With the RFS waiver request comment period coming to a close yesterday, the ethanol industry sent another round of comments to the EPA saying a waiver was not needed. But the ethanol industry was not the only sector to respond, the National Corn Growers Association submitted a letter in support of the RFS as is, as did the Governors of Iowa, Illinois, Minnesota, South Dakota and Oregon. In addition, a group of 22 CEOs, presidents and other executives from bioenergy and agricultural sectors submitted a letter.

Tom Buis CEO of Growth Energy noted that several governors and big food companies who have been pushing for the waiver have failed to show severe economic harm directly attributable to the RFS.

He noted in the comments submitted by his organization, “A decision to grant the waiver requests would come at a great cost to the United States, both economically and through the sacrifice of larger policy goals. A full waiver of the national Renewable Fuel Standard could lead to closed or idled biorefineries throughout the nation, resulting in as many as 3,000 to 8,300 job losses in ethanol producing areas and $2.9 to $7.8 billion in lost revenues.”

“Consumers would then suffer much higher prices at the gas station, costing U.S. drivers more than $7.5 billion a year or $62.70 per household – far more than any potential impact on food prices,” the comments continued, ” The waiver could also mean losses of between $5.8 and $27.75 billion for U.S. corn farmers, exacerbating what is already a time of economic hardship in rural America.”

Comments submitted by the Renewable Fuels Association added that those requesting were unable to show that waiving the RFS would cure the claimed harm; failed to recognize the impact of RFS compliance flexibilities; and failed to consider the economic benefits of the RFS.

After taking all these failures into account coupled with the fact the RFS has shown to work as intended, RFA CEO and President Bob Dinneen said, “EPA has no option but to deny the waiver requests because they are procedurally incomplete, legally insufficient, and factually flawed.  Perhaps most outrageous is the fact the petitioners make no mention of the RFS program’s inherent flexibilities, and they blatantly ignore the fact that the ethanol industry is responding rationally to current grain market conditions by significantly reducing production.

“Supporters of a waiver overlook the impact of RIN credit banking, borrowing, and trading provisions. The very provision that allows obligated parties to meet up to 20 percent of their current year RFS obligation with RINs generated in the previous compliance year was designed specifically to mitigate the impacts of a drought on agricultural markets. The RFS is unquestionably working as intended. It is a proven success, and it absolutely should not be waived,” concluded Dinneen.