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Renewable Fuel Standard Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019

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May 6, 2025
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closed 3204d ago
American Soybean Association filings
5

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American Soybean Association filed 5 comments on this docket between Aug 21, 2017 and Oct 24, 2017. 162 other organizations filed here. The comment window closed 3204d ago.

What American Soybean Association filed (5)

Oct 24, 2017· Comment submitted by Ron Moore, President, American Soybean Association (ASA)· EPA-HQ-OAR-2017-0091-4653

Comments attached

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Oct 20, 2017· Mass comment campaign sponsored by the American Soybean Association (ASA). Sample attached (web)· EPA-HQ-OAR-2017-0091-4458

On behalf of the American Soybean Association, we want to provide our response to the notice on the Renewable Fuel Standard (RFS) Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019; Availability of Supplemental Information and Request for Further Comment (also referred to as a Notice of Data Availability or NODA) ASA urges EPA to withdraw this ill-conceived notice and more appropriately increase biomass-based diesel and advanced biofuels volumes in 2018-19 to reflect the real and proven potential of our farmers, biodiesel plants, and their rural communities. In comments provided to EPA in August in response to the proposed volumes, the soybean and biodiesel industry supported an increase in the volumes for biomass-based diesel to at least 2.5 billion gallons for 2019 and to increase total Advanced Biofuels volumes to 4.75 billion gallons in 2018. Soybean farmers are proud of the leading role we have played in establishing and developing the biodiesel industry. From the first investments made by the soybean industry, biodiesel has grown into a domestic market approaching 3 billion gallons. While biodiesel is now made from a diverse and growing volume of feedstocks, soybean oil remains the largest source of biodiesel feedstock. Biodiesel has expanded markets for farmers and livestock producers and created new jobs and economic growth, particularly in rural America. Biodiesel also provides additional economic, energy, and environmental benefits, such as increasing volumes of domestically produced, renewable energy while providing significant reductions in greenhouse gas emissions resulting in improved air quality. The biodiesel industry has provided these benefits without any significant disruption or adverse impacts to consumers. Our industry has always advocated for RFS volumes that are modest and achievable and we have met or exceeded the targets each and every year that the program has been in place. In July, EPA proposed Renewable Volume Obligations (RVOs) that would halt the biomass-based diesel industry's growth. The reductions contemplated in the NODA would have significant adverse impacts on the soybean and biodiesel industry. The proposed reductions in the NODA run counter to the text, structure, and purpose of the Renewable Fuel Standard as enacted in the Energy Independence and Security Act. None of the factors cited in the NODA justify EPA reducing biomass-based diesel volumes. There is neither an inadequate domestic supply of advanced biofuels nor a severe economic harm occurring as a result of the increased volumes being produced and consumed in the United States. There are no factors that support EPA's use of the General Waiver Authority. Likewise, there are no emergency circumstances causing a "severe feedstock shortage or other market disruption" that would justify use of the biomass-based diesel waiver authority. The supply of soybean oil - the most prevalent biodiesel feedstock - is increasing and soybean oil prices have been declining. The NODA also raises misplaced concerns with the tax credit and imports as reasons for reducing biomass-based diesel volumes. The expiration and uncertainty of the biodiesel tax credit will not prevent the biomass-based diesel industry from meeting the volume requirements. The industry has consistently met the volume requirements in the past even when the tax credit has not been in place. To the extent that there is any future change in conditions that impact the growing level of imports of biomass-based diesel into the United States, those volumes can be replaced by domestic production. Imports will not be prohibited or entirely eliminated. If volumes of imports continue to increase, the RFS volumes should also grow. The purpose and intent of the RFS program is to enhance energy security and promote the growth in domestic renewable biofuels. President Trump promised rural America his Administration would support the RFS and this notice and t…

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Sep 11, 2017· Comment submitted by John Heisdorffer, Soybean Farmer, American Soybean Association (ASA)· EPA-HQ-OAR-2017-0091-3432

Filed on regulations.gov — full text not in the inline record.

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Sep 6, 2017· Comment submitted by Ron Moore, President, American Soybean Association (ASA)· EPA-HQ-OAR-2017-0091-1775

Filed on regulations.gov — full text not in the inline record.

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Aug 21, 2017· Mass comment campaign sponsored by American Soybean Association (web)· EPA-HQ-OAR-2017-0091-0252

On behalf of the American Soybean Association, I appreciate this opportunity to comment on the proposal for the Renewable Fuel Standard (RFS) Program: Standards for 2018 and Biomass-Based Diesel Volume for 2019. Soybean farmers nationwide urge EPA to increase the volumes for biomass-based diesel to at least 2.75 billion gallons for 2019 and to increase total Advanced Biofuels volumes to 5.25 billion gallons in 2018. Soybean farmers are proud of the leading role we have played in establishing and developing the biodiesel industry. From the first investments made by the soybean industry, biodiesel has grown into a domestic market approaching 3 billion gallons. While biodiesel is now made from a diverse and growing volume of feedstocks, soybean oil remains the largest source of biodiesel feedstock. Biodiesel has expanded markets for farmers and livestock producers and created new jobs and economic growth, particularly in rural America. Biodiesel also provides additional economic, energy, and environmental benefits, such as increasing volumes of domestically produced, renewable energy while providing significant reductions in greenhouse gas emissions resulting in improved air quality. The biodiesel industry has provided these benefits without any significant disruption or adverse impacts to consumers. Our industry has always advocated for RFS volumes that are modest and achievable and we have met or exceeded the targets each and every year that the program has been in place. EPA expresses an expectation and concern over decreasing growth in biodiesel feedstocks yet, as USDA data demonstrates, soybean production has been increasing significantly and acreage is increasing again in 2017. Per acre yields are trending upwards and the supply and ending stocks of soybean oil have been steady or increasing. The U.S. soybean harvest last year was a record 4.3 billion bushels-380 million bushels larger than the previous year. Those additional bushels represent an extra half a billion gallons of vegetable oil that the global market has had to absorb resulting in lower prices for agricultural producers and lower profit potential. The U.S. biodiesel industry is operating well under capacity and has significant room for growth above the volumes proposed by EPA for 2019. As EPA correctly recognizes and states in the proposal, the planted crops that supply vegetable oil for biodiesel are grown in response to protein meal demand for livestock feed and the oil is a co-product. Biodiesel production creates a value-added market for the co-product soybean oil generated by the growing global demand for protein meal. We have met the increased demand for soybean protein meal and done so with increasing efficiency and sustainability. Since 1980 U.S. farmers have increased production by 96% while using 8% less energy; land use per ton of soybean production has decreased by 35%; and greenhouse gas emissions have decreased by 41% per ton. EPA's concern for the potential for feedstock switching if RFS volumes are increased is unwarranted. Demand from biodiesel markets and the RFS have not caused the switching of soybean oil from food use. In fact, soybean oil has been displaced from food markets and the biodiesel market has provided soybean farmers with a valuable replacement for that lost market. Soybean oil has been displaced from domestic food markets as a result of the FDA determination requiring the elimination of all partially hydrogenated oil, which creates trans-fat. Since the trans-fat labeling requirements were announced in 2003, approximately four billion pounds of annual soy oil use has been displaced from the food market. The market outlet that biodiesel provides for soybean oil also benefits livestock production by improving the margins for soybean processing and lowering the cost of soy meal used for livestock feed. A 2015 analysis showed that biodiesel resulted in lower feed costs for U.S. livestock producers that ranged f…

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Abstract

EPA is proposing applicable percentage standards for the four categories of renewable fuel in the Renewable Fuel Standard (cellulosic biofuel, biomass-based diesel, advanced biofuel, and total renewable fuel) for 2018. EPA is also proposing the biomass-based diesel volume for 2019.

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Co-filers (162)

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