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BIO Comments on RFS Standards for 2020 and Biomass-Based Diesel Volumes for 2021, Response to the Remand of the 2016 Standards

The Biotechnology Innovation Organization (BIO) is pleased to provide comment on the U.S. Environmental Protection Agency’s (EPA’s) proposed rule on the Renewable Fuel Standard Program: Standards for 2020 and Biomass-Based Diesel Volume for 2021, Response to the Remand of the 2016 Standards, and Other Changes (proposed rule).

BIO is the world's largest trade association representing biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of innovative healthcare, agricultural, and industrial and environmental biotechnology products. In the energy space, BIO represents more than 70 companies leading the development of new technologies for producing conventional and advanced biofuels. Through the application of industrial biotechnology, BIO members are improving conventional biofuel processes, furthering advanced and cellulosic biofuel production technologies, and speeding development of new energy crops.

The Renewable Fuel Standard (RFS) has been a vital tool to BIO’s member companies who are leading the development of advanced and cellulosic biofuels. As a market driver providing access to the transportation fuel market, the RFS has spurred research and investment in the development of low-carbon biofuels. The RFS has enabled the United States to become a leader in the development and deployment of new technologies which has led to the growth of the biobased economy, benefitting farmers and commodity producers, helping revitalize rural economies, creating good paying jobs, and fostering energy independence.

Unfortunately, EPA’s administration of the program has put the investments made by these companies at risk and threatens to prevent growth in advanced and cellulosic biofuels as the RFS intended. EPA’s expansion of granting small refinery exemptions (SRE) retroactively after setting the annual percentage standard ensures that the proposed annual volume obligations will not be met with liquid biofuels, contrary to the statute and congressional intent.

BIO Comments on RFS Standards for 2020 and Biomass-Based Diesel Volumes for 2021