Algae Biomass Organization calls EPA’s RFS proposal a “first step toward restoring the investment climate for advanced biofuels,” but says distribution must not be limited by administrative barriers, obligated party intransigence

August 2, 2015 |

In Washington, the Algae Biomass Organization added its voice to comments on the EPA’s Renewable Fuel Standard proposal for 2014-2016. We highlighted commentary from other parties here. Matt Carr, executive director of the Algae Biomass Organization, writes:

EPA’s proposed RVOs for 2014-2016 represent a significant improvement over the prior notice of proposed rule-making released in November 2013. EPA’s November 2013 proposal to dramatically lower advanced biofuel volumes, combined with the Agency’s inability to set standards in a timely fashion, ongoing delays in approving new fuel pathways and arbitrary restrictions on biofuels not completely produced within a single location, have crippled investment in advanced biofuels over the past 18 months. Once finalized, the 2014-2016 RVOs will provide a first step toward restoring the investment climate for advanced biofuels and providing market confidence for algae-based and other advanced biofuels in the years to come.

To achieve the full energy security, economic development and greenhouse gas potential of advanced biofuels, however, EPA must do everything in its power to minimize uncertainty for advanced biofuel developers and leave no doubt in its final rule and in future year rules that advanced biofuel developers will have a market for their fuel. This requires setting volumes that reflect Congressional intent and take the advanced biofuels industry beyond today’s real and perceived market constraints.

It also requires removing administrative barriers to deployment, including delays in new pathway approval and unnecessary limitations on feedstocks and co-location of facilities.

Specifically, EPA must reiterate in its final rule the Agency’s commitment to interpreting the term “algae” broadly in the context of the RFS. We concur with EPA’s assertion that a broad interpretation of “algae” furthers the purposes of the authorizing statute and urge EPA to include as renewable biomass – in addition to all micro-algae and macro-algae – any autotrophic microorganism used to create a renewable fuel from the biological capture and utilization of carbon in waste gases that have already served a different primary purpose.

Carbon capture and utilization is recognized implicitly in the RFS through the inclusion of algae as renewable biomass. EPA in previous rule-making correctly included cyanobacteria (blue-green algae). Scientific consistency and the statutory goals of the RFS call for inclusion of other autotrophic microorganisms that perform the same set of biochemical transformations. Arbitrary exclusion of such microorganisms would be inconsistent with basic principles of microbiology and biotechnology, previous EPA interpretations, and the expressed intent of the Energy Independence and Security Act of 2007 (EISA).

By converting industrial sources of CO2 to advanced biofuels, algae and similar carbon-converting organisms offer an unprecedented opportunity to transform CO2 emissions from environmental challenge to economic opportunity. It’s time that federal policy fully embraced this opportunity. ABO also urges EPA to further accelerate approval of new fuel pathways to eliminate the backlog of pending pathway approvals, and to initiate immediately a rule making process for co-location and intermediate feedstocks that maximizes the opportunity for advanced biofuel developers to deploy the broadest possible set of feedstocks and conversion technologies.

Finally, we urge EPA not to allow distribution limitations imposed by obligated parties to constrain RVOs for any renewable fuel. To spur investment in commercialization of algae-based fuels, developers must have confidence in their ability to access markets under the RFS. Limiting fuel obligations based on distribution constraints within the control of obligated parties – including the so-called “blend wall” puts this market certainty at risk. EPA should set annual RVOs, as required by statute, based on production.

The Proposed Rule offers an important first step toward restoring the investment climate for algae-based and other advanced biofuels. Additional actions outlined in these comments would provide important additional market confidence for algae-based fuel developers. We ask that you provide full consideration to these recommendations.

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