Advocacy recently submitted comments on EPA’s May 2009 proposed rule concerning the Renewable Fuel Standard Program. The rule under consideration would require specified types and amounts of renewable fuels to be blended into the nation’s gasoline and diesel fuel. It would require ever-increasing amounts of renewable fuels such as ethanol and cellulose-based fuel to be added to U.S. petroleum stocks over the coming years. Refiners would have to either blend the renewable fuels into their products or buy renewable fuel credits from a national credit exchange.
In a comment letter filed on September 25, Advocacy conveyed the concerns of small business fuel refiners about the program. Small refiners are concerned that (1) the fuel standard is not technically feasible because many of the mandated renewable fuels are not currently commercially available, and (2) the price of fuel credits may be exorbitantly high or the credits themselves may not be available. Advocacy recommended that EPA either delay the implementation schedule for small refiners until these problems can be solved, or implement it in phases to allow time for these problems to be adequately addressed. And fyi, Advocacy’s website contains a fact sheet summarizing the letter’s main points.
—Keith Holman, Assistant Chief Counsel