IER Comments on EPA's Flawed Biofuel Mandate

Yesterday, the Institute for Energy Research (IER) submitted a public comment on the Environmental Protection Agency’s (EPA) proposed Renewable Fuel Standard (RFS) Program for 2014. IER commends EPA for proposing to reduce the total renewable fuel mandate for this year, but explains that EPA does not go far enough. Furthermore, EPA has once again proposed an unrealistic cellulosic biofuel mandate. As IER explains:

EPA’s reduction from 16.55 billion gallons to 15.21 billion gallons as the total ethanol mandate for 2014 is a good first step and well within EPA’s statutory authority. But EPA should go further in its reduction of the total renewable fuel mandate.

EPA has the ability to reduce the RFS if severe harm would occur. We believe that the severe harm has already occurred because the RFS drives up food and fuel costs and because it can harm engines—especially small engines.

While EPA took a good step in proposing to reduce the overall mandate, they took a big step back by proposing a large increase in the cellulosic ethanol mandate. As we explain in the comment:

EPA’s method of analysis has resulted in extremely inaccurate predictions for the past four years. The Proposed Rule for 2014 mandates an amount of cellulosic biofuel that, once again, likely will not exist by the end of the year. EPA should set the mandated level of cellulosic biofuel at 422,000 gallons for 2014 so as to reflect the most recent proven capabilities of the domestic cellulosic biofuel industry. Furthermore, EPA should reduce further both the overall renewable mandate and the advanced ethanol mandate.

EPA has issued wildly inaccurate cellulosic biofuel projections for the last four years. In fact, the closest EPA has come to accurately projecting cellulosic biofuel volumes was 2010, the year in which EPA mandated the lowest volumes.


The D.C. Circuit Court ruled that EPA’s cellulosic projections must not be “aspirational,” but instead based on a “neutral methodology.” It is difficult to see how EPA’s proposal to nearly triple the 2014 mandate to 17 million gallons—when just more than 422,000 gallons of cellulosic biofuel were produced last year—reflects the reality on which EPA is legally obligated to base its projections.

To read the full IER comment, click here.

IER Policy Associate Alex Fitzsimmons authored this post.


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