An Open Letter to EPA Acting Administrator Wheeler

September 03, 2018

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by Brian Jennings (American Coalition for Ethanol/Ethanol Producer Magazine) ... Consider this a blueprint for restoring the trust EPA has broken with farmers and rural America.

1. Make good on the president’s promises to allow E15 use year-round.

Trump has made three or four public promises to allow E15 use year-round and has not said it has to be a package deal whereby refiners get another win in exchange. EPA should issue a clean and legally defensible proposal to provide Reid vapor pressure (RVP) relief for all ethanol blends greater than 10 percent so a final rule is in place before the spring of 2019.

2. Make good on Trump’s Renewable Fuel Standard promises.

As a former Senate staffer, perhaps you will have better appreciation for the need to adhere to the letter of the law when implementing the RFS than Pruitt. Trump proclaims to support the RFS. Here are steps EPA could take with the RFS to reverse some of the damage Pruitt has done to ethanol demand.

• Stop handing Small Refinery Exemptions out like trick-or-treat candy. Immediately reallocate the 2.25 billion gallons already waived. If and when EPA issues legitimate Small Refinery Exemptions, reallocate the waived gallons to remaining obligated parties as required by the law.

• Comply with the court ruling (Americans for Clean Energy et al. vs EPA) on EPA’s improper use of the RFS waiver authority, which requires you to restore a 500 million-gallon renewable identification number (RIN) obligation to the 2016 renewable volume obligation (RVO).

• Take the export RIN scheme to the trash once and for all. It’s illegal, would add insult to the trade war injury already hurting farmers, and jeopardize our ability to export ethanol.

• Adopt the most recent Argonne National Laboratory’s GREET model to determine the life-cycle analysis of corn ethanol. EPA’s analysis of the carbon footprint of ethanol is severely flawed and has not been updated since 2010.

• Clear the red tape stalling the progress of cellulosic biofuel. Unfortunately, it can take more than 1,000 days to approve new pathways for cellulosic feedstocks. For plants with approved pathways, EPA appears to be slow-walking the registration process. Accelerate the approval of cellulosic ethanol registration applications. This would help put more volumes of cellulosic biofuels online as intended under the RFS.

3. Unleash high-octane fuels to help meet future Corporate Average Fuel Economy greenhouse gas (GHG) standards.

Ethanol is a superior high-octane, low-carbon fuel that can help automakers comply with fuel economy and GHG standards and save consumers money at the pump. Here are actions EPA should take to help pave the way for a high-octane future.

• Approve an alternative certification fuel with 25 to 30 percent ethanol and a minimum octane of 98 to 100 RON so automakers can begin testing future engines on a high-octane blend.

• Establish a minimum octane performance standard for fuel in the range of 98 to 100 RON. This will foster a marketplace that spurs competition and innovation to produce low-cost, high-octane fuels.

• Restore credits to automakers for the manufacture of flexible fuel vehicles and consider a new incentive for future engines designed to achieve optimal efficiency on high-octane fuels.

• Correct the outdated MOVES2014 model used in calculating the tailpipe and evaporative emissions of ethanol. READ MORE

At 13 years old, the RFS is still vital policy (Biodiesel Magazine)

Ethanol Industry Still Waiting For Year Round Allowance Of Sales Of E15 (WNAX)

Illinois, Nebraska Farm Bureau members meet with EPA (Farm Week Now)

Summer Restriction on E15 Sales Ends Sunday (Energy.AgWired.com)

Renewable Fuel And Farm Groups Ask President For Year Round Use Of E15 (WNAX)

ETHANOL, FARM GROUPS SEND E15 LETTER TO TRUMP (Brownfield Ag News)

‘Unnecessary’ and ‘Ridiculous’ Summertime Restriction on E15 Ends Sunday (Renewable Fuels Association)

House members advocate for strong RFS, year-round E15 sales (Ethanol Producer Magazine)

Excerpt from Ethanol Producer Magazine: Within the letter, the House members ask the agency to increase proposed renewable volume obligation (RVOs) for biomass-based diesel under the Renewable Fuel Standard and address the 48 retroactive small refinery hardship waivers the EPA approved for compliance years 2016 and 2017. Those 48 waivers effectively eliminated demand for 2.25 billion gallons of biofuel.

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“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,” the House members continued in the letter. “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.”

In addition to Noem and Peterson, the letter is signed by Reps. Dave Loebsack, D-Iowa; Rodney Davis, R-Ill.; Steve King, R-Iowa; Cheri Bustos, D-Ill.; Mark Pocan, D-Wisc.; Rod Blum, R-Iowa; Jeff Fortenberry, R-Neb.; Adrian Smith, R-Neb.; Darin LaHood, R-Ill.; Sam Graves, R-Mo.; Roger Marshall, R-Kan.; Tim Walz, D-Minn.; Ron Estes, R-Kan.; Don Bacon, R-Neb.; Richard M. Nolan, D-Minn.; Tom Emmer, R-Minn.; Mike Bost, R-Ill.; David Young, R-Iowa; Kevin Yoder, R-Kan.; Marcy Kaptur, D-Ohio; Andre Carson, D-Ind.; and Emanuel Cleaver II, D-Mo. READ MORE

Tags

EPA (Environmental Protection Agency) E15 E15 pumps Reid vapor pressure (RVP) one pound waiver Renewable Fuel Standard (RFS and RFS2) Regulations-Federal waiver renewable volume obligation (RVO) Litigation-Federal import/export RINs (Renewable Identification Numbers) life cycle analysis (LCA) cellulosic biofuel Cellulosic ethanol pathways Corporate Average Fuel Economy (CAFE) standards High Octane Fuel (HOF) octane price/value E30 E30 certification fuel E25 98 octane 100 octane flex-fuel vehicles (FFV) F Factor R Factor MOVES (motor vehicle emissions simulator) modeling system MOVES2014 White House Engine Development High Octane Vehicles (HOV) ethanol/bioethanol biodiesel Illinois Nebraska small refinery exemption (SRE)

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