Earlier this week, Illinois Corn Growers Association joined several other state corn associations and National Corn Growers Association in submitting comments to the U.S. EPA on their RFS2 “Guidance Document.”The cooperative effort is an excellent example of the incredible work that can be done in an organization such as ours, partnering with our sister-states and national organization. The Guidance Document hoped to provide direction for the automobile and renewable fuels industries and a vision for renewable fuel sources in our country’s future.
These comments, which were submitted in response to EPA's Draft Guidance for E85 Flexible Fuel Vehicle Weighting Factors, expressed concern that the Agency's proposal does not adequately incentivize the automobile manufacturers to continue building FFVs after the 2016 model year.
To read the full comments as submitted, please click here.
Sadly, the Guidance didn’t echo the commitment to corn-based ethanol that we saw in 2005 when the Renewable Fuel Standard was first passed by Congress. Nor did the Guidance reflect the intent of our elected officials during the update to the RFS (RFS2) in 2007.
“In March of this year, a Guidance letter was released by the EPA. While preliminary discussions indicated that the automobile manufactures would see attractive incentives to continue building FFVs, this was not the case. Increasing the use of E85 and the availability of FFVs should be concurrent goals for the EPA as both are integral to the implementation of the RFS. Instead, the proposed weighting factor sets them at odds with each other. This is disappointing and surprising given that one policy was put into place in 2007 and five years later a complete change in focus was mandated,” the corn industry stated in their comments.
What the Guidance does is send a signal to automakers that the future of renewable energy is in natural gas and electric vehicles. Automakers will be provided incentives to build cars running on both, with diminishing incentives for FFVs utilizing higher blends of ethanol. This is surprising, given that infrastructure for the sale of natural gas and electricity to power vehicles doesn’t yet exist, nor is providing electric and natural gas powered vehicles cost-effective for consumers.
According to the comments submitted, “It is counter to the intent of the RFS2 to diminish the supply of FFVs by providing insufficient incentives, phasing out FFV credits and shifting all credits and incentives to electric vehicle technology.We believe the FFV production incentives should be restored to insure at least 50 percent production volumes of FFVs from all manufacturers through the entire term of the RFS.”
Illinois Corn Growers Association continues to monitor these sorts of rulemaking and regulatory concerns on behalf of Illinois farmers. When opportunities arise to participate in rulemaking and be a part of a commonsense solution to benefit American consumers AND farmers, Illinois Corn is your voice in Washington, DC.