RFS Was Never Contingent on Gas Consumption

The public comment period on the U.S. EPA’s contentious—and we think misguided—2014 proposed renewable volume obligation (RVO) volumes began nearly a month ago. Keeping up with the industry’s fiery reaction and the ensuing melee of newspaper editorials about the proposal has been absorbing for this self-proclaimed, biofuels-advocate journalist, and I, too, jumped into the fray a few weeks ago. 

IN early December, I posted a 550-word blog that echoed what so many of our readers were already saying about the EPA’s seemingly improper validation of its proposal. That is, the agency’s inclusion of the E10 blend wall as part of its rationale for suggesting an RVO deceleration. Aside from the fact that the EPA probably lacks the authority to backslide on the RFS on the basis of the oil industry’s blending reluctance, the spirit and intention of the RFS was never to create a national biofuels program that would be unable to grow during periods when gasoline consumption declined. “In 2007, when the current renewable fuels standard became law, policymakers and industry stakeholders knew, as they know now, that our nation’s vision for biofuels wouldn’t happen without a stepwise introduction of higher-level blends of biofuels into the nation’s transportation fuel supply,” I wrote in my blog. “Not at any time did law makers or representatives of any industry believe that 36 billion gallons of biofuels would, by 2022, make up just 10 percent of our nation’s total transportation fuel stream.”

The bottom line, I concluded, is that America’s biofuels plan was never supposed to be contingent on U.S. gasoline consumption rising. From an environmental perspective, it was, and still is, reckless for anyone to hope gasoline use would not decline with our rising fuel economy standards. If anything, I suggest, biofuels play an even more meaningful role when they have an opportunity to make up a relatively larger component of our overall motor fuels portfolio. Flat gasoline consumption is an opportunity, therefore, and the Obama administration should see it as such.     

Those are my thoughts. You can offer yours at www.FuelsAmerica.com on the organization’s easy-to-use portal for making comments that will be forwarded to the EPA.