The Minnesota Corn Growers Association joined the National Corn Growers Association and other state organizations around the country in submitting comments to the Environmental Protection Agency (EPA) addressing concerns with the 2019 Renewable Volume Obligations under the Renewable Fuel Standard (RFS).
In his comments, MCGA President Kirby Hettver said the state’s corn growers were pleased to see conventional biofuels remain at 15 billion gallons in the 2019 RVO; however, EPA’s actions to continue to issue small refinery waivers leave farmers with no confidence those volumes will be met.
The RFS statute and regulations give EPA the tools to ensure that retroactive refinery exemptions do not reduce 2019 volume obligations set through this rulemaking. As noted in comments by MCGA, EPA failed to propose to use these tools, leaving the door open to waive the volume requirements after EPA finalizes them.
For example, Hettver stated the EPA should project an exempted small refinery volume and ensure that volume does not lower the 15 billion gallons proposed in the 2019 RVO. Currently, the RVO projects zero gallons of renewable fuels will be exempted in 2019, but the state’s farmers have no reason to think that will be the case based on past actions by the EPA.
Retroactive exemptions have been issued to 48 refineries for 2016 and 2017 obligations, resulting in a 2.25 billion ethanol-equivalent gallon reduction in the nation’s fuel supply. These lost gallons were never accounted for, rendering proposed volumes in 2019 meaningless, Hettver said.
In addition to the volume concerns, Hettver also states EPA has failed to address the lack of Reid Vapor Pressure (RVP) parity for ethanol bends greater than 10 percent, which is a significant regulatory barrier to ethanol consumption. While not part of the RFS, removing this RVP regulatory barrier would ease implementation of the RFS. RVP parity would lead to further expansion of E15 availability and provide a consistent product to consumers. Hettver urged the EPA to set a transparent timeline to remove this barrier.
The implications of these lost volumes and the continued efforts to undermine the RFS have significant effects on the farm economy. In his comments, Hettver stated the need for a strong RFS to support the nation’s growers, who are now in their fifth consecutive year of depressed income and commodity prices. A strong RFS supports a market-based solution for supporting the agriculture economy.
Click here to view the comments stated by MCGA to EPA.