Today morning, Minnesota Bio-Fuels Association's executive director, Tim Rudnicki, testified during a virtual hearing on the EPA's proposed RVOs for 2020, 2021 and 2022. Read his prepared testimony below:

Good morning.  My name is Timothy J. Rudnicki.  I represent the Minnesota Bio-Fuels Association, a trade organization for ethanol producers in Minnesota. 

In Minnesota, the annual total ethanol production has once again exceeded 1 billion gallons.  Our ethanol is a greenhouse gas emission cutting tool because our producers reuse water, operate innovative production technology, including combined heat and power systems, and explore ways to further reduce GHG emissions in the supply chain.

These and other production factors make renewable ethanol an important tool in the efforts to cut transportation sector GHG emissions.  The EPA acknowledges this point in the Federal Register at page 72441. 

We recognize the EPA is requesting comment on several critical provisions of the proposed rule.  To keep my comments here short, we will submit written comments addressing specific issues with the proposed rule.  With that, I will briefly speak to what appears to be a fundamental EPA assumption about the lack of effectiveness of the RFS and the RVOs.

At the outset, we commend the EPA for taking some steps to get the RFS back on track.  Yet, perhaps, a fundamental assumption about the inability of the Renewable Fuel Standard to increase the use of higher ethanol blends may be holding the EPA back on the RVO track.

The EPA, at Federal Register page 72447, talks about the limited success the RFS has and will have in growing the use of ethanol beyond E10 even with various incentive programs.  

From our vantage point in Minnesota, the RFS has actually helped to grow the use of ethanol well beyond the mythical E10 blendwall.

In Minnesota, the greater the RVO numbers, the greater the incentive for the fuel supply chain to use higher blends of renewable ethanol.  In Minnesota, the combination of state and federal programs and private investments help fuel retailers transition to offering E15 as evidenced by the 408 fuel retailers that now offer E15.  In Minnesota, based on the last data sets from the Energy Information Administration, at least 12.6% of the liquid fuel for internal combustion engines was renewable ethanol.

So, from our vantage point, the RFS is helping to grow the use of renewable fuel.  The RFS is boosting the economy in Minnesota while helping to make us more energy independent.  And the RFS is helping to cut GHG emissions.  We need the EPA to stand strong and set forth aggressive RVOs to keep the focus on reducing the use of fossil fuels and using biofuels to cut transportation sector GHG emissions.