WASHINGTON — Brazil's RenovaBio program establishes national annual emissions reduction targets for transportation fuels that will likely require a significant increase in biofuels consumption. Therefore, the program must accurately reflect the carbon intensity for all ethanol pathways, including imports, the Renewable Fuels Association (RFA) wrote in comments to Brazil's Ministry of Mines and Energy submitted Sunday. Under RenovaBio, which was approved in late December 2017, the average carbon intensity (CI) of gasoline must be reduced by 10.1% by 2028. Brazilian officials recently sought comment from the public on the proposed annual CI emissions reduction targets. "Given that many of our member companies produce ethanol that is exported to Brazil, the pathway for imported corn ethanol is of particular interest to RFA....[I]t is imperative that the CI scoring of biofuel pathways under RenovaBio is conducted in an accurate, transparent, and science-based manner," RFA explained in its comments. RFA's comments primarily focused on the draft CI calculation tool (known as "RenovaCalc") that MME will use to determine CI values for various biofuel pathways. Overall, RFA applauded the efforts of MME and others to develop and refine the RenovaCalc tool, but sought clarity on the wide discrepancy between CI scores for imported corn ethanol and Brazil-produced corn ethanol. Under preliminary RenovaCalc estimates, imported corn ethanol is found to reduce GHG emissions by more than 50% compared to Brazilian gasoline. Meanwhile, Brazil-produced corn ethanol is found to reduce GHG emissions by 70%. With certain further refinements, RFA said it believes the calculator can provide both regulators and regulated entities with reliable estimates of the CI associated with various fuel pathways. "RenovaBio's program will likely encourage significant growth in biofuels consumption in Brazil; thus, we believe the program's methodology for estimating carbon intensity must correctly reflect the emissions impacts of U.S.-produced corn ethanol, the lowest cost, lowest carbon fuel on the global market," said RFA President and CEO Bob Dinneen. "Last year, Brazil was the top U.S. ethanol export market. If current trade barriers are resolved, we expect that implementation of RenovaBio could provide additional opportunities for biofuel trade with Brazil. If done incorrectly, however, it could also result in another non-tariff barrier to U.S. ethanol. We look forward to working with the Brazilian government and industry to ensure the benefits of all biofuels are properly recognized both in RenovaBio and in transportation-climate policies worldwide." To view a full copy of RFA's RenovaBio comments, click here.