Both the National Corn Growers Association and Growth Energy this week submitted comments to the Environmental Protection Agency's June request for input on technical amendments to the Renewable Fuels Standard regarding Renewable Identification Numbers, advanced biofuels pathways and cellulosic volumes.
Specifically, EPA is proposing to allow renewable diesel produced from landfill biogas to generate advanced biofuel Renewable Identification Numbers. The rule also proposes to clarify the definition of crop residue to include corn kernel fiber.
The rule also offers several other changes, including proposing a new approach to determining how many cellulosic RINs are produced from the varying cellulosic feedstocks and suggests technical corrections to E15 misfueling mitigation regulations.
NCGA President Pam Johnson said her organization supported generation of D3 or D7 RINS from specific cellulosic feedstock sources, and that all biomass feedstock sources be renewable.
Johnson also suggested that the definition of crop residue should not be modified, however corn kernel fiber should be included as a residue. Additionally, NCGA supports butanol's potential inclusion as a new pathway for advanced RINs.
Similarly, Growth Energy supported the pathway for cellulosic biofuel from corn kernel fiber, as well as additional crop residues.
"We believe that any renewable biomass meeting the 60 percent greenhouse gas threshold should be able to generate cellulosic RINs," explained Growth Energy CEO Tom Buis.
Meanwhile, amid concerns that the quantity of ethanol produced in the U.S. is exceeding the amount that can be blended into fuels, the American Petroleum Institute Monday announced the launch of a new campaign aimed at ending the RFS, called "Fuel for Thought."
The campaign involves TV, radio and print ads on what API says are dangers of the RFS.
"These ads will encourage more Americans to tell the White House to fix the problem before it's too late, while urging Congress to completely repeal the RFS," said API Downstream Group Director Bob Greco.
But both the NCGA and Growth Energy supported the RFS in comments to the EPA, with Growth Energy noting that, "the RFS has been the law of the land since 2007; the petroleum and other industries have had ample time to plan and adjust their business accordingly to accept higher ethanol blends."
The EPA has set a target of producing 36 billion gallons of renewable fuel by 2022.