Any waiver of the RFS would have little to no effect on corn prices, but would certainly harm biofuel producers and biotechnology companies across the United States, the Biotechnology Industry Organization (BIO) said today in official comments to the Environmental Protection Agency on the requests by governors of several states for a waiver of America’s Renewable Fuel Standard.
BIO’s letter to EPA states:
“While waiving RFS requirements in the relevant time period would have little to no impact on the economy of a State, a region or the United States, it would cause severe harm to biofuel producers and biotechnology companies across the United States, including those in the states submitting petitions. The petitions, as presented for comment, fail to demonstrate that continued implementation of the RFS would severely harm the economy or the environment of a State, a region, or the United States as a whole during the waiver period.”
The letter cites two recent studies – the first by researchers at Purdue University and another from the University of Missouri’s Food and Agricultural Policy Research Institute – that demonstrate a waiver of the RFS cannot undo the economic harm already caused by the drought. BIO’s letter states:
“The request by petitioners not only fails to demonstrate that the RFS itself is causing severe harm to the economy or environment of a State, a region or the United States, but it essentially amounts to a request that EPA redistribute the economic harm caused by the drought to both benefit and harm other industries. It is not EPA’s job to redistribute the loss caused by the drought regardless of the relative size of the industries harmed and benefited.”
The letter concludes:
“The stability and growth of the entire biofuels industry depends on the continued and predictable implementation of the RFS to meet the policy’s overall goals of expanded production and use of renewable fuels in the transportation sector.
“A waiver of the RFS would have a significant negative impact on investments in advanced biofuels. The RFS and EPA’s consistent implementation of the law is the fundamental policy driver for the continued development of U.S. biofuels, particularly advanced and cellulosic biofuels. It provides the industry and investors confidence that if they can produce commercial volumes of advanced and cellulosic biofuels, the RFS will ensure market access for those types of fuels. Waiving the RFS would cause great investment uncertainty, thus harming the nascent advanced and cellulosic industries which depend on it for survival.”