ACE comments on proposed 2018 RFS
Posted on 08/31/2017
Sioux Falls, SD (August 31, 2017) – The American Coalition for Ethanol (ACE) today submitted comments to the Environmental Protection Agency (EPA) on the proposed blending volumes for 2018 under the Renewable Fuel Standard (RFS).
The organization emphasized the economic benefits of the RFS and stated in its comments that “Congress directed EPA to take seriously the impact any reductions of RFS volumes would have on rural economies. When proposing RFS volumes, EPA, in consultation with the Secretary of Agriculture, must look at issues such as job creation, economic development, and commodity prices. EPA is bound by law to ensure it does no harm to commodity prices or the rural economy.”
ACE also offered comment on the conventional biofuel level, use of the general waiver authority — given the recent decision by the U.S. Court of Appeals for the D.C. Circuit in Americans for Clean Energy et al. v. EPA, the potential of a future “reset” of the RFS, and the advanced and cellulosic biofuel levels. Finally, ACE underscored the importance of clearing regulatory bottlenecks, the need to update lifecycle greenhouse gas modeling for corn ethanol, and why EPA should provide Reid vapor pressure (RVP) relief for E15 and higher blends.
Some of ACE’s comments to EPA on these matters are summarized below:
- A strong rural economy depends upon growing the use of renewable fuels. EPA needs to implement the RFS as enacted by Congress and take regulatory steps so E15 and higher blends have market access.
- Maintaining 15 billion gallons of conventional biofuel in 2018 is imperative to ensuring a properly functioning RFS and increasing demand for renewable fuels in 2018 and beyond.
- While the proposed rule does not rely on the general waiver authority related to “insufficient domestic supply,” which was impermissibly applied by EPA in previous rulemakings, the Agency’s discussion of assessing attainable volumes based on demand-side factors in the proposed rule is legally barred and should be struck from the final rule.
- ACE urges EPA to finalize at least 19.38 billion gallons of total renewable fuel for 2018 of which at least 380 million gallons would be cellulosic biofuel and 4.38 billion gallons would be advanced biofuel. This would avoid nearing the 20 percent threshold for the so-called “reset” waiver of the total volume.
ACE's full comments are available here.