The deadline to submit comments on the Environmental Protection Agency's proposed rule for the Renewable Fuel Standard's 2020 volume standards is Nov. 29, 2019.

The National Corn Growers Association and National Farmers Union submitted their comments Nov. 25.

In their comments, the NCGA calls on the EPA to follow the law.

"As EPA significantly expanded RFS exemptions for refineries and waived 4 billion gallons of renewable fuel blending over the past three RFS compliance years, we have asked EPA to use available tools to fulfill the agency’s obligation to ensure RFS volume requirements are met," NCGA President Kevin Ross wrote. "However, EPA didn’t take that action in the 2019 volume rule or the original 2020 proposal."

Rather than addressing the impact of waived renewable fuel gallons based on exemptions actually granted by EPA, the proposed rule would use a three-year average of Department of Energy recommended waivers. By using DOE recommendations, not actual waived gallons, EPA’s proposal to redistribute any future waived gallons is half of what President Trump previously committed to farm-state senators.

The EPA's supplemental proposed rule “fails to accurately account for the lost gallons and betrays President Trump’s promise to rural America,” according to National Farmers Union. NFU President Roger Johnson urged the agency to account for all 4 billion gallons worth of demand lost to SREs and to establish provisions to prevent the future abuse of waivers.

Related:NCGA targets EPA RFS waivers in new campaign

“On the campaign trail and now as president, Donald Trump has sworn his allegiance to family farmers and ranchers and promised to uphold policies that ensure their prosperity," Johnson said. "But actions speak louder than words ­– despite those promises, his EPA has repeatedly and deliberately undercut the American biofuels industry, prioritizing the needs of multibillion-dollar oil corporations at farmers’ expense."

NFU calls for the EPA to recalculate its obligations and reallocate all 4 billion gallons lost to small refinery exemptions since Trump took office.

"Further, we strongly urge the agency to prevent future abuses by providing greater transparency on both the criteria and the process for granting small refinery exemptions," Johnson said.

“EPA’s proposal does not ensure sufficiently accurate projections for waived gallons and, therefore, will continue to shortchange the RFS when waivers are granted,” Ross wrote.

Between 2013 and 2015, EPA granted no more than eight small refinery waivers per year. The Trump administration retroactively approved 19 waivers for 2016, granted 35 waivers in 2017 and another 31 in 2018 – ultimately exempting more than 4 billion gallons of renewable fuel obligations over the past three years.

Related:Trump suggests rescinding ethanol waivers

Before the Trump administration took office, EPA approved between 50% and 62% of the applications. Under this administration, EPA approved 95% of the exemptions requested in 2016 and 2017 and 74% of the petitions in 2018 – after prolonged pushback from key agriculture and biofuel industry stakeholders.

“These decisions have had significant impacts on struggling farmers, who have watched the demand for corn grown for ethanol drop as the renewable fuel volume obligations diminish with each exemption granted," American Farm Bureau Federation said. "It is alarming that the agency will continue down this path as farmers are facing extreme weather challenges, trade headwinds and a rural economy nearing its breaking point."

More than 1,900 corn farmers have submitted comments to the EPA.

Click the download button below to see the comments submitted by National Farmers Union and the National Corn Growers Association.