The National Corn Growers Association today submitted comments to the Environmental Protection Agency (EPA) on the proposed rule for the 2019 volume standards under the Renewable Fuel Standard (RFS) program. The rule proposes an implied 15 billion-gallon volume for conventional ethanol but fails to account for, nor consider comments on, retroactive exemptions granted to refineries.
“To uphold the full clean air, cost-savings, energy independence and rural economic benefits consumers and farmers receive from the RFS, EPA must also use the 2019 volume rule to make and keep the RFS whole,” NCGA President and North Dakota Farmer Kevin Skunes said.
In the proposed rule, EPA disclosed the agency granted retroactive exemptions to 48 refineries for 2016 and 2017 RFS obligations, amounting to 2.25 billion ethanol-equivalent gallons. Through this proposed rule, EPA has the tools to ensure retroactive exemptions do not further reduce volumes. However, EPA stated the agency is not soliciting comments on how to account for exemptions going forward to prevent exemptions from lowering RFS volumes.
“While EPA may not want feedback on how the agency is failing to maintain the integrity of the RFS and administer the volume standards in accordance with the law, corn farmers will provide that feedback nonetheless and make our voices heard,” NCGA’s comments state. “The process for accounting for these volumes is central to the integrity of the RFS, and it is offensive to farmers that EPA does not believe our comments on this issue are worth soliciting and considering.”
NCGA’s comments also stressed the importance of a strong RFS for farmers facing their fifth consecutive year of depressed income and commodity prices. The financial stress on agriculture impacts rural businesses and communities across the country.
“Maintaining an implied volume for conventional renewable fuel at 15 billion gallons, consistent with the statutory target for 2019 and the proposed rule, provides a firm base of support for ethanol production and corn prices. A strong RFS is a market-based solution for sustaining the agriculture economy,” the comments state.
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