RFS Comments Continue

OMAHA (DTN) -- Just five days remain in the EPA's public comment period on the latest proposed Renewable Fuel Standard volumes, and a number of agriculture, ethanol and other interests have filed comments on the proposal.

The proposed 2017 Renewable Fuel Standard volumes increase mandate requirements for blenders compared to the 2016 numbers across all biofuels. Ethanol supporters, however, are pushing for EPA to set volumes as called for in the original 2007 law.

EPA proposed a 2017 total RFS volume of 18.8 billion gallons. That would include 4 billion gallons of advanced biofuels, which is comprised of 312 million gallons of cellulosic biofuels, 2 billion gallons of biodiesel and 1.68 billion of other advanced biofuels. The rest of the RFS volume -- 14.8 billion gallons -- would be covered largely with corn-based ethanol.

Part of the problem of meeting the RFS requirements under the law is the inability of the cellulosic industry to take off and produce the necessary volumes. This is an issue EPA grapples with every year. Under the RFS law, refiners are mandated to blend in 5.5 billion gallons of cellulosic ethanol in 2017, but there are only a handful of viably commercial cellulosic plants operating in the country.

Under the law, the total RFS for 2017 should be 24 billion gallons, which would include that 5.5 billion gallons of cellulosic ethanol. The volume of corn-based ethanol would be 15 billion gallons. Other advanced biofuels and biodiesel would account for 4.5 billion gallons.

The National Corn Growers Association has filed lists of mass public comments collected, including more than 10,000 commenters listed on Excel spreadsheets and posted to regulations.gov in the past week.

In all, there has been more than 6,000 total comments posted to the website, including those collected during some mass commenting campaigns. The vast majority of comments posted are anonymous in nature, ahead of the July 11 deadline.

"I am writing in response to your proposal to reduce the use of ethanol in the Renewable Fuel Standard," NCGA commenters were asked to acknowledge. "Biofuels provide a clean, renewable alternative to oil, allowing us to decarbonize transportation fuels, reducing the need for more drilling and fracking that pollutes our water, air and pristine habitats. On average, corn ethanol reduces CO2 emissions by 34% and advanced biofuels can reduce emissions by 100% or more over gasoline. Globally, ethanol has reduced greenhouse gas emissions by 110 million metric tons -- the equivalent of taking more than 20 million vehicles off the road..."

Among comments posted were those by South Dakota Gov. Dennis Daugaard, who wrote in a letter on the proposal that the RFS volumes affect many of his constituents.

"I appreciate the Environmental Protection Agency's effort to release the proposed renewable volume obligation this year in a timely manner," Daugaard wrote. "It is important the EPA continue to commit to releasing these proposals on a consistent and timely basis in order to provide the renewable fuels industry with the information they need to comply with this regulation.

"However, I am disappointed to see once again, the agency's proposed standards fall short of the volume levels Congress felt were appropriate when the law was enacted. Establishing low volume levels, particularly for conventional biofuel, hurts both the renewable fuels industry and South Dakota's economy which is largely impacted by the agriculture industry."

Kevin Mobley, a board member and shareholder of East Kansas Agri-Energy, wrote in public comments that his company is financially stable, but federal RFS policy will continue to be an important factor. Mobley also stated he believes the EPA proposal violates the law.

"Due to favorable market timing, a high-performing plant and workforce and a healthy ethanol market, our company has been financially successful. As a result, we increased our capital investment in producing renewable fuel for America based on the belief that market conditions will be favorable. The primary reason we would stop investment or divest is the lack of a long-term, stable energy policy that ensures a healthy business environment for ethanol producers."

The 25X'25 Alliance said in written comments that changing the RFS will have economic effects. The group pushing for 25% of U.S. energy consumption to be renewable by 2025, said the RFS has created more than 357,000 jobs and resulted in nearly $24 billion in wages in the ethanol sector.

"While the proposed 2017 RVOs do increase the overall volume of renewable fuels beyond what was required in 2016, the rate of growth threatens the economic stability and resiliency of rural communities," the 25X'25 group wrote. "The levels proposed by EPA will have an impact on farm and rural economies by keeping down the price American farmers receive for some of their commodities to below the cost of production."

Some agriculture segments continue to be concerned that expanding the use of biofuels will hurt some producers.

The Southeastern Meat Association based in Florida represents meat and poultry interests. The group's executive director, Anna Ondick, wrote in comments that there are concerns about controlling transportation and other costs. She said the RFS is harmful to those on the distribution side of the meat and poultry industry.

"Fuel blended with ethanol has less energy content than regular gasoline, causing lower fuel economy and increased fuel costs for consumers," Ondick said.

File or read public comments on the proposed volumes here: http://bit.ly/…

Todd Neeley can be reached at todd.neeley@dtn.com

Follow him on Twitter @toddneeleyDTN

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