(Posted Thu. Oct 11th, 2012)

Oct. 11:  In comments submitted to the U.S. Environmental Protection Agency today, the National Corn Growers Association expressed strong support for the Renewable Fuel Standard and noted that granting a waiver at this point would be premature.


“NCGA and our member associations have long supported the RFS2, including the waiver provision process,” wrote NCGA President Pam Johnson, an Iowa corn grower.  In response to a 2008 waiver request, EPA had established that severe harm to the economy attributed to the RFS was one of only two grounds for granting a waiver. “We believe the burden of proof for severe harm to the economy falls on the petitioner,” Johnson said. “Since higher feed prices are only one piece of a complicated economic puzzle we believe the petitioners have failed to establish this proof.”


NCGA also pointed out that, with harvest still underway, a complete count of the 2012 corn crop is unavailable, and that this information is needed for an informed decision by the EPA.


“USDA will continue to refine the crop production estimates throughout the fall,” Johnson noted.  “There is potential for this yield forecast to change, up or down, as well as future changes in harvested acreage.  Based on these crucial changes we encourage the Agency to wait until USDA has produced the November report before making any decision tied to corn availability.”


Although most livestock groups have lobbied for some waiver relief from the RFS, a large waiver may not be in their best long-term interest, NCGA’s comments state. Most notably, reducing the amount of corn processed for ethanol will cause a reduction in distillers grains. Several recent  studies have analyzed potential impacts on the feed markets from reductions in the RFS.  While a waiver may modestly lower corn prices, reduced distillers grains availability and increased soybean meal costs will negate a significant portion of the savings from reduced corn prices.


The Renewable Fuel Standard, NCGA asserts, has been a success.  Since its enactment in 2005, and expansion in 2007, it has increased national energy security by creating a market for renewable fuel as a substitute for petroleum-based fuel thereby accelerating the nation’s progress toward energy independence; contributed to the reduction of greenhouse gas emissions, thereby reducing the nation's contribution to global climate change; and had an overall positive impact on the U.S. economy.


Click here for NCGA’s complete comments, as submitted to the EPA.