Editor’s note: The comment period on EPA’s “Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019” ended Aug. 31.
The rulemaking docket shows the proposal drew 1,234 comments and 148 supporting documents. Following are portions of comments and documents. The docket is at http://bit.ly/2woEj42.
National Corn Growers Association
Keith Alverson, Chester, S.D.
My local ethanol plant was constructed one year prior to my college graduation. That plant, and the economic opportunity it created, is a large part of what enabled me, as well as other young farmers, to return to the farm. Likewise, childhood friends and relatives found good jobs at our ethanol plant, enabling them to stay at home and help our rural community grow. …
While NCGA supports the proposal for conventional biofuel, we are concerned that EPA reduced the total volume by 40 million gallons – and the cellulosic volume by 73 million gallons – compared with final 2017 levels.
As EPA noted in the proposed rule, many ethanol producers are investing in new technologies to produce cellulosic ethanol at existing facilities. NCGA urges EPA to work with producers to fully quantify this production and consider all 2017 cellulosic data.
It’s not only corn stover that can produce fuels with greater [greenhouse gas] benefits. For example, we have documented substantial carbon sequestration on our farm through ongoing soil testing. Our data translates to an 85 percent GHG reduction for ethanol compared to gasoline.
American Soybean Association
Soybean farmers nationwide urge 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. …
While biodiesel is now made from a diverse and growing volume of feedstocks, soybean oil remains the largest source of biodiesel feedstock. …
Biodiesel also provides additional economic, energy, and environmental benefits, such as increasing volumes of domestically produced, renewable energy while providing significant reductions in greenhouse gas emissions resulting in improved air quality. …
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.
Energy Resources Center
University of Illinois at Chicago
Steffen Mueller, Ph.D.
Of concern to us is the fact that the RFS is based on outdated life cycle methodology and the outdated modeling runs are still widely posted throughout the EPA websites. In fact, the outdated modeling exercises have been superseded by much newer and very comprehensive analyses conducted by other U.S. government entities including the USDA and the U.S. Department of Energy. …
EPA’s outdated RFS modeling runs have had direct negative impact in the recent past as foreign countries look at importing U.S. produced corn ethanol. Brazil cited the outdated greenhouse gas modeling runs in that country’s development of import barriers against U.S. produced corn ethanol. Other countries likewise cite these modeling runs in their evaluations of U.S. produced corn ethanol for consideration as blending additive into their fuel supply.
Therefore, we urge the EPA to update the life cycle modeling runs for biofuels including corn ethanol.
C. W. Martin
I am an American rancher/beef producer and am much in favor of expanding the amount of ethanol/biofuels that could be available to the public. Considering the valuable positive economic impact to our American farmer, it is imperative that we support, and hopefully increase, our corn growers’ bottom line.
It may seem paradoxical that I as a beef producer want to see higher prices for feedstuffs, especially corn, which is the main driver of all other commodities, since that means a higher cost of inputs for me to finish beef for harvest. The fact is this, the total American agricultural economy must achieve a higher plateau of prices, or our national pride and priority of bountiful food production will be severely harmed because of the negative return to our ranchers and farmers.
Anonymous public comments:
… I’m just a homeowner with a sputtering mower in the shed and two snow throwers in the shop awaiting expensive repairs due to E10 phase separation.
I don’t know what to expect in the long term for my boat engines, but they definitely consume more fuel than before, and that’s while operating at lower RPM. As for my vehicles, they all get lower MPG and reduced power/torque. …
This whole corn lobby driven program is, and always has been, headed down the wrong road, inflating the cost of all sorts of foods and reducing the amount available for consumption, both domestically and for the export markets, driving up expenses across the board, consuming more energy to produce than it has the thermal potential to provide …
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Any mandate of ethanol in gasoline is support for the worst kind of crony capitalism. It creates distortions of the market, causing corn to be grown for the benefits of the farmer, costing the consumer in higher fuel costs, lower fuel efficiency and higher grocery prices. It is wrong economically and from an environmental standpoint!
Don’t do it.
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As a recreational boat owner, I urge the EPA to carefully review the consequences of the proposed Renewable Volume Obligations for 2018 and their effect on the supply of fuel that is safe to use in my boat. I am deeply concerned the proposed mandated ethanol volumes will make it more difficult for me to find fuel that is safe and legal to use in my boat’s engine. …
I am also very troubled that not enough has been done to prevent the mis-fueling of my boat with the higher ethanol blends. The mis-fueling mitigation plans currently available, essentially only one sticker on fuel pumps dispensing E15, are totally inadequate protection against my inadvertently using the wrong gasoline in my boat. …
This whole issue is a politician’s answer to propping up corn farmers with a fuel that gets worse mileage, is more expensive and results in virtually no improvement in air quality.