Four ethanol producers representing plants in four different states made “substantially similar” points at hearing Friday on proposed regulatory changes related to retail sales of 15% ethanol blended fuel (E15) and the renewable identification number (RIN) compliance system Renewable Fuel Standard (RFS) program.

Substantially similar, otherwise known as “sub-sim”, is a term used in the EPA proposal relating to the definition of E15 in relation to the Tier 3 certification fuel, which is E10. Ethanol producers support that definition but oppose EPA’s proposal to impose certain restrictions on the use of E15 under the “sub sim” approach. Producers also expressed concerns about the regulation of E15 made at blender pumps, which as proposed would not qualify for the 1-psi RVP waiver.

All four producers also urged EPA to separate the E15 and RIN reform provisions of the proposal and consider them individually. In addition, they stressed the damage caused by the granting of Small Refinery Exemptions (SRE) by EPA and urged the agency to reevaluate how those requests are being handled.

Listen to their comments below:

Ethanol producers –
EPA Michigan hearing - Randy Doyal, Al-Corn Clean Fuel, MN