BIO Comments to the EPA RVOs 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]. 

a.    Biofuels are lowering fuel costs, reducing dependence on foreign oil, creating jobs, and providing environmental benefits.

Congress established the RFS to encourage the use of conventional biofuels and the development of advanced and cellulosic biofuels in order to reduce our reliance on the rising cost and price volatility of oil.  The RFS has already provided real benefits to America’s economy by reducing dependence on foreign oil, creating jobs, and providing environmental benefits. 

The RFS has contributed to improved energy security.  Ethanol and biodiesel already represent 10 percent of the nation’s motor fuel supply.  This means motor fuel that would have been made from oil, most likely from foreign sources, is now being produced in the U.S. at facilities typically in rural areas, providing high-skilled jobs and keeping revenues in the country.  As noted by the U.S. Energy Information Administration (EIA), U.S dependence on imported oil has declined since peaking in 2005, in part because of the increased use of biofuels[3] as mandated by the first RFS passed in 2005’s Energy Policy Act (P.L. 109-58).

Since 2000, increased use of biofuels has reduced dependence on foreign oil by 25 percent.  While the decline in oil imports from 60 percent to 41 percent can be partially attributed to increased domestic production and more efficient vehicles, without ethanol, import dependence would have been 48 percent.[4]

Without the RFS, U.S. dependence on imported oil would be higher, despite increases in domestic oil production and falling demand.  While there is much discussion of energy independence in “North America,” since we get much of our imported oil from Canada, we continue to send more than $1.3 billion outside our borders every day for oil.  Every barrel of oil we import, even from our neighbors to the north, adds to our growing deficit and to our energy insecurity.