(April 8, 2013) WASHINGTON — The Renewable Fuels Association (RFA) has submitted comments in response to the U.S. Environmental Protection Agency’s (EPA) notice of proposed rulemaking regarding 2013 Renewable Fuel Standard (RFS) required volumes.

RFA’s comments can be read in full here. The four key points of the comments are:

1. EPA should revise its proposed 2013 cellulosic biofuel standard to better correspond with current expectations of actual 2013 cellulosic biofuel production volumes.
2. EPA should partially reduce the 2013 advanced biofuel standard, as sugarcane ethanol imports are unlikely to be available in sufficient volumes to meet the requirement.
3. Because there are legal and economical options available for surmounting the “blend wall”, the E10 saturation point should not be a factor in EPA’s decision-making process for 2013 RVO levels.
4. EPA should propose 2014 RFS standards as expeditiously as possible and ensure the 2014 RVOs are established no later than Nov. 30, 2013.

Summarizing RFA’s comments, Bob Dinneen, President and CEO of the RFA said, “The RFS is a flexible program that is a proven success.  It is lowering this country’s dependence on foreign oil, creating American jobs, and stimulating investment in the next generation of biofuels.  To ensure the RFS continues to be implemented in the most effective way, we are calling on EPA to exercise its discretion to adjust the 2013 advanced biofuel standard. We do not believe the levels of sugarcane ethanol imports assumed by EPA are reasonable given current market conditions. Further, our comments request that EPA publish the 2014 proposed RFS standards as soon as possible so stakeholders can engage with the Agency to ensure the program is implemented as efficiently as possible next year.”