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RFA to EPA: REGS Proposal Should Be Retooled to Truly Address Barriers Impeding Renewable Fuels Expansion

February 16, 2017


WASHINGTON The Environmental Protection Agency (EPA) suggests its recent Renewables Enhancement and Growth Support (REGS) proposed rule will promote renewable fuels and remove barriers to their production, distribution and consumption. However, the proposal does not adequately address key regulatory barriers that are constraining growth in ethanol production and use, according to comments filed today by the Renewable Fuels Association (RFA). In order to truly promote expansion in renewable fuels production and use, RFAs comments encourage EPA to take immediate action to eliminate a number of significant regulatory impediments. While well-intentioned, the REGS rule does not adequately address the key regulatory barriers that are significantly limiting growth in renewable fuel production and use, said RFA President and CEO Bob Dinneen in the comments. In fact, we are concerned some elements of the REGS proposal may actually serve to add complexity and create new barriers to renewable fuel market expansion, an effect that would be the opposite of the rules stated purpose. While the proposal does resolve the ambiguity surrounding regulation of certain ethanol blends like E16-E50, it largely overlooks the actions required to truly support and promote an expanded role for renewable fuels in the marketplace. Rather than proceeding with the current rulemaking, EPA should initiate a far more comprehensive process to reform existing fuel regulations in a way that levels the playing field for renewable fuels and genuinely removes regulatory barriers to growth, Dinneen continued. Among actions EPA should take to reform existing fuel regulations, RFA recommends:

  • Establishing regulatory parity in the volatility limits for all fuel blends containing more than 9 percent ethanol by volume;
  • Streamlining and harmonizing survey programs intended to monitor and verify fuel quality and regulatory compliance;
  • Simplifying the petition process for new certification fuels and eliminating unreasonable criteria for approval;
  • Eliminating unnecessarily burdensome and costly requirements related to the fuel and fuel additive registration process;
  • Leveling the playing field for all alternative fuel vehicles, including flexible fuel vehicles (FFV), under the fuel economy and light-duty vehicle greenhouse gas program;
  • Rejecting the results of the a flawed fuel effects study and suspending further use or development of the MOVES2014 emissions model until a new emissions study based on appropriate test fuels is conducted; and
  • Updating the lifecycle greenhouse gas (GHG) analysis of corn ethanol conducted for RFS2.
Implementing these recommendations would go a long way toward truly enabling future growth of the renewable fuels industry, said Dinneen. We urge EPA to go back to the drawing board with this proposal and draft new amendments that genuinely stimulate renewable fuels growth, ensuring consumers have greater access to ethanol, the lowest-cost, cleanest-octane transportation fuel on the planet. In addition to these recommendations, the RFA comments offer detailed input on specific provisions of the REGS package, such as the proposals classifying E16-E83 as ethanol flex fuels and establishing provisions for biointermediates. A full copy of RFAs comments is here.