Minneapolis, Feb 10 - The Minnesota Bio-Fuels Association (MN Bio-Fuels) submitted today its comments to the U.S. Environmental Protection Agency (EPA) on the latter’s proposed renewable volume obligation (RVO) targets for 2023, 2024 and 2025.

In December 2022, the EPA announced an RVO target of 15 billion gallons of conventional ethanol for 2023 and 15.25 billion gallons for both 2024 and 2025. In addition, it proposed a supplemental volume of 250 million gallons to be added to the 2023 RVO.

In comments to the EPA, MN Bio-Fuels executive director Brian Werner said that the proposed rule establishes a firm foundation for the future and creates a pathway for sustainable growth in the production and use of low-carbon ethanol.

To build on that foundation, in the letter, MN Bio-Fuels encouraged the EPA to take several actions when finalizing the proposal including:

• Setting the implied conventional renewable fuel volumes at the aforementioned targets, which would send a strong signal that there will be a buyer for D6 volumes produced for the next three compliance years. 
• Continuing the implementation of the 2023 supplemented volume of 250 million gallons would finally bring the EPA into full compliance with the DC Circuit Court of Appeals’ remand of the 2016 RVO rule in Americans for Clean Energy vs EPA.
• Increase D3 cellulosic biofuel volumes by up to 250 million gallons a year from 2023 to 2025 “so that cellulosic biofuels made from corn kernel fiber are given the opportunity to advance in the marketplace.
• Remaining consistent with the holdings of the Tenth Circuite Court's decision in Renewable Fuels Association vs EPA in denying small refinery waivers during the three compliance years. 

Finally, Werner said, "...biofuels can do even more to help increase energy security and reduce costs for consumers while providing environmental benefits."

In the letter, MN Bio-Fuels encouraged the EPA to implement the outstanding regulatory action to remove the 1-PSI volatility waiver for gasoline-ethanol blends in Midwest states so that E15 (Unleaded 88) can be sold in the summer of 2023 and adopt the US Department of Energy's Argonne GREET model for lifecycle assessments.

Read MN Bio-Fuels’ full comments to the EPA here.