WASHINGTON — The Renewable Fuels Association (RFA) submitted comments today to EPA on its proposed 2017 Renewable Fuel Standard renewable volume obligations (RVO), urging the agency to raise the requirement for conventional renewable fuel volumes to the statutory level of 15 billion gallons. There’s no justification for lowering the requirement, which would turn the RFS “into a stagnant, backward-facing policy.”
EPA’s recent proposal calls on refiners to blend 14.8 billion gallons of conventional biofuels in 2017, slightly below the 15-billion-gallon level envisioned by Congress when it expanded the RFS in 2007. 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 readily achievable in 2017.
“EPA seems to be burdened by a fundamental misunderstanding of the RFS,” said RFA President and CEO Bob Dinneen in comments to EPA. “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.
“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,” Dinneen wrote. “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,” Dinneen added.
A full copy of RFA’s comments is here.