The Renewable Fuels Association has submitted 16 pages of comments to the Environmental Protection Agency on its Renewable Fuel Standard proposed rulemaking for 2012. In its comments, RFA addressed both the proposed levels of renewable fuel use for 2012 as offered by EPA as well as reissued calls for EPA to address fundamental problems it created when crafting the RFS.
"Ensuring the integrity the RFS is strengthened and the intent with which Congress created it is honored is absolutely critical to the growth and evolution of domestic ethanol production," said RFA President and CEO Bob Dinneen. "EPA officials have done yeomen's work to get this groundbreaking program up and running, but work still remains. The RFA is committed to working with EPA to make sure the RFS, and the implementation of E15 to help refiners meet the RFS requirements, are successful."
Three key areas of focus in RFA's comments included the cellulosic biofuel requirements of the 2012 RFS, the "small refiner" de facto waiver issued by EPA and the continued inclusion of indirect land use change penalties against corn-based ethanol despite reams of scientific data proving EPA's data and modeling are out-of-date, to say the very least.
The Renewable Fuels Association strongly encourages EPA to re-evaluate and refine the indirect land use change analysis that was conducted for the RFS2 Final Rule - taking into account newly available studies, modeling results and data. The RFA has criticized EPA's inclusion of so-called ILUC penalties and has pointed out that several new scientific analyses have been completed that better demonstrate to what extent if any such land use changes are occurring and those factors that are responsible for such changes.
RFA's comments also addressed a number of technical changes proposed by EPA as well as market-expanding issues such as the Renewable Identity Number carry-over precisions from year to year. The entirety of RFA's comments can be read here.