08/15/2011
NAFB News Service
The Renewable Fuels Association has submitted 16 pages of comments to the Environmental Protection Agency on its Renewable Fuel Standard proposed rulemaking for 2012. In its comments RFA addressed both the proposed levels of renewable fuel use for 2012 as offered by EPA and also reissued calls for EPA to address fundamental problems it created when crafting the RFS.
Three key areas of focus in RFA's comments included the cellulosic biofuel requirements of the 2012 RFS, the “small refiner” de facto waiver issued by EPA and the continued inclusion of indirect land use change penalties against corn-based ethanol despite reams of scientific data proving EPA’s data and modeling are out-of-date, to say the very least.
The Renewable Fuels Association strongly encourages EPA to re-evaluate and refine the indirect land use change analysis that was conducted for the RFS2 Final Rule - taking into account newly available studies, modeling results and data. The RFA has criticized EPA’s inclusion of so-called ILUC penalties and has pointed out that several new scientific analyses have been completed that better demonstrate to what extent - if any - such land use changes are occurring - and those factors that are responsible for such changes
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