ACE & other corn, biofuels groups sign EPA letter on commercial-ready cellulosic biofuel
Posted on 02/19/2018
Representatives of the cellulosic biofuels industry asked the U.S. EPA to take a renewed look at commercial-ready cellulosic biofuels, including cellulosic ethanol made from corn kernel fiber, as the agency begins its work to develop proposed 2019 Renewable Fuel Standard renewable volume obligations (RVOs), in a Feb. 15 letterthat the American Coalition for Ethanol (ACE) and 19 other trade groups sent to EPA Administrator Scott Pruitt.
The letter stresses that cellulosic ethanol made from corn kernel fiber warrants EPA’s closer attention. EPA stated in 2017 that its review of cellulosic biofuel production data showed that “facilities that convert corn kernel fiber to cellulosic ethanol at existing ethanol production facilities have generally over performed relative to our estimates.”
"Unleashing corn kernel fiber ethanol production will bring significant and immediate economic, environmental and energy security benefits.” Existing ethanol plants could produce hundreds of millions of gallons of cellulosic ethanol from this single stream of agricultural residue in the near term.
While the outlook for corn kernel fiber ethanol is strong, EPA set low volumetric projections for the biofuel in the proposed 2018 RVOs and reduced targets for corn kernel fiber ethanol in the final rule. “The overly conservative corn kernel fiber ethanol projection, compounded with uncertainty around how quickly EPA will approve new corn kernel fiber ethanol technologies for D3 RIN generation, threatens to slow adoption of cellulosic production capacity at existing ethanol facilities across the country.”
ACE and other signatories of the letter are concerned the new methodology used by the EPA to forecast cellulosic biofuel production in 2018 will continue to result in inappropriately low production projections for certain commercially ready technologies if used again for the 2019 RVO. Specifically, the methodology relies too heavily on historic trends that do not accurately reflect recent advancements achieved by the corn kernel fiber cellulosic ethanol sector. We encourage EPA to return to a more forward-looking methodology that better accounts for technological readiness and forecasts the projected volume of cellulosic production expected during the compliance year.
We also ask EPA to address facets of the program that create unnecessary market uncertainty. Specifically, for EPA to move quickly to answer key questions pertaining to corn kernel fiber D3 eligibility. The unconditional availability of cellulosic waiver credits (CWCs) continues to undercut demand for liquid cellulosic biofuel gallons and indicates they have suggestions for improving CWW management.
In addition to ACE, the letter is signed by BIO, ABBC, NFU, National Corn Growers Association, Growth Energy, Renewable Fuels Association, Association of Equipment Manufacturers, National Corn-to-Ethanol Research Center, Iowa Renewable Fuels Association, Renewable Fuels Nebraska, Michigan Bio, Illinois Bio, IowaBio, Bio Nebraska, South Dakota BIO, BioKansas, Nebraska Corn Growers, Iowa Corn Growers, and Michigan Corn.
A full copy of the letter is available from the ABBC website.