Re: Docket ID No. EPA‐HQ‐OAR‐2012‐0632

The EESI advises the EPA against waiving the Renewable Fuel Standard (RFS) despite 2012 extreme weather, arguing that the RFS is not the cause of the economic harm to livestock and poultry producers. The document asserts that market forces and existing RFS flexibility are already reducing corn demand, and that a waiver would create policy uncertainty, deterring the estimated $168 billion in investment needed for advanced biorefineries by 2022. EESI maintains that the long-term benefits of the RFS—including reduced oil imports, lower greenhouse gas emissions, and rural economic growth—outweigh the potential short-term gains of a waiver.

• The 2012 drought and heat wave, likely intensified by climate change, were the primary causes of harm to livestock and poultry industries, not the Renewable Fuel Standard (RFS).
• The corn ethanol industry is already responding to market conditions by reducing production and stocks without a waiver; corn ethanol production fell nearly 15% between early June and early October 2012.
• Existing RFS flexibility allows refiners to use approximately 2.5 billion gallons of surplus blending credits from previous years, which could reduce corn demand by over 850 million bushels.
• A waiver may not significantly lower corn prices because refiners lack the short-term flexibility to change fuel formulas and have little incentive to reduce ethanol demand while ethanol futures (~$2.40/gallon) remain much cheaper than gasoline futures (~$3.30/gallon).
• Waiving the RFS would create policy uncertainty that could deter the investment of tens of billions of dollars required to build over 500 new biorefineries, estimated to cost up to $168 billion to meet 2022 goals.
• Continued RFS implementation provides several national benefits, including displacing about 10% of the gasoline supply with biofuels to reduce oil import dependence and lowering life cycle greenhouse gas emissions.

APA

Environmental and Energy Study Institute (2012). Re: Docket ID No. EPA‐HQ‐OAR‐2012‐0632. https://www.eesi.org/files/101212_EESI_Comments_to_EPA.pdf

Chicago

Environmental and Energy Study Institute. Re: Docket ID No. EPA‐HQ‐OAR‐2012‐0632. 2012. https://www.eesi.org/files/101212_EESI_Comments_to_EPA.pdf.

Wikipedia

{{cite press release |author=Environmental and Energy Study Institute |title=Re: Docket ID No. EPA‐HQ‐OAR‐2012‐0632 |date=10 October 2012 |url=https://www.eesi.org/files/101212_EESI_Comments_to_EPA.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{environmentalandenergystudyinstitute2012docket, author = {{Environmental and Energy Study Institute}}, title = {{Re: Docket ID No. EPA‐HQ‐OAR‐2012‐0632}}, publisher = {Environmental and Energy Study Institute}, year = {2012}, month = oct, url = {https://www.eesi.org/files/101212_EESI_Comments_to_EPA.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }