Iowa Experience Proves EPA Should Enforce the RFS as Congress Intended

The Iowa Renewable Fuels Association (IRFA) recently submitted comments on the proposed Renewable Fuel Standard (RFS) volumes, urging the Environmental Protection Agency (EPA) to enforce the law as Congress intended and set the final targets at 15 billion gallons for corn-based ethanol in 2017 and at least 2.5 billion gallons for biomass-based diesel in 2018.

“The current RFS proposal simply doesn’t go far enough in advancing the use of homegrown, cleaner-burning renewable fuels,” stated IRFA Executive Director Monte Shaw. “From feedstocks and production capabilities to consumer use and marketplace trends, every data point demonstrates that the EPA should increase the proposed volumes and finalize corn-based ethanol levels at 15 billion gallons for 2017 and biomass-based diesel levels at 2.5 billion gallons for 2018.”

irfa-rfsDiscussing corn-based ethanol in its comments to the EPA, the IRFA stated, “The only physical barrier to greater use of renewable fuels is the inability of the average motorist to pull up to a fuel pump and choose from a variety of fuel options.

“This restriction on competition is not the result of consumer preference, equipment availability or renewable fuels supply. Iowa retailers have had great success with higher ethanol blends like E15 and E85, when they are allowed to sell it. Customer demand is high. Contrary to the blatantly false claims that a ‘blend wall’ exists, even more motorists would buy E15 and E85 if it were just available for them to choose.”

In fact, Iowa data shows retailers that offer a range of ethanol blended fueling options through blender pumps are already meeting the full 2022 RFS levels today, often meeting or exceeding the 18 to 19 percent renewable content targets for gasoline sales.

Switching to biodiesel, the IRFA commented, “Biodiesel has been an unmitigated success under the RFS… In fact, the U.S. is expected to use about 2.5 billion gallons of biomass-based diesel in 2016 – 400 million gallons more than the number EPA proposes to set for 2018—two years from now. Finalizing the proposed level would simply memorialize the status quo while nearly 60 percent of U.S. biodiesel industry capacity sits idle.

“Through May of 2016, roughly 30 percent of the biodiesel market was imports, and the number continues to grow… Congress gave the EPA the authority to set the biodiesel level to ensure growth for this widely-successful advanced biofuel. Factoring in imports, the proposed level does not achieve this goal.”

Discussing Iowa-specific data, the IRFA commented, “In 2010, the average blend level of biodiesel-blended gallons sold in Iowa was 3.1 percent. By 2015, the average biodiesel blend level in Iowa had more than tripled to 11.0 percent—a level that simply could not have been reached without selling a significant amount of not just B11, but B15 and B20 as well.”

The IRFA concluded, “The bottom line remains clear: there is no legal, marketplace or consumer rationale for reducing the conventional biofuels level below the statutory requirements.

“We urge the Obama Administration to reembrace the goals of the RFS that President Obama voted for in 2007, to level the playing field against 100 years of oil subsidies. We urge the Obama Administration to reexamine its support and aspirations for the RFS voiced back in 2008. And we urge the Obama Administration to set RFS levels—in this, its final opportunity—that recommit the RFS to pushing for more competition, more energy security, more jobs and a cleaner environment.”

To read IRFA’s full comments, please click here.

In May, the EPA proposed capping the corn-based ethanol portion of the RFS at 14.8 billion gallons for 2017, below levels prescribed by Congress under the Energy Independence and Security Act of 2007. Also included was the biomass-based diesel level for 2018, proposed at just 2.1 billion gallons. To view the EPA’s full proposal, please click here.

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