In formal comments submitted in response to the US Environmental Protection Agency (EPA) annual proposed 2020 renewable volume obligations (RVO) rule, the National Biodiesel Board (NBB) calls for higher volumes for biomass-based diesel and "proper accounting" for small refinery exemptions.
The National Biodiesel Board (NBB) submitted comments on the Environmental Protection Agency’s (EPA) annual proposed Renewable Fuel Standard (RFS) rule outlining 2020 renewable volume obligations (RVO).
NBB argues that EPA must increase advanced biofuel volumes for 2020 and biomass-based diesel volumes for 2021 to accommodate domestic biodiesel and renewable diesel producers’ proven ability to increase output.
Furthermore, that the Agency must “properly account” for small refinery exemptions – which are actively rolling back biodiesel volumes – and the 500 million (US) gallons (≈ 1.89 billion litres) of biofuel unlawfully waived in 2016.
The RFS is intended to increase production and use of advanced biofuels such as biodiesel and renewable diesel. EPA’s proposal to flat-line both biomass-based diesel and advanced biofuels – combined with its small refinery exemption spree – will roll back growth of our industry, said Kurt Kovarik, NBB’s Vice President of Federal Affairs
Biodiesel demand destruction
According to NBB, EPA’s recent grant of 31 small refinery exemptions for 2018 destroyed demand for as much as 250 million gallons (≈ 946 million litres) of biodiesel and renewable diesel.
Following the decision, one of the largest US producers of biodiesel and renewable diesel closed three facilities, impacting more than 100 workers.
EPA’s small refinery exemptions are turning the RFS upside down and blocking our industry’s progress. By handing out waivers to everyone that asks, EPA is destroying demand for hundreds of millions of gallons of biodiesel and renewable diesel and forcing US producers to close up shop and lay off workers. EPA cannot continue to pretend it isn’t harming biodiesel producers, said Kovarik.
NBB is asking EPA to restore the lost volumes in the 2020 rule and adjust its RVO formula to include a reasonable estimate of future small refinery exemptions.
EPA must also restore 500 million gallons(≈ 1.89 billion litres) of biofuel demand that it unlawfully waived in 2016. The agency uses the same logic that the Court overturned in the 2016 case — demand-side constraints — to resist restoring the waived volumes. The agency must ensure the RFS volumes are made whole and that the renewable fuel industry can have confidence in the program’s volumes, ended Kurt Kovarik.