In testimony delivered at a public hearing today in Ypsilanti, Mich., RFA President and CEO Geoff Cooper urged the agency to finalize the Modifications to Fuel Regulations to Provide Flexibility for E15proposal ahead of the summer driving season. In remarks to EPA officials, Cooper said, We strongly support EPAs proposal allowing E15 to take advantage of the 1-psi Reid Vapor Pressure (RVP) waiver that currently applies to E10 during the summer months.Extending the 1-psi RVP waiver to E15 during the summer volatility control season will open the marketplace to a fuel that provides consumers higher octane, lower cost, and reduced tailpipe emissions. We firmly endorse EPAs proposal to interpret section 211(h)(4) of the Clean Air Act as being applicable to ethanol blends containing at least 10 percent ethanol, including E15, and we believe EPAs justification for this interpretation is well supported by the statutory text and Congressional intent. Cooper further commented on E15 made at blender pumps, stating, RFA encourages EPA to consider a more flexible approach to regulation of E15 made at blender pumps. A majority of the retail dispensers selling E15 today are, in fact, blender pumps that mix E85 and E10 together to make the finished fuel. Under your proposal, E15 made in this manner would not qualify for the 1-psi RVP waiver, even if the finished fuel met applicable sulfur and benzene standards and had volatility of 10.0 psi or less. This seems unreasonable, especially because E15 made from E85 and E10 via a blender pump typically contains just 1 percent natural gasoline. In addition, Cooper testified to the RIN Reform portion of the proposal, saying RFA generally opposes any changes that would reduce RFS compliance flexibility, diminish liquidity in the RIN market, give certain parties in the marketplace unfairly advantaged positions, add unnecessary complexity, increase administrative burdens, or impugn the RIN markets ability to incentivize expansion of renewable fuel consumption. RFA does not believe any of the four main options proposed represent an improvement or enhancement of the current RIN program. Cooper further discussed the issue of Small Refinery Exemptions (SREs), noting while RFS small refinery exemptions are not the explicit subject of this rulemaking or todays hearing, we feel compelled to remind EPA that continued abuse of the SRE program would significantly undermine the ethanol market expansion intended to result from finally allowing year-round sales of E15. In closing, he stated, We continue to believe it is very important that the Agency sever the RVP and RIN reform provisions into two rulemaking efforts in the event it appears from the comments submitted that the RIN reform provisions might jeopardize or complicate promulgation of the RVP measures before May 31. Coopers testimony, as prepared for delivery, is here.