Letter to EPA: Don't change RFS point of obligation

By Ann Bailey | December 01, 2016

 Several associations sent a letter this week to Gina McCarthy, EPA administrator, expressing their unified support for keeping the renewable fuel standard (RFS) program’s point of obligation unchanged.

The associations, made up members of the bioenergy and energy industries, said in the letter, that while they each have unique, and often conflicting, positions regarding the broader RFS program, they are one in their opposition to move the point of origin for RFS compliance.  The letter was signed by the Advanced Biofuels Association, American Petroleum Institute, Growth Energy, Association for Convenience & Fuel Retailing, NATSO, Petroleum Marketers Association of America, Renewable Fuels Association and Society of Independent Gasoline Marketers of America.

“Each of the undersigned associations strongly supports the Environmental Protection Agency’s proposed denial of petitions for a rulemaking to change the point of obligation under the RFS. There is no sound public policy rationale for moving the point of obligation and further, such a change would add complexity and uncertainty to the current RFS program,” the letter said. “We urge EPA to finalize its conclusion and deny the petitions to move the point of obligation,” said the letter representing the eight organizations.

 Growth Energy CEO Energy Skor reiterated her association’s support of the current RFS point of obligation in a statement released after the letter to the EPA was sent.

 “The point of obligation, as outlined under the RFS, is doing exactly what it is designed to do, incentivizing marketers to blend additional biofuels and encouraging the availability of higher-level ethanol blends to retailers who wish to sell them,’ Skor said. “The bottom line is that the current point of obligation encourages consumer choice and cost savings at the pump, and any change would undermine the continued success of the RFS and reward those parties who have refused to comply with the intent of the law.”

The Advanced Biofuels Association said in a statement it also strongly supports EPA’s recent published proposed rejection of the waiver request to move the point of obligation.

 “For us it is a Trojan horse intended to undercut and punish those companies who made investments to be able to blend the mandated fuels under the Renewable Fuels Standard,” said Michael McAdams, ABFA president. “It would create more uncertainty, be harder to enforce and discourage and reduce levels of current blending. As for the group of so called “savvy” business guys, sometimes being too cute by half comes at a price. Time to make investments for the future, rather than simply try and escape your commitment to blend renewable sustainable fuels.”