Kansas Corn Farmers Tell EPA to Keep RFS Whole
he Kansas Corn Growers Association submitted comments to the docket for EPA’s supplemental proposal to the 2020 Renewable Volume Obligation (RVO) rulemaking. KCGA told EPA to hold true to President Trump’s commitment to follow the letter of the law and keep the Renewable Fuel Standard (RFS) whole. Many Kansas farmers submitted their own comments through the KCGA and National Corn Growers Association websites.
At issue is EPA’s proposal to account ethanol demand lost through EPA refinery exemptions going forward in the RFS. The recent expansion of RFS waivers has reduced RFS requirements by more than 4 billion gallons over three years. However, EPA’s proposal uses a formula that would return just half of the actual waived gallons to the 2020 RFS and doesn’t provide certainty for future years. EPA proposes to base its formula on the amount the Department of Energy (DOE) recommended in waivers, instead of the amount EPA actually waived. Because EPA consistently waived nearly double the gallons the DOE recommended, the proposal using DOE numbers to redistribute future waived gallons is half of what the President committed to in early October.
In the submitted comments, KCGA President Steve Rome, Hugoton said:
“KCGA appreciates the implied volume of 15 billion gallons for conventional renewable fuel and an increase in total volumes for 2020. However, the 85 retroactive RFS exemptions granted by EPA totaling more than 4 billion gallons of ethanol from 2016-2018 has rendered these totals virtually useless. Hence, given this administration’s tendency to grant nearly all waiver requests, KCGA has virtually no confidence that the volumes published for 2020 will be met.”