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Comment Period Countdown: The Public’s Opportunity to Show Support for a Strong RFS

June 30, 2016


The Environmental Protection Agency says it is determined to get the Renewable Fuel Standard (RFS) back on track, but so far the agency has kept the programs wheels spinning. In May, EPA released its proposed rule for 2017 blending requirements under the RFS. The proposal calls for 14.8 billion gallons of conventional biofuel to be blended into the national gasoline supply. While the 2017 level marks an improvement over the rule for 2016, it still falls 200 million gallons short of the 15-billion-gallon target outlined in the RFS statute. EPA is accepting public comment on its proposal through July 11. While the RFA will formally submit comments in the next few weeks, heres a preview of our concerns: EPAs underwhelming proposal is disappointing because it is completely unnecessary. The agencys decision goes against all real-world market data, which shows that ethanol consumption continues to grow due to expanded availability of E15 and E85. Whats more, gasoline demand continues to rise; the more consumers hit the road, the more E10 is purchased at the pump. The Energy Information Agency predicts Americans will consume nearly 143 billion gallons next year. Add on the increasing popularity of higher ethanol blends and the volumes of other biofuels that qualify as a D6 RIN, and there is no issue in surpassing the 15 billion gallon 2017 statutory RFS level whatsoever. Luckily, the 2017 proposal was just that: a first draft pending finalization. EPA opened the issue to gain feedback from the public during a hearing on June 9 in Kansas City. The testimony received was overwhelmingly in support of the RFS and renewable fuels. The RFAs own Bob Dinneen was just one of the many biofuel advocates who came out to show their support. He argued that a lower renewable volume obligation for 2017 runs counter to the very purpose of the RFS. EPA justified the reduction by referencing the realities of the market, adopting the narrative of the oil industry regarding the so-called blendwall. But the program, he said, was designed to change the realities of the market. It was intended to change the way oil companies do business and spur investment in cleaner, low carbon, domestic fuels like ethanol and the infrastructure necessary to accommodate higher biofuel blends. Indeed, that was the intent of Congress when it created this program more than a decade ago. RFA has been a consistent advocate for maintaining the statutorily required blending levels, but we are by no means the industrys only supporter. In fact, a large majority of the 120 public officials and citizens who testified at the June 9 public hearing were overwhelmingly in support of the RFS and for increasing the targets to their statutory levels. The public comment period is set to close soon. Ethanol advocates should not pass up the opportunity to express their support for the RFS. If you favor increased energy security, reduced greenhouse gas emissions, economic revitalization of rural communities, and more consumer choice at the pump, make your voice heard. Leave your comments for EPA in support of the RFS here (search docket ID number EPA-HQ-OAR-2016-0004).