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RFA Offers Recommendations for EFF Provisions at REGS Rule Hearing

December 6, 2016


WASHINGTON At a public hearing today in Chicago, Geoff Cooper, senior vice president at the Renewable Fuels Association, testified before the Environmental Protection Agency to provide recommendations for the agencys proposed Renewables Enhancement and Growth Support (REGS) rule. Coopers testimony focused primarily on strengthening ethanol flex-fuel (EFF) provisions, telling EPA officials that the recommendations are intended to boost flexibility and allow EFF producers, distributors, and consumers to capitalize on economic efficiencies in the marketplace. Cooper noted that the RFA supports increasing the sulfur limit for certified natural gasoline to 30 ppm. Along with EPAs proposal to limit natural gasoline content to 32% of the finished EFF blend, this would ensure the finished fuel does not exceed 10 ppm sulfur, he stated. Cooper also stressed the RFAs opposition to EPAs plan to establish a quality survey program (stemming from the industrys negative experience with the E15 fuel survey) that would collect and analyze EFF samples as the costs for implementing such a program would outbalance the benefits. As the E15 survey has demonstrated, the costs of such programs often outweigh the benefits and the program scope can quickly expand beyond its intended purpose, he said. As an alternative to physical sampling, EPAs proposal discusses a survey arrangement in which the independent surveyor reviews PTDs to ensure that EFF bulk blender-refiners and blender pump-refiners used appropriate parent blendstocks to make EFF. This alternative is certainly preferable to physical sampling, and we agree with EPA that it would greatly reduce the cost of compliance assurance. The Renewable Fuels Association agrees with EPA that it is unreasonable to subject E15 retailers to the registration, reporting and batch testing requirements that apply to gasoline producers, Cooper testified. He noted the importance of the proposal in highlighting the different volatility treatment between E10 and E15, and pushed the EPA to take action to resolve the issue. RFA first encouraged EPA to level the playing field for the RVP of E10 and E15 in 2010, when we formally requested that EPA use its administrative authority to simply apply the 1.0 psi RVP waiver for E10 to E15 as well We understand the REGS rulemaking process is not intended to address RVP standards for E15, but it does accentuate the importance of resolving this barrier. We again strongly encourage EPA to take immediate action separately to either limit the RVP of conventional gasoline to 8.0 psi in the summertime, or extend the 1.0 psi waiver to E15. View Coopers testimony as prepared for delivery here.