BIO Comments to the EPA PR 2014 RFS RVOs Docket ID No. EPA-HQ-OAR-2013-0479

 

January 28, 2014

 

The Honorable Gina McCarthy Administrator, Environmental Protection Agency Air and Radiation Docket and Information Center Mailcode: 2822T 1200 Pennsylvania Avenue NW Washington, DC  20460  

Docket ID No. EPA-HQ-OAR-2013-0479

Dear Administrator McCarthy:

I.             Introduction

The Biotechnology Industry Organization (“BIO”) is pleased to have the opportunity today to comment on the U.S. Environmental Protection Agency’s (“EPA”) Proposed Rule on the 2014 Standards for the Renewable Fuel Standard (RFS) Program[1] (“the proposed rule”) and the renewable volume obligations (RVO) for biofuels in 2014.

BIO is the world's largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology products. 

BIO represents nearly 90 companies leading the development of new technologies for producing conventional and advanced biofuels.  Through the application of industrial biotechnology BIO members are improving conventional biofuel processes, enabling advanced and cellulosic biofuel production technologies and speeding development of new purpose grown energy crops. Our membership includes four companies EPA cites in its proposed rule as producing commercial gallons of cellulosic biofuels in 2014[2]



[1] 2014 Standards for the Renewable Fuel Standard Program, 78 Fed. Reg. 230, 71732 (proposed Nov. 29, 2013) (to be codified at 40 C.F.R. pt. 80) (available at: http://www.gpo.gov/fdsys/pkg/FR-2013-11-29/pdf/2013-28155.pdf) [hereinafter The Proposed Rule].     

[2] Visible Progress in Biorefinery Commercialization, Industrial Biotech Companies Show Progress in Commercialization,  Biotechnology Industry Organization, Jun. 15, 2012, available at: http://www.bio.org/articles/visible-progress-biorefinery-commercialization (Appendix I)