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RFA to EPA: Maintain 15 BG Conventional Renewable Fuel RVO, Increase Cellulosic Requirements

August 31, 2017


WASHINGTON - The Renewable Fuels Association (RFA) submitted commentstoday to EPA on its proposed 2018 Renewable Fuel Standard renewable volume obligations (RVOs), strongly supporting the 15 billion gallon (BG) requirement for conventional renewable fuels like corn ethanol, but urging the agency to finalize the RVOs that were included in EPAs first draft of the proposal that was submitted for interagency review in May. In July, EPA proposed a total renewable fuel volume of 19.24 BG, of which 4.24 BG is advanced biofuel, including 238 million gallons of cellulosic biofuel. That leaves a 15 BG requirement for conventional renewable fuels. RFA is pleased that the EPA maintained the statutory implied volume requirement of 15 billion gallons for conventional renewable fuels in 2018, wrote RFA President and CEO Bob Dinneen in comments to EPA Administrator Scott Pruitt. In doing so, the agency has sent a positive signal to the marketplace to continue the infrastructure investments necessary to grow the renewable fuel marketplace and expand the availability of gasoline blends containing more than 10 percent ethanol. However, RFA is concerned that EPAs assessment of reasonably attainable renewable fuel levels in 2018 continues to inappropriately rely on demand-side factors, which is clearly barred by the recent decision by the U.S. Court of Appeals for the District of Columbia. We encourage the agency to adopt the intended approach of simply evaluating the physical supply of renewable fuels (and RINs) available to obligated refiners, blenders and importers relative to the statutory volume requirements, Dinneen noted in comments. In EPAs initial May draft that it sent to the White House Office of Management and Budget, the proposed RVO requirements were 384 million gallons of cellulosic biofuel; 4.38 BG of advanced biofuel; and 19.38 BG of total renewable fuel, higher than what the agency ultimately proposed in July. In comments, RFA urged EPA to finalize the requirements that were initially proposed. On cellulosic biofuel, RFA urged the agency to use projections that reflect new and emerging technologies. EPAs proposed approach for assessing available cellulosic biofuel supplies pessimistically assumes new and emerging cellulosic biofuel facilities and technologiesincluding cellulosic ethanol from corn kernel fiberwill not produce any material volume in 2018, wrote Dinneen. This backward-looking methodology ignores marketplace realities and turns the market-driving purpose of the RFS on its head. EPA should abandon its proposed approach for projecting likely volumes of cellulosic biofuel and return to the methodology used for the 2016 and 2017 RVO rules (and early drafts of the 2018 RVO proposed rule). RFA strongly recommends that EPA finalize the RVO levels that were included in early drafts of the 2018 proposed rule submitted to the White House Office of Management and Budget.Restoring the 2018 RVOs to these levels would support Congressional intent by returning the RFS program to a growth trajectory and driving continued investment in the biofuel sector, Dinneen added in his comments. A full copy of RFAs comments is here:/upload/files/PDFs/2017/08/RFA-Comments_2018-RVO-Proposed-Rule_Final.pdf