You may find yourself wondering exactly why the centerpiece of the renewable fuels industry’s response to the introduction of the Toomey-Feinstein “Corn Ethanol Mandate Elimination Act” in Congress today is a letter to President Obama about EPA action or the lack thereof.
In a nutshell, a variety of forces have joined forces against the RFS — poultry farmers, chain restaurant operators, cattle ranchers and oil companies. One of their primary arguments that “the RFS is broken” is based in EPA delays in getting 2014 and 2015 mandates into the marketplace.
As Advanced Ethanol Council executive director Brooke Coleman observed, “the opponents of the RFS have drawn a clear line between EPA and the need for reform, which is their code word for weakening the RFS. We want with this letter to make clear that we see that the problem can be resolved by the Administration using the authority they already have, and no legislation action is required.”
RFA CEO Bob Dinneen added, “The RFS has been a tremendous success and the resulting production of ethanol has many value added benefits. For instance, every $1.00 worth of feedstock that goes into the production of ethanol results in $1.83 in fuel and animal feed. Moreover, the RFS has created jobs, helped reduce the amount of oil the United States must import from foreign countries, significantly lowered greenhouse gas emissions and helped bolster rural communities.
“The sad irony of the Feinstein-Toomey effort is that, if passed, the sector most likely to be harmed would be the advanced and cellulosic technologies that are just now realizing commercial success. This bill would desolate investment in that nascent sector by crushing the foundation upon which those new technologies hope to build.”
Here follows the complete text:
The Honorable Barack Obama
United States of America
The White House
Washington, DC 20500
Dear Mr. President:
The Renewable Fuel Standard (RFS) is a critical policy reducing both our nation’s dependence on foreign oil and greenhouse gas emissions. Your recent bold actions on climate are proof of your leadership and commitment to prioritize climate issues. The U.S. Environmental Protection Agency’s (EPA) 2014 proposed RFS rule, however, threatened these gains and jeopardized additional investment in cellulosic and advanced fuels. Our industry implores you to take the same bold measures when it comes to biofuels and protect the integrity of the RFS. Now that EPA has outlined its timeline, we urge you to direct EPA to craft a new rule that supports growth for existing and new biofuels technologies and lives up to the original intent of the bipartisan law.
The RFS is working and has resulted in significant environmental gains. For example, the RFS is America’s only fully implemented policy that reduces greenhouse gas emissions and other pollutants. In a 2012 study, Argonne National Laboratory and the U.S. Department of Energy showed that the lifecycle CO2 emissions from traditional corn ethanol are 34% lower than gasoline. Cellulosic ethanol, an advanced biofuel made from switchgrass, corn stover or miscanthus, represents a reduction in lifecycle CO2 emissions of 88%, 96%, and 108%, respectively.
EPA’s proposed 2014 rule would have put your climate legacy at risk. If finalized, the rule would have increased the nation’s CO2 emissions by 21 million metric tons in 2014 alone, the equivalent of adding 5.5 new coal-fired power plants. Carrying the EPA’s proposed approach forward in future years would have triggered even larger increases in climate-altering emissions; by 2022, the cumulative emissions of greenhouse gases would have been nearly 1 billion metric tons higher than would occur if EPA set the RFS at statutory levels.1
1 Erickson, Brent; Carr, Matt; and Winters, Paul. Industrial Biotechnology. April 2014, 10(2): 57-63.
In the U.S. this year, three new commercial scale cellulosic ethanol plants are online and will produce the cleanest motor fuel in the world. In part, this achievement can be credited to the billions of dollars of government investment in advanced biofuels over the past six years. If implemented as designed, the RFS will continue to attract both domestic and foreign investment in cellulosic and advanced biofuels.
Unfortunately, EPA’s proposal has temporarily frozen investment in the next wave of cellulosic ethanol facilities here at home. Instead, the advanced biofuels industry sees dollars flowing to countries such as China and Brazil because of their strong, stable policies. For example, your recent agreement with China marks one of the largest steps in history toward combatting climate change at a global scale. China’s plan is to replace fossil fuels in its fuel supply with biofuels as part of a goal to increase non-fossil fuel use to 20 percent. This means that China is well positioned to invest in cellulosic ethanol technology and join Brazil as one of the world’s leaders.
When it was passed, the RFS offered policy stability with a gradual and predictable ramping up of renewable fuel targets year by year. It created the market certainty needed to foster private sector investment in these new innovative fuels. The 2014 proposed rule undermined Congress’s intent, changing the rules midstream, creating uncertainty in the market and making it virtually impossible for additional U.S. cellulosic ethanol facilities to secure financing and investor support.
If finalized, the 2014 proposed RFS rule would have utilized a flawed methodology for calculating the quantity of biofuels that the industry can produce. It would codify a limit on biofuels production based on the quantity that the oil industry brings to market, a 10 percent limit, rather than what our industry is able to produce. This approach is at odds with the goals of the RFS and jeopardizes the goal of 36 billion gallons of renewable fuel in 2022.
Your Administration has made commitments to the American people and the international community to pursue ambitious goals over the coming years to reduce our dependence on fossil fuels and combat climate change. We urge you to stay the course and allow the commonsense, bipartisan Renewable Fuel Standard to continue working as intended to create American green energy jobs and promote American innovation.