural land that facilitates crop
management (including biomass removed from such lands in relation to invasive species control or fire
management), whether or not the biomass includes any portion of a crop or crop plant. Biomass is considered crop
residue only if the use of that biomass for the production of renewable fuel has no significant impact on demand
for the feedstock crop, products produced from that feedstock crop, and all substitutes for the crop and its
products, nor any other impact that would result in a significant increase in direct or indirect GHG emissions.
16 Examples of materials that EPA considers crop residue are: sugarcane and sweet sorghum bagasse; kernel fiber
from barley, corn, oats, rice, rye, grain sorghum and wheat; and stover from corn and grain sorghum; straw from
barley, oats, rice, rye, soybeans and wheat.
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If you choose MISSING DATA or leave this cell blank for any of the dates, the GHG Calculator will
evaluate all of the ethanol produced on that date as having lifecycle greenhouse gas emissions of 98.2
kgCC>2e/mmBtu, the lifecycle GHG emissions for the gasoline baseline.17
Quick Check
Provides a quick check of whether you are missing required information.
For EP petitions, if this tab identifies any missing information (marked as "ERRORS") your petition will be
returned as incomplete.
This tab is meant as a tool to help users do a quick check for missing information. It is not meant as full
check of the completeness or accuracy of the information entered in the GHG Calculator. Even if this
tab does not identify missing or erroneous information, EPA may still return your petition as incomplete
if we find missing or incorrect data. It is the petitioner's responsibility to ensure that the data provided
are complete and accurate. Similarly, for producers with an activated EP pathway, it is the fuel
producer's responsibility to ensure that the data provided are complete and accurate.
Daily Data 5
This tab provides a summary of the data entered in the preceding data entry tabs. We recommend
reviewing the information on this tab as a way to help identify and prevent errors.
Till iriies Results
This tab provides a time series look at your fuel's lifecycle GHG emissions based on the data you
entered. Daily and rolling average results are provided for corn and grain sorghum ethanol. The 365-
day rolling average GHG results are based on the average lifecycle GHGs for the fuel produced over the
preceding 365 days. Results are provided for corn ethanol and grain sorghum ethanol in terms of
kgC02e/mmBtu. The tab also shows on which days the corn ethanol produced at your facility meets the
20% GHG reduction threshold and the days when the grain sorghum ethanol meets the 50% GHG
reduction threshold. The percent GHG reductions compared to the gasoline baseline are also displayed
here.
Results Summary
After all of the data is properly entered in the data entry tabs, this tab provides a summary of the 365-
day rolling average lifecycle GHG emissions during the specified averaging time period for the corn
and/or grain sorghum ethanol produced at your facility.
For an EP petition, the results on this tab should show that your fuel meets the applicable GHG
reduction threshold (20% reduction for renewable fuel or 50% reduction for advanced biofuel). If you
submit a GHG Calculator that does not demonstrate adequate GHG reductions, EPA will return the
petition as incomplete.
Corn Ethanol GHG Callcs
This tab is used to calculate the daily and 365-day rolling average lifecycle GHG emissions for corn
ethanol based on the data entered in the preceding tabs. This tab is protected from editing.
17 Details on what constitutes valid versus missing data should be provided in the EP determination document for
your facility and the Compliance Monitoring Plan included as part of your registration for the EP3 pathway.
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Sorghum Ethan oil GHG Callcs
This tab is used to calculate the daily and 365-day rolling average lifecycle GHG emissions for grain
sorghum ethanol based on the data entered in the preceding tabs. This tab is protected from editing.
Em is Facs
This information tab includes the GHG emissions factors used by the GHG Calculator. These values are
for reference and protected from editing.
Abbreviations
This tab includes a list of abbreviations used on other tabs. It also stores list data used on other tabs,
and is protected from editing.
RIF82500~Coirn
Corn starch ethanol data are automatically generated on this tab to help with quarterly reporting using
the RFS Efficient Producer Data Form (RFS2500).18 To assist with reporting, the data from this tab can be
copied and pasted in the Unified Report Form.19 Note that fields 2-10 are not automatically generated,
and need to be completed by the reporting party. This tab is meant to assist with reporting - reporters
are responsible for the accuracy of all the data they report.
RFS2500-Sorghum
Grain sorghum ethanol data are automatically generated on this tab to help with quarterly reporting
using the RFS Efficient Producer Data Form (RFS2500). See the instructions for the previous tab for
more information.
RIFS2500-CKIF
Corn kernel fiber ethanol data are automatically generated on this tab to help with quarterly reporting
using the RFS Efficient Producer Data Form (RFS2500). The only data generated for corn kernel fiber
ethanol is the volume cellulosic ethanol produced from corn kernel fiber. Data fields 14-21 for rows
associated with corn fiber ethanol production can remain blank for reporting.
For-IE IP A-Use
The EPA uses this tab to expedite review of GHG Calculators that are submitted as part of EP3 petitions.
It is protected from editing.
18 https://www,epa,gov/fuels-registration-reporting-and-compliance-help/rfs25QO-rfs-efficient-producer-data-
report
19 https://www.epa.goy/fuejs-regjstration-reporting-and-compliance-help/unified-report-fqrm
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A|jj 1 v'i 1 I I 1 in' 1 Aci on; ins
Abbreviation or Acronym
Description
Btu
British Thermal Units
bu
Bushel
CAA
Clean Air Act
CFR
Code of Federal Regulations
ch4
Methane
DGS
Distillers grains and solubles
EISA
Energy Independence and Security Act
EP
Efficient Producer
EP3
Efficient Producer petition process
EPA
Environmental Protection Agency
F
Fahrenheit
FR
Federal Register
gal
Gallon
GHG
Greenhouse gas
Hr
Hour
kgC02e
Kilograms of carbon dioxide-equivalent emissions
kWh
Kilowatt hour
lb
Pound
LCA
Life cycle assessment
LHV
Lower heating value
mmBtu
Million British Thermal Units
RFS
Renewable Fuel Standard
RIN
Renewable Identification Number
scf
Standard cubic feet
std. gal
Standardized gallon of ethanol at 60° F
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Appendix 2: lifecycie GHG Equations
The GHG Calculator uses the following equations to calculate the lifecycie GHG emissions for corn and
grain sorghum ethanol.
Conn Starch Ethanol
The 365-day rolling average lifecycie GHG emissions are calculated using the following formula:
LCghgc = GHGuc + GHGpc + GHGd
Where:
LCghgc = Lifecycie GHG emissions, in kgC02e/mmBtu, of the volume of all corn ethanol produced at the
facility during the averaging time period.
GHG uc Upstream GHG emissions, in kgC02e/mmBtu, related to the production and transport of the
volume of corn starch feedstock used to produce all corn ethanol produced at the facility during the
averaging time period, calculated per the formula below.
GHG pc - Process GHG emissions, in kgC02e/mmBtu, related to the processes used for conversion of corn
into ethanol during the averaging period, including energy used for feedstock, fuel and co-product
operations, as calculated per the formula below.
GHGd = Downstream GHG emissions, in kgC02e/mmBtu, related to the distribution and use of all corn
ethanol produced during the averaging period, calculated per the formula below.
GHGuc is calculated according to the following formula:
9.73 * Bc
Qj-JQ = _
U° (Vcss * 0.076* Rc)
Where:
9.73 = Upstream emissions factor for corn, in kgC02e per bushel, based on the lifecycie GHG modeling
done by EPA for the March 2010 RFS rule.
Bc = Bushels of corn used as feedstock to produce ethanol during the averaging time period in terms of a
standard bushel at 15.5% moisture. Bc is calculated according to the following formula:
/ 1 mc \
Bc = Bc * (l-O.ISs)
Where:
BCm = Bushels of corn used to produce ethanol during the averaging time period.
mc = Average moisture content of corn, in mass percent, for the corn delivered for use as
feedstock to produce ethanol during the averaging time period.
0.155 = Moisture content of a standard bushel of corn at 56 pounds per bushel.
Vcss = Vs - Vcfs, the standardized volume of corn starch ethanol produced during the averaging time
period, in gallons of undenatured ethanol.
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Vs = Standardized volume of all ethanol produced at the facility during the averaging time period
(including both corn starch and grain sorghum ethanol), in gallons of undenatured ethanol. In
determining the standardized volume, the actual volumes of ethanol shall be adjusted to a standard
temperature of 60 degrees Fahrenheit using the following formula:
Where:
VA = Actual volume of undenatured ethanol, in gallons.
T = Actual temperature of ethanol, in degrees Fahrenheit, measured at the same time that VA is
measured.
0.00114 = Coefficient to standardize volumes of undenatured ethanol.
60 = Standard temperature, in degrees Fahrenheit, for volumes of ethanol.
459.67 and 5/9 = Conversion factors for Fahrenheit to Kelvin
Vcfs = Standardized volume of ethanol produce from corn kernel fiber at the facility during the averaging
time period, in gallons of undenatured ethanol, determined in accordance with the methods and
techniques specified in the facility's activated registration on file with EPA for the crop residue (i.e., corn
kernel fiber) ethanol pathway in row K of Table 1 to 40 CFR 80.1426.
0.076 = Energy content of ethanol, in mmBtu/gallon (lower heating value).
Bgs = Bushels of grain sorghum used as feedstock to produce ethanol during the averaging time
period in terms of a standard bushel at 13% moisture. BGs is be calculated according to the
following formula:
BGSm = Measured bushels of grain sorghum used as feedstock to produce ethanol during the
averaging time period.
mgs = Average moisture content of grain sorghum, in mass percent, for the grain sorghum
delivered for use as feedstock to produce ethanol during the averaging time period.
0.13 = Moisture content of a standard bushel of grain sorghum at 56 pounds per bushel.
y5 = VA * 1 - 0.00114 *[ {T + 459.67}
Rr = (Vt:\ which is the ratio of corn feedstock used, on a mass basis.
c Vbc+bgs;'
Where:
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GHGrc is calculated according to the following formula:
GHGtherm , GHGelec
0.963 * Rqs + Rc 0.993 * Rq$ + Rc
Where:
GHGjherm = GHG emissions, in kgC02e, associated with producing and using thermal energy used for
feedstock, fuel and co-product operations during the averaging period. GHGjherm is calculated according
to the following formula:
Where:
p = Type of fuel used.
PEp = a measure of the amount of fuel p used as energy used for feedstock, fuel and co-product
operations, as follows:
PEi = Standard cubic feet (scf) of natural gas used in feedstock, fuel and co-product
operations.
PE2 = Standard cubic feet (scf) of biogas CH4 from landfills, waste treatment plants and/or
waste digesters used as energy used for feedstock, fuel and co-product operations.
PE3 = Tons of coal, used as energy used for feedstock, fuel and co-product operations.
LHVpe,p = Lower Heating Value factor for fuel type p, as follows:
LHVpe,i = 983 Btu per scf of natural gas.
LHVpe,2 = 983 Btu per scf of biogas CH4.
LHVpe,3 = 19,546,300 Btu per ton of coal.
EFpe,p = Lifecycle GHG emissions factor for fuel type p, (based on lower heating value) as follows:
EFpe,i = 6.86 * 10"5 kgC02e per Btu of natural gas.
EFpe,2 = 3.64 * 10"7 kgC02e per Btu of biogas CH4.
EFpe,3 = 1.12 * 10"4 kgC02e per Btu of coal.
BIO = Dry pounds (0% moisture) of biomass used as energy used for feedstock, fuel and co-
product operations.
EFbio = 5.40*10"3 kgC02e per dry lbs of crop residue biomass.
Rgs = , which is the ratio of grain sorghum feedstock used, on a mass basis.
3
GHGtherm
^ (PEp * LHVpE p * EFPE p) + BIO * EFbio
v=1
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GHG elec - GHG emissions, in kgC02e, associated with producing and using electrical energy for
feedstock, fuel and co-product operations during the averaging period. GHGelec is calculated according
to the following formula:
GHGelec = ELEC * EFeiec
Where:
ELEC = kWh of Grid electricity used as energy used for feedstock, fuel and co-product
operations.
EFeiec = 0.750 kgC02e per kWh of grid electricity, based on the United States grid average.
0.963 = Adjustment factor for grain sorghum processing using 3.7% less thermal energy than corn
ethanol processing.
0.993 = Adjustment factor for grain sorghum processing using 0.7% less electrical energy than corn
ethanol processing.
GHGd is calculated to be 2.1 kgCC^e per mmBtu of ethanol.
Days with missing data
For all corn ethanol produced by the facility during a day where there is missing data on any of the
factors described above, the corn ethanol produced on all such days is assessed as having lifecycle GHG
emissions of 98.2 kgC02e per mmBtu. In the spreadsheet, this is done by adjusting GHGD so that the
lifecycle GHG emissions for those days equals 98.2 kgC02e per mmBtu.
Grain Sorghum Ethanol
The 365-day rolling average lifecycle GHG emissions are calculated using the following formula:
LCghggs = GHGugs + GHG PGS + GHGd
Where the terms in the equation are the similar to the terms specified above for corn ethanol lifecycle
GHG emissions, but with references to corn replaced with grain sorghum.
GHGugs is calculated according to the following formula:
8.93 * Bqq
fUf _
Ugs (Vgss* 0.076* Rqs)
Where:
8.93 = Upstream emissions factor for grain sorghum, in kgC02e per bushel, based on the lifecycle GHG
modeling done by EPA for the December 2012 grain sorghum rule.
Vgss = Vs - VCfs, the standardized volume of grain sorghum ethanol produced during the averaging time
period, in gallons of undenatured ethanol.
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GHGrgs is calculated according to the following formula:
GHGTherm . GHGp
¦ * 0.963 + n nno n gC, n * 0.993
njlr, _ 0.963 *RCS + RC ' 0.993 * Rcs + Rc
GHGpcs~ VGSS* 0.076
Days with missing data
Days with missing data for grain sorghum ethanol are treated the same as days with missing data for
corn ethanol (see above).
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