The American Coalition for Ethanol (ACE) submitted comments to the Environmental Protection Agency (EPA) on the proposed blending volumes for 2019 under the Renewable Fuel Standard (RFS) on the final day of accepting public comments on the proposal.
ACE commented on several facets of the proposed rule including: how EPA exemptions and waivers are harming rural America and violate statutory authority, the need for reallocation of Small Refinery Exemptions (SREs) and for EPA to comply with the Americans for Clean Energy et al v. EPA lawsuit, conventional, cellulosic, and advanced biofuel levels, RIN market operations, the need to issue a rulemaking extending the Reid Vapor Pressure (RVP) relief to blends above E10, encouraging EPA to adopt the latest GREET model with respect to the lifecycle analysis of corn ethanol.
“Unfortunately, EPA continues to take actions which undermine the letter and spirit of the statute and harm the rural economy. While refiners are reporting double-digit profits, the heart of America is being left behind. Farmers are losing money while refiners have the best of both worlds: fat profit margins and minimal RFS compliance costs. EPA needs to discard its refiner-win-at-all-costs mentality and get the RFS back on track.”
“While the proposed rule purports to maintain the 15-billion-gallon conventional blending target for the 2019 RVO, nearly 50 Small Refinery Exemptions (SREs) will reduce ethanol blending far below 15 billion gallons. Known exemptions for 2016 and 2017 have resulted in at least 2.25 billion in demand destruction for U.S. ethanol. These so-called ‘hardship’ waivers flood the market with RINs which refiners can bank, thereby artificially inflating the size of the RIN carryover to more than 3 billion gallons. As a result, D6 RIN prices have cratered. One year ago, D6 RINs were fetching approximately 90 cents but SREs have sunk those prices to about 20 cents today, nearly an 80 percent collapse. This, consequently, has reduced the incentive to blend ethanol with gasoline.”
ACE’s full comments will be available at www.ethanol.org.
