RFS Comments Piled High at EPA Doors

Joanna Schroeder

Boxes upon boxes of comments relating to the Renewable Fuel Standard were delivered to the Environmental Protection Agency’s (EPA) doors yesterday as the comment period ended for the final 2014/2015 rule. Despite clear legislation on the amount of renewable volumetric obligations (RVOs) for all facets of renewable fuels, the EPA lowered the amount of corn-ethanol required to be blended in America’s fuel supply. During the timeframe allocated for comments, the biofuels industry came together not only in support of the industry but to call on the EPA to “get back on track” and put the RVOs at minimum at the levels set by legislation.

Leaders from the National Farmers Union and I Am Biotech delivered more than 200,000 comments on behalf of Fuels America to the EPA.

Leaders from the National Farmers Union and I Am Biotech delivered more than 200,000 comments on behalf of Fuels America to the EPA.

Fuels America collected more than 200,000 written comments while VoteVets.org turned in nearly 47,000 petition signatures calling on the EPA to strengthen the RFS.

“It is absolutely crucial, for the wellbeing of our military, and our national security, that we lessen our dependence on oil,” said Jon Soltz, Iraq veteran and chairman of VoteVets.org.  “A strong RFS is a key part of that equation.  It is very simple – every drop of renewable fuel in our gasoline means one less drop of oil.  The EPA should listen to those who love and support our military, and care about our national security, and strengthen the RFS.”

Last week the National Corn Growers Association (NCGA) held an RFS rally where hundreds of corn growers from across the country called the EPA to task and told them to “stay the course”. A letter submitted by NCGA states, “The RFS has spurred growth in agriculture, increased energy diversity and decreased GHG emissions from fossil fuels through the development of renewable energy resources. We urge the Agency to stay the course and support this important piece of transformational energy policy, and we request it reconsider its proposed reduction in the 2014, 2015 and 2016 renewable volume obligations.”

Also submitting a letter along with comments was the Renewable Fuels Association (RFA). The letter, authored by President and CEO Bob Dinneen, called the proposal “surprising” and imprudent” and he charged the EPA with buying into the oil industry’s false narrative regarding the so-called blend wall. By doing so, he wrote, “EPA has unnecessarily and illegally curtailed the unprecedented evolution occurring in the transportation fuels market that was delivering technology innovation, carbon reduction, and consumer savings.”

The American Coalition for Ethanol (ACE0 also submitted comments that included E15 sales data demonstrating that consumers are choosing ethanol at the pump. Executive Vice President Brian Jennings wrote, “The RFS is intended to reduce the GHG emissions of motor fuel and provide consumer access to E15 and flex fuels which are less expensive and cleaner than gasoline. These sweeping goals will not be realized if EPA continues to ride the brakes on the RFS. Issuance of the final RFS in November has consequences beyond trying to get the program back on track.  The decision will come at the same time the President prepares to negotiate an international agreement to reduce GHG emissions in Paris.  What an embarrassment it will be if EPA betrays the Administration’s commitment to curb climate change by restricting the use of low carbon biofuels in the U.S.”

Tom Buis, CEO of Growth Energy noted in the comments to EPA’s RFS rules, “The RFS has been an overwhelming success. It has created American jobs, revitalized rural America, injected much-needed competition into a monopolized vehicle fuels market, lowered the price at the pump, improved the environment, and made our nation more energy independent and secure by reducing our dangerous dependence on foreign oil. It makes no sense that EPA would try and move this program backward.”

Other comment topics cited by the Iowa Renewable Fuels Association (IRFA) included: The Need for Strong Growth in Biodiesel; Iowa Retailers Prove There is No “Blend Wall”; Removing the E15 Vapor Pressure Barrier; and RINs Lower Gas Prices. The comments call for the “EPA [to] discard its convoluted misinterpretation of the “general” waiver authority and maintain the levels for undifferentiated renewable fuel at the levels prescribed by Congress.” In addition the comments state, “The bottom line remains clear: there is no legal, marketplace, or consumer rationale for reducing the conventional biofuels level below the RFS statutory requirements. The EPA must enforce the RFS as Congress wrote the law. Let the RIN marketplace do its job in lowering fuel prices and incenting additional renewable distribution capacity.”

The EPA will now set about reading all of the comments before issuing its final ruling in November.

ACE, advance biofuels, Biodiesel, EPA, Ethanol, Growth Energy, Iowa RFA, NCGA, RFA, RFS