WASHINGTON Testifying at a public hearing on the Renewable Fuel Standard (RFS) being held today in Kansas City, Kansas, by the Environmental Protection Agency (EPA), the Renewable Fuels Associations senior vice president, Geoff Cooper, and its board chairman, Randy Doyal, urged the agency to implement the statute as Congress intended and abandon its blend wall methodology in setting the 20142016 renewable volume obligations. We continue to believe EPA is overstepping the bounds of its legal authority by proposing to partially waive the RFS based on perceived distribution capacity constraints, Cooper said in his prepared remarks. Nothing in the statute allows EPA to set the renewable volume obligations (RVOs) based on the so-called blend wall or alleged infrastructure limitations. Congress considered measures that would have allowed waivers based on distribution infrastructure. But they rejected those concepts because they knew allowing such off-ramps would allow oil companies to hold the RFS program hostage. In his prepared testimony, Doyal said that even though gasoline consumption might be slightly lower today than Congress anticipated when it adopted the RFS, it was always the intent of the program to push beyond the blend wall and increase the share of renewable fuels in our nations fuel supply. the Clean Air Act statute does not permit EPA to take into account factors that affect consumption, such as purported infrastructure constraints or the so-called blend wall, in determining whether to grant a general waiver of the RFS, Doyal noted. By embracing the blend wall concept, the EPA proposal not only violates the law, but also undermines the incentive to expand biofuel production and distribution capacity, and allows oil companies to only blend as much renewable fuel as they are comfortable using. Geoff Coopers full testimony is available here. Randy Doyals full testimony is available here.