PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO AMEND ITS “AGGREGATE COMPLIANCE” APPROACH TO THE DEFINITION OF “RENEWABLE BIOMASS” UNDER THE RENEWABLE FUEL STANDARD IN ORDER TO PREVENT THE CONVERSION OF NATIVE GRASSLAND

The petition argues that the EPA's aggregate compliance scheme allows the conversion of millions of acres of native grasslands into corn and soy cropland, violating the Energy Independence and Security Act (EISA) of 2007. This conversion is linked to significant greenhouse gas emissions, water pollution, and habitat loss. The petitioners request that the EPA require individualized proof of compliance for each biomass source and adjust renewable volume obligations to match the supply of EISA-compliant land.

• Since the passage of EISA, actively managed cropland in the U.S. increased by approximately 4 to 7.8 million acres, with corn and soy production for biofuels driving much of this conversion.
• The conversion of native grasslands to corn ethanol production creates a "carbon debt," meaning it would take at least 93 years for the cumulative emissions of the ethanol to be lower than those of the petroleum it replaces.
• Increased land conversion for biofuels leads to higher nitrogen fertilizer use, contributing to water pollution and the expansion of the Gulf of Mexico "dead zone," which reached a record 22,720 km2 in the summer of 2017.
• The expansion of cropland into marginal and sensitive areas has resulted in the drainage of over 136,000 acres of wetlands in the Western Corn Belt, with 42% of these losses concentrated in PPR wetlands.
• Land conversion harms the agricultural economy by reducing biological services, such as natural pest control; the loss of biocontrol for soybean aphids due to corn ethanol expansion costs farmers an estimated $60 million annually.
• The petitioners request that the EPA require biofuel producers to provide documentation (such as sales records or management plans) to prove each source of biomass was grown on EISA-compliant land to qualify for a Renewable Identification Number (RIN).

APA

Earthjustice (2018). PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO AMEND ITS “AGGREGATE COMPLIANCE” APPROACH TO THE DEFINITION OF “RENEWABLE BIOMASS” UNDER THE RENEWABLE FUEL STANDARD IN ORDER TO PREVENT THE CONVERSION OF NATIVE GRASSLAND. https://earthjustice.org/wp-content/uploads/aggregatecompliancepetition.pdf

Chicago

Earthjustice. PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO AMEND ITS “AGGREGATE COMPLIANCE” APPROACH TO THE DEFINITION OF “RENEWABLE BIOMASS” UNDER THE RENEWABLE FUEL STANDARD IN ORDER TO PREVENT THE CONVERSION OF NATIVE GRASSLAND. 2018. https://earthjustice.org/wp-content/uploads/aggregatecompliancepetition.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO AMEND ITS “AGGREGATE COMPLIANCE” APPROACH TO THE DEFINITION OF “RENEWABLE BIOMASS” UNDER THE RENEWABLE FUEL STANDARD IN ORDER TO PREVENT THE CONVERSION OF NATIVE GRASSLAND |date=30 October 2018 |url=https://earthjustice.org/wp-content/uploads/aggregatecompliancepetition.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2018petition, author = {{Earthjustice}}, title = {{PETITION TO THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY TO AMEND ITS “AGGREGATE COMPLIANCE” APPROACH TO THE DEFINITION OF “RENEWABLE BIOMASS” UNDER THE RENEWABLE FUEL STANDARD IN ORDER TO PREVENT THE CONVERSION OF NATIVE GRASSLAND}}, publisher = {Earthjustice}, year = {2018}, month = oct, url = {https://earthjustice.org/wp-content/uploads/aggregatecompliancepetition.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }