IRFA to EPA: Follow the law to improve final RFS rule

By The Iowa Renewable Fuels Association | August 31, 2017

The Iowa Renewable Fuels Association submitted comments Aug. 31 on the proposed Renewable Fuel Standard volumes for 2018 and 2019, arguing the proposed rule falls short of Congressional intent to provide market access for renewable fuels.

EPA’s proposed rule maintains the 15 billion-gallon RFS level for corn-based ethanol as required by Congress. However, citing alleged concerns over consumer demand, EPA proposed lowering advanced biofuel RFS levels. In public comments, IRFA urged EPA to increase the advanced biofuel levels in the final rule, noting that there is ample domestic supply and that proposed reductions fall short of the letter and intent of the RFS as passed by Congress.

“The EPA deserves credit for proposing 15 billion gallons for corn ethanol, the first time that level has been in a proposed rule,” said IRFA Executive Director Monte Shaw. “IRFA certainly urges EPA to maintain that level in the final rule. On the advanced biofuel side, the proposal was not as good. It uses methodologies that are sometimes questionable, if not illegal, to justify lowering biodiesel and cellulosic RFS levels. Following Congressional intent, EPA should set a 2.75 billion gallon biodiesel level and a 384 million gallon cellulosic level in the final rule.”

Noting that the real challenge to renewable fuel growth isn’t supply or consumer demand, but a lack of compliance with the letter of the law, Shaw added, “We are calling on EPA to reembrace the fundamental purpose of the RFS—to crack open the petroleum monopoly so that renewable fuels can have access to consumers.”

In extensive comments submitted to EPA, IRFA also highlighted that:

-The current proposal fails to execute the fundamental objective of the RFS, to increase the amount of renewable fuels used in the U.S.

-The so-called reset function built into the RFS should not be used to lower conventional biofuels levels.

-The proposed rule contains an inherent bias by asking 12 times for comments on additional cuts, but never once asks for comments on the possibility of increasing proposed volumes.

-Given that the U.S. consumed 2.9 billion gallons of biodiesel in 2016, proposing to flatline the biodiesel level at 2.1 billion gallons for 2019 ignores Congressional intent for biodiesel growth.

-Limiting biodiesel volumes won’t stop imports, it will only decrease the amount of domestic supply used in the market place.

-Use and availability of E15 is growing but continues to be stifled by unfair RVP regulations. EPA has the authority and duty to give E15 the same RVP treatment as all other ethanol blends, the fastest way to reduce RIN prices.

-Excessively reducing the cellulosic ethanol blend level based on past production trends without considering expected new production is illegal.

-EPA should not undermine cellulosic ethanol production by prolonging approval of new pathways for production.

“We fully respect that the document we reviewed is only a proposal,” Shaw said. “I’m confident that the final rule will live up to Administrator Pruitt’s commitment to honor the letter and spirit of the law according to the intent of Congress.”

To read IRFA’s full comments, please click here.

 

 
 
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