Letter to Peter Orzag, Director of the Office of Management and Budget

For the signed PDF of this letter, please CLICK HERE.

April 2, 2009

Mr. Peter Orszag
Director
Office of Management and Budget
Eisenhower Executive Office Building
1650 Pennsylvania Ave., NW
Washington, DC 20503
 
Dear Director Orszag:

We are writing regarding EPA’s Notice of Proposed Rulemaking (NOPR) for implementation of the updated Renewable Fuels Standard (RFS-2), and, in particular, with regard to the statutorily required analysis of direct and indirect greenhouse gas emissions.   
 
As you know, the Energy Independence and Security Act (EISA) of 2007 (P.L. 110-140) explicitly requires EPA to include “direct emissions and significant indirect emissions, such as significant emissions from land use changes, as determined by the Administrator.” 

This provision is central to meeting the intent of the RFS’s expanded mandate for biofuels as a tool to fight global warming pollution.  Recent science has made it abundantly clear that some biofuels production can make global warming worse by driving global deforestation and loss of grasslands, which releases large amounts of carbon into the atmosphere.  Although we understand that some may be calling for release of the proposal without values for indirect land-use change, doing so would undermine the intended environmental benefits of the RFS-2 and would not be consistent with the letter of the law. 

After eight years of denial and delay in meeting the urgent challenge of global warming, we must embark now on a new era of scientific integrity and transparency.  We ask you to join us in this effort by ensuring that EPA’s RFS NOPR includes a full life-cycle analysis with consideration of direct and indirect emissions, based on the best available science and as prescribed by the law.  

We look forward to working with you on this and other matters. 

For the signed PDF of this letter, please CLICK HERE.

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