Eliminating the unnecessary regulatory barrier to year-round sales of E15 is among a dozen recommended reforms the Environmental Protection Agency (EPA) should immediately undertake to alleviate unnecessary regulatory burdens on the U.S. ethanol industry and American consumers, according to comments submitted on May 15 by the Renewable Fuels Association (RFA).
The comments responded to EPA’s request for input on burdensome, conflicting or unnecessary regulations that should be repealed or reformed, in accordance with President Trump’s Executive Order 13777.
“In recent years, our industry has invested billions of dollars in capacity expansions that would allow further increases in ethanol production and use. However, a number of burdensome EPA regulations are stifling growth in ethanol production and demand, inhibiting job creation, imposing unnecessary costs on both industry and consumers and preventing renewable fuels from reaching their full potential,” RFA explained in its comments.
“While there are a number of EPA regulations that need reforming, the most pressing is the agency-imposed restriction that denies consumers year-round access to E15,” said RFA President and CEO Bob Dinneen.
EPA could either apply the existing 1-psi Reid vapor pressure (RVP) volatility waiver for 10% ethanol to all fuel blends containing more than 9% ethanol by volume; or EPA could promulgate rules requiring a 1-psi reduction in the maximum allowable RVP of conventional gasoline blendstock during the summer ozone control season.
“Securing equal RVP treatment for all ethanol blends is our top priority this year,” said Dinneen. “Simply put, consumers are being denied access to a lower-cost, higher-octane fuel simply because of antiquated EPA regulations that offer absolutely no environmental benefit.”
Among other actions EPA should take to reform existing regulations and remove unnecessary burdens, RFA’s comments recommend:
- Streamlining survey programs intended to monitor and verify fuel quality and regulatory compliance, and consider eliminating costly surveys that offer little or no regulatory benefit.
- Reforming the petition process for new certification fuels (e.g., high-octane mid-level blends like E25 or E30) and eliminating unreasonable criteria for approval.
- Eliminating unnecessarily burdensome and costly requirements related to the registration process for new fuels and additives.
- Leveling the playing field for credit generation for all alternative fuel vehicles, including flexible fuel vehicles (FFV), under the 2017 – 2025 fuel economy and light-duty vehicle greenhouse gas program (CAFE/GHG).
- Reducing EPA’s workload and eliminating a costly administrative burden by revising the agency’s outdated lifecycle greenhouse gas (GHG) analysis of corn ethanol.
- Including the impact of fuel properties (e.g., octane rating) on fuel economy and emissions in analyses related to the Midterm Evaluation of 2022 – 2025 CAFE/GHG standards.
- Rejecting the results of the EPAct/V2/E-89 Fuel Effects Study and suspend further use or development of the MOVES2014 model until a new emissions study based on appropriate test fuels is conducted.
- Eliminating unnecessary regulatory barriers to cellulosic ethanol production from corn kernel fiber.
A full copy of RFA’s comments can be found here.