The National Biodiesel Board or NBB is the national trade association representing the biodiesel industry in the United States. Biodiesel is a domestic, renewable fuel for diesel engines derived from natural oils? like soybean oil?, and which meets the specifications of ASTM D6751.

The NBB is currently mounting a grassroots campaign against certain changes to the Renewable Fuels Standard?, known as RFS-2. The campaign is being supported by a number of biodiesel organizations such as the North Carolina Biodiesel Association, and others.

The call to action is as follows:

Please speak up to help save the biodiesel industry and our drive toward economic development, energy independence, and climate change mitigation. Click here to send an email to the EPA to support biodiesel or visit the NBB to learn more.

At the end of 2007, we were all encouraged when Congress passed a Renewable Fuels Standard RFS in order to wean the US off foreign oil and spur domestic economic growth through biofuels. Unfortunately, the proposed EPA rule^citation? threatens to wipe out the US biodiesel industry. Seventy percent ^citation?of existing biodiesel feedstock stands to be excluded from the RFS, driving prices up further and limiting production. This exclusion harms not only the users of sustainable plant oils, but the entire industry – threatening the survival of the biodiesel industry and future opportunities for innovation. This will have a devastating impact on the environment, energy independence, and our economy.

While the primary goal of the RFS is achieving energy independence and security by supporting domestic, renewable fuel use, Congress also saw fit to include environmental protections such as prohibiting the clearing of land for biofuel production and requiring that biodiesel and other advanced biofuels reduce greenhouse gas or GHG emissions compared to petroleum by a minimum of 50%. Worthy goals - the US biodiesel industry adamantly supports the protection of forests and GHG reductions. Biodiesel is proven to reduce lifecycle greenhouse gas emissions by 78% or more.^citation?

Unfortunately, the proposed rule ^citation? seeks to include the international indirect land use change effects in calculating biodiesel’s GHG reductions. Modeling these changes is a new discipline, which can yield dramatically different results based on even small modeling input changes. In light of these facts, and the fact that this rule could devastate the biodiesel industry, which is widely regarded as the most energy and environmentally efficient, commercially available alternative fuel available today, we ask you to write to EPA and urge them to reconsider their proposed rule.

While we commend EPA for attempting to undertake this monumental challenge, we have identified several flaws in the attempts to model indirect emissions from projected, not actual, land use changes in other countries. These flaws include:

• Actual land use data runs counter to current modeling results. For example, when US biodiesel production increased exponentially between 2004-2008, soybean acreage in Brazil decreased by 1.5 million hectares. ^citation?
• The models do not have the capacity to model or compare factors driving indirect land use change such as foreign policy, alternative investment decisions, alternative industry trends and policies, subsistence farming, even though these factors are the primary drivers of land use change.
• Many of the inputs these models are inaccurate or obsolete. For example, the model penalizes soy for nitrogen emissions, when, in fact, soy fixes nitrogen in the soil and ''reduces'' emissions according to the International Panel on Climate Change? ^citation?.
• The science of “indirect impacts” is not currently developed. In its place, EPA had to combine multiple models together to produce data. These models were not designed to be combined. When the output of one model is used as the input for the next, margins of error are multiplied and the final results are not reliable.
• Petroleum GHG? calculations do not include comparable but definitive “indirect” impacts. In determining relative GHG benefits, it is essential to compare apples to apples.
• Tropical deforestation was a problem well before there ever was a biodiesel industry. The quickest, most effective way to end this practice is to address its direct causes, such as logging. Looking to weakly-linked indirect actions is not an effective or logical solution for change.
• Thousands of jobs and businesses are dependent on the biodiesel industry. Sacrificing these jobs based on overseas actions, over which Americans have no control, is unprecedented and irrational.

Please preserve America’s renewable fuels industry by asking EPA to move forward with a fuel standard that includes biodiesel. Time is limited - visit the RFS Action Center at www.biodiesel.org/news/RFS/ to learn more and submit comments EPA.

This message is from the National Biodiesel Board Sustainability Task Force:

• Darryl Brinkmann, American Soybean Association?
• Victoria Carver, Iowa Soybean Association?
• Dennis Fisher, Archer Daniels Midland?
• Rachel Burton, Piedmont Biofuels
• Tim Maneely, Knack Process Design?
• Emily Landsburg, BlackGold Biofuels
• Dennis Smith, Baker Commodities?
• Jeff Trucksess, Green Earth Fuels?
• Brian Young, Element Strategic?