Mail Call! Biofuels Write to EPA on Strategy

by Kelsey Tamborrino (Politico's Morning Energy) A coalition of Midwest biofuels associations sent a letter Thursday to EPA asking it to move administrative time and staff away from Renewable Fuel Standard exemptions and instead toward approvals for cellulosic ethanol. "The discrepancy between the way EPA is handling RFS exemptions and cellulosic ethanol pathway approvals tells you everything you need to know about how this EPA is treating the RFS," said Iowa Renewable Fuels Association Executive Director Monte Shaw in a statement. Read the letter.

- The Business Council for Sustainable Energy, a coalition of companies and trade associations, wrote to members of Congress on Thursday, asking that they reauthorize energy title programs in the farm bill, H.R. 2 (115). "It is essential that a healthy, robust bipartisan energy title continue as part of new comprehensive agriculture legislation," writes the group's president, Lisa Jacobson. The letter also lays out potential improvements to the programs. Read it here. READ MORE

Administrator Scott Pruitt
Environmental Protection Agency
1200 Pennsylvania Avenue, NW
Washington, DC 20460

During recent testimony before Congress you noted that under your leadership the EPA has approved
several dozen small refinery exemptions from the Renewable Fuel Standard (RFS). It is reported that
those exemptions destroyed the demand for well over one billion gallons of corn ethanol. The
exemptions also reduce the demand for cellulosic ethanol and other advanced biofuels.

At the same time, we hear from our members that requests for RFS pathway approvals are stalled at
EPA, preventing the production of millions of gallons of cellulosic ethanol and their related D3 RINs.
Dozens of plants are ready to produce and, in some cases, have been waiting months and months for
pathway approvals for proven and commercially successful cellulosic technologies.

Both the volume and expeditious manner in which your EPA has granted demand-destroying RFS
exemptions is unparalleled in the history of the EPA and the RFS program. If the same urgency could be
brought to bear on pathway approvals, the increase in cellulosic ethanol production could be
substantial.

In order to implement the letter and spirit of the law as was promised by President Trump, it is not
unreasonable for us to expect that the EPA would devote at least as much effort to process new RFS
pathway approvals as to grant highly-questionable, demand-destroying small refinery exemptions for
some of the largest oil companies in the world.

As such, we request that you review the EPA’s current staffing and workloads in order to prioritize new
RFS pathway applications. We suggest that the results to date clearly indicate that the EPA could shift
some personnel from working on RFS small refinery exemptions and redirect them to instead focus on
RIN-generating pathway approvals. Given the fact that the granting of dozens of RFS small refinery
exemptions during a timeframe when new pathway approvals are gathering dust is neither fair nor
balanced, it only seems reasonable to expedite this approval process immediately.

We appreciate you looking into this situation and right-sizing the staff working on both of these areas.
With the draft 2019 RVO rule surely near completion, it is important that D3 RIN generation not be
artificially limited in order to justify unnecessarily large cuts to the cellulosic ethanol RVO.