Yesterday, NACS submitted its comments regarding the Environmental Protection Agency’s (EPA’s) proposed 2018 renewable volume obligations (RVOs). As NACS previously reported, EPA proposed to use its waiver authority to lower the levels for cellulosic biofuel, advanced biofuels, and conventional biofuels. Levels for biomass-based diesel generally remained steady.
A table showing EPA’s proposed RVOs and percentage standards for 2018 is below. The prior 2015, 2016, and 2017 final volumes and percentage standards are also listed for reference (the previously finalized volumes/percentages are shaded, with newly proposed volumes/percentages are not shaded).
| Volumes Used to Determine the Proposed Percentage Standards | |||||
| 2015 | 2016 | 2017 | 2018 | 2019 | |
| Cellulosic biofuel | 123 mill gal | 230 mill gal | 311 mill gal | 238 mill gal | n/a |
| Biomass-based diesel | 1.73 bill gal | 1.90 bill gal | 2.0 bill gal | 2.1 bill gal | 2.1 bill gal |
| Advanced biofuel | 2.88 bill gal | 3.61 bill gal | 4.28 bill gal | 4.24 bill gal | n/a |
| Total renewable fuels | 16.93 bill gal | 18.11 bill gal | 19.28 bill gal | 19.24 bill gal | n/a |
| Proposed Percentage Standards | ||||
| 2015 | 2016 | 2017 | 2018 | |
| Cellulosic biofuel | 0.069% | 0.128% | 0.173% | 0.131% |
| Biomass-based diesel | 1.49% | 1.59% | 1.67% | 1.74% |
| Advanced biofuel | 1.62% | 2.01% | 2.38% | 2.34% |
| Total renewable fuels | 9.52% | 10.10% | 10.70% | 10.62% |
EPA sought comments on a variety of issues, including general comments on the proposed RVOs, whether EPA should use its general waiver authority, and concerns regarding the Renewable Identification Number (“RIN”) market, among other topics.
In general, NACS told EPA “overall, NACS supports EPA’s proposed rule because it recognizes that without adjusting the congressionally mandated renewable volume obligations, the RFS could cause substantial upheaval in the retail fuels market.” In addition, NACS supports EPA’s proposed use of its cellulosic waiver authority and encourages EPA to also make use of its general waiver authority.
NACS did share its concerns regarding efforts on the part of the domestic biodiesel industry to limit the importation of biodiesel from non-domestic sources, explaining that these actions make it difficult to achieve the proposed renewable volume obligations. For that reason, NACS urged EPA to proceed with caution and consider the impact of those efforts on its proposed levels.
EPA’s public comment period ended yesterday. By statute, EPA must finalize the 2018 volumes by November 30.
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