The new renewable fuels standard (RFS 2) aims to distinguish corn-ethanol that achieves a 20% reduction in greenhouse gas (GHG) emissions compared with gasoline. Field data from Kim et al. (2009) and from our own study suggest that geographic variability in the GHG emissions arising from corn production casts considerable doubt on the approach used in the RFS 2 to measure compliance with the 20% target. If regulators wish to require compliance of fuels with specific GHG emission reduction thresholds, then data from growing biomass should be disaggregated to a level that captures the level of variability in grain corn production and the application of life cycle assessment to biofuels should be modified to capture this variability.