EPA opens comment period on cottonseed oil analysis

By Erin Voegele | July 17, 2015

The U.S. EPA has published a notice inviting public comment on its preliminary analysis of the lifecycle greenhouse gas (GHG) emissions attributable to the production and transport of Gossypium spp. seed oil (cottonseed oil) feedstock for use a biofuel feedstock.

According to the notice, the cottonseed oil analysis was completed in response to a petition from the National Cottonseed Products Association requesting EPA evaluate the lifecycle GHG emissions for biofuels produced using cottonseed oil. The petition also requests the EPA provide a determination of the renewable fuel categories under the renewable fuel standard (RFS) such biofuels may be eligible.

Cottonseed oil is the fourth most produced vegetable oil in the U.S, after soybean oil, corn oil and canola oil, and ranks seventh in consumption. It accounts for approximately 2.5-4 percent of U.S. production and 1.5-2.5 percent of consumption. Internationally, cottonseed oil is the sixth most produced and consumed vegetable oil, representing 3-3.5 percent of global production and consumption. The EPA indicated that U.S. cottonseed oil production has averaged just under 800 million pounds per year over the past decade. In the unlikely event that that entire volume were used for biofuel production, it would equate to approximately 100 million gallons of fuel.

Within its analysis, the EPA explains the agency believes it is reasonable to apply the GHG emissions estimates it established in 2010 for the production and transport of soybean oil to cottonseed oil. “We believe this approach will provide a conservative estimate of potential emissions associated with the production and transport of cottonseed oil. EPA solicits comment on this proposed approach,” said the EPA in its notice.

According to the EPA, it will review comments received in response to its notice, and combine its evaluation of agricultural sector GHG emissions associated with the use of cottonseed oil as feedstock with its evaluation of GHG emissions associated with individual producers’ production processes and finished fuels to determine whether any proposed pathway satisfies the emissions reduction requirements for RFS-qualifying renewable fuels. The EPA also noted that each individual biofuel producer seeking to generate RINs for non-grandfathered volumes of biofuels produced from cottonseed oil will need to submit a petition requesting EPA evaluation of their renewable fuel pathway.

A 30-day public comment period is now open. Comments are due Aug. 13. Additional information, including directions on how to submit comments, is available on the Federal Register website.