In the 12 page RTFA response we

  • cautioned against a best use biomass hierarchy
  • pointed out the problems with the waste hierarchy
  • questioned the belief that advanced biofuels by definition always have superior GHG emissions characteristics, see RTFA GHG study Broadmanor Consulting first draft
  • showed how the sustainability standards applied for biofuels have percolated into agriculture generally
  • pointed out why biofuels should not be overlooked on the basis that they will eventually be replaced by electrification… and more.

Read it here.