BIO Comment on EPA’s Renewables Enhancement and Growth Support (REGS) Proposed Rule
BIO supports EPA’s ongoing efforts to improve the efficiency and effectiveness of the federal Renewable Fuel Standard (“RFS”) program, which was created by Congress, with bipartisan support, in statutory provisions that President George W. Bush signed into law as part of the Energy Policy Act of 2005 and Energy Independence and Security Act of 2007.
First, BIO supports EPA’s efforts to facilitate inclusion of additional biofuels under the RFS program. To this end, we support EPA’s proposed allowance of biofuels produced using a biointermediate developed at one facility which is then processed into renewable fuel at another. However, BIO and its members are concerned that the current proposal to allow for biointermediaries—including imposing the same registration and recordkeeping requirements on biointermediate producers as required of a renewable fuel producer—would be unnecessary and overly costly and burdensome, and would deter most biointermediate producers from partnering with renewable fuel producers. BIO, therefore, urges EPA to take a more practical and feasible approach and to allow renewable fuel producers to ensure that biointermediates meet the requirements of the RFS program without imposing a new regime of separate requirements on biointermediate producers.
Second, we support the inclusion of new pathways for the production of qualifying cellulosic fuels using short rotation hybrid poplar and willow trees as feedstocks. BIO encourages the EPA to continue working to approve additional pathways for qualifying fuels under the RFS.