BioFuels Journal

Washington, DC—This week, the Environmental Protection Agency (EPA) is holding hearings and workshops in Washington to gather feedback and explain its rationale in creating its proposed rule for the Renewable Fuels Standard (RFS).

At the June 9 public hearing, the Renewable Fuels Association (RFA), the leading voice of America’s ethanol industry, will be detailing a number of concerns the industry has with EPA’s proposed rule.

Yesterday, RFA President Bob Dinneen previewed his testimony on a conference call with reporters.

A replay can be heard here. Dinneen’s full testimony as prepared for delivery can be found here.

“By expanding the Renewable Fuels Standard, the Energy Independence and Security Act of 2007 (EISA) capitalizes on the substantial benefits that renewable fuels offer,” said Dinneen.

“However, for the potential benefits of the RFS2 to be fully realized, it is imperative that the regulation is guided by sound science, transparent analysis and economic modeling that stands up to scrutiny.

"After reviewing the RFS2 Notice of Proposed Rulemaking (NOPR) and related materials, RFA has several major concerns and we will be submitting detailed written comments soon focused on the following areas and many others.”

Specifically, the RFA would like the EPA to address:

Lifecycle greenhouse gas analysis. One of the RFA’s primary concerns with the RFS2 proposal is the tremendous amount of uncertainty and speculation associated with EPA’s lifecycle GHG analysis of biofuels, including emissions from indirect land use change.

Modeling integration, inclusion of international land use change emissions, model validation, and the peer review process are some of the specific areas of concern to the RFA and its members.

Petroleum baseline. By using 2005 as the baseline for gasoline, EPA is ignoring the carbon impacts of increased use of marginal petroleum supplies, such as the Canadian tar sands.

No indirect GHG emissions considered for oil.

No mechanism for site-specific lifecycle analysis. No two bio-refineries are the same.

EPA should allow for individual facilities to demonstrate their carbon impacts as they may be differ from EPA’s prescribe ethanol pathways.

Renewable biomass definition.

Registration, recordkeeping and reporting.

Renewable Identification Numbers (RINs) Equivalency Values.

Grandfathering. The RFA is generally supportive of EPA’s basic grandfathering approach.

However, the RFA is strongly opposed to alternatives that set an expiration date of the grandfather period for existing facilities.

“Blend Wall” Issues. The RFS2 proposal discusses various legal, practical and economic issues associated with overcoming the E10 Blend Wall.

We support redefining “substantially similar” to facilitate an immediate allowance for the use of blends up to E12 or E13 in conventional automobiles and existing gasoline infrastructure.

Effective Date. The RFA supports a proposed implementation date of Jan. 1, 2011.

Economic Impact Analysis

Experts from the RFA are in Washington this week participating in these meetings and are available for comment. Please contact Matt Hartwig at 202-289-3835 if you have specific questions.

See Related Websites/Articles:

• EPA
• RFA

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