Growth Energy submits comments on EPA's 2017 renewable volume obligation proposal

US biofuels lobby group Growth Energy has submitted comments to a public consultation on the Environmental Protection Agency’s 2017 Renewable Volume Obligations (RVOs), which are part of the broader Renewable Fuel Standard (RFS).

Emily Skor, CEO of Growth Energy, said: “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.”

The US RFS was created in 2005 by Congress in an effort to reduce greenhouse gas emissions and expand the nation’s renewable fuels sector while reducing reliance on imported oil. It was a bipartisan policy signed into law by President George W. Bush.

In 2007, Congress set benchmarks for where the biofuel industry should be each year in terms of volume, but Congress gave the EPA power to amend the amount of ethanol that blenders must add to fuel each year. This initiative is called the Renewable Volume Obligations (RVO), which is part of the RFS programme.

On 31 May, 2016, the US Environmental Protection Agency (EPA) proposed a 14.8 billion (bn) gallons of conventional biofuel RVO 2017 target. This falls short of the statutory target of 15bn gallons for 2017, which Congress originally set in 2007.

In a statement, Growth Energy made the following points in relation to the EPA’s RFS proposals:
• 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.