Summary:
On Nov.15, 2013, the U.S. EPA released the proposed Renewable Volume Obligations (RVOs)
under the Renewable Fuels Standard (RFS) for 2014. These volumes represent the amount of
renewable fuel that must be blended into the nation’s transportation fuel supply.
The agency has proposed to significantly reduce the volumes Congress set by statute. EPA
proposes to reduce the total renewable fuel volume from 18.15 billion gallons to 15.21 billion
gallons. Within the total 15.21 billion gallons of renewable fuel, EPA has proposed to reduce the
volume of advanced biofuels (fuels which must be at least 50 percent improvement to gasoline
for greenhouse gas emissions) from 3.75 billion gallons to 2.2 billion. Within the advanced pool,
EPA has proposed 17 million gallons of cellulosic ethanol and 1.28 billion gallons of bio-based
diesel.
Together, these proposals have the effect of reducing the total amount of grain-based ethanol that
can be used to meet the standards from 14.4 billion gallons to 13.01 billion gallons. This is also a
reduction from last year’s total of 13.8 billion gallons for grain-based ethanol. EPA’s proposals
would leave room for the possibility of 263 million gallons of imported ethanol in the advanced
pool.
It is important to remember that this is just EPA’s proposal. It is being presented for public
comment for the 60 days after it is published in the Federal Register, and there is an opportunity
to change the agency’s mind. If we are to change these volumes and get them back to where they
should be, we must get substantive comments to the agency by the projected 60-day deadline
sometime in late January. Growth Energy will be filing extensive comments, but the Agency
must here from everyone associated with the biofuels industry – ethanol producers, farmers,
vendors and anyone along the value chain.
We have included some relevant background and information along with links to EPA’s
proposed rule and summary of the rule as well as directions on how to comment below. If you
have questions or need additional assistance, please contact Chris Bliley at Growth Energy.
Key Points:

Ethanol accounts for some 400,000 American jobs, saves consumers money at the pump
and reduces our dangerous dependence on foreign oil.

A drastic cut such as that proposed here will have a devastating impact on agriculture and
our rural economies. Some analysts have said it could decrease the price of corn, pushing
the price American farmers receive for their grain well below the cost of production.

These drastic cuts will almost certainly idle ethanol production and cause lost jobs in
many rural areas of the country – all to benefit some of the world’s largest oil companies.
ActiveUS 118041295v.2

EPA has proposed the reductions because of concern about the so-called “blend wall” –
the perceived inability to blend additional biofuels above 10 percent of our gasoline
supply. But that is not a permissible consideration under the statute. Barring evidence
there that is inadequate supply of renewable fuel (which there is not) or evidence that the
statutory levels would cause severe economic harm (which they would not), the agency
cannot arbitrarily cut these volumes.

When the RFS was established, it always envisioned ethanol blends above 10 percent –
even with decreasing gasoline consumption, but oil companies are doing everything they
can to maintain their stranglehold on the nation’s fuel supply.

These drastic cuts will also prohibit the development of next generation biofuels
including cellulosic ethanol – jeopardizing billions of dollars that have already been
invested for future biofuel development.

With this flawed proposal, EPA is fundamentally changing how the RFS works by
putting the burden of fuel distribution on biofuel producers rather than the oil refiners and
integrated marketers who control 50 percent of the convenience stores in this country.

A requirement of 14.4 billion gallons of ethanol can easily be met – 13.3 billion gallons
can be consumed as E10 leaving just 1.1 billion gallons which can be met with increased
E85, E15, carry-over RINs or increased amounts of biodiesel.

Ethanol consistently trades around 70 cents cheaper than gasoline. By cutting the
volumes of ethanol and other biofuels, EPA is continuing high prices at the pump for
American consumers – some estimate an increase between $6.8 and $11.3 billion for
2014.

If these volumes are not increased, it will simply continue our dangerous dependence on
foreign oil and ensure that dirty fossil fuels continue to pollute our environment.

With these cuts, our nation will not see the dramatic decrease in greenhouse gas
emissions assumed under the RFS – with full implementation, the RFS would reduce
GHG emissions by 138 million metric tons, the equivalent of taking 27 million cars off
the road.
Links to EPA Documents and Directions for Submitting Comments:
Comments may be submitted online, by email, by mail, or by hand delivery. Detailed directions
on how to submit comments are set forth on pages 2 and 3 of EPA’s proposed rule. We have
found the easiest way is to send directly by email to: a-and-r-docket@epa.gov with the subject
line: Docket ID: EPA-HQ-OAR-2013-0479
ActiveUS 118041295v.2
To view EPA’s proposed rule, you may click here:
http://www.epa.gov/otaq/fuels/renewablefuels/documents/rfs-2014-standards-nprm-11-15-13.pdf
To view EPA’s summary of the proposed rule, you may click here:
http://www.epa.gov/otaq/fuels/renewablefuels/documents/420f13048.pdf
ActiveUS 118041295v.2