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Letter to Gina McCarthy, Administrator, Environmental Protection Agency - Renewable Fuel Standard


The Honorable Gina McCarthy
EPA Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington DC 20460

RE: 2014 Renewable Fuel Standard

Dear Administrator McCarthy -

We are writing to express our concern regarding the Environmental Protection Agency's (EPA) proposed rule for the 2014 renewable volume obligations (RVOs) under the Renewable Fuel Standard (RFS) program. By reducing the amount of renewable fuel blended into gasoline lower than in 2013, this rule could hurt rural economies, jeopardize American jobs, raise prices at the pump and deter investment in biofuels and biofuel infrastructure. We are further concerned that the rationale used by the EPA is inconsistent with the current statute and could jeopardize the future of the renewable fuel industry.

As you are aware, Congress first approved the Renewable Fuel Standard in the Energy Policy Act of 2005 and then significantly expanded it in 2007 through the Energy Independence and Security Act. From 2005 through 2012 our dependence on imported petroleum products declined from 60% to 41%, due in part to increased use of ethanol and other biofuels. Reducing our dependence on foreign oil is in the best interest of our country's national security. Additionally, the RFS supports almost 400,000 American jobs and has helped encourage billions of dollars of investment in research and development in biofuel-related technologies.

The significant reduction in renewable volume obligations under this proposed rule could destabilize the renewable fuel industry and send the wrong message to investors. This risks jobs and threatens the development of advanced and cellulosic biofuels that bring higher-level ethanol and biodiesel blends to consumers. Seventy-five percent of the current vehicle fleet is approved to operate on E15.

In the RFS, Congress provided flexibility to the EPA to adjust required volumes based on anticipated production for advanced biofuels. Furthermore, this year is one of the biggest corn harvests on record and yet the proposed rule would reduce the RVOs significantly. Instead of using a higher volume of available corn for ethanol blending, gasoline would need to be refined from more foreign oil, which could drive up gas prices for all consumers.

We respectfully request that EPA revise this proposal, ensuring that it is consistent with the law and its requirement to set volumes based on anticipated production. Without a revised proposal, we are concerned that the EPA's proposed rule would impose significant burdens on rural economies while increasing gas prices and our reliance on foreign oil.