NWF Comments:
Dear Christopher-
 
Thank you for the opportunity to provide input into EPA's literature review on jatropha. While I do not have any comments related specifically to lifecycle GHG emissions of jatropha, I do have two comments on behalf of the National Wildlife Federation:
 
   1.       NWF is very concerned about the potential for jatropha (and other feedstocks) to become invasive and cause economic and ecological damage While jatropha is not necessarily invasive, and certainly not necessarily invasive everywhere  -  we believe that there is enough in the literature on the potential for jatropha to become invasive to warrant further investigation, including through a literature review and a weed risk assessment. We urge EPA to include this vital assessment as part of the RFS pathway approval process. Under Executive Order 13112, (issued Feb 3, 1999), a federal agency cannot take action that causes or promotes the spread of invasive species unless the agency has publicly determined that the benefits of such actions clearly outweigh the potential harm. Therefore, we believe that EPA must evaluate the invasive potential of jatropha. To that end, I've included a list of publications that would be useful in evaluating the invasive potential of jatropha. Additionally, I am attaching a letter signed by over 200 scientists from 41 states calling on federal agencies to comply with the E.O. 13112 and do an assessment of the invasion risk of bioenergy feedstocks before they are eligible for federal incentives that pave the way for their cultivation.
 
   2.       The use of the term "jatropha" as a common name is vague and therefore problematic. Jatropha refers to a genus, not a species. There are around 170 species included in the genus jatropha, each with different characteristics- and likely a different GHG profile. NWF strongly believes that full scientific taxonomy  -  including genus and species, as well as subspecies, cultivar, hybrid, or variety when applicable -- should be used in RFS feedstock pathway rulemaking in order to be as specific as possible and prevent problems down the line.
 
Thank you for your consideration. I'd be happy to answer any questions or to come in and discuss these issues with you further.
 
Regards,
 
Aviva Glaser
 
 
Suggested literature on jatropha invasive potential
Chimera, C, CE Buddenhagen, and PM Clifford. 2010. Biofuels: the risks and dangers of introducing invasive species. Biofuels 1(5): 785-796.
Csurhes, SM. 1999. Bellyache bush (Jatropha gossypiifolia) in Queensland. Pest Status Review Series. Queensland, Australia.
Gordon, DR, KJ Tancig, DA Onderdonk, and CA Gantz. 2011. Assessing the invasive potential of biofuel species proposed for Florida and the United States using the Australian Weed Risk Assessment. Biomass and Bioenergy 35(1): 74-79.
Heard, TA, RR Chan, and R Segura. 2002. Prospects for the biological control of bellyache bush, Jatropha gossypiifolia. Thirteenth Australian Weeds Conference. http://www.caws.org.au/awc/2002/awc200213661.pdf.
Henderson, L. 20007. Invasive, naturalized, and casual alien plants in southern Africa: a summary based on the Southern African Plant Invaders Atlas (SAPIA). Bothalia 27(2): 215-248.
Low, T and C Booth. 2007. The Weedy Truth about biofuels. Published by the Invasive Species Council. http://www.lifeofthelandhawaii.org/Bio_Documents/2007.0346/LOL_EXH_7_Weedy_Truth.pdf
Prentis, PJ, DP Sigg, S Raghu, K Dhileepan, A Pavasovic, and AJ Lowe. 2009. Understanding invasion history: genetic structure and diversity of two globally invasive plants and implications for their management. Diversity and Distributions 15(5): 822-830.
Sahoo, NK, A Kumar, S Sharma, and SN Naik. 2009. Interaction of Jatropha Plantation with Ecosystem.  Proceedings of International Conference on Energy and Environment ISSN: 2070-3740.
 
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Aviva Glaser
Legislative Representative, Agriculture Policy
National Wildlife Federation
901 E St. NW, Suite 400
Washington, DC 20004
202-797-6616
GlaserA@nwf.org

