NCGA submits comments to EPA on renewable fuels

Higher renewable fuel volumes over the next three years would go a long way in improving energy security, lowering gas prices and reducing greenhouse gas emissions, according to recent comments the National Corn Growers Association submitted to the U.S. Environmental Protection Agency.

The Renewable Fuel Standard, or RFS, requires that U.S. transportation fuel contain a minimum volume of renewable fuel each year. NCGA’s comments were in response to EPA’s proposed volume requirements for 2023, 2024 and 2025.

“NCGA supports EPA’s proposal of annual increases in volumes, including an implied conventional biofuel volume of 15.25 billion gallons, and recognition that ethanol plays a critical role in cutting GHG emissions and our energy security,” said Tom Haag, NCGA president. “With continued pressure on energy security and costs, and the need to accelerate GHG emission reductions, however, biofuels can contribute even more. We ask EPA to continue working with us on complementary policies to advance higher ethanol blends, enabling ethanol to do more to cut emissions and costs.”

NCGA also noted that renewable fuel adds more than 20 billion gallons to the nation’s fuel supply annually, lowering consumer costs, creating rural jobs and reducing greenhouse gas emissions by more than 1 billion metric tons since the RFS was enacted.

As producers of the primary feedstock for low carbon ethanol, corn farmers contribute to the success of the RFS through higher corn yields and enhanced sustainability. Haag noted that by producing more corn with less land and fewer resources, famers cut the carbon intensity of ethanol while meeting food, feed, export and fuel needs.

NCGA also urged EPA to adopt the U.S. Department of Energy’s Argonne National Lab GREET model for lifecycle GHG assessment.
“EPA acknowledges that its 2010 modeling framework is old and requires updating,” Haag said. “Yet instead of adopting the federal government’s most robust and updated analysis, EPA uses outdated estimates in the proposal while continuing modeling reviews.”
Additionally, NCGA strongly urged EPA to separate the proposal for renewable electricity, or eRINs, from the volume proposal, allowing additional time for consideration because the proposal is inconsistent with the way the RFS functions for other renewable fuels.

NCGA members also weighed in directly with EPA on the proposal, with 2,164 farmers submitting individual comments. With the RFS comment period now closed, EPA faces a June deadline to issue a final volume rule.