| EPA ‘Well-Justified’ to Maintain 15  Billion Conventional Biofuel RVO in 2018 RFS, But Cellulosic Ethanol  Target Needs Increase, RFA Tells EPA By
 
 Emily Druckman
 
 August 1, 2017 at 8:20 am
 
 
 WASHINGTON – In  testimony  delivered at a public hearing today in Washington, D.C., Renewable  Fuels Association (RFA) President and CEO Bob Dinneen thanked the  Environmental Protection Agency for proposing to maintain the 15 billion  gallon requirement for conventional renewable fuels in its 2018  Renewable Fuel Standard (RFS) rule, but urged the agency to increase its  proposed cellulosic ethanol requirement to reflect growing bolt-on  technologies at existing ethanol plants.
 
 EPA’s recently released 2018 RFS proposal calls on refiners to blend  15 billion gallons of conventional renewable fuels like corn ethanol in  2018, adhering to the statutory requirement and unchanged from the final  2017 renewable volume obligation (RVO) rule.
 
 “We believe EPA is well-justified in that decision, given the  overwhelming evidence that more than sufficient D6 RINs [conventional  ethanol renewable identification numbers] will be available for  compliance this year and next,” Dinneen testified.
 
 However, EPA is proposing to lower the cellulosic ethanol requirement  to 238 million gallons in its 2018 rule.  “We understand the agency’s  dilemma in establishing an appropriate RVO for cellulosic ethanol, but  we truly believe the agency has erred on the side of pessimism with  regard to the potential for significant growth in cellulosic ethanol  commercialization,” Dinneen told EPA. “We know that many plants are in  the process of adding bolt-on fiber conversion technology to their  existing facilities that could dramatically increase cellulosic ethanol  production next year, and we intend to provide you with updated  projections during the comment period.”
 
 In EPA’s proposal, the agency noted that it will initiate a separate  re-set rule, since a reduction in both the cellulosic ethanol and  advanced biofuel requirements have triggered this authority. “We respect  the agency’s obligation to reset the advanced and cellulosic biofuel  targets to provide greater long term stability and certainty in these  markets,” Dinneen testified. “But we caution the agency that reset does  not mean repeal, and the agency must be faithful to the spirit and  intent of the RFS, which is to maximize the nation’s use of these fuels,  to drive marketplace innovation and investment in these new  technologies, and to make the U.S. more energy diverse and lower carbon  emissions from transportation fuels.  Congress entrusted EPA with the  ability to reset the RFS, not to gut the RFS,” he told EPA.”
 
 Dinneen also told EPA about continued concerns with RIN market  manipulation and suggested EPA continue to allow imported biofuels to  help comply with the RFS. “The RFS is not the platform to address trade  concerns,” he testified.
 
 “The RFS has been an incredible success story – lowering consumer  gasoline costs, creating jobs, reducing carbon, stimulating investment  in new technologies, providing energy and economic security, and  assuring a more sustainable energy future,” Dinneen said. A strong RFS  will continue to help drive investment and ensure the future growth of  ethanol, the cleanest, lowest cost and highest source of octane on the  planet, he added.
 
 Dinneen’s testimony, as prepared for delivery, is  here.
 
 ethanolrfa.org
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