BIO Comment on EPA's Proposed Denial of Petitions for Rulemaking to Change the RFS Point of Obligation
April 26, 2017
Because the oil industry is highly consolidated and vertically integrated, enforcing the RFS program at the right point in the supply chain is critical to ensure that key market players have the incentive to facilitate the goals of the program. Moving the point of obligation downstream would remove that imperative for refiners and inject uncertainty into the program, undermining the ability of market actors to plan for growth in renewable fuels use as mandated by Congress. Further, committing to one regulatory regime only to change the rules midstream hampers the RFS program’s goal -- mandated by Congress in the law that created the program -- of accelerating the commercialization of advanced and cellulosic biofuels. Changing the point of obligation would achieve just the opposite of that goal. It would increase program complexity, impose a set of new administrative and compliance costs and risks that would adversely affect a significant range of new entities, and undermine investor confidence in the broader renewable fuels industry just as cellulosic and other advanced biofuels are coming online2. Also, as EPA rightly noted in its draft analysis of the Proposed Denial, market data does not justify changing the RFS point of obligation.
One thing that we can all agree on is the need to give our children a fighting chance so they can lead long and productive lives. That is why it is critical to pass the bipartisan Give Kids a Chance Act and ensure the Pediatric Priority Review…
Dear Colleagues, This month marks my one-year anniversary as BIO's CEO. Like most of us in biotech, this post has been a labor of love. At no time in my 25-year career in this industry have I ever witnessed such awe-inspiring science. Today, we…
Re: BIO Comments on Office of Management and Budget (OMB) Statistical Policy Directive No. 8 North American Industry Classification System (NAICS)-Request for Comments on Possible Revisions for 2027 (USBC–2024–0032)Dear Ms. Orvis,The Biotechnology…
Because the oil industry is highly consolidated and vertically integrated, enforcing the RFS program at the right point in the supply chain is critical to ensure that key market players have the incentive to facilitate the goals of the program. Moving the point of obligation downstream would remove that imperative for refiners and inject uncertainty into the program, undermining the ability of market actors to plan for growth in renewable fuels use as mandated by Congress. Further, committing to one regulatory regime only to change the rules midstream hampers the RFS program’s goal -- mandated by Congress in the law that created the program -- of accelerating the commercialization of advanced and cellulosic biofuels. Changing the point of obligation would achieve just the opposite of that goal. It would increase program complexity, impose a set of new administrative and compliance costs and risks that would adversely affect a significant range of new entities, and undermine investor confidence in the broader renewable fuels industry just as cellulosic and other advanced biofuels are coming online2. Also, as EPA rightly noted in its draft analysis of the Proposed Denial, market data does not justify changing the RFS point of obligation.