The CEO of the Renewable Fuels Association (RFA) today sent a letter to the head of the Environmental Protection Agency challenging claims by the oil industry regarding the Renewable Fuel Standard (RFS).
In a letter sent to EPA earlier this week, the American Petroleum Institute (API) requested that EPA use October 2013 fuel consumption projections—instead of the most current projections—when setting the final 2014 RFS renewable volume obligations (RVOs). RFA president and CEO Bob Dinneen called the suggestion that outdated fuel consumption projections should be used to establish the RVOs “the highest form of hypocrisy and misdirection.”
“Common sense and the principles of good rulemaking dictate that the final RVOs should be based on the latest available fuel consumption projections from EIA,” wrote Dinneen in the letter to EPA Administrator Gina McCarthy. “Since the inception of the RFS2, EPA has always relied on the most recent EIA projections to set annual RVOs. API has never objected to this—until now.” Dinneen adds that API has repeatedly requested that EPA base its cellulosic biofuel RVO on the most current available production data.
Dinneen said API also misconstrues the fact that the RFS is fundamentally a volumetric standard, not a percentage-based requirement. “In the Energy Independence and Security Act of 2007, Congress set forth the specific volumes of renewable fuels that must be consumed annually. From these statutorily required volumes, as well as projected levels of gasoline and diesel consumption, EPA derives its annual percentage RVOs,” wrote Dinneen. “API obviously has the RVO-setting process backward, requesting that EPA start with an arbitrary renewable volume percentage and work in reverse to establish the commensurate volumetric requirements.”