Tell EPA to Implement the RFS as Intended!

The Environmental Protection Agency (EPA) recently released proposed 2019 Renewable Volume Obligations (RVOs) for the Renewable Fuel Standard (RFS). The proposed RVOs set blending targets across different classes of biofuels and take comment on a range of issues related to the RFS in advance of a final regulation.

The EPA issued a proposal for 19.88 billion gallons of biofuel including 15 billion gallons of conventional biofuel to be blended in 2019, which on its surface is in line with the statutory levels intended by Congress. However, that blending target cannot be relied upon, because recent actions at the EPA have made clear that those gallons are not guaranteed to be blended. The agency has aggressively abused the so-called “small refinery waiver,” which was designed for small refineries experiencing disproportionate economic hardship to absolve them of their duty to blend biofuels under the RFS. Under the watch of this EPA, the frequency of these waivers being issued has dramatically spiked, and the waivers have been granted to numerous oil refiners including some of the world’s largest oil companies.

The misuse of EPA waivers has destroyed an estimated 2.25 billion gallons of biofuel demand in 2016 and 2017 alone by giving oil refiners a handout that allows them to neglect their responsibility to blend ethanol into the fuel supply. This flies in the face of the intent of the RFS and hurts farmers across the American heartland at a time when farm income is at a 12-year low, all to line the pockets of a select few oil refiners. The 2019 RVO proposal does nothing to reallocate the countless gallons of ethanol that were lost due to RFS waivers handed out by the EPA, nor does it restore the volumes lost to from the 2016 RVO, despite our victory in court last July that directs EPA to properly exercise its RVO authority which would lead to the restoration of 500 million gallons of biofuel demand.

President Trump has stated his support for farmers, the biofuels industry, and the RFS. Meanwhile, the EPA continues its failure in implementing the President’s agenda at the expense of rural America. We need you to take action today to tell EPA regulators that they must restore biofuel volumes under the RFS and stop bailing out oil refineries.

Enter your information to protect the RFS and support the biofuels industry!

Subject:

Docket ID No. [EPA-HQ-OAR-2018-0167]

Dear Official,

Docket ID No. [EPA-HQ-OAR-2018-0167]

Air and Radiation Docket and Information Center
U.S. Environmental Protection Agency
Mailcode: 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

To Whom it May Concern,

I am writing to urge you to reconsider your proposal for the 2019 Renewable Volume Obligations (RVOs) under the Renewable Fuel Standard (RFS). As an ethanol industry employee, I am concerned to see that the proposal does nothing to ensure that the biofuel gallons laid out in the proposal will, in fact, be blended. The ethanol industry takes pride in producing a homegrown biofuel that saves other hardworking Americans money at the gas pump, while also promoting cleaner air. This industry was borne out of American ingenuity, and we work hard to ensure that we are constantly improving our product and pushing the envelope for clean energy. 
In the past, the EPA would issue RVOs late and under-target, which cooled investment. Our industry needs certainty so that it can confidently invest in new technologies, processes, and in our rural communities.  So, while the proposal was timely and proposes 15 billion gallons for conventional ethanol, and an increased proposal for cellulosic ethanol blending, we cannot push the industry to new heights knowing that many oil refiners will never have to actually blend those gallons.

EPA’s decision not to reallocate the considerable gallons lost to refinery waivers completely undercuts the RFS and runs counter to the intent of the program. The RFS was enacted to ensure that oil refiners blend cleaner, renewable biofuels, and these refinery waivers let them off the hook with no repercussions. I understand that the waivers were created for use with smaller refiners who might be experiencing economic hardship, but numerous reports show that waivers are being handed out to refiners who are neither small, nor experiencing any kind of economic distress. It seems that EPA is putting the interests of some of the largest oil refineries ahead of hardworking Americans across the heartland.

Rural America is experiencing the worst agriculture crisis in a generation with farm income at a 12-year low. The biofuels industry has played in integral role in helping revitalize the rural community, and we cannot afford to have the RFS undermined. I urge you to show a clear commitment to implementing the RFS as intended, which includes strong RVOs and the guarantee that those accompanying volumes will actually be blended by refiners, not wiped out with the stroke of a pen and the gift of a waiver. I thank you for your consideration, and ask that you please restore the countless volume of biofuel demand that have been wiped out by refinery waivers.

Regards, Your Name

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