Both the National Corn Growers Association and the Renewable Fuels Association have submitted comments to the Environmental Protection Agency in support of altering current biofuels production levels as stipulated in the Renewable Fuels Standard to better reflect market conditions.
Comments regarding the RFS volume levels are required under section 211(o) of the Clean Air Act.
Lower cellulosic requirement
RFA called for revising the proposed 2013 cellulosic biofuel standard to correspond with current expectations of actual 2013 production volumes. The group said while the industry continues to make significant advances towards commercial production on a large scale, cellulosic capacity is still below the required levels of the RFS.
The original timeframe and volume goals for cellulosic production included 500 million gallons by 2012, 1 billion gallons for 2013 and 16 billion gallons by 2022. However, by the end of last year, the Energy Information Administration reported that commercial-scale production of cellulosic biofuel generated only about 20,000 gallons.
Despite the big difference, RFA clarified that they are asking EPA to focus not on past production, rather offer forward-looking projections.
"Basing annual cellulosic biofuel requirements on past production levels would entirely ignore volumes of cellulosic biofuel production scheduled to come online during the year," RFA CEO Bob Dineen said in RFA comments. "Such an approach would discourage project developers from expeditiously completing construction and commissioning of new cellulosic biofuel facilities."
Partial reduction of advanced biofuels
The RFA and the National Corn Growers also called for a slight reduction in the 2013 advanced biofuel standard to account for lower sugarcane ethanol imports.
EPA is proposing a 2.75 billion ethanol equivalent gallons, with 1.92 billion eeg of biomass diesel and 150 million eeg of other fuels counting toward the requirement. While RFA says biomass diesel can meet the requirement, they say EPA's estimate of the contribution from other domestic advanced biofuels may be overly aggressive.