On behalf of the more than 35 advanced biofuel companies listed below, we are writing to express our concern about a recently released draft of the proposed 2014 RFS volumetric blending requirement. While the official proposed rule has not been released, it is clear that a number of key issues are under consideration at the present time.
As you know, there are two overarching compliance pools in the RFS – conventional and advanced. The biofuels industry has stepped up to provide the legislatively required gallons for both RFS categories through 2012. More specifically, the ethanol industry has produced more than enough fuel to meet the conventional standard, and administrative flexibility in the advanced pool has allowed other types of advanced biofuels to make up for the shortfall in the cellulosic biofuel pool through 2012. We also expect to provide sufficient volumes of biofuel in 2013 to meet the originally legislated RFS targets. Simply put, this is a tremendous accomplishment during very difficult economic times.
Going into 2014, it is clear that the Administration is considering making a number of administrative adjustments to the originally legislated blending requirements. This possibility raises some important issues that we would like to comment on.