The National Corn Growers Association (NCGA) today urged EPA Administrator Scott Pruitt to pull back on the further reductions to the Renewable Fuel Standard (RFS) volumes the Environmental Protection Agency (EPA) contemplates in the October 4, 2017 Notice of Data Availability (NODA).
In the NODA, EPA requested additional comments on potential reductions in volume requirements under the RFS. While EPA proposed no direct changes to the implied 15 billion gallon volume for conventional ethanol, NCGA believes the volume reductions EPA is exploring are inconsistent with the law and with the United States Court of Appeals for the District of Columbia Circuit’s July 28, 2017 decision in Americans for Clean Energy v. EPA.
“As one of the petitioners comprising Americans for Clean Energy, NCGA is concerned with EPA’s attempt to incorrectly apply the Agency’s waiver authority in order to justify further reductions in volumes,” NCGA President Kevin Skunes wrote in comments submitted today to the Agency. “The further volume reductions summarized in the NODA would harm Congress’ energy and economic security objectives that motivated enactment of the RFS.”
The RFS requires increasing amounts of renewable fuel to be introduced into the nation’s fuel supply, and these additional volume reductions result from incorrect interpretations of EPA’s waiver authorities.
Skunes urged the EPA to not exercise any of the waiver authorities proposed in the NODA saying, “EPA is once again at risk of erring in its interpretation of domestic supply, despite the Court’s thorough analysis of EPA’s waiver authority.”
Although not specifically addressed in the NODA, NCGA further recommends EPA pursue no change to the treatment of Renewable Identification Numbers (RINs) on biofuel exports, a proposal raised in comments on the proposed volume rule and that EPA is reportedly considering.
“Such a change would result in new barriers to our growing ethanol exports and trade retaliation, significantly harming an export area in which the United States leads the world,” said Skunes.
NCGA’s full comments can be found here.
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