EMA Testifies Before EPA On Proposed Ethanol Blending Mandates For 2020, 2021, 2022
Last week, EMA President Rob Underwood provided comments during an EPA public hearing regarding the proposed ethanol blending mandates for 2020-2022.
Rob urged the EPA to fully consider the impact the RFS places on small business energy marketers when setting the upcoming annual RVOs for 2020, 2021 and 2022.
“If ethanol volumes continue to rise as proposed in 2022, obligated parties will be forced to manufacture E15 blends to meet their annual RVOs. E15 blends made from corn ethanol are not compatible with most existing underground storage tank systems in operation today.
“Look no further than EPA’s document from January 2020 entitled E15’s Compatibility with UST Systems which states, “Most older and even some newer existing UST systems (which includes but is not limited to tanks, pumps, ancillary equipment, lines, gaskets, and sealants) are not fully compatible with E15 and require modification before storing E15.
“For example, the actual tank is often compatible with E15, but some of the connectors and pump components may not be. That can lead to leaks. Dispensers are not part of the UST system, by definition, but face the same compatibility concerns and are a critical part of the fueling system for our constituents.”
The EPA issued proposed RFS annual blending mandates last month that significantly lowered renewable fuel (ethanol) volumes for 2021 (13.3 billion), and in an unprecedented move, the agency retroactively reduced the 2020 renewable fuel (ethanol) blending mandate previously set at 15 billion gallons to 12.5 billion gallons.
According to the EPA, the retroactive reduction is due to lower demand for transportation fuels during the COVID-19 pandemic.
The EPA already set the 2021 biomass-based diesel (biodiesel) blending mandate at 2.43 billion gallons in a previous rulemaking. The EPA delayed decisions on 2021 blending obligations by more than a year and recently missed the November 30th deadline to finalize 2022 blending mandates.
EMA has for many years called for lower annual corn ethanol blending volumes that would allow marketers to determine for themselves whether to sell E15 rather than be required to do so through a de facto mandate.
EMA sent multiple letters to the EPA and the National Economic Council this year requesting urgent action to reduce the corn ethanol mandate to address the current E15 crisis.
EMA fully believes in renewable fuels and their importance in the liquid fuels market and plans to ask the Biden Administration to ensure that future federal grant funds be available for small business energy marketers to upgrade their underground storage tank system equipment to safely and legally sell E10 plus blends.