December 14, 2011

MEMORANDUM

TO: 			Air Docket EPA-HQ-OAR-2011-0542

SUBJECT:	Supporting Documentation for Analysis of Lifecycle Greenhouse
Gas (GHG) Emissions from Palm Oil-Based Biodiesel and Renewable Diesel 

This memorandum accompanies information related to EPA’s analysis of
lifecycle greenhouse gas (GHG) emissions from palm oil-based biodiesel
and renewable diesel.  As explained in the preamble to the Notice of
Data Availability (NODA), our analysis utilizes several data sources and
models.  To facilitate public review, below is a brief description of
the informational materials which accompany this memorandum.

1.  Summary of Modeling Inputs and Assumptions

This memorandum provides information on the key inputs and assumptions
used in EPA’s lifecycle analysis of palm oil used as a feedstock to
produce biodiesel and renewable diesel.  Assumptions include crop
yields, energy use, energy sources, fertilizer use, co-products, and
other important factors in our lifecycle analysis.

2. Consideration of Uncertainty

This memorandum provides additional information regarding consideration
of uncertainty in our modeling of the lifecycle GHG emissions associated
with the palm oil-based biodiesel and renewable diesel fuel production
pathways analyzed in the Notice of Data Availability (NODA).

3.  Lifecycle GHG Emissions Results

A spreadsheet that integrates results from all stages of the fuel
lifecycle to calculate lifecycle GHG emissions from the production and
use of the palm oil-based biodiesel and renewable diesel pathways
analyzed.  The lifecycle GHG reductions are calculated as percent
emissions reductions compared to the statutory 2005 petroleum baseline.

4.  Calculation of International Agricultural Impacts from the
FAPRI-CARD Model

This spreadsheet includes calculations that convert the raw FAPRI-CARD
model results into differences between scenarios to determine
biofuel-induced GHG emissions impacts associated with the palm oil-based
biofuel pathways analyzed.

5.  Spatial Modeling of Future Oil Palm Expansion in Indonesia

This report explains the models, data and assumptions used to project
the future locations of palm oil expansion in Indonesia for the
scenarios modeled.  The results include the area of palm oil expansion
by administrative unit, land cover type converted and soil type
converted.  The results are used to calculate land use change GHG
emissions in Indonesia for the scenarios modeled.

6.  Spatial Modeling of Future Oil Palm Expansion in Malaysia

This report explains the models, data and assumptions used to project
the future locations of palm oil expansion in Malaysia for the scenarios
modeled.  The results include the area of palm oil expansion by
administrative unit, land cover type converted and soil type converted. 
The results are used to calculate land use change GHG emissions in
Malaysia for the scenarios modeled.

7.  High Resolution Land Use Change Analysis of Oil Palm Plantations in
Sumatra and Kalimantan Circa 2000

This report documents our analysis of remote sensing data to map areas
of oil palm cultivation in Indonesia in the 2000 time period.  The
resulting spatial map was used as a data input to the spatial modeling
of future oil palm expansion in Indonesia.

8.   High Resolution Land Use Change Analysis of Oil Palm Plantations in
Sumatra and Kalimantan Circa 2010

This report documents our analysis of remote sensing data to map areas
of oil palm cultivation in Indonesia in the 2010 time period.  The
resulting spatial map was used as a data input to the spatial modeling
of future oil palm expansion in Indonesia.

9. Revisions to Land Conversion Emission Factor’s since the RFS2 Final
Rule

This report explains the revisions made, based on new data, since the
RFS2 final rule to the land conversion emissions factors used in our
analysis of land use change GHG emissions.  Such revisions include
updates to our treatment of harvested wood products, oil palm carbon
stocks, peat soil assumptions and forest carbon stocks.

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