The EPA has proposed 2018 volume requirements of 238 million gallons for cellulosic biofuels; 2.1 billion gallons of biomass-based diesel; 4.24 billion gallons of advanced biofuels; and 19.24 billion gallons of renewable fuel. For standard ethanol, the EPA proposed an implied volume of 15 billion gallons.
The National Corn Growers Association (NCGA) said it would like the EPA to maintain the proposed amount of conventional ethanol and to raise the amount of cellulosic, advanced, and total biofuels.
In a letter to Scott Pruitt, administrator at the EPA, Wesley Spurlock, president of the NCGA, wrote, “In the 10 years since Congress expanded the RFS in 2007, corn farmers have responded to the growing market for ethanol, increasing production efficiency to help meet the RFS goal of moving the United States toward greater energy independence and security, boosting production of clean, renewable fuels and protecting consumers.”
The EPA’s 2018 proposal lowers the cellulosic fuel volume by 73 million gallons and the total renewable fuel volume by 40 million gallons. Spurlock said lowering the volumes takes implementation of the RFS law backward.
“We ask EPA to maintain the proposed conventional fuel requirement in the final rule,” he said. “We also ask EPA to take a more forward-looking approach with stronger final volumes for cellulosic, advanced and total biofuels in order to draw the continued investment and innovation needed to support the ongoing expansion of cellulosic and advanced fuel production.”
The National Biodiesel Board (NBB) also called for higher volumes of advanced biofuels and biomass-based diesel in its comments to the EPA.
“NBB is extremely concerned with the proposed rule’s unprecedented cut to the advanced biofuel volume and freeze in the biomass-based diesel volume,” said Doug Whitehead, chief operating officer of the NBB. “Both of these proposals run counter to Congress’s objectives to promote the growth of biofuels that provide American jobs, reduce emissions and enhance U.S. energy security. EPA cannot enact its own policy when Congress has spoken, so we look forward to working with the EPA on addressing these concerns.”
Biomass-based diesel has been a great success story of the RFS, the NBB said. Assisted in its development by the market incentive from both the biomass-based diesel volume and advanced biofuel volume, the biomass-based diesel industry has grown to support more than 64,000 jobs throughout its supply chain.
The industry has routinely surpassed the annual biomass-based diesel volumes and currently comprises the vast majority of advanced biofuel production (roughly 93%), the NBB said. Unfortunately, the EPA’s proposal would halt the progress of the biomass-based diesel industry and thwart Congress’s intent to increase advanced biofuel production.
“The proposed rule sends a chilling message that EPA is not interested in promoting growth in biofuels in accordance with the RFS, which will discourage any future investment and cause a contraction in the industry,” the NBB noted in its comments. “It will result in a blow to our country’s energy security, a loss of jobs and wages of employees concentrated in rural areas, and a reduction in the income that American farmers receive for their crops and livestock products.”
The NBB suggests the proposal’s volumes be changed more in line with congressional intent. In its comments, the NBB calls on the EPA to increase the advanced biofuel volume for 2018 to at least 4.75 billion gallons and the biomass-based diesel volume for 2019 to at least 2.5 billion gallons. Doing so is necessary to effectuate Congress’s intent to “create incentives to increase renewable fuel supplies and overcome constraints in the market” and to respect the EPA’s methodology from its own past rules, the NBB said. Raising the advanced biofuel volume to at least 4.75 billion gallons is an increase that could be achieved so easily by the industry that there is no non-arbitrary justification for the EPA to set the volumes lower.
