Ethanol organizations submitted comments to the Environmental Protection Agency Friday on its Proposed Volume Standards for 2020, 2021, and 2022 under the Renewable Fuel Standard (RFS).

The Renewable Fuels Association expressed strong support for the agency’s proposed 2022 renewable volume obligations (RVO) while opposing the proposed retroactive reduction of the previously finalized 2020 RVO requirements.

RFA President and CEO Geoff Cooper wrote that the organization is “strongly supportive of the proposed volumes for 2022 for all categories of renewable fuel,” but noted that ethanol producers are “very troubled by EPA’s questionable proposed use of its ‘reset’ authority to reopen the 2020 RVO.” According to Cooper, retroactively revising the 2020 RVO “…would set a dangerous precedent and contradict the agency’s long-held position that it does not have the authority to retroactively adjust RFS standards once finalized.”

The American Coalition for Ethanol (ACE) submitted similar comments that also urge EPA to withdraw the proposed cut for 2020 and maintain volumes realized during that year, citing the unprecedented, unnecessary, and legally dubious nature of the proposal to retroactively reduce the volumes.

Both groups express support for EPA’s plan to restore the 500 million gallons unlawfully waived in 2016 by implementing a 250-million-gallon supplemental volume remedy for 2022 and 2023.