U.S. Environmental Protection Agency’s Public Hearing for the 2014 Standards for the Renewable Fuel Standard Program, Docket Number: EPA-HQ-OAR-2013-0427

Thursday, December 5, 2013

U.S. Environmental Protection Agency’s Public Hearing for the 2014 Standards for the Renewable Fuel Standard Program, Docket Number: EPA-HQ-OAR-2013-0427

Hyatt Regency, Crystal City, 2799 Jefferson Davis Highway, Arlington, VA

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 ethanol processes, enabling advanced biofuel production technologies and speeding development of new dedicated energy crops.  To date, these companies have invested more than $5.7 billion in private capital here in the United States in building the advanced and cellulosic biofuels industry[2].  Our membership includes four companies EPA cites in its proposed rule as producing commercial gallons of cellulosic biofuels in 2014[3]

Our member companies are deeply concerned the proposed rule is a fundamental change in direction and it sets a troubling precedent for the RFS in 2014 and beyond.  Creating an inconsistent regulatory climate will undercut investment and undermine the development of advanced and cellulosic biofuels, just as they are set to produce millions of commercial gallons and launch a rapid scale up.