BIO Sends Letter to EPA Administrator Gina McCarthy RE: RFS Petition Process Input
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On March 31, 2014, the Biotechnology Industry Organization (“BIO”) sends letter to the U.S. Environmental Protection Agency’s (“EPA”) expressing concerns with the Agency's decision to halt its petition process for new renewable fuel pathways.</p>
Subject: “Petition Process Input”
Dear Administrator McCarthy:
The Biotechnology Industry Organization (“BIO”) has significant concerns with the U.S. Environmental Protection Agency’s (“EPA”) decision to halt its petition process for new renewable fuel pathways (“the petition process”) for approximately six months while making improvements to the overall system1. While EPA’s efforts to improve the petition process for new renewable fuel pathways under the Renewable Fuel Standard (RFS) is welcomed, the Agency should aim to complete this review process in a timelier and less disruptive manner.
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, industrial and environmental biotechnology products.
Representing nearly 90 companies leading the development of new technologies for producing conventional and advanced biofuels through the application of industrial biotechnology, BIO is concerned its members will be adversely affected by EPA’s delay in evaluating new renewable fuel pathways under the RFS. This delay will add to the uncertainty for the advanced biofuels industry created by EPA’s Proposed Rule on the 2014 Standards for the Renewable Fuel Standard (RFS) Program2 (“the proposed rule”) and the renewable volume obligations (RVO) for biofuels in 2014. Combined with the proposed rule the proposed delay of the petition process may further undermine the development of advanced and cellulosic biofuels just as they are set to produce millions of commercial gallons and launch a rapid scale up. Even more damaging, this delay may create more confusion and uncertainty for biofuel producers and their investors as to whether their processes will be approved and whether there will be a market for advanced and cellulosic biofuels in the near future.
In the past four years, EPA has completed only 42 percent of the petitions it has received for new renewable fuel pathways under the RFS. On average, all biofuel companies have had to wait an average of 17 months for approval of new pathways under the RFS; while companies filing cellulosic biofuel pathway petitions have faced the longest wait times – on average 24 months. Currently, more than 36 petitions are still awaiting action – either approval or denial – and the average time that all pending petitioning companies have waited currently exceeds 19 months. These delays have slowed deployment of new advanced biofuel technologies.
An added six-month delay to the petition process – even if it results in a speedier process for the future – risks jeopardizing the availability of cellulosic and advanced biofuels to meet future year RFS obligations. EPA runs the risk of creating a self-fulfilling prophecy in setting the annual obligations below achievable volumes, while continuing to keep some volumes from reaching the market.
Visit the link below to read the letter in its entirety.
