Ethanol Investor
SAMPLE COMMENT LETTER on the Environmental Protection Agency’s (EPA) Request
for Comment on proposed Renewable Volume Obligations (RVOs) under the Renewable Fuel
Standard (RFS) for 2014-2016.
Below is a sample letter that you can use as guidance when formatting your written comments on
EPA’s Request for Comment on a proposed reduction in the RVO volumes.
This letter is a formatting sample that you can use to offer your support of the RFS and increased
RVO numbers.
The deadline to submit a comment is July 27, 2015.
Docket ID No. EPA-HQ-OAR-2015-0111
Air and Radiation Docket and Information Center
U.S. Environmental Protection Agency
Mailcode: 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460
To Whom It May Concern:
As an investor in XX local ethanol plant, I am writing you with deep concern regarding the
recent proposed rule for the 2014-2016 Renewable Volume Obligations (RVOs) as required as
part of the Renewable Fuel Standard (RFS).
The impact that the RFS has had on ethanol plants and production cannot be overstated. Since its
original enactment in 2005, I have witnessed firsthand the positive impact it has had on my local
economy and how it stimulates investment from domestic and international sources.
I am proud to invest in technologies that further America’s national and energy security goals.
Furthermore, I have made a substantial investment in the production of renewable fuels to further
drive innovation and help make next generation fuels, such as cellulosic ethanol from agriculture
waste, a reality. The renewable fuel production at my plant saves consumers money at the pump,
reduces our dangerous dependence on foreign oil and improves the quality of the air we all
breathe, all while creating many good paying jobs in my community that cannot be outsourced.
My investments have helped my local community (XX town) grow and thrive, showing the
nation and the world that rural America is booming and a leading area of innovation and
investment in future energy technologies.
Drastic cuts, such as those that EPA proposed, will have a devastating impact on agriculture and
our rural economies, as well as investments in ethanol plants throughout the nation. By taking a
step backward, you are sending a signal that the government no longer supports the production of
biofuels. This uncertainty, coupled with a dramatic cut in what should be produced, puts the
Ethanol Investor
future of investment, growth and innovation of renewable fuels at risk. I know, with such
uncertainty surrounding the RFS, I will likely scale back, if not completely withdraw, my
investments to prevent future losses.
The ramifications for the industry and for the towns and communities that count on these
facilities to generate economic activity would be widespread and very damaging. When there is
uncertainty and increased risk, investments by nature dry up quickly, causing the renewable fuels
industry to fall well short of its potential.
Furthermore, if EPA and the government turn their backs on the production of current
conventional biofuels, it will have a devastating effect on the full-scale commercialization of
next generation biofuels, such as cellulosic biofuel from agricultural waste. The biofuels industry
has just begun the commercialized production of next generation of biofuels. Now would be the
worst possible time to take a step backward.
As an investor that works closely with XX plant(s), I know the statutory requirements can be met
through a combination of gasoline consumption in the form of E10, increased use of higher
ethanol blends such as E15 and E85, carry-over RINs and increased biodiesel use. There is no
need for EPA to move backward with its proposed volumes for 2015 and 2016.
When the RFS was established, it always envisioned ethanol blends above 10 percent – even
with a projected increase in gasoline consumption—but oil companies are doing everything they
can to maintain their stranglehold on the nation’s fuel supply.
With this flawed proposal, EPA is fundamentally changing how the RFS works by putting the
burden of fuel distribution on biofuel producers rather than branded oil, which controls more
than 50 percent of the convenience stores in this country through branding agreements and
ownership.
The bottom line is that this proposal will have a devastating ripple effect on investment in
ethanol plants, their production and the jobs they support, as well as the surrounding
communities. With less money, there is a smaller tax base – our schools, hospital and local
municipal services will suffer. During a time of economic uncertainty we need to capitalize on
opportunities, such as biofuel production, to spur investment and innovation that will keep
America and our rural economy strong.
As you move forward in developing a final rule, I hope you will consider the fallout that a rule
such as the one proposed would have on the investors and workers who count on their jobs at
ethanol production facilities around the country. I would also ask that you return the RFS to a
program based on supply of renewable fuel and ambitious goals to reduce our dangerous
dependence on foreign oil and not let the program be held captive by the oil industry and its
unwillingness to allow higher ethanol blends into the marketplace.
Sincerely,
Ethanol Investor
Name and location