Comment Log Display

I support your rules to require fuels to meet certain standards as
to their total, overall carbon impact.  Corn based ethanol is a
prefect example of an industry with an overall highly negative
carbon impact. 

I live in central South Dakota and spent over 20 years as the
state's cheif wildlife biologist.  I witnessed firsthand the impact
on the land that the corn ethanol boom created.  SD has a
cumulative 10 year loss of 1,000,000 acres of grass.  This loss is
directly tied to the development and growth of corn based ethanol
in SD.  The demand for corn to convert into ethanol created a corn
planting frenzy that is only be rivaled by the wheat boom of the
1970s and the homestead sod conversion that occurred in the late
1800s.  

To meet the demand for corn created by the ethanol refineries
farmers have converted native prairie to farm corn, removed land
that had been idled by conservation progrms and found loopholes in
existing swampbuster regulations to drain wetlands.  Annual losses
of native prairie have averaged about 300,000 acres per year - much
of loss occuring in the prairie pothole region of eastern SD which
provides nesting cover for numerous species of grassland dependant
migratory birds.  Although draining small isolated wetlands by
"whole field pattern tiling" may not directly increase significat
addtional corn acreage the practice is profitable and in high
demand because it allows farmers to move their corn planting
equipment faster and more efficiently thus providing additional
corn acres they can farm which means higher profits.  Finally, due
to the high prices and demand for corn, farmers are putting less
land into conservation practices and are letting enrollements in
programs such as CRP (Conservation Reserve Program) expire. 

The total cumulative impact that corn based ethanol is having on
the land is a significant reduction in acres of native prairie, a
loss of wetland acres (especially small isolated prairie pothole
wetlands) and a declining interest in conservation programs.  All
resulting in a significant loss of habitats that are critical to
hold and/or sequester carbon. 

Please also be aware that the cost of the above negative impacts
to the land (and to the carbon allowed to escape) is being paid for
by taxpayers.  Corn based ethanol is triple subsidized 1) the
farming of corn is highly subsidized by USDA 2) the ethanol
distileries are provided a per gallon Fed. govt. payment and
finally 3) ethanol at the pump is taxed at a lower rate than
regular, unleaded gasoline.  Despite these heavy taxpayer
subsidies, the corn based ethanol industry remains a "house of
cards" and is barely able to keep profitable.  Finally, ethanol
blends provide lower mileage than traditional non-leaded gasoline
and ethanol is priced competatively with gasoline only due to the
triple subsidies.  If the overall environmental cost of loss of
grassland and wetlands habiat and the overall reduction of habitats
available for countless migratory prairie nesting birds is combined
with the accelarated loss of carbon, corn based ethanol should be
seen as the scam on the public that it really is.

Please use sound science and not the corn based ethanol bs
rethoric to uncover the true facts about this industry and the
overall negative impact it is having on our environment.

Thank you.