August 13, 2015
Air and Radiation Docket
Docket No. EPA-HQ-OAR-2015-0092
Environmental Protection Agency
Mail code: 28221T
1200 Pennsylvania Ave. NW
The National Cotton Council (NCC) is pleased to submit comments on Docket Number EPA-HQ-OAR-2015-0092, regarding the analysis of the greenhouse gas emissions attributable to production and transport of cotton (Gossypium spp.) seed oil for use in biofuel production.The NCC is supportive of this Notice and the Environmental Protection Agency's (EPA) determinations within.
The NCC is the central organization of the U.S. cotton industry representing growers, ginners, warehousemen, cottonseed merchandisers and processors, merchants, marketing cooperatives and textile manufacturers whose primary business operations are located in 17 cotton producing states stretching from Virginia to California. U.S. cotton growers produce a crop with an annual farm-gate value in excess of $5 billion.The industry and its suppliers, together with the cotton product/manufacturers, account for approximately 200,000 jobs and generate total annual economic activity in excess of $100 billion.
The NCC supports EPA's view that new agricultural sector modeling is not needed to evaluate the lifecycle greenhouse gas (GHG) impacts of using cottonseed oil as a biofuel feedstock. The methods of producing cottonseed oil are nearly identical to those of other vegetable seed oils. The seeds are crushed, oil and meal are separated, and the two products are sold separately into the vegetable oil and animal feed markets respectively. Cotton fiber production represents approximately 80-85 percent of the value of the average U.S. acre of cotton, while cottonseed and its products represent the remaining approximate value per acre of 15-20 percent.For soybeans and other major oilseeds, the seed itself comprises nearly 100 percent of the value per acre.
Cottonseed oil is the fourth most produced vegetable oil in the U.S., after soybean oil, corn oil, and canola oil respectively. It is the seventh most consumed vegetable oil in the U.S., behind soybean oil, canola oil, palm oil, corn oil, coconut oil, and olive oil respectively. It accounts for about 2.5-4 percent of U.S. vegetable oil production and about 1.5-2.5 percent of U.S. consumption of vegetable oil. Over the last decade, annual U.S. cottonseed oil production has averaged just under 800 million pounds. If this entire supply were used for biodiesel and/or renewable diesel production, it would generate approximately 100 million gallons of fuel. However, the actual potential is more likely in the range of 20 million gallons of biodiesel per year. Since U.S. biodiesel and renewable diesel production was approximately 1.5 billion gallons in 2014, the potential contribution of cottonseed oil is relatively small in comparison to the overall biodiesel and renewable diesel market. It is our expectation that during periods when cottonseed oil prices approach parity with soybean oil prices, biofuel producers might utilize cottonseed oil – especially if they are near cottonseed crushing locations and can reduce transportation costs. As a result, the approval of pathways for cottonseed oil-based fuels would not have a significant impact on U.S. biofuel or vegetable oil production.
The NCC supports the EPA's decision to accept and evaluate petitions from biofuel producers to use cottonseed oil as an approved feedstock and for it to be eligible for a renewable identification number on a case by case basis. While we support this as a step forward toward the use (though limited) of cottonseed oil in the biofuel market, we would be remiss if we did not express our belief that cottonseed oil should be eligible to all biofuel producers without the additional petition process. Further, the NCC encourages the EPA to expedite all petitions submitted from biofuel producers in order for cottonseed to be used as an approved feedstock as soon as possible.
Thank you for the consideration of our views.
Gary M. Adams
President and CEO