Editor’s note: The EPA conducted a public hearing Aug. 1 as part of its process of gathering comments on its Renewable Fuel Standard proposal. These are excerpts from hearing statements, with links to more information. Comments filed in the rulemaking process are posted at http://bit.ly/2vwyRfv.
American Coalition for Ethanol — Jonathon Lehman
We are extremely pleased that the proposed rule maintains the 15-billion-gallon volume for conventional renewable fuel. The ethanol industry has a current production capacity of 16.1 billion gallons with another 113 million gallons of capacity under construction.
The industry’s operating production levels stand at 15.66 billion gallons, which easily exceeds the domestic supply necessary to meet the 15 billion level called for in the statute. …
Ethanol production remains a critical market for U.S. corn farmers. According to the USDA, surplus stocks of corn will swell to a 30-year high of 2.4 billion bushels and corn prices will fall to a 10-year low in 2017. Working capital has declined to its lowest level since 2002. ...
As the D.C. Court of Appeals stated, the intent of the RFS’s “increasing requirements are designed to force the market to create ways to produce and use greater and greater volumes of renewable fuel each year.” EPA must not use the lack of demand as justification to bring volume requirements down. …
EPA should focus its attention in helping clear obstacles to using the ethanol supply being made available to refiners, importers and blenders. One such issue is removing the regulatory barrier for using E15 year-round. See more at http://bit.ly/2fetKdW.
National Biodiesel Board
The current numbers shortchange the progress we have made. They are a step back for the RFS, job creation, small businesses and rural economies. Let me assure you — these steps backwards are not about paper but people. — Donnell Rehagen
This market extends across the country – in rural areas, in urban areas, on-road, off-road and even in homes, buildings and factories. That’s the flexibility of biodiesel, which can be used throughout the distillate fuel market. This market is expected to increase, and the RFS program should ensure continued growth in renewable fuels for that market. — Scott Fenwick
Domestic production capacity is significantly underutilized, with 4.2 billion gallons of registered capacity according to EPA’s own assessment. This doesn’t even include non-registered plants or foreign production we expect will continue to reach our shores.
EPA’s proposal doesn’t acknowledge the ability of the domestic industry to step up to the plate when given proper signals by EPA. — Doug Whitehead
See more at http://bit.ly/2fe2yfn.
American Soybean Association — John Heisdorffer
ASA urges EPA to increase the volumes for biomass-based diesel to at least 2.75 billion gallons for 2019 and to increase total Advanced Biofuels volumes to 5.25 billion gallons in 2018. …
Biodiesel has expanded markets for farmers and livestock producers and created new jobs and economic growth, particularly in rural America. …
As EPA correctly recognizes and states in the proposal, the planted crops that supply vegetable oil for biodiesel are grown in response to protein meal demand for livestock feed and the oil is a co-product. …
Soybean oil has been displaced from domestic food markets as a result of the FDA determination requiring the elimination of all partially hydrogenated oil, which creates trans-fat.
Since the trans-fat labeling requirements were announced in 2003, approximately four billion pounds of annual soy oil use has been displaced from the food market.
The market outlet that biodiesel provides for soybean oil also benefits livestock production by improving the margins for soybean processing and lowering the cost of soy meal used for livestock feed. See more at http://bit.ly/2f5tHB0.
U.S. Sen. Joni Ernst
While I was pleased that the EPA set the proposed volume requirements for conventional ethanol for 2018 at congressionally directed levels, I am disappointed that the advanced biofuels numbers were lowered.
Additionally, I am concerned that the biodiesel numbers for 2019 are being held constant, and would like to see it increased to more accurately reflect our current domestic production capacity and usage.
Reducing volumes for biodiesel and cellulosic biofuels would create uncertainty and slow investment in advanced biofuels.
Especially as rural communities continue to experience a downturn in the ag economy, it is essential that the EPA’s volume requirements provide stability for these critical industries. See more at http://bit.ly/2vzvF3G.
Capital Research Center — Steven J. Allen
The RFS has all the usual characteristics of bureaucratic central planning: It features unrealistic (actually, impossible) goals, hidden taxes and regulatory burdens, and costly consequences, supposedly unintended but, often, foreseeable. …
RFS reduces the mileage of motor vehicles, funnels money from consumers to well-connected “crony capitalists,” raises the price of food, including food for the world’s poor, destroys rain forest and wetlands, and expands the dead zone in the Gulf of Mexico.
It was supposed to make us more energy independent and it was supposed to protect the environment, but it does harm to the environment, while other types of technology such as horizontal drilling and fracking have actually put us on the road to energy independence. See more at http://bit.ly/2feS8w5.
Campaign for Liberty — Norman Singleton
The standard violates the principles of a free society and harms consumers by forcing them to use biofuels, raising fuel costs and forcing consumers to spend more on fuel, and less on other goods, than they would prefer. The mandate also harms consumers by diverting the use of corn from food to fuel production, thus increasing food prices and even causing shortages.
Furthermore, interventions in the marketplace that favor certain producers encourage those producers and their rivals to spend their time, money and talent lobbying legislators and federal agencies to maintain and expand their subsidies. The resources spent on lobbying would be better spent developing new products that better serve the needs of consumers.
Finally, the mandate exceeds the powers granted to the government by the United States Constitution. See more at http://bit.ly/2ursHZY.