ABC Regulatory Alert Comment Period Begins for Renewable Fuel Standard (RFS) 2014 Targets: Time to Take Action!
Summary - What You Need To Know Now
Comments on EPA's 2014 renewable fuel targets are due by January 28, 2014.
As you know, EPA lowered its renewable fuel targets for 2014. Lower targets mean that refiners of fossil fuels need to buy less renewable fuel, meaning lower prices for biogas producers who convert biogas to vehicle fuel. That sends the wrong message to markets and investors and stands to make the road to biogas project investment even more difficult.
EPA is seeking comments on targets for advanced biofuels through January 28, 2014. ABC will be commenting in favor of increasing those targets. We ask that you lend your voice to ABC and send individual comments to EPA as well. Our FLRA team will be coordinating this important effort.
The EPA RFS Targets for 2014
As many of you are aware the EPA released its renewable fuel targets for 2014. For the first time since Congress passed the national biofuel mandate in 2007, it has lowered its targets.
The agency proposal would require that refiners blend 15.21 billion gallons of renewable fuels into petroleum-based gasoline and diesel next year. Of that, 13.01 billion gallons is to come from conventional ethanol and 2.2 billion gallons from "advanced biofuels" that do not use corn starch as an input. Under existing EPA rules, biogas from landfills, waste-water treatment and manure digesters qualifies as an "advancedbiofuels." Under a prior, but still pending EPA Notice of Proposed Rule Making (NOPR), biogas from anaerobic digesters processing plant base materials such as crop residue and municipal solid waste would also qualify as advanced biofuel under the RFS.
As part of the 2014 target, EPA is proposing that at least 1.28 billion gallons be biodiesel -- made from soybean oil, animal fats and used cooking grease. Seventeen million gallons must be cellulosic biofuelmade from other plant-based materials such as crop residue and municipal solid waste.
EPA is also seeking comment on ranges of targets. For overall renewable fuels, the agency has proposed a range from 15 billion to 15.52 billion gallons. For advanced biofuels, the range stretches between 2 billion and 2.51 billion gallons, and cellulosic biofuel is between 8 million and 30 million gallons. Under a Notice of Proposed Rule Making issued earlier this year but not yet finalized, biogas generated from landfills would qualify as a cellulosic fuel. Biogas from waste digesters would qualify as an advanced fuel.
The 2007 law which created the RFS2, the Energy Independence and Security Act, calls for 18.15 billion gallons of renewable fuels to be blended into petroleum-based gasoline and diesel next year. Of that, 14.4 billion gallons was set to be conventional ethanol and 3.75 billion gallons advanced biofuels.
2013 targets are 13.8 billion gallons for corn ethanol and 2.75 billion gallons for advanced biofuels, for an overall renewable fuels target of 16.55 billion gallons.
The Comment Period for the new regulations will close sixty (60) days from the official publication in the Federal Register which was November 29, 2013. Currently, the NOPR is available via the following link: https://www.federalregister.gov/articles/2013/11/29/2013-28155/2014-standards-for-the-renewable-fuel-standard-program The official sixty day comment period closes on January 28, 2014.
Implications for the Biogas Industry
Lowering the targets for advanced biofuels sends a message to the markets and investment community that growth of biogas as a biofuel is headed in the wrong direction. RFS mandates are an important driver for establishing biogas markets and substantiating the guaranteed demand that supports investment. We cannot afford the potential chilling effect EPA's lowered targets may have on investment in our industry.
ABC will prepare and submit written comments to EPA advocating for higher advanced biofuel targets.
What ABC Members Can Do
Get in touch with the FLRA. Let ABC know how this issue impacts you. What will it do to your business? What does or could it do to your project pipeline? We need to hear from you to make the most impact on your behalf.
What Your Company Can Do
Write a letter echoing and in support of ABC's comments to EPA. We'll give you the tools to do so.
After you've submitted comments, please share your submission with us. Knowing what, when and how you took action helps us advocate on your and the industry's behalf.
Also, if your company has further detailed analysis or views to share with the rest of the industry to advance our common understanding, please do so through the FLRA.
The Comment Period for the new regulations opened November 29, 2013 and closes January 28, 2014. The time to take action is now.
Please contact Amy Kessler (email@example.com)or Doug Ross (firstname.lastname@example.org) for more information about how you can get involved.
For your convenience, you may download:
President, Dynamic Change Group
Lobbyist for the American Biogas Council
American Biogas Council | 1211 Connecticut Ave NW, Suite 600, Washington, DC 20036-2701 | 202-640-6595 | email@example.com
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