EESI_Comments to EPA on 2013-2016 RFS

EESI urges the EPA to reject proposed reductions to the 2014-2016 Renewable Fuel Standard (RFS) volumes, arguing that such cuts stifle investment in advanced and cellulosic biofuels. The document contends that the 'blend wall'—the limit of E10 ethanol in the fuel supply—is a result of oil industry restrictions rather than a lack of fuel supply. EESI proposes several solutions, including holding oil refineries accountable for infrastructure, approving mid-level ethanol blends (E25-E40) to reduce greenhouse gases and toxic aromatics, and restoring credits for FlexFuel Vehicles (FFVs). It further argues that the EPA's MOVES 2014 emissions model is flawed and that the agency should use the Clean Air Act to regulate toxic gasoline aromatics (BTEX) by promoting ethanol as a cleaner octane booster.

• The RFS has historically contributed to energy security, rural economic growth, and the reduction of greenhouse gases; specifically, between 2005 and 2012, ethanol's share of gasoline supplies increased from 1 to 10 percent, creating 100,000 direct jobs.
• Proposed reductions to RFS volumes create a 'chilling effect' on the biofuels industry, with the Biotechnology Industry Organization (BIO) reporting a loss of $13.7 billion in investments, primarily in advanced fuels, following the 2013 proposed reductions.
• The 'blend wall' is not caused by a lack of fuel supply but by infrastructure constraints and restrictive contracts from the 'Big Five' oil companies (Shell, BP, Chevron, ExxonMobil, and ConocoPhillips) that discourage gas stations from offering blends higher than E10.
• Mid-level ethanol blends (E25 to E40) could increase fuel efficiency, lower greenhouse gas emissions, and reduce the use of toxic gasoline aromatics by 60 percent compared to E10 blends.
• The EPA's MOVES 2014 model is criticized for using 'match blending' instead of 'splash blending,' which EESI claims mischaracterizes ethanol emissions as being worse for ozone than gasoline.
• EESI advocates for the use of Section 202 of the Clean Air Act to regulate toxic gasoline aromatics (BTEX), such as benzene, toluene, ethylbenzene, and xylene, by replacing them with biofuels as a cleaner octane-boosting alternative.

APA

Environmental and Energy Study Institute (n.d.). EESI_Comments to EPA on 2013-2016 RFS. https://www.eesi.org/files/EESI_Comments_to_EPA_on_2013-2016_RFS.pdf

Chicago

Environmental and Energy Study Institute. EESI_Comments to EPA on 2013-2016 RFS. n.d. https://www.eesi.org/files/EESI_Comments_to_EPA_on_2013-2016_RFS.pdf.

Wikipedia

{{cite press release |author=Environmental and Energy Study Institute |title=EESI_Comments to EPA on 2013-2016 RFS |url=https://www.eesi.org/files/EESI_Comments_to_EPA_on_2013-2016_RFS.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{environmentalandenergystudyinstitutendeesicomments, author = {{Environmental and Energy Study Institute}}, title = {{EESI\_Comments to EPA on 2013-2016 RFS}}, publisher = {Environmental and Energy Study Institute}, url = {https://www.eesi.org/files/EESI_Comments_to_EPA_on_2013-2016_RFS.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }