MN Biofuels Testimony on EPA's Supplemental Proposal

  • Wednesday, 30 October 2019 09:43

The Minnesota Bio-Fuels Association (MN Biofuels) joined many other members of the ethanol industry in Ypsilanti, Michigan today to testify at the EPA's public hearing over its proposed supplemental notice for SRE reallocations. Below is MN Biofuels executive director, Tim Rudnicki's, full prepared testimony:

Good morning.

I’m Timothy Rudnicki, the executive director for the Minnesota Bio-Fuels Association.

The black letter law of the Renewable Fuel Standard.  The clear, unequivocal statements of Congressional intent.  These are the legal and policy elements that have, thus far, guided the ethanol industry and its agricultural partners.

More broadly, the RFS has been the roadmap and compass used to navigate us, as a Nation, toward cleaner, renewable transportation fuel.

It seems, however, over the last couple of years the EPA has undermined the RFS.  The EPA has lost both the necessary compass and map as evidenced by:

The abuse of the small refinery exemption waivers, the loss of 4.6 billion gallons of renewable biofuel, the 2018 blend rate that plunged to 10.07 percent, the sham of a supplemental proposal.

Not only has the EPA lost its navigation instrument, but it’s driving renewable biofuels backwards and toward the cliff.

The damage done by the EPA is very real in Minnesota.  One producer has already shutdown operations - it went over the cliff.

Other producers are scaling back production and approaching the cliff.  And still others are hemorrhaging millions of dollars each month.  Under the current scenario, it’s only a matter of time before more producers shut down operations and also go over the proverbial cliff.

We will submit detailed written comments to the EPA.  So here I offer three high level suggestions for how we can push away from the cliff and more fully actualize the Renewable Fuel Standard.

First, EPA should get back to basics by complying with the law.  The RFS is amply clear that by now at least 26 billion gallons of renewable biofuel should be in the transportation fuel.  Interestingly, just as the EPA is gutting the RFS, some Minnesota ethanol producers are unleashing cellulosic ethanol production.  Once EPA fixes the RIN pathway, there can be a significant increase in cellulosic renewable biofuel gallons.

Second, now that E15 can be sold throughout the year, EPA should move rapidly to streamline the process for making it the new regular fuel across the Nation.  EPA should mirror the approach it used to move the Nation from leaded to unleaded fuel.  Doing the math with 2018 EIA data, at least 20 billion gallons of renewable biofuel will be needed.   With some reasonable ramp up time, the biofuel industry can meet the demand.

Third, EPA should work in tandem with the United States Dept of Agriculture to replicate the successful Biofuel Infrastructure Partnership Program.  BIP can help locally owned and independently operated retail fuel stations make changes so they can offer E15 and higher blends.  Given the success we have had with the first round of BIP funding in Minnesota, we have a model that can be expanded in Minnesota and replicated in other States.  We welcome the opportunity to work with EPA and USDA to actualize a robust BIP.

In closing, to navigate to a better place, to undo the damage done by EPA, EPA must take bold, decisive and rapid action to comply with both the letter and spirit of the RFS.  Such actions will help The ethanol producers I represent, with operations in multiple states and a combined production capacity of 890 million gallons.

The estimated 14,000 farm operations that supply nearly 300  million bushels of corn.

And all of us, as a Nation, because greater amounts of clean, renewable biofuels will reduce greenhouse gas emissions and boost the economy.

Thank you.