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Biofuel Advocates' Letter to EPA Administrator Pruitt on 2019 Cellulosic Volumes

As the U.S. EPA begins its work to develop the proposed 2019 Renewable Fuel Standard (RFS) Renewable Volume Obligation (RVO), a group of trade association advocates encourage the agency to take a renewed look at commercially ready cellulosic biofuels.

The Honorable Scott Pruitt
Administrator
U.S. Environmental Protection Agency
Washington, DC 20460

Dear Administrator Pruitt,

As the U.S. Environmental Protection Agency (EPA) begins its work to develop the proposed 2019 Renewable Fuel Standard (RFS) Renewable Volume Obligation (RVO), we encourage the agency to take a renewed look at commercial-ready cellulosic biofuels.

One sector warranting EPA’s closer attention is cellulosic ethanol made from corn kernel fiber. In 2017, EPA noted that “when reviewing the cellulosic biofuel production data … we find that facilities that convert corn kernel fiber to cellulosic ethanol at existing ethanol production facilities have generally over performed relative to our production estimates.” Unleashing corn kernel fiber ethanol production will bring significant and immediate economic, environmental and energy security benefits. Existing ethanol plants could produce hundreds of millions of gallons of cellulosic ethanol from this single stream of agricultural residue in the near term.

While the industry outlook for corn kernel fiber cellulosic ethanol is strong, EPA set low volumetric projections for corn kernel fiber cellulosic ethanol in the proposed 2018 RVO and reduced the targets for corn kernel fiber ethanol in the final rule. The overly conservative corn kernel fiber ethanol projection, compounded with uncertainty around how quickly EPA will approve new corn kernel fiber ethanol technologies for D3 RIN generation, threatens to slow adoption of cellulosic production capacity at existing ethanol facilities across the country.

Group Letter to EPA on 2019 Cellulosic Biofuel RFS Volumes