In response to the Environmental Protection Agency’s (EPA) proposal for the 2017 Renewable Volume Obligations (RVOs), which are part of the broader Renewable Fuel Standard (RFS), Growth Energy submitted detailed comments as part of the public comment period.
Emily Skor, CEO of Growth Energy, stated, “The Renewable Fuel Standard (RFS) has been the most successful energy policy in the last 40 years. Biofuels, like ethanol, are cleaner burning and reduce harmful emissions that have been linked to cancer and smog. They provide consumers with a choice and savings at the pump, and the RFS promotes economic growth and energy security, helping to isolate America from the volatile price of oil from foreign, and often hostile nations.”
Skor added, “The comments filed today outline the case for why EPA must continue to move the RFS and, ultimately the development of biofuels forward. It is vital that EPA meet the statutory biofuel targets for America’s fuel mix and keep their promises to consumers, investors and the nation. The RFS always envisioned higher blends in the marketplace, such as E15, and currently ethanol producers, retailers and the current auto fleet are fully capable of providing consumers with a fair and open fuel marketplace and a true choice at the pump.”
While Growth Energy filed extensive comments, the following points are among the most critical in showing EPA why they must adjust their final proposal to match the statutory levels that Congress intended:
- EPA’s continued use of the general waiver authority to contort the definition of “supply” to mean supply and demand is legally invalid. Additionally, EPA is statutorily required to account for the carryover RIN bank when assessing whether there is “inadequate domestic supply” for purposes of the general waiver authority. Putting aside these legal infirmities, EPA’s proposal underestimates the volume of renewable fuels the market could consume.
- EPA significantly understates the volume of E85 that could be consumed. Growth Energy provides expert analyses that support that the market could easily consume at least 750 million gallons of E85 in 2017, and very likely substantially more.
- EPA similarly understates the volume of E15 that could be consumed.
Click HERE to view the Executive Summary.
Click HERE for the full comments submitted to EPA.
Click HERE for the exhibits submitted to EPA.