In individual and joint comments submitted to EPA, CATF urges the Agency to ensure that annual biofuel consumption requirements for 2017 and 2018 do not exacerbate the environmental damage already attributable to the Renewable Fuel Standard program.
CATF comments and multi-organization joint comments urging EPA’s Science Advisory Board (SAB) to fix the discussion on “temporal scale” in the SAB draft report on EPA’s proposed framework for determining the net CO2 emissions from biomass-burning power plants.
CATF and other environmental and public health organizations push EPA to revisit its proposal to allow biofuels made from the oilseed plant jatropha curca to qualify for credits under the Renewable Fuel Standard. The comments spotlight the negative impacts of jatropha production on greenhouse gas emissions from land use change,…
In individual and joint comments submitted to EPA on the proposed “renewable volume obligations” for the Renewable Fuel Standard, CATF urges the Agency to use its full statutory authority to reduce the RFS’s annual biofuel consumption requirements below the target levels set by Congress in 2007.
Comments from CATF and thirteen other organizations to the White House Office of Management and Budget concerning EPA’s Clean Power Plan, alerting OMB to environmental and legal problems associated with EPA’s proposed treatment of carbon dioxide emissions from biomass combustion.
In response to the California Air Resource Board’s ongoing review of indirect land use change (ILUC) emissions and their effect on the carbon intensity calculations for biofuels, CATF shared its analyses of recent studies that examine water availability, yields, and other key factors that influence ILUC.
In response to EPA’s proposed determination that fuels made from the oilseed crop brassica carinata can qualify as “advanced biofuels” under the Renewable Fuel Standard, CATF comments focus on several problematic assumptions in the Agency’s lifecycle GHG emissions analysis.