27 Jun '14, 4pm

#Fact filled response to the CBO #RFS study via @EthanolRFA #DefendRFS

#Fact filled response to the CBO #RFS study via @EthanolRFA #DefendRFS

Most important, CBO improperly assumes EPA will require waivered cellulosic biofuel volumes to be entirely offset by other advanced biofuels. EPA has the statutory authority to waive the advanced biofuel standard and total RFS by the same, or lesser, amount as the waiver of the cellulosic biofuel standard. Thus, for example, if only 300 mg of cellulosic biofuel are available in 2017, EPA could (and likely would) reduce the cellulosic biofuel standard from 5.5 bg to 300 mg, reduce the advanced biofuel standard from 9.0 bg to 3.8 bg, and reduce the total RFS from 24 bg to 18.8 bg. Biodiesel and renewable diesel could very likely account for most of the 3.8 bg advanced biofuel requirement, while primarily ethanol would be used to fulfill the statutory 15.0 bg requirement for renewable fuel. In this example, which entirely comports with EPA’s statutory authority, required rene...

Full article: http://www.ethanolrfa.org/exchange/entry/response-to-cbo-...

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