What frustrates me most about the EPA&rsquo;s proposed 2014 RVO volumes is that the spirit and intention of the federal renewable fuels standard (RFS) was never to create a national biofuels program that would be unable to grow during periods when gasoline consumption declined. In 2007 when the current renewable fuels standard became law, policy makers and industry stakeholders knew&mdash;as they know now&mdash;that our nation&rsquo;s vision for biofuels wouldn&rsquo;t happen without a stepwise introduction of higher-level blends of biofuels into the nation&rsquo;s transportation fuel supply.
Not at any time did policymakers or representatives of any industry believe that 36 billion gallons of biofuels would, by 2022, make up just 10% of our nation&rsquo;s total transportation fuel stream. Everyone knew that E10 wouldn&rsquo;t get us home.
In 2007, U.S. drivers were using about 145 billion gallons of gasoline (including ethanol blends) per year. And, yes, it was presumed that gas consumption would grow to 176 billion gallons by 2022. But keep in mind that 36 billion gallons is not 10 percent of 176 billion gallons. It&rsquo;s closer to 20 percent. Hence, everyone knew that the biofuels industry and oil industry would have to work together to encourage America&rsquo;s gasoline retailers to make a transition to E15 (or higher)&mdash;which would have had the circular effect encouraging investment in cellulosic and advanced ethanol. &nbsp;
From an environmental viewpoint, isn&rsquo;t it good that gasoline consumption is down slightly? Americans should be celebrating the fact that America is successfully increasing more biofuels into the marketplace while simultaneously increasing the fuel economy of new cars and trucks. There was a time when opponents of ethanol said biofuels could never make a big enough difference in the marketplace to be meaningful. Now they say biofuels will make too big a difference because the pool is smaller. So which is it? Does ethanol make too little of a difference or too much of a difference?&nbsp;&nbsp;&nbsp;
The ethanol industry did its part, and continues to do its part, to grow the E15 market, tear down barriers to implementation and help the nation achieve what federal law dictates with the RFS. At the same time, America&rsquo;s first wave of next-generation biofuels plants are just now starting to come on line.&nbsp; The oil industry, on the other hand, has done nothing to accommodate the RFS. Correction: The oil industry has done everything within its power to prevent E15 implementation. And there&rsquo;s no wondering why. If it&rsquo;s successful in its attempt to impede the RFS, the oil industry will retain billions in extra profits at the expense of American farmers and everyday Americans.
Believe me, I am not against oil or gas. Not at all. But there&rsquo;s no disputing that ethanol has been lowering the price of gas lately. And I truly believe that less ethanol in America&rsquo;s fuel supply will equate to higher prices at the pump. Plus, if this proposal goes through, American jobs are at risk, and we will lose the chance to attract new companies and investments to the U.S.&nbsp;
The advanced biofuels industry is arriving&mdash;right now. The only question is: Will it continue to arrive here in the United States, as intended by the RFS, or will it move off shore to other countries that are less sympathetic to industries that don&rsquo;t stand to gain from change.&nbsp;
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The spirit and intention of the renewable fuels standard was never to create a national biofuels program that would be unable to grow during periods when gasoline consumption declined. 

RFS intended for higher biofuels blends

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