At the end of last month, FreedomWorks Foundation’s Regulatory Action Center submitted comments to the Environmental Protection Agency (EPA) expressing disappointment with the agency’s proposed compliance rules for 2018 under the Renewable Fuel Standard (RFS) program.
FreedomWorks Foundation believes the proposed RFS levels for 2018 do not reflect economic reality. While encouraged that EPA is exercising some of its waiver authority regarding cellulosic biofuels, FreedomWorks Foundation believes EPA is mistaken in its attempt to keep the mandated level of conventional biofuels, or ethanol, in-line with the targets set in statute under the Energy Independence and Security Act (EISA) of 2007.
The economic reality of today does not reflect the projections of 2007, upon which RFS targets are based. As fully acknowledged by EPA, there is a threshold where ethanol levels begin to imperil the fuel supply, known as the “blend wall.” EPA’s proposed 2018 standards skirt this threshold, providing little flexibility in the case of further changes in economic conditions. FreedomWorks Foundation sees little need for EPA to attempt to comply with foolhardy goals set in 2007 considering the very realistic chance such standards will cross the ethanol blend wall.
Read the full comments here or in the attached document below.