U.S. soybean farmers have much to lose and little to gain from the current language in the Environmental Protection Agency’s proposed rule on the implementation of the expanded Renewable Fuel Standard.

“The EPA’s proposed rule on RFS-2 implementation is significantly flawed and would do unnecessary harm to the competitive position of the U.S. soy biodiesel industry,” American Soybean Association President Johnny Dodson said in a press release issued by ASA.

For that reason, said Dodson, a soybean producer from Halls, Tenn., ASA is calling on all U.S. soybean producers and their family members to contact EPA and other government officials to voice concerns about the expanded RFS-2 proposed rule.

“A loss of the domestic biodiesel market would significantly decrease prices paid to U.S. farmers for their soybeans,” said Dodson, referring to the higher soybean prices growers have been enjoying in recent months. (Chicago November futures closed at $9.96 a bushel on Aug. 26, down from last year’s highs but up $4 per bushel from three years ago.)

Dodson listed these concerns:

• Flawed and immature assumptions and methodology utilized to measure the indirect land use impacts of U.S. soy biodiesel production;

• Unnecessary and onerous feedstock certification requirements;

• A methodology that contains a major error pertaining to the direct emission calculations for nitrogen in soybean production;

• A lack of accounting for glycerine as a co-product;

• Inaccurate assessment of the energy balance of biodiesel;

• A proposed pathway of using a 52-48 feedstock ratio of biodiesel feedstocks that is not workable in practice;

• A lack of accounting for improved agriculture yields and efficiency;

• A baseline analysis that compares estimated, future direct and indirect GHG emissions for biodiesel to only direct emissions for petroleum.

“Soybean farmers have a great interest in the implementation of the RFS-2,” Dodson said. “Unless the flaws in EPA’s proposed rule are corrected, soy-based biodiesel effectively will be excluded from the meeting the renewable energy targets established under RFS-2.

“Soybean farmers would lose a source of demand for soybean oil, biodiesel manufacturers would be left without sufficient feedstock supply, jobs would be lost, and our nation would not decrease its dependence on imported oil. None of these outcomes are what Congress intended. That’s why ASA is providing detailed comments to the EPA, and why ASA is asking farmers and the agricultural community to contact EPA as well.”

ASA is providing an easy to use online form where people can read the letter, add personal contact information, and submit comments with the click of a button. Family members, friends and neighbors are also encouraged to use this form.

Dodson urged producers to click on RFS2 Policy to access the online form, which includes the letter and links to additional background information.

e-mail: flaws@farmpress.com