On January 18, 2017, Christopher Grundler, the Director of the Office of Transportation and Air Quality for the U.S. Environmental Protection Agency (EPA), signed a notice inviting comment on its analysis of the upstream greenhouse gas (GHG) emissions from the production of sugar beets for use as biofuel feedstock. The notice describes the analysis performed, which considers the extraction of non-cellulosic beet sugar for conversion to biofuel and the use of the remaining beet pulp...