EPA on Monday closed its public comment period on proposed Renewable Fuel Standard renewable volume obligations for 2014-2016.
EPA released the proposed volumes in May, covering 2014-2016. For 2014, EPA proposed levels that were actually produced and used as transportation and jet fuel or heating oil in the U.S.
For 2015, EPA is proposing 16.30 billion gallons of total renewable fuels; for 2016 that total moves up to 17.40 billion gallons. That's an increase from proposed 2014 levels that were released in November, 2013, which amounted to 15.21 billion gallons.
The proposed volumes were higher than expected, yet lower than the volumes originally set by Congress. At the time, EPA said this was due to "constraints in the fuel market to accommodate increasing volumes of ethanol, along with limits on the availability of non-ethanol renewable fuels."
EPA said though the volumes were lower than Congress asked for, they are "above historical levels and would ensure continued growth in advanced biofuels."
See the issues both sides discussed >>
Supporting/advancement groups discussed…
Production capacity and distribution infrastructure
"USEPA's delays in RFS implementation and willingness to cede to obligated parties' refusal to install distribution infrastructure has undercut the goals of the statute While the proposed RVOs are a step in the right direction for biomass based biodiesel and advanced biofuel, these RVOs can and should be increased to better reflect the growth capacity of the biofuel industry." - American Council on Renewable Energy
Economic growth and stability
"The RFS has spurred growth in agriculture, increased energy diversity and decreased GHG emissions from fossil fuels through the development of renewable energy resources. We urge the Agency to stay the course and support this important piece of transformational energy policy, and we request it reconsider its proposed reduction in the 2014, 2015 and 2016 renewable volume obligations.
"[We are asking the EPA to] provide regulatory certainty to the most successful renewable fuel program in place. The continued stability and health of the rural economy and the nation's environmental improvements hinge upon your decision." - National Corn Growers Association
"The growth and expansion of the U.S. biodiesel industry in recent years represents a tremendous success story under the RFS. Today, nearly 2 billion gallons of biodiesel and renewable diesel displace an equivalent amount of petroleum diesel. This has resulted in significant reductions in pollution and greenhouse gas emissions, while creating thousands of jobs and millions of dollars in economic impact across the nation.
"The biomass-based diesel program has exceeded expectations and is achieving the goals that Congress outlined in creating the RFS. As a result, it warrants additional volume growth to meet the objectives of Congress in expanding renewable fuel use in the diesel market and in promoting advanced biofuels under the program." – National Biodiesel Board
RIN prices and other impacts
"EPA's proposed standards are already a proven failure and have been demonstrated to be too weak. The market has responded to the proposal with crashing D6 RIN prices, undermining the very mechanism necessary to push for higher volumes of biofuels.
"POET – one of the world's largest investors in cellulosic biofuels – expects to stop all future U.S. cellulosic investments if EPA's proposed base renewable fuel requirements are not strengthened. The development of cellulosic and other advanced biofuels is inexorably entwined with continued regulatory predictability based on RFS targets. – POET
Opponents of the RFS discussed …
"The diversion of corn into ethanol production, when mandated by the RFS or influenced by the RFS regulatory process as it was in 2014 absent final regulations, has created an uneven playing field for chicken companies to compete for necessary feedstuffs. Corn is the primary feed ingredient for the poultry industry. Since the RFS was enacted, chicken companies have faced more than $50 billion in higher actual feed costs due to the RFS." – National Chicken Council
"AFPM supports EPA's decision to use its waiver authority to adjust the 2014 and 2015 volumes. However, we strongly disagree with the volumes set for 2016, which will break the 10% blend wall. EPA relies on overly ambitious estimates for how much ethanol consumers want in their gas tanks. Consumers do not want the federal government making decisions for them on the types of fuels they buy." - Brendan Williams, American Fuels and Petrochemical Manufacturers
"High ethanol blends – such as E15 and E85 – that EPA is pushing are not compatible with most cars on the road today, and they could potentially put American consumers and their vehicles at risk. Consumers have shown they have little to no interest in purchasing increasing amounts of high ethanol fuels. Consumers' interests should come ahead of ethanol interests." - Bob Greco, American Petroleum InstituteContinued reading: Purdue economist says EPA's RFS volumes are compromise