National Corn Growers Association filed 4 comments on this docket between Sep 6, 2017 and Jan 19, 2018. 162 other organizations filed here. The comment window closed 3204d ago.
Filed on regulations.gov — full text not in the inline record.
Filed on regulations.gov — full text not in the inline record.
Please find below and attached the comments of the Kansas Corn Growers Association, and also, for reference, the comments of the National Corn Growers Association. October 19, 2017 Administrator Scott Pruitt Environmental Protection Agency 1200 Pennsylvania Ave. NW Washington, DC 20460 Docket ID No. EPA-HQ-OAR-2017-0091 Dear Administrator Pruitt: The Kansas Corn Growers Association (KCGA) would like to voice its opposition to further reductions in Renewable Fuel Standard (RFS) volumes the Environmental Protection Agency (EPA) contemplates in the October 4, 2017 Notice of Data Availability (NODA). While EPA proposed no direct changes to the implied 15-billion-gallon volume requirement for conventional ethanol, a key market for corn, we understand that EPA is considering volume reductions for 2018 and 2019 volume reductions. These reductions would be inconsistent with the intent of the RFS statute. As we stated in our comments on Aug. 31, we are concerned about EPA's proposed annual standards rule that reduces cellulosic, advanced and total volumes below 2017 levels relying on new methodology to expand EPA's cellulosic waiver authority. The additional volume reductions summarized in the NODA are not justified and undermine the intent of the Renewable Fuels Standard. Additionally, we join the National Corn Growers Association in imploring EPA to not change the treatment of RINs on biofuel exports, a proposal raised in comments to the volume rule. Exports of corn in all forms especially ethanol exports, truly are a bright spot in a time of low commodity prices. USDA recently reported that U.S. ethanol exports are surging with 1.37 billion gallons (488 million bushels in corn equivalent) exported, which is a 34 percent increase over last year. A change in the treatment of RINS on biofuel exports would result in new barriers to our growing ethanol exports and damaging trade retaliation, significantly harming our growing ethanol exports. KCGA strongly urges EPA to follow the law and reverse course on the proposals considered in the NODA. Please refer to the detailed comments submitted by NCGA (attached) which have our full support. Sincerely, Greg Krissek, CEO
Comments submitted by the National Corn Growers Association are in the attached file.
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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