RFA Comments Support Addition of RFS Cellulosic Biofuel Pathways, Applaud Approach to RIN Generation

July 15, 2013

RFA Comments Support Addition of RFS Cellulosic Biofuel Pathways, Applaud Approach to RIN Generation

(July 15, 2013) WASHINGTON — The Renewable Fuels Association (RFA) voiced its support today for the Environmental Protection Agency’s (EPA) proposal to expand the number of qualified biofuel production pathways under the Renewable Fuel Standard (RFS2). In written comments to the EPA regarding RFS Pathways II and Technical Amendments to the RFS2 Standards, RFA backed the EPA’s efforts to add cellulosic fiber from the corn kernel to the list of qualifying cellulosic biofuel feedstocks, and the agency’s simplified approach to RIN generation for renewable fuels derived from cellulosic biomass.

“We applaud EPA for confirming that corn kernel fiber is ‘crop residue,’ and believe the Agency has proposed a sensible and straightforward approach to RIN generation for renewable fuels derived from cellulosic biomass feedstocks,” wrote RFA President and CEO Bob Dinneen. “Several technologies to convert corn kernel fiber into cellulosic ethanol have been developed in recent years, and a number of existing ethanol plants have already adopted these technologies or are poised to integrate them in the near future. The volumes of cellulosic ethanol produced from corn kernel fiber can meaningfully contribute to RFS2 cellulosic biofuel requirements in the near term.” The comments also included a scientific analysis from a noted animal nutritionist examining the potential impacts of reduced fiber DDGS on livestock and poultry markets.

RFA’s 28-page comments expressed support for most of the RFS2 technical amendments and new pathways proposed by EPA. For example, the RFA submission supports a proposal by EPA to provide an alternative approach to applying RVP volatility standards to commingled mixtures of E10 and approved gasoline additives, such as butanol. However, Dinneen noted, the conditions for applying the alternative RVP approach should be limited to whether blending an approved gasoline additive with E10 results in no net increase in RVP.

RFA’s full comments are available here.