On Jan. 17, Clean Fuels Alliance America filed written comments on the U.S. EPA’s proposed Partial Waiver of 2024 Cellulosic Biofuel Volumes. Clean Fuels asks EPA to pause the rulemaking process until the agency can provide a full accounting of available cellulosic RINs for 2024 and consider whether pending small refinery exemptions or other mechanisms provide relief to refiners. Additionally, Clean Fuels encourages EPA to address the significant underestimation of biomass-based diesel and advanced biofuel volumes for 2024 and 2025.

“We cannot accurately evaluate EPA’s calculation of an inadequate supply of cellulosic RINs for 2024 without first knowing the number of RINs that might be returned to the market through small refinery exemptions,” Clean Fuels writes.

“We ask that EPA finalize a step-change in 2024 advanced RVOs to EPA’s own projected advanced RIN generation, which is currently expected to exceed the required volumes by at least 2.6 billion RINs,” the comments continue. “Clean Fuels appreciates EPA’s acknowledging a more-than-adequate supply of advanced and renewable RINs, but this alone is not enough. EPA should take this opportunity instead to address Clean Fuels’ petition and reconsider the 2024 and 2025 BBD and Advanced Biofuel RVOs.”

The comments are available on cleanfuels.org.

Kurt Kovarik, Clean Fuels vice president of federal affairs, added, “Last June, Clean Fuels petitioned EPA to increase the 2024 and 2025 Biomass-based Diesel and Overall Advanced volumes for 2024 and 2025, because the agency set these volumes significantly below our industry’s demonstrated production. EPA’s low volumes are holding back the potential of the clean fuels industry to meet the energy security, environmental, and economic goals of the RFS. EPA should take this opportunity to address our petition by proposing and finalizing an appropriate step up in the volumes for 2024 and 2025.”