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Letter to the Hon. Andrew Wheeler, Acting Administrator of the Environmental Protection Agency - Push for Year-Round E15

Letter

Dear Acting Administrator Wheeler,

As representatives of our country's strongest farming communities, we are writing to share our comments regarding the 2019 Renewable Volume Obligations (RVO) proposal under the Renewable Fuel Standards (RFS).

The RFS promotes economic development and energy security for American farmers and families. The proposed rule for the 2019 RVO demonstrates a strong commitment to ethanol production and future growth for cellulosic and advanced biofuels. Although the increase to 2.43 billion gallons in biomass-based biodiesel for 2020 is a positive step, the Environmental Protection Agency acknowledged in its proposed rule (83 Fed. Reg. § 132 July 10, 2018) that biodiesel production can reach 2.8 billion gallons in 2019 and we ask that the final rule incorporate this conclusion. But these commitments and the integrity of the RFS are undermined if the EPA continues to abuse the hardship waiver authority for small refineries.

The EPA approved 48 retroactive RFS waivers for refineries for 2016 and 2017 obligations, effectively eliminating 2.25 billion gallons in the marketplace. The 2019 RVO targets and the success of the RFS will continue to be undermined if the EPA does not account for further waivers. We urge the EPA to put an end to these secret waivers until a process is established to make the name of the refinery, the gallons waived, and other relevant information publicly available. Additionally, accounting for any 2019 waived gallons in the final rule would help ensure biofuel production is not harmed by retroactive refinery exemptions.

Instead of advancing policies that would hurt farmers and prevent market growth of ethanol, we encourage you to also consider reducing regulations, like those that prohibit the year-round sale of E15. This regulatory change would increase consumption of biofuels while also lowering RIN prices, which eases implementation of the RFS and provide consumers with another choice at the pump.

We look forward to working with you to help protect the RFS and urge you to address these issues so this important program continues to drive economic growth and investment in our rural communities.


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