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Good morning, my name is Glenn Johnston. I am here to testify on behalf of the Advanced Biofuels Association (ABFA). ABFA represents a diverse set of companies engaged in producing and distributing Biodiesel, Renewable Diesel, Renewable Gasoline, and Renewable Aviation fuel. Currently, ABFA represents over 4 billion gallons of production a year of advanced biofuels. ABFA and its members appreciate the opportunity to share today our brief reactions to the proposal and to elaborate further in our written comments which will be submitted to the docket in February 2023.
First, our Association supports a program and an industry that can and will be rewarded for the fuels they actually produce. To that end in our written comments, we will be including a study conducted by Lipow and Associates of the actual renewable diesel production expected to come online by 2025. In addition, we will submit a study we commissioned by LMC that demonstrates, after accounting for fuel and feed usage, the available fats, oils, greases and tallows, expected to be available for the production of advanced biofuels. These two scientific data sets will provide a substantive fact basis from which to make final decisions on the volumes of fuel for both Advanced and Biomass Based Diesel pools. The proposed flat lining of volumes significantly underestimates and undercuts the basic intent of the program.
ABFA members agree with the Agency’s stated focus of the program — shifting emphasis to reducing carbon. In that regard we strongly support EPA’s interest and solicitation of comments that support recognition for rewarding advanced fuels that exceed the minimum GHG reduction requirements with a higher RIN value. A majority of our members also support continued updates to GHG models (such as GREET) to allow for scientific, up to the date, carbon reduction accounting.
Finally, we thank the Agency for its work in the area of adopting regulatory provisions that allow for the use of Bio-intermediate feedstocks. This is a key component to support the development and commercialization of advanced technologies, new feedstock utilization and addressing climate change. That stated, the current bio intermediate regulations remain overly and unnecessarily restrictive, severely limiting the true potential of advanced and cellulosic feedstock and fuels. One key impediment remains, the restriction of intercompany transfers and limitations of allowances for multiple company engagement.
We appreciate the work the Agency has conducted to issue the SET proposal and look forward to working with the Agency to make the final rule more reflective of the reality of the advanced fuels market.
Thank you for your time this morning and would be happy to answer any questions.
Glenn Johnston
Chairman, ABFA Regulatory Affairs Committee
