Renewable Fuels Association (RFA) President and CEO Bob Dinneen applauded a recent decision by the Environmental Protection Agency (EPA) to recalculate its ethanol export estimates for 2014. In a memorandum, which was placed on the RVO docket on July 24, EPA acknowledged that it made an error in determining the 2014 available supply of Renewable Identification Numbers (RINs), which are credits used to keep track of the amount of ethanol.
“Kudos to the EPA for recognizing this important error and reassessing the 2014 ethanol export data,” said Dinneen. “This is a critical issue because it affects the estimate of how many RINs generated in 2014 will remain available for compliance with biofuel obligations required by the Renewable Fuel Standard (RFS). It also has implications for estimates of RIN carryover stocks.”
The memo comes after RFA and member biofuel companies raised the issue in correspondence with the EPA in early June and again at a public hearing on June 25 on the RFS in which dozens of commenters took issue with the agency’s proposal to slash the renewable blending volume obligations (RVOs) for 2014–2016.
According to the memo, “… public commenters indicated that they believed it was an error to treat the reported amounts of undenatured ethanol as being part of the 2014 supply of RINs. Ethanol that is exported in undenatured form would not have generated RINs, and thus should not have been subtracted from the total number of RINs generated for fuel ethanol in 2014 for purposes of calculating the available supply of RINs for 2014 in the proposal. EPA intends to account for this…in the determination of the appropriate volume requirements in the final rulemaking.”
As a result of EPA’s error, the agency will likely revise the 2014 RVO. This revision could increase the blending obligation for renewable fuel from a proposed level of 13.25 billion gallons to more than 13.6 billion gallons.
“We applaud the EPA for responding to stakeholder feedback and committing to make the requisite change regarding exported ethanol in the final rulemaking,” said Dinneen. “However, as underscored in the comments we submitted to the EPA last week, we continue to urge the Agency to consider carryover RIN stocks in determinations of ‘available supply.’ We hope and trust that EPA will make other changes consistent with the facts on the ground—and the law—prior to issuing a final rule in November.”