BIO comments on EPA’s proposed rule on the Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019
BIO requests that EPA revise its proposed 2018 RFS rule to build upon the successes of the 2017 RFS and send a signal that there will be market growth for advanced and cellulosic biofuels. The proposed rule in its current form puts at risk industry progress and development with a new methodology that will in effect limit the volumes for cellulosic biofuels.
The advanced and cellulosic biofuels industry are poised for rapid growth in 2018 if the final 2018 RFS rule includes the necessary changes from the proposed version to allow these producers access to the transportation fuel market.
When allowed to work, the RFS has enabled billions of dollars of investment in new technologies that have led to the rapid growth of the renewable fuels industry and the biobased economy. This benefits our nation’s economic and energy security. The growth of the biofuels industry has bolstered our rural communities and provided agriculture producers stable commodity markets. To continue this success and bring even greater job growth to rural America, the final rule for the 2018 RFS should not arbitrarily limit growth of advanced and cellulosic biofuels industry.
To make this possible, EPA must reject its new methodology of forecasting gallons under the cellulosic waiver and return to a forward-looking forecasting methodology that considers current market activity. EPA should also not limit advanced and overall volumes by reducing them at the same levels as the cellulosic biofuels market. EPA can help ensure that additional gallons of advanced and cellulosic biofuels will be available by expediting pathway approvals and adjusting its treatment of carryover RINs.
We respectfully urge the Agency to work with us and other stakeholders to make the recommended changes laid out in our comments. Stable implementation of the RFS in line with the statutory requirements can help drive the growth of the advanced and cellulosic biofuels industry. The result will be to spur the development of new investment, innovation, and job growth; and to enhance energy and national security.
We look forward to working with you toward these goals. Thank you for considering these comments.