API Comments to EPA on Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (July 11, 2016)
API appreciates the opportunity to comment on the proposed rulemaking for the 2017 Renewable Fuels Standard (RFS). As refiners and importers of transportation fuels, our member companies are obligated parties under the RFS program and subject to its requirements. The RFS mandate is unworkable, and API leads a chorus of diverse interests call on Congress to repeal it.
API's primary concern with the RFS is the ethanol blendwall. There are serious vehicle and infrastructure compatibility issues with ethanol blends above 10%. Gasoline demand increases projected at the inception of the RFS have not materialized, nor has the commercialization of cellulosic biofuels at the rate Congress envisioned. The statutory volumes set for the Energy Independence and Security Act of 2007 are unattainable and maintaining these volumes could result in fuel supply disruptions that damage our economy. Congress provided EPA with waiver authority and we are encouraged that EPA has again proposed to exercise its waiver authority to reduce the 2017 volumes, thereby avoiding the potential negative impacts on America's fuel supply and preventing harm to American consumers.
See letter and related materials below:
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Appendix A to the Comments of the American Petroleum Institute
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Appendix B to the Comments of the American Petroleum Institute
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Appendix C to the Comments of the American Petroleum Institute
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