EPA Underestimates Emissions from Palm Oil Biofuels, Public Comment Deadline Tomorrow

Scientific and environmental groups summarized their comments on the Environmental Protection Agency's (EPA) proposed finding that palm oil should not qualify for inclusion in the EPA's Renewable Fuels Standard (RFS). While the organizations agreed with the EPA's conclusion not to include palm oil, they argued that EPA's analysis actually underestimates the greenhouse gas emissions of palm oil and the serious environmental problems that palm cultivation creates.

"The emissions of palm oil based biofuels substantially exceed the emissions from conventional petroleum diesel," said Dr. Jeremy Martin, Senior Scientist at the Union of Concerned Scientists.

This is one of the most critical climate and environmental decisions the Obama administration will make, with thousands of square miles of rainforest, and the corresponding tons of greenhouse gas emissions, at stake.

Several scientific and environmental groups will submit stakeholder comments to the EPA in advance of the deadline tomorrow, Friday, April 27^th. The comments are a response to the EPA's Notice of Data Availability (NODA), which analyzes palm oil used as a feedstock to produce biodiesel and renewable diesel. EPA's analysis found that palm oil based biodiesel fails to meet the minimum qualifying standard of 20% fewer greenhouse gas emissions than conventional petroleum based diesel for the RFS, as well as the 50% greenhouse gas emissions reduction to qualify as a renewable diesel.

The EPA is under pressure to reverse this finding from lobbying groups aligned with the Indonesian, Malaysian, and Chinese palm oil industry, such as the American Legislative Exchange Council (ALEC) and other extremist organizations that are ideologically opposed to the Renewable Fuels Standard, yet have suddenly decided they want the EPA to include palm oil under the RFS government mandate.

"It is a disturbing development to see a politically motivated group like ALEC join forces with the shadowy palm oil lobby from Malaysia and Indonesia as well as with huge agribusiness companies Cargill and Wilmar to pressure the EPA to overturn what is supposed to be a science-based decision made in the best interests of the American people," said Laurel Sutherlin with the Rainforest Action Network. "The question the EPA is tasked with answering is whether biofuels made with palm oil meet our nation's greenhouse gas requirements as a renewable fuel. The stark reality of the impacts of palm oil plantation expansion in Southeast Asia, where nearly 90% of the world's palm oil comes from, makes it clear that it does not."

Rainforests are among the largest natural storehouses, or sinks, of carbon on earth and palm oil has quickly become one of the leading drivers of rainforest destruction in the world today, making palm oil production a globally significant source of carbon pollution. It has been estimated that deforestation in Indonesia alone contributes more carbon to the atmosphere than all the transportation sector in the US combined.

Analysis of EPA's assessment by scientific groups such as the Union of Concerned Scientists and the International Council on Clean Transportation found that in several important areas, EPA substantially underestimated the likely emissions of palm oil. They identify three main areas of concern:

1. The EPA's analysis underestimates the extent to which palm oil expansion is occurring on peat soils, which leads to a substantial underestimate of heat trapping emissions.

- EPA bases its findings on the assumption that only nine percent of palm oil expansion will occur on peat land in Malaysia and 13 percent in Indonesia. However, a new report by the National Academy of Sciences, released today, says that 50 percent of oil palm plantations were established on peat lands through last year. The study found that if oil palm expansion continues, with no restrictions on peat land development, almost 90 percent of palm oil's greenhouse gas emissions will come from peat lands by 2020.

- EPA employs a statistical factor "Kappa" in its calculations that its own creator has repudiated in an article entitled "Death to Kappa": "We know of no cases in remote sensing where the Kappa indices offer useful information... The first author apologizes for publishing some of the variations of Kappa in 2000, and asks that the professional community does not use them."

- EPA uses wildly optimistic projections on yield, failing to properly factor the palm oil planting cycle in which palm trees decline significantly in productivity as they mature.

2. The EPA projects that 42% of the palm oil used for biodiesel will not be replaced, as poor consumers will consume less palm oil as food in response to higher prices. Loss of a food supply should not count as an environmental benefit for fuel.

3. The EPA has received claims from industry and government bodies about coming improvements in yield, governance, land development policies and palm oil mill operations. Given the significant risks of palm oil expansion and a history of deforestation and illegal activity, EPA should reject optimistic claims and projections that are unsupported by conclusive evidence. This will preserve the incentive for the governments, producers, and mills to make good on their commitments which can be recognized once they have occurred.

While the palm oil industry claims to embrace sustainability, its' actions on the ground prove to the contrary: In just the last few weeks, the palm oil industry rushed into Sumatra's world-famous Tripa swamp forest, home to one of the world' densest populations of critically endangered orangutans. Plantation owners have purposely lit dozens of forest fires to clear the land, meanwhile sending the ultra carbon-rich peat soils into the atmosphere in a massive inferno - and killing an estimated one hundred of the world's 6000 remaining Sumatran orangutans.

"The very month that the palm oil industry is burning and clearing the world famous carbon-rich Tripa forest and its orangutans, they're trying to browbeat the EPA into declaring this fuel so sustainable that they should qualify for a massive U.S. government mandate," said Glenn Hurowitz, Climate Advisers Director of Campaigns. "I don't think so. If the palm oil industry wants to actually reduce its environmental impact and qualify for this mandate, the solution is simple: end deforestation for palm."

Clearing and burning of rainforests for palm oil plantations is one of the primary drivers of deforestation in Southeast Asia, and is one of the major reasons Indonesia is the world's third largest global warming polluter, just behind China and the United States.

EPA's decision will have far broader influence than just in US biofuels markets. Other governments are looking closely at EPA's findings as a basis for their own assessments of palm oil's impact. In particular, Europe, which uses substantially more palm biodiesel than the United States, is currently assessing the shape of its own biofuels mandate.

"U.S. consumers should not be forced to fill their gas tanks with a fuel that is pushing species like orangutans and Sumatran tigers to the brink of extinction, is one of the world's leading drivers of climate change, and whose production involves child and slave labor," Hurowitz said. "Palm oil is so polluting that it somehow manages to make even dirty old oil look like an environmentalist dream."