The National Corn Growers Association, in conjunction with the Illinois Corn Growers Association and the Minnesota Corn Growers Association, has filed comments with the Environmental Protection Agency and the National Highway Traffic Safety Administration outlining several concerns with the proposed Corporate Average Fuel Economy standards.
“We are concerned that the proposed CAFE/GHG rule is inconsistent with the RFS2 regulation and the EISA requirement to use 36 billion gallons of renewable fuel in 2022 in several areas,” the letter stated. “In other regulatory actions, EPA continues to express support for achieving the requirements of RFS2, yet there is no mention in the CAFE/GHG rule concerning the role of renewable alternative fuels in achieving the required GHG reductions.”
Commending the agencies on the joint effort to improve fuel economy and greenhouse gas emissions at a national level, NCGA urges the agencies to address the concerns outlined through a concerted dialogue prior to finalizing the rule.
Specifically, the comments recommend modifying three areas in order to achieve a more balanced, technology-neutral approach to controlling greenhouse gas emissions while improving fuel economy.
First, the comments recommend allowing vehicle and fuel technologies to compete on a level playing field when trying to meet the goals outlined in the standards. As currently written, the rule would favor electric vehicle technology over renewable fuels.
Next, the comments recommend that the rule be rewritten to integrate the revised Renewable Fuel Standard (RFS2) promulgated by the EPA in response to the Energy Independence and Security Act (EISA) of 2007, which was written to simultaneously address both national energy security as well as greenhouse gas emissions concerns.
Finally, the comments suggest that the proposed rule should be amended to provide incentives for the production of flex fuel vehicles that are needed to consume the target amounts of renewable fuels outlined in the RFS2. To ensure that the new rule is consistent with the intent of the EISA, continuation of incentives to produce vehicles designed for high-blend biofuel consumption is necessary at the current time.