Petroleum association warns EPA on electrifying RFS, asks agency to boost advanced biofuel volumes

Patrick Kelly, the senior director of fuels and vehicle policy with American Fuel and Petrochemical Manufacturers, testified Jan. 10 during the U.S. EPA’s public hearing on the proposed Renewable Fuel Standard set proposal covering years 2023-’25.

Kelly’s prepared comments are summarized below and linked in their entirety here.

AFPM supports reducing the carbon impact of transportation fuels, and the refining sector has made significant investments to reduce carbon emissions.

Congress directed EPA to focus the RFS on second-generation, lower-carbon biofuels after 2022. EPA’s proposal will stifle advanced biofuels, promote first-generation biofuels beyond the market’s ability to absorb them and shift overall RFS growth away from liquid biofuels and into the power electricity sector. This is completely contrary to how congress envisioned EPA’s handling of the program.

According to AFPM, EPA should revise its proposal to reflect the following:

The RFS implied conventional biofuel mandate should be based on a realistic projection of market consumption, below 15 billion gallons. Continually relying on advanced biofuels to meet a portion of the implied mandate inflates the cost of every D6 RIN, imposing unnecessary costs without corresponding carbon-emission reductions.

The total advanced biofuel volume should be based on a reasonable projection of annual consumption, which EPA has undercounted. Refiners have made large investments in renewable diesel and EPA’s proposal unhelpfully caps refiners’ ability to utilize the fuel to satisfy RFS obligations and reduce overall carbon emissions from the transportation sector.

The focus of RFS should remain on liquid biofuels. eRINs will discourage investment in the biofuel sector and inappropriately charge refiners and American drivers with the cost of reducing power-sector emissions. Making automakers RIN generators is a clear attempt to siphon capital away from liquid biofuels to electric vehicles.

Kelly’s full remarks, as prepared, are available here.