The comment period for the U.S. EPA&rsquo;s rule revisions to the renewable fuel standard (RFS) have closed, with <a href="https://www.regulations.gov/docket?D=EPA-HQ-OAR-2016-0041" target="_blank">254 comments posted to regulations.gov</a> regarding the Renewables Enhancements and Growth Support Rule, dubbed REGS. &nbsp;
In its summary statement, EPA says REGS proposes &ldquo;to make numerous changes to promote the production of renewable fuels and clarify certain requirements under the RFS program. This action would propose to allow for feedstocks partially converted at a facility other than a renewable fuel production facility to be fully converted at a renewable fuel production facility into finished renewable fuel. These partially converted feedstocks are referred to as biointermediate feedstocks.
&ldquo;Further, this action would also propose to add new registration, recordkeeping, and reporting requirements for certain renewable fuel production facilities using carbon capture and storage (CCS) if the EPA were to allow CCS as a lifecycle GHG emissions reduction technology in the context of the RFS program.
&ldquo;Additionally, this action also proposes to require obligated parties to report a breakdown of their gasoline, diesel, and heating oil production; provide an additional RIN-generating pathway that is an extension of an existing pathway; and make numerous technical corrections. Finally, this action would implement fuel quality specifications for blends containing 16 to 83 volume percent ethanol. This action would provide substantial additional flexibility for ethanol flex fuel (EFF) producers that accommodate current market realities while continuing to ensure EFF quality is consistent with controlling pollution when used in flexible fuel vehicles.&rdquo;&nbsp;
In its comments about REGS, the Renewable Fuels Association said the proposal is not adequate. &ldquo;While well-intentioned, the REGS rule does not adequately address the key regulatory barriers that are significantly limiting growth in renewable fuel production and use,&rdquo; said RFA President and CEO Bob Dinneen in the comments. &ldquo;In fact, we are concerned some elements of the REGS proposal may actually serve to add complexity and create new barriers to renewable fuel market expansion, an effect that would be the opposite of the rule&rsquo;s stated purpose. While the proposal does resolve the ambiguity surrounding regulation of certain ethanol blends like E16-E50, it largely overlooks the actions required to truly support and promote an expanded role for renewable fuels in the marketplace.&rdquo;
Among actions EPA should take to reform existing fuel regulations, RFA recommends:
-Establishing regulatory parity in the volatility limits for all fuel blends containing more than 9 percent ethanol by volume.
-Streamlining and harmonizing survey programs intended to monitor and verify fuel quality and regulatory compliance.
-Simplifying the petition process for new certification fuels and eliminating unreasonable criteria for approval.
-Eliminating unnecessarily burdensome and costly requirements related to the fuel and fuel additive registration process/
-Leveling the playing field for all alternative fuel vehicles, including flexible fuel vehicles (FFV), under the fuel economy and light-duty vehicle greenhouse gas program.
-Rejecting the results of the a flawed fuel effects study and suspending further use or development of the MOVES2014 emissions model until a new emissions study based on appropriate test fuels is conducted.
-Updating the lifecycle greenhouse gas (GHG) analysis of corn ethanol conducted for RFS2.
The Urban Air Initiative, along with a coalition of supporters, focused several of its comments on the EPA&rsquo;s interpretation of the Clean Air act. &ldquo;We argue that the Clean Air Act does not forbid the use of midlevel gasoline-ethanol blends in conventional vehicles, and that EPA's interpretation to the contrary is unlawful.&rdquo; It also argued that under the Clean Air Act, &ldquo;EPA bears the burden of showing that ethanol increases emissions. By imposing that burden on the ethanol industry, EPA's interpretation of the sub-sim law unlawfully subverts the regulatory scheme designed by Congress. UAI asks that EPA correct its misinterpretation of the sub-sim law to recognize that mid-level ethanol blends may be legally used in all vehicles.&rdquo; As written, the REGS rule would create additional obstacles for the ethanol industry and fall short of the purported goal of expanding the market for ethanol, UAI said.
UAI&rsquo;s position was joined by a coalition of organizations including Energy Future Coalition, Clean Fuels Development Coalition, Glacial Lakes Energy, Siouxland Ethanol, ICM Inc., Nebraska Ethanol Board, National Farmers Union, South Dakota Farmers Union, Minnesota Farmers Union, Montana Farmers Union, North Dakota Farmers Union, and Wisconsin Farmers Union.
To view other comments or read the transcript of the Dec. 6 public hearing on the proposed rule, <a href="https://www.regulations.gov/docket?D=EPA-HQ-OAR-2016-0041" target="_blank">click here.</a>

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EPA's proposed revision to the RFS dubbed REGS for Renewable Enhancements and Growth Support Rule, is inadequate, says the RFA. The UAI focused several of its comments on the EPA's inadequate interpretation of the Clean Air Act. 

Ethanol advocates critical of EPA proposed RFS revisions in REGS

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