The Environmental Protection Agency (EPA) is seeking comments from stakeholders on the EPA’s proposed Renewable Fuel Standards for 2013. The proposed final standards would require the blending of more domestic corn ethanol in 2013 than was anticipated by the original 2007 statute and more imported sugar ethanol from Brazil. Does that make sense at this time? Comments are due by April 7.

As reported previously in SBFF , on January 31, the EPA proposed volumetric standards for 2013 for "Advanced Biofuels," "Cellulosic Biofuels," and "Total Renewable Fuels" as defined in the Energy Independence and Security Act of 2007 . The proposed 2013 overall volumes and standards are:
 

  • Biomass-based Diesel - 1.28 billion gallons (1.12 percent) (1.92 billion ethanol equivalent gallons)
  • Advanced Biofuel - 2.75 billion ethanol equivalent gallons (1.60 percent)
  • Cellulosic Biofuels - 14 million ethanol equivalent gallons (0.008 percent)
  • Total Renewable Fuels - 16.55 billion ethanol equivalent gallons (9.63 percent)


To see the EPA’s proposed rule and explanation of the EPA’s underlying assumptions, click here .

The EPA has already finalized the standard for Biomass-based Diesel for 2013 at 1.28 billion gallons. Biomass-based Diesel is defined in the 2007 statute as a type of Advanced Biofuel. This volume counts as 1.92 billion ethanol equivalent gallons toward fulfilling the 2.75 billion gallon 2013 Advanced Biofuel volume requirement.

In the final rule that the EPA is now proposing for 2013, the EPA estimates that the nascent cellulosic biofuels industry will be able to produce only about 14 million gallons of Cellulosic Biofuel in 2013, substantially less than the 1.0 billion gallons anticipated for 2013 in the 2007 statute.

Further, the EPA estimates that other domestic Advanced Biofuel producers will only be able to provide about 150 million gallons to help meet the Advanced Biofuel quota. Adding this to the 1.92 ethanol equivalent gallons of Biomass-based Diesel, this will leave a gap of more than 600 million gallons to fill in the Advanced Biofuel category.

However, the EPA’s proposal for 2013 does not reduce the Total Renewable Fuels volume to account for the reduced volume of Cellulosic Biofuels or for the gap in domestically produced Advanced Biofuels. Instead, the EPA proposes to continue to meet the standard for Total Renewable Fuels as set in the 2007 statute (16.55 billion gallons) and require that the difference be made up by blending increased amounts of domestic corn ethanol and imported sugar ethanol from Brazil. This would require significantly more corn be used in 2013 than was anticipated in the original 2007 statute and would depend on Brazil significantly increasing its sugar ethanol exports to the U.S.

Under the original 2007 statute, fuel blenders would have been expected to blend about 12.8 billion gallons of corn ethanol in 2013, up from 12.7 billion gallons in 2012. However, with the delayed start-up of the cellulosic fuel industry, the EPA reduced the standard for Cellulosic Fuels in 2012, but did not reduce the standard for Total Renewable Fuels for 2012. The result was to require blenders to use about 13.2 billion gallons of corn ethanol in 2012. Now, under the EPA’s 2013 proposal, that level would be raised again, with the expectation that blenders would blend about 13.8 billion gallons of corn ethanol into the nation’s gasoline supply.

The EPA counts sugar ethanol from Brazil as an Advanced Biofuel. After accounting for Biomass-based Diesel and the anticipated production and blending of additional small quantities of other Advanced Biofuel in 2013, the EPA estimates that about 666 million gallons of sugar ethanol will need to be imported to meet the 2.75 billion gallon volume requirement for Advanced Biofuel. In 2012, the U.S. imported about 422 million gallons of sugar ethanol from Brazil.

The question is whether this additional volumetric demand for more corn and sugar ethanol is feasible, appropriate, and environmentally sustainable given the current challenges facing the biofuels industries both in the U.S. and Brazil.

The EPA is seeking comments from stakeholders on these issues by April 7. Direct your comments to Docket ID No. EPA-HQ-OAR-2012-0546 at www.regulations.gov .