Growth Energy has submitted comments on a proposed rule from the U.S. EPA that would change how the agency conducts the benefit-cost analysis (BCA) of new rules under the Clean Air Act, including the Renewable Fuel Standard. In a letter to the EPA, Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley urged the agency to ensure agency calculations continue to recognize the full benefits of the RFS, including “reduced cost at the pump, reductions in greenhouse gas emissions, reductions in harmful air toxics like carbon monoxide, and significant value added to farmers and rural communities.”

“Following development of the RFS over the past 15 years, the industry has grown from 81 plants producing nearly 4 billion gallons of ethanol to 200 plants now producing roughly 16 billion gallons of ethanol annually,” wrote Bliley. “Today, this industry supports more than 350,000 jobs including thousands of farmers accounting for roughly 40 percent of the corn demand in the United States. The use of biofuels has also helped to reduce our dangerous dependence on foreign oil imports replacing 10 percent of our nation’s fuel and reduced consumer costs at the pump.”

Growth Energy also cautioned the agency against changes that could undercut the ability of regulators to consider the full benefits of the RFS, including those to the environment.

“Relatedly, we have seen numerous studies, including those done by Argonne National Laboratory and the U.S. Department of Agriculture, that confirm that ethanol significantly reduces greenhouse gas emissions compared to gasoline,” wrote Bliley. “However, under this proposal, limited results from a BCA could distort EPA’s examination of the social cost of carbon which could then, in turn, be used to unjustly distort the greenhouse gas reductions called for in the RFS and described in the original RFS regulatory impact analysis.”

In addition, Growth Energy expressed concerns about changes that could require the agency to annually recalculate previously established benefits of the RFS or be used to justify retroactive changes that could create needless volatility in the markets for biofuels and related farm crops.

“In short, we believe that the agency needs to better articulate how it intends to use these benefit-cost analyses,” concluded Bliley. “Specifically, the agency needs to assure biofuel producers, farmers, and the public that any adjustment in benefit-cost analysis will not undermine the policy goals of the Energy Policy Act, Energy Independence and Security Act, and the RFS. In addition, EPA should not reverse years of considerable investment and development in the renewable fuels industry by applying a narrow benefit-cost analysis that does not take into consideration the full range of benefits Congress intended to be served by the RFS.”