Today is the deadline for submission of comments to the U.S. Environmental Protection Agency (EPA) for the 2017-2018 proposed renewable volume obligations (RVO) under the Renewable Fuel Standard (RFS). The Renewable Fuels Association (RFA) urged the EPA to raise the requirement for conventional renewable fuel volumes to the statutory level of 15 billion gallons per year. Signed by RFA President and CEO Bob Dinneen, he writes in the comments, “There’s no justification for lowering the requirement, which would turn the RFS into a stagnant, backward-facing policy.”
RFA is calling for higher blend levels in part because the ethanol industry is already producing well above the 15 billion gallons per year. With record levels of E10 consumption, broader availability of E15 and E85, more than 2 billion surplus renewable identification numbers and other factors make the statutory requirement easily achievable in 2017, according to RFA.
“EPA seems to be burdened by a fundamental misunderstanding of the RFS,” Dinneen said in the comments. “By adopting the narrative of the oil industry with regard to how much ethanol can be blended into gasoline, EPA has incomprehensibly and illegally curtailed the continued evolution occurring in the transportation fuels market that is delivering technology innovation, carbon reduction and consumer savings.
“The agency continues to justify reducing required volumes of conventional renewable fuel by suggesting that certain ‘marketplace realities’ preclude refiners from meeting the higher statutory volumes,” Dinneen continued. “This narrative hinges upon a belief that refiners and gasoline marketers simply cannot supply higher volumes of ethanol to consumers because of a lack of infrastructure, consumer demand, or vehicles that could safely utilize fuels containing more than 10% ethanol.
Dinneen added, “This is a false premise, and turns the RFS from a technology- and market-driving program into a stagnant, backward-facing policy that sacrifices environmental and economic benefits by allowing the oil industry to determine how much biofuel it can use based upon their infrastructure and marketplace decisions. RFA is strongly opposed to the proposal to reduce the 2017 RVO for undifferentiated renewable fuel from the statutory levels specified by the statute. We encourage EPA to finalize a rule that demonstrates fidelity to the statute and truly reflects today’s marketplace realities: ethanol is providing the consumer savings, carbon reductions, and energy security benefits envisioned by Congress.”