BIO has filed official comments stating that the EPA lacks the authority to waive the overall 2014 volume requirements for the RFS, particularly when production and supply of advanced biofuels continues to grow. BIO has also said that if EPA does lower advanced biofuel volume requirements, it will undercut efforts to commercialise new cellulosic biofuel technologies just as they begin to enter the market.
Comments to the EPA
Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section has commented, ‘a court would not likely uphold the 2014 RFS rule as proposed, given that EPA’s proposed interpretation of its authority under the general and cellulosic waiver authorities exceeds the bounds of appropriate deference under the law.’
Last year, the advanced biofuel industry produced more than 3.26 billion qualifying gallons of renewable fuel. And BIO believe that based on proven production, the industry will be able to produce an adequate supply of 3.75 billion gal. in 2014, called for in the RFS statute. Erickson said, ‘multiple avenues exist for blending additional volumes of biofuel into the nation’s fuel supply…These options, combined with the introduction of new ‘drop in’ fuel molecules, provide a suite of opportunities for the growth of the entire biofuels industry and RFS compliance.’
In the comments submitted, Erickson went on to explain that because the RFS program’s compliance system has a nested structure, with RINs used as tradable compliance credits, ‘EPA’s proposal to lower the advanced biofuel obligation from 2.75 billion RINs in 2013 to 2.21 billion RINs in 2014 will create a disincentive for purchasing cellulosic biofuel, by artificially lowering the cost of the alternative method of compliance.’
The comments to concluded that the EPA should not put at risk the progress the advanced biofuel industry has made in commercialising new biofuels and the environmental benefits that can be achieved. The advanced biofuel industry has invested US$ 5.9 billion and created 8000 jobs over the past five years, with the potential to create up to 800 000 career opportunities by 2022. Further, these advanced biofuels are reducing greenhouse gas emissions now and will continue to do so in the future. ‘The net increase in CO2 emissions resulting from the proposed rule is equivalent to adding 5.6 million additional vehicles to the roads,’ in 2014, Erickson commented, with cumulative foregone reductions of nearly 1 billion t of CO2 by 2022.
Adapted from press release by Claira Lloyd
Read the article online at: https://www.hydrocarbonengineering.com/gas-processing/29012014/support_for_higher_rfs_levels/