Both the Renewable Fuels Association (RFA) and Growth Energy submitted comments to the Environmental Protection Agency (EPA) this week on pathways forward for the Renewable Fuel Standard (RFS). The comments highlight the importance of next generation biofuels and how increased market access will play a critical role in the ultimate success of the RFS.

Both organizations voiced support for the addition of cellulosic fiber from the corn kernel to the list of qualifying feedstocks, and the agency’s simplified approach to RIN generation for renewable fuels derived from cellulosic biomass.

“We applaud EPA for confirming that corn kernel fiber is ‘crop residue,’ and believe the Agency has proposed a sensible and straightforward approach to RIN generation for renewable fuels derived from cellulosic biomass feedstocks,” wrote RFA President and CEO Bob Dinneen. “Several technologies to convert corn kernel fiber into cellulosic ethanol have been developed in recent years, and a number of existing ethanol plants have already adopted these technologies or are poised to integrate them in the near future. The volumes of cellulosic ethanol produced from corn kernel fiber can meaningfully contribute to RFS2 cellulosic biofuel requirements in the near term.” The comments also included a scientific analysis from a noted animal nutritionist examining the potential impacts of reduced fiber DDGS on livestock and poultry markets.

RFA’s comments expressed support for most of the RFS2 technical amendments and new pathways proposed by EPA. However, Dinneen noted, the conditions for applying the alternative RVP (Reid Vapor Pressure) approach should be limited to whether blending an approved gasoline additive with E10 results in no net increase in RVP.

“The RFS has been the country’s most successful energy policy over the last forty years. Since the inception of the RFS, Growth Energy’s members and the ethanol industry have produced significant volumes of renewable fuel that have displaced 10 percent of U.S. transportation fuel, which has substantially helped reduce our dangerous dependence on foreign oil, improve our air quality, create thousands of jobs and revitalize rural communities nationwide,” noted Tom Buis, Growth Energy CEO in his comments. “The industry has successfully built the foundation of the RFS with the first generation of grain-based ethanol production, and our members are poised to do the same in the next generation with advanced biofuels and cellulosic ethanol.”

Growth Energy also supports additional pathways to meet the goals of the RFS including the new pathway for cellulosic biofuel from corn kernel fiber, as well as additional crop residues. “We believe that any renewable biomass meeting the 60 percent greenhouse gas threshold should be able to generate cellulosic RINs.” Comments also addressed the issue of foreign ethanol producers, advocating that those who produce biofuels, generate RINs and importers of renewable fuel should be subject to U.S. jurisdiction to prevent fraud, and that E15 fuel should be treated the same as E10 fuel with regards to RVP.