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Goffman, Joseph[Goffman.Joseph@epa.gov]
Jack Gerard, API
Tue 5/20/2014 1:27:43 PM
Fix the RFS

May 20, 2014

Dear Joseph,
Although the deadline for this year's biofuels mandate was November 2013, the Environmental
Protection Agency (EPA) is still finalizing the 2014 Renewable Fuel Standard (RFS)
requirements, which will determine how much ethanol the fuel industry will be required to blend
into the nation's fuel supply this year. True to form, regulators have proposed a mandate for 17
million gallons of cellulosic biofuel, despite the fact that less than 60,000 gallons have been
produced to date this year.
Whether corn-based or cellulosic, the EPA must establish these mandates in a more timely
fashion and align biofuel targets more closely with reality. It's essential that EPA limit the
ethanol mandate to no more than
of gasoline in the 2014 renewable fuel
requirements to
to protect consumers against consequences
associated with exceeding the 10 percent "blend wall" - including:
Engine damage: The overwhelming majority of vehicles on the road today are not
manufacturer-approved to use fuel blends above 1O percent (E10), and ovTonc"""'
that EPA-approved E15 fuel can lead to engine damage.

Unavailability of EO: Owners of

vintage cars and
like lawnmowers
demand low- or zero-ethanol fuel, but the constantly increasing requirements of the RFS
threaten to drive ethanol-free options off the market entirely.
Economic harm: According to a
continuing to implement
the RFS could lead to fuel rationing and supply shortages that could drive up gasoline costs by
30 percent and the cost of diesel by 300 percent by 2015 - decreasing worker income by $580
billion.
Food prices: Ethanol production has already diverted more than 40 percent of the U.S. corn
crop from food to fuel, leading to a 25 percent increase in the consumer price index for food
since 2005. Anti-hunger groups like
warn the corn ethanol mandate is "contributing

CREW FOIA 2014-006851-0001980

~===='-'-"'~=-'==~'-'=~==~== as well as an=~=-"-""-"'=~=""'is urging action to fix the RFS. The EPA must set reasonable targets to protect
consumers from the damages of the blend wall.

~~~"-'-''

Sincerely,
Jack N. Gerard
President & CEO
API

Up a Creek

Boat owners and manufacturers are among the many

Americans negatively impacted by the RFS.
about the effects of higher ethanol blends on
boats.

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Jack Gerard, API

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CREW FOIA 2014-006851-0001982